Annova Final EIS

20190419-3027 FERC PDF (Unofficial) 04/19/2019
Federal Energy Regulatory Commission

Office of Energy Projects
Washington, DC 20426
ANNOVA LNG BROWNSVILLE PROJECT

Final Environmental Impact Statement
Volume I
Annova LNG Common Infrastructure, LLC Docket No. CP16-480-000

Annova LNG Brownsville A, LLC FERC\EIS: 0291F
Annova LNG Brownsville B, LLC April 2019
Annova LNG Brownsville C, LLC
Cooperating Agencies:
U.S. Army Corps

of Engineers U.S. Environmental U.S. Fish and U.S. Coast Guard
National Wildlife Service
Protection Agency
Park Service
U.S. Department U.S. Department of National Oceanic and Federal Aviation

of Energy Transportation, Pipeline and Atmospheric Administration - Administration
Hazardous Materials Safety National Marine Fisheries Service
Administration
FEDERAL ENERGY REGULATORY COMMISSION

WASHINGTON, D.C. 20426
OFFICE OF ENERGY PROJECTS

In Reply Refer To:
OEP/DG2E/Gas Branch 3
Annova LNG Common Infrastructure, LLC
Annova LNG Brownsville A, LLC
Annova LNG Brownsville B, LLC
Annova LNG Brownsville Project
Docket No. CP16-480-000
TO THE INTERESTED PARTY:
The staff of the Federal Energy Regulatory Commission (FERC or Commission) has
prepared a final environmental impact statement (EIS) for the Annova LNG Brownsville
Project (referred to as the Annova LNG Project, or Project). Annova LNG Common
Infrastructure, LLC; Annova LNG Brownsville A, LLC; Annova LNG Brownsville B, LLC;
and Annova LNG Brownsville C, LLC (collectively Annova), request authorization to site,
construct, and operate a liquefied natural gas (LNG) export facility in Cameron County,
Texas. The Project would include a new LNG export terminal capable of producing up to
6.95 million metric tons per year of LNG for export. The LNG terminal would receive
natural gas to the export facilities from a third-party intrastate pipeline.
The final EIS assesses the potential environmental effects of the construction and
operation of the Project in accordance with the requirements of the National Environmental
Policy Act (NEPA). The FERC staff concludes that approval of the Project would result
in adverse environmental impacts. With the mitigation measures recommended in the EIS
and Annova’s proposed mitigation measures, most impacts in the Project area would be
avoided or minimized and would not be significant. However, we have determined that
the Project would have significant construction noise impacts during the six months of
nighttime pile-driving. In addition, the Annova LNG Project combined with other projects
within the geographic scope, including the Texas LNG and Rio Grande LNG Projects,
would contribute to potential significant cumulative impacts from construction noise
during nighttime pile-driving, sediment/turbidity and shoreline erosion within the
Brownsville Ship Channel during operations from vessel transits; on the federally listed
ocelot and jaguarundi from habitat loss in combination with past actions and potential for
increased vehicular strikes during construction; on the federally listed aplomado falcon
from habitat loss in combination with past actions; and on visual resources from the
presence of aboveground structures. Construction and operation of the Project would result
in mostly temporary or short-term environmental impacts; however, some long-term and
permanent environmental impacts would occur.
-2-
The U.S. Army Corps of Engineers; U.S. Coast Guard; U.S. Department of
Transportation; U.S. Environmental Protection Agency; U.S. Fish and Wildlife Service;
National Parks Service; the National Oceanic and Atmospheric Administration, National
Marine Fisheries Service; Federal Aviation Administration; and U.S. Department of
Energy participated as cooperating agencies in the preparation of the EIS. Cooperating
agencies have jurisdiction by law or special expertise with respect to resources potentially
affected by the proposal and participate in the NEPA analysis.
The final EIS addresses the potential environmental effects of the construction and
operation of the following Project facilities:
 pipeline meter station;

 natural gas pretreatment and liquefaction facilities;
 two LNG storage tanks;
 marine and LNG transfer facilities;
 control room, administration/maintenance building;
 site access road; and
 utilities (power, water, and communication systems).
The Commission mailed a copy of the Notice of Availability of the final EIS to
federal, state, and local government representatives and agencies; elected officials;
environmental and public interest groups; Indian Tribes; potentially affected landowners
and other interested individuals and groups; and newspapers and libraries in the area of the
Annova LNG Project. The final EIS is only available in electronic format. It may be
viewed and downloaded from the FERC’s website (www.ferc.gov), on the Environmental
Documents page (https://www.ferc.gov/industries/gas/enviro/eis.asp). In addition, the
final EIS may be accessed by using the eLibrary link on the FERC’s website. Click on the
eLibrary link (https://www.ferc.gov/docs-filing/elibrary.asp), click on General Search, and
enter the docket number in the “Docket Number” field, excluding the last three digits (i.e.,
CP16-480). Be sure you have selected an appropriate date range. For assistance, please
contact FERC Online Support at FercOnlineSupport@ferc.gov or toll free at (866) 208-
3676, or for TTY, contact (202) 502-8659.
Additional information about the Project is available from the Commission’s Office
of External Affairs, at (866) 208-FERC, or on the FERC website (www.ferc.gov) using
the eLibrary link. The eLibrary link also provides access to the texts of all formal
documents issued by the Commission, such as orders, notices, and rulemakings.
In addition, the Commission offers a free service called eSubscription that allows
you to keep track of all formal issuances and submittals in specific dockets. This can
reduce the amount of time you spend researching proceedings by automatically providing
you with notification of these filings, document summaries, and direct links to the
documents. Go to www.ferc.gov/docs-filing/esubscription.asp.
TABLE OF CONTENTS

Page
TABLE OF CONTENTS ............................................................................................................................I
LIST OF TABLES .................................................................................................................................... VI
LIST OF FIGURES .................................................................................................................................. IX
LIST OF APPENDICES ........................................................................................................................... X
1.0 INTRODUCTION....................................................................................................................... 1-1
PROJECT PURPOSE ...................................................................................................... 1-3
AGENCY PURPOSE AND SCOPE OF THE EIS ......................................................... 1-4
Federal Energy Regulatory Commission Purpose and Role............................ 1-4
U.S. Army Corps of Engineers Purpose and Role ........................................... 1-5
U.S. Coast Guard Purpose and Role ................................................................ 1-5
U.S. Department of Transportation Purpose and Role .................................... 1-6
U.S. Environmental Protection Agency Purpose and Role ............................. 1-7
U.S. Fish and Wildlife Service Purpose and Role ........................................... 1-7
National Parks Service Purpose and Role ....................................................... 1-8
National Oceanic and Atmospheric Administration, National Marine
Fisheries Service Purpose and Role................................................................. 1-8
Federal Aviation Administration Purpose and Role ........................................ 1-9
U.S. Department of Energy Purpose and Role ................................................ 1-9
PUBLIC REVIEW AND COMMENT .......................................................................... 1-10
Pre-Filing Process and Scoping ..................................................................... 1-10
Public Review of Draft and Final EIS ........................................................... 1-14
NON-JURISDICTIONAL FACILITIES ....................................................................... 1-15
Natural Gas Supply Lateral ........................................................................... 1-15
Natural Gas Interconnection Facilities .......................................................... 1-15
Electric Transmission Line and Switchyard .................................................. 1-17
Potable Water Pipeline .................................................................................. 1-18
PERMITS, APPROVALS, AND REGULATORY REVIEWS .................................... 1-21
2.0 DESCRIPTION OF PROPOSED ACTION............................................................................. 2-1
PROPOSED FACILITIES ............................................................................................... 2-1
Gas Pretreatment Facilities .............................................................................. 2-1
Liquefaction Facilities ..................................................................................... 2-1
LNG Storage Tanks ......................................................................................... 2-2
Boil-Off Gas Handling System........................................................................ 2-3
Flare System .................................................................................................... 2-3
Marine Facilities .............................................................................................. 2-4
Control, Administrative, and Support Buildings ............................................. 2-5
Access Road .................................................................................................... 2-5
Fencing and Barrier Wall ................................................................................ 2-7
i Table of Contents
Utilities ............................................................................................................ 2-8

LNG CARRIERS ............................................................................................................. 2-8
LAND REQUIREMENTS............................................................................................... 2-9
CONSTRUCTION SCHEDULE AND WORKFORCE ................................................. 2-9
ENVIRONMENTAL COMPLIANCE AND MONITORING ...................................... 2-10
CONSTRUCTION PROCEDURES .............................................................................. 2-12
Land-based Facilities ..................................................................................... 2-13
Marine Facilities ............................................................................................ 2-16
Water Supply and Demand ............................................................................ 2-18
Stormwater Management ............................................................................... 2-18
Solid and Hazardous Waste Management ..................................................... 2-19
OPERATION AND MAINTENANCE PROCEDURES .............................................. 2-19
LNG Marine Traffic Along the Waterway .................................................... 2-19
LNG Terminal Facilities................................................................................ 2-23
Water Supply and Demand ............................................................................ 2-23
Sanitary Waste ............................................................................................... 2-23
Ballast Water and Cooling Water .................................................................. 2-24
SAFETY AND SECURITY PROCEDURES ............................................................... 2-24
Spill Containment .......................................................................................... 2-25
Thermal Exclusion and Vapor Dispersion Zones .......................................... 2-25
LNG Carrier Safety and Facility Security ..................................................... 2-25
Hazard Detection System .............................................................................. 2-26
Fire Protection System................................................................................... 2-26
FUTURE PLANS AND ABANDONMENT ................................................................ 2-26
3.0 ALTERNATIVES ....................................................................................................................... 3-1
INTRODUCTION ........................................................................................................... 3-1
NO-ACTION ALTERNATIVE....................................................................................... 3-3
SYSTEM ALTERNATIVES ........................................................................................... 3-3
3.3.1 Currently Authorized LNG Export Facilities in Texas.................................... 3-6
3.3.2 Proposed and Planned LNG Export Projects in Texas .................................... 3-7
3.3.3 Conclusion on System Alternatives ............................................................... 3-11
ALTERNATIVE SITES ................................................................................................ 3-11
3.4.1 Proposed Site ................................................................................................. 3-14
3.4.2 Northside Site 3 ............................................................................................. 3-14
3.4.3 Northside Site 4 ............................................................................................. 3-15
3.4.4 Northside Site 5 ............................................................................................. 3-15
3.4.5 Southside Site 1 ............................................................................................. 3-15
3.4.6 South Bay Site ............................................................................................... 3-16
3.4.7 Conclusion on Alternative Sites .................................................................... 3-16
ACCESS ROAD ALTERNATIVES ............................................................................. 3-17
PROCESS AND DESIGN ALTERNATIVES .............................................................. 3-19
3.6.1 On-site Power Plant versus Grid-Supplied Power ......................................... 3-19
3.6.2 Carbon Capture .............................................................................................. 3-21
3.6.3 Gas-Fired Compressors versus Electric Compressors ................................... 3-21
3.6.4 Flare Design................................................................................................... 3-22
DREDGED MATERIAL PLACEMENT AREA ALTERNATIVES ........................... 3-23
3.7.1 Proposed Dredged Material Placement Area................................................. 3-23
Table of Contents ii
3.7.2 DMPA 4A and DMPA 4B ............................................................................. 3-24

3.7.3 DMPA 5B ...................................................................................................... 3-24
3.7.4 Dredged Material Placement Area Conclusions ............................................ 3-24
CONCLUSION .............................................................................................................. 3-24
4.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES ................ 4-1
4.1 GEOLOGIC RESOURCES ............................................................................................. 4-1
4.1.1 Geologic Setting .............................................................................................. 4-1
4.1.2 Mineral Resources ........................................................................................... 4-2
4.1.3 Blasting ............................................................................................................ 4-3
4.1.4 Paleontological Resources ............................................................................... 4-3
4.1.5 General Impacts and Mitigation ...................................................................... 4-3
4.1.6 Conclusion ....................................................................................................... 4-3
4.2 SOILS .............................................................................................................................. 4-4
4.2.1 Existing Soil Resources ................................................................................... 4-4
4.2.2 Contaminated Soils .......................................................................................... 4-6
4.2.3 General Impacts and Mitigation ...................................................................... 4-7
4.2.4 Conclusion ....................................................................................................... 4-9
4.3 WATER RESOURCES ................................................................................................. 4-10
4.3.1 Groundwater .................................................................................................. 4-10
4.3.2 Surface Water ................................................................................................ 4-12
4.4 WETLANDS ................................................................................................................. 4-30
4.4.1 Existing Wetland Resources .......................................................................... 4-30
4.4.2 Wetland Impacts and Mitigation ................................................................... 4-31
4.4.3 Conclusion ..................................................................................................... 4-33
4.5 VEGETATION .............................................................................................................. 4-35
4.5.1 Existing Vegetation Communities ................................................................. 4-35
4.5.2 Vegetation Impacts and Mitigation ............................................................... 4-38
4.5.3 Exotic or Invasive Plants and Noxious Weeds .............................................. 4-39
4.5.4 Vegetation Communities of Special Concern................................................ 4-39
4.5.5 Conclusion ..................................................................................................... 4-40
4.6 WILDLIFE AND AQUATIC RESOURCES ................................................................ 4-41
4.6.1 Terrestrial Wildlife ........................................................................................ 4-41
4.6.2 Marine Resources .......................................................................................... 4-52
4.7 SPECIAL STATUS SPECIES....................................................................................... 4-65
4.7.1 Federally Listed Threatened and Endangered Species .................................. 4-65
4.7.2 State-Listed Threatened and Endangered Species ......................................... 4-87
4.7.3 Conclusions and Recommendations .............................................................. 4-95
4.8 LAND USE, RECREATION, AND VISUAL RESOURCES ...................................... 4-96
4.8.1 Land Use........................................................................................................ 4-96
4.8.2 Landowner and Easement Requirements....................................................... 4-97
4.8.3 Existing and Planned Residences and Commercial Developments ............... 4-98
4.8.4 Recreation and Special Interest Areas ........................................................... 4-99
4.8.5 Visual Resources ......................................................................................... 4-109
4.8.6 Coastal Zone Management .......................................................................... 4-126
4.8.7 Conclusion ................................................................................................... 4-127
4.9 SOCIOECONOMICS .................................................................................................. 4-128
4.9.1 Population .................................................................................................... 4-128
iii Table of Contents

4.9.2 Economy and Employment ......................................................................... 4-129

4.9.3 Property Values ........................................................................................... 4-135
4.9.4 Construction Payroll and Material Purchases .............................................. 4-136
4.9.5 Tax Revenues .............................................................................................. 4-136
4.9.6 Housing........................................................................................................ 4-138
4.9.7 Removal of Agricultural, Pasture, or Timberland from Production ............ 4-139
4.9.8 Public Services ............................................................................................ 4-140
4.9.9 Environmental Justice.................................................................................. 4-143
4.9.10 Transportation and Traffic ........................................................................... 4-147
4.9.11 Conclusion ................................................................................................... 4-159
4.10 CULTURAL RESOURCES ........................................................................................ 4-160
4.10.1 Cultural Resource Survey ............................................................................ 4-160
4.10.2 Unanticipated Discovery Plan ..................................................................... 4-166
4.10.3 Native American Consultation .................................................................... 4-166
4.10.4 Impacts and Mitigation ................................................................................ 4-166
4.10.5 Conclusions and Recommendation ............................................................. 4-167
4.11 AIR QUALITY AND NOISE ..................................................................................... 4-168
4.11.1 Air Quality ................................................................................................... 4-168
4.11.2 Noise ............................................................................................................ 4-190
4.12 RELIABILITY AND SAFETY ................................................................................... 4-205
LNG Facility Reliability, Safety, and Security Regulatory Oversight ........ 4-205
DOT Siting Requirements and 49 CFR 193 Subpart B Determination ....... 4-206
Coast Guard Safety Regulatory Requirements and Letter of
Recommendation ......................................................................................... 4-209
LNG Facility Security Regulatory Requirements........................................ 4-218
FERC Engineering and Technical Review of the Preliminary
Engineering Designs .................................................................................... 4-220
Recommendations from FERC Preliminary Engineering and
Technical Review ........................................................................................ 4-261
Conclusions on LNG Facility and Marine Vessel Reliability and
Safety ........................................................................................................... 4-277
4.13 CUMULATIVE IMPACTS ......................................................................................... 4-279
4.13.1 Temporal and Geographic Distribution (Geographic Scope) ...................... 4-279
4.13.2 Projects and Activities Considered .............................................................. 4-281
4.13.3 Potential Cumulative Impacts by Resource ................................................. 4-290
5.0 CONCLUSIONS AND RECOMMENDATIONS .................................................................... 5-1
5.1 SUMMARY OF THE ENVIRONMENTAL ANALYSIS .............................................. 5-1
5.1.1 Geologic Resources ......................................................................................... 5-1
5.1.2 Soils ................................................................................................................. 5-1
5.1.3 Water Resources .............................................................................................. 5-2
5.1.4 Wetlands .......................................................................................................... 5-3
5.1.5 Vegetation........................................................................................................ 5-4
5.1.6 Wildlife and Aquatic Resources ...................................................................... 5-4
5.1.7 Special Status Species ..................................................................................... 5-6
5.1.8 Land Use, Recreation, and Visual Resources .................................................. 5-7
5.1.9 Socioeconomics ............................................................................................... 5-8
5.1.10 Cultural Resources........................................................................................... 5-9
5.1.11 Air Quality and Noise .................................................................................... 5-10
5.1.12 Reliability and Safety .................................................................................... 5-11
Table of Contents iv
5.1.13 Cumulative Impacts ....................................................................................... 5-12

5.1.14 Alternatives.................................................................................................... 5-15
5.2 FERC STAFF’S RECOMMENDED MITIGATION .................................................... 5-16
v Table of Contents
LIST OF TABLES
Number Title Page
Table 1.3-1 Issues Identified and Comments Received During the Scoping Process for
the Annova LNG Project...................................................................................... 1-12
Table 1.5-1 Environmental Permits and Agency Reviews for the Annova LNG
Brownsville Project .............................................................................................. 1-21
Table 2.3-1 Land Requirements for the Annova LNG Brownsville Project ............................. 2-9
Table 2.5-1 Summary of Annova’s Requested Changes to FERC’s Plan and Procedures ..... 2-10
Table 2.6.1-1 Estimated Pilings Required for LNG Storage Tanks and Liquefaction
Process Facilities .................................................................................................. 2-14
Table 2.6.2-1 Summary of Excavated and Dredged Material .................................................... 2-17
Table 2.6.2-2 Pilings Required for the Marine Facilities ........................................................... 2-17
Table 2.6.3-1 Water Supply and Demand Requirements During Construction ......................... 2-18
Table 2.7.3-1 Estimated Water Use During Project Operation .................................................. 2-23
Table 3.3-1 Existing, Proposed, and Planned LNG Export Projects Along the Texas
Gulf Coast .............................................................................................................. 3-6
Table 3.4-1 Comparison of the Proposed and Alternative Sites.............................................. 3-14
Table 3.5-1 Comparison of Access Road Alternatives............................................................ 3-17
Table 3.6.1-1 Potential Emissions Associated with On-Site Generation Alternative vs
Proposed Grid-Sourced Electricity ...................................................................... 3-20
Table 3.6.3-1 Comparison of Compressor Technology Emissions ............................................ 3-22
Table 3.6.4-1 Comparison of Proposed Flare Stack and Ground Flare Design Alternatives ..... 3-23
Table 4.2.1-1 Project Site Soil Characteristics ............................................................................. 4-4
Table 4.3.2-1 Surface Waterbodies in the Vicinity of the Proposed Project Site ....................... 4-16
Table 4.3.2-2 Average Physiochemical Parameters in the Brownsville Ship Channel .............. 4-17
Table 4.3.2-3 Estimates of LNG Carrier Cooling Water Use and Intake Rates at the LNG
Terminal ............................................................................................................... 4-26
Table 4.4.2-1 Impacts to Wetlands from Project Construction and Operation .......................... 4-31
Table 4.5.2-1 Vegetation Communities Affected by Construction and Operation of the
Project .................................................................................................................. 4-38
Table 4.6.2-1 Gulf of Mexico Marine Mammal Summary with Likelihood of Occurrence
in Brownsville Ship Channel ............................................................................... 4-52
Table 4.6.2-2 Common Fish and Invertebrate Species within the Project Area......................... 4-55
Table 4.7.1-1 Federally Listed and Candidate Species Known to Occur or Potentially
Occurring in Cameron County, Texas ................................................................. 4-66
Table 4.7.2-1 State-Protected Species and Habitat Potentially Occurring Within the
Project Area.......................................................................................................... 4-87
Table 4.8.1-1 Land Cover Types Affected by Construction and Operation ............................... 4-97
Table 4.9.1-1 Population by County and State ......................................................................... 4-128
Table 4.9.2-1 Economic Characteristics, 2014 ......................................................................... 4-130
Table 4.9.2-2 Estimated One-Time Economic Impacts of Project Construction ..................... 4-131
Table of Contents vi
Table 4.9.2-3 Estimated Annual Economic Impacts of Project Operation............................... 4-131

Table 4.9.2-4 Tourism-Related Economic Impacts by County and State ................................ 4-133
Table 4.9.5-1 Revenues and Expenditures in Cameron County for FY 2015 .......................... 4-137
Table 4.9.5-2 Estimated Annual State and Local Tax Revenues by Tax Type ........................ 4-138
Table 4.9.6-1 Housing .............................................................................................................. 4-138
Table 4.9.8-1 Public Safety Services: Fire Departments and Law Enforcement Agencies...... 4-140
Table 4.9.8-2 Public School Inventory in the Project Area ...................................................... 4-142
Table 4.9.9-1 Race and Ethnicity and Poverty by Geographic Area, 2014 .............................. 4-146
Table 4.9.10-1 Major Existing Roadways Near the Project Site ................................................ 4-148
Table 4.9.10-2 Measured and Calculated Overall Levels of Service at Intersections During
Construction and Operation ............................................................................... 4-151
Table 4.9.10-3 Potential Mitigation Measures for Construction-Related Traffic as
Identified in Annova’s Traffic Impact Analysis ................................................ 4-152
Table 4.9.10-4 Average Annual Commercial Vessel Calls at the Port of Brownsville, 2012
to 2014 ............................................................................................................... 4-156
Table 4.9.10-5 Average Annual Volume of Waterborne Cargo Transported via the Port of
Brownsville, by Direction of Vessel Movement, 2012 to 2014 ......................... 4-156
Table 4.9.10-6 Estimated Small Vessel Delay Times During LNG Carrier Transit .................. 4-159
Table 4.11.1-1 Ambient Air Quality Standards.......................................................................... 4-170
Table 4.11.1-2 Existing Ambient Air Concentrations for the Project Area ............................... 4-172
Table 4.11.1-3 Total Project Construction Emissions by Year .................................................. 4-180
Table 4.11.1-4 Estimated Annual Project Operating Emissions for Onshore Stationary
Sources ............................................................................................................... 4-185
Table 4.11.1-5 Estimated Annual Project Operating Emissions for Mobile Sources................. 4-186
Table 4.11.1-6 Estimated Maintenance, Startup, and Shutdown Emissions .............................. 4-187
Table 4.11.1-7 Stationary Source Ambient Impact Analysis Results ........................................ 4-188
Table 4.11.1-8 Stationary Source Ambient Impact Analysis Results with LNG Ship ............... 4-189
Table 4.11.1-9 Estimated Combined Construction, Commissioning, and Operational
Emissions of the Annova LNG Project .............................................................. 4-190
Table 4.11.2-1 Sound Levels and Relative Loudness................................................................. 4-191
Table 4.11.2-2 Existing Sound Levels ....................................................................................... 4-194
Table 4.11.2-3 Sound Levels of Common Construction Equipment.......................................... 4-195
Table 4.11.2-4 Predicted Changes to Sound Levels during Construction .................................. 4-196
Table 4.11.2-5 Unattenuated Underwater Sound Pressure Levels Measured for Pile
Driving at the Benicia-Martinez Bridge ............................................................. 4-199
Table 4.11.2-6 Major Operational Equipment and Estimated Sound Levels ............................. 4-200
Table 4.11.2-7 Predicted Changes to Sound Levels during Operation....................................... 4-200
Table 4.13.1-1 Geographic Scope by Resource for the Annova LNG Project ........................... 4-280
Table 4.13.3-1 Summary of Cumulative Impacts....................................................................... 4-291
Table 4.13.3-2 Estimated Construction Emissions for the Brownsville LNG Projects.............. 4-324
Table 4.13.3-3 Peak Concentrations Estimated in Cumulative Air Dispersion Modeling for
Stationary Source and LNG carriers for the Brownsville LNG Projects ........... 4-328
vii Table of Contents

Table 4.13.3-4 Standardized NSAs and Calculation Point Locations for Cumulative Noise
Analysis.............................................................................................................. 4-336
Table 4.13.3-5 Summary of Cumulative LNG Construction Impacts at Standardized NSA
and CP Locations, All Levels are dBA Ldn ........................................................ 4-336
Table 4.13.3-6 Calculation of the Incremental Impact of Cumulative LNG Construction
Noise at Standardized NSA and CP Locations, Measured as dBA Ldn .............. 4-338
Table 4.13.3-7 Cumulative Operational Noise Impacts from LNG Facilities ............................ 4-340
Table of Contents viii

LIST OF FIGURES
Number Title Page
Figure 1-1 Annova LNG Brownsville Project General Location ............................................ 1-2
Figure 1-2 General Site Plan for Proposed Facilities............................................................... 1-3
Figure 1.4.1-1 General Location of the Natural Gas Supply Lateral ........................................... 1-16
Figure 1.4.2-1 Location of Natural Gas Interconnection Facilities ............................................. 1-17
Figure 1.4.3-1 Potential Route for 138-kV Electric Transmission Line ...................................... 1-19
Figure 1.4.4-1 Potential Route for Potable Water Pipeline.......................................................... 1-20
Figure 2.1.3-1 Typical Single-Containment LNG Storage Tank ................................................... 2-3
Figure 2.1.8-1 Access Road Location ............................................................................................ 2-6
Figure 2.1.8-2 Typical Access Road Cross Section....................................................................... 2-7
Figure 2.7.1-1 Anticipated LNG Carrier Routes in the Gulf of Mexico...................................... 2-21
Figure 2.7.1-2 LNG Carrier Route within the Brownsville Ship Channel .................................. 2-22
Figure 3.3-1 Texas Gulf Coast LNG Export System Alternatives ............................................. 3-5
Figure 3.4-1 Proposed and Alternative LNG Terminal Sites ................................................... 3-13
Figure 3.5-1 Location of Proposed and Alternative Access Roads .......................................... 3-18
Figure 4.2.1-1 Soils Map of Project Site ....................................................................................... 4-5
Figure 4.3.2-1 South Laguna Subbasin ........................................................................................ 4-13
Figure 4.3.2-2 Surface Waterbodies in the Vicinity of the Proposed Project .............................. 4-15
Figure 4.3.2-3 Known Seagrass Beds within the Vicinity of the Proposed Project .................... 4-20
Figure 4.4.2-1 Wetlands Affected by Construction and Operation of the Project ....................... 4-32
Figure 4.8.3-1 Proposed SpaceX Launch Facilities ................................................................... 4-100
Figure 4.8.4-1 Recreational Resources ...................................................................................... 4-102
Figure 4.8.5-1 Key Observation Points ..................................................................................... 4-112
Figure 4.9.9-1 Environmental Justice Study Area ..................................................................... 4-145
Figure 4.9.10-1 Traffic Impact Study Intersections Map ............................................................ 4-150
Figure 4.9.10-2 Potential Truck Routes During Construction ..................................................... 4-155
Figure 4.11.2-1 Noise Sensitive Areas and Noise Monitoring Locations ................................... 4-193
Figure 4.11.2-2 Operational Steady-State Noise Contours .......................................................... 4-203
Figure 4.12-1 Accidental Hazard Zones along LNG Marine Vessel Route ............................. 4-216
Figure 4.12-2 Intentional Hazard Zones along LNG Marine Vessel Route ............................. 4-217
Figure 4.13.2-1 Projects Included in Cumulative Impact Analysis ............................................. 4-283
Figure 4.13.3-1 Cumulative Impact NSAs and Calculation Point Locations .............................. 4-335
ix Table of Contents
LIST OF APPENDICES
Appendix A Distribution List for the Notice of Availability

Appendix B Annova’s Plan and Procedures
Appendix C Dredged Material Transport Plan
Appendix D Migratory Birds in Cameron County
Appendix E Key Observation Point Visual Simulations
Appendix F Essential Fish Habitat Assessment
Appendix G Fugitive Dust Control Plan
Appendix H Projects Considered in Cumulative Impacts
Appendix I Cumulative Construction Noise Impact Assessment
Appendix J List of Preparers
Appendix K List of References
Appendix L Comments on the Draft EIS and Responses
Appendix M Index
Table of Contents x
TECHNICAL ACRONYMS AND ABBREVIATIONS
AADT average annual daily traffic

ACHP Advisory Council on Historic Preservation
ACT Antiquities Code of Texas
AEP American Electric Power Service Corporation
AERMOD American Meteorological Society/EPA Regulatory Model
AIChE American Institute of Chemical Engineers
Annova Plan Annova’s Upland Erosion Control, Revegetation, and Maintenance Plan
Annova Annova’s Wetland and Waterbody Construction and Mitigation
Procedures Procedures
Annova Annova LNG Common Infrastructure, LLC; Annova LNG Brownsville
A, LLC; Annova LNG Brownsville B, LLC; and Annova LNG
Brownsville C, LLC
Annova LNG Annova LNG Brownsville Project
Project
ANSI American National Standards Institute
APCI Air Products & Chemicals Incorporated
AQCR Air Quality Control Region
APE area of potential effect
API American Petroleum Institute
ASL above sea level
ASME American Society of Mechanical Engineers
AST Office of Commercial Space Transportation
BA biological assessment
B&A Blanton and Associates, Inc.
BACT Best Available Control Technology
Bcf billion cubic feet
Bcf/d billion cubic feet per day
BCR Bird Conservation Region
BGCC Bahia Grande Coastal Corridor
BGEPA Bald and Golden Eagle Protection Act
BIH Brazos Island Harbor
BLEVE boiling liquid expanding vapor explosion
BLM Bureau of Land Management
BMP best management practice
BND Brownsville Navigation District
BOG boil-off gas
BPVC Boiler and Pressure Vessel Code
BSC Brownsville Ship Channel
BU beneficial use
CAA Clean Air Act of 1970
CAAA Clean Air Act Amendments
CCPS Center for Chemical Process Safety
CEQ Council on Environmental Quality
CFR Code of Federal Regulations
xi Acronyms and Abbreviations

CH4 methane
CO carbon monoxide
CO2 carbon dioxide
CO2e carbon dioxide equivalent
Coast Guard U.S. Coast Guard
COE U.S. Army Corps of Engineers
COTP Captain of the Port
CP calculation point
CPT cone penetration test
CWA Clean Water Act
CZMA Coastal Zone Management Act of 1972
CZMP Coastal Zone Management Program
dB decibel
dBA A-weighted decibels
DCS distributed control system
DE Design Earthquake
DEIS draft Environmental Impact Statement
DHS Department of Homeland Security
DMPA Dredged Material Placement Area
DOD U.S. Department of Defense
DOE U.S. Department of Energy
DOE/FE U.S. Department of Energy, Office of Fossil Energy
DOT U.S. Department of Transportation
DPS distinct population segment
EA Environmental Assessment
ECOS Environmental Conservation Online System
EEZ Exclusive Economic Zone
EFH essential fish habitat
EI environmental inspector
EIS Environmental Impact Statement
EMST Ecological Mapping System of Texas
Eos Eos LNG, LLC
EPA U.S. Environmental Protection Agency
ERCOT Electric Reliability Council of Texas
ERP Emergency Response Plan
ESA Endangered Species Act of 1973
ESD emergency shutdown
FAA Federal Aviation Administration
FEED front-end engineering design
FEIS Final Environmental Impact Statement
FEMA Federal Emergency Management Administration
FERC or Federal Energy Regulatory Commission
Commission
FERC Plan FERC’s Upland Erosion Control, Revegetation, and Maintenance Plan
FERC Procedures FERC’s Wetland and Waterbody Construction and Mitigation Procedures
FHWA Federal Highway Administration
Acronyms and Abbreviations xii

FIS Flood Insurance Study

FLEX Freeport LNG Expansion, LP and FLNG Liquefaction, LLC
FLNG floating liquefied natural gas
FM Farm to Market Road
FR Federal Register
FSA Facility Security Assessment
FSP Facility Security Plan
FTA Free Trade Agreement
FWS U.S. Fish and Wildlife Service
FY fiscal year
g factor of gravity
g/bhp-hr gram per brake horsepower-hour
GE General Electric
GHG greenhouse gas
GMD geomagnetic disturbance
gpm gallons per minute
Gulf Coast LNG Gulf Coast LNG, LLC
H2S hydrogen sulfide
HAP hazardous air pollutant
HAZOP hazard and operability
HGB Houston-Galveston-Brazoria
HILFD Homeland Infrastructure Foundation Level Data
HMB heat and material balance
HUC Hydrologic Unit Code
Hz hertz
hp horsepower
IBC International Building Code
ICC International Code Council
IMO International Maritime Organization
IMR Inter-Mountain Region
ISA International Society for Automation
ISD Independent School District
kHz kilohertz
KOP key observation point
kPa kilopascals
kV kilovolt
L50 median sound pressure level
Ldn day-night average sound level
Leq equivalent continuous sound level
Lmax maximum sound level
lb pound
LNG liquefied natural gas
LOD Letter of Determination
LOI Letter of Intent
LOR Letter of Recommendation
LOS level of service
xiii Acronyms and Abbreviations

µPa micropascal
m3 cubic meter
MACT Maximum Achievable Control Technology
MBTA Migratory Bird Treaty Act
MEOW maximum envelope of water
mg/L milligram per liter
MLLW mean lower low water
MMBtu million British thermal units
MMBtu/hr million British thermal units per hour
MMPA Marine Mammals Protection Act
MOF material offloading facility
MOU Memorandum of Understanding
MOVES Motor Vehicle Emission Simulator
MPGF multipoint ground flare
m/s meter per second
MSA Magnuson-Stevens Fishery Conservation and Management Act of 1976
MSS maintenance, start-up, and shut-down (events)
mtpa million tonnes per annum
MTSA Maritime Transportation Security Act of 2002
MW megawatt
N2O nitrous oxide
NAAQS National Ambient Air Quality Standards
NAISA National Aquatic Invasive Species Act of 2003
NANPCA Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990
NAVD88 North American Vertical Datum of 1988
NBSIR National Bureau of Standards Information Report
NEHRP National Earthquake Hazards Reduction Program
NEPA National Environmental Policy Act of 1969
NESHAP National Emission Standards for Hazardous Air Pollutants
NFIA National Flood Insurance Act of 1968
NFIP National Flood Insurance Program
NFPA National Fire Protection Association
NGA Natural Gas Act
NHD National Hydrography Dataset
NHL National Historic Landmark
NHP National Historical Park
NHPA National Historic Preservation Act of 1966
NHTSA National Highway Traffic Safety Administration
NISA National Invasive Species Act
NLCD National Land Cover Database
nm nautical mile
NML noise monitoring location
NO2 nitrogen dioxide
NOx nitrogen oxides
NOAA National Oceanic and Atmospheric Administration
Acronyms and Abbreviations xiv

NOAA Fisheries National Oceanic and Atmospheric Administration National Marine

Fisheries Service
NOI for the Notice of Intent to Prepare an Environmental Impact Statement for the
Annova LNG Planned Annova LNG Brownville Project, Request for Comments on
Project Environmental Issues, and Notice of Public Scoping Meeting
NPDES National Pollutant Discharge Elimination System
NPS National Park Service
NRCS Natural Resources Conservation Service
NRHP National Register of Historic Places
NSA noise sensitive area
NSNSD Natural Sounds and Night Skies Division
NSPS New Source Performance Standards
NSR New Source Review
nT nano-Tesla
NWI National Wetlands Inventory
NWR National Wildlife Refuge
O2 oxygen
O3 ozone
OBE operating basis earthquake
OEP Office of Energy Projects
P&ID piping and instrumentation diagram
PEM palustrine emergent
PFD process flow diagram
PHMSA United States Department of Transportation’s Pipeline and Hazardous
Materials Safety Administration
PIR Potential Impact Radius
PJD Preliminary Jurisdictional Determination
PM2.5 particulate matter less than 2.5 microns in diameter
PM10 particulate matter less than 10 microns in diameter
ppm part per million
PRICO® Poly Refrigerant Integrated Cycle Operation
Project Annova LNG Brownsville Project
PSD Prevention of Significant Deterioration
PTE potential to emit
PUC Public Utility Commission
RCRA Resource Conservation and Recovery Act
re 1 µPa2/Hz in reference to 1 µPa squared per hertz
RG LNG Rio Grande LNG, LLC
RHA Rivers and Harbors Act
RMP Risk Management Plan
RMS root mean squared
RRC Railroad Commission of Texas
RV recreational vehicle
SAFE Port Act Security and Accountability For Every Port Act
SAL State Antiquities Landmark
SCPT seismic cone penetration test
xv Acronyms and Abbreviations

SGCN species of greatest conservation need

SH State Highway
SHPO State Historic Preservation Office
SIP State Implementation Plan
SLOSH Sea, Lake, and Overland Surge from Hurricanes
SO2 sulfur dioxide
SOC species of concern
SOI Secretary of Interior
SOLAS International Convention for the Safety of Life at Sea
SpaceX Space Exploration Technologies Corporation
SPL sound pressure level
SPCC Plan Spill Prevention, Control, and Countermeasure Plan
SSE safe shutdown earthquake
SSURGO Soil Survey Geographic
STEC South Texas Electric Cooperative
STSSN Sea Turtle Stranding and Salvage Network
SWEL stillwater elevation
SWPPP Stormwater Pollution Prevention Plan
TAC Texas Administrative Code
TAHC Texas Animal Health Commission
TCEQ Texas Council on Environmental Quality
TDS total dissolved solids
Texas LNG Texas LNG Brownsville LLC
TEGF totally enclosed ground flare
TGLO Texas General Land Office
THC Texas Historical Commission
TPWD Texas Parks and Wildlife Department
tpy ton per year
TSS total suspended solids
TWIC Transportation Worker Identification Credential
TxDOT Texas Department of Transportation
TXNDD Texas Natural Diversity Database
UDP Unanticipated Discovery Plan
U.S. United States
USC United States Code
USGCRP U.S. Global Change Research Program
USGS United States Geological Survey
VCP Valley Crossing Pipeline, LLC
VIA visual impact assessment
VLCC very large crude carrier
VOC volatile organic compound
VRM Visual Resource Management
WMA Wildlife Management Area
WSA Waterway Suitability Assessment
Acronyms and Abbreviations xvi

EXECUTIVE SUMMARY
The staff of the Federal Energy Regulatory Commission (FERC or Commission) prepared
this final Environmental Impact Statement (EIS) to assess the environmental issues associated with
the construction and operation of facilities proposed by Annova LNG Common Infrastructure,
LLC; Annova LNG Brownsville A, LLC; Annova LNG Brownsville B, LLC; and Annova LNG
Brownsville C, LLC, which are collectively referred to as Annova. The EIS was prepared in
accordance with the requirements of the National Environmental Policy Act of 1969 (NEPA) and
the Commission’s implementing regulations under Title 18 of the Code of Federal Regulations,
Part 380 (18 CFR 380). On July 13, 2016, Annova filed an application with the FERC in Docket
Number CP16-480-000 pursuant to Section 3(a) of the Natural Gas Act (NGA) and under Title 18
CFR, Part 153 of the Commission’s regulations to construct and operate liquefied natural gas
(LNG) export facilities. This project is referred to as the Annova LNG Brownsville Project
(Project) and consists of a new LNG export terminal with natural gas liquefaction facilities on the
west side of the Brownsville Ship Channel (BSC), near Brownsville, Cameron County, Texas.
The purpose of this EIS is to inform the FERC decision-makers, the public, and the
permitting agencies about the potential adverse and beneficial environmental impacts of the
proposed Project and its alternatives, and recommend mitigation measures that would reduce
adverse impacts to the extent practicable. We 1 prepared our initial analysis based on information
provided by Annova and further developed the analysis using information from data requests, field
investigations, scoping, literature research, and communications with federal, state, and local
agencies, Native American tribes, and individual members of the public.
The FERC is the federal agency responsible for authorizing onshore LNG facilities, and is
the lead federal agency for the preparation of this EIS in compliance with the requirements of
NEPA. The U.S. Army Corps of Engineers (COE); U.S. Coast Guard (Coast Guard); U.S.
Department of Energy (DOE); U.S. Environmental Protection Agency (EPA); U.S. Fish and
Wildlife Service (FWS); National Parks Service (NPS); the National Oceanic and Atmospheric
Administration, National Marine Fisheries Service (NOAA Fisheries, or NMFS); Federal Aviation
Administration (FAA); and the U.S. Department of Transportation (DOT) are cooperating
agencies for the development of this EIS consistent with 40 CFR 1501.6(b). A cooperating agency
has jurisdiction by law or has special expertise with respect to environmental resource issues
associated with the Project.
PROPOSED ACTION
The Project is designed to receive 0.9 billion cubic feet per day of feed gas via an intrastate
pipeline and would have an LNG export capacity of 6.95 million metric tons per year. 2 The LNG
would be pumped from the storage tanks to the marine transfer facilities where it would be loaded
for export onto up to 125 LNG carriers per year at the berthing dock using cryogenic piping.
Annova would construct the Project on a 731-acre property adjacent to the BSC on land
owned by the Brownsville Navigation District (BND). The property would be obtained through a
1
“We,” “us,” and “our” refer to the environmental and engineering staff of the FERC’s Office of Energy Projects.
2
The Project would receive natural gas supply from an as-yet undetermined third-party–owned and –operated
intrastate pipeline that would connect to the Valley Crossing Pipeline System.
ES-1 Executive Summary

long-term lease with the BND. The property, located at approximate mile marker 8.2 on the BSC,
has direct access to the Gulf of Mexico via the Brazos Santiago Pass. Annova anticipates a five-
year construction period if the Project is authorized. The facilities for the Project include the
following major components:
• gas pretreatment facilities;

• liquefaction facilities (six liquefaction trains and six approximately 72,000
horsepower [hp] electric motor-driven compressors);
• two LNG storage tanks;
• boil-off gas handling system;
• flare systems;
• marine facilities;
• control, administration, and support buildings;
• access road;
• fencing and barrier wall; and
• utilities (power, water, and communication).
PUBLIC INVOLVEMENT
On March 11, 2015, the FERC began its pre-filing review of the Project and established
the pre-filing Docket Number PF15-15-000 to place information related to the Project into the
public record. As part of the pre-filing process, Annova sponsored a public open house in
Brownsville, Texas on April 21, 2015. The purpose of the open house was to provide the general
public and government and agency officials with information about the Project and to give them
an opportunity to ask questions and express their concerns. We participated in the open house and
provided information regarding the Commission’s environmental review process to interested
stakeholders.
On July 23, 2015, the FERC issued a Notice of Intent to Prepare an Environmental Impact
Statement for the Planned Annova LNG Brownsville Project, Request for Comments on
Environmental Issues, and Notice of Public Scoping Meeting (NOI). The NOI was sent to over
400 interested parties including federal, state, and local officials; agency representatives;
conservation organizations; Native American tribes; local libraries and newspapers; and
interveners in the proceeding. There was a 30-day comment period on the NOI which ended on
August 24, 2015. On August 5, 2015, the FERC issued a Notice of Extension of Time which
extended the comment period on the NOI to September 4, 2015. We received over 6,000 comment
letters in response to the NOI. On August 11, 2015, the FERC staff held a public scoping session
in Port Isabel, Texas, to provide an opportunity for the public to learn more about the Project and
provide verbal comments on environmental issues to be addressed in the EIS. Ninety-five people
provided verbal comments at the scoping session and a transcript was entered into the public record
for the Project, as noted below.
On August 12, 2015, the FERC staff participated in a site visit to the Project site along with
representatives from the FWS, NPS, and Annova. On August 12, 2015, the FERC’s staff also held
an interagency meeting to solicit comments and concerns regarding the Project from other
Executive Summary ES-2

jurisdictional agencies. In addition to the FERC staff, representatives from four federal and state
agencies were present at this meeting including the FWS, Coast Guard, NPS, and Texas Parks and
Wildlife Department (TPWD). On February 4, 2016, the FERC’s staff participated in a second
site visit that included representatives from the FWS, NPS, EPA, FAA, NOAA Fisheries, TPWD,
and the Texas Historical Commission.
Through the scoping and agency comment process, we received comments on a variety of
environmental issues. We continued to receive and consider public comments during the entire
pre-filing period, and throughout development of this EIS. Substantive environmental issues
identified through this public review process are addressed in this EIS. The transcripts of the
public scoping session and all written comments are part of the FERC’s public record for the
Project and are available for viewing under the Project docket numbers. 3,4
We issued a Notice of Availability of the Draft Environmental Impact Statement for the
Proposed Annova LNG Brownsville Project on December 14, 2018. The draft EIS was filed with
the EPA, and a formal notice of availability (NOA) was issued in the Federal Register on
December 21, 2018, indicating that the draft EIS was available online. The NOA was mailed to
1,992 federal, state, and local government agencies; elected officials; Native American tribes; local
libraries and newspapers; and other interested parties (i.e., individuals who provided scoping
comments or asked to be on the mailing list). The distribution list for the NOA was included as
appendix A of the draft EIS. The NOA established a comment period on the draft EIS that ended
on February 4, 2019. The notice described procedures for filing comments on the draft EIS and
how information about the Project could be found on the FERC’s website. On February 7, 2019,
we issued a Notice of Reopening of Comment Period that extended the comment period to March
13, 2019 due to the funding lapse at certain federal agencies between December 22, 2018 and
January 25, 2019.
We held one public comment session on January 10, 2019, in Port Isabel, Texas. The
comment session provided interested parties with an opportunity to present verbal comments on
our analysis of the environmental impacts of the Project as described in the draft EIS. A total of
40 people commented at the session. In addition, we received over 1,200 comment letters in
response to the draft EIS. All environmental comments on the draft EIS have been addressed in
this final EIS either in the body of the text or in appendix L. A transcript of the comment session
and copies of each written comment are part of the public record for the Project. Our responses to
comments are provided in appendix L of this final EIS.
PROJECT IMPACTS
We evaluated the potential impacts of construction and operation of the Project on geologic
resources; soils; water resources; wetlands; vegetation; wildlife and aquatic resources; threatened,
endangered, and other sensitive species; land use, recreation, and visual resources;
3
Transcript of the public scoping meeting for the Project (Docket No. PF15-15-000) is available on the FERC
website at http://ferc.gov/docs-filing/elibrary.asp. To access public documents on the FERC website, select
“General Search” from the eLibrary menu, and enter the docket number, excluding the last three digits, in the
“Docket Number” field (i.e., PF15-15 or CP16-480). Be sure to select an appropriate date range.
4
Comments submitted after the Project application was filed with the FERC are part of the public record for the
Project (Docket No. PF15-15-000 and CP16-480-000) and are available on the FERC website at
http://ferc.gov/docs-filing/elibrary.asp.

socioeconomics; cultural resources; air quality and noise; safety and reliability; and cumulative
impacts. Where necessary, we recommend additional mitigation to minimize or avoid these
impacts. Section 5.2 of the EIS contains a compilation of our recommendations.
Overall, construction of the Project facilities would disturb approximately 550 acres for
construction. About 412 acres of the areas disturbed during construction would either contain
permanent facilities or be permanently maintained as either concrete, paved, or gravel surfaces, or
maintained in an herbaceous state. The remaining disturbed areas would be stabilized and restored
to native salt prairie. Following the completion of construction, the site would shift from
undeveloped to industrial land use. Annova estimates that up to 125 LNG carriers per year would
call on the terminal.
Based on our analysis, Project scoping, agency consultations, and public comments, the
major Project construction and operational issues are impacts on water resources and wetlands,
vegetation, wildlife and aquatic resources, federally listed species, visual resources,
socioeconomics including onshore traffic and waterway traffic within the BSC, cultural resources,
air quality and noise, safety and reliability, and cumulative impacts.
Water Resources
Annova would adhere to the best management practices contained in its project-specific
Upland Erosion Control, Revegetation, and Maintenance Plan (Annova’s Plan) and Wetland and
Waterbody Construction and Mitigation Procedures (Annova’s Procedures), as well as a
Construction Spill Prevention, Control, and Countermeasures (SPCC) Plan, which was developed
in accordance with applicable regulations and permit requirements to minimize water resource
impacts. No potable water supply wells are located within the Project site or within 150 feet of
Project. The nearest domestic water supply well is located over 4 miles north of the Project. The
majority of Project-related excavation would occur adjacent to the BSC where groundwater is
located near the surface. Excavation, the addition of fill, and the installation of foundations and
underground utilities would have localized and short-term effects on the groundwater during
construction with effects to local water table elevations. Implementation of mitigation measures
included in Annova’s Plan and SPCC Plan would reduce the potential for groundwater impacts.
Because of the temporary localized effects of construction on groundwater, implementation of
mitigation, and the relatively large distance between the Project site and any water supply wells,
we conclude that the potential impacts on groundwater resources due to Project-related
construction and operation activities would be minimal.
Construction and operation of the Project would result in decreased water quality of the
BSC within the vicinity of the site as a result of initial dredging and maintenance dredging, as well
as vessel traffic, site modification and stormwater runoff, and hydrostatic testing. Sediment-laden
water could be transported into the Bahia Grande and result in a potential for some increased
turbidity and sedimentation effects near the channel entrance to the Bahia Grande wetland
restoration site adjacent to the Project area. However, the potential impact would be only a
moderate increase in total suspended solids and limited to near the channel entrance; therefore, we
conclude the impact on water quality within the Bahia Grande would not be significant. Based on
Annova’s proposal, and in consideration of its proposed mitigation measures and design criteria,
we conclude that impacts on surface water resources as a result of construction and operation of
the Project would not be significant.

Wetlands
Construction and operation of the Project would result in the disturbance of 57.7 acres of
wetlands, with 52.8 acres of permanent wetland loss. The entirety of impact on vegetated wetlands
would occur to estuarine emergent marsh wetlands. Annova is consulting with the COE and other
relevant agencies regarding mitigation for wetland impacts. Annova has prepared a draft
Conceptual Mitigation Plan that identifies preliminary Project mitigation requirements and
proposed compensation for the Project’s impacts on wetlands and waters under the COE’s
jurisdiction. The acceptability of any proposed compensatory mitigation measures would be
determined by the COE prior to construction. Annova is still refining the mitigation plan, which
has not yet been approved by the COE.
Adherence to measures contained in Annova’s Procedures would adequately address

wetlands that are only temporarily affected by Project construction, such that impacts on
temporally affected wetlands would be less than significant. Loss of nearly 53 acres of wetland
would be a permanent impact. However, we anticipate that if the COE issues a Section 404/Section
10 permit for the Project it would be conditioned upon Project-related adverse impacts on waters
of the United States being effectively offset by wetland mitigation similar to what Annova has
identified in its draft Conceptual Mitigation Plan; therefore, the permanent wetland impacts would
be reduced to less than significant levels.
Vegetation
Construction of the Project would impact approximately 462 acres of vegetation, with
approximately 409 acres permanently affected during Project operation. The majority of these
impacts would be to the following vegetative communities: South Texas Loma Evergreen
Shrubland, Gulf Coast Salty Prairie, South Texas Loma Grassland/Shrubland, and Coastal Sea Ox-
eye Daisy Flats. Lomas are dunes formed from wind-blown clay that support dense thornscrub
vegetation that provide important habitat for protected wildlife species in the region. The FWS
considers thornscrub and coast salty prairie to be vegetation communities of special concern
because of their importance to federally listed species and limited distribution, with less than 5
percent of this habitat remaining in the Rio Grande Valley according to the FWS. To minimize
impacts on vegetation from construction and operation of the Project, Annova would implement
measures described in its Plan and Procedures, which include measures that address revegetation
procedures and post-construction monitoring of revegetation success. No state-designated rare,
threatened, or endangered plants are known to occur in the Project site. Of the approximately 409
acres of vegetation communities that would be permanently affected by the Project, about 310
acres (76 percent) would be vegetation communities identified as special concern (dense loma
thornshrub and coastal salt prairie) by the FWS. However, because this impact would represent
only about 6 percent of the lomas in the immediate Project area and less than 1 percent of the dense
shrub vegetation within a 13.7-mile radius around the Laguna Atascosa National Wildlife Refuges
(NWR), we have determined that construction and operation of the Project would not significantly
impact vegetation.
Wildlife and Aquatic Resources

Construction and operation of the Project would result in the removal and/or conversion of
wildlife habitats at the site, some of which would be habitat for federally listed species (see above
for Vegetation and below for Threatened, Endangered, and Other Sensitive Species). Annova

would minimize impacts on wildlife through implementation of TPWD recommendations during

construction and restoration, as well as through development and implementation of a Facility
Lighting Plan for operation of the LNG terminal. Because Annova has not yet developed the
Facility Lighting Plan, we recommend that, prior to construction, Annova file its Facility Lighting
Plan for operation of the LNG terminal for our review and approval. At the request of the FWS,
we recommend that the Facility Lighting Plan also address construction and commissioning.
Construction and operation of the Project could affect migratory bird species through
permanent and temporary removal of habitat and Project lighting. In accordance with FWS
recommendations, Annova would attempt to limit clearing on the Project site to between
September 1 through and February 28 to avoid impacts on migratory bird nesting. We recommend
that prior to construction Annova consult with the FWS to develop a Project-specific Migratory
Bird Plan to include measures to avoid and minimize impacts on migratory birds, and that the
Migratory Bird Plan should include details from the Facility Lighting Plan that are intended to
reduce impacts on wildlife and birds. The occasional use of warm/cold gas flares could impact
some migratory birds if present during the flaring event but is not expected to substantially impact
migratory bird populations.
Construction and operation activities with the potential to affect aquatic resources,
including managed species and essential fish habitat, include: excavation and dredging of the
marine berth, driving of piles, hydrostatic testing of the LNG tanks, additional vessel traffic in the
BSC, discharge of ballast water, cooling water intake and discharge, increased noise levels,
stormwater runoff or spills, and lighting. With Annova’s proposed mitigation measures in place,
impacts on aquatic resources, including managed species and essential fish habitat, would vary
depending on the species but are expected to range from negligible to short-term and minor. In
comments on the draft EIS, NOAA Fisheries concurred that impacts on essential fish habitat would
be temporary and minor. Impacts from pile driving are expected to be less than significant
considering the short in-water work schedule and the implementation of Annova’s proposed best
management practices. Noise-related mitigation measures for in-water pile driving during
construction, if appropriate would be determined based on consultation with NOAA Fisheries.
Threatened, Endangered, and Other Sensitive Species

Based on information obtained from the FWS and NOAA Fisheries, 21 federally listed,
proposed, and candidate threatened and endangered species could potentially be affected by the
Project. This total includes 18 federally listed, two proposed, and one candidate species. We have
determined that construction and operation of the Project would: have no effect on 2 of the
federally listed species; may affect, but is not likely to adversely affect 16 of the federally listed
species as well as the proposed species; and may affect, and is likely to adversely affect 2 federally
listed species (Ocelot and Gulf Coast jaguarondi). We also determined that the Project would not
contribute to a trend toward federal listing for the identified candidate species. Potentially suitable
habitat is present in the Project area for 45 of the 54 state-listed species in Cameron County.
Measures proposed by Annova to minimize impacts on federally and state-listed species

include implementation of conservation measures, and providing LNG carrier captains with a
NOAA-issued guidance document that outlines collision avoidance measures. Consultation with
NOAA Fisheries and the FWS is ongoing; therefore, we recommend that Annova should not begin

construction until the FERC staff completes consultation with the FWS and NOAA Fisheries under
section 7 of the Endangered Species Act.
Land Use, Recreation, and Visual Resources

Lands permanently affected during operation would either contain permanent facilities or
be permanently maintained as concrete, paved, or gravel surfaces, or maintained in an herbaceous
state. Following the completion of construction, the site would shift from undeveloped to
industrial land use in accordance with its current designation. The lands surrounding the Project
site are largely undeveloped providing a variety of dispersed outdoor recreational activities,
including fishing and bird/wildlife watching. Increases in dust, noise, and traffic during
construction would likely affect some recreationists, but the duration would be temporary. Project
construction and operation would not permanently affect access to the majority of regional fishing
locations in the waters located in the vicinity of the Project site. The increase in the number of
large vessels transiting the BSC during Project operation could potentially result in additional
delays for other traffic within the BSC but is not expected to substantially affect recreational
fishing. Annova’s Visual Impact Assessment evaluated 10 Key Observation Points (KOP) at
representative visually sensitive areas, including areas used for recreation and wildlife viewing,
key travel routes, the Palmito Ranch Battlefield National Historic Landmark (NHL) and Palo Alto
Battlefield National Historical Park (NHP), and other public gathering areas. Potential visual
impacts occurred at all KOPs and ranged from low to moderate at most locations. However, the
visual impacts at KOP 8 at the State Highway 48 pull-off near Bahia Grande Channel would be
moderately high. Based on our analysis, Project construction and operation would not result in
significant impacts on current land use, visual resources, and recreation.
Socioeconomics
Project construction would result in a short-term, moderate increase to the local population,
and Project operation would result in a negligible, long-term increase to the local population.
Construction and operation would generate local and state tax revenues from sales and payroll
taxes, and support some local employment. In addition, construction and operation of the Project
would not have high and adverse human health or environmental effects on any nearby
communities. Annova proposes to stagger construction shifts to minimize impacts from Project-
related vehicles, as well as transport construction workers to and from the construction site from
an off-site centralized location via passenger buses, which would reduce potential delays at key
intersections and the Border Patrol checkpoint on State Highway 4 (Boca Chica Boulevard). In
response to our recommendation in the draft EIS, Annova filed information on three potential
locations for the off-site parking; however, the exact locations are not identified. We considered
the use of these parking areas when determining impacts on traffic and visitors to the Palmito
Ranch Battlefield NHL. Therefore, to ensure that Annova establishes an off-site parking area(s)
and to ensure potential impacts from these areas are evaluated prior to use, we recommend that
prior to construction, Annova should file the specific location(s) of the off-site centralized parking
sites. Construction and operation of the Project would result in an increase in marine traffic in the
area, with minor impacts on other vessels.
Although the demographics indicate that potential environmental justice communities are
present within the census blocks near the Project site, there is no evidence that these communities
would be disproportionately affected by the Project or that impacts on these communities would

appreciably exceed impacts on the general population. It is not anticipated that the Project would
cause significant adverse health or environmental harm to any community with a disproportionate
number of minority or low-income populations. We conclude that the Project would not have
disproportionate adverse impacts on minority and low-income residents in the area.
Cultural Resources
Cultural resource surveys conducted for the Project identified eight sites that the Texas
State Historic Preservation Office (SHPO) agreed are not eligible for listing on the National
Register of Historic Places or as State Antiquities Landmarks. The SHPO determined that the area
around another site (41CF48) is considered unevaluated due to the inability to survey the area. If
this site cannot be avoided, the SHPO must be consulted and a survey plan for this area
implemented to ascertain the site’s eligibility. We recommend that Annova survey the area prior
to construction. Annova contacted several Native American tribes to identify properties of
traditional, religious, or cultural importance that may be affected by the proposed Project. Two
tribes responded indicating that they do not have resources that would be affected by the Project.
Additionally, no traditional cultural resources, burials, or sites of religious significance to Indian
tribes were identified within areas of the site that were surveyed.
Annova prepared a Visual Impact Assessment for three historic resources in the vicinity of
the site and we evaluated potential visual effects on the viewshed from these properties. We
conclude that the Project would not affect the essential features of the Palmito Ranch Battlefield
for the period of significance (the Civil War) or the Palo Alto Battlefield for the period of
significance (the Mexican War), and the overall integrity of these properties would remain intact.
However, in its comments on the draft EIS, the NPS indicated the agency disagrees with the
definition of the indirect Area of Potential Effect used in our analysis and believes the visual and
auditory effects of the Project on the Palmito Ranch Battlefield NHL and Palo Alto Battlefield
NHP and NHL would be adverse. While the Project may be visible from the location of the Brazos
Santiago Depot, construction and operation would not affect the site’s potential to provide
information about its period of significance or to yield information about the past.
Compliance with Section 106 of the NHPA is not complete for the Project and we have not
completed our consultation with the NPS regarding the visual effects of the Project on two historic
properties. Therefore, we recommend that Annova file all outstanding reports and agency
comments with the FERC and that FERC staff complete the Section 106 consultation process
before construction may begin.
Air Quality and Noise

Air quality impacts associated with construction of the Project would include emissions
from fossil-fueled construction equipment and fugitive dust. The five-year Project construction
period would result in short-term, localized impacts on air quality. These impacts would transition
to permanent operational-phase emissions after commissioning and initial start-up. Annova would
comply with all air permit requirements for the Project. Air dispersion modeling that included
both the Project’s stationary sources and emissions from the marine vessels that would operate as
part of the Project’s activities demonstrated that the stationary sources plus mobile source
emissions would not cause or contribute to an exceedance of the National Ambient Air Quality
Standards at any location.

With the exception of pile-driving activities, the maximum noise levels attributable to
Project construction would be equal or similar to existing noise levels. If observed levels exceed
the noise levels with the potential to impact nearby noise sensitive areas during daytime, we
recommend that Annova cease pile driving and implement noise mitigation measures. The Project
would have significant construction noise impacts during the six months of nighttime pile-driving.
Operation and maintenance of the Project is not expected to cause significant noise impacts
although certain short-term activities such as flaring would be distinctly noticeable to residents or
the public in the vicinity of the Project. To ensure that noise from operation of the Project is not
significant, we recommend that Annova file a noise survey with the FERC no later than 60 days
after placing each liquefaction unit and the entire Project in service, and implement mitigation
measures to reduce noise if it exceeds our criteria at the nearest noise sensitive area.
Reliability and Safety

We assessed the potential impact on the human environment in terms of safety and whether
the Project would operate safely, reliably, and securely. As a cooperating agency, the DOT
assisted the FERC staff by determining whether Annova’s proposed design would meet the DOT’s
49 CFR 193 Subpart B siting requirements. On March 20, 2019, the DOT issued a Letter of
Determination 5 on the Project’s compliance with 49 CFR 193 Subpart B. This determination is
provided to the Commission for consideration in its decision to authorize or deny the Project. If
the Project is authorized, constructed, and operated, the facility would be subject to the DOT’s
inspection and enforcement program; final determination of whether a facility is in compliance
with the requirements of 49 CFR 193 would be made by the DOT staff.
As a cooperating agency, the Coast Guard also assisted the FERC staff by reviewing the
proposed LNG terminal and the associated LNG marine vessel traffic. The Coast Guard reviewed
a Waterway Suitability Assessment submitted by Annova that focused on the navigation safety
and maritime security aspects of LNG marine vessel transits along the affected waterway.
On February 13, 2018, the Coast Guard issued a Letter of Recommendation (LOR) that
recommended that the BSC be considered suitable for accommodating the type and frequency of
LNG marine traffic for the Project based on the Waterway Suitability Assessment (WSA) and in
accordance with the guidance in the Coast Guard’s NVIC 01-11. Although the WSA was based
on a maximum of 125 ships the Coast Guard's LOR for the Annova Project states that the BSC
would be suitable for 80 ships. Annova has requested that the number of ships be increased from
about 80 to 125 ship-calls per year as indicated in the WSA. The Coast Guard is currently
evaluating this to determine if a revised LOR should be issued. As indicated previously, the safety
and environmental analysis in the final EIS has evaluated 125 ships. If the Project is authorized,
constructed, and operated, the facilities would be subject to the Coast Guard’s inspection and
enforcement program to ensure compliance with the requirements of 33 CFR 105 and 33 CFR 127.
As a cooperating agency, the FAA assisted FERC staff in evaluating impacts on and from
the Space Exploration Technologies Corporation (SpaceX) rocket launch facility in Cameron
County. We are including specific recommendations to address potential impacts from rocket
5
The Aug 31, 2018 Memorandum of Understanding between FERC and DOT states DOT will issue a Letter of
Determination to FERC no later than 30 days prior to the estimated issuance date of the final NEPA document.

launch failures on the Project. However, the extent of impacts on SpaceX operations, the National
Space Program, and to the federal government would not fully be known until SpaceX submits an
application with the FAA requesting to launch and whether the LNG terminal is under construction
or in operation at that time.
We conducted a preliminary engineering and technical review of the Annova design,

including potential external impacts based on the site location. Based on this review, we
recommend a number of mitigation measures to ensure continuous oversight prior to initial site
preparation, prior to construction of final design, prior to commissioning, prior to introduction of
hazardous fluids, prior to commencement of service, and throughout life of the facility, in order to
enhance the reliability and safety of the facility to mitigate the risk of impact on the public. With
the incorporation of these mitigation measures and oversight, we conclude that Annova’s terminal
design would include acceptable layers of protection or safeguards that would reduce the risk of a
potentially hazardous scenario from developing into an event that could impact the offsite public.
Cumulative Impacts
We considered the contributions of the proposed Project in conjunction with other projects
in the Project area to determine the potential for cumulative impact on the resources affected by
the Project. As part of that assessment, we identified existing projects, projects under construction,
projects that are proposed or planned, and reasonably foreseeable future projects – including
proposed LNG terminals, currently operating and future oil and gas projects, land transportation
projects, commercial and industrial developments, and dredging projects. Reasonably foreseeable
projects that might cause cumulative impacts in combination with the proposed Project include the
proposed Rio Grande LNG Project and the proposed Texas LNG Project. Many of the identified
cumulative impacts would be temporary and minor. Cumulative impacts have the potential to be
more substantial for water resources, protected wildlife, visual resources, air quality, noise, and
transportation, as discussed below.
The greatest potential for cumulative impacts associated with surface water resources
would be during dredging activities, as well as during operation. Concurrent dredging of the
maneuvering basin for the proposed Project as well as the Rio Grande LNG, Texas LNG, Bahia
Grande Estuary Channel Widening/Restoration, and Brazos Island Harbor Channel Improvement
Project would result in increased turbidity and sedimentation, resulting in short-term impacts on
water quality. The Brazos Island Harbor Channel Improvement Project is not expected to result
in sediment accumulation during dredging as the purpose of the project is to deepen the main
channel and any accumulated sediments would likely be accounted for with the allowed over-
dredge depth to achieve the final design depth. While the BSC is a routinely maintained, manmade
channel, concurrent dredging activities and other impacts on surface water resources during
construction activities, as described above, are anticipated to be temporary and moderate.
The operation of all three proposed Brownsville LNG projects would also result in a
substantial increase in the number of large, ocean-going vessels transiting the BSC (estimated to
be about 511 LNG carriers per year combined). During operation, increased vessel traffic would
result in a cumulative impact on surface water resources from increases in turbidity and shoreline
erosion. Each of the three LNG projects has designed its respective facilities to minimize shoreline
erosion through placement of rock riprap along the shoreline, or similar measures. Cumulative
impacts on surface water quality during operation would be permanent and moderate to significant

due to the persistent transit of LNG carriers and other large vessels within the BSC resulting in the
potential increased erosion of the shoreline along unarmored portions of the BSC.
The proposed Project, Rio Grande LNG, and Texas LNG Projects, as well as the pipeline
projects proposed in the area, are anticipated to have the greatest cumulative impacts on ocelot
habitat through removal and conversion to industrial uses and fragmentation, respectively. In
addition, these projects along with several of the transportation projects could result in increased
road traffic and/or additional roads for transiting ocelots and jaguarundis to cross, thus increasing
the potential for vehicle strikes. The current remaining habitat corridor in the region to connect
U.S. and Mexico populations of these federally listed species is within and adjacent to the proposed
Annova Project site on the south side of the BSC, and adjacent to and within the proposed Rio
Grande LNG and Texas LNG Project sites north of the BSC. Other impacts, such as those
associated with noise, would be minimized by the projects to the extent practicable; however, due
to the proximity of the proposed Annova LNG Project and Rio Grande LNG Project to the wildlife
corridors, facility-generated noise during construction and operation would still be audible to
ocelots and jaguarundis utilizing the wildlife corridor. Due to the past, present, and proposed
future development throughout the geographic scope for assessing cumulative impacts on ocelots
and jaguarundis, as well as the associated increases in road traffic, light, and noise, we have
determined that cumulative impacts on ocelots and jaguarundis would be permanent and
significant.
The proposed Project, Rio Grande LNG, and Texas LNG Projects are anticipated to have
the greatest cumulative impacts on the northern aplomado falcon. In comments on the draft EIS
the FWS estimates that about 546 acres of suitable northern aplomado falcon habitat would be
affected by the three proposed LNG Projects. Because of the past cumulative habitat loss and
construction of aboveground structures within and adjacent to remaining habitat, we conclude that
the cumulative impacts on aplomado falcons would be significant.
Projects with permanent aboveground components, such as the proposed Project, Texas
LNG, and Rio Grande LNG terminals, have the most potential to contribute to cumulative impacts
on visual resources. In particular, motorists on State Highway 48 and visitors to the nearby
recreation areas where two or three LNG Terminals would be visible (including the NWR, Loma
Ecological Preserve, and South Bay Coastal Preserve and South Bay Paddling Trail) would
experience a permanent change in the existing viewshed during construction and operation of the
projects. The proposed Annova LNG Project would have a low to moderate impact on visual
resources in the area. Due to the proximity of the Rio Grande LNG and Texas LNG Projects to
the same visual receptors as the Annova LNG Project, we conclude that significant cumulative
impacts on visual resources are anticipated.
Cumulative air quality impacts could occur as a result of concurrent construction and
operation of the Annova LNG Brownsville Project, Rio Grande LNG, and Texas LNG Projects.
Concurrent construction of these projects could result in temporary, moderate to major increases
in emissions of air pollutants during construction. The potential impacts of these localized elevated
emissions would be greatest in the immediate vicinity of the LNG terminal sites; however, the
implementation of mitigation measures (e.g., water application) would minimize such impacts.
The operation of the Rio Grande LNG and Texas LNG projects would have the greatest potential
to contribute to cumulative impacts on air quality with the operating Annova LNG terminal, given

the proximity of the projects. A conservative air quality modeling analysis of the emissions from
these three projects operating concurrently shows that for all criteria pollutants and averaging
periods, except for short-term (1-hour) Nitrogen Dioxide (NO2), cumulative impacts would be
below the National Ambient Air Quality Standards (NAAQS). The predicted maximum
cumulative 1-hour NO2 impact would exceed the 1-hour average NAAQS, although this impact is
between the fence lines of the Texas LNG and Rio Grande LNG ES-15 terminals, on Port of
Brownsville property. These occur due to the overlapping of emissions from simultaneous
operation and proximity of Rio Grande LNG and Texas LNG projects to each other. NO2
concentrations would disperse to levels of less than 40 percent of the 1-hour NO2 NAAQS before
reaching nearby communities. While concurrent maximum operations of the three LNG terminals
would result in increased concentrations of air pollutants in the vicinity of the terminals, the
emissions from the projects are not expected to result in a significant impact on regional air quality,
nor would any exceedance of the NAAQS occur in a populated area.
Cumulative noise impacts would primarily occur as a result of the concurrent construction
and operation of the Annova LNG Project, and the Texas LNG and Rio Grande LNG Projects.
For simultaneous construction activities at all three LNG projects, the predicted sound level
increase over the existing ambient ranges from 2.2 to 9.8 A-weighted decibels (dBA) day-night
sound level (Ldn) at the noise sensitive areas and sound levels of slightly over 55 dBA Ldn are
predicted for several noise sensitive areas, and range from less than noticeable increases in ambient
noise to a doubling of noise at specific noise sensitive areas. For construction activities that are
not simultaneous but incremental, the predicted sound level increase ranges from 1.0 to 8.6 dBA
Ldn at the noise sensitive areas. These increases would result in a minor to moderate impact;
however, all levels would be below 55 dBA Ldn. However, during Annova’s 6 months of nighttime
pile-driving, we have determined that impulsive noise levels (Lmax) would result in significant
cumulative noise impacts.
For the Palmito Ranch Battlefield National Historic Landmark, the predicted cumulative
construction increase was 10.1 dBA Ldn over the existing ambient, which could result in periods
of perceived doubling of noise. At the Laguna Atascosa NWR, there is a higher ambient sound
level so the predicted increase due to cumulative construction noise would be 2.7 dBA Ldn,
resulting in a minor impact.
For operational noise with all three LNG projects fully operational, the predicted sound
level impacts are much lower than construction impacts, with potential increases over the existing
ambient of between 0.3 and 1.5 dBA Ldn at noise sensitive areas, resulting in minor impacts.
Operational impacts would be slightly higher at the Palmito Ranch Battlefield National Historic
Landmark and the Laguna Atascosa NWR, with possible increases in sound levels due to operation
of all three LNG projects of between 1.3 and 4.8 dBA Ldn. This is generally considered a minor
to moderate long-term impact.
If the three LNG projects were constructed concurrently, the combined impact of
construction traffic would be approximately 14,624 daily trips during active construction, with the
Annova LNG Project accounting for approximately 14 percent of this total. This cumulative
impact would result in increased wait times and congestion on local roadways during construction.
If all three proposed LNG projects were authorized and go into operation, and the other identified
dredging projects also occur, there would be a substantial increase of large and ocean-going vessel

traffic on the BSC. The three LNG projects combined would support an estimated 511 LNG carrier
trips per year, with periodic channel maintenance dredging activities, on average, contributing
about 420 vessel trips per year. This cumulative impact would represent a substantial increase in
the number of large and ocean-going vessels in the BSC, and small vessels and recreational boaters
attempting to access South Bay and the BSC would likely experience delays, ranging from 12 to
35 percent of daylight hours per year.
ALTERNATIVES CONSIDERED
In accordance with NEPA and our policies, we evaluated alternatives to the Project to
determine whether an alternative would be environmentally preferable, reasonable, and/or
technically and economically feasible. We considered: a no action alternative; system
alternatives; alternative sites; access road alternatives; process and design alternatives; and
dredged material placement area alternatives.
While the no action alternative would avoid the environmental impacts identified in this
EIS, the objectives of the Project would not be met. Further, the objectives could be met by similar
development elsewhere with associated environmental impacts similar to the proposed Project.
System alternatives considered in this analysis are those alternatives to the proposed action that
would make use of other existing, modified, or proposed facilities to meet the stated purpose and
need of the proposed action. Our evaluation of potential system alternatives to the Project did not
identify any existing, proposed, or planned LNG export facilities in the region that could be
considered a viable system alternative.
We received comments from the public and other federal agencies during the scoping
period regarding the need for an evaluation of alternative sites such as industrial areas that are not
in proximity to communities and important wildlife habitat. Based in part on the information
provided by Annova, we evaluated alternative sites that may also meet the stated objectives of the
Annova LNG Project. We applied screening criteria to identify sites that would be reasonable and
most likely to provide some environmental advantage over the proposed terminal site. Based on
this analysis, we conclude that the proposed site represents an acceptable site for the proposed
LNG terminal, and that the alternative sites are either not feasible or are not environmentally
preferable to the proposed site.
Based on scoping comments, Annova (in consultation with the FWS) identified two
alternatives to its proposed access road from State Highway 4 to the Project site. The two
alternative routes (Access Road Alternatives 1 and 3) reflect possible modifications to minimize
potential impacts on wildlife movement through the area. We conclude that neither alternative
access road would be environmentally preferable to the proposed access road. However, use of
the proposed access road would require an appropriateness determination and a compatibility
determination from the FWS. Annova has stated it is in discussion with the FWS regarding the
appropriateness determination for use of the proposed access road. Annova states that it would
construct and operate its access road on the route identified as Access Road Alternative 1 in the
event that the FWS regulatory process precludes the use of the proposed access road.
At our request, Annova evaluated process and design alternatives that include an on-site
power plant versus grid-supplied power as proposed, gas-fired compressors versus electric
compressors as proposed, and several flare design alternatives. We conclude that neither an on-

site power plant, or gas-fired compressors would provide a significant environmental advantage
over the proposed design when comparing local air quality impacts. Based on our analysis of
alternative flare designs we conclude that a Totally Enclosed Ground Flare design would not result
in a significant environmental advantage over the proposed combined warm/cold flare stack.
Annova proposes to use the existing Dredged Material Placement Area 5A located along
the BSC just west of the Project site for placement of dredged material not used as fill on site.
Annova’s proposed Dredged Material Transport Plan includes evaluation of three alternative
placement areas also located along the BSC which we summarize in our EIS. We conclude that
none of the three alternative placement areas would provide an environmental advantage over the
proposed placement area.
CONCLUSIONS
We determined that construction and operation of the Annova LNG Project would result
in some unavoidable adverse environmental impacts. We conclude that impacts on the
environment from the proposed Project would be reduced to less than significant levels with the
implementation of Annova’s proposed impact avoidance, minimization, and mitigation measures
and the additional measures recommended by FERC staff.
In addition, the Annova LNG Project, combined with other projects in the geographic
scope, including the Rio Grande LNG and Texas LNG Projects, would result in significant
cumulative impacts from sedimentation/turbidity and shoreline erosion within the BSC during
operations from vessel transits and on the federally listed ocelot and jaguarundi from habitat loss
and potential for increased vehicular strikes during construction; on the federally listed aplomado
falcon from habitat loss and construction of elevated structures and on visual resources from the
presence of aboveground structures. We based our conclusions upon information provided by
Annova and through environmental information requests; field visits; literature research;
geospatial analysis; alternatives analysis; public comments and scoping session; and coordination
with federal, state, and local agencies and Native American tribes. The following factors were
also considered in our conclusions:
• impacts on wetlands and aquatic habitat, including Essential Fish Habitat, would
be mitigated per Annova’s draft Conceptual Mitigation Plan;
• Annova would implement its Project-specific Upland Erosion Control,
Revegetation, and Maintenance Plan and Wetland and Waterbody Construction
and Mitigation Procedures to minimize construction impacts on soils, wetlands,
and waterbodies;
• we recommend that all appropriate consultations with the FWS and NOAA
Fisheries under the Endangered Species Act should be completed before
construction is allowed to begin;
• the Coast Guard issued a Letter of Recommendation indicating the BSC would be
considered suitable for the LNG marine traffic associated with the Project;
• we recommend that Annova file all outstanding cultural resource reports and
agency comments for our review before construction is allowed to begin;

• the LNG Terminal design would include acceptable layers of protection or

safeguards that would reduce the risk of a potentially hazardous scenario from
developing into an event that could impact the offsite public; and
• FERC’s environmental and engineering inspection and mitigation monitoring
program for this Project would ensure compliance with all mitigation measures and
conditions of any FERC Authorization.
In addition, we developed site-specific mitigation measures that Annova should implement

to further reduce the environmental impacts that would otherwise result from construction and
operation of the Project. We recommend these mitigation measures, presented in section 5.2 of
this EIS, be attached as conditions to any authorization issued by the Commission for this Project.

1.0 INTRODUCTION
The staff of the Federal Energy Regulatory Commission (FERC or Commission) prepared
this final Environmental Impact Statement (EIS) to describe our assessment of the potential
environmental impacts that may occur from constructing and operating the Annova LNG
Brownsville Project liquefied natural gas (LNG) export terminal in Cameron County, Texas
(referred to as the Annova LNG Project, or Project).
The vertical line in the margin identifies text that is new or modified in the final EIS
and differs materially from corresponding text in the draft EIS. Changes were made to address
comments from the cooperating agencies and other stakeholders on the draft EIS; incorporate
updated information provided by Annova regarding the Project after publication of the draft
EIS; and incorporate information filed by Annova in response to our recommendations in the
draft EIS.
On July 13, 2016, Annova LNG Common Infrastructure, LLC; Annova LNG Brownsville
A, LLC; Annova LNG Brownsville B, LLC; and Annova LNG Brownsville C, LLC (collectively
Annova) filed an application with the FERC, in Docket No. CP16-480-000, under Section 3(a) of
the Natural Gas Act (NGA) and under Title 18 of the Code of Federal Regulations (CFR), Parts
153 and 380 of the Commission’s regulations to construct and operate an LNG export terminal.
This application was noticed in the Federal Register (FR) on July 27, 2016.
As part of the Commission’s consideration of the application, we 1 prepared this EIS to

assess the potential environmental impacts resulting from construction and operation of the
proposed Project in accordance with the National Environmental Policy Act of 1969 (NEPA).
The new liquefaction facility would include six liquefaction “trains” (each train being the
liquefaction process facilities arranged in a linear relationship), each with a nameplate capacity of
1.0 million metric tons per annum (mtpa), for an aggregate nameplate capacity of 6 mtpa and a
maximum output at optimal operating conditions of 6.95 mtpa (approximately 0.9 billion cubic
feet per day). The facility would be located on a 731-acre site on the south bank of the Brownsville
Ship Channel (BSC) at approximately mile marker 8.2 on the Brazos Santiago Pass. Natural gas
would be delivered to the Annova LNG facility via a new intrastate pipeline to be constructed by
an as-yet undetermined third party. More detailed information regarding the proposed facility
components is provided in section 2.1 of this EIS.
In its July 13, 2016 application with the FERC, Annova anticipated that the Project would
be fully operational in 2022. On September 10, 2018, Annova filed with the Commission an
updated Project development schedule that included an estimated start of commercial operation in
2024.
Figure 1-1 shows the general location of the proposed facilities and figure 1-2 shows the
general site plan.
1
“We”, “us”, and “our” refer to the environmental staff of the FERC’s Office of Energy Projects.
1-1 Introduction
Figure 1-1 Annova LNG Brownsville Project General Location
Introduction 1-2
WILDLIFE
CORRIDOR
Figure 1-2 General Site Plan for Proposed Facilities
PROJECT PURPOSE
Section 3 of the NGA, as amended, requires that authorization be obtained from the U.S.
Department of Energy (DOE) prior to importing or exporting natural gas, including LNG, from or
to a foreign country. For applicants that have, or intend to have, a signed gas purchase or sales
agreement/contract for a period of time longer than two years, long-term authorization is required.
Under Section 3 of the NGA, the FERC considers, as part of its decision to authorize natural gas
facilities, all factors bearing on the public interest. Specifically, regarding whether to authorize
natural gas facilities used for importation or exportation, the FERC shall authorize the proposal
unless it finds that the proposed facilities would not be consistent with the public interest.
The FERC is the federal agency responsible for authorizing onshore LNG facilities. As
such, the FERC is the lead federal agency for the preparation of this EIS in compliance with the
requirements of the NEPA, the Council on Environmental Quality’s (CEQ) regulations for
implementing the NEPA (40 CFR 1500-1508), and the FERC’s regulations for implementing the
NEPA (18 CFR 380). Because the proposal under consideration is conceived, designed, and
funded by the applicant, the project purpose considered in this EIS is defined by the project
proponent. Annova stated that the purpose of the Project is to construct and operate a mid-scale
1-3 Introduction
natural gas liquefaction facility to source natural gas from the South Texas Gulf Coast region and
export LNG to international markets. Annova further states that the mid-scale size of the facility
would meet the requirements of multiple foreign purchasers whose annual demand is best met with
increments of 1 mtpa. We have reviewed this purpose statement and find it to be reasonable and
sufficient to support our analysis in this EIS.
AGENCY PURPOSE AND SCOPE OF THE EIS

The EIS describes the affected environment as it currently exists, the environmental
consequences of the Project, and compares the Project’s potential impact with various alternatives.
The EIS also presents our conclusions and recommended mitigation measures.
Our principal purposes in preparing this EIS are to:
• identify and assess potential impacts on the human environment that would result
from the implementation of the proposed action;
• identify and assess reasonable alternatives to the proposed action that would avoid
or minimize adverse impacts on the human environment;
• identify and recommend specific mitigation measures to minimize environmental
impacts; and
• facilitate public involvement in identifying significant environmental impacts on
specific resources.
Topics addressed in this EIS include alternatives; geology; soils and sediments; water
resources; wetlands; vegetation; wildlife and aquatic resources; threatened, endangered, and other
special status species; land use, recreation, and visual resources; socioeconomics; transportation
and traffic; cultural resources; air quality and noise; reliability and safety; and cumulative impacts.
Our analysis in this EIS focuses on facilities that are under the Commission’s jurisdiction (i.e., the
proposed LNG facility). Non-jurisdictional facilities would also be constructed in association with
the Project (see section 1.4). Non-jurisdictional facilities are not under the Commission’s
jurisdiction and are not part of the proposed action reviewed by this EIS. The Commission has no
authority to approve, modify, or deny these facilities. However, we are providing the public and
the Commission with the available information on the impacts of the non-jurisdictional facilities,
as appropriate, in section 4.13, Cumulative Impacts.
Federal Energy Regulatory Commission Purpose and Role

The Commission’s purpose for reviewing the Annova LNG Project is based on its
obligations under the NGA. Under Section 3 of the NGA, the Commission considers as part of its
decision to authorize natural gas facilities, all factors bearing on the public interest. Specifically,
regarding whether to authorize siting of natural gas facilities used for exportation, the Commission
would authorize the proposal unless it finds the proposed facilities would not be consistent with
the public interest.
Several agencies are cooperating agencies for the development of this EIS. A cooperating
federal agency has jurisdiction by law or special expertise with respect to environmental impacts
associated with the proposal. Cooperating agencies for the Project include: the U.S. Army Corps
Introduction 1-4
of Engineers (COE); U.S. Coast Guard (Coast Guard); U.S. Department of Transportation (DOT);
U.S. Environmental Protection Agency (EPA); U.S. Fish and Wildlife Service (FWS); National
Parks Service (NPS); the National Oceanic and Atmospheric Administration, National Marine
Fisheries Service (NOAA Fisheries) 2; Federal Aviation Administration (FAA); and DOE. The
purpose and role of each cooperating agencies is provided below.
U.S. Army Corps of Engineers Purpose and Role

The COE has jurisdictional authority pursuant to Section 404 of the Clean Water Act
(CWA) (Title 33 of the United States Code [USC], Section 1344 [33 USC 1344]), which governs
the discharge of dredged or fill material into waters of the U.S., and Section 10 of the Rivers and
Harbors Act (RHA) (33 USC 403), which regulates any work or structures that potentially affect
the navigable capacity of a waterbody. Because the COE would need to evaluate and approve
several aspects of the Project and must comply with the requirements of NEPA before issuing
permits under the above statutes, it has elected to participate as a cooperating agency in the
preparation of this EIS. The COE would adopt the final EIS (FEIS) to satisfy its requirements
under NEPA per 40 CFR 1506.3 if, after an independent review of the document, it concludes that
the FEIS satisfies the COE’s comments and suggestions. The Project occurs within the Galveston
District of the COE. Staff from this COE district participated in the NEPA review and would
evaluate COE authorizations, as applicable.
The primary decisions to be addressed by the COE include:

• issuance of a Section 404 Permit for wetland impacts associated with construction
of the Project; and
• issuance of Section 10 Permit for construction activities within navigable waters
of the U.S.
This EIS contains information needed by the COE to reach decisions on these issues.
Through the coordination of this document, the COE would obtain the views of the public and
natural resource agencies prior to reaching the COE’s decisions on the Project.
As an element of its review, the COE must consider whether a proposed project avoids,
minimizes, and compensates for impacts on existing aquatic resources, including wetlands, to
strive to achieve a goal of no overall net loss of values and functions. Based on its participation
as a cooperating agency and its consideration of the final EIS (including responses to public
comments), the COE would issue a Record of Decision to formally document its decision on the
proposed action, including a Section 404 (b)(1) analysis and required environmental mitigation
commitments.
U.S. Coast Guard Purpose and Role

The Coast Guard is the federal agency responsible for determining the suitability of
waterways for LNG marine traffic. The Coast Guard exercises regulatory authority over LNG
facilities that affect the safety and security of port areas and navigable waterways under Executive
Order 10173, the Magnuson Act (50 USC 191), the Ports and Waterways Safety Act of 1972, as
amended (33 USC 1221, et seq.), and the Maritime Transportation Security Act of 2002 (MTSA)
2 May also be abbreviated as “NMFS.”
1-5 Introduction
(46 USC 701). The Coast Guard is responsible for matters related to navigation safety, vessel
engineering and safety standards, and all matters pertaining to the safety of facilities or equipment
in or adjacent to navigable waters up to the last valve immediately before the LNG storage tanks.
The Coast Guard also has authority for LNG facility security plan reviews, approval and
compliance verification as provided in 33 CFR 105, and siting as it pertains to the management of
vessel traffic in and around LNG facilities to a point 12 nautical miles (nm) seaward from the
coastline (to the territorial seas). As appropriate, the Coast Guard (acting under the authority in
33 USC 1221 et seq., and under a 2004 Interagency Agreement 3) also would inform the FERC of
design and construction related issues identified as part of safety and security assessments. If the
Annova LNG Project is authorized, constructed, and operated, the Coast Guard would continue to
exercise regulatory oversight of the safety and security of the LNG Terminal facilities, in
compliance with 33 CFR 127.
As required by its regulations, the Coast Guard is responsible for issuing a Letter of
Recommendation (LOR) as to the suitability of the waterway for LNG marine traffic following a
Waterway Suitability Assessment (WSA). On February 23, 2015, Annova submitted to the Coast
Guard a Letter of Intent pursuant to 33 CFR 127.007 and a preliminary WSA for the Project. The
preliminary WSA provided information on the port, assessment of maritime safety and security,
risk management strategies, and resources required for safety, security, and response. The Coast
Guard reviewed the preliminary WSA and responded to Annova that it had no comments. On
February 13, 2018, the Coast Guard issued an LOR that recommended that the BSC be considered
suitable for accommodating the type and frequency of LNG marine traffic for the Project. Annova
indicates that up to 125 vessels per year may visit the terminal, depending on the storage capacity.
The LOR currently evaluates 80 vessels sized at 178,000 m3. Annova is coordinating with the
Coast Guard to determine if a larger number of smaller vessels, or a mix of vessel sizes, would
require any modification to the LOR. Our analysis in this EIS assumes that up to 125 vessels per
year may visit the Project.
U.S. Department of Transportation Purpose and Role

The DOT has prescribed the minimum federal safety standards for LNG facilities in
compliance with 49 USC 60101. Those standards are codified in 49 CFR Part 193 and apply to
the siting, design, construction, operation, maintenance, and security of LNG facilities. The
National Fire Protection Association (NFPA) Standard 59A, Standard for the Production,
Storage, and Handling of Liquefied Natural Gas (2001 ed.), is incorporated into these
requirements by reference, with regulatory preemption in the event of conflict. In accordance
with the 2004 Interagency Agreement, the DOT participates as a cooperating agency on the
safety and security review of waterfront import/export LNG facilities. The DOT does not issue a
permit or license but, as a cooperating agency, assists FERC staff in evaluating whether an
applicant’s proposed siting criteria meets the DOT requirements in Part 193, Subpart B. On
August 31, 2018, the DOT and FERC signed a new Memorandum of Understanding (MOU) to
improve coordination throughout the LNG permit application process for FERC jurisdictional
LNG facilities. On March 20, 2019, the DOT issued the Letter of Determination for the Annova
LNG Project which provides DOT's analysis and conclusions regarding 49 CFR 193, Subpart B
3
Interagency Agreement among the FERC, Coast Guard, and DOT Research and Special Programs Administration,
for the Safety and Security of Waterfront Import/Export of LNG Facilities (https://www.ferc.gov/industries/gas/indus-
act/lng/2004-interagency/2004-interagency.pdf?csrt=14440234472018644188).
Introduction 1-6
regulatory requirements for the Commission’s consideration in its decision to authorize, with or
without modification or conditions, or deny an application (see additional discussion in section
4.12.2 of this EIS).
U.S. Environmental Protection Agency Purpose and Role
The EPA has delegated water quality certification, under Section 401 of the CWA, to the
jurisdiction of individual state agencies. The EPA may assume Section 401 authority if no state
program exists, if the state program is not functioning adequately, or at the request of the state.
The EPA also oversees the issuance of a National Pollutant Discharge Elimination System
(NPDES) permit by the state agency, under Section 402 of the CWA, for point-source discharge
of used water into surface waters of the U.S. In addition to its authority under the CWA, the EPA
also has jurisdictional authority under the Clean Air Act of 1970 (CAA) to control air pollution by
developing and enforcing rules and regulations for all entities that emit toxic substances into the
air. Under this authority, the EPA has developed regulations for major sources of air pollution and
has delegated the authority to implement these regulations to state and local agencies. State and
local agencies are allowed to develop and implement their own regulations for non-major sources
of air pollutants.
In addition to its permitting responsibilities, the EPA is required under Section 309 of the
CAA to review and publicly comment on the environmental impacts of major federal actions
including actions that are the subject of draft and final EISs, and responsible for implementing
certain procedural provisions of NEPA (e.g., publishing Notices of Availability of the draft and
final EISs) to establish statutory timeframes for the environmental review process. On February
12, 2019, the EPA filed a letter on the draft EIS stating the EPA has no comments on the Project
as proposed.
U.S. Fish and Wildlife Service Purpose and Role

The FWS is responsible for ensuring compliance with the Endangered Species Act (ESA)
for most listed terrestrial and freshwater species, but also several marine mammal species. Section
7 of the ESA, as amended, states that any project authorized, funded, or conducted by any federal
agencies should not “…jeopardize the continued existence of any endangered species or threatened
species or result in the destruction or adverse modification of habitat of such species which is
determined…to be critical…” (16 USC 1536(a)(2)). The FWS also reviews project plans and
provides comments regarding protection of fish and wildlife resources under the provisions of the
Fish and Wildlife Coordination Act (16 USC 661 et seq.). The FWS is responsible for the
implementation of the provisions of the Migratory Bird Treaty Act (MBTA) (16 USC 703) and
the Bald and Golden Eagle Protection Act (BGEPA) (16 USC 688).
Section 7 of the ESA requires identification of and consultation on aspects of any federally
authorized action that may have effects on federally listed species, species proposed for federal
listing, and their habitat. The ultimate responsibility for compliance with section 7 remains with
the lead federal agency (i.e., the FERC for this project).
FERC consulted with the FWS pursuant to section 7 of the ESA to determine whether
federally listed endangered or threatened species or designated critical habitat are found in the
vicinity of the Project, and to evaluate the proposed action’s potential effects on those species or
1-7 Introduction
critical habitats. On February 15, 2019, we submitted a biological assessment to the FWS
requesting concurrence on our findings of effect under section 7 of the ESA. Consultation on the
biological assessment is ongoing. The FERC coordinated with the FWS regarding other federal
trust wildlife resources, such as migratory birds, the Migratory Bird Treaty Act (MBTA), the Bald
and Golden Eagle Protection Act (BGEPA), the Fish and Wildlife Coordination Act, and NEPA.
National Parks Service Purpose and Role

The NPS manages four sites in the Project vicinity: the Palo Alto Battlefield National
Historical Park, the Palmito Ranch Battlefield National Historic Landmark (NHL), the Resaca de
la Palms Battlefield NHL, and the Padre Island National Seashore. The NPS elected to cooperate
in preparing this EIS because of potential impacts on these four sites. Section 110(f) of the
National Historic Preservation Act (NHPA) requires that “prior to the approval of any Federal
undertaking, which may affect any National Historic Landmark, the head of the responsible
Federal agency shall, to the maximum extent possible, undertake such planning and actions as may
be necessary to minimize harm to such landmark, and shall afford the Advisory Council on Historic
Preservation a reasonable opportunity to comment on the undertaking.” Also, as stated in 36 CFR
Part 800.10(c), federal agencies are required to notify the Secretary of the Interior (delegated to
the NPS) of any consultation involving an undertaking at an NHL and invite the Secretary to
participate in the consultation. Effects include visual, night sky light pollution, noise, and
cumulative effects.
The Natural Sounds and Night Skies Division of the NPS is tasked with managing,
protecting, and restoring the nighttime photic environment and naturally dark skies in national park
units. Due to the large outputs of artificial lighting associated with some LNG facilities and the
great distances that artificial light can travel, the Project has the potential to adversely affect the
resources of Palo Alto Battlefield National Historical Park and Padre Island National Seashore.
On March 13, 2019, the NPS filed comments on the draft EIS, stating that it disagrees with the
definition of the indirect APE used in our analysis, and that the visual effects of the Project
on Palmito Ranch Battlefield NHL and Palo Alto Battlefield NHL will be adverse.
National Oceanic and Atmospheric Administration, National Marine Fisheries

Service Purpose and Role
NOAA Fisheries is responsible for ensuring compliance with the ESA for marine and
anadromous species. NOAA Fisheries is also responsible for implementing the Magnuson-Stevens
Fishery Conservation and Management Act of 1976 (MSA), as amended by the Sustainable Fisheries
Act of 1996 (Public Law 104-267). The MSA requires federal agencies to consult with NOAA
Fisheries on all actions or proposed actions authorized, funded, or undertaken by the agency that
may adversely impact essential fish habitat (EFH) (MSA Section 305(b)(2)). We included an EFH
Assessment in the draft EIS, and on February 5, 2019, NOAA Fisheries filed comments on the EFH
Assessment, stating it concurs with the findings, has no Conservation Recommendations to provide
on the Project, and that no further consultation with NOAA Fisheries is required under the MSA.
As the lead federal agency for the Project, the FERC consulted with NOAA Fisheries
pursuant to Section 7 of the ESA to determine whether federally listed endangered or threatened
species or designated critical habitat are found in the vicinity of the Project, and to evaluate the
Introduction 1-8
proposed action’s potential effects on those species or critical habitats. NOAA Fisheries elected
to cooperate in preparing this EIS because it has special expertise with respect to environmental
impacts associated with the Project.
Federal Aviation Administration Purpose and Role

The FAA is a federal agency responsible for regulating all aspects of civil aviation including
management of airports, air traffic control, and protection of the public, property, and the national
security and foreign policy interests of the U.S. during commercial space launch and reentry
activities. In its mission to safely manage U.S. airspace and air traffic, the FAA requires that certain
elevated structures with the potential to affect navigable airspace are placed on public notice (14
CFR 77). This notification should identify all equipment that are more than 200 feet above ground
level or lesser heights if the facilities are within 20,000 feet of an airport or within 5,000 feet of a
helipad. Annova proposes to limit heights of permanent structures to 200 feet. On July 26, 2017,
Annova received a FAA Determination of No Hazard to Air Navigation in accordance with 14 CFR
77 for the temporary construction cranes that would exceed 200 feet in height.
In addition, the FAA Office of Commercial Space Transportation (AST) has special
expertise and responsibilities related to issuing launch licenses and/or experimental permits to
allow Space Exploration Technologies Corporation (SpaceX) to conduct launches from a launch
site that is under construction and located east-southeast of the Project. The FAA AST’s
responsibilities are authorized by Executive Order 12465 (Commercial Expendable Launch
Vehicle Activities, 49 FR 7099, 3 CFR, 1984 Comp., p. 163) and the Commercial Space Launch
Act (51 USC Subtitle V, ch. 509 §§50901-50923) for oversight of commercial space launch
activities, including issuing launch licenses and experimental permits to operate reusable orbital
and suborbital launch vehicles. The FAA AST has special expertise related to potential future
space launch missions, including quantification of risk (likelihood and consequences) in
accordance with 14 CFR Parts 415 and 417. The FAA AST elected to cooperate in preparing this
EIS to ensure it meets its responsibilities related to future operation of the SpaceX launch facility.
U.S. Department of Energy Purpose and Role

The DOE, Office of Fossil Energy (DOE/FE) must meet its obligation under Section 3 of
the NGA to authorize the import and/or export of natural gas, including LNG, unless it finds that
the proposed import or export is not consistent with the public interest. By law, under Section 3(c)
of the NGA, applications to export natural gas to countries with which the United States has Free
Trade Agreements (FTA) that require national treatment for trade in natural gas are deemed to be
consistent with the public interest and the Secretary must grant authorization without modification
or delay. In the case of applications to export LNG to non-FTA nations, NGA Section 3(a) requires
the DOE/FE to conduct a public interest review and to grant authorizations unless the DOE/FE
finds that the proposed exports will not be consistent with the public interest. Additionally, the
NEPA requires DOE/FE to consider the environmental effects of its decisions regarding
applications to export natural gas to non-FTA nations.
On February 20, 2014, in Order No. 3394, DOE/FE authorized Annova LNG, LLC, an
affiliate of the Annova entities, to export up to approximately 342 billion cubic feet per year of
natural gas to FTA nations. On July 17, 2014, in Order No. 3464, DOE/FE approved the transfer
of the FTA authorization to Annova LNG Common Infrastructure, LLC. On February 26, 2019,
1-9 Introduction
Annova Common Infrastructure, LLC submitted an application to DOE/FE for export of

approximately 360 billion cubic feet per year (Bcf/yr) of natural gas as LNG (which it states is
equivalent to 6.95 mtpa of LNG) to non-FTA nations. A supplement to the application was
submitted on March 13, 2019. The purpose and need for DOE action for the current proposal is
to enable DOE’s public interest evaluation and NEPA review of Annova’s application to export
LNG to non-FTA countries. Annova has indicated it plans to bring the export volume in the FTA
proceeding into alignment with the volume in the non-FTA export proceeding so that both will be
for 360 Bcf/yr.
The DOE has exclusive jurisdiction over the export of natural gas as a commodity. DOE
has delegated to the Commission authority to approve or disapprove the construction and operation
of particular facilities. The facilities are considered the site at which such facilities would be
located, and with respect to natural gas that involves the construction of new domestic facilities,
the place of entry for imports or exit for exports. However, the DOE Secretary has not delegated
to the Commission any authority to approve or disapprove the import or export of the commodity
itself as part of the Commission’s public interest determination. The Commission’s authorization
alone would not enable the export of any additional volumes of LNG.
The DOE conducts its review under Section 3 of the NGA. Additionally, NEPA requires
the DOE to consider the environmental impacts of its decisions on non-FTA export applications.
In this regard, the DOE acts as a cooperating agency with FERC in the preparation of the EIS
pursuant to the requirements of NEPA. In accordance with 40 CFR 1506.3, after an independent
review of the FEIS, DOE may adopt the FEIS to satisfy its requirements under NEPA.
PUBLIC REVIEW AND COMMENT

Pre-Filing Process and Scoping
Annova initiated the FERC pre-filing process for the Project on March 11, 2015. On March
27, 2015, the Director of the Office of Energy Project granted Annova’s request to utilize the pre-
filing process and assigned Docket No. PF15-15-000. The pre-filing process ended on July 13,
2016, when Annova submitted its application to the FERC. The pre-filing process allows the
FERC staff to become involved with scoping of environmental issues before the applicant files its
application, thus overlapping the applicant’s planning process with the NEPA process.
During the pre-filing process we conducted biweekly conference calls with Annova to
discuss the then-planned Project’s progress and identify and address issues and concerns that had
been raised. Interested agencies were invited to participate. Summaries of biweekly conference
calls, and scoping comments, are part of the public record for the Project and are available for
viewing on the FERC website (http://www.ferc.gov) under the prefiling Docket No. PF15-15-000.
Annova hosted an open house information session for landowners, agencies, and other
interested stakeholders on April 21, 2015, in Brownsville, Texas, at which FERC staff also
participated. The open house provided stakeholders the opportunity to learn about the Project and
ask questions in an informal setting. Notification of the open house was mailed to stakeholders and
published in local newspapers. On July 23, 2015, the FERC issued a Notice of Intent to Prepare an
Environmental Impact Statement for the Planned Annova LNG Brownville Project, Request for
Comments on Environmental Issues, and Notice of Public Scoping Meeting (NOI). The NOI was
Introduction 1-10
sent to over 400 interested parties including nearby landowners, federal, state, and local officials;
agency representatives; conservation organizations; local libraries and newspapers, and tribal
representatives. There was a 30-day comment period on the NOI which ended on August 24, 2015.
On August 5, 2015, the FERC issued a Notice of Extension of Time, which extended the comment
period to September 4, 2015. We received over 6,000 comment letters in response to the NOI. Of
the comment letters filed during the public scoping period, 16 were from state or federal agencies,
and the remaining were from interested parties or individuals. The majority of comments indicated
concerns regarding safety, air quality, commercial and recreational fishing, tourism, fish and
wildlife, visual resources, and noise and light pollution. Annova filed a letter addressing comments
filed during the public scoping period in a submittal to the Commission on September 18, 2015.
On August 11, 2015, the FERC conducted a public scoping meeting in Port Isabel, Texas,
to provide an opportunity for the public to learn more about the Project and provide comments on
environmental issues addressed in the EIS. Ninety-five people provided verbal comments at the
scoping meeting. Transcripts of the scoping meeting have been entered into the public record for
the Project, under Docket No. PF15-15-000.
On August 12, 2015, the FERC’s staff participated in a site visit of the Project site along
with representatives from the FWS, NPS, and Annova. On August 12, 2015, the FERC’s staff also
held an interagency meeting to solicit comments and concerns regarding the Project from other
jurisdictional agencies. In addition to the FERC’s staff, representatives from four federal and state
agencies were present at this meeting including the FWS, Coast Guard, NPS, and Texas Parks and
Wildlife Department (TPWD). On February 4, 2016, the FERC’s staff participated in a second
site visit that included representatives from the FWS, NPS, EPA, FAA, NOAA Fisheries, TPWD,
and the Texas Historical Commission (THC).
On August 4, 2015, FERC staff issued a letter to the U.S. Department of Defense requesting
comments on whether the Project could potentially have an impact on the test, training, or
operational activities of any active military installation. On September 18, 2015, the U.S.
Department of Defense Siting Clearinghouse responded stating that, based on an informal review,
the Project would have minimal impact on military training and operations conducted in the area.
On December 16, 2015, December 1, 2016, July 19, 2017, and May 2, 2018, we issued a
Project update to inform the public and agencies of the status of the FERC review process. These
documents, as well as all documents and comments submitted as a part of the Project pre-filing and
application processes, are publicly available online at www.ferc.gov/docs-filing/ elibrary.asp.
We developed a mailing list for the Project that includes nearby landowners, federal, state,
and local officials; agency representatives; conservation organizations; local libraries and
newspapers, and tribal representatives. The mailing list also includes parties that have commented
on the Project and that provided a complete mailing address with their comments. The mailing list
has been maintained since the start of the pre-filing process and is included in Appendix A.
Table 1.3-1 lists the environmental issues that were identified during the scoping process
described above, as well as comments received in response to our Notice of Application issued on
July 27, 2016. Table 1.3-1 also indicates the section of this EIS in which each issue is addressed.
Additional issues that we independently identified are also addressed as appropriate in this EIS.
1-11 Introduction
Additionally, many comments raised concerns that are outside the scope of this EIS. Examples
include comments concerning unconventional natural gas production (“fracking”), induced
production of natural gas, development of a programmatic EIS for export terminals, and economic
impacts of export of LNG. These issues were not addressed in our analysis, but we’ve provided
responses to these comments in appendix L if they were filed in response to the draft EIS.
TABLE 1.3-1
Issues Identified and Comments Received During the Scoping Process for the Annova LNG Project
Percent of EIS Section
Topic/Sub-Topics
Comments Addressing Comment
General 20% Chapter 1 and 2
Purpose and Need of the Project
Mitigation for all impacted resources
Abandonment plan and identification of company liability
Right of eminent domain
Out of scope comments
General support/opposition to the Project
Alternatives <1% Chapter 3
Alternative facility locations
Alternative Project design and layout
Alternative placement or use of dredged materials
Renewable energy alternatives
Geology and Soils <1% 4.1
Use of fill materials to stabilize the site
Potential for toxic sediments in dredging area
Water Resources <1% 4.3
Impacts on surface waters, including drainage patterns and water quality
Impacts on ground water, including local wells
Water use during construction and operation
Surface water and groundwater contamination
Hydrostatic testing
Impacts associated with ballast water
Wetlands 10% 4.4
Impacts on wetlands, including their function and values
Impacts on the Bahia Grande wetland restoration site
Vegetation <1% 4.5
Impacts on vegetation including sensitive resources (e.g., lomas)
Development of an invasive species control plan for terrestrial and aquatic species
Wildlife and Aquatic Resources <1% 4.6
Impacts on terrestrial wildlife
Impacts on migratory birds
Impacts on waterbirds
Impacts on marine mammals
Impacts on aquatic species (e.g., fisheries and marine invertebrates)
Impacts on nocturnal species
Impacts on unique, pristine, or sensitive wildlife habitats
Impacts of habitat loss on fauna
Threatened and Endangered Species 10% 4.7
Impacts on federal and state listed species
Impacts on the piping plover, Aplomado falcon, marine mammals, sea turtles, ocelot
(including the migration corridor), and jaguarondi.
Measures to avoid/minimize impacts on listed species
Land Use, Recreation, and Aesthetics 11% 4.8
Location of the Project near incompatible land-uses (e.g., National Wildlife Refuges,
Boca Chica State Park, Brazos Island State Park, Bahia Grande wetland
restoration site, Las Palomas Wildlife Management Area, South Bay Texas
Coastal Preserve, and SpaceX)
Visual impacts of the Project on adjacent lands and uses (comments specifically
called-out the following areas: boy-scout camps, Boca Chica Boulevard;
Brownsville-Port Isabel Highway, Isla Blanca Beach; Schlitterbahn Waterpark;
Jaime Zapata Boat ramp, Palmito Ranch Battlefield, South Bay Coastal
Preserve, Resaca de la Palms NHL)
Light pollution levels and their extent
Impacts on recreational fishing and boating
Impacts on tourism and recreation
Introduction 1-12
TABLE 1.3-1 (continued)
Issues Identified and Comments Received During the Scoping Process for the Annova LNG Project
Percent of EIS Section
Topic/Sub-Topic
Comments Addressing Comment
Socioeconomics 24% 4.9
Economic impacts on the local economy and taxes
Potential effects on recreation and tourism industry (including ecotourism)
Available workforce
Economic impacts of LNG exports on local and global prices
Impacts on property values
Impacts on insurance rates
Impacts on local job growth
Impacts on public services
Impacts on commercial fishing/shrimping
Impacts on agricultural areas
Impacts on communities covered by Environmental Justice regulations
Transportation and Traffic <1% 4.9
Impacts of construction on access to roads and areas in the region
Safe navigation of the BSC
Impacts of LNG ship traffic and security zones on existing ship traffic
Maintaining vehicular access to recreational areas
Cultural Resources <1% 4.10
Impacts to cultural sites within the Rio Grande Watershed, including need to consult
with local resources and entities
Air Quality 12% 4.11
Air quality attainment status
Fugitive dust mitigation
Greenhouse gas emissions and mitigation
Climate change
Impacts of hazardous chemical air pollutants on human health
Impacts of the flares on air quality
Noise <1% 4.11
Impacts from noise during construction
Impacts from noise during operations
Reliability and Safety 11% 4.12
Emergency response and evacuation plan
Spill contingency plan
Hurricane and earthquake response plan
Procedures to maintain worker safety
Emergency notification systems
Catastrophic system failures
Risk of hazardous spills to occur
Potential for the Project to be a terrorist target
Proximity to SpaceX
Proximity to a densely populated area
The company’s past safety record
Cumulative Impacts <1% 4.13
The cumulative effect of multiple LNG facilities being approved along the BSC
The cumulative effect of this Project combined with other actions/facilities in the area
(such as SpaceX).
The need to include the associated LNG pipelines in the analysis
Induced natural gas production or increased hydraulic fracturing
Effect of predicted sea-level rise on the Project
1-13 Introduction
Public Review of Draft and Final EIS

We issued a Notice of Availability of the Draft Environmental Impact Statement for the
Proposed Annova LNG Brownsville Project (NOA) on December 14, 2018. The draft EIS was
filed with the EPA, and a formal notice of availability was issued in the Federal Register on
December 21, 2018, indicating that the draft EIS was available online. 4 The NOA was mailed to
1,992 federal, state, and local government agencies; elected officials; Native American tribes; local
libraries and newspapers; and other interested parties (i.e., individuals who provided scoping
comments or asked to be on the mailing list). The distribution list for the NOA was included as
appendix A of the draft EIS. The NOA established a comment period on the draft EIS that ended
on February 4, 2019. The notice described procedures for filing comments on the draft EIS and
how information about the Projects could be found on the FERC’s website. On February 7, 2019,
we issued a Notice of Reopening of Comment Period that extended the comment period to March
13, 2019 due to the funding lapse at certain federal agencies between December 22, 2018 and
January 25, 2019.
We held one public comment session during the draft EIS comment period, held on January
10, 2019 in Port Isabel, Texas. The comment session provided interested parties with an
opportunity to present verbal comments on our analysis of the environmental impacts of the Project
as described in the draft EIS. A total of 40 people commented at the session. In addition, we
received over 1,200 comment letters in response to the draft EIS. All environmental comments on
the draft EIS have been addressed in this final EIS. A transcript of the comment session and copies
of each written comment are part of the public record for the Project. Our responses to comments
are provided in appendix L of this final EIS. A subject index is provided in appendix M.
Substantive changes in the final EIS are indicated by vertical bars that appear in the margins. The
changes were made both in response to comments received on the draft EIS and as a result of
updated information that became available after the issuance of the draft EIS.
The Commission’s Notice of Availability for this final EIS is being mailed to the agencies,
tribes, individuals, and organizations on the distribution list shown in appendix A. The Notice of
Availability includes information on how this final EIS may be viewed and downloaded from the
FERC website. This final EIS is being concurrently filed with the EPA for issuance of a formal
public notice of availability in the Federal Register. In accordance with CEQ’s regulations
implementing NEPA, no agency decision on a proposed action may be made until 30 days after
the EPA publishes a notice of availability for this final EIS. However, the CEQ regulations provide
an exception to this rule when an agency decision is subject to a formal internal process that allows
other agencies or the public to make their views known. In such cases, the agency decision may
be made at the same time the notice of this final EIS is published, allowing both periods to run
concurrently.
Should the Commission issue an authorization and Certificate to Annova for the proposed
action, it would be subject to a 30-day rehearing period. Therefore, the Commission may issue its
decision concurrently with issuance of the final EIS.
4
83 Fed. Reg. 65650 (2018) Document 2018-27638
Introduction 1-14
NON-JURISDICTIONAL FACILITIES
Under Section 7 of the NGA, the FERC is required to consider, as part of a decision to
authorize jurisdictional facilities, all facilities that are directly related to a proposed project where
there is sufficient federal control and responsibility to warrant environmental analysis as part of
the NEPA environmental review for the proposed project. Some proposed projects have associated
facilities that do not come under the jurisdiction of the Commission. These “non-jurisdictional”
facilities may be integral to the need for the proposed facilities, or they may be merely associated
as minor components of jurisdictional facilities that would be constructed and operated as a result
of authorization of the proposed facilities. Non-jurisdictional facilities associated with the Project
are addressed below as well as in our cumulative impacts analysis in section 4.13 of this EIS.
Natural Gas Supply Lateral

The Project would receive natural gas supply from an as yet undetermined third-party–
owned and –operated intrastate pipeline that would connect to the Valley Crossing Pipeline
System. This information was gathered from a COE permit application a copy of which was filed
with FERC. The approximately 9-mile-long, 36-inch-diameter natural gas supply lateral would
begin at an existing Valley Crossing compressor station north of Highway 48 within the boundary
of the Port of Brownsville, cross the BSC, and continue generally south and then east to the Project
site. The supply lateral would be an intrastate pipeline and therefore would not be under the
FERC’s jurisdiction. The general location of the supply lateral is shown on figure 1.4.1-1.
We received numerous comments on the draft EIS questioning the ability of the Valley
Crossing Pipeline system to supply natural gas to the Annova LNG Project, with some commenters
citing statements made by Valley Crossing Pipeline that it is not designed to supply natural gas to
LNG projects. On March 15, 2019, we requested that Annova respond to these concerns. In its
response filed March 25, 2019 (accession number 20190325-5179), Annova acknowledges that
design changes to the Valley Crossing Pipeline system would be required to accommodate the
natural gas supply required for the Annova LNG Project. Annova anticipates the design changes
could include expansion of the Valley Crossing receipt header system and addition of
approximately 150,000 hp of new compression.
Natural Gas Interconnection Facilities

Annova would take custody of natural gas delivered to the LNG terminal through
interconnection and metering facilities constructed and operated by the owner and operator of the
natural gas supply lateral. The interconnection facilities would be located in a 200-foot by 300-foot
fenced yard within the southwest corner of the proposed LNG terminal site. The interconnection
facilities would include valves and gas measurement devises, and related instrumentation and
communications equipment. The interconnection facilities would also provide the necessary
infrastructure for the supply lateral to measure and receive compressed boil-off gas (BOG) from the
Project. The location of the natural gas interconnection facilities is shown on figure 1.4.2-1.
1-15 Introduction
Figure 1.4.1-1 General Location of the Natural Gas Supply Lateral
Introduction 1-16
Figure 1.4.2-1 Location of Natural Gas Interconnection Facilities
Electric Transmission Line and Switchyard

The South Texas Electric Cooperative (STEC) would provide the electric transmission
service to the Project. Supplying power to the Project would require a tie-in to STEC’s existing
transmission system and construction of a new electric transmission line to the Project site. Project
power service needs would require:
• modifications of the existing Highway 511 and Waterport Electric Substations to

provide interconnection to the new 138-kilovolt (kV) line;
• construction of a new 138-kV switchyard within the Project site; and
• installation of a new 138-kV line between the existing STEC system and the new
switchyard.
STEC would permit, construct, own, operate, and maintain the new transmission line and
switchyard. Annova indicates that STEC would conduct a routing study, including a public
information meeting, and analyze several potential routes for the new transmission line, and would
1-17 Introduction
then file an application for the facilities with the Public Utility Commission (PUC) of Texas to
initiate the regulatory process. The PUC would then select the final location of the transmission
line route. Annova anticipates that STEC will file an application with the PUC in 2019. Pending
completion of the review and approval, STEC would need to complete construction of the electric
transmission line and switchyard prior to operation of the Project.
The new 138-kV transmission line would be approximately 15 miles long. The poles
supporting the transmission line wires would be 90 to 110 feet in height and spaced approximately
600 feet apart within a right-of-way width of about 100 feet. Annova identified a potential route
for the transmission line for the purpose of describing non-jurisdictional facilities and evaluating
cumulative impacts. See figure 1.4.3-1.
Potable Water Pipeline

Annova would obtain potable water to support construction and operation of the Project
through a water pipeline that would be constructed and operated by the Brownsville Navigation
District (BND). The new water pipeline would be an extension of an existing water pipeline and
would be about 5.9 miles long. Annova identified a potential route for the water pipeline for the
purpose of describing non-jurisdictional facilities and evaluating cumulative impacts. See figure
1.4.4-1.
Introduction 1-18
Figure 1.4.3-1 Potential Route for 138-kV Electric Transmission Line
1-19 Introduction
Figure 1.4.4-1 Potential Route for Potable Water Pipeline
Introduction 1-20
PERMITS, APPROVALS, AND REGULATORY REVIEWS

As the lead federal agency for the Project, the FERC is required to comply with various
federal environmental laws and regulations, including but not limited to, the ESA, the MSA, the
NGA, the NHPA, and the Coastal Zone Management Act of 1972 (CZMA). In addition, Annova’s
Project is subject to the RHA, the CWA, the CAA, the Federal Aviation Act of 1958, the MTSA,
and the National Flood Insurance Act of 1968 (NFIA). Each of these statutes has been taken into
account in the preparation of this document.
Major permits, approvals, and consultations for the Project are identified in table 1.5-1 and
discussed below. The FERC encourages cooperation between applicants and state and local
authorities, but this does not mean that state and local agencies, through applications of state and
local laws, may prohibit or unreasonably delay the construction or operation of facilities approved
by the FERC. Any state or local permits issued with respect to jurisdictional facilities must be
consistent with the conditions of any authorization issued by the FERC.
TABLE 1.5-1
Environmental Permits and Agency Reviews for the Annova LNG Brownsville Project
Agency Regulation/Permit/Approval Agency Actions Submission Date/Status
Federal
NEPA review, federal agency
Authorization under Section Annova submitted application on July 13,
FERC consultations, and consider
3(a) of the NGA 2016.
issuance of authorization
Annova submitted application on July 21,
2016; on May 21, 2018 the COE requested
additional information on the supply
pipeline; on July 31, 2018 the COE notified
Annova application was withdrawn without
Section 404 of the CWA;
Consider issuance of Section prejudice pending receipt of information on
COE Section 10 of the Rivers and
404/10 Individual Permit the supply pipeline. On November 21,
Harbors Act
2018, Annova submitted application for the
supply pipeline, on December 3, 2018 the
COE acknowledged receipt of applications.
On December 27, 2018 the COE issued
Public Notice No. SWG-2015-00110.
Annova submitted Preliminary Waterway
33 CFR 105; 33 CFR 127;
Suitability Assessment to Coast Guard on
Notice to mariners; Consider issuance of Letter
Coast Guard February 23, 2015; on February 13, 2018,
Maritime Transportation of Recommendation
the Coast Guard issued LOR stating the
Security Act
BSC is suitable for LNG marine traffic.
NPDES Stormwater Annova would provide notification prior to
Construction General Permit construction, anticipated 2018.
Consider issuance of NPDES
Annova anticipates application to be
EPA NPDES Hydrostatic Testwater
submitted 2020.
Discharge Permit
Consider issuance of NPDES Annova anticipates application to be
Industrial Wastewater Permit submitted 2021.
Annova submitted initial consultation
request letter to FWS on March 27, 2015;
followed by correspondence and meetings
Threatened and endangered
Section 7 of the ESA between Annova and FWS (see complete
species consultation
list filed by Annova in accession number
20180119-5058). The FERC submitted BA
FWS to the FWS on February 15, 2019.
Annova submitted request for use of
access road to conduct surveys on April 18,
Crossing or use of National 2016; follow-up responses and submittals
Special Use Permit
Wildlife Refuge lands occurred through December 2017 (see list
filed by Annova in accession number
20180119-5058).
1-21 Introduction
Environmental Permits and Agency Reviews for the Annova LNG Brownsville Project
Agency Regulation/Permit/Approval Agency Actions Submission Date/Status

request letter to NOAA Fisheries Habitat
Section 7 of the ESA;
Protection Division, and Protected
Section 305 of the MSA; Marine threatened and
Resources Division, on March 27, 2015.
NOAA Fisheries Marine Mammal Protection Act; endangered species
On February 5, 2019 NOAA Fisheries
Fish and Wildlife Coordination consultation
notified FERC that it has no
Act
Conservation Recommendations for EFH
and EFH consultation is complete.
Annova is proposing no structures that
Notice of proposed require this notice. Annova received FAA
Federal Aviation Section 1101 of the Federal construction of a structure notice for temporary construction cranes.
Administration Aviation Act exceeding airspace Notice may be required for LNG carriers
obstruction standards if height exceeds other vessels that
normally traverse the BSC.
Consider authorization to Annova submitted application on October
export LNG to Free Trade 9, 2013. DOE granted authorization on
Agreement countries February 20, 2014.
Section 3 of the NGA;
DOE Annova submitted application on
15 USC Section 717b Consider authorization to
February 26, 2019, and supplement on
export LNG to Non-Free
March 13, 2019. The application is
Trade Agreement countries
pending with DOE.
State
Review concurrent with COE CWA
Consider Issuance of Water
Section 401 of the CWA; Section 404 permit application. See
Railroad Quality Certification
status above.
Commission of
Determine Consistency with Review concurrent with COE CWA
Texas Coastal Zone Management
Coastal Zone Management Section 404 permit application. See
Program
Program status above.
Annova submitted air permit application
to TCEQ in January 2017; TCEQ issued
Declaration of Administrative
PSD Air Permit for
Completeness on January 25, 2017;
Construction
Annova submitted air quality impact
Texas Council modeling report to TCEQ on July 31,
on Texas Clean Air Act; CAA; 2017.
Environmental 40 CFR 50-99 Consider issuance of Title V Annova anticipates submitting
Quality Operating Permit application in 2020.
Consider issuance of Temp. Annova anticipates submitting
Water Rights Permit application prior to construction.
Consider issuance of
Annova anticipates submitting
Permanent Water Rights
application in 2020.
Permit
Annova submitted bathymetric survey
report for ship channel impacts to THC
Comment on archaeological
Texas Historical Section 106 of the NHPA; on August 4, 2015; and draft reports for
investigations within Area of
Commission Antiquities Code of Texas Project site to THC on September 2,
Potential Effect
2015. THC provided comments on
Project site report on October 1, 2015.
Chapters 67, 68, and 88 of
Texas Parks and Wildlife Code, Comment on potential
request letter to TPWD on March 27,
TPWD and Sections 65.171 - 65.176 of impacts on state-listed
2015. TPWD provided response on July
Title 31 of the Texas species
30, 2015.
Administrative Code
Local
Consider issuance of
44 CFR 60 Floodplain Annova anticipates submitting
Commercial Construction
Management application prior to construction.
Cameron County and Floodplain Permit
On-Site Sewage Facility Consider issuance of On- Annova anticipates submitting
Requirements Site Sewage Facility Permit application prior to construction.
Introduction 1-22
2.0 DESCRIPTION OF PROPOSED ACTION

The Project consists of a new natural gas liquefaction and LNG export terminal located in
Cameron County, at approximate mile marker 8.2 on the BSC, near Brownsville, Texas. The
Project includes two principal parts: the LNG facilities and the associated marine transfer facilities.
The LNG facilities are designed to receive 900 million cubic feet per day of natural gas from a
third party–owned and –operated non-jurisdictional intrastate pipeline lateral. The natural gas
would be treated, liquefied, and stored on-site in two single-containment LNG storage tanks, each
with a net capacity of approximately 160,000 cubic meters (m3). The LNG would be pumped from
the storage tanks to the marine transfer facilities where it would be loaded onto LNG carriers at
the berthing dock using cryogenic piping.
A general location map of the Project is provided as figure 1-1 and a general site plan is
provided as figure 1-2. The following sections describe the proposed facilities associated with the
Project, construction procedures and schedule, environmental compliance and inspection
monitoring, operation and maintenance procedures, safety controls, and land requirements.
PROPOSED FACILITIES
Combined, Annova’s proposed facilities are characterized as an LNG terminal. The LNG
terminal would be made up of various component facilities, the details of which are described
below.
Gas Pretreatment Facilities

Pipeline quality natural gas consists primarily of methane, with smaller amounts of ethane
and propane; with small amounts of heavier hydrocarbons. Pipeline quality natural gas also
contains trace amounts of other constituents such as carbon dioxide (CO2), nitrogen, water, and
sulfur. The pretreatment process would remove constituents that would freeze during the
liquefaction or affect the liquefaction process, primarily CO2, hydrogen sulfide (H2S), water,
mercury, and heavy hydrocarbons.
An amine treatment system would remove CO2 and H2S (i.e., acid gases) from the natural
gas stream. The amine would be regenerated to release the absorbed acid gas. The acid gas would
then be routed through a sulfur removal unit to remove H2S before being incinerated in the thermal
oxidizer. The natural gas stream would then pass through a dehydration system to remove water
using a molecular sieve and solid adsorbents, and downstream of the dehydration system an
activated carbon bed would remove any trace amounts of mercury. Any mercury or nongaseous
H2S captured during gas pretreatment would be handled and disposed of by licensed personnel per
applicable federal and state regulations, including 40 CFR Parts 239-282 Resource Conservation
and Recovery Act (RCRA) and 30 TAC 335, Industrial Solid Waste and Municipal Hazardous
Waste.
Liquefaction Facilities
Annova would utilize Black & Veatch’s PRICO® technology for natural gas liquefaction.
The liquefaction facilities would be primarily electrically powered, and essential components of
the liquefaction facilities would include refrigeration through compression and removal of heat.
2-1 Description of Proposed Action

By cooling to a temperature of minus 260 degrees Fahrenheit (°F), the methane stream from the
Gas Treatment Facilities would change from a gas to a liquid.
The liquefaction facilities would consist of six liquefaction trains, with each train
employing a closed-loop refrigeration system using a mixed refrigerant consisting of nitrogen and
a combination of hydrocarbons such as methane, ethane or ethylene, propane, butane, and pentane.
Power for the liquefaction process would be grid-sourced electricity. There would be one 72,000-
hp electric motor-driven compressor per liquefaction train to provide needed compression.
Heavy hydrocarbons would be removed at an intermediate temperature during the

liquefaction process. Heavy hydrocarbon vapors would be routed to the fuel gas system. Heavy
hydrocarbon liquids would be stored in a condensate storage tank and would be moved off-site via
truck for sale or disposal by licensed personnel per applicable federal or state regulations. The
condensate storage tank would be 40 feet in diameter and 30 feet in height and painted a dull green
color (“covert green”) to reduce visual impacts. No other byproducts would result from the
liquefaction process.
After removal of heavy hydrocarbons, the refrigeration process would cool the gas further.
LNG would exit the liquefaction train and enter an LNG expander to reduce the system pressure
to atmospheric pressure, which would further lower the LNG temperature before placement into
LNG storage tanks.
LNG Storage Tanks

The LNG would be stored in two single-containment LNG storage tanks, each designed to
store approximately 160,000 m3 to provide sufficient inventory to accommodate the anticipated
loading schedule for typical LNG carriers. Each tank would consist of a primary inner container
of 9 percent nickel steel and an outer container of carbon steel. To reduce visual impacts the outer
container would be painted a dull green color (“covert green”, see artist rendering inset photo on
the cover of this EIS). The insulation in the annular space between the inner and outer containers
would consist of expanded perlite and resilient glass wool. The LNG storage tanks would maintain
the LNG at minus 260°F.
The tank foundations would be concrete supported by piles and elevated approximately
6 feet above ground level. This design would prevent freezing of the ground by allowing ambient
air to flow underneath the tanks and eliminate the need for a heating system within each tank
foundation. The height of each LNG storage tank would be approximately 186 feet above grade
and would have a diameter of approximately 260 feet. In addition, a 15-foot-tall winch crane on
the top of each LNG storage tanks would be used for maintenance purposes. Figure 2.1.3-1 shows
the major components of a typical single-containment LNG storage tank.
49 CFR Part 193.2181 specifies that the impoundment system around the LNG storage
tanks must contain 110 percent of the maximum liquid capacity in one LNG storage tank. An
engineered earthen berm around each LNG storage tank would contain 110 percent of the tank
capacity of stored LNG. The top elevation of the containment berms would be approximately +36
feet (elevations in North American Vertical Datum of 1988 [NAVD88]).
Description of Proposed Action 2-2

Figure 2.1.3-1 Typical Single-Containment LNG Storage Tank
Boil-Off Gas Handling System

During normal operation, a portion of the produced LNG vaporizes and is referred to as
boil-off gas, or BOG. BOG results from changes in pressure and ambient heat gain during the
transfer of LNG from storage tanks to an LNG carrier, and displacement of vapors returned from
loading to an LNG carrier.
The BOG handling system would recover these vapors for reliquefaction or use as fuel gas.
Because the gas must be compressed before being returned to the liquefaction process, there would
be one BOG compressor plus a stand-by compressor for each liquefaction train. Also, a separate
pipeline compressor would compress the BOG for re-injection back into the intrastate pipeline
lateral as per contractual terms during periods when the BOG system is not operating.
Flare System
Flaring would be required during commissioning, cool downs, start-up, planned
maintenance shutdowns, and during certain LNG carrier loading operations. The flare system
would include a cold flare system, a warm flare system, and a marine flare system. The cold flare
system would collect dry or cryogenic fluids (i.e., liquefied gases maintained at cryogenic
temperatures) relieved from the liquefaction trains. The warm flare system would collect wet or
non-cryogenic relief fluids (i.e., fluids that are liquid at non-cryogenic temperatures) during plant

start-up or conditions other than normal operation. The marine flare would operate during the
transfer of LNG to an LNG carrier that is arriving at port with warm LNG cargo tanks, which
typically occurs on the first visit following dry dock. Each flare system would have separate
multiple flare pilots and redundant flame-detection systems to ensure integrity. There would be
two flare stack structures, a single combined warm and cold flare measuring 160 feet in height,
and a marine flare measuring 45 feet in height. The flare stacks would be painted a dull green
color (“covert green”) to reduce visual impacts.
Flaring from the warm/cold flare stack would occur during initial Project start-up and
intermittently during subsequent routine operation. During routine operation, flaring would only
occur during planned maintenance, shutdown, and start-up (MSS) events, which would be
scheduled to occur during daytime hours. Although not planned, MSS flaring during nighttime
may occasionally occur. Annova estimates that flaring would occur at intervals of once every 6
months, once every 2 to 4 years, and once every 10 years for various MSS activities. MSS flaring
would typically occur for up to 12 hours each year (i.e., 6 hours for each biannual MSS event) with
a worst-case scenario of up to 40 hours during a year when all MSS flaring events coincide. In
that case, the 40 hours would be discontinuous, occurring intermittently during the year.
Flaring from the marine flare would occur during the transfer of LNG from the marine
terminal to an LNG carrier that arrives with warm cargo tanks. LNG initially introduced into warm
LNG carrier tanks would vaporize to produce gas in sufficient volume requiring treatment by
flaring before discharge to the atmosphere. Annova estimates these marine flaring events would
occur up to two times per year, with the flaring operating continuously for up to 25 hours per event
for an annual total of up to 50 hours per year. Because the marine flare would operate continuously
for up to 25 hours, nighttime flaring would occur approximately twice per year.
Marine Facilities
The marine facilities would include a 1,500-foot-diameter turning basin and widened
channel approach areas to the turning basin. LNG carriers would dock on the loading platform at
the south side of the turning basin. The marine facilities would also include a material offloading
facility (MOF) on the west side of the berth. The MOF would accommodate delivery by barge of
major equipment and modular plant components during construction and would also be maintained
for use during operation as needed. The marine facilities include the following components:
• loading platform and berth for one LNG carrier, including turning basin and access
areas along the BSC;
• cryogenic pipelines and vapor return lines;
• aids to navigation;
• MOF;
• mooring dolphins;
• breasting dolphins;
• fire protection equipment; and
• tug berth area.

LNG transfer would occur through one cryogenic loading line positioned on the north side
of the LNG storage tanks. The design loading rate would be a maximum of 13,500 m3 per hour.
The loading platform would include four 16-inch-diameter marine loading arms: two for loading
LNG to the LNG carriers, one for vapor return to the LNG storage tanks, and one dual-service arm
capable of loading LNG or returning vapor. The vapor return line would transfer BOG from the
LNG carrier to the BOG compressors. Each loading arm would be fitted with a hydraulically
interlocked double ball valve and powered emergency release coupling to isolate the arm and the
ship in the event of any condition requiring rapid disconnection.
Control, Administrative, and Support Buildings

The proposed LNG facilities include a control room, administration building, guard
building, maintenance workshop, and various equipment shelters. The control room would include
control and monitoring stations for facility operators as well as instrumentation, electrical
equipment, and power systems. The administration building would include personnel offices,
meeting rooms, workstations, a break room, and restroom facilities. The guard building would
house guard staff at the entrance gate to the facility. The maintenance workshop would be co-
located with the administration building and would support repairs and maintenance of facility
equipment. Equipment shelters would consist of firewater pump shelters, generator shelters,
electric motor control center enclosures, compressor shelters, and additional small buildings
designed to comply with safety standards and guidelines.
Access Road
Annova would construct one new access road off State Highway 4 (Boca Chica Boulevard)
that would be used as the access road for both construction and operation. Initially, an existing
unpaved road would provide temporary access until construction of the permanent main access
road is complete. The site plan also includes interior plant roads that would be used to access
facility components, the marine berth, and site perimeter. Figure 2.1.8-1 shows the location of the
access road.
In its application, Annova identified two options for the location of the site access road.
Annova stated that access road alternative 2 is preferred; however, either road would be feasible.
In a data request dated October 20, 2016, we requested clarification for which alternative Annova
considers the proposed access road. In response, Annova confirmed that access road option 2 is
the proposed access road, and alternative 2 is evaluated in this EIS as the proposed action. The
alternative access road location is evaluated in section 3 of this EIS. Figure 3.5-1 shows the
locations of access road alternatives.

Figure 2.1.8-1 Access Road Location

The proposed width of the access road is the result of several factors, including raising the
road elevation as needed to be above the 100-year flood elevation, and Cameron County standard
specifications for rural roads more than 2 miles in length. Annova anticipates that two, 12-foot-
wide paved travel lanes would be required to accommodate regular two-way industrial traffic,
including tractor-trailers. Each side of the road would also have a 10-foot-wide gravel shoulder
able to accommodate a disabled tractor-trailer without blocking incoming or outgoing traffic.
Installation of fill needed to raise the road elevation to meet Cameron County specifications for a
100-year flood event would result in an additional width of 46.5 feet on either side of the road.
Construction would also disturb 10 additional feet on either side of the access road. In total, this
would result in a 157-foot-wide construction impact, and a 137-foot-wide operational impact for
the access road. Figure 2.1.8-2 shows a typical cross section of the proposed access road.
Figure 2.1.8-2 Typical Access Road Cross Section
Fencing and Barrier Wall

Fencing would consist of the two different types of fencing. The perimeter of the
maintained LNG facilities would be surrounded by an approximately 7-foot-tall chain-link security
fence with 1 foot of barbed wire at the top. This fence would prevent access to the facility except
through a controlled gate. A second fence farther away from the LNG facilities would be installed
around the boundary of the real estate lease option agreement area with the BND (shown as
Property Boundary on figure 1-2), which would consist of a smooth-wire boundary fence (cattle-
type fence with two to three wires spaced apart). This fence would mark the property and deter
trespassing but would not inhibit wildlife movement.
As a result of consultation with the FWS regarding potential impact on wildlife movement,
Annova revised the site plan to include an undisturbed corridor of vegetation in the southwest side
of the site, between the outer smooth wire boundary fence and the inner chain-link security fence,
to allow for potential ocelot movement through the area. Annova proposes to install approximately
6,000 feet of barrier wall along the west edge of the inner security fence, between the maintained
LNG facilities site and the wildlife corridor, to reduce light and noise impacts on wildlife using
the corridor. The barrier wall would generally follow what is shown on figure 1-2 as the

westernmost Limit of Disturbance. The barrier wall would consist of posts drilled into the ground
and approximately 25-foot-tall concrete panels between the posts painted a dull green color
(“covert green”) to reduce visual impacts. The barrier wall would include three-inch-high cut outs
spaced along the base of the wall to allow for stormwater drainage.
Utilities
Power
Annova would use power from the electric grid to operate the facility, including motor drives
for refrigeration compressors. STEC would deliver power to an electrical switchyard located within
the Project site through a new 138-kV electric transmission line that would be permitted, constructed,
owned, operated, and maintained by STEC (see discussion of non-jurisdictional facilities in section
1.4). The switchyard would include switching, protection, and control equipment, as well as
transformers and a grounding system. The Project would also include a standby generator and
uninterruptable power supplies to ensure back-up power would be available for critical loads and for
safe shutdown of the facility in the event of loss of the STEC power supply.
Potable Water
Potable water would be delivered by the BND through an underground pipeline and stored
on the site. During construction, Annova would use potable water for hydrostatic testing of pipes
and some tanks, drinking water, soil conditioning, and dust control. Annova would not use potable
water for hydrostatic testing of LNG storage tanks. During operation, Annova would use potable
water for demineralized water, staff drinking water, sanitation, and for testing of the fire water
system. See additional discussion of the non-jurisdictional water supply pipeline in section 1.4.
Communication
The telecommunication systems for the Project would include a telephone exchange, radio
system, computer network, plant telecommunications network, e-mail system, and closed-circuit
television system. All telecommunication systems required for Project construction and operation
would comply with applicable governmental rules and regulations. In addition, marine band very-
high-frequency radios would provide for communication with the LNG carriers.
LNG CARRIERS
A maximum of 125 LNG carriers per year are anticipated to call on the Annova LNG
terminal, based on the maximum output at optimal operating conditions of the facility. 5 The LNG
carriers that would transit to and from the terminal are expected to be foreign-flagged and are not
under the jurisdiction of the Commission. As discussed in section 1.2.3, on February 13, 2018,
the Coast Guard issued an LOR that recommended that the BSC be considered suitable for
accommodating the type and frequency of LNG marine traffic associated with the Project. The
Project would be designed to accommodate 138,000 m3 to 177,000 m3 LNG carriers. Smaller or
larger LNG carriers than this range would require confirmation of the carrier’s compatibility with
5
The Coast Guard LOR estimated an average of 2 to 6 LNG carriers per month would call on the terminal, up to a
maximum of 80 carriers per year; however, Annova’s WSA is based on an estimate of up to 125 LNG carriers per
year, and therefore we are including the maximum of up to 125 per year in this EIS.

the marine facility design characteristics and that the carrier’s mooring system meets the Oil
Companies International Marine Forum (OCIMF 2008) requirements.
The ships that transport LNG are specially designed and constructed to carry LNG for long
distances. LNG carrier construction is highly regulated and consists of a combination of
conventional ship design and equipment, with specialized materials and systems designed to safely
contain liquids stored at a temperature of –260°F. Additional information on LNG carrier
regulations and safety measures is presented in section 4.12.
LAND REQUIREMENTS
Annova estimates that approximately 550 acres would be affected by construction of the
LNG terminal facilities and access road. Operation of the Project would affect approximately 412
acres. Table 2.3-1 lists the land requirements for the Project by facility.
TABLE 2.3-1
Land Requirements for the Annova LNG Brownsville Project

Land Water Total Area
Land Impacted Water Impacted Total Area Impacted
Impacted by During Impacted by During Impacted by During
Construction Operation Construction Operation Construction Operation
Facility (acres) (acres) (acres) (acres) (acres) (acres)
LNG Terminal, Land-Based
363 327 1 0 364 327
Facilities
Marine Facilities 37 16 21 a/ 21 a/ 58 37
Temporary Access Road 14 0 0 0 14 0
Permanent Access Road 55 48 0 0 55 48
Brownsville Ship Channel a/ 0 0 59 0 59 0
Total 469 391 81 21 550 412
a/ Impact related to dredging within the BSC for the proposed turning basin. This area is submerged and is not
vegetated; therefore, this value is not included in the impact values reported in the vegetation, wetland, land-use, or
soil sections of section 4.
CONSTRUCTION SCHEDULE AND WORKFORCE

As previously indicated, on September 10, 2018, Annova filed with the Commission an
updated Project development schedule that included an estimated start of commercial operation in
2024. Annova estimates the total construction period would be about 48 months, from the start of
site ground work for the first stage, to completion of structural, mechanical, and electrical
installations for the last stage. The Project would be commissioned to allow commercial operation
to start in three stages of two trains each, with the first commissioning activities for the first two
trains overlapping the later construction activities.
The construction workforce would peak at 1,200 personnel during the height of
construction, with an average of 700 on-site workers per month. Annova anticipates that about
65 percent of the average 700 on-site jobs would be hired from the local area (see section 4.9.1).
Annova states that most construction would occur for 50 hours per week Monday through Friday,

and work would not take place on federal holidays. Dredging for the marine berth is estimated to
occur in two, 10-hour shifts, 6 days per week.
Annova is proposing to use some prefabricated components, assembled off-site, to reduce

on-site construction time and on-site lay-down space. Components that are prefabricated off-site
would be delivered by barge or ocean-going cargo vessels and may include the liquefaction trains,
gas pretreatment units, BOG compressors, and pipe racks. The modules would be prefabricated
and preassembled at existing commercial facilities.
ENVIRONMENTAL COMPLIANCE AND MONITORING

The FERC may impose conditions on any authorization it may grant for the Project. These
conditions may include additional requirements and mitigation measures recommended in this EIS
to minimize the environmental impact that would result from construction and operation of the
Project (see individual recommendations in various discussions in section 4 and a complete listing
of recommendations in section 5.2).
Annova developed a Project-specific Upland Erosion Control, Revegetation, and

Maintenance Plan (Annova Plan) and Wetland and Waterbody Construction and Mitigation
Procedures (Annova Procedures) based, respectively, on FERC’s Upland Erosion Control,
Revegetation, and Maintenance Plan (FERC Plan; FERC 2013a) and Wetland and Waterbody
Construction and Mitigation Procedures (FERC Procedures; FERC 2013b). The Annova Plan and
Procedures include a number of Project-specific revisions to the FERC Plan and FERC Procedures.
In an October 20, 2016, Environmental Information Request we requested clarification of several
items contained in the Annova Plan and Procedures. Annova filed revisions to its Plan and
Procedures on November 9, 2016. We have reviewed the revised Annova Plan and Procedures and
find them acceptable. Differences between the Annova Plan and Procedures and FERC Plan and
FERC Procedures are summarized in table 2.5-1, and copies are included in appendix B.
TABLE 2.5-1
Summary of Annova’s Requested Changes to FERC’s Plan and Procedures

Section Number Annova Requested Change Justification
Plan (Upland Erosion Control, Revegetation, and Maintenance Plan)
III.B.8. Test subsoil and topsoil as appropriate to measure This change reflects that there are no agricultural
compaction for preparation of seed bed. or residential areas within the Project site.
III.B.10 Ensure final contours are in accordance with final Project site would be re-contoured as needed to
project grading plans (rather than pre-construction support facility structures and prevent potential
contours). flooding.
IV.B.5. Segregated topsoil may not be used for constructing Topsoil segregation not required because site
temporary slope breakers, improving or maintaining does not include agricultural or residential areas.
roads, or as a fill material, without prior approval.
IV.E.3. Amend to specify hardtop (asphaltic or concrete) This change is to specify that this requirement is
roadways. specific to paved roads.
IV.F.4.c(1) Mulch is to be applied to disturbed upland areas Due to extensive earthwork required on portions
where needed to prevent erosion. of the site, this change would allow for disturbed
areas to be mulched based on temporary and
permanent stabilization conditions.

Summary of Annova’s Requested Changes to FERC’s Plan and Procedures

Section Number Annova Requested Change Justification
IIV.F.4.c(2) Mulch disturbed upland areas if construction activity is This change adopts this section of the Plan to fit
interrupted for a period of 14 days or more, such that LNG terminal construction rather than pipeline
soil stabilization becomes necessary. construction and would comply with the EPA 2012
NPDES General Permit for Discharges from
Construction Activities.
V.A.5. Grade the disturbed areas to direct stormwater flows This change adopts this section of the Plan to fit
in accordance with stormwater management plans LNG terminal construction rather than pipeline
and leave the soil in the proper condition for planting. construction and would be consistent with
required stormwater management plans.
V.D.1.b. Complete landscaping in accordance with final project This change adopts this section of the Plan to fit
plans. LNG terminal construction rather than pipeline
construction.
VII.A.2. Continue revegetation efforts in areas formerly This change adopts this section of the Plan to fit
disturbed by construction until groundcover provides LNG terminal construction rather than pipeline
similar pre-construction stabilization. construction.
Procedures (Wetland and Waterbody Construction and Mitigation Procedures)
IV.A.1.e. The EI would determine if there is no reasonable This change accommodates required construction
alternative for hazardous materials to be stored within immediately adjacent to the BSC, including
100 feet of a wetland or waterbody with verification construction of the marine berth and site
that appropriate steps (including secondary earthwork activities.
containment structures) have been taken to prevent
spills and provide for prompt cleanup in the event of a
spill. This applies to storage of these materials and
does not apply to normal operation or use of
equipment in these areas.
V.B.1. Dredging operations and installation of pilings within This change accommodates terminal construction
the BSC would occur during the timeframe outlined in and waterway work within and immediately
the permit issued by the appropriate federal or state adjacent to the BSC. The timing of work within
agency. the BSC would be in accordance with Project-
specific requirements.
V.B.4.c. Dredged spoil material would be placed on-site and This change accommodates Project-specific LNG
into Port of Brownsville (Port) placement areas, as terminal dredging and construction requirements,
authorized by applicable regulatory agencies and the including potential beneficial use of dredged
Port. material for fill on-site.
V.B.10.c. Use silt/turbidity curtains as necessary to minimize Use of silt fences and turbidity curtains are
transport of displaced silt, sediment, or solids while recognized industry measures for inhibiting the
construction activities are occurring in or directly transport of sediment off-site for site development
adjacent to a waterway or waterbody. activities occurring in or adjacent to waterbodies.
VI.A.3 Limit disturbance to wetland areas in accordance with This change accounts for Project-specific wetland
USACE permits and approved drawings. impacts and marine dredging activities.
VI.D.1. To facilitate perimeter patrols and security This change adopts this section of the Plan to
observations, a corridor external and adjacent to the account for vegetation maintenance required for
primary security fence line up to 20 feet wide may be the Project-specific LNG terminal site rather than
cleared at a frequency necessary to maintain the 20- a pipeline right-of-way.
foot-wide corridor in an herbaceous state.
VII.B.1. Perform testing and inspections of welded and non- This change adopts this section of the Plan to
welded pipeline systems in accordance with account for integrity testing of LNG terminal site
appropriate engineering codes and standards, before components rather than a transmission pipeline.
installation under waterbodies or wetlands.
Based on FERC’s Upland Erosion Control, Revegetation, and Maintenance Plan (FERC 2013a) and FERC’s Wetland and
Waterbody Construction and Mitigation Procedures (FERC 2013b).
Annova also developed a preliminary Construction Spill Prevention, Control, and

Countermeasure (SPCC) Plan for the Project to comply with regulations in 40 CFR Part 112, which
includes measures to prevent spills from equipment and material storage areas containing oil. As

defined by 40 CFR Part 112, oil includes all grades of motor oil, hydraulic oil, lube oil, fuel oil,
gasoline and diesel, automatic transmission fluid, used oil, transformer mineral oil, and non-
petroleum oils such as animal or vegetable oils and synthetic oils. The preliminary Construction
SPCC Plan also specifies procedures, methods, and equipment requirements to prevent spills,
including secondary containment and earthen berms to prevent and minimize impacts from spills
during construction. We have reviewed the preliminary Construction SPCC Plan and find it
acceptable, and we are recommending that Annova file its final Construction SPCC Plan prior to
construction (see section 4.2.3).
Annova would employ at least one full-time environmental inspector (EI) dedicated to the
Project throughout construction. The primary responsibility of the EI(s) would be to ensure all
construction activities comply with environmental obligations, conditions, and other requirements
of environmental permits and authorizations, document compliance, and oversee any corrective
actions where needed. The EI(s) would also oversee installation and maintenance of sediment and
erosion controls. Additional details of the responsibilities of the EI(s) are described in the Annova
Plan and Procedures.
Prior to construction Annova would prepare a Project-specific Implementation Plan for

review and approval by FERC. The Implementation Plan would provide details and procedures
for implementing required environmental construction procedures and mitigation measures.
Annova would also develop an environmental training program designed to ensure that all
individuals receive training tailored to their particular role before beginning on-site work.
Annova’s preliminary Construction SPCC Plan also includes a requirement that the construction
contractor develop a training program for job-specific personnel for oil spill prevention,
preliminary response procedures, and applicable pollution control laws, rules, and regulations.
In addition to Annova’s environmental compliance activities, FERC staff would conduct

field inspections during construction. Other federal and state agencies may also conduct oversight
or inspections to the extent determined necessary by the individual agency. After construction is
completed, FERC staff would continue to monitor affected areas during operation to verify
successful restoration. Additionally, FERC staff would conduct annual engineering safety
inspections of the LNG terminal throughout the life of the facility.
CONSTRUCTION PROCEDURES
This section describes the general construction procedures proposed by Annova. Refer to
section 4 for more detailed discussions of proposed construction and restoration procedures as they
apply to specific resources, as well as additional measures that we are recommending to avoid or
reduce environmental impacts.
Under the provisions of the Natural Gas Pipeline Safety Act of 1968, as amended, the
proposed LNG terminal would be designed, constructed, operated, and maintained in accordance
with the DOT’s Liquefied Natural Gas Facilities: Federal Safety Standards (49 CFR 193) and the
NFPA’s Standards for the Production, Storage, and Handling of LNG (NFPA 59A, 2001 ed.).
These standards specify siting, design, construction, equipment, and fire protection requirements
for new LNG facilities. The LNG ship loading facilities and any appurtenances located between
the LNG ships and the last valve immediately before the LNG storage tanks would comply with

applicable sections of the Coast Guard regulations in Waterfront Facilities Handling Liquefied
Natural Gas (33 CFR 127) and Executive Order 10173.
To prevent contamination of soils or surface waters during construction, Annova would

implement project-specific spill prevention and response procedures in accordance with the
requirements of 40 CFR 112. Annova would implement its project-specific Construction SPCC
Plan during construction and would develop and implement a separate SPCC Plan during
operation. The intent of these plans is to outline potential sources of hydrocarbon releases at the
site, measures to prevent a release to the environment, and initial responses in the event of a spill.
Annova would also implement conditions resulting from other permit requirements and its
project-specific plans and measures developed to avoid or minimize environmental impacts during
construction, which are discussed throughout this EIS.
Land-based Facilities
Site Preparation and Workspace
Initially, the existing unpaved road leading from SH 4 (i.e., Boca Chica Boulevard) would
serve as a temporary access road to convey personnel and equipment to the site. Construction of
the permanent access road would occur adjacent to the temporary access road. Upon completion
of the permanent access road, the temporary road would be decompacted, seeded, and allowed to
revegetate naturally.
Construction would progress with clearing of vegetation and grading of the Project site.
Clearing of vegetation would be limited to the areas necessary to accommodate the liquefaction
facilities, marine facilities, and associated workspaces. During construction, Annova would use
areas within the Project site for equipment and materials laydown, contractor yard, soil stockpiling,
soil borrow, and parking. These areas would be graded and covered with gravel as appropriate.
Cleared debris would be chipped and stored for use as mulch or burned.
The existing natural ground surface elevation on the site ranges from 0 feet to +29 feet
(elevations in NAVD88). The elevation of the liquefaction trains would be raised +16.5 feet and
the LNG storage tank area would be raised to +6 feet above ground level (the height of the top of
the LNG storage tank would be approximately 186 feet NAVD88). Excavation within the Project
site would provide fill material that would be used in part to raise the elevation of these components
(in addition to the use of pilings). Conventional mechanical earthmoving equipment such as
scrapers, bulldozers, backhoes, excavators, and front-end loaders would be used. Following initial
excavation and grading activities, security fencing would be installed to control site access.
Construction of the marine facilities would occur at the same time as site clearing and grading (see
below). Once the MOF is constructed, materials for the facility installation would arrive via the
BSC, and construction of the aboveground facilities would begin.

Construction of Aboveground Facilities

The general construction process for aboveground facilities at the LNG facility would
include the following activities:
• installation of piles and underground utilities during both the excavation and raising
of the site elevation;
• foundation work in areas where the site elevation is raised, beginning in the LNG
storage tank area and progressing outward to include process equipment sites;
• installation of major equipment, including process modules, and construction of the
LNG storage tanks and installation of pipe racks;
• installation of process equipment, utility piping, and electrical instrumentation; and
• construction of buildings, including the control, maintenance, and administration
buildings.
Foundations
Foundations would consist of both deep foundations for large, heavily loaded structures
and shallow foundations for lightly loaded structures. Annova performed site-specific
geotechnical evaluations to determine the soil conditions and the appropriate foundation design.
The major site components requiring pile foundations include process equipment, equipment and
pipe rack modules, the LNG loading platform, and the LNG storage tanks. The Project would
require 7,817 concrete piles for the foundations. Table 2.6.1-1 provides additional information on
the number and type of piles required to support foundations of the LNG storage tanks and the
liquefaction facilities. The pile design and installation would comply with the Draft Seismic
Design Guidelines and Data Submittal Requirements for LNG Facilities and applicable federal
and state codes (FERC 2007). Following installation of the piles, installation of the LNG storage
tank foundations would include installation of sand beds, formwork and reinforcement steel,
settlement monitoring system, and pouring of the concrete slabs.
TABLE 2.6.1-1
Estimated Pilings Required for LNG Storage Tanks and Liquefaction Process Facilities
Installation No. Blows per Duration
Facility Pile Type Depth Dimension Number Method Pile (days)
LNG Storage Concrete -77 feet 14x14 inch 2,808 Impact hammer 1,275 132
Tanks
Liquefaction Concrete -27 feet 14x14 inch 7,009 Impact hammer 650 176
Process Facilities
LNG Storage Tank Construction

Construction of each of the two single-containment LNG storage tanks on the pile
foundations would consist of installing the outer carbon-steel tank walls and roof dome, insulation,
a 9 percent nickel steel secondary bottom, and inner container annular and bottom plates. Next
would include installation of internal accessories, including pump columns, instrument wells, and
purge and cool-down piping. The final phase would be installation of external accessories,

including roof platforms, walkways, and piping. After completion of all insulation system
installations, the tanks would be visually inspected and cleaned.
Milled perlite would be thermally expanded on site. The temporary on-site perlite
expansion would use a tractor-trailer-mounted mobile expander unit and a mobile delivery unit.
The expander package would include perlite ore receiving equipment, a natural gas-fired furnace,
conveyors, cyclones, and bag filters. The delivery unit would include bins for expanded perlite,
valving, and air compressors for delivery. The perlite ore would be fed from the delivery truck to
the expander unit by conveyance, heated to allow expansion, conveyed through a series of cyclones
to a set of tanks that would then be pressurized with air to allow the expanded perlite to flow to
the tank top and into the annular space. The perlite expansion operations would require
approximately 4 to 6 months to complete, after which the tractor-trailer-mounted mobile expander
unit and mobile delivery unit would be removed from the site.
Hydrostatic Testing
The LNG storage tanks would be hydrostatically tested in accordance with the
requirements of the American Petroleum Institute Standard 620. The inner tank would be filled
with water from the BSC at an estimated rate of 2,000 gallons per minute and pressurized to verify
its strength. Annova does not anticipate the need to add biocides or corrosion inhibitors or perform
desalination of the hydrostatic test water. The inner tank would be comprised of nickel alloy,
which would resist corrosion for the short duration of the testing, and the tanks would be flushed
and cleaned with fresh water following completion of testing. The estimated duration of the entire
hydrostatic testing program for the two LNG storage tanks would be approximately 8 weeks.
Upon completion of hydrostatic testing, the test water would be discharged back into the
BSC at a rate of approximately 1.8 million gallons per day. Annova would submit an application
for the NPDES permit and the Railroad Commission of Texas (RRC) Hydrostatic Test Water
Discharge permit and comply with testing and monitoring requirements prior to discharge.
Piping would be tested using hydrostatic testing at 1.5 times design pressure (for piping
carrying natural gas) or pneumatic testing methods (for cryogenic piping carrying LNG).
Pneumatically tested cryogenic piping would be filled with dry air or nitrogen at 1.1 times design
pressure. Testing would be performed in accordance with American Society of Mechanical
Engineers Standard B31.3.
Site Restoration
Following construction, site restoration would include clean-up, grading to the final design
elevations, installing permanent erosion control measures, and revegetation. Stabilization of
disturbed areas would be in accordance with the Annova Plan and Procedures. Upon completion
of final site stabilization, land within the Project site would be in one of the conditions listed below:
• built facilities, including concrete or gravel – would include the liquefaction

facilities and buildings, or any concrete, paved, or gravel surfaces;
• mowed or highly maintained – would include areas revegetated with turf grasses
such as Bermuda grass, and would be mowed regularly;

• non-mowed or low maintenance – would include areas revegetated with native

meadow grasses such as buffalo grass, which would be mowed infrequently only
to prevent growth of brush or trees;
• restored temporary workspace (fence lines) – would include areas revegetated with
native grasses and allowed to revert to pre-construction land covers with no planned
vegetation maintenance. This would include about 4.9 acres of wetland; and
• restored temporary workspace (borrow area) – would include area planted in native
grasses with the goal of restoring to a Gulf Coast: Salty Prairie land cover per the
TPWD’s Ecological Mapping System of Texas with no planned vegetation
maintenance.
Marine Facilities
A description of the construction of the major marine facility components is below.
Marine Berth
The marine berth would be constructed using both land-based excavation and dredging.
Land-based excavation would occur in land areas and the excavated material would be stored for
later use on the Project site. A portion of the shoreline would be retained as excavation begins and
serve as an earthen berm to isolate the excavated area of the berth from the BSC; however, it is
expected that once excavation reaches a depth below +2 feet the excavation would require
dewatering. Land-based excavation would remove the material to a depth of about -21 feet, at
which point the earthen berm would be removed and the remainder of the berth would be dredged
using a hydraulic cutter dredge. The berth would be dredged to the final design depth of -45 feet
mean lower low water (MLLW), plus 3 feet for advance maintenance and over depth, with side
slopes at a ratio of 3:1 where sheet piling is not used.
Material removed by land-based excavation would be used for on-site fill where possible
or placed on the Project site to support landscaping and final grading. Annova proposes to use the
existing 704-acre Dredged Material Placement Area (DMPA) 5A, just west of the Project site, for
dredged material not used as fill on site. Annova evaluated the use of other dredged material
placement options, including use of DMPA 4A, 4B, and 5B (see the Dredged Material Transport
Plan included in appendix C). Dredged material would be moved to the DMPA through an
approximately 1.6-mile-long, floating dredged material pipeline that would be temporarily
anchored along the south shore of the BSC. The dredged material pipeline would be marked with
navigation lights and reflective signs and monitored to ensure the safety of area traffic. Use of
DMPA 5A would require a relatively low levee crest elevation increase over the life of the project
and comply with the COE requirements for levee raising over a 50-year life of the placement area.
Annova also evaluated the potential for beneficial use of dredged and excavated material, and
states that it is coordinating with the COE, EPA, and state and local entities to evaluate the potential
for beneficial use. Potential beneficial use of dredged material is described in detail in section 2.4
of the Dredged Material Transport Plan in appendix C of this EIS, and in Annova’s application
to the COE.
Table 2.6.2-1 provides estimates of the areas and volumes of excavated and dredged
materials, by method and placement.

TABLE 2.6.2-1
Summary of Excavated and Dredged Material

Duration Volume by Soil
Area (working Volume Texture a/
Project Facility Method and Depth (acres) days) (cubic yards) (cubic yards) Placement Location
Marine Berth Excavation of Topsoil 39 39 60,000 Clay Project site
and Turning Excavation to +2 feet 530,000 Clay
Basin (South) NAVD88
Excavation from +2 feet 76 90 1,125,000 Clay
NAVD88 to 20.85
NAVD88
Dredging to -45 feet 145 3,520,000 Sand – 3,520,000 Dredged Material
MLLW b/ Placement Area 5A
Turning Basin Dredging to -45 feet 20 31 726,000 Clay – 573,000 Dredged Material
(North) MLLW b/ Sand – 153,000 Placement Area 5A
Total Excavation for Placement on the Project site 1,715,000 Clay -1,715,000
Total Material for Dredged Material Placement Area 5A 4,246,000 Clay – 573,000
Sand – 3,673,000
Total Material Excavated and Dredged 5,961,000 Clay – 2,288,000
Sand – 3,673,000
a/ Volume includes advance maintenance and overdepth volumes.

b/ Based on soil borings that show clay layers to -35 feet North American Vertical Datum of 1988 (NAVD88) and sand from -
35 to -65 feet NAVD88.
Key: MLLW = mean lower low water
The marine berth would also require installation of pilings. Pilings for the mooring
dolphins and access trestle would be installed from land following land-based excavation but prior
to removal of the earthen berm. Pilings for the breasting dolphins would be installed using in-
water equipment. Table 2.6.2-2 summarizes the number, type, and installation methods for pilings
required for the marine berth.
TABLE 2.6.2-2
Pilings Required for the Marine Facilities

Depth (feet Diameter Blows Duration
Facility Pile Type NAVD88) (inches) Number Installation Method per Pile (days)
Breasting dolphins Monopiles -133 96 4 Impact hammer, in water 3,625 5
Dolphin walkway support Steel piles -76 42 3 Impact hammer, on land 2,900 2
Mooring dolphins Steel piles -131 42 24 Impact hammer, on land 3,360 6
Trestle Steel piles -152 36 12 Impact hammer, on land 3,190 3
MOF Steel piles -156 30 241 Impact or vibratory 3,725 60
hammer a/, on land
MOF Steel sheet -63 700 mm (Type 923 linear Impact or vibratory 1,000 20
piles AZ-37-700) feet hammer a/, on land
LNG Carrier Loading Steel piles -152 42 28 Impact hammer, on land 3,400 7
Platform
a/ To be determined during engineering.

mm = millimeters
Material Offloading Facility

The initial excavation and dredging of the marine berth would create a berth of sufficient
size to accommodate the MOF, which would be constructed on the west side of the marine berth.

The MOF would include a retaining wall consisting of a combination of piles and steel sheet
bulkhead. The MOF deck would consist of a series of driven piles. The number, type, and
installation methods for pilings required for the MOF are included in table 2.6.2-2.
LNG Carrier Loading Platform

Pilings for the LNG carrier loading platform would be installed following completion of
dredging. Installation of berth piping, equipment, utility hookup, and commissioning of the
loading system would follow pile installation. The number, type, and installation methods for
pilings required for the LNG carrier loading platform are included in table 2.6.2-2.
Shoreline Protection
Scour protection analysis completed by Annova indicates that protection from wind waves,
vessel wakes, and LNG carrier and tug propeller scour would be required from the base of the
LNG loading platform to above the water line at approximately +20 feet. Accordingly, shoreline
protection would be installed at the base of the steel sheet pile bulkhead wall for the MOF, the
shoreline at each end of the marine berth, and the base of the LNG loading platform and breasting
dolphin piles. The shoreline protection would consist of rock riprap armoring installed by crane
or long-reach backhoe. The rock for the armoring would be delivered to the site by barge.
Water Supply and Demand

During construction, water would be required for hydrostatic testing of pipes and tanks,
drinking water, dust control, and general use. Annova would use water from the BSC for hydrostatic
testing of the LNG storage tanks and would use potable water from the BND for hydrostatic testing of
facility piping and other requirements. Table 2.6.3-1 provides estimates of water use requirements
during construction.
TABLE 2.6.3-1
Water Supply and Demand Requirements During Construction

Volume - Volume - total for Discharge Rate
one-time use Volume per Month construction Discharge (million gallons
Component/ Use Source (million gallons) (million gallons) (million gallons) Location per day)
LNG storage tanks/ BSC 56 NA 56 BSC 1.8
hydrostatic testing
LNG facility piping/ BND 1 NA 1 BSC 1
hydrostatic testing
Potable BND NA 0.1 4.9 Holding NA
tanks
Dust control BND NA 2.7 83.2 None NA
General uses BND NA 1.3 110.4 None NA
during construction
Total 57 4.1 255.5
Stormwater Management
Annova would obtain an NPDES General Permit for Storm Water Discharges from
Construction Activities and conduct activities in accordance with applicable federal and state
regulations, including the development of a Stormwater Pollution Prevention Plan (SWPPP). The
SWPPP would include practices to minimize exposure of construction materials to stormwater and

measures to reduce the risk of spills. In addition, Annova’s preliminary Construction SPCC Plan
specifies procedures, methods, and equipment requirements to prevent spills, including secondary
containment and earthen berms to prevent and minimize impacts from spills during construction.
Solid and Hazardous Waste Management

Examples of solid waste that may be generated during construction activities include wood,
metals, glass, asphalt, plastics, insulation, cardboard, paper, and rubber. Examples of hazardous
waste materials that may be generated during construction activities include used oils, transmission
and hydraulic fluids, antifreeze, greases, paints, and cleaning agents. Hazardous waste
management is also addressed in the preliminary Construction SPCC Plan.
Annova would establish nonhazardous (solid) and hazardous waste management areas at
the Project construction site for accumulation and management of the wastes pending
transportation and proper disposal off site in accordance with applicable regulatory requirements
and best management practices. Prior to creating or designating such areas, suitable locations
would be identified based on access and suitability, and proximity to waste-producing activities or
environmental features.
All solid and hazardous wastes would be collected regularly and disposed of in accordance
with applicable federal and state requirements. Recyclable materials would be separated from the
solid waste stream produced during construction. Solid waste and hazardous wastes would be
transported in accordance with applicable DOT regulations for recycling, treatment, or disposal in
compliance with federal, state, and local regulations.
OPERATION AND MAINTENANCE PROCEDURES

LNG Marine Traffic Along the Waterway
Annova anticipates that it would load up to 125 LNG carriers per year when operating at
full plant capacity, though the actual number of port calls would depend on future offtake
agreements and the capacity of the specific vessels. As previously indicated, although LNG
carriers and their operation are directly related to the use of the proposed LNG terminal, they are
not subject to the NGA Section 3 authorization sought by Annova. The LNG carriers arriving at
the LNG terminal must comply with all federal and international standards regarding LNG
shipping. A detailed discussion of design and safety features of LNG carriers is presented in
sections 2.2 and 4.12 of this EIS.
The LNG carriers would navigate through the Gulf of Mexico and the U.S. Exclusive
Economic Zone (EEZ) using designated fairways and typical vessel routes to avoid obstructions
and to maximize efficiency, considering distance and currents. Figure 2.7.1-1 shows anticipated
routes for LNG carriers through the Gulf of Mexico. Before entering the BSC, all inbound LNG
carriers would be boarded by a local Brazos-Santiago Pilot one mile east of the BS Buoy about
4 nautical miles offshore, who would then pilot the carrier to the Project site. LNG carriers would
transit about 1.4 miles of the entrance channel before reaching the jetty channel through the
Brazos-Santiago Pass. After transiting about 1 mile through the jetty channel the LNG carriers
would begin transit of the main channel for about 7.5 miles to the Project site. LNG carriers would
be restricted to daylight transits only to allow adequate visibility. Figure 2.7.1-2 shows the route
from the Brazos Santiago Pass into the BSC.

Once at the Project site, tugs would maneuver the vessel within the berthing area, the pilot
would direct the securing of the lines, and would turn navigational control back to the captain
when the carrier is fastened. Following loading at the LNG terminal, a pilot would resume
navigational control of the vessel when the mooring lines are let go. Loaded LNG carriers would
transit outbound along the reverse route described for inbound LNG carriers.
In accordance with the Coast Guard’s regulations under 33 CFR 165.805(a)(2), LNG
carriers would have a moving security zone during transit through the BSC. As a safety and
security precaution, typically no vessels are allowed to meet, cross, or overtake LNG carriers in
transit or otherwise enter the security zone without the express permission of the Coast Guard. At
its discretion, the Coast Guard may elect to provide escort boats during LNG carrier transits to
enforce the moving security zone. See additional discussion in section 4.12.
The COE is responsible for maintenance dredging of the BSC, and during Project operation
Annova would be responsible for maintenance dredging of its marine berth and associated turning
basin. Annova estimates that shoaling rates in the marine berth would be greater than those in the
main channel. Based on estimated current annual shoaling rates within the BSC of approximately
10 cubic yards per linear foot, Annova estimates that maintenance dredging would generate up to
100,000 cubic yards of material annually. Material from maintenance dredging would be placed
into DMPA 5A. See additional discussion in section 4.3.2.2.

Figure 2.7.1-1 Anticipated LNG Carrier Routes in the Gulf of Mexico
Figure 2.7.1-2 LNG Carrier Route within the Brownsville Ship Channel

LNG Terminal Facilities

Annova would operate and maintain its facilities in compliance with 49 CFR 193, 33 CFR
127, 40 CFR 68, NFPA 59A, and other applicable federal and state regulations. Annova would
prepare operating procedures in accordance with 33 CFR §127.305, which addresses regulatory
requirements and industry standards and implement extensive training for LNG facility personnel.
These procedures would address safe start-up, shutdown, cool down, and other activities, as well
as routine operation and monitoring.
Operation and maintenance would initially require about 115 personnel, which would
increase to up to 165 personnel when fully operational. Early staffing plans assume that the
liquefaction facility would operate 24 hours a day, 7 days a week. Annova anticipates hiring
approximately 35 percent of these workers from the local area. The remaining positions would
likely be filled by workers with specialty skills who would relocate to the region from outside the
Project area. The full-time maintenance staff would conduct routine maintenance and minor
repairs, while specialized contract personnel would handle major overhauls and maintenance.
Water Supply and Demand

During operation, the Project would use water to support operations, for drinking and sanitary
purposes, and testing of fire water pumps. Annova would obtain water from the BND during
operation. Fire suppression equipment would use potable water for flushing and testing purposes.
An on-site 250,000-gallon potable water storage tank would provide water necessary to conduct the
monthly fire suppression system test. The tank would be 40 feet in diameter and 30 feet in height and
painted a dull green color (“covert green”) to reduce visual impacts. In an emergency, water would
be withdrawn from the BSC. Table 2.7.3-1 provides estimated water consumption requirements
during Project operation.
TABLE 2.7.3-1
Estimated Water Use During Project Operation

Consumption Continuous or
Service (gallons/month) Source Intermittent Use Discharge
Amine system 337,000 Brownsville Navigation District a/ Continuous None
Steam make-up b/ 104,000 Brownsville Navigation District Continuous None
Potable c/ 250,000 Brownsville Navigation District Continuous Wastewater Package
Treatment System
General Washdown 45,000 Brownsville Navigation District Intermittent Wastewater Package
Treatment System
Fire suppression 69,000 Brownsville Navigation District Intermittent Oil Water Separator
system testing d/
Total 805,000
a/ BND obtains potable water from the Brownsville Public Utility Board.
b/ Assumes a 3 percent blowdown requirement. To be confirmed during detailed engineering.
c/ Assumes 50 gallons/day/individual for 165 employees.
d/ Assumes a 10- to 15-minute system test.
Sanitary Waste
An on-site packaged sewage treatment plant would treat sanitary wastewater, which would
discharge through the stormwater management system to the BSC. Sludge and solids would be
directed to an on-site holding tank. Annova would contract with a sanitary waste contractor who

would remove the contents of the holding tank as necessary and dispose of the contents at
authorized disposal sites through the contractor’s permits.
Ballast Water and Cooling Water
LNG carriers would arrive at the Project with empty cargo tanks and onboard ballast water
to compensate for the empty tanks. Ballast water would be discharged as the LNG is loaded. The
Coast Guard regulates ballast water management and established mandatory ballast water
management requirements for all ships entering U.S. waters from outside the U.S. EEZ pursuant
to 33 CFR 151. Ballast water discharges would also comply with International Maritime
Organization standards for ballast water management as well as ballast water regulations contained
in the Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 as amended by the
National Invasive Species Act of 1996. The Coast Guard ballast water management guidelines
also include reporting and record-keeping requirements for all vessels that take up and/or discharge
ballast water. See additional discussion in section 4.6.2.2.
During arrival, loading, and departure from the berth, LNG carriers would draw water
(cooling water) from the BSC to keep their main engines and auxiliary equipment cool and within
prescribed operating temperatures. The cooling water flow rate and volume of water required for
cooling the machinery varies depending on the type of vessel propulsion and the mode of
operation. Impacts and mitigation associated with cooling water are discussed further in section
4.6.2.2 of this EIS
SAFETY AND SECURITY PROCEDURES

Annova must site, design, construct, operate, and maintain the Project in accordance with
the DOT Pipeline and Hazardous Materials Safety Administration’s (PHMSA) Federal Safety
Standards for Liquefied Natural Gas Facilities, 49 CFR Part 193. In addition, the Project design
would meet all Coast Guard standards in 33 CFR Part 127, Waterfront Facilities Handling
Liquefied Natural Gas and Liquefied Hazardous Gas. In particular, pursuant to the provisions of
the Federal Pipeline Safety Laws (49 USC § 60101 et seq.) amended in 2011, the Project would
be operated and maintained in accordance with the Federal Safety Standards for Liquefied Natural
Gas Facilities (and as referenced in 49 CFR 193, the NFPA 59A-2001).
Coordination with and involvement of local officials would be an important component of

operational safety. Annova worked with the Coast Guard and state and local agencies to prepare
a draft Emergency Response Plan (ERP) that provides a framework for the guidelines and
procedures to be developed (see additional discussion in section 4.12). The ERP would provide
on-scene incident protocol and actions to implement during a maritime or on-land emergency.
Should the Commission grant Annova’s request for Section 3 authorization for the Project, Annova
would submit the final ERP to FERC for approval approximately nine months prior to Project
commissioning. Annova would furnish the Captain of the Port at Coast Guard Sector Corpus
Christi with copies of the ERP and the Operations Manual at least 60 days prior to commencing
LNG transfer operations.

Spill Containment
All LNG equipment and piping systems holding LNG in the process area would include a
spill containment system utilizing curbed areas, troughs, open drains, and an impoundment basin
to hold LNG spills.
The facility would also include a spill containment system for each process area. The
condensate storage tank and the amine make-up tank would be surrounded by a perimeter concrete
containment wall. Each process area would either direct liquid releases to spill containment basins
or contain liquid releases within perimeter curbs. Each basin would contain stormwater removal
pumps designed to remove stormwater from a 10-year, one-hour storm event. Stormwater from
perimeter curbs around equipment containing oil or grease would flow or be pumped to the oily
water collection sumps. Additional information regarding spill containment system operation,
maintenance, and safety information is presented in section 4.12.
Thermal Exclusion and Vapor Dispersion Zones

The LNG facility must comply with the DOT’s siting requirements in 49 CFR 193, Subpart
B, which incorporates the 2001 edition of the NFPA 59A. As specified in 49 CFR 193.2057,
thermal radiation protection exclusion zones must be calculated for each LNG container and LNG
transfer system based on three radiation flux levels in accordance with Section 2.2.3.2 of NFPA
59A (2001 ed.) Additionally, as prescribed in 49 CFR 193.2059 and Sections 2.2.3.3 and 2.2.3.4
of NFPA 59A (2001 ed.), vapor-gas dispersion exclusion zones must be calculated for each LNG
container and LNG transfer system. These LNG exclusion zones are designed to protect people
and property in the event of an accident and fire at an LNG facility. More specific information
regarding vapor dispersion zones and thermal radiation is provided in section 4.12.
LNG Carrier Safety and Facility Security

The security and safety requirements for the onshore components of the Project are
governed by PHMSA regulations in 49 CFR Part 193, Subpart J – Security. This subpart includes
requirements for conducting security inspections and patrols, liaison with local law enforcement
officials, design and construction of protective enclosures, lighting, monitoring, alternative power
sources, and warning signs. The requirements for safety and security of the marine facilities are
contained in Coast Guard regulations in 33 CFR Part 127 and 33 CFR Part 105, respectively.
Annova would develop and implement a Facility Security Plan (FSP), which must be approved by
the Coast Guard, and would implement any applicable PHMSA security requirements not
otherwise covered by the FSP.
Safety and security features would include security fencing, lighting, access control, and
closed-circuit television. Access through the plant gate and buildings would be in accordance with
the FSP. Closed-circuit television cameras would permit viewing of the Project site, and a security
staff would man the facility at all times. The facility would include sirens audible in all locations,
in compliance with Coast Guard LNG facility regulations (33 CFR Part 127). Plant security would
include a perimeter fence consistent with established BND protocol.
When an LNG carrier is at the marine berth, the gate at the jetty shore side entrance would
close with security present as long as the LNG carrier remains at the facility. A standby tug at the

marine berth would provide any operational support, and security vessels would keep other marine
traffic on the BSC away from the LNG carrier while docked.
Hazard Detection System

Hazard detectors for the LNG terminal would be installed throughout the facilities to give
operations personnel a means for early detection and location of released flammable gases and
fires. The hazard detection system would be designed in accordance with NFPA requirements and
other applicable standards. The hazard detection system would include detectors/sensors for:
• flammable gas;
• fire and flame;
• leak detection;
• high temperature;
• low temperature;
• smoke; and
• toxic gas.
Additional detail regarding the hazard detection system is provided in section 4.12.
Fire Protection System

The LNG terminal would include an independent fire protection system that would use
water, foam, and chemical agents. The firewater supply and distribution component of this system
would include water intake structures and three diesel-fired and one electric motor-driven
emergency firewater pumps on the BSC and a 250,000-gallon potable water storage tank.
Hydrants and monitors would be strategically located and installed to protect plant equipment and
facilities. In addition, dry chemical extinguishers would be provided in each process area to allow
onsite staff to address small, incipient fires. Additional detail regarding the fire protection system
is provided in section 4.12.
FUTURE PLANS AND ABANDONMENT

Annova has no reasonably foreseeable plans for expansion or abandonment of the Project
facilities. If future expansion plans are developed, Annova would seek the appropriate
authorizations from federal, state, and local agencies. Annova anticipates at least a 25-year life
span for the Project, but the facilities would be designed and capable of operating for 50 years or
more with proper maintenance.

3.0 ALTERNATIVES
INTRODUCTION
In this section, we evaluate a range of reasonable alternatives, as required by NEPA (at 40
CFR 1502.14) and Commission po1icy. We also discuss other alternatives that were eliminated
from detailed review because they were not reasonable or practicable. The alternatives may have
been presented by Annova, cooperating and other governmental resource agencies, affected
landowners, the public, and FERC staff. The range of alternatives we evaluated include the no
action alternative, system alternatives, access road alternatives, and LNG process and design
alternatives.
Each of the cooperating agencies with obligations under NEPA can use this alternatives
analysis as part of their decision-making process. Individual agencies would ensure consistency
with their own administrative procedures prior to accepting the conclusions in this draft EIS.
Evaluation Process
The purpose of this evaluation is to determine whether an alternative would be preferable
to the proposed action. We generally consider an alternative to be preferable to a proposed action
using three evaluation criteria, as discussed in greater detail below. These criteria include:
1. the alternative meets the stated purpose of the project;

2. is technically and economically feasible and practical; and
3. offers a significant environmental advantage over a proposed action.
The alternatives were reviewed against the evaluation criteria in the sequence presented
above. The first consideration for including an alternative in our analysis is whether it could satisfy
the stated purpose of the Project. An alternative that cannot achieve the purpose for the project
cannot be considered as an acceptable replacement for the project. All the alternatives considered
here are able to meet the project purpose stated in section 1.0 of this draft EIS.
For further consideration, an alternative has to be technically and economically feasible.

Technically practical alternatives, with exceptions, would generally require the use of common
construction methods. An alternative that would require the use of a new, unique, or experimental
construction method may not be technically practical because the required technology is not
available or is unproven. Another component of feasibility is whether characteristics of an
alternative are sufficient and compatible with the proposed action. For example, based on
Annova’s proposed design, a waterfront site of at least 400 acres would be preferable to allow for
placement of all Project components and the construction laydown area. A smaller alternative site
may not be feasible.
Economically practical alternatives would result in an action that generally maintains the
price competitive nature of the proposed action. Generally, we do not consider the cost of an
alternative as a critical factor unless the added cost to design, permit, and construct the alternative
would render the project economically impractical.
3-1 Alternatives
Determining if an alternative provides a significant environmental advantage requires a

comparison of the impacts on each resource as well as an analysis of impacts on resources that are
not common to the alternatives being considered. The determination must then balance the overall
impacts and all other relevant considerations. In comparing the impact between resources
(factors), we also considered the degree of impact anticipated on each resource. Ultimately, an
alternative that results in equal or minor advantages in terms of environmental impact would not
compel us to shift the impacts from the current set of stakeholders to a new set of stakeholders.
We considered a range of alternatives in light of the Project’s objectives, feasibility, and

environmental consequences. Through environmental comparison and application of our
professional judgment, each alternative is considered to a point where it becomes clear if the
alternative could or could not meet the three evaluation criteria. To ensure a consistent
environmental comparison and to normalize the comparison factors, we generally used desktop
sources of information (e.g., publicly available data, aerial imagery) and assumed the same general
site area requirements. We evaluated data collected in the field if surveys were completed for both
the proposed site and alternative sites. Where appropriate, we also used site-specific information
(e.g., detailed designs). Our environmental analysis and this evaluation considers quantitative data
where available (e.g., counts, acreage, or mileage) and uses common comparative factors such as
land requirements.
Our evaluation also considers impacts on both the natural and human environments. The
natural environment includes water resources and wetlands, vegetation, wildlife and fisheries
habitat, soils, and geology. The human environment includes nearby landowners, residences, land
uses and recreation, utilities, and industrial and commercial development near construction
workspaces. In recognition of the competing interests and the different nature of impacts resulting
from an alternative that sometimes exists (i.e., impacts on the natural environment versus impacts
on the human environment), we also consider other factors that are relevant to a particular
alternative or discount or eliminate factors that are not relevant or may have less weight or
significance. In our alternatives analyses, we often have to weigh impacts on one kind of resource
(e.g., habitat for a species) against another resource (e.g., residential land use impact).
The following sections discuss and analyze each of the alternatives we evaluated in
sufficient detail to explain why they were eliminated from further consideration or are
recommended for adoption into the Project.
Public Comments
Prior to the issuance of our draft EIS, we received about 70 comments related to Project
alternatives. In response to some comments, we requested that Annova provide additional
environmental information to enable us to compare alternatives to the proposed action. Annova
participated in our pre-filing process (see section 1.3) during the preliminary design stage of the
Project. This process emphasizes identification of potential stakeholders early in the development
of a project, identification and resolution of issues before a formal application is filed with the
Commission, and identification and evaluation of alternatives that may avoid or minimize
environmental impact. During this process, Annova made some modifications to the proposed site
layout to address stakeholder concerns identified during scoping. The changes were made to
minimize impacts on wetlands and wildlife habitat on the LNG terminal site. These changes were
Alternatives 3-2
subsequently made a part of Annova’s proposed action when it filed its formal application and
supplements, and as such are evaluated in section 4 of this draft EIS.
The Commission also received comments during scoping suggesting that electricity
generated from solar panels, wind farms, and/or other renewable energy sources, or implementing
energy conservation or efficiency measures to reduce energy use, could eliminate the need for the
Annova Project. Annova’s stated purpose of the Project is to operate a mid-scale natural gas
liquefaction facility along the South Texas Gulf Coast for exporting natural gas to international
markets. The generation of electricity from renewable energy sources or energy conservation are
reasonable alternatives for a review of power-generating facilities, and states or federal entities
that are contemplating new fossil-fuel based power plants may indeed decide to consider alternate
forms of energy or energy conservation for a comparison of overall impacts and benefits.
However, authorizations related to how the markets will meet demands for electricity are not part
of the application before the Commission and their consideration is outside the scope of this EIS.
Therefore, because the purpose of the Annova Project is to export natural gas to international
markets, and the generation of electricity from renewable energy sources or the gains realized from
increased energy efficiency and conservation are not consistent with this purpose, they cannot
function as a substitute for the Project. These alternatives cannot meet the purpose for the Project
and are not considered or evaluated further in this analysis.
NO-ACTION ALTERNATIVE
Our evaluation of the no-action alternative primarily addresses the effects and actions that
may result if the Project is not constructed. Under the no-action alternative, the environmental
impacts described in this EIS would not occur; however, the stated purpose of the Annova proposal
would not be met.
In an order issued February 20, 2014, the DOE authorized the export of LNG from the
Annova facility to FTA nations (DOE 2014). By law, under Section 3(c) of the NGA, applications
to export natural gas to countries with which the United States has FTAs that require national
treatment for trade in natural gas are deemed to be consistent with the public interest. It is
reasonable to expect that if the Annova Project is not constructed (the no-action alternative), export
of LNG from one or more other mid-scale LNG export facilities located near a natural gas
production and distribution hub along the South Texas Gulf Coast could also be authorized by the
DOE and eventually be constructed. Thus, although the environmental impacts associated with
constructing and operating the Annova Project would not occur under the no-action alternative,
similar impacts could occur at other location(s) in the region as a result of another LNG export
project seeking to meet the demand identified by Annova. That is, LNG terminal developments
of similar scope and magnitude to the proposed Project would likely result in environmental
impacts of comparable significance, especially those projects in a similar regional setting.
We conclude that the no-action alternative does not meet the Project objective, and it was
thus eliminated. Therefore, we do not consider it further.
SYSTEM ALTERNATIVES
To analyze system alternatives, we evaluated potential impacts associated with alternatives
to the proposed action that would make use of other authorized, or proposed LNG export facilities,
3-3 Alternatives
or possible expansion of those other facilities, that would meet the stated purpose and need of the
proposed action. By definition, implementation of a system alternative would make it unnecessary
to construct part or all of the proposed action. However, additions or modifications to the system
alternatives may be required to increase capacity or provide receipt and delivery capability
consistent with that of the proposed Project. These additions or modifications could result in
environmental impacts that are less than, similar to, or greater than the environmental impacts of
the proposed facility. The proponent of a system alternative would also have to be willing to
undertake the financial and regulatory requirements associated with the additions or modifications.
Our analysis of system alternatives considers currently authorized, proposed, or planned 6

LNG export facilities located in the Texas Gulf Coast region of the U.S. to replace all or part of
the Project. Annova’s stated purpose is to source natural gas from the South Texas Gulf Coast
region, however we believe it is reasonable to expand the area of our analysis of potential system
alternatives to include the entire Texas Gulf Coast. We believe that the existing supply and
pipeline network in the Texas Gulf Coast could meet Annova’s objective for the source of natural
gas, and this slightly larger region of analysis would not significantly change the duration of LNG
carrier transits. We considered whether any of the recently authorized, proposed, or planned LNG
export terminal projects in this region could be viable system alternatives to the Project. To be
considered a viable system alternative, the other projects in this region would need to provide LNG
send-out capacities similar to Annova’s proposal, in addition to current or planned expansion
capacities for the other terminals.
The system alternatives considered in this analysis are shown on figure 3.1-1, summarized
in table 3.3-1, and described below. Although we have considered each of the authorized,
proposed, or planned projects below as potential system alternatives, the market would ultimately
decide which and how many of these facilities are built.
The DOE considers applications to export LNG to FTA or Non-FTA nations for proposed
LNG export projects. Annova’s authorization from the DOE to export natural gas to FTA nations
is based on the export of approximately 342 Bcf of natural gas per year as LNG (DOE 2014), and
its pending non-FTA application requests authority to export up to 360 Bcf/yr.
To be a viable system alternative, other authorized, proposed, or planned LNG export

facilities must be able to meet the same export capacity and customer base as the Project. We
recognize that LNG capacity may not be fully subscribed at all facilities based on contracts
executed as of the writing of this EIS. However, because the DOE’s export approval is a
determination that the export is in the public interest, we will not speculate that any portion of
other LNG terminals’ LNG capacity is in “excess” or available for use by Annova to meet its
objectives. We evaluated the potential system alternatives below.
6
Proposed projects are projects for which the proponent has submitted a formal application with the FERC; planned
projects are projects that have been announced or are in the FERC’s Pre-Filing phase but for which no formal
application has been filed with the FERC.
Alternatives 3-4
Figure 3.3-1 Texas Gulf Coast LNG Export System Alternatives
3-5 Alternatives
TABLE 3.3-1
Existing, Proposed, and Planned LNG Export Projects Along the Texas Gulf Coast
Location Distance from Projected In-
Project (County, State) Project (miles) Service Date FERC Docket Number
Annova Project
Annova LNG Brownsville Cameron, TX 0 2021 CP16-480
LNG Export Projects Approved by FERC
Corpus Christi Liquefaction San Patricio, TX 125 2018 CP12-507
Freeport LNG Freeport, TX 235 2018 CP12-509, CP15-518
ExxonMobil-Golden Pass Sabine Pass, TX 340 2020 CP14-517
Proposed LNG Export Projects (currently filed applications with FERC)

Texas LNG Cameron, TX 0.8 2020 CP16-116
Rio Grande LNG Cameron, TX 0.4 2020 CP16-454
Port Arthur LNG Port Arthur, TX 340 2023 CP17-20
Freeport LNG Train 4 Freeport, TX 235 2020 CP17-470
Corpus Christi Stage 3 Project San Patricio, TX 125 2021 CP18-512, CP18-513
Planned LNG Export Projects (announced or in pre-filing with FERC)
Galveston Bay LNG Galveston, TX 270 2027 PF18-7
3.3.1 Currently Authorized LNG Export Facilities in Texas

There are currently three LNG export facilities authorized by FERC for construction and
operation along the Texas Gulf Coast. The potential for each of these facilities to serve as system
alternatives to the proposed Annova Project is described below.
3.3.1.1 Corpus Christi Liquefaction

DOE authorized Corpus Christi Liquefaction and Cheniere Marketing, LLC to export 767
Bcf per year, or approximately 15 mtpa, of natural gas to non-FTA countries (DOE 2015a), and
previously authorized the same volume for export to FTA countries. In order for Corpus Christi
Liquefaction to meet the export capacity and purpose of the Project, it would need to expand in
size and design beyond its DOE authorized capacity to match the 7.0 mtpa required by Annova.
In addition, Corpus Christi Liquefaction uses 4.5 mtpa trains, whereas the Project would use 1
mtpa trains. Annova’s Project is designed with 1 mtpa liquefaction trains to target the LNG market
segment of customers whose annual demand ranges from 1 to 2 mtpa. Since contracts are based
on a per-liquefaction-train annual output, the 4.5 mtpa trains used for the Corpus Christi
Liquefaction project could not meet the same export capacity requirement and customer base as
proposed for the Annova Project, and therefore the Corpus Christi Liquefaction project is not
considered a viable system alternative.
It is possible that the currently authorized Corpus Christi Liquefaction Project could be
expanded, and that the expanded project could serve as a system alternative to the Annova Project.
In fact, on June 28, 2018, Corpus Christi Liquefaction filed an application with the FERC for an
expansion, called the Stage 3 Project (FERC Docket Numbers CP18-512 and CP18-513). See
section 3.3.2 for a discussion of the potential for the Stage 3 project to serve as a system alternative.
3.3.1.2 Freeport LNG

The existing Freeport LNG terminal is on Quintana Island in Brazoria County, Texas. The
import terminal started operations in 2008 and includes two 160,000 m3 LNG storage tanks and a
Alternatives 3-6
single berth capable of handling LNG carriers in excess of 200,000 m3. It has a peak send out
capability of approximately 1.5 Bcf of natural gas.
Freeport LNG Expansion, LP and FLNG Liquefaction, LLC (collectively, FLEX) have
been authorized to add liquefaction facilities to the existing terminal to provide export capacity of
up to approximately 15 mtpa of LNG. The existing Freeport LNG terminal is about 235 miles
northeast of the proposed Project site (see figure 3.3-1). The authorized expansion project requires
approximately 86 acres for three proposed trains, each with a capacity of 4.4 mtpa. The DOE has
approved two applications for export of LNG to FTA nations, each for 511 Bcf per year, and has
also approved three applications to export LNG to non-FTA nations. Construction began in late
2014.
It is possible that the currently authorized Freeport LNG Expansion project could be further
expanded using 1 mtpa liquefaction trains, and that the expanded project could serve as a system
alternative to the Annova Project. In fact, FLEX has currently proposed a further expansion that
would involve addition of a fourth liquefaction train (FERC Docket Number CP17-470). See
section 3.3.2 below.
3.3.1.3 ExxonMobil-Golden Pass

The Golden Pass LNG terminal is near the town of Sabine Pass, Texas, on the western
shore of Sabine Pass Channel, about 340 miles northeast of the proposed Project site (see figure
3.3-1). Operations started in 2010 on the approximately 477-acre site. The import terminal
includes five 155,000 m3 LNG storage tanks and two LNG carrier berths. It has a maximum send-
out capacity of 2.5 Bcf per day (Bcf/d) of natural gas. On December 21, 2016 FERC authorized
the addition of 15.6 mtpa of LNG export capacity to the LNG terminal, with the export facility
using the existing LNG storage tanks, berthing facilities, and pipeline infrastructure of the import
terminal. Golden Pass received approval from DOE to export LNG to FTA nations in 2012, and
to non-FTA nations in April 2017. Construction of the export facility has not begun as of the date
of this EIS, however start of service is projected for 2020.
DOE authorized Golden Pass to export up to 808 Bcf per year, or approximately 15.6 mtpa,
of natural gas as LNG, to non-FTA nations. It is possible that the currently authorized Golden
Pass LNG export project could be expanded using 1 mtpa liquefaction trains to add additional
export capacity, and that the expanded project could serve as a system alternative to the Annova
Project. It is not clear if the Golden Pass LNG terminal site could support the addition of new
facilities required to add the capacity proposed by Annova. Any such project would need to be
evaluated but would likely result in similar or greater environmental impacts and would not
provide a significant environmental advantage over the proposed location. Therefore, the Golden
Pass system alternative was not evaluated further.
3.3.2 Proposed and Planned LNG Export Projects in Texas

There are currently five LNG export facilities proposed before the FERC for construction
and operation along the Texas Gulf Coast and a sixth in the FERC’s pre-filing stage (see table 3.3-
1 and figure 3.3-1). The potential for each of these proposed projects, or an expansion of these
projects, to serve as system alternatives to the proposed Annova Project is described below. There
are also two projects that have been announced as contemplated for development at the Port of
3-7 Alternatives
Brownsville, Eos LNG and Gulf Coast LNG Export. Neither of these projects have begun the
FERC pre-filing process, and in June 2016, Gulf Coast LNG’s authorization from the DOE for
FTA countries was vacated it its request. Because neither of these projects have progressed to the
point they can be considered reasonable alternatives, they are not addressed further in this analysis.
3.3.2.1 Texas LNG

The Texas LNG export project is proposed to be sited on the BSC, about 3 miles northeast
of the proposed Annova site. DOE has authorized Texas LNG to export up to the equivalent of
200.75 Bcf per year of natural gas (DOE 2015b) to FTA nations. On March 31, 2016, Texas LNG
filed an application with FERC in Docket Number CP16-116. The Texas LNG project would be
developed in two phases, with phase 1 designed for 2 mtpa, and phase 2 designed for an additional
2 mtpa at some point in the future.
We considered whether an expansion of the proposed Texas LNG project could serve as a
system alternative. Texas LNG proposes to use approximately 240 acres of its 625-acre site for
permanent facilities, with the balance of the parcel (385 acres) used for temporary construction
areas or retained as undisturbed lands. Over one-half of the 385 unused acres are wetlands or tidal
mudflats, leaving less-than 200 acres potentially available for expansion. For an expanded Texas
LNG project to meet the export capacity of 7 mtpa and serve as a system alternative to the Annova
LNG Project, it would have to nearly triple in size and design beyond its DOE authorized capacity.
The unused portion of the Texas LNG site would not be large enough to support the expansion
needed to add 7 mtpa of additional capacity. Therefore, an expansion of the proposed Texas LNG
project is not technically feasible and is not considered further.
3.3.2.2 Rio Grande LNG

The Rio Grande LNG export project is proposed to be sited on the BSC, west of the Texas
LNG site, and nearly directly across from the proposed Annova site. Rio Grande LNG has received
authorization from DOE to export up to the equivalent of 1,318 Bcf per year of natural gas as LNG
(DOE 2015c) to FTA nations, and on May 5, 2016 filed an application with FERC in Docket
Number CP16-454.
We considered whether an expansion of the proposed Rio Grande LNG project could serve
as a system alternative. Rio Grande LNG proposes to use approximately 770 acres of its 985-acre
site, with the balance of the parcel (approximately 215 acres) retained as a narrow natural buffer
between the site and State Route 48 to the north and between the site and the Bahia Grande pilot
channel to the west, or part of the planned and permitted widening of the pilot channel. For an
expanded Rio Grande LNG project to meet the export capacity and serve as a system alternative
to the Project, it would have to expand in size and design beyond its DOE authorized capacity by
an additional 7 mtpa. The remaining acreage within the Rio Grande LNG project site does not
include enough land to add one or two additional 4.5 mtpa liquefaction trains (using Rio Grande
LNG’s design model), or six additional 1 mtpa liquefaction trains (using Annova’s design model),
and the one or two additional LNG storage tanks, that would be required to add the 7 mtpa capacity
needed to be an alternative to the Project. In addition, Rio Grande LNG proposes to use 4.5 mtpa
trains, whereas the Annova Project would use 1 mtpa trains. Annova’s Project is designed with 1
mtpa liquefaction trains to target the LNG market segment of customers whose annual demand
ranges from 1 to 2 mtpa. Since contracts are based on a per-liquefaction-train annual output, the
Alternatives 3-8
4.5 mtpa trains proposed for the Rio Grande LNG project could not meet the same export capacity
and customer base as proposed for the Annova Project. For the reasons described above, the Rio
Grande LNG project is not a feasible system alternative and is not considered further.
3.3.2.3 Port Arthur

On November 29, 2016 Port Arthur filed an application with FERC in Docket Number
CP17-20 for authorization to site, construct, and operate its proposed Port Arthur LNG export
project located about 6 miles north of Sabine Pass, in Jefferson County, Texas. The project
includes two 6.7 mtpa liquefaction trains and total LNG production capacity of approximately 13.5
mtpa. Port Arthur received authorization from DOE on August 20, 2015 to export LNG to those
countries with which the U.S. currently has, or in the future will have, a free trade agreement.
Based on a subsequent request from the applicant, DOE, on November 20, 2018, increased the
authorized FTA volume to a total of approximately 698 Bcf per year, equivalent to approximately
13.5 mtpa. Port Arthur has also filed an application with DOE on June 15, 2015 seeking
authorization to export LNG from the project to any country with which the U.S. does not have a
free trade agreement. A DOE decision on that application is pending.
We considered whether an expansion of the proposed Port Arthur LNG project could serve
as a system alternative. The Port Arthur project would be within an approximately 937-acre site,
the majority of which would be used for both construction and operation of the project. However,
Port Arthur classifies approximately 416 acres of its proposed operation footprint as “mixed use”
that does not include permanent facilities, and it is possible that additional facilities could be
located within this space. Port Arthur’s proposed liquefaction facilities and LNG storage tanks
(for 13.5 mtpa of capacity) require about 178 acres of its total site footprint, therefore it may be
possible that facilities required for an additional 7 mtpa of production (Annova’s proposed
capacity) could be installed within the 416 acres of mixed use. Such an alternative would require
redesign and engineering and an assessment of location and size of property. In addition, any
expansion of the proposed facilities at the Port Arthur site to accommodate the proposed capacity
for the Annova Project would need to be fully evaluated by FERC and other applicable agencies,
but such an expansion would likely result in similar or greater environmental impacts and would
not provide a significant environmental advantage over the proposed location. Therefore, it was
not evaluated further as a system alternative.
3.3.2.4 Freeport LNG Train 4 Expansion

On June 29, 2017, Freeport LNG filed an application with FERC in Docket Number CP17-
470 for authorization to site, construct and operate Train 4 at the existing Freeport LNG facility
currently under construction on Quintana Island, Texas. The proposed Train 4 Expansion would
add 5 mtpa of capacity, increasing the project’s total LNG export capacity to approximately 20
mtpa. On March 6, 2018, Freeport filed an application with DOE seeking authorization to export
LNG, specifically associated with Train 4, from the project to any country with which the U.S.
does not have a free trade agreement. That application is under DOE review. On September 5,
2018, Freeport LNG announced that it has entered into a binding agreement with Sumitomo
Corporation of Americas for 2.2 mtpa of the Train 4 Expansion LNG capacity.
Although the Train 4 Expansion project is already an expansion of a previously authorized

project, we considered whether an expansion of the proposed Train 4 Expansion project could
3-9 Alternatives
serve as a system alternative to the Annova Project. The Train 4 Expansion project would require
a construction footprint of about 175 acres (not including the associated pipeline), the majority of
which would be located within the site of the existing facilities. For an expanded Train 4
Expansion project to meet the export capacity of 7 mtpa and serve as a system alternative to the
Annova LNG Project, it would have to at least double (from 5 to 12 mtpa) in size and design
beyond its proposed capacity. Based on review of the Train 4 Expansion site it does not appear
there is space available to accommodate such an expansion. Therefore, an expansion of the Train
4 Expansion project is not a feasible system alternative and is not considered further.
3.3.2.5 Corpus Christi Stage 3

In June 2015, Corpus Christi Liquefaction entered into the FERC’s pre-filing process
(Docket Number PF15-26) and in June 2018 filed an application (Docket Number CP18-512) for
the Corpus Christi Stage 3 project, which would add seven additional LNG trains with
approximately 9.5 mtpa of capacity at the existing site of the Corpus Christi Liquefaction project.
With the addition of the Stage 3 project, the Corpus Christi Liquefaction project would have three
4.5 mtpa LNG trains and seven 1.36 mtpa LNG trains, with a total LNG production capacity of
approximately 25.4 mtpa. DOE authorized Corpus Christi Liquefaction Stage III, LLC to export
approximately 582 Bcf per year to FTA countries, on November 9, 2018. A non-FTA application
is pending with the DOE. The targeted in-service date is 2022.
Although the Corpus Christi Stage 3 project is already an expansion of a previously

authorized project, we considered whether an expansion of the proposed Corpus Christi Stage 3
project could serve as a system alternative to the Annova Project. The Corpus Christi Stage 3
project would require a construction footprint of about 1,009 acres (not including the associated
pipeline) and an operation footprint of about 239 acres, the majority of which would be located
within areas previously disturbed during construction of the Corpus Christi Liquefaction project.
For an expanded Stage 3 project to meet the export capacity of 7 mtpa and serve as a system
alternative to the Annova LNG Project, it would require about a 40 percent increase in size and
design beyond its proposed capacity. Any expansion of the proposed facilities at the Corpus
Christi Stage 3 project to accommodate the proposed capacity for the Annova Project would need
to be fully evaluated by FERC and other applicable agencies, but such an expansion would likely
result in similar or greater environmental impacts and would not provide a significant
environmental advantage over the proposed location. Therefore, it was not evaluated further as a
system alternative.
3.3.2.6 Galveston Bay LNG

On December 7, 2018, Galveston Bay LNG entered into the FERC’s pre-filing process
(Docket Number PF18-7) for the Galveston Bay LNG project. The project would include a natural
gas liquefaction and LNG export facility on an approximately 750-acre parcel within the city of
Texas City, Texas at a site on Galveston Bay known as Shoal Point. The project would include
three LNG liquefaction trains with the capacity to export up to 16.5 mtpa of LNG. On June 13,
2018, Galveston Bay LNG received authorization from DOE to export LNG to FTA nations.
We considered whether an expansion of the planned Galveston Bay LNG project could
serve as a system alternative. Galveston Bay LNG proposes to develop approximately 550 upland
acres of the 750-acre site for its facilities, with the balance of the parcel (200 acres) used for
Alternatives 3-10
dredged material placement. For an expanded Galveston Bay LNG project to meet the export
capacity of 7 mtpa and serve as a system alternative to the Annova LNG Project, it would need to
be expanded in size and design beyond its DOE authorized capacity. It is unclear if the upland
portion of the site would be large enough to support the expansion needed to add 7 mtpa of
additional capacity. In addition, development and permitting of the Galveston Bay LNG Project
is over two years behind development of the Annova LNG Project. Therefore, an expansion of
the proposed Galveston Bay LNG project is not considered further.
3.3.3 Conclusion on System Alternatives

All of the projects presented in table 3.3-1 and summarized above have already been
approved to export to FTA countries. To accommodate the additional volume approved by the
DOE for Annova LNG to export to FTA countries, additional facilities similar to those of the
proposed Project would be required. Any such project would require review and authorization of
the additional facilities and would likely result in similar impacts to the proposed Project, and in
some cases, it does not appear that physical space would be available for the necessary expansion
of the already proposed or planned facilities. Therefore, none of the evaluated system alternatives
would result in a significant environmental advantage over the proposed Project.
ALTERNATIVE SITES
period regarding the need to evaluate alternative sites such as industrial areas that are not in
proximity to communities and important wildlife habitat. Based in part on the information
provided by Annova, we evaluated alternatives sites that may also meet the stated objectives of
the Annova Project. We applied screening criteria to identify sites that would be reasonable and
most likely to provide some environmental advantage over the proposed terminal site. The
screening criteria included:
• Waterfront Access. This criterion is required to allow LNG carrier access to the
site. Sites with existing deepwater waterfront access via a deep-draft navigable
waterway (water depths greater than 40 feet below mean sea level) were considered
preferable to avoid or minimize the need for extensive new dredge work.
• Available Land. Siting an LNG facility requires suitable property available for
development. Availability is critical since section 3 of the NGA does not grant the
authority of eminent domain. In some cases, a site may be of adequate size for an
LNG terminal, but the owner is unwilling to sell or lease the property.
• Waterway Obstructions. Waterway obstructions could impede navigation to and
from the site and cause safety concerns. Although bridges with adequate clearance
and spans do not present obstructions to an LNG carrier, bridges can present
navigational challenges and preference is given to sites that are free of waterway
obstructions and can be reached without transit under a bridge.
• Proximity to Natural Gas Supplies. Sites located near sufficient natural gas
supplies and existing infrastructure were considered preferable in order to provide
a source of natural gas to the Project site.
3-11 Alternatives
• Property Size. Based on Annova’s proposed design and the objective of providing
up 7.0 mtpa of LNG, a site of at least 400 acres would be preferable to allow for
placement of all Project components and the construction laydown area, and to
ensure compliance with regulatory requirements for LNG vapor dispersion and
thermal radiation exclusion zones.
A number of sites warranted initial consideration, but ultimately failed to satisfy all the
criteria identified above. For instance, we screened four alternative sites along the Texas Gulf
Coast (Port Lavaca, Port of Corpus Christi – Ingleside, Port Aransas, and Powderhorn Ranch) that
were identified in other pending applications. All of these were dropped from consideration
because they either lacked sufficient size or were not currently available for development. We
also reviewed other sites along the Texas coast that Annova identified in its application, but none
of those sites met the criteria described above and therefore they are not described in detail here.
We also evaluated whether a site in Port Mansfield approximately 30 miles north of the
proposed site might be feasible. While Port Mansfield has waterfront access it would require
significant dredging of the channel to meet deep-draft vessel requirements. Because of the
environmental impacts that would be associated with this dredging, we eliminated this site from
further analysis.
Finally, we identified five alternative sites for further consideration using the criteria
described above. All of the sites are located on the BSC. The general locations of the proposed
and alternative sites, and a comparison of each alternative site to the proposed site, are presented
in figure 3.4-1 and table 3.4-1 and discussed below.
Alternatives 3-12
Figure 3.4-1 Proposed and Alternative LNG Terminal Sites
3-13 Alternatives
TABLE 3.4-1
Comparison of the Proposed and Alternative Sites

Northside Northside Northside Southside South Bay
Factor Proposed Site Site 3 Site 4 Site 5 Site 1 Site
Screening Criteria
Waterfront access Yes Yes Yes Yes Yes Yes
Available land Yes No, under No, under No, under Yes Yes
agreement agreement agreement
Waterway obstructions No No No No No No
Proximity to natural gas supply Yes Yes Yes Yes Yes Yes
Property size (acres) 655 470 503 602 770 1,280
Located in an Environmental Yes Yes Yes Yes Yes Yes
Justice Community
Nearest noise sensitive area 2.3 2.8 1.8 1.1 3.6 1.0
(NSA) (miles)
Number of NRHP-Listed or 0 0 0 1 0 0
Eligible Sites within Alternative
Site boundaries a/
Land Use/Land Cover (acres) (% of site acreage) b/
Forest 4.2 (0.6) 0.0 (0.0) 0.0 (0.0) 0.0 (0.0) 2.4 (0.3) 0.0 (0.0)
NWI-Mapped Wetlands c/ (acres) (% of site acreage)
Estuarine and Marine Wetland 74.8 (11.4) 67.5 (14.4) 207.9 (41.4) 173.6 (28.7) 0.0 (0.0) 726.6 (56.7)
Freshwater Emergent Wetland 58.7 (9.0) 18.5 (3.9) 17.8 (3.5) 125.6 (20.8) 221.3 (28.7) 32.8 (2.6)
Total 133.5 (20.4) 86.0 (18.3) 225.7 (44.9) 299.2 (49.5) 221.3 (28.7) 759.4 (59.3)
Lomas and Mature, Dense Thornshrub Vegetation (acres) (% of site acreage)
Lomas/Point Isabel clay loam 308.3 (47.1) 28.6 (6.1) 136.9 (27.2) 137.7 (22.8) 40.8 (5.3) 0.0 (0.0)
(acres)
South Texas Loma Evergreen 205.8 (31.4) 25.7 (5.5) 24.3 (4.8) 81.0 (25.0) 48.6 (6.3) 0.0 (0.0)
Shrubland (acres)
Sources:
a/ NPS 2015
b/ NLCD 2011
c/ National Wetland Inventory mapping
3.4.1 Proposed Site
The proposed site is located on the south/west side of the BSC, near Brownsville, Cameron
County, Texas, on a site leased from the Port of Brownsville. The site is bordered to the north by
the BSC, to the west by an active dredged material placement area, and to the south and east by
undeveloped land. The proposed site is fully described in sections 2 and 4 of this EIS. The
proposed site meets the screening requirements described above.
3.4.2 Northside Site 3
Northside Site 3 is on the north/east side of the BSC across the channel from the proposed
site. The site is a 470-acre parcel owned by the Port of Brownsville that is currently undeveloped
land. The site is bordered to the north by SR 48, to the south by the BSC, to the west by the Bahia
Grande channel and undeveloped land, and to the east by undeveloped land
Northside Site 3, combined with Northside Site 4 (see below), make up the site of the
proposed Rio Grande LNG Project currently being reviewed by FERC under Docket Number
Alternatives 3-14
CP16-454. While the site is available for development, the site is currently under a lease agreement
between Rio Grande LNG and the Port of Brownsville. Because the site is currently proposed for
another LNG project and is under agreement, it fails to meet the availability criterion and we do
not consider Northside Site 3 further.
Northside Site 4 is on the northeast side of the BSC about 2 miles northeast from the
proposed site. The site is immediately adjacent to the northeast edge of Northside Site 3.
Northside Site 4 is a 503-acre parcel owned by the Port of Brownsville that is currently
undeveloped land. The site is bordered to the northwest by SR 48, to the south by the BSC, and
to the east and west by undeveloped land.
Northside Site 4, combined with Northside Site 3 (see above), make up the site of the
proposed Rio Grande LNG Project currently being reviewed by FERC under Docket Number
CP16-454. While the site is available for development, it is currently under a lease agreement
between Rio Grande LNG and the Port of Brownsville. Because the site is currently proposed for
another LNG project and is under agreement, it fails to meet the availability criterion and we do
not consider Northside Site 4 further.
Northside Site 5 is on the northeast side of the BSC about 3 miles northeast of the proposed
site. The site is immediately adjacent to the northeast edge of Northside Site 4. Northside Site 5
is a 602-acre parcel owned by the Port of Brownsville that is currently undeveloped land. The site
is bordered to the northwest by SR 48, to the south by the BSC, and to the east and west by
undeveloped land.
Northside Site 5 is the site of the proposed Texas LNG Project currently being reviewed
by FERC under Docket Number CP16-116. While the site is available for development, it is
currently under a lease agreement between Texas LNG and the Port of Brownsville. Because the
site is currently proposed for another LNG project and is under agreement, it fails to meet the
availability criterion and we do not consider Northside Site 5 further.
3.4.5 Southside Site 1
The Southside Site 1 is on the southwest side of the BSC directly across from the Port of
Brownsville Shrimp Basin, approximately 4.5 miles southwest of the proposed site. The site is
approximately 770 acres owned by the Port of Brownsville that is currently undeveloped land.
The site is bordered to the north by the BSC, to south by SR 4, and to the east and west by
undeveloped land and open water. The site meets the screening requirements described above.
The primary disadvantages of the Southside Site 1 are its location directly across from the
entrance to the Port of Brownsville Shrimp Basin, and its location 4.5 mile farther along the BSC
than the proposed site. These factors would result in a greater impact on other users of the BSC
during passage of LNG vessels to and from the site as a result of the moving safety exclusion zone
that would be associated with each LNG vessel passage. The Southside Site 1 also abuts SR 4
directly across from the Palmito Ranch Battlefield National Historic Landmark, and the
3-15 Alternatives
aboveground terminal facilities at the alternative site would be significantly closer to the landmark
than the proposed site increasing the potential for visual impacts on the landmark. The Southside
Site 1 would be about 5 miles closer to Brownsville (approximately 4.5 miles distant) compared
to the proposed site (approximately 9.5 miles distant). Finally, based on NWI wetland mapping,
the Southside Site 1 contains more wetlands (approximately 29 percent of the site) than the
proposed site (approximately 20 percent of the site). For the reasons described above, the
Southside Site 1 would not provide a significant environmental advantage to the proposed site.
3.4.6 South Bay Site
The South Bay Site is on the south/west side of the BSC approximately 4 miles northeast
of the proposed site. The site is approximately 1,280 acres owned by the Port of Brownsville that
is currently undeveloped land, portions of which have been previously used for dredged material
disposal (placement area 4A). The site is bordered to the north by the BSC, to the south by South
Bay, to the east by the channel into South Bay, and to the west by undeveloped land. The site
meets the screening requirements described above.
The primary advantage of the South Bay Site is its closer proximity to the entrance of the
BSC. Constructing the Project at this site would require LNG vessel passage of about 4.5 miles
from the entrance of the BSC compared to about 8 miles for the proposed site. Reducing the length
of LNG vessel passage within the BSC would result in potentially reduced impact on other vessel
traffic during passage of LNG vessels to and from the site as a result of the moving safety exclusion
zone that would be associated with each LNG vessel passage.
The disadvantages of the South Bay Site include closer proximity to the communities of
Port Isabel (less than 2 miles) and South Padre Island (3 miles) compared to the proposed site (5
miles and 8 miles, respectively). The South Bay Site is also directly across the BSC from the boat
channel to Port Isabel and, depending on where the LNG carrier marine berth would be located
within the site, its proximity to the boat channel could increase impact on existing boat traffic
within the BSC and the Port Isabel boat channel. Also, based on NWI wetland mapping, the South
Bay Site contains more wetlands (approximately 59 percent of the site) than the proposed site
(approximately 20 percent of the site). Finally, the entire South Bay Site is within designated
critical habitat for the federally threatened piping plover. For the reasons described above, the
South Bay Site would not provide a significant environmental advantage to the proposed site.
3.4.7 Conclusion on Alternative Sites

We conclude that the proposed site represents an acceptable site for the proposed LNG
terminal, and that the alternative sites are either not feasible or are not environmentally preferable
to the proposed site. While the Northside Sites 3, 4, and 5 are acceptable sites for an LNG terminal
these sites are the subject of other proposed LNG projects and are under lease agreements with the
Port of Brownsville. The proposed site is geographically separated from the populated areas of
Brownsville, Port Isabel, and South Padre Island when compared to the Southside Site 1 and South
Bay site.
Alternatives 3-16
ACCESS ROAD ALTERNATIVES

We received comments during the scoping process on the location of the access road. In
consultation with the FWS, Annova identified two potential alternative access road routes in
addition to its proposed route to identify potential options to minimize potential impacts on wildlife
movement through the area.
Table 3.5-1 summarizes and compares the environmental features that would be affected
by construction and operation of each access road alternative. Figure 3.5-1 shows the location of
the proposed and alternative access roads.
TABLE 3.5-1
Comparison of Access Road Alternatives

Proposed Access Road Access Road
Feature Unit Access Road a/ Alternative 1 Alternative 3
Total Length Miles 3.0 3.3 2.6
Collocation with Existing Roads Miles 3.0 2.4 0
Land Cover
South Texas: Loma Evergreen Shrubland
Acres b/ 0.2 5.1 0
(dense thornshrub)
South Texas: Loma Grassland/Shrubland Acres b/ 3.7 2.7 0.4
Delineated Wetlands
Emergent Wetlands Acres b/ 2.2 2.4 34.1
NHD Waterbodies
Streams Linear feet 665.2 25.1 159.8
Ponds Acres 0.0 0.1 0.0
Wildlife Exposure to Traffic
Total Road Distance Traveled c/ Miles 3.8 3.3 5.2
Land Ownership
Brownsville Navigation District Miles along 2.5 3.3 0.2
centerline
FWS Owned Property – Lower Rio Grande Miles along 0.5 0.0 1.3
Valley National Wildlife Refuge centerline
Loma Ecological Preserve (owned by Miles along 0.0 0.0 1.1
Brownsville Navigation District and leased by centerline
FWS)
a/ Called Alternative 2 in Annova’s application.

b/ Based upon 157-foot-wide corridor for equal comparison between alternatives. Actual area of impact would be
somewhat less.
c/ Total distance traveled represents the potential for exposure of wildlife to vehicular traffic. Total distance traveled was
calculated along SH 4 and the access road alternative beginning from the intersection of the westernmost alternative
(Access Road Alternative 1) and SH 4.
No trails or residential areas are within 0.5 mile of the three access road alternatives. The
proposed access road and the other access road alternatives are located within 200 feet of the border
of the Palmito Ranch Battlefield, a National Historic Landmark listed on the NRHP.
3-17 Alternatives
Figure 3.5-1 Location of Proposed and Alternative Access Roads
Alternatives 3-18
Access Road Alternative 1 is collocated with approximately 2.4 miles of existing roads,
the proposed access road is collocated with approximately 3.0 miles of existing roads, and Access
Road Alternative 3 is not collocated with any existing roads. The proposed access road and Access
Road Alternative 1 would generally disturb a similar acreage of wetlands, but both would disturb
approximately 32 fewer acres of total wetlands than Access Road Alternative 3. Additionally,
Access Road Alternative 1 would impact 640 and 135 fewer linear feet of streams than the
proposed access road and Access Road Alternative 3, respectively; however, Access Road
Alternative 1 would impact an additional 0.05 acre of ponds than the proposed access road and
Access Road Alternative 3.
Access Road Alternative 1 is 0.36 mile longer than the proposed access road and 0.74 mile
longer than Access Road Alternative 3. However, Access Road Alternative 1 would require fewer
miles traveled overall than the proposed access road and Access Road Alternative 3 because the
entrance to Access Road Alternative 1 is the westernmost route along State Highway (SH) 4.
Therefore, vehicles would have to travel additional miles along SH 4 to reach the entry points for
the proposed access road and Access Road Alternative 3, a critical factor related to the potential
for ocelot mortality. Access Road Alternative 1 would require approximately 0.5 mile less of
travel than the proposed access road, and 1.8 fewer miles traveled than Access Road Alternative
3. However, Access Road Alternative 1 would traverse the greatest amount of ocelot habitat,
approximately 5.1 acres, compared to little or none by the other alternatives.
Access Road Alternative 1 crosses property solely owned by the BND, whereas the other
access roads also cross property owned or leased by the FWS. Therefore, obtaining an easement
for the proposed access road and Access Road Alternative 3 would result in additional regulatory
processes and the fragmentation of FWS-managed properties.
Based on the overall analysis of these criteria and the minimization of impacts on
waterbodies, wetlands, and biological resources, we believe that neither Access Road Alternative
1 nor 3 would provide a significant environmental advantage over the proposed access road.
However, use of the proposed access road would require an appropriateness determination and a
compatibility determination from the FWS. Annova has stated it is in discussion with the FWS
regarding the appropriateness determination for use of the proposed access road. Annova states
that it would construct and operate its access road on the route identified as Alternative Access
Road 1 in the event the FWS’ regulatory process precludes use of the proposed access road.
PROCESS AND DESIGN ALTERNATIVES

3.6.1 On-site Power Plant versus Grid-Supplied Power
At our request, Annova provided a quantitative estimate of the emissions that would result
from an alternative that would use a purpose-built on-site gas-fired power plant to generate the
electricity required by the Project, versus exclusive use of grid-supplied electric power as proposed.
For this analysis, Annova assumed the on-site gas-fired power plant would be a nominal 400 MW
combined-cycle gas-fired power plant, with a configuration and emission rates based on those
recently approved for the nearby Tenaska Brownsville combined cycle power plant. Table 3.6.1-1
presents estimated emissions for a purpose-built on-site power plant, with a comparison to the
potential emissions from the grid-supplied power. Emissions from grid-sourced electricity emissions
were estimated using emission factors provided in the EPA’s eGRID database, which provides
3-19 Alternatives
system-wide average emission factors for regional grids across the United States, reflecting the
different fuel mix used by electric generators in each region. However, eGRID emission factors are
only available for nitrogen oxides (NOx), sulfur dioxide (SO2), and greenhouse gases (GHG), so they
do not allow comparisons for emissions of other pollutants such as particulate matter and volatile
organic compound (VOC). FERC staff updated Annova’s analysis and selected eGRID emission
factors for the Electric Reliability Council of Texas (ERCOT) region, which serves most of the state
of Texas. The indirect emissions presented below have been updated to use EPA’s latest eGRID
2016 emission factors, which were updated in February 2018 (EPA 2018). The Sierra Club
commented that EPA’s Avoided Emissions and Generation Tool (AVERT) was a more appropriate
and nuanced tool for the analysis of emissions from the grid-derived power for the Project. FERC
staff consulted with the EPA and concluded that we should provide both eGrid and AVERT
estimates of emissions from grid derived power in the ERCOT region.
TABLE 3.6.1-1
Potential Emissions Associated with On-Site Generation Alternative vs Proposed Grid-Sourced Electricity
Annual emissions (tpy)
400 MW On-Site Combined Indirect Emissions from 400 MW Indirect Emissions from 400MW of
Cycle Power Plant of Grid-Sourced Generation (Proposed) Grid-Sourced Generation (Proposed)
Pollutant (Alternative) a/ using eGrid estimate b/ using AVERT estimate c/
NOx 125 955 1,141
VOC 431 Not available (N/A) N/A
CO 1,134 N/A N/A
SO2 9 1,813 2,275
PM10 40 N/A N/A
PM2.5 36 N/A 133
Ammonia 179 N/A N/A
Sulfuric Acid Mist 7.2 N/A N/A
CO2e 1,703,274 1,777,000 2,423,000
______________________
a/ Example power plant employs BACT for NOx control, which utilized selective catalytic reduction. Based on publicly
available data for the Tenaska Brownsville natural gas combined-cycle gas turbine power plant in a 1-on-1
configuration (1 gas turbine with 1 duct burner for supplemental heat) producing approximately 400 MW. See Tenaska
Brownsville Partners LLC PSD Application dated February 2013, proposed State Air Quality Permit Number 108411
and PSD Air Quality Permit Number PSDTX1350.
b/ Grid emissions would be produced by existing power generation facilities distributed across the regional grid service
area. Emissions based on eGRID 2016 factors for the ERCOT region (EPA 2018), assuming 8,760 hrs/yr utilization.
c/ Grid emissions would be produced by existing power generation facilities distributed across the regional grid service
area. Emissions based on AVERT v2.2 factors for the ERCOT region (EPA 2018), assuming 8,760 hrs/yr utilization.
As shown in table 3.7.1-1, the use of a purpose-built, on-site power plant would result in
net emission reductions of NOx and SO2, particulate matter less than 2.5 microns in diameter
(PM2.5), and CO2e. For grid-based electricity, the emissions would be spread across the entire
regional grid service area (which covers almost the entire state of Texas). The s larger amount of
emissions calculated could be attributed to the fact that a 28.8 percent of power generated by
ERCOT in 2016 was coal-fueled (ERCOT 2017), which emits larger amounts of NOx, SO2,
greenhouse gases, particulate matter less than 10 microns in diameter (PM10), PM2.5. Additionally,
43.7 percent of power generated by ERCOT in 2016 was natural gas fueled. Many older natural
gas power plants may not have emission controls as efficient as new combined cycle gas-fired
plants.
Alternatives 3-20
Emission impacts can have both local impacts as well as regional impacts. While a small
400 MW power plant would result in local emissions increases in the area around the power plant
(similar to the modeling analysis in section 4.12), it is unlikely to cause impacts on a regional
basis. The grid-based emissions would likely cause increased utilization of multiple power plants
spatially distributed across the ERCOT grid in Texas, with only incremental increases at any one
power plant site. Additionally, it is possible that the grid power would be derived from ERCOT’s
utility scale wind plants (15.1 percent of generated electricity in 2016). Therefore, a purpose-built
gas-fired power plant would cause increases in local ambient emission impacts around the LNG
facility. It would also result in increased local noise, increased water usage to provide cooling for
the power plant, and increased physical footprint and visual impacts for the Project. This is
compared to the grid-derived power as proposed, where any emissions would be distributed across
the ERCOT grid. In addition, a purpose-built power plant would require additional land to build
the facility. This would have additional land use impacts, as well as impacts on associated habitat,
wildlife, threatened and endangered species, construction noise, operational noise, and visual
impacts. Therefore, we conclude the purpose-built, on-site power plant alternative would not
provide a significant environmental advantage when comparing local air quality impacts with
those of the proposed generation.
3.6.2 Carbon Capture

We received a comment requesting that we mandate carbon capture. We do not have a
response from Annova analyzing the feasibility of carbon capture. However, typically carbon
capture requires a use for the captured CO2. We are not aware of a nearby CO2 pipeline, drilling
operations, or commercial operation needing CO2. In addition, the majority of the power (and
associated emissions) for liquefaction would be obtained from electricity from the grid. We cannot
recommend carbon capture for the CO2 emissions from Annova at this time. It is possible that
CO2 capture technology can be retrofitted in the future for Annova and/or other facilities in the
area for commercial use or storage.
3.6.3 Gas-Fired Compressors versus Electric Compressors

In response to our information request dated October 20, 2016, Annova provided a
quantitative estimate of the emissions from the use of natural gas-fired turbine compressors, as an
alternative to the proposed use of electric motor-driven compressors using grid-based electricity, as
above. Annova determined that six General Electric (GE) model LM6000 PF+ simple cycle gas
turbines would be required, one for each liquefaction train. It was assumed that each GE turbine
would be equipped with dry low NOx combustors and no post-combustion emission controls. Table
3.6.2-1 presents a comparison between the alternative of using six GE LM6000 PF+ turbines and the
potential indirect emissions associated with the proposed use of grid-based electricity generation for
electric motor-driven compressors. The indirect emissions presented below have been updated to
use EPA’s latest eGRID 2016 emission factors. We received a comment from the Sierra Club
indicating that the use of eGRID is not appropriate for this analysis and that the EPA’s Avoided
Emission and Generation Toll (AVERT) should be used instead. After consultation with the EPA,
we have included grid sourced emissions using the AVERT analysis in table 3.6.3-1.
Similar to the discussion above, as shown in table 3.6.3-1 the use of natural gas–fired
turbine compressors would result in net emission reductions of SO2, PM2.5 and CO2e across the
entire ERCOT grid, local NOx emissions would have a net increase. The grid-based emissions
3-21 Alternatives
would likely cause increased utilization of multiple power plants across the grid, and incremental
increases at any one power plant site. Additionally, it is possible that the grid power would be
derived from ERCOT’s utility scale wind plants (15.1 percent of generated electricity in 2016).
Therefore local emission impacts around the LNG facility would increase due to the gas-fired
compressors. It would also result in increased local noise, increased water usage to provide cooling
for the power plant, and increased physical footprint and visual impacts for the Project. This is
compared to the grid-derived power as proposed, where any emissions would be distributed across
the ERCOT grid.
Therefore, the alternative of using gas-fired compressors would not provide a significant
environmental advantage when comparing local air quality impacts with those of the proposed use
of electric motor-driven compressors using grid-supplied generation.
TABLE 3.6.3-1
Comparison of Compressor Technology Emissions
Annual Emissions (tpy)

Indirect Emissions from Electric Indirect Emissions from Electric
Pollutant Estimated Emissions from Six
Motor-Driven Compressors using Motor-Driven Compressors using
GE LM6000 PF+ Gas-Fired
Grid-Based Electricity Generation Grid-Based Electricity Generation
Turbines (Alternative) a/
(Proposed) Using eGRID b/ (Proposed) Using AVERT c/
NOx 1,074 860 1,028
SO2 18 1,632 2,048
PM2.5 105 Not Available 119
CO2e 1,321,404 1,599,000 2,180,000
______________________
a/ Emissions based on GE LM6000 PF+ air permit BACT analysis for Cheyenne Prairie Generating Station. NOx
emission rate reflects use of dry/low NOx emission controls.
b/ Indirect emissions would be produced by existing power generation facilities distributed across the regional grid service
area. Six electric motor-driven compressors are estimated to require 360 MW, or 3,153,600 MWh per year. Emissions
based on eGRID 2016 factors for the ERCOT region (EPA 2018).
c/ Indirect emissions would be produced by existing power generation facilities distributed across the regional grid service
area. Six electric motor-driven compressors are estimated to require 360 MW, or 3,153,600 MWh per year. Emissions
based on AVERT 2007-2017 factors for the ERCOT region (EPA 2018).
3.6.4 Flare Design

Because of concerns about visual impact and potential impact on migrating birds from the
combined warm and cold flare stack that would be 160 feet in height, we asked Annova in an
environmental information request to evaluate the alternative of using a ground flare system.
Annova provided an analysis of a multipoint ground flare (MPGF) system, and totally enclosed
ground flare (TEGF) system, which we have used for our alternative analysis below. Table 3.6.4-
1 provides an analysis and comparison of the proposed flare stack with the two ground flare design
alternatives.
The primary advantage of the MPGF and TEGF alternatives would be that the flare
structures would be shorter than the proposed flare stack. The shorter structures would reduce
visibility of the flares and reduce the potential for migrating birds to strike the tall flare structure
as proposed). As discussed in section 4.8.5 and shown on visual simulations included in appendix
E, the 160-foot-tall proposed flare stack would be visible during the day from several locations
surrounding the site. The flare would also be visible at night during limited flaring events which
would typically only occur up to 12 hours each year, but could occur with a worst-case scenario
Alternatives 3-22
of up to 40 hours per year (see section 2.1.5). However, the reduced visibility of the ground flares
would not eliminate visual impact of the Project since the plant design includes other tall
equipment such as the 186-foot-tall LNG storage tanks.
TABLE 3.6.4-1
Comparison of Proposed Flare Stack and Ground Flare Design Alternatives

Proposed Multipoint Totally Enclosed
Engineering Consideration (Flare Stack) Ground Flare (MPGF) Ground Flare (TEGF)
Required Quantity 2 2 2
Approximate Height 160 feet 58 feet 115 feet
Approximate Footprint ~500-foot-diameter 270-foot by 262-foot area 90-foot-diameter area for
exclusion zone each
Pilot Flame Visible No No No
Relief Flame Visible Yes No No
Smokeless Yes Yes Yes
Safety Concerns None Introduces 140-foot open flames near grade None
where a vapor cloud could accumulate
Process Implications Operates at minimal Requires 20-25 psi of pressure at the flare Operates at minimal flare
flare header inlet, prompting larger flare headers and header pressure
pressure potentially balanced bellows or pilot relief
valves
Disadvantages of the MPGF option include higher flare operating pressure, increased space
required, and the additional safety protocols required for a ground-based flare system. Measures
would also be required to prevent birds and other wildlife from entering the burner zone.
Additionally, Annova states the cost of installing the MPGF alternative would be approximately
three times that of the proposed flare stack. We conclude that the MPGF alternative would not
provide a significant environmental advantage over the proposed flare design because it would
require the largest footprint (approximately 4.5 acres of exclusion zone, compared to 1.6 acres)
and would increase the area of disturbance at the site.
The primary advantage of the TEGF would be the reduced height of 115 feet compared to
160 feet for the proposed flare stack. The reduced height would reduce visibility and potential
impact on migrating birds. The TEGF would also have a reduced footprint (exclusion zone) when
compared to the proposed flare stack. We conclude these would not result in a significant
environmental advantage over the proposed flare stack.
DREDGED MATERIAL PLACEMENT AREA ALTERNATIVES
Annova’s proposed Dredged Material Transport Plan is included in appendix C and

alternative placement sites evaluated in that plan are summarized here. Annova proposes to use
the existing DMPA 5A located along the BSC just west of the Project site for placement of dredged
material not used as fill on site. We evaluated the use of DMPA 4A, 4B, and 5B also located along
the BSC as summarized below. The locations of the proposed and alternative placement areas are
shown on figures 1 and 4 in appendix C.
3.7.1 Proposed Dredged Material Placement Area
The proposed dredged material placement area, DMPA 5A, is approximately 704 acres in
size and is located directly west of the Project site. DMPA 5A is surrounded by a containment
3-23 Alternatives
dike with an average height of 6 feet above the existing grade and a length of about 21,690 linear
feet. The site is used for placement of maintenance dredged material from the adjacent section of
the BSC. The drop-outlet structure was recently refurbished and is functioning.
3.7.2 DMPA 4A and DMPA 4B
DMPA 4A is approximately 469 acres in size and is located about 2 miles east of the Project
site and south of the Port Isabel Channel. DMPA 4A was last used for dredged material placement
in 2009. The drop-outlet structure is currently known to be silted and in need of refurbishment.
DMPA 4B is approximately 243 acres in size and is located directly east of the Project site. DMPA
4B is surrounded by a containment dike with an average height of 7 feet above the existing grade
and a length of about 16,340 linear feet. The site has not been used for maintenance dredging for
several years and the drop-outlet structure is currently not functioning. Both DMPA 4A and 4B
are located in federally listed endangered piping plover critical habitat unit TX-01 which would
restrict use of these DPMAs for future dredge material disposal. Because DMPA 4A and 4B would
be located within piping plover critical habitat, the use of these alternative areas would not provide
an environmental advantage over the proposed placement area.
3.7.3 DMPA 5B
DMPA 5B is approximately 1,020 acres in size and is located west of DMPA 5A. The site
is surrounded by a containment dike with an average height of 12 feet above the existing grade
and a length of about 29,343 linear feet (based upon post-construction surveys provided by the
BND). The site is used for placement of maintenance dredged material from the adjacent section
of the BSC. The drop-outlet structure was recently refurbished and is functioning. DMPA 5B
currently would have capacity to handle the proposed volume of dredged material and appears to
be an acceptable alternative to the proposed area. It would require about 3.5 miles of dredge slurry
pipeline to reach the center of DMPA 5B, whereas Annova’s Dredged Material Transport Plan
includes about 1.6 miles of dredge slurry pipeline required to reach the proposed DMPA 5A.
Because it would require a longer dredge slurry pipeline, this alternative area would not provide
an environmental advantage over the proposed placement area.
3.7.4 Dredged Material Placement Area Conclusions
As described above, none of the alternative dredged material placement areas would
provide an environmental advantage over the proposed placement area DMPA 5A.
CONCLUSION
We reviewed alternatives to the applicant’s proposals based on our independent analysis

and comments received. Although many of the alternatives appear to be technically feasible, we
identified no alternatives that would provide a significant environmental advantage over the
Project. Based on these findings, we conclude that the proposed Project, as modified by our
recommended mitigation measures, is the preferred alternative than can meet the project
objectives.
Alternatives 3-24
4.0 AFFECTED ENVIRONMENT AND ENVIRONMENTAL CONSEQUENCES
In the following sections, we address direct and indirect effects collectively, by resource.
In section 4.13, we also analyze the Project’s contribution to cumulative impacts, by resource. The
environmental consequences of constructing and operating the proposed Project would vary in
duration and significance. Four levels of impact duration were considered: temporary, short term,
long term, and permanent. Temporary impacts generally occur during construction, with the
resource returning to pre-construction conditions almost immediately afterward. Short-term
impacts could continue for up to 3 years following construction. Impacts are considered long-term
if the resource would require more than 3 years to recover. A permanent impact could occur as a
result of any activity that modified a resource to the extent that it would not return to pre-
construction conditions during the 25-year life of the Project, such as within the footprint of the
LNG terminal.
In this section, we discuss the affected environment, general construction and operational
impacts, and proposed mitigation for each resource. We evaluated the applicant’s proposed
mitigation measures to determine whether additional measures would be necessary to reduce
impacts; if we deemed additional measures to be appropriate, we have included them as bulleted,
boldfaced paragraphs in the text. We will recommend that these measures be included as specific
conditions to any authorization that the Commission may issue.
4.1 GEOLOGIC RESOURCES
4.1.1 Geologic Setting
The Project site is located on the West Gulf Coastal Plain Section of the Coastal Plain
Province. The surficial geology consists of Quaternary Holocene sediments, notably alluvium of
the Rio Grande valley and coastal deposits of deltaic, tidal-flat, beach, barrier island, lagoon,
estuary, and dune environments. Surficial geologic units in the vicinity of the Project site include
muddy floodplain alluvium; silty and sandy floodplain alluvium; clay dune and clay to sand dune
deposits; undivided Holocene alluvium; and artificial fill and spoils. These sediments are
underlain by the Pleistocene Beaumont and Lissie Formations, the Pliocene Goliad Sand, and the
Miocene Fleming Formation and Oakville Sandstone (Page et al. 2005).
The topography of the West Gulf Coastal Plain has minimal relief. The elevation in the
Project vicinity (5-mile radius) ranges from 0 to 40 feet NAVD88. The low hills in the area are
aeolian (wind-deposited) landforms, referred to as lomas, with maximum elevations ranging from
15 to 40 feet NAVD88. The Project site includes three distinct lomas: Loma del Potrero Cercado,
Loma del Divisadero, and the eastern portion of Loma de la Juaja.
4-1 Geologic Resource

Annova has performed a geotechnical investigation of the site (Black & Veatch 2016a)
including the following components:
• Twenty-seven geotechnical borings and standard penetration tests from the

surface to depths ranging between 38.5 feet (elevation of -33.2 feet NAVD88) and
200 feet (elevation of -194.3 feet NAVD88);
• soil samples for laboratory analysis and 15 pressure-meter modulus tests in
conjunction with the geotechnical borings at four locations;
• thirty cone penetration tests (CPTs) to depths from 10.5 feet (elevation of -4.1 feet
NAVD88) to 119.3 feet (-113.0 feet NAVD88) and three seismic CPTs to depths
ranging from 90.2 feet (-83.8 feet NAVD88) to 100.5 feet (-97.7 feet NAVD88)
below the existing grade to determine the dynamic properties of the soil;
• three seismic cone penetrometer test soundings;
• thirty-four vane shear tests at eight locations; and
• seventeen dynamic cone penetrometer tests.
The results of the subsurface exploration were used to characterize the site stratigraphy.
Geologic sections that show the soil borings, CPTs, and stratigraphic layers are included in the
Geotechnical Investigation Report (Black & Veatch 2016a). The subsurface stratigraphy consists
of four distinct layers and four sublayers within the top layer (Black & Veatch 2016a). The top
layer in the stratigraphy (Layer 1) consists of clay material that extended from the existing ground
surface to elevations of -20 to -50 feet NAVD88. The next layer down in the stratigraphy (Layer
2) consists of sand with a bottom elevation ranging from -40 to -60 feet NAVD88. The next layer
down in the stratigraphy (Layer 3) consists of a clay material extending to -150 feet NAVD88.
This stratum appears interlayered with sand layers, especially on the northern portion of the site.
The bottom layer (Layer 4) consists of a sand material below the elevation of -150 feet NAVD88.
More information on soils and sediments is contained in section 4.2.
4.1.2 Mineral Resources
Texas is the largest producer in the nation of lignite coal, which is mostly found in narrow
bands in the Texas Gulf Coast region (USEIA 2015); however, there are no known lignite coal
reserves on the Project site. The nearest coal mines are located more than 150 miles northwest;
while the nearest active oil/gas well is located 4.5 miles southeast of the Project site (RRC 2015).
Two dry oil/gas wells are located on the Project site and one directional well is located 2,100 feet
to the northwest. Based on a review of the USGS Mineral Resources Data System (USGS 2014),
no mineral commodity resources occur within 0.25 mile of the Project. The nearest nonfuel
industrial mineral resources (i.e., barite and strontium sulfate) are processed at the Brownsville
Mineral Plant, located 15 miles west-southwest of the Project site.
Based on the lack of mineral resources around the Project site, no impacts on mineral
resources are anticipated as a result of construction or operation of the Project.
Geologic Resources 4-2

4.1.3 Blasting
Based on available soils and geologic maps, and the geotechnical investigations conducted
by Annova (Black & Veatch 2016b), there are no bedrock, glacial moraines, or similar obstructions
within the proposed construction depth, so the need for blasting is not anticipated. Therefore,
adverse impacts from blasting are not expected.
4.1.4 Paleontological Resources
No paleontological resources have been identified within the Project site. The fossil-
bearing formation nearest to the surface at the Project site is the Lissie Formation, which may
contain Pleistocene vertebrate fauna (USGS 2018). The Lissie Formation is expected to have more
than 300 feet of overburden at the Project site (Baker 1995), which is well beyond the depth of
proposed excavation or dredging. Therefore, no impacts on paleontological resources are
anticipated from constructing and operation.
4.1.5 General Impacts and Mitigation
The Project site would be graded to the extent necessary to construct Project facilities
including grading of all but the northeast and southwest portions of Loma Del Potrero Cercado.
As a result, the LNG facilities would alter the existing surface geologic conditions at the site. The
final Project site would include asphalt-surfaced roads, gravel-surfaced roads, general gravel
surfacing, and application of top soil, seed, and mulch for planned vegetated areas.
Construction of the marine berth and turning basins would include excavation and dredging
as well as installation of pilings. Land-based excavation would occur in terrestrial areas and
excavated material would be used for fill where possible or placed on the Project site.
Two dry oil/gas wells are located on the Project site and one directional well located 2,100
feet to the northwest. In accordance with TAC 16 Rule §3.14, cement plugs would be set to isolate
each productive horizon and usable quality water strata in the dry oil/gas wells. Usable quality
water strata is defined as all strata determined by the Groundwater Advisory Unit of the Oil and
Gas Division to contain usable quality water generally less than 1,000 mg/L total dissolved solids
(TDS) but can be up to 3,000 mg/l TDS. Additionally, a 10-foot cement plug would be placed in
the top of abandoned wells, and casing cut off three feet below the ground surface. Since there are
no other known mineral resources at the Project site, we do not anticipate that there would be
impacts on mineral resources in the area.
4.1.6 Conclusion
The potential for geologic hazards such as seismicity, shoreline erosion, and flooding to
impact the proposed Project facilities and measures that would be implemented to minimize those
impacts is discussed in section 4.12. Based on the above discussion, and in consideration of
Annova’s proposed mitigation and design criteria, we conclude that the Project would have a
permanent effect on geological conditions but that potential impacts would be minimized to the
extent practical.
4-3 Geologic Resource

4.2 SOILS
4.2.1 Existing Soil Resources
Project site soils are derived from a mix of natural and anthropogenic processes.
Historically, the Project site was a coastal floodplain comprising a mix of marshes, flats, and lomas
(unique clay dunes that develop over time in arid regions through wind-driven depositional
processes). However, channel dredging activities conducted during the construction of the BSC
in the early 1930s introduced disturbed, saline, poorly developed dredge material to portions of
the Project site (Ferguson 1976).
Soil characteristics were identified using the NRCS SSURGO database for Cameron
County, Texas. The soils identified on the Project site consist of Barrada clay, Point Isabel clay
loam, Sejta silty clay loam, and Twinpalms-Yarborough complex (NRCS 2015b). The results of
geotechnical investigations conducted on the Project site (Black & Veatch 2016a) were also
consistent with the NRCS Soil Survey data. The SSURGO data, described in table 4.2.1-1 and
shown in figure 4.2.1-1, were used to evaluate the soils that would be most susceptible to impacts
from the Project.
TABLE 4.2.1-1
Project Site Soil Characteristics

Total Affected
Ponding Wind Water Poor Construction
Map Prime Frequency/Flooding Erosion Erosion Compaction Revegetation Area
Unit Soil Series Farmland Frequency Hazard Hazard Potential Potential (acres) c/
BA Barrada Clay No Occasional/very Low Slight Severe Yes 8
frequent
PO Point Isabel No None/none Moderate High Moderate Yes 177
clay loam
SE Sejta silty clay No Occasional/none Low Slight Severe Yes 208
loam
TwY Twinpalms- No None/occasional a/ High a/ Slight Moderate a/ Yes b/ 35
Yarborough frequent b/ Moderate High b/
complex b/
W Water N/A N/A N/A N/A N/A N/A 42
Source: NRCS (2015)
a/ Limited to the Twinpalms portion of this complex, 55 percent of the map unit.
b/ Limited to the Yarborough portion of this complex, 40 percent of the map unit.
c/ Numbers may not sum correctly due to rounding.
4.2.1.1 Prime Farmland
Prime farmland soils are defined as those that are best suited to food, feed, fiber, forage,
and oilseed crops (NRCS 2015b). Prime farmland typically contains few or no rocks, is permeable,
excessively erodible, or saturated for long periods, and is not subject to frequent or prolonged
flooding during the growing season. Prime farmland is a soil-series attribute in the SSURGO
database. None of the soils in the Project site are designated as prime farmland.
Soils 4-4
Figure 4.2.1-1 Soils Map of Project Site
4-5 Soils
4.2.1.2 Erosion
Soil erosion is a natural process driven by the action of wind or water. Factors such as
rainfall intensity, wind velocity, topography, ground cover, and physical and chemical properties
of the soil affect soil erosion potential. Soils most susceptible to erosion are those with bare or
sparse vegetation cover, non-cohesive soils with low infiltration rates, and soils on moderate to
steep slopes. As shown in table 4.2.1-1, soils found on the Project site have water erosion hazard
ratings ranging from slight to high, and wind hazard ratings ranging from low to high based on
soil type. The Point Isabel clay loam soils series has a high water erosion hazard rating and the
Twinpalms portion of the Twinpalms-Yarborough complex has a high wind erosion hazard rating.
4.2.1.3 Compaction Potential
Compacted soils have the potential to increase stormwater runoff at the site due to the
reduced infiltration rates of soils when they are compacted. Soils with fine textures and poor
drainage classes are susceptible to compaction. As shown in table 4.2.1-1, all Project site soils
have a moderate to severe compaction potential because they are predominantly clays or clay
loams that are poorly drained and have a high shrink-swell potential.
4.2.1.4 Revegetation Potential
Successful revegetation is important for restoring soil productivity. Soil physical and
chemical properties such as texture, water availability, restrictive layers, stony soil, pH, and
salinity can affect revegetation success. For example, drier soils have less water available for
establishing new vegetation, while coarser textured soils drain more efficiently and have less
holding capacity, which can result in difficult growing conditions for many plants. The
revegetation potential for soils within the Project site is generally poor, as shown in table 4.2.1-1.
The revegetation potential of soils is only a concern outside of the footprint of permanent Project
facilities where Annova would conduct revegetation efforts, while areas within the footprint of
permanent Project facilities would not be revegetated.
4.2.2 Contaminated Soils
There are no known contaminated soils in either the Project site or the BSC. It is not
expected that contaminated sediments would be found during construction based on the on-site
soil investigation results and previous studies. Annova reviewed sediment sampling results from
several previous efforts and all sample results were below regulatory limits for the water use.
Section 4.3 provides additional information about sediment sampling results.
Waterbodies and shorelines are highly susceptible to contamination through the release of
various chemicals from human activities that occur over time along, within, or near the
waterbodies. Therefore, the COE conducted sediment sampling in the BSC for contaminants as
part of the Brazos Island Harbor (BIH) Channel Improvement Project. The results indicate that no
contaminants of concern would be expected to be found in BSC sediments (COE 2013a).
Soils 4-6
4.2.3 General Impacts and Mitigation
Project site soils would be permanently affected by Project facilities, paved or gravel roads,
stormwater detention and evaporation ponds, or other impervious surfaces. Construction at the
Project site would involve grading and raising the site elevation with fill material, excavating for
building foundations, compacting soils, creating impermeable surfaces, and trenching to install
necessary piping and utilities. About 600,000 to 700,000 cubic yards of fill material would be
imported from an off-site location, to be determined prior to construction. Construction activities
such as clearing and grading could accelerate soil erosion processes. Construction activities could
also cause a temporary loss of soil structure, increasing the potential for erosion and compaction.
Left exposed, disturbed soils and soil stockpiles may erode from both wind and water. No soils
would be disturbed or exposed during operation of the Project.
Annova would adhere to its best management practices (BMP) contained in its Plan and
Procedures, which were developed in accordance with applicable regulations and permit
requirements to minimize soil impacts. Adherence to the measures in the Annova Plan and
Procedures would minimize environmental impacts during construction and operation through
sedimentation control and workspace restoration. Additionally, Annova has developed a
preliminary draft Construction SPCC Plan for the Project. Annova would implement its project-
specific Construction SPCC Plan during construction and would develop and implement a separate
Operation SPCC Plan during operation.
Clearing of vegetation would be limited to the areas necessary to accommodate the

liquefaction facilities, marine facilities, and associated workspaces. During construction, Annova
would use areas within the Project site for equipment and materials laydown, contractor yard, soil
stockpiling, soil borrow, and parking. These areas would be graded and covered with gravel as
appropriate. Cleared debris would be chipped and stored for use as mulch or burned as appropriate
(see section 2 for more details regarding the construction process). Where cut and fill would occur,
topsoil would be segregated from subsoil during construction and stored for workplace restoration.
The topsoil stockpiles would be stabilized to minimize erosion from wind and water using the
sediment control measures used for construction-disturbed soils, as described below.
Project site soils are susceptible to wind and water erosion including areas of high erosion
hazard. As required by the Annova Plan and Procedures, temporary slope breakers and sediment
barriers (e.g., silt fences, straw bales, straw logs) would be used to reduce runoff velocity and
divert water to protect adjacent surface waters and wetlands by controlling the movement of
sediment from construction work areas. During clearing and initial grading, sediment barriers
installed at the base of slopes within 50 feet of waterbodies and wetlands near the Project site,
would minimize the potential for adverse impacts until permanent revegetation is determined
successful. Annova’s Environmental Inspectors would inspect erosion control measures for
compliance with the requirements of the Annova Plan and Procedures and the required mitigation
measures. Mulch (consisting of straw, erosion-control fabric, or an equivalent) would be used to
reduce water and wind erosion. As outlined in the Annova Plan and Procedures, mulch would be
applied to stabilize the soil surface or to reduce wind and water erosion in areas where erosion and
sedimentation is not controlled with other erosion control measures. Where applied, mulch would
be spread uniformly over at least 75 percent of the disturbed ground surface to minimize erosion
from construction work areas.
4-7 Soils
Wave generation and propeller-induced scour from Project-related ship traffic in the BSC
may cause erosion along the shoreline. During operation of the Project, vessel traffic in the BSC
would increase by approximately two LNG carriers per week, along with supporting vessels as
needed. LNG carriers would travel at low speeds within the BSC. Rock rip-rap protection would
be placed along the terminal shoreline at the Project facilities to prevent erosion due to vessel
propellers or bow thrusters. Annova developed a two-dimensional hydrodynamic model to examine
Project impacts on water velocity, or current speed, in the BSC to evaluate the potential for increased
shoreline erosion. The model assessed changes in BSC water velocity with and without the terminal
marine slip and turning basin in place. The results indicate the water velocities in the BSC would be
reduced (about 5 to 7 percent) on the shoreline opposite the Project site and relatively unchanged on
the south bank adjacent to the Project site and therefore the Project would not result in increased
shoreline erosion (Black & Veatch 2016c). Section 4.3 provides additional information about
hydrodynamic modeling results.
Grading, spoil storage, and equipment traffic can compact soil, reducing porosity and
increasing runoff potential. Soils in the Project site have a moderate compaction potential because
they are predominantly clays or clay loams that are poorly drained and have a high shrink-swell
potential. While the soils have a moderate compaction potential and high shrink-swell potential,
they are believed to be suitable for use as fill material. On-site soil used as fill for roads or other
heavy traffic areas would likely require drying or blending with lime or other material to meet
compaction requirements, which Annova has agreed to implement as needed. Subsoil and topsoil
would be tested to measure compaction and determine the need for corrective action prior to
seeding in accordance with the Annova Plan and Procedures. Annova would also minimize the
potential for impacts from compacted soils by constructing stormwater runoff systems at the
Project site to reduce the potential for erosion. Significant impacts associated with the compaction
potential of Project soils are not anticipated given the implementation of these measures
Annova would work to promote the rapid, successful reestablishment of vegetation of

temporarily disturbed areas in accordance with its Plan and Procedures and would develop
specific measures in coordination with the land-management authorities and permitting agencies.
Soils within the Project site are characterized as slightly to strongly saline, which reduces
revegetation potential. Annova would consult with the Cameron County office of the NRCS to
identify native, salt-tolerant plant species suitable for the soils where revegetation potential is
limited because of saline soils. Annova would conduct follow-up inspections of all disturbed
areas, as outlined in its Plan and Procedures, to determine the success of revegetation.
The Project would include dredging of material for construction of marine facilities and
turning basins (see section 2.6.2). Annova proposes to use DMPA 5A, located just west of the
Project site, for disposal of dredged material not used as on-site fill. Although there are no known
contaminated soils within the Project site or the BSC, dredging has the potential to expose
unidentified contaminated soils. Annova has developed a Dredged Area Sampling and Analysis
Plan for dredging activities as part of the COE permit application (SWG-2015-00110) and would
implement the sediment sampling and analysis following COE guidance for dredged material
sampling and testing to minimize the potential for the release of contaminated soils.
Spills or leaks of fuels, lubricants, and coolant from construction equipment and operating
activities may contaminate soils on or adjacent to the site. Annova would develop a project-
Soils 4-8
specific Spill Prevention and Response Procedures for construction in accordance with the SPCC
Plan, as required by the Annova Plan and Procedures, and applicable federal and state
requirements. The Spill Prevention and Response Procedures would establish procedures,
methods, and equipment requirements, as well as secondary containment for fuel and chemical
storage areas to prevent and minimize impacts from spills during operation; therefore, any impacts
resulting from soil contamination are expected to be minor and temporary. Annova has submitted
to FERC a preliminary Construction SPCC Plan that describes general preventive BMPs,
including personnel training, equipment inspection, and refueling procedures to reduce the
likelihood of a spill. It also describes the mitigation measures, including containment and cleanup,
to minimize potential impacts should a spill occur. These plans would address the storage and
transfer of hazardous materials and petroleum products. However, because Annova has not yet
provided the final Spill Prevention and Response Procedures and Construction SPCC Plan or the
Operation SPCC Plan, we recommend that:
• Prior to construction, Annova should file with the Secretary of the

Commission (Secretary), for review and written approval by the Director of
the Office of Energy Projects (OEP), its final Spill Prevention and Response
Procedures and Construction SPCC Plan, and Operation SPCC Plan.
4.2.4 Conclusion
Based on the above discussion, and in consideration of Annova’s proposed mitigation

measures and design criteria, we conclude that the Project would have a permanent effect on soils
within the terminal site but that potential impacts would be minimized to the extent practical.
4-9 Soils
4.3 WATER RESOURCES
4.3.1 Groundwater
4.3.1.1 Aquifers
The Project is located in the Coastal Lowlands aquifer system in Cameron County, Texas.
The Coastal Lowlands aquifer is commonly referred to as the Gulf Coast Aquifer system, which
stretches from Florida to Mexico along the Gulf of Mexico, and consists of several aquifers,
including the Jasper, Evangeline, and Chicot aquifers. The aquifers are composed of mostly sand,
silt, and clay (George et al. 2011). The Texas portion of the Gulf Coast Aquifer system supports
a third of the state’s population (Mace et al. 2006), with 1.1 million acre-feet of groundwater
pumped annually, the majority of which is used for municipal and irrigation purposes (Chowdhury
and Turco 2006; Ashworth and Hopkins 1995). The Gulf Coast Aquifer system increases in
thickness to the southeast beneath the Project and into the Gulf of Mexico. At the Project site,
groundwater is near the surface due to the proximity of the BSC (Black & Veatch 2016a). The
shallow subsurface geology varies but generally consists of alternating deposits of clays, silts, and
sands deposited over time by ancestral streams, tidal marshes, and/or estuarine environments, and
local surficial groundwater sources consist of discontinuous beds of sand near the surface.
The portion of the Gulf Coast Aquifer system that underlie the Project is not suitable for
potable uses. The Gulf Coast Aquifer system is separated into five permeable zones and two
confining units (Ryder 1996) with the Chicot Aquifer nearest to the surface and the Evangeline
Aquifer just below. The Chicot Aquifer in the Project area is considered saline and not suitable
for potable use. The Evangeline and Chicot aquifers provide a majority of the groundwater used
in Cameron County. However, because the quality of groundwater in the area does not meet Texas
Department of Health standards, the Rio Grande and surface water reservoirs supply over 97
percent of the water consumed in the valley (TWDB 1990; Paine 2000).
Sole source aquifers are designated by the EPA and protected as they are the principal
source of drinking water for an area and for which no other reasonably available alternative sources
exist if that aquifer becomes contaminated (Section 1424(e) of the Safe Drinking Water Act of
1974). No designated sole source aquifers occur near or within the Project site (EPA 2008) as the
Chicot Aquifer is not designated as a sole source aquifer in Texas (EPA 2017).
4.3.1.2 Water Supply Wells
No potable water supply wells are located within the Project site or within 150 feet of
Project (TCEQ 2015a, 2015b). Based on a review of the TCEQ Well Protection Program for
Cameron County, the Project is not within a groundwater conservation district (TWDB 2015), and
the nearest domestic water supply well is over 4 miles north of the Project site (TCEQ 2015b;
TWDB 2016).
4.3.1.3 Groundwater Quality
In coastal areas, groundwater becomes increasingly saline because of higher total dissolved
solids (TDS) concentrations found near and along the coast. The concentrations of some
constituents such as chloride, often exceed the Texas Department of State Health Service
Water Resources 4-10

recommended drinking water or irrigation water quality standards. TDS concentrations in

groundwater in the lower Rio Grande Valley often increase to about 3,000 milligrams per liter
(mg/L) (Chowdhury and Mace 2007). The results of a survey by the Texas Water Development
Board of groundwater wells within counties adjacent to the Rio Grande, including Cameron
County, indicate increasing salinity closer to the coast, with wells near the Project exhibiting saline
to briny (5,000 mg/L to 40,000 mg/L) groundwater (Paine 2000). The increased concentration of
TDS in coastal counties is likely due to windblown salt into shallow inland aquifers or saltwater
intrusion from the Gulf of Mexico (Paine 2000).
4.3.1.4 Groundwater Impacts and Mitigation
Construction
Section 2.5 of this EIS provides a detailed description of construction activities associated
with the Project. The majority of the excavation would occur adjacent to the BSC where
groundwater is located near the surface. Excavation, the addition of fill, and the installation of
foundations and underground utilities would have localized and short-term effects on the
groundwater during construction with effects to local water table elevations. The shallow aquifer
could sustain minor, temporary indirect impacts from changes in overland water flow and recharge
caused by clearing and grading of the work areas. Near-surface soil compaction caused by heavy
construction vehicles could cause localized reduction in the soil’s ability to absorb water.
Because of the temporary localized effects of construction on groundwater and the

relatively large distance between the Project site and any water supply wells, we conclude that the
potential impacts on groundwater resources due to Project-related construction activities would be
minimal.
Contamination
Shallow groundwater areas could be vulnerable to contamination caused by inadvertent

surface spills of hazardous materials used during construction and operation of the Project.
Accidental spills and leaks of hazardous materials, such as fuels, lubricants, and coolants,
associated with equipment trailers, the refueling of maintenance vehicles, and the storage of fuel,
oil, and other fluids pose the greatest risk to groundwater resources. If not cleaned up,
contaminated soil could continue to leach and add pollutants to groundwater long after a spill has
occurred.
Implementation of Annova’s project-specific Plan and Procedures (see appendix B), as

well as their SPCC Plan, would minimize the potential impacts of spills of hazardous materials
during construction and operation. As previously described, the draft SPCC Plan addresses
training, prevention, and mitigation to reduce potential impacts.
All LNG equipment and piping systems holding LNG would include a spill containment
system utilizing curbed areas, troughs, open drains, and an impoundment basin. An engineered
earthen containment berm around each LNG storage tank would contain 110 percent of the tank
capacity of stored LNG per Title 49 CFR Part 193 requirements.
4-11 Water Resources

Section 2 provides a description of pile-driving activities that would occur during

construction. The maximum depth of pile-driving activities would extend to approximately 156
feet below ground surface. These activities would occur within the saline portion of the Chicot
Aquifer, which is not used as a source of potable water. Pilings would not extend beyond the
Chicot Aquifer, as the bottom of the Chicot Aquifer lies at an elevation of -1,200 feet (TWDB
2006). Therefore, pilings would not intersect with the Evangeline Aquifer, which yields moderate
to large quantities of fresh to slightly saline water (TWDB 1990).
Groundwater Withdrawals
Annova would obtain potable water from the BND via the Brownsville Public Utilities
Board, who obtains water (surface water) from the Rio Grande. Therefore, Annova would not use
or withdraw groundwater during construction or operation of the Project.
4.3.1.5 Conclusion for Groundwater
With the implementation of measures described above and the distance to water supply
wells, we conclude that the potential for the Project to contaminate aquifers or water supply wells
would be minimal. As Annova would not use or withdraw groundwater during construction or
operation of the Project, no impacts on groundwater resources are anticipated.
4.3.2 Surface Water
4.3.2.1 Existing Surface Water Resources
The Project is located (from large region to small sub-watershed) within the Texas-Gulf
water resource region; South Laguna Madre subbasin; Brownsville Ship Channel watershed; Bahia
Grande-Brownsville Ship Channel subwatershed, identified by USGS Hydrologic Unit Code
(HUC) 121102080900 (USGS 2016). As shown in figure 4.3.2-1, the eastern side of the South
Laguna Madre subbasin extends 59 miles southward from the Padre Island sand and mudflats to
within 3 miles of the Mexican border and opens into the Gulf of Mexico through the Brazos
Santiago Pass (Onuf 2002). The South Laguna Madre subbasin encompasses the Project site and
four counties (Cameron, Hidalgo, Starr, and Willacy) (EPA 2016). Major waterbodies located
within the north end of the subbasin include the Arroyo Colorado, the Raymondville Drain, the
North Floodway, and the Hidalgo County Main Flood Channel, which are all located north of the
Project site (see figure 4.3.2-1). Other major waterbodies located within the south end of the
subbasin include the Resaca de Los Cuates, Resaca del Rancho Viejo, Resaca de La Palma, and
the BSC. The Project would not cross any streams, Wild and Scenic Rivers, or special designation
surface water protection areas. No potable surface water intakes are located within 3 miles
downstream of the Project site.
Freshwater inflow events to the system are limited due to the arid conditions of the
watershed. The relatively flat topography surrounding the BSC results in drainage into the BSC
from South Bay and Bahia Grande. The historic average annual rainfall for the Brownsville area
is approximately 27.4 inches (NOAA 2013).

Figure 4.3.2-1 South Laguna Subbasin

The BSC is the only waterbody that occurs within the Project site. Other surface
waterbodies connected to the BSC and in the vicinity of the Project site or the LNG carrier route
to the site include Laguna Madre, South Bay, Bahia Grande, and San Martin Lake. Figure 4.3.2-
2 identifies these waterbodies in relation to the Project site, and table 4.3.2-1 provides a summary
of attributes associated with these waterbodies.
The BSC is approximately 42 feet deep and 17 miles long, and includes a turning basin
located at the western terminus approximately 36 feet deep and 1,200 feet wide (BND 2012). Field
surveys report that open water within the Project site is non-vegetated; the channel is a poor habitat
for seagrass due to the channel being disturbed by drawdowns and return surges associated with
normal tidal movement and human-induced actions such as vessel traffic. Average
physiochemical and water quality parameters of the BSC are provided in the following subsection.
The Laguna Madre is a long, narrow, shallow lagoon separated from the Gulf of Mexico
by a barrier island (North and South Padre islands). The Laguna Madre is rich in seagrasses at
least in part due to its hypersaline environment in which salinities often exceed that of seawater.
Low precipitation, flat terrain, and relatively few large fresh waterbodies all contribute to the
hypersaline environment in which evaporation exceeds freshwater inflows (Handley et al. 2007).
The Lower Laguna Madre is connected to the Gulf of Mexico through the Brazos Santiago Pass,
which also serves as the entrance to the BSC and would be used by LNG carriers transiting to the
Project site.
South Bay is located within the South Laguna Madre watershed and consists of
approximately 3,500 surface acres of water (TPWD 2016a, b). South Bay is connected to the south
side of the BSC about 5 miles northeast of the Project site. The South Bay Coastal Preserve is
bounded on the south by the Rio Grande riparian edge, on the north by the BSC, and on the east
by Brazos Island (TPWD 2016a). South Bay is a shallow waterbody with unique ecological
features such as seagrass beds, black mangroves (Avicennia germinans), and oyster reefs (TPWD
2016b). Like the Lower Laguna Madre, South Bay contains seagrass beds that function as nursery
habitat for commercially important fishes and crustaceans. Section 4.6 provides additional
information on fisheries and wildlife that inhabit local waterbodies.
The Bahia Grande is located approximately 0.7 mile north of the Project site on the north
side of the BSC. This waterbody is a large saline lagoon connected to the BSC via a pilot channel
constructed in 2005. Between the 1930s and the 1950s, the accumulation of material along the
BSC from maintenance dredging decreased the tidal flow into the small connection between Bahia
Grande and the BSC. The pilot channel allowed the area to refill (FWS 2015). The Port has plans
to widen the pilot channel to increase tidal flow into the Bahia Grande basin for water exchange
on a daily basis (FWS 2015).
San Martin Lake is north of the BSC and southwest of the Bahia Grande and connected to
the BSC by a channel that is about one mile southwest of the Project site. It is a shallow saline
lagoon with characteristics generally similar to Bahia Grande.

Figure 4.3.2-2 Surface Waterbodies in the Vicinity of the Proposed Project

TABLE 4.3.2-1
Surface Waterbodies in the Vicinity of the Proposed Project Site

Waterbody Type State Water Quality Classification a/ Fishery Type
Laguna Madre Estuary Aquatic Life (exceptional and oyster) Warmwater
Recreational Use (primary contact recreation)
Brownsville Ship Channel Estuary Aquatic Life (exceptional) Warmwater
Recreational Use (noncontact)
Additional Use (navigation)
South Bay Estuary Aquatic Life (exceptional and oyster) Warmwater
Recreational Use (primary contact recreation)
Additional Use (seagrass propagation)
Bahia Grande Estuary none b/ Warmwater
Aquatic life
Additional Use (wetland water quality functions) c/
San Martin Lake Estuary none b/ Warmwater
Source: TCEQ 2014a, b; TPWD 2016b; FWS 2004, 2015
a/ The specific “Additional Uses” are not identified in TCEQ (2014a), but “General Use” is listed in the 2014 Integrated
Report (TCEQ 2014b).
b/ TCEQ (2014a) does not have a water quality classification for Bahia Grande or San Martin Lake.
c/ FWS (2015) identifies the uses of Bahia Grande, but are not regulated by TCEQ for water quality
Surface Water Quality and Designated Uses
Water quality standards are developed by states to enhance or maintain water quality,
protect the public health or welfare, and provide for the designated uses of the waters of the state.
In Texas, the surface water quality standards are codified in TAC 30:307. These designated uses
are identified for each waterbody in table 4.3.2-1.
The TCEQ designates uses for surface waters in Texas, including:
1. Recreation (primary contact recreation 1, primary contact recreation 2, secondary

contact recreation 1, secondary contact recreation 2, and noncontact recreation)
2. Domestic water supply (public water supply, sole-source surface drinking water
supply, and aquifer protection)
3. Aquatic life (minimal, limited, intermediate, high, exceptional aquatic life, and
oyster waters)
4. Additional uses (navigation, agricultural water supply, industrial water supply,
seagrass propagation, and wetland water quality functions)
The TCEQ designates boundaries within its surface waters (called segments and
subsegments) to monitor all portions of streams and waterbodies. The Project site is adjacent to
the BSC stream segment 2494 (subsegment 2494_01), which includes waters from the Laguna
Madre-BSC confluence upstream to the Port of Brownsville (TCEQ 2012). The TCEQ collects
water quality data from a surface water quality monitoring station located northeast of the Project
site within the BSC (TCEQ 2016). Similar water quality data were collected in the BSC during a
pilot study for construction of a desalinization plant in south Texas (NRS Engineering 2008).

Generally, water quality parameters in the BSC exhibit averages and ranges similar to nearshore
marine waters, with slight variations in salinity and dissolved oxygen associated with episodic
rainfall events. Table 4.3.2-2 presents water quality physiochemical data from the TCEQ
monitoring station and from the Texas Water Development Board pilot study (NRS 2008).
The TCEQ considers the waters of the BSC (segment ID 2494) impaired due to the
presence of Enterococci bacteria; because it does not meet applicable water quality standards, the
BSC is on the CWA Section 303(d) list of impaired waters (TCEQ 2014b). TCEQ plans to obtain
additional data concerning the non-attainment of the standard for recreational use before
implementing any actions (i.e., management strategies) to correct the impairment (TCEQ 2014b).
This waterway also had depressed dissolved oxygen as a listed concern for screening level (TCEQ
2014b). The South Bay meets the water quality standards and therefore is not included on the list
of impaired waters. The Bahia Grande has not been evaluated by the TCEQ.
There are no known contaminated sediments within the BSC. Annova reviewed sediment
sampling results reported in 2012 by TCEQ, in 2000 by the FWS, and in 2013 by the COE.
Between December 1, 2003, and November 30, 2010, the TCEQ collected sediment samples from
the BSC and tested them for metals (i.e., mercury, zinc, silver, nickel, lead, copper, chromium,
arsenic, and cadmium). All of the sample results were below regulatory limits for the water use
(TCEQ 2012b). Sediment sampling was also conducted in 2000 due to a nearby spill of furfural,
an organic compound derived from agricultural byproducts, into storm drains in the city of
Brownsville. Although the BSC was one of three possible impact zones, subsequent sediment
sampling showed no evidence of furfural contamination (NOAA 2000). The COE also conducted
sediment sampling for contaminants as part of the Brazos Island Harbor Channel Improvement
Project. The analytical results indicated no chemical or physical concerns regarding the placement
of BSC sediments in upland or offshore dredged material placement areas (COE 2014).
TABLE 4.3.2-2
Average Physiochemical Parameters in the Brownsville Ship Channel

Dissolved Oxygen pH Alkalinity Total Salinity
Year Temperature (°C) (mg/L) (standard units) (mg/L) (ppt)
2007-2008 a/ 25.0 NA 8.0 140.9 NA
2010 b/ 27.9 8.6 8.0 123.8 31.8
2011 b/ 24.6 6.1 8.0 133.5 36.1
2012 b/ 22.0 7.2 7.9 129.9 34.3
2013 b/ 27.9 6.3 8.0 128.4 36.9
2014 b/ 24.9 6.2 8.0 133.2 31.9
2015 b/ 20.9 7.2 8.0 131.9 31.8
a/ NRS 2008
b/ TCEQ 2016; Surface Water Quality Monitoring Segment ID 2494
°C = degrees Celsius
mg/L = milligrams per liter
NA = data not available
ppt = parts per thousand

Annova developed a Sampling and Analysis Plan for dredging activities as part of the COE
permit application (SWG-2015-00110). Annova would implement the sediment sampling and
analysis following COE guidance for dredged material sampling and testing.
4.3.2.2 Surface Water Impacts and Mitigation
Potential impacts on surface waters during construction and operation of the Project are
associated with dredging and dredge material placement, as well as construction of the LNG
loading and ship berthing facilities; vessel traffic; site modification and stormwater runoff
(including spills or leaks of hazardous materials); and hydrostatic testing. The following sections
describe these potential impacts as well as measures that would be taken by Annova to avoid or
minimize impacts on surface waters
Dredging, Dredge Material Placement, and In-Water Work
Section 2.6.2.1 of this EIS includes a summary of the estimated volumes and types of
dredged and excavated material for the marine berth and turning basin. The majority of the
excavation would occur on land, thereby minimizing suspension of sediment and turbidity impacts
on water quality that could occur due to direct dredging within the BSC. The dredging would
employ a hydraulic cutter suction dredge. Suction dredging reduces impacts on water quality
compared to other dredging methods because the excavated material is suctioned into a pipeline,
minimizing the loss of material and re-suspension of sediments into the water column. Additional
details are included in Annova’s Dredged Material Transport Plan in appendix C.
The BSC is not impaired for turbidity, and no total maximum daily loads (TMDLs) have
been established for this waterbody. Annova would conduct sediment testing specific to the
Project in accordance with the Sampling and Analysis Plan as approved by the COE to determine
the characteristics of the sediments to be removed for the Project.
As described in section 2.6.2.1 of this EIS, Annova proposes to place dredged material in
the Port of Brownsville DMPA 5A, located immediately west of and adjacent to the Project site.
During transport of dredged material, a wye valve would evenly distribute the dredged material
into internal partitions. The current configuration of DMPA 5A uses a series of internal berms
(dewatering lanes) to guide water through the DMPA from the discharge point to the final outfall
point, at a rate that allows the fine particles to settle out, with final discharge through the existing
drop outfall structure directly to the BSC. Annova would raise the levee heights using existing
material in the DMPA and re-profiling the dewatering lanes prior to the start of dredging operations
to allow for appropriate residence time, such that the discharge would be limited to constrain total
suspended solids to a maximum of 300 mg/L. Annova would perform column settling tests early
in detailed engineering to confirm the settling characteristics of the dredged material to ensure
efficient function of the DMPA. This distribution of the deposited material during dredging would
ensure that the rate of particle settling upon discharge and the residence time can be appropriately
managed without affecting the dredging production rate. The effluent outfall at the drop-outlet
structure would be monitored for excessive turbidity and erosion issues.
Dredging activities would result in increased turbidity in the BSC, which could have
localized effects. These localized effects would include reduced light penetration and a

corresponding reduction in the primary production of aquatic plants, algae, and phytoplankton. As
a result, a short-term reduction in dissolved oxygen concentrations in the BSC may occur, resulting
in temporary displacement of motile organisms, and/or stress and reduction in numbers of sessile
benthic organisms (LUMC 2016) (see section 4.6 for more details regarding impacts on organisms
due to turbidity). The results of field surveys indicate that no vegetation occurs in the open water
in the BSC within the Project site (see figure 4.3.2-3). Known seagrass beds are identified in the
BCS at Port Isabel and the entrance to South Bay and the Lower Laguna Madre over 5 miles
downstream (figure 4.3.2-3). Comments on the draft EIS also stated that the Project would have
adverse impacts on seagrasses in the Bahia Grande. No seagrasses are currently mapped in the
Bahia Grande, nor is the Bahia Grande identified as an area containing seagrass in the TPWD’s
2012 update to its Seagrass Conservation Plan (Onuf et al. 2012, TPWD 2019); however, anecdotal
records indicate that earlier restoration efforts have resulted in some seagrasses growing in the
interior of the wetland unit (The Brownsville Herald 2017). However, increases in turbidity in the
BSC would not likely extend into any known important seagrass nursery habitats over 3 miles
downstream, or to the potential seagrass beds in the Bahia Grande interior.
Annova performed turbidity plume modeling using the COE’s DREDGE model, plus a
“far-field” distribution model of suspended sediment (Black & Veatch 2016d). The results were
predicted using a maximum velocity of current in the BSC at 5 feet/second. We used the results
to evaluate potential impact on water quality within the BSC and the Bahia Grande wetland
mitigation site. The model predicted a total suspended solids (TSS) concentration of 4 to 6 mg/L
above ambient within the greatest lateral extent of the plume, 328 feet (100 meters) to either side
of the plume centerline, at the surface of the BSC (Black & Veatch 2016d). The outgoing tide
would transport the suspended clay particles downstream of the shallow (-3.25 to [proposed] -9
feet mean sea level) Bahia Grande Pilot Channel entrance. This, combined with the tidal flow
from the Bahia Grande during an outgoing tide, would prevent particle transport into the Bahia
Grande. Particle transport into the Bahia Grande would occur during an incoming tide, where
effects to the Bahia Grande would likely be greater with elevated TSS concentrations of 4 to 6
mg/L at the periphery of the plume 328 feet from the dredge cutterhead, and would result in a
minor impact on water quality within the portions of the Bahia Grande closest to the connection
with the Pilot Channel. Similarly, although not directly modeled, particle transport during a slack
tide would be limited due to the lack of water movement, which would restrict particle transport
from the dredging area. As a result, there would be limited impact on the Bahia Grande from
dredging during a slack tide.

Figure 4.3.2-3 Known Seagrass Beds within the Vicinity of the Proposed Project

Regarding downstream movement of particles during dredging activities on an outgoing

tide (5 feet/second), there would be effects on water quality downstream for a distance of
approximately 2.5 miles or more at the surface of the water and mid-water column (at 20 feet
above the dredge cutterhead), and the effects on water quality downstream near the sediment
surface (dredge cutterhead level) would extend approximately 1,600 feet downstream. Clay
particles, which are re-suspended, generally do not settle out of the water column. Currents can
increase re-suspension by acting directly on the newly dredged faces and affect the dispersion of
the re-suspended sediments by moving particles along with the current. The mean TSS level in
the BSC is approximately 36 mg/L (Dannenbaum Engineering and URS 2004). The predicted
increase of 4 to 6 mg/L above ambient would represent an 11-17 percent increase over ambient
within the range of impact (up to 2.5 miles downstream), which would be a moderate impact.
Annova developed a two-dimensional hydrodynamic model to assess potential changes to

water velocity (current speed) and shoaling (sedimentation) rates from construction and operation
of the Project (Black & Veatch 2016c, 2016e). The model also evaluated the effect of the proposed
widening of the Bahia Grande Pilot Channel. The modelling predicts that water velocity at the
Project site would be reduced due to the proposed dredging; however, there would be a 2 percent
increase in water velocity in the BSC to the east of the Project. This change in water velocity
would not be expected to significantly impact the transport distance of the turbidity plume caused
by dredging. In contrast, the modeling results indicate water velocities in the BSC and the Bahia
Grande Pilot Channel, which leads to the Bahia Grande wetland restoration site, would increase
considerably as a result of the widening of the Bahia Grande Pilot Channel. The water velocity in
the BSC east of the Project would increase by 62 percent and the water velocity in the Bahia
Grande Pilot Channel would increase by 57 percent following channel widening. The change in
water velocity as a result of the proposed widening of the Bahia Grande Pilot Channel may increase
the transport distance of the turbidity plume caused by Project dredging, although the extent of the
turbidity plume was not evaluated in the model. The potential extent of the turbidity plume was
assessed with the DREDGE model, as described above.
The hydrodynamic model developed by Annova included a sediment transport model to

evaluate suspended sediment transport and deposition patterns as a result of Project dredging
activities (Black & Veatch 2016e). The model simulated dredging at the Project site for a one-
month period. Model results indicate a higher rate of shoaling than has been observed in the main
channel of the BSC, which is 10 cubic yards per linear foot (COE 2014). Modeled shoaling rates
in the BSC were 0.01 inches with a maximum of 0.05 over the one-month simulation period. The
sediment transport modeling assumed the Bahia Grande Pilot Channel widening was completed
and therefore shoaling rates in that channel were lower than average due to the increased water
velocity that would be caused by channel widening.
Construction of the marine facilities would require installation of pilings using land-based
and in-water equipment. Table 2.6.2-2 in section 2.6.2.1 identifies the number and types of pilings
associated with construction of the marine facilities. In-water construction within the BSC using
impact and vibratory hammers would result in increases in turbidity. Upon completion of in-water
construction activities, suspended particles would settle; however, due to the nature of the new
material (consisting of mostly clay), the duration of the turbidity is undetermined.

During operation of the Project, periodic maintenance dredging would be required to

maintain depth in the turning basin. Maintenance dredging would only occur in areas that have
been previously dredged during the initial construction of the Project. Hydraulic cutter suction
dredging would also be used to limit re-suspension, and sediments would be sampled and tested
for priority pollutants prior to each maintenance dredging event according to the methodology
described in the Inland Testing Manual (EPA and COE 1998). During maintenance dredging,
there may be an increase in turbidity in the BSC; however, the cutter of the dredge would suction
most of the suspended fine-grained sediments, and the temporary increase in turbidity and
suspension of solids would be contained to meet water quality criteria identified in the 401 Water
Quality Certification at the edge of the work zone, resulting in localized effects.
Annova submitted permit applications for dredging activities to the COE. Annova is
required to obtain several permits that would address dredging and dredged material management,
including permits from the COE under Section 404 of the CWA and Section 10 of the RHA.
Permits for water discharges into the BSC would be obtained from the EPA and/or the TCEQ
under Section 401 of the CWA. An NPDES permit under Section 402 of the CWA issued by the
RRC would be necessary to regulate return water flowing from the DMPA 5A. The issuance of
these permits takes into consideration impacts on environmental resources; therefore, the permits
may contain operational limitations designed to minimize or avoid environmental impacts.
To further minimize impacts, Annova would prepare a Dredging Water Quality Monitoring
Plan. This plan would include use of BMPs during dredging and would require monitoring of
turbidity, flow rate, pH, and TSS at locations near dredging operations. If monitoring indicates
that TSS or turbidity levels exceed the limits established by the plan or the COE or EPA permit
requirements, Annova would implement the following measures as appropriate:
• reduction of cutter rotation speed to reduce potential for side-casting sediment away
from the suction entrance and resuspending sediment (typically effective on
relatively loose, fine-grain sediment);
• reduction of swing speed to ensure that the dredge head does not move through the
cut faster that it can hydraulically pump the sediment, thereby reducing
resuspended sediment;
• reduction or elimination of bank undercutting by removing the sediment in
maximum lifts equal to 75 percent of the cutterhead diameter; and/or
• termination of suction pump motor after cutterhead shutdown and commencement
of the suction pump before cutterhead startup to avoid a period when materials are
resuspended without active suction occurring.
Vessel Traffic
Shoreline Erosion and Resuspension of Sediments
LNG carrier and barge traffic would use the BSC and the Gulf Intracoastal Waterway, both
of which are well-traveled commercial routes. Increased vessel traffic, including transit of LNG
carriers during operations, could result in short-term periods of increased turbidity resulting from
entrained bottom sediments (e.g., sediment on the channel bed is incorporated into the increased

flow resulting from LNG carrier transit). The potential effects of vessel transit on shoreline erosion
depends on the speed and distance of the propeller or jet to the sea floor or shoreline.
The hydrodynamic model developed by Annova was used to assess the impacts of the
Project on shoreline erosion by evaluating changes in water velocities along the shoreline (Black
& Veatch 2016c). The modeling included scenarios to evaluate the impacts of the Project and the
Bahia Grande Pilot Channel widening. The results indicate the Project would decrease the water
velocity about 5 to 7 percent along the north bank directly across the BSC from the Project
facilities, with minimal changes elsewhere. The model did not assess the potential for localized
propeller scour to cause shoreline erosion. The hydrodynamic modeling indicates the potential for
shoreline erosion would not likely increase as a result of the Project provided the LNG carriers
avoid shoreline erosion from propeller scour when approaching Project facilities. Rock rip-rap
protection would be placed along the terminal shoreline at the Project facilities to prevent erosion
due to vessel propellers or bow thrusters.
The potential for scour by propeller discharges in the BSC during LNG carrier transit
would be mitigated by several factors. The BND established a vessel speed limit of 8 knots in the
BSC, which would reduce impacts on water quality due to shoreline erosion resulting from vessel
traffic. LNG carriers are expected to move at about 6 to 7 knots within the BSC and would operate
at a low speed (i.e., approximately 15 percent of their maximum capacity) thereby significantly
reducing propeller discharge force. Tug boats would escort the LNG carriers into the berth at
speeds less than 5 knots, thereby minimizing the potential for erosion.
Outgoing loaded LNG carriers would have the greatest potential for disturbing bottom
sediment due to their deeper draft (approximately 40 feet). Incoming, empty LNG carriers would
have less draft (approximately 38 feet) and thus ride higher in the water column, allowing a greater
buffer of entrained water between the propeller and the seabed (-45 feet MLLW).
It is assumed that sediment within the BSC is composed primarily (70%-80%) of stiff,
consolidated clay material based on the COE (2014) statement that new work material extracted
during dredging operations would be deposited as relatively firm, large pieces of clay (i.e.,
consolidated). Stiff, consolidated clay has been shown to be highly resistant to scour in flowing
systems, especially when compared to sand. Reice et al. (1990) provides that consolidated clay
has critical velocities (e.g., velocity at which particles may be entrained and transported in a
current) similar to gravel. These factors would require greater current velocities (greater than 10
feet/second) to dislodge and disassociate consolidated clay (Reice et al. 1990). Outgoing LNG
carrier transits represent the greater likelihood for entrainment of sediment because, again, the
propeller force occurs closer to the bottom of the sea bed. This assumes that most entrained
material would be silts, sand, and disassociated clay particles found at the bottom of the BSC as a
result of land-based, erosional runoff. Entrainment of non-consolidated substrate would result in
a short-term, but minor, impact on water quality as LNG carriers transit the BSC. Similar analysis
of incidental LNG carrier propeller wash for the Golden Pass LNG Terminal (FERC 2005) noted
that there would likely be localized increases in turbidity, but these were considered minor and
short term.
The BSC was specifically created to provide deep water access for maritime commerce. It
is governed by the BND and maintained by regular dredging. Similarly, LNG carriers transiting

the Gulf of Mexico would use established shipping channels. As such, use of the waterways by
LNG carriers, barges, and support vessels during construction and operation of the Project would
be consistent with the planned purpose and existing use of active shipping channels, and we
conclude that associated impacts on shoreline erosion and water quality from resuspension of
sediments due to vessel traffic would not be significant.
Ballast Water Discharge
LNG carriers docked at the marine berth would discharge ballast water that may affect the
salinity, dissolved oxygen level, temperature, pH, and aquatic species in the BSC. Large vessels
withdraw water and place it in separate onboard ballast tanks to provide additional draft and
improve navigational performance. Once moored at the loading dock, a ship’s ballast water
typically discharges simultaneously with the LNG cargo loading. The marine berth would
accommodate LNG carriers with cargo capacities up to 177,000 cubic meters. LNG carriers
serving the Project would arrive with virtually empty cargo tanks. Assuming that an LNG carrier’s
ballast water would weigh approximately 50 percent of the weight of the loaded LNG cargo, a
177,000 m3 carrier would discharge approximately 9,950,000 gallons of ballast water during LNG
cargo loading. Ballast discharge periods would vary, but vessels generally would discharge a
volume equal to 10 percent of their LNG capacity each hour. Therefore, a vessel of 177,000 m3
capacity would discharge approximately 995,000 gallons per hour. By comparison, the
approximate volume of the BSC is estimated as 9 billion gallons, and the ballast water discharged
per vessel represents 0.1 percent of this volume.
The Coast Guard established regulations for ballast water management in 33 CFR Part 151
and 46 CFR Part 162, effective June 21, 2012, that apply to all new ships constructed on or after
December 2013 and to existing ships beginning in 2014. The Coast Guard amended its ballast
water management regulations by establishing a standard for the allowable concentration of living
organisms in ballast discharged into U.S. waters. The Coast Guard also established engineering
equipment requirements and an approval process for ballast water treatment systems installed on
ships. All ships calling at U.S. ports and intending to discharge ballast water must either carry out
open sea exchange of ballast water or ballast water treatment, in addition to fouling and sediment
management. These discharges would also comply with International Maritime Organization
standards for ballast water management and U.S. ballast water regulations contained in the
Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990 (NAISA), as amended by
the National Invasive Species Act of 1996 (NISA). Federal oversight and the applicable Coast
Guard regulatory requirements that govern ballast water discharges into U.S. waters would apply
to all LNG carriers calling at the Project site. Additionally, upon entry into the marine berth,
Annova would review all applicable documentation to ensure that the visiting vessel is operating
in accordance with the federal standards and practices prior to discharging any ballast water.
During ballast water exchange, water is withdrawn from below the surface, where salinities are
typically higher than near the surface. Likewise, in the marine berth, LNG carriers would
discharge ballast water below the surface.
In 2017, the International Convention for the Control and Management of Ships’ Ballast
Water and Sediments (BWM Convention) developed measures to minimize the potential for
introduction of non-native species through ballast water. These measures have since been adopted
by the International Maritime Organization and are required to be implemented in all ships

engaged in international trade. While the open sea exchange of ballast water has been used in the
past and reduces the potential for non-native species introductions, on-board ballast water
treatment systems are more effective at removing potential non-native species from ballast water.
There are two different standards that ships must meet. All new ships must meet the “D-2”
performance standard, which establishes the maximum number of viable organisms allowed to be
discharged in ballast water. Conformity with the D-2 standard requires ships to utilize on-board
ballast water treatment systems. Existing ships that do not currently have on-board ballast water
treatment systems must continue to, at a minimum, conduct open sea exchanges of ballast water
(“D-1” standard). Eventually, all ships will be required to conform with the D-2 standard. The
timetable for conformity with the D-2 standard for existing ships is based on the date of the ship’s
International Oil Pollution Prevention Certificate renewal survey, which occurs every five years
(International Maritime Organization, 2017). Therefore, most ships calling on the Project,
estimated to begin in 2024 at the earliest, would be expected to have conformed to D-2 standards.
Generally, in inland waterbodies, salinities are higher in the lower portions of the water
column than at the surface, but in the BSC salinities are relatively constant throughout the column
because of minimal freshwater intake and the low flow creating potential for evaporation. Because
of this condition and the small volume of discharge relative the volume of the BSC, ballast
discharged into the BSC would have little to no effect on the BSC’s salinity regime. In fact, the
ballast water salinities may be lower than ambient conditions within the BSC and provide a small
amount of relief to elevated salinities typically observed in South Texas estuarine waterbodies.
Section 4.6 discusses impacts on species tolerant of transient saline conditions.
Dissolved oxygen levels in the BSC may be influenced by the introduction of ballast water.
Dissolved oxygen is essential for the respiration of aquatic marine organisms. Among many other
factors, dissolved oxygen levels in water can be influenced by water temperature, water depth,
phytoplankton, wind, and current. Within estuaries, many factors (e.g., air temperature, rainfall,
tidal magnitude, organic enrichment) can affect a waterbody’s dissolved oxygen capacity. During
the summer, a distinct stratification may occur between cooler, higher-salinity bottom waters and
warmer, nutrient-rich (as a result of photosynthetic activity) surface waters. Based on the
seasonally variable nature of dissolved oxygen levels within an estuary, ballast discharge could
result in minor, local, dissolved oxygen reductions during the winter, as well as minor, local,
increases of dissolved oxygen during the summer. The actual effect on dissolved oxygen may be
difficult to measure, considering the dynamic and variable nature of water quantity and quality
within the BSC. Given the relatively minimal volume of discharged ballast water expected from
the LNG carriers calling on the Project compared to the water volume within the BSC and the
change in volume during tides, ballast discharges would have minimal impacts on dissolved
oxygen levels in the BSC.
Ballast water is not expected to significantly alter water temperatures or pH in the BSC.
Since ballast water is stored in the LNG carrier’s hull below the water line, water temperatures
would be similar to ambient temperatures of the surrounding sea water. The pH of ballast water
reflects open-ocean conditions and may be slightly higher compared with the freshwater or
brackish water that occurs seasonally within estuaries; however, this slight variation is not
anticipated to impact water quality.

Due to the volumes of ballast water often collected by vessels, living aquatic organisms
may enter ballast tanks. Some of the larger macro-organisms collected often die; however, some
of the smaller planktonic organisms can survive. Vessels loaded with ballast water from the ports
and coastal waters throughout the world can carry diverse marine organisms that may be foreign
and exotic to the vessel’s port of destination. The port-to-port transfer of water can introduce
invasive aquatic species. Based on current federal and state regulations regarding ballast water
discharge, no specific operational permits are required to discharge ballast water. Annova is
consulting with NOAA Fisheries, the FWS, and the TPWD and would address concerns or interest
in ballast water discharge as requested.
Cooling Water Discharge
During operation, LNG vessels would re-circulate water for engine cooling while loading
LNG at the berth, requiring water for cooling of the main engine/condenser, diesel generators, and
fire main auxiliary and hotel services (Hunt 2003). No chemicals would be added to the cooling
water. The volume of cooling water to be re-circulated is a function of the mode of operation of
the LNG vessel. The mode of operation would be transit in the open ocean, and maneuvering
mode to get the vessel in the BSC and berth, and while in the berth would be in-port mode. Cooling
water is need for the auxiliary diesel engines that are used to generate electrical power for onboard
systems while loading LNG.
Table 4.3.2-3 identifies the volumes of water required for cooling. The volumes required
would vary based on the type of propulsion system of the LNG vessel. Steam-powered LNG
vessels (maximum LNG capacity of 138,000 m3) would require the largest volume of 11.7 million
gallons of water for engine cooling during maneuvering and while docked at the LNG terminal,
assuming the vessels would leave immediately after loading. During the same period, LNG vessels
with dual fuel/diesel electric engines (maximum LNG capacity of 218,000 m3) would use 5.5
million gallons of water. LNG barges, being smaller than LNG carriers having increased
maneuverability and reduced time spent at the LNG terminal, would require only 535 gallons of
waters (maximum LNG capacity of 15,000 m3).
TABLE 4.3.2-3
Estimates of LNG Carrier Cooling Water Use and Intake Rates at the LNG Terminal
Time to Time to Maneuvering Maneuvering In-port Rate In-port
Maneuver Load Rate (gallons Volume (gallons per Volume Total Volume
Vessel Type (hours) (hours) per hour) (gallons) hour) (gallons) (gallons)
Duel fuel/diesel 2 18 1,680,000 3,360,000 120,000 2,160,000 5,520,000
electric LNG carrier
Steam-powered 3 18 2,820,000 8,460,000 180,000 3,240,000 11,700,000
LNG carrier
Articulated tug/barge 1.25 4 300 375 40 160 535
Impacts as a result of cooling water intake and discharge would be primarily limited to an
increase in water temperature in the vicinity of the LNG vessel. Cooling water return temperatures
vary widely depending on the type of LNG carrier and mode of operation. Based on a review of
available information, we anticipate that cooling water discharged could range between 2.7°F and
7.2°F warmer than ambient water temperatures (Caterpillar 2007, 2011, 2012). Due to the limited
temperature differences, relatively small volume of discharge compared to the total water within

the BSC, and location near an active port that is already subject to withdrawals and discharges of
vessel engine cooling water, we anticipate the warmer water would diminish shortly after
discharge and, therefore, would have temporary and minor impact on water quality. Information
on the effects of cooling water on aquatic resources is presented in section 4.6.
Site Modification and Stormwater Runoff
As stormwater runoff moves across the site surfaces, it may pick up sediment particles or
soil, as well as oil, grease, and residue from materials used on the site. This occurs if materials
such as fuels, grease, and lubricants incidentally leak from vehicles and equipment or accidentally
spill. To minimize impacts on water resources due to erosion, Annova would install soil erosion
and sediment control measures prior to initiating site development.
BMPs would be taken to prevent the spill or release of hazardous materials into
waterbodies, including limiting the quantity and duration of storage, fortifying barriers or
providing additional containment, using trained personnel to monitor activities, and coordinating
with the Environmental Inspector during construction. In addition, Annova would have to file a
variance request for any areas where hazardous materials would be stored within 100 feet of
waterbodies. Clean-up materials, including absorbent spill pads and plastic bags, would be stored
in these areas. Hazardous materials storage areas would be protected from flooding or inundation.
The Annova Plan and Procedures (see appendix B) include temporary erosion controls
such as slope breakers, sediment barriers, and mulching. These erosion and sediment controls
would reduce runoff velocity, divert water off construction work areas, and stop the flow and
deposition of sediments beyond approved workspaces or into sensitive resources. Annova would
obtain an NPDES General Permit for Construction Storm Water Discharge from the EPA prior to
any site disturbance. The effects of stormwater runoff would be minimal and localized; therefore,
no negative impacts would affect water quality in the BSC, the nearby Bahia Grande, or South
Bay. Annova would follow the SWPPP required as part of the EPA NPDES General Permit for
Construction Storm Water Discharge, as well as the SPCC Plan for construction to prevent and
respond to spills. During operation, the Project design would direct stormwater to designated
retention and detention ponds.
Annova would obtain an NPDES Industrial Waste Water Discharge Permit for facility
discharges of stormwater from an oily water separator, stormwater ponds, and on-site packaged
sanitary wastewater treatment pond. Annova would prepare and implement a Stormwater
Pollution Prevention Plan describing all pollution control measures or BMPs that would control
erosion, sedimentation, and pollutants in runoff from the site. In addition, Annova would prepare
an SPCC Plan to establish procedures, methods, and equipment requirements, including secondary
containment and earthen berms to prevent and minimize impacts from spills during operation.
Annova would not discharge untreated process-related wastewaters to the BSC or nearby
Bahia Grande. Stormwater that contacts process areas would be directed to an oil/water separator
prior to discharging to the BSC. Annova would adhere to all NPDES permit stipulations following
monitoring and reporting requirements to the TCEQ. The effects of stormwater runoff and
wastewater discharge during operation would be minimal and localized; therefore, only temporary

and localized impacts would occur on water quality in the BSC, with minimal or no impacts
extending into nearby Bahia Grande or South Bay.
Ship and boat traffic has the potential to adversely impact water quality in the event of an
accidental release of a hazardous substance such as fuel, lubricants, coolants, or other materials on
board the vessel. Annova would implement the measures outlined in its SPCC Plan in the event
of a spill, as well as measures outlined in its Plan and Procedures. Annova would minimize the
risk of a spill by implementing general preventive BMPs, including personnel training, equipment
inspection, and refueling procedures.
Water Use
The Rio Grande provides potable water in the region including Cameron County and the
surrounding counties that make up the lower Rio Grande Valley. The BND receives its water
supply through a Water Service Agreement with the Brownsville Public Utilities Board
Brownsville Irrigation District. The Brownsville Public Utilities Board has the capability of
receiving up to 40 million gallons per day (1.2 billion gallons per month) from the Rio Grande and
an additional 7.5 million gallons per day from a reverse osmosis desalination plant that withdraws
water from brackish aquifers. During construction, Annova would use approximately 4 million
gallons of potable water per month for dust control, sanitary purposes, and general construction
needs. Potable water would be obtained from the BND. The volume needed during construction
is approximately 0.3 percent of the capacity of the BND.
During operation, Annova would use approximately 805,000 gallons per month for
drinking and sanitary purposes as well as testing of firewater pumps. This volume is about 0.07
percent of the total capacity of the BND’s water supply. The Project’s use would be a small
percentage of the entire public water supply volume from the Rio Grande. Section 4.9 provides
additional information on public utilities in the Project area.
Hydrostatic Testing
During construction, Annova would use water for hydrostatic testing of pipes and LNG
storage tanks. See section 2.6 for general description of the hydrostatic testing process.
Approximately 28 million gallons of water would be withdrawn from the BSC for hydrostatic
testing of each LNG storage tank. Intake structures used for this withdrawal would be fitted with
appropriate screens to limit impingement or organisms and prevent debris from collecting on the
screen. The approximate volume of the BSC is 9 billion gallons, and the use of 56 million gallons
for hydrostatic testing would represent 0.6 percent of the BSC volume. Annova would obtain a
TCEQ temporary water rights permit for the withdrawal of water for hydrostatic testing of the
LNG storage tanks. The hydrostatic test water for the LNG facility piping would use potable water
obtained from the BND. No chemicals would be added to any water used for hydrostatic testing.
At the completion of all hydrostatic testing, approximately 1.8 million gallons would
discharge to the BSC per day for approximately 30 days. Annova would obtain an EPA
Hydrostatic Test Water Discharge Permit and an RRC permit to discharge hydrostatic test water.
Prior to discharge, Annova would analyze the hydrostatic test water for total suspended solids, oil

and grease, and pH, and any other parameters required by the EPA or RRC. Discharge of
hydrostatic test water may cause localized, short-term turbidity in the BSC.
4.3.2.3 Conclusion for Surface Water
Surface water impacts resulting from the construction and operation of the Project could
result from site grading activities, fill activities, dredging and construction activities associated
with the marine facilities, vessel traffic, hydrostatic testing, and spills or leaks of hazardous
materials. With implementation of the mitigation measures identified for each of the proposed
activities, we have determined that construction and operation of the Project would result in
primarily temporary and less than significant impacts on surface waters.

4.4 WETLANDS
As defined by the COE, wetlands are areas inundated or saturated by surface water or
groundwater at a frequency and duration sufficient to support, and under normal circumstances do
support, a prevalence of vegetation typically adapted for life in saturated soil conditions (COE
1987). Wetlands can be a source of substantial biodiversity and serve a variety of functions that
include providing wildlife habitat, recreational opportunities, flood control, and naturally
improving water quality.
Wetlands are protected under Section 404 of the CWA. Section 404 establishes standards
to evaluate and reduce impacts on wetlands under the jurisdiction of the COE. These standards
require avoidance of wetlands where possible and minimization of disturbance where impacts are
unavoidable. Annova must also demonstrate that appropriate steps have been taken to minimize
wetland impacts, in compliance with the COE’s section 404(b)(1) guidelines that restrict
discharges of dredged or fill material where less environmentally damaging alternatives exist.
Wetland impacts authorized under Section 404 of the CWA also require state water quality
certification under Section 401 of the CWA. In the State of Texas, water quality certification is
delegated to the TCEQ, with review by the EPA.
4.4.1 Existing Wetland Resources
Annova conducted wetland delineations of the Project site in 2014, 2015, and 2017 in
accordance with the COE Wetland Delineation Manual (COE 1987) and the Regional Supplement
to the Corps of Engineers Wetland Delineation Manual: Atlantic and Gulf Coastal Plain Region
(COE 2010) and classified these wetlands according to the Classification of Wetlands and
Deepwater Habitats in the United States (Cowardin et al. 1979). Approximately 165 acres of
wetlands were delineated within the Project site, including the permanent access road. Wetlands
delineated within the Project site include estuarine open water; unvegetated tidal flat; estuarine
emergent marsh and estuarine scrub-shrub, each of which is briefly described below.
Non-vegetated wetlands identified within the Project site include:
• Estuarine Open water (E1OW): open water includes the portion of sub-tidal area
adjacent to the BSC. This wetland occurs along the shore, is relatively shallow,
and is periodically disturbed by drawdown and return surges associated with vessel
traffic in the BSC.
• Unvegetated tidal flats (E2US3): unvegetated tidal flats are found in the eastern
portion of the Project site adjacent to open water areas along the BSC. This wetland
is characterized by sparse (less than 5 percent vegetative cover) to no vegetation.
These areas are intermittently inundated by wind-driven tides.
Vegetated wetlands identified within the Project site include:
• Estuarine emergent marsh (E2EM1): estuarine emergent marshes are found in

higher elevations along the BSC compared to the open water and tidal flats. These
areas are dominated by plants that grow in waters of high salinity (halophytic plant
species), including glassworts (Salicornia depressa; S. bigelovii), saltwort (Batis
Wetlands 4-30
maritima), cenicilla (Sesuvium portulacastrum), sea purslane (Sesuvium

verrucosum), and sea blite (Suaeda linearis) below the annual high tide line and
seashore dropseed (Sporobolus virginicus), shoregrass (Distichlis littoralis), sea
lavender (Limonium carolinianum), and seaside heliotrope (Heliotropium
curvassivicum) above the high tide line. These wetlands are infrequently inundated
by tides and are likely supported by a tidally influenced water table and periodic
washover from vessel traffic in the BSC.
• Estuarine scrub-shrub (mangrove) (E2SS2): this habitat is found in the intertidal
zone along the banks of the BSC on a low shelf of unconsolidated mud. These
wetlands are dominated by black mangrove (Avicennia germinans) and saltwort.
Construction and operation of the Project would not impact estuarine scrub-shrub
wetlands.
Several commenters on the draft EIS, including the FWS, noted differences between
wetlands within the site as reported in Annova’s application to FERC and in Annova’s Section
10/404 application to the COE. In an EIR dated March 15, 2019 we asked Annova to clarify this
apparent discrepancy. In its response filed on March 25, 2019 (FERC accession number
20190325-5179) Annova clarified that initial emergent wetlands on site were classified as
freshwater (palustrine) emergent, but after consultation with the COE these wetlands were
reclassified as estuarine emergent.
4.4.2 Wetland Impacts and Mitigation
Constructing and operating the Project would temporarily and permanently disturb
wetlands and non-wetland waters of the U.S. within the Project site. Construction of the facilities
within the Project site, including the permanent access road, would disturb approximately 53.0
acres of vegetated wetlands and 4.7 acres of tidal flats and open water. Operation of the Project,
including the permanent access road, would permanently affect approximately 50.8 acres of
vegetated wetlands and 2.0 acres of non-vegetated tidal flat and open water. Table 4.4.2-1
summarizes the impacts on wetlands from construction and operation of the Project. Wetlands
that would be affected by Project construction and operation are shown on figure 4.4.2-1.
TABLE 4.4.2-1
Impacts to Wetlands from Project Construction and Operation
Construction Operational
Cowardin Impacts (acres) Impacts (acres)
Wetland Type Classification a/ b/
Non-Vegetated
Estuarine open water (within Project property) E10W 2.0 1.0
Unvegetated tidal flat E2US3 2.7 1.0
Vegetated Wetlands
Estuarine emergent marsh E2EM1 53.0 50.8
Non-vegetated and Vegetated Wetlands Total 57.7 52.8
a/ Construction impacts include all areas that would be disturbed during construction of the Project.
b/ Operation impacts include those areas that would be maintained during operation of the Project.
4-31 Wetlands
Figure 4.4.2-1 Wetlands Affected by Construction and Operation of the Project
Wetlands 4-32
About 4.9 acres of wetlands would be temporarily affected. Temporary impacts would
include loss of wetland vegetation and disturbance of soils, hydrology, and wetland functions
during construction, which could be up to about four years. Following construction, temporarily
affected wetlands would be allowed to revert to pre-construction wetland types, and would be
monitored for successful revegetation per Annova’s Procedures (see appendix B). The
temporarily affected wetlands would be located outside of the 20-foot-wide corridor adjacent to
the primary security fence and would include about 1 acre of estuarine open water, 1.7 acre of
unvegetated tidal flat, and about 2.2 acres of estuarine emergent marsh.
Annova is consulting with the COE and other relevant agencies regarding permanent and
temporary impacts on wetlands. Additionally, Annova has prepared a draft Conceptual Mitigation
Plan that has identified preliminary Project mitigation requirements and proposed compensation
for the Project’s impacts on wetlands and waters of the U.S. (Blanton & Associates, Inc. 2017).
The draft Conceptual Mitigation Plan proposes to enhance and restore an estimated 145 acres of
estuarine open water, estuarine emergent marsh, and estuarine scrub-shrub (mangrove) marsh at
the Little San Martin Lake Mitigation Site, located approximately 1.2 miles northwest of the
Project site. Annova is still developing the mitigation plan and is currently collecting additional
information on the baseline conditions at the proposed mitigation site, and coordinating with the
COE to review and finalize functional assessments of wetlands that would be affected at the Project
site to determine total mitigation needs. Based on the results of these efforts, Annova would further
develop and refine the Conceptual Mitigation Plan as needed. Annova states that additional
detailed engineering, design, construction, and monitoring information is required before it
finalizes the mitigation plan, and that Annova would continue to incorporate those details as the
mitigation plan develops. The COE would determine the acceptability of any proposed
compensatory mitigation for wetland impacts.
We received numerous comments on the draft EIS related to the draft Conceptual
Mitigation Plan, including commenters that questioned the accuracy of the reported existing
wetland conditions of the proposed mitigation area, and the validity of using Little San Martin
Lake as a mitigation area when it may already be under the control and management of the FWS.
In an EIR dated March 15, 2019, we asked Annova to provide an update on the status of the draft
Conceptual Mitigation Plan and clarify certain questions in response to comments. In its response
filed on March 25, 2019 (FERC accession number 20190325-5179), Annova pointed to the
description and mapping in the draft Conceptual Mitigation Plan that are based on recent wetland
delineations of the site, and that accurately represent the existing conditions. Annova further
explained that, while the mitigation site is within the Laguna Atascosa NWR, it is also within a
perpetual easement controlled by the BND that was established prior to the FWS acquiring the
property. The terms of the perpetual easement allow the BND to conduct certain activities such
as dredge disposal and excavation and drainage improvements. The intent of the Conceptual
Mitigation Plan would be to create legal site protection that would protect the mitigation area from
detrimental activities that may be allowed by the existing BND perpetual easement.
4.4.3 Conclusion
We conclude that adherence to measures contained in Annova’s Procedures would

adequately address wetlands that are only temporarily affected by Project construction, such that
impacts on temporally affected wetlands would be less than significant.
4-33 Wetlands
Construction of the Project would result in the permanent loss of 50.8 acres of emergent
vegetated wetlands and 2 acres of unvegetated open water and tidal flat. This loss of nearly 53
acres of wetland would be a permanent impact. Annova used a hydrogeomorphic model to assess
the existing functions of the wetlands that would be permanently affected by the Project, and is
working with the COE to finalize that assessment for the purpose of identifying required
mitigation. We anticipate that if the COE issues a Section 404/Section 10 permit for the Project,
it would be conditioned upon Project-related adverse impacts on waters of the U.S. being
effectively offset by mitigation similar to what Annova has identified in its draft Conceptual
Mitigation Plan, such that permanent impacts on wetlands would be reduced to less than
significant levels.
Wetlands 4-34
4.5 VEGETATION
The Project would be located within the Gulf Coast Prairies and Marshes Ecoregion
(TPWD 2016c). This ecoregion is a nearly level, slowly drained plain less than 150 feet in
elevation, which is dissected by streams and rivers flowing into the Gulf of Mexico (TPWD
2016c). The majority of the Project site would be less than 5 feet above sea level and is flat with
shallow depressions and isolated lomas. Lomas are dunes formed from wind-blown clay that
support dense shrub vegetation communities that provide important habitat for protected wildlife
species (FWS 2012b). Three distinct lomas—Loma del Potrero Cercado, Loma del Divisadero,
and the eastern portion of Loma de la Juaja—are located within the Project site. These lomas and
their habitat value for wildlife are discussed in greater detail in section 4.5.4 and section 4.6.
Portions of the Project site support emergent herbaceous wetlands or are devoid of vegetation due
to high concentrations of salt.
4.5.1 Existing Vegetation Communities
The majority of the Project site is covered in South Texas loma grassland and shrublands,
Gulf Coast salty prairie, and coastal sea ox-eye daisy flats. Vegetation communities within the
Project site are summarized below. Nomenclature for vegetation communities is primarily based
on the Ecological Mapping System of Texas (EMST; Ludeke et al. 2010); however, the names of
a few of the vegetation communities diverge from the EMST name to more accurately represent
the site-specific vegetation community, to separate wetland communities from upland
communities, and to distinguish between similar vegetation communities that may differ in terms
of wildlife habitat value. Wetlands are addressed further in in section 4.4.
4.5.1.1 Emergent Herbaceous Wetland

Coastal Salt and Brackish High Tidal Marsh
Coastal salt and brackish high tidal marsh consists of tidally herbaceous wetlands in salt
and brackish waters. Typical vegetation includes glassworts (Salicornia depressa, S. bigelovii),
saltwort (Batis maritima), cenicilla (Sesuvium portulacastrum), sea purslane (Sesuvium
verrucosum), Matamoros saltbush (Atriplex matamorensis), sea blite (Suaeda linearis), seashore
dropseed (Sporobolus virginicus), shoregrass (Monanthochloe [Distichlis] littoralis), sea lavender
(Limonium carolinianum), and seaside heliotrope (Heliotropium curassavicum). Approximately
10 acres 7 of coastal salt and brackish high tidal marsh vegetation is found within the Project site
along the BSC; however, this vegetation community would not be affected by construction and
operation of the Project.
Coastal Salty Flat/Depression

The coastal salty flat/depression community consists of shallow topographic depressions
that capture and pond water, which then evaporates thereby concentrating salt. Typical vegetation
is similar to the coastal salt and brackish high tidal marsh community and includes glassworts,
saltwort, cenicilla, sea purslane, sea blite, and shoregrass. The BSC and dredged material has
7
Acres of existing vegetation communities listed in section 4.5.1 do not include unvegetated areas (i.e.,
barren areas, existing roads, open water, and tidal flat/washover); therefore, the sum of the acreages listed in this
section are less than the total acreage of the Project site and access road.
4-35 Vegetation
isolated these areas from tidal influence. Approximately 55 acres of this vegetation community is
found along the southwest boundary of the Project site and along the access road.
Salt and Brackish Wetland

Salt and brackish wetlands are found in large depressions and vegetation is variable,
depending on rainfall and standing water. In the wet season, water remains in these wetlands
longer, which may shift the vegetation community toward freshwater species as salinity drops.
Approximately 62 acres of this vegetation community are found in the Project site south of the
Loma del Potrero Cercado. Typical vegetation includes shoregrass, saltwort, saltgrass (Distichlis
spicata), Berlandier wolfberry (Lycium berlandieri), spikerush (Eleocharis compressa),
arrowhead (Sagittaria sp.), and jointed flatsedge (Cyperus articulatus).
South Texas Saline Lake Grassland
South Texas saline lake grassland forms in bands around saline lakes or in saline
depressions. Approximately 10 acres of South Texas saline lake grassland occur within the Project
site, on top of Loma del Potrero Cercado. Typical vegetation includes: sea ox-eye daisy (Borrichia
frutescens), saltwort, seashore dropseed, saltmarsh bulrush (Bolboschoenus [Schoenoplectus]
maritimus), jointed flatsedge, shoregrass, camphor daisy (Rayjacksonia phyllocephala), and
tornillo (Prosopis reptans).
4.5.1.2 Grassland/Herbaceous
Coastal Sea Ox-eye Daisy Flats
Coastal sea ox-eye daisy flats consist of grasslands adjacent to, but higher in elevation,
than tidal and non-tidal wetlands and wind flats. Approximately 66 acres of this vegetation
community are found interspersed throughout the western half of Project site. Typical vegetation
includes sea ox-eye daisy, sacahuiste (Spartina spartinae), saltwort, glassworts, shoregrass, sea
blite, and seashore dropseed.
Gulf Coast Salty Prairie
Gulf coast salty prairie vegetation occurs in flat uplands and is the dominant community in
southeastern portion of the Project site and along the access road. Typical vegetation includes
seashore dropseed, smutgrass (Sporobolus indicus), whorled dropseed (S. pyramidatus),
guineagrass (Urochloa maxima), leatherleaf (Maytenus phyllanthoides), camphor daisy, tornillo,
sea ox-eye daisy, Texas pricklypear (Opuntia engelmannii var. lindheimeri), Spanish dagger
(Yucca treculeana), tasajillo (Cylindropuntia leptocaulis), Bermudagrass (Cynodon dactylon),
whiplash pappusgrass (Pappophorum vaginatum), silver bluestem (Bothriochloa laguroides),
witchgrass (Panicum capillare), short-spike windmillgrass (Chloris X subdolichostachya), and
hooded windmillgrass (Chloris cucullata). Approximately 181 acres of this vegetation community
occur within the Project site and along the access road.
4.5.1.3 Scrub-shrub
South Texas Loma Evergreen Shrubland
South Texas loma evergreen shrubland is an upland vegetation community consisting of
dense cover of thornshrub species found at higher elevations on lomas. It occurs on top of all three
lomas found within the Project site. Typical vegetation includes ebony (Ebenopsis ebano),
Vegetation 4-36
granjeno (Celtis ehrenbergiana [C. pallida]), lime prickly-ash (Zanthoxylum fagara), honey
mesquite (Prosopis glandulosa), desert yaupon (Schaefferia cuneifolia), lotebush (Ziziphus
obtusifolia), coma (Sideroxylon celastrinum), coyotillo (Karwinskia humboldtiana),Texas Lantana
(Lantana urticoides [L. horrida]), Berlandier’s fiddlewood (Citharexylum berlandieri), Spanish
dagger (Yucca treculeana), few-flower climbing-dalea (Dalea scandens var. paucifolia), goatbush
(Castela erecta [C. texana]), cow-itch vine (Cissus incisa [C. trifoliata]), old-man’s beard
(Clematis drummondii), threadvine (Cynanchum barbigerum), hierba del soldado (Waltheria
indica), Tamaulipan mistflower (Tamaulipa azurea), Lozano’s false Indian mallow
(Allowissadula lozanii), Cuban germander (Teucrium cubense), tropical sage (Salvia coccinea),
guineagrass, big sacaton (Sporobolus wrightii), and smutgrass. Approximately 208 acres of this
vegetation community occur within the Project site and along the access road. Because this is a
mixed shrub community that contains some trees, the National Land Classification Database
characterizes portions of this vegetation type as forested.
South Texas Loma Grassland/Shrubland
This community is a mix of grassland and shrubland found at low elevations around the
base of lomas and typically forms a continuous ring around the loma. Shrub cover is typically
greater than 10 percent. This community occurs throughout the Project site and along the access
road at the base of lomas. Typical vegetation includes: big sacaton, guineagrass, whiplash
pappusgrass, silver bluestem, witchgrass, short-spike windmillgrass, hooded windmillgrass,
smutgrass, multi-flower false rhodesgrass (Trichloris pluriflora), hierba del soldado, white
mistflower (Fleischmannia incarnata), blue mistflower (i), false ragweed (Parthenium
hysterophorus), goldenweed (Isocoma drummondii), Tamaulipan mistflower, cow-itch vine, old-
man’s beard, threadvine, dwarf morning glory (Evolvulus alsinoides var. angustifolius [E.
alsinoides var. hirtcaulis]), corona del Christo (Passiflora foetida var. gossypiifolia), honey
mesquite, Spanish dagger, Berlandier fiddlewood, Texas lantana, Texas pricklypear, lotebush,
lime prickly-ash, granjeno, coma, tasajillo, coyotillo, cenizo (Leucophyllum frutescens), and
camphor daisy. At lower elevations, the loma grasslands consist of dense monotypic stands of
buffelgrass (Pennisetum ciliare) or Angleton bluestem (Dichanthium aristatum). Approximately
178 acres of this vegetation community occur within the Project site and along the access road.
4.5.1.4 Coastal Mangrove Shrubland
This vegetation community is located in the intertidal zone and is dominated by black
mangrove (Avicennia germinanas) and saltwort. Approximately 2 acres of coastal mangrove
shrubland occur within the Project site; however, this vegetation community would not be affected
by construction and operation of the Project.
4.5.1.5 South Texas Tidal Wind Flats
This community has less than five percent vegetative cover and is infrequently inundated
with water from high, wind-driven tides. The sparse vegetation, when present, is composed of
scattered individuals of species common in salt marshes. Algal flats may also intermittently occur
within tidal flats during periods of long-term inundation; however, given their sporadic and
intermittent occurrence within the Project site, algal flats are not included as a permanent
vegetation community. Approximately 13 acres of South Texas tidal wind flats occur along the
northeastern edge of the Project site.
4-37 Vegetation
4.5.2 Vegetation Impacts and Mitigation
As summarized in table 4.5.2-1, constructing and operating the Project would temporarily
and permanently impact vegetation. Constructing the Project would impact approximately 462
acres of vegetation, of which approximately 409 acres would be permanently affected by the
Project.
TABLE 4.5.2-1
Vegetation Communities Affected by Construction and Operation of the Project

Construction Impacts Operation Impacts
Vegetation Community (acres) a/ (acres) b/
Emergent Herbaceous Wetland
Coastal Salty Flat/Depression 3 1
Salt and Brackish Wetland 40 40
South Texas Saline Lake Grassland 10 10
Grassland / Herbaceous
Coastal Sea Ox-eye Daisy Flats 52 48
Gulf Coast Salty Prairie 131 98
Scrub-shrub
South Texas Loma Evergreen Shrubland 130 127
South Texas Loma Grassland/Shrubland 94 85
Tidal Flats
South Texas Wind Tidal Flats 2 0
Total c/, d/ 462 409
a/ Construction impacts include all areas disturbed during construction.

b/ Operation impacts include those areas that would be maintained during operation of the Project.
c/ Totals do not include impacts on non-vegetated land cover types (e.g., open water, mud flat, and barren areas).
d/ Numbers may not sum due to rounding.
As summarized in the table above, construction would primarily impact Gulf Coast Salty
Prairie (131 acres), South Texas Loma Evergreen Shrubland (130 acres), South Texas Loma
Grassland/Shrubland (94 acres), and Coastal Sea Ox-eye Daisy Flats (52 acres). Impacts on
vegetation in areas not occupied by permanent facilities and located outside of the temporary
workspace (borrow area) would be considered temporary because areas would be allowed to revert
to pre-construction land covers and would be monitored for successful revegetation per the Annova
Plan and Procedures (see appendix B). However, the duration of these impacts could be either
short term or long term depending on pre-disturbance vegetation cover. Impacts are considered
short term if, after three growing seasons, the revegetated disturbed areas resemble adjacent
undisturbed lands. Temporary impacts would be considered short-term for the majority of the
vegetation communities affected since most of the vegetation communities have the potential for
revegetation within three growing seasons. Impacts on South Texas Loma Evergreen Shrubland
and South Texas Loma Grassland/Shrubland vegetation communities, however, would be
considered long term as these vegetation communities would potentially take longer than three
growing seasons to resemble adjacent undisturbed lands.
Operation and maintenance of the Project would impact approximately 409 acres of
vegetation communities. Operation of the Project would result in permanent loss of vegetation.
This would primarily affect South Texas Loma Evergreen Shrubland (127 acres), Gulf Coast Salty
Vegetation 4-38
Prairie (98 acres), South Texas Loma Grassland/Shrubland (85 acres), Coastal Sea Ox-eye Daisy
Flats (48 acres), and Salt and Brackish Wetland (40 acres) vegetation communities.
In addition to the direct loss of vegetation, temporary and permanent removal of vegetation
communities for construction and operation of the Project would result in indirect impacts on
wildlife. Impacts of the Project on wildlife are discussed in section 4.6.
At the request of the FWS, Annova has modified the original Project layout to minimize
clearing of mature dense thornshrub vegetation (i.e., South Texas Loma Evergreen Shrubland and
South Texas Loma Grassland/Shrubland). The current site layout reduces Project impacts on these
vegetation communities on the western and eastern boundaries of the Project site. Additionally,
Annova would comply with any Project-specific recommendations and mitigation requirements
associated with the Section 404 and Section 10 permits issued by the COE, which would be
expected to include implementation of compensatory wetland mitigation similar to what Annova
has identified in a draft Compensatory Mitigation Plan.
4.5.3 Exotic or Invasive Plants and Noxious Weeds
Exotic and invasive plants and noxious weeds can out-compete and displace native plant
species, which can also alter the composition and habitat value of the affected areas. During field
surveys of the Project site, Annova did not identify any species listed on federal or state noxious
weed lists; however, eight exotic (i.e., introduced) species were observed within the Project site.
These include Bermudagrass (Cynodon dactylon), Kleberg bluestem (Dichanthium annulatum),
Angleton bluestem (Dichanthium aristatum), false ragweed (Parthenium hysterophorus),
buffelgrass (Pennisetum ciliare), silky leaf frog fruit (Phyla fruticosa [P. strigulosa]), smutgrass
(Sporobolus indicus), and guineagrass (Urochloa maxima). Because none of these eight
introduced species are federally or state-listed as noxious weeds, no special control measures are
required by federal or Texas noxious weed control regulations. However, the Annova Plan and
Procedures include measures to control noxious weeds, if any are identified.
In accordance with its Plan and Procedures, Annova would coordinate with the appropriate
agencies to prevent any Project-related introduction or spread of invasive plants and noxious weeds
and would conduct post-construction monitoring. As part of this monitoring program, Annova
would examine disturbed areas for the presence of invasive species. To ensure that construction
equipment brought to the Project site would be clean and free of noxious or invasive species, all
contractor-owned equipment would be pressure washed in the contractor’s equipment yard and
inspected to ensure it is clean. Prior to transport to the Project site, equipment would be inspected
and, if necessary, re-washed. For equipment that is not contractor owned, a cleaning and
inspection program would be implemented at each rental yard to ensure equipment is clean and
free of noxious or invasive species prior to transport to the Project site.
4.5.4 Vegetation Communities of Special Concern
Vegetation communities of special concern include ecologically important natural

communities, threatened or endangered plant species, or other rare or imperiled plants in need of
special protection or minimal disturbance. No state-designated rare, threatened, or endangered
plants are known to occur within the Project site. However, loma vegetation communities,
4-39 Vegetation
including South Texas loma evergreen shrubland and South Texas Loma Grassland/Shrubland,
and the Gulf Coast Salty Parairie community, do provide habitat for several federal and state-listed
threatened and endangered species (see sections 4.6 and 4.7). The FWS considers the dense loma
shrub communities and Gulf coast salty prairie vegetation community to be of special concern
because of their importance to the federally listed ocelot and northern aplomado falcon, and the
limited distribution of these vegetation types, with less than 5 percent of the dense shrub vegetation
remaining in the Lower Rio Grande Valley (FWS 2010c). The FWS estimated that the amount of
dense shrub vegetation available in the Laguna Atascosa NWR and the surrounding area (within a
13.7-mile buffer around the refuge, the Project site being located just outside this buffer) is 19,200
acres. On the Project site, South Texas Loma Evergreen Shrubland vegetation is found on top of
all three lomas and South Texas Loma Grassland/Shrubland is located at the base of lomas. As
described in table 4.5.2-1, approximately 224 acres of South Texas Loma Evergreen Shrubland
and Grassland/Shrubland vegetation would be affected during construction, of which 212 acres
would be permanently lost due to operation of the Project. This includes Loma del Potrero Cercado
within the site, which represents one of the 22 named lomas located in the vicinity of the Project.
The loss of about 130 acres of habitat within Loma del Potrero Cercado on the Project site would
represent about 6 percent of the approximately 2,075 acres of lomas in the immediate Project area
and less than 1 percent of the dense shrub vegetation within a 13.7-mile radius around the Laguna
Atascosa NWR. Approximately 131 acres of Gulf Coast Salty Prairie vegetation would be affected
during construction, of which 98 acres would be permanently lost due to operation.
In addition to lomas and coastal salt prairie, wetlands can be a source of substantial
biodiversity and serve a variety of functions that include providing wildlife habitat, recreational
opportunities, flood control, and naturally improving water quality. Wetland communities and
open water habitats are addressed in more detail in section 4.4.
4.5.5 Conclusion
Of the approximately 409 acres of vegetation communities that would be permanently

affected by the project (lost), about 310 acres (76 percent) would be vegetation communities
identified as special concern (dense loma shrub and coastal salt prairie) by the FWS. However,
because this impact would represent only about 6 percent of the lomas in the immediate Project
area and less than 1 percent of the dense shrub vegetation within a 13.7-mile radius around the
Laguna Atascosa NWR, we have determined that construction and operation of the Project would
not significantly impact vegetation. Annova is evaluating off-site lands for conservation, either
through purchase or conservation easement, which may compensate for the loss of loma and coastal
salt prairie vegetation and their value as wildlife habitat (see section 4.7).
Vegetation 4-40
4.6 WILDLIFE AND AQUATIC RESOURCES

The Project area generally includes upland, wetland, and marine habitats, each supporting
a variety of terrestrial and aquatic wildlife. Wildlife occurring in the Project area are generally
characteristic of the vegetation (described in section 4.5) present. Aquatic wildlife occurring in
the BSC or Gulf of Mexico are discussed separately in section 4.6.2. Threatened and endangered
species and other protected species are addressed in section 4.7.
4.6.1 Terrestrial Wildlife

In general, the wildlife habitat types present in the Project area include: uplands
(herbaceous and scrub-shrub), wetlands, barren/unvegetated, tidal flats, and open water. Typical
wildlife occurring within these habitat types are described below.
Upland habitat at the Project site can be further characterized as herbaceous and scrub-
shrub. Herbaceous habitat consists of areas dominated by sea ox-eye daisy interspersed in the
western half of the Project site, and also salty prairie which is found along the southeastern portion
of the Project site and along the proposed access road. Herbaceous habitat supports mammals,
reptiles, and birds, including white-tailed deer (Odocoileus virginianus), coyote (Canis latrans),
Eastern gray squirrel (Sciurus carolinensis), grasshopper mice (Onychomys spp.), Eastern cotton-
tail rabbit (Sylvilagus floridanus), desert cottontail (Sylvilagus audubonii), black-tailed jackrabbit
(Lepus californicus), least shrew (Cryptotis parva), desert shrew (Notiosorex crawfordi), and
bullsnake (Pituophis catinefer sayi).
Scrub/shrub habitats comprise the majority of the Project site and are primarily associated
with three distinct lomas: Loma del Potrero Cercado (a large loma system with two distinct peaks),
Loma del Divisadero, and the eastern portion of Loma de la Juaja. Lomas are dunes made of wind-
blown clay that provide important habitat for protected species such as the ocelot (Leopardus
pardalis) and jaguarundi (Herpailurus yagouaroundi cacomitli) (FWS 2012b), which are further
discussed in section 4.7. The lomas, due to their clay substrate and elevation, typically range from
5 to 30 feet above mean high tide and support a specific vegetative cover type, which is described
in section 4.5. Wildlife typically associated with scrub/shrub habitat include common raccoon
(Procyon lotor), white-tailed deer, coyote, bobcat (Lynx rufus), collared peccary (Tayassu tajacu),
Eastern gray squirrel, grasshopper mice, desert cottontail, black-tailed jackrabbit, least shrew,
desert shrew, and bullsnake.
Wetland habitats are located along the BSC and also shallow topographic depressions
found along the southwest boundary of the Project site and along portions of the Access Road.
Wetland habitats typically support diverse ecosystems that provide nutrients, cover, shelter, and
water for a variety of terrestrial and aquatic wildlife, including waterfowl, wading birds, raptors,
mammals, reptiles, and amphibians. Wildlife typically associated with wetlands include white-
tailed deer, grasshopper mice, Eastern cottontail rabbit, least shrew, Rio Grande lesser siren (Siren
intermedia texana), barred tiger-salamander (Ambystoma tigrinum mavortium), black-spotted
newt (Notophthalmus meridionalis), and red-eared slider (Trachemys scripta elegans).
In addition to the upland and wetland habitats, the Project site also contains
barren/unvegetated land and tidal/wind flats. Barren areas on the Project site is restricted to areas
along the toe of slopes of lomas where vegetation is lacking due to soil movement and active
4-41 Wildlife and Aquatic Resources

erosion. Tidal flats are frequently inundated for extended periods by tidal fluctuations. In addition
to tidal fluctuations, vessel wakes from the BSC cause these areas to be frequently inundated or
“washover” areas. At the Project site, tidal flats occur along portions of the waterfront of the BSC.
Wind tidal flats are mostly free of vegetation (less than 5 percent cover) and infrequently inundated
with water from high, wind-driven tides. These areas are located along the northeastern edge of
the Project site and are associated with South Bay. Typical wildlife associated with these habitats
include small mammals, reptiles, amphibians, and birds such as least shrew, and Rio Grande lesser
siren.
Open water comprises the portions of the BSC that extend into the Project site. Typical
wildlife associated with open water habitat include several bird species such as common loon
(Gavia immer), brown pelican (Pelecanus occidentalis), and laughing gull (Larus atricilla), and
marine mammals and fishes as discussed below in section 4.6.2.
Wildlife species that have been observed within the Project vicinity include: bobcat,
coyote, striped skunk (Mephitis mephitis), common raccoon, Virginia opossum (Didelphis
virginiana), nine-banded armadillo (Dasypus novemcinctus), white-tailed deer, nilgai antelope
(Boselaphus tragocamelus), collared peccary, feral pig (Sus scrofa), Eastern cottontail rabbit,
black-tailed jackrabbit, southern plains woodrat (Neotoma micropus), Mexican ground squirrel
(Spermophilus mexicanus), American badger (Taxidea taxus), long-tailed weasel (Mustela
frenata), and domesticated cats (Felis catus), horses (Equus caballus), cows (Bos taurus), and
goats (Capra hircus). Certain wildlife species, such as white-tailed deer and feral pigs have
recreational value for hunters. Horses, cows, and goats that have been observed in the vicinity of
the Project site may be considered commercially important species.
4.6.1.1 Impacts and Mitigation

As described in table 4.5.2-1 (see section 4.5), constructing the Project would affect about
491 acres of upland and wetland habitat and about 80 acres of open water habitat. Operating the
Project would result in the permanent loss of about 412 acres of habitat.
Impacts on wildlife resulting from construction of the Project would include displacement,
increased stress, and could lead to increased rates of injury and mortality. Vegetation clearing and
loss of habitat would reduce suitable cover, nesting, and foraging opportunities available for
wildlife. More mobile wildlife, such as birds and mammals, may relocate to similar adjacent
habitats when construction activities commence. This displacement and relocation would result
in “edge effects”; increased population densities, resulting in increased inter- and intra-specific
competition and reduced reproductive success of individuals.
Construction and operation of the Project would result in increased noise, lighting, and
human activity that could disturb wildlife in the area. Increased noise and nighttime lighting may
cause temporary displacement of terrestrial wildlife. See sections 4.11.2.3 and 4.11.2.4 for
detailed discussion of noise that would be generated during construction and operation,
respectively. However, there is abundant habitat available in the vicinity of the Project for wildlife
displaced temporarily and permanently by construction and operation of the Project. Increased
project-related traffic would result in higher rates of stress, injury, and mortality experienced by
wildlife. Smaller, less mobile wildlife such as reptiles and amphibians could experience increased
rates of injury and mortality (e.g., crushed by heavy equipment or falling into open excavations)
Wildlife and Aquatic Resources 4-42

during construction and potentially during operation. In accordance with TPWD

recommendations, Annova would cover any excavations or trenches that must be left unfilled at
the end of the work day, have escape ramps placed in them (made from boards or soil), or would
fence off the trench or excavation area with an exclusion fence. Annova would inspect any
excavations or trenches left open overnight the following morning for the presence of wildlife.
Construction activities would also result in temporary, localized air emissions that would
last for the duration of the construction period. Emissions from construction would not result in
the violation of any applicable ambient air quality standards. Impacts on wildlife species due to
air emissions during construction and operation of the site are expected to be minimal. Additional
information on air quality is provided in section 4.11.
Operating the Project would permanently remove wildlife habitat. In addition, the
boundary fence would permanently displace larger wildlife from entering the facility; however,
many reptiles, small mammals, and birds would continue to use habitat within the boundary fence
right-of-way. Although construction would permanently remove wildlife habitat, ample
undisturbed habitat is available in the vicinity of the Project site. In addition, Annova would
maintain a wildlife corridor on the west side of the Project site, where existing dense thornshrub
and other habitats would be avoided and preserved for use by various wildlife species. A barrier
wall located between the site and along the wildlife corridor would reduce light and noise impacts
on wildlife using the corridor. Some habitat within the fenced boundaries would only be
temporarily disturbed and vegetation would be allowed to revert to pre-existing land covers after
construction. Fencing and wildlife crossings along the access road and establishment of speed
limits is expected to reduce the possibility of vehicle collisions.
Temporary workspaces would be disturbed during construction, then planted with native
grasses in the goal of restoring a grassland/herbaceous wildlife habitat. Annova would implement
the applicable BMPs from the TPWD Wildlife Habitat Assessment Program, which includes the
TPWD Guidelines for Revegetation of Disturbed Landscapes (TPWD 2016d). As a result, any
habitats within the fenced boundaries that would be temporarily disturbed would be converted to
herbaceous habitat during Project operation.
In its comments on the draft EIS, TPWD identified a number of measures that it
recommends Annova incorporate into its proposal to reduce potential impact on wildlife resources.
In an EIR dated March 15, 2019, we asked Annova to provide a response to each of the TPWD
recommendations. On March 25, 2019, Annova filed its response, stating that it has consulted
with TPWD to discuss the TPWD comments on the draft EIS and included a table summarizing
how it would address the TPWD recommendations. The filing is included on the FERC docket
under accession number 20190325-5179.
Annova has proposed measures that would minimize the effects of light on visual
resources, off-site areas, and contrast with the night sky. The proposed lighting design and
practices to minimize light emitted from the Project include the following:
• installing lighting only where needed (motion sensors or timers would be

incorporated where use at night is intermittent);
• shielding bulbs and directing light downward;

• installing lamps with warmer colors and minimum blue light;

• minimize lighting on the access road to that required for safety reasons;
• whenever possible place lights so they do not shine directly towards adjacent
undisturbed habitats or the beach; and
• avoiding flaring of gas at night whenever feasible.
Annova would incorporate this information into a Facility Lighting Plan for use during
Project operation. The FWS has commented that Annova should also evaluate methods to
minimize the effects of light on wildlife during construction. Because construction would occur
over a period of four years, we agree. Because Annova has not yet developed its Facility Lighting
Plan, we recommend that:
• Prior to construction, Annova should file with the Secretary, for review and
written approval by the Director of OEP, its Facility Lighting Plan for
operation of the LNG terminal. In addition, Annova should include in its
Facility Lighting Plan measures to reduce the effects of light during
construction and commissioning of the Project.
4.6.1.2 Unique and Sensitive Wildlife

Unique or sensitive wildlife resources are present in the vicinity of the Project and are
discussed below. Species protected under the ESA are discussed in section 4.7.
Migratory Birds
Migratory bird species nest in the United States and Canada during the summer months
and then migrate south to the tropical regions of Mexico, Central and South America, and the
Caribbean for the non-breeding season. Some species migrate from breeding areas in the north to
the Gulf Coast for the non-breeding season. Migratory birds are protected under the Migratory
Bird Treaty Act (MBTA), which prohibits the take or killing of individual migratory birds, their
eggs and chicks, and active nests. The MBTA provides that it is unlawful to pursue, hunt, take,
capture, kill, possess, sell, purchase, barter, import, export, or transport any migratory bird, or any
part, nest, or egg of any such bird. Executive Order 13186 (January 2001) directs federal agencies
to consider the effects of agency actions on migratory birds and determine where unintentional
take is likely to have a measurable negative effect on migratory bird populations, and to avoid or
minimize adverse impacts on migratory birds through enhanced collaboration with the FWS.
Executive Order 13186 states that emphasis should be placed on species of concern, priority
habitats, and key risk factors, and that particular focus should be given to addressing population-
level impacts.
On March 30, 2011, the FWS and the Commission entered into a Memorandum of
Understanding (MOU) that focuses on avoiding or minimizing adverse impacts on migratory birds
and strengthening migratory bird conservation through enhanced collaboration between the two
agencies. This voluntary MOU does not waive legal requirements under the MBTA, BGEPA,
ESA, Federal Power Act, NGA, or any other statute and does not authorize the take of migratory
birds.

Consistent with EO 13186 which emphasizes a focus on species of concern and priority
habitats, the Project would be located within the North American Bird Conservation Initiative -
Bird Conservation Region 37 – Gulf Coastal Prairie (FWS 2015d). Appendix D identifies the
Birds of Conservation Concern known to occur in Cameron County and also includes species that
have nesting ranges within the county. Nineteen species of birds of conservation concerns have
the potential to nest within the Project site from approximately February to September (Cornell
Lab of Ornithology 2015; FWS 2015d).
Migratory birds follow broad routes called flyways between breeding grounds and
wintering grounds. South Texas and the Gulf of Mexico are part of the North American Central
Migratory Flyway, an important pathway for migratory birds, with many coastal and marine
species using the coastlines of Louisiana and Texas during migration (FWS 2012c; BOEM 2011).
Colonial waterbirds, a subset of migratory birds, include a large variety of bird species that
share two common characteristics: 1) they tend to gather in large assemblies, called colonies or
rookeries, during the nesting season; and 2) they obtain all or most of their food from the water
(FWS 2002). 8 No colonial waterbird rookeries have been identified within the Project site. The
closest documented rookery to the Project site is an island approximately 5 miles northeast at the
confluence of the Port Isabel Channel and the BSC.
Impacts and Mitigation

A variety of migratory birds including birds of conservation concern and waterfowl use or
could use the habitats affected by the Project. These birds use these habitats for foraging, resting
(stopover), sheltering, breeding, and nesting. These habitats and the impacts on them resulting
from constructing and operating the Project were addressed previously. As described previously,
constructing the Project would require the temporary removal of habitat that may be used by
migratory birds, much of which would be permanently removed for operation. Behavior changes
including nest abandonment combined with the loss and/or conversion of wildlife habitats as well
as direct impacts from construction could increase the amount of stress, injury, and mortality
experienced by migratory birds. In addition, increased noise and construction-related activity
could deter birds from nesting and, therefore, potentially decrease fertility. Migratory birds using
the Project area for foraging or roosting activities could be disrupted if they are disturbed while
engaging in these activities. The temporary and permanent loss of migratory bird habitat and the
general disruption to bird behavior created by the use of construction equipment could result in
the displacement of migratory birds. Displacement and avoidance could impact bird migration,
nesting, foraging, and mating behaviors.
Many migratory birds use natural light from the sun, moon, and stars for navigation, and
artificial lighting and flaring can suppress natural light sources, which could have unknown effects
on birds at the population level. Fatalities to avian species due to artificial light are well
documented, with avian fatalities associated with attraction to light sources, especially in low light,
fog, and when there is a low cloud ceiling (Orr et al. 2013). In addition, migratory birds are often
attracted to artificial lighting on large land-based facilities, and this light can disrupt migration
8Colonial waterbirds demonstrate nest fidelity, meaning they return to the same rookery year after year. Rookeries
are typically in marshes or near the shores of ponds or streams. Although some colonial waterbirds (e.g., least terns)
will nest in developed areas, many waterbirds (e.g., great blue heron and great egrets) are wary of human activity.

patterns and cause the birds to veer off course. A 2008 study showed that the strongest bird
attraction response is to white light, which seems to interfere with visual orientation (Poot et al.
2008). Attraction to artificial lighting could impact migratory birds if they collide with lighting
structures or elevated structures at the Project site. In addition, injury and mortality has been
documented from flaring events.
The FAA requires that structures exceeding 200 feet be marked and/or lighted (FAA 2016).
The FAA conducted a study that evaluated obstruction lighting arrangements to better understand
how migratory birds are negatively affected by obstruction lights and to identify lighting
techniques to reduce avian fatalities (Patterson 2012). Annova is not proposing any structures over
200 feet, therefore, we do not anticipate that the Project would include any FAA-required markings
or lighting on structures or facilities.
To minimize potential impacts on migratory bird nesting, the FWS recommends that
vegetation clearing activities be conducted outside the nesting season or between September 1 and
February 28 of each year in this area. In addition, several species that may occur in the Project
area are ground-nesting species and could nest within the construction site after initial vegetation
clearing; therefore, the FWS recommends that ground-disturbing activities also be conducted
outside the migratory bird nesting season. Annova would attempt to limit clearing on the Project
site to between September 1 through and February 28 to avoid impacts on migratory bird nesting.
Annova also states in its Plan that no winter construction is anticipated. If vegetation clearing or
construction during the nesting season cannot be avoided, Annova would follow the FWS
recommendation to have a biologist trained in bird identification available to survey the work area
to identify and avoid active nests prior to and during the clearing or construction activity. If nests
are found, a buffer around the active nest would be established until the birds fledge. Upon
fledging, clearing or construction activities would resume within the buffer.
Concerning the other FWS recommendations, Annova would implement the FWS’
recommendation that the construction cranes have the boom down when not in use and at night, in
order to minimize impacts on migratory birds, especially during inclement weather or during
conditions of limited visibility, and during bird migration. Because the MBTA is under the
jurisdiction of the FWS, we recommend that:
• Prior to construction, Annova should consult with the FWS to develop a

Project-specific Migratory Bird Plan that includes measures to avoid and
minimize impacts on migratory birds, including details from the Facility
Lighting Plan that are intended to reduce impacts on wildlife and birds.
Annova should file the Migratory Bird Plan and evidence of consultation with
the FWS with the Secretary.
To address potential impacts related to construction and operation lighting, Annova would
ensure that facility lighting meets the required codes for safety, security, and egress and would
include design measures and practices that would reduce off-site light impacts and light impacts
on the nighttime sky (see above) that would limit nuisance light and reduce potential impact on
migratory birds. Section 4.8 provides additional information on mitigation measures for lighting
to reduce visual impacts. As previously indicated, because Annova has not yet developed a plan
that identifies guidelines for lighting during operation of the LNG terminal, we recommend that

Annova file its Facility Lighting Plan with the Secretary prior to construction, and that Annova
include measures to address construction and commissioning in its Facility Lighting Plan. In its
comments on the draft EIS to FWS recommended that the Facility Lighting Plan also address
flaring. Because flaring would be infrequent we do not believe that it is appropriate to include
flaring in the Facility Lighting Plan.
During operation of the terminal, Annova anticipates that the use of warm/cold gas flares
would only occur intermittently during planned maintenance, shut-down, and start-up (MSS)
events. MSS flaring would typically occur for up to 12 hours each year (i.e., 6 hours for each
biannual MSS event) with a worst-case scenario of up to 40 hours during a year when all MSS
flaring events could coincide. Flaring from the marine flare stack would occur during the transfer
of LNG from the marine terminal to an LNG carrier that arrives with warm inert cargo tanks full
of either carbon dioxide or nitrogen. Annova estimates these marine flaring events would occur
up to two times per year, with the flaring operating continuously for up to 25 hours per event for
an annual total of up to 50 hours per year. Although this occasional flaring could impact some
migratory birds if present during the flaring event, we find that occasional flaring during operation
would not substantially impact migratory bird populations.
LNG ship traffic along the BSC could impact colonial waterbirds if they are nesting on an
island located along the BSC at the confluence with the Port Isabel Channel, approximately 5 miles
from the site, that has been known to be used in the past as a colonial waterbird nesting rookery.
Impacts could include erosion of the island due to wakes from passing LNG carriers. These
potential impacts are not expected to be significant but could cause minor to moderate impacts.
The BSC is an active shipping channel and the island currently experiences waves from vessel
wakes, and it would be expected that any waterbird nesting would occur above the zone of
influence from vessel wakes.
National Wildlife Refuges and Preserves

Two National Wildlife Refuges (NWR), two wildlife preserves, and a wildlife corridor
are located within 1.0 mile of the Project site. Impacts on wildlife within these areas are further
discussed below.
Laguna Atascosa National Wildlife Refuge
The Laguna Atascosa NWR is a 97,000-acre coastal refuge located north of the Project site
across the BSC and SH 48. Established in 1946 as a migratory bird habitat area, the landscape
consists of thornscrub, coastal prairie, sand dunes, lomas, and tidal flats. Within the Laguna
Atascosa NWR is the Bahia Grande Unit, a 6,500-acre tidal basin connected to the BSC by a pilot
channel. The closest portion of the NWR to the Project site is the Bahia Grande Unit which is
approximately 0.7 mile northwest from the Project site, and borders along the north side of SH 48.
In the 1930s, the Bahia Grande was cut off from the natural tidal flow provided from Laguna
Madre by various construction projects. In the early 2000s, a pilot channel was constructed
between the Bahia Grande and the BSC to provide a natural tidal flow and restore the basin to its
original, natural state. Work continues today on the Bahia Grande restoration, with the next phase
of construction involving the widening of the pilot channel between the Bahia Grande and the
BSC. Upon completion, it is expected that this expanded pilot channel will allow exchange of
more water with the BSC and a more natural tidal flow (FWS 2015b).

The Laguna Atascosa NWR would not have any Projects components constructed within
the NWR; however, impacts on the Bahia Grande Unit of the Laguna Atascosa NWR may occur
during construction and operation, including disturbance from increased noise, nighttime lighting,
and dredging within the BSC.
Construction and operation noise impacts on humans is addressed in section 4.11.2 and
summarized here relative to the NWR. Noise impacts on species are addressed in previous sections
and in section 4.7. Existing daytime and nighttime sound levels were measured at 4 locations near
the Project site, with the closest location to the Bahia Grande Unit being within the site about 0.7
mile from the southwest border of the NWR (Noise Monitoring Location 4 (NML4). Existing
sound levels at all locations ranged from 40 to 54 decibels (dBA), with the range at NML4 being
47-54 dBA. During construction, the most prevalent noise-generating equipment and activity is
anticipated to be pile driving, although general construction equipment and dredging would also
produce sound levels that would be perceptible in the vicinity of the site. Predicted construction
sound levels are listed in table 4.11.2-4, which shows that construction sound levels would be less
than 55 dBA at any of the four residential areas evaluated, however construction noise would be
audible at off-site locations, including within the Bahia Grande Unit of the Laguna Atascosa NWR.
This noise impact could continue periodically, depending on the phase of construction, for up to
four years. Because the most prevalent noise-generating equipment and activity is anticipated to
be pile driving, we have included a recommendation in section 4.11.2.3 to ensure that noise
generated from pile driving would not exceed predicted levels.
During operation, noise from the Project is predicted to be less than 50 dBA or less at the
edge of the Bahia Grande Unit of the Laguna Atascosa NWR at SH 48, and 45 dBA or less within
several hundred feet of SH48 (see figure 4.11.2-2). This change of sound level from the existing
sound levels measured in the Project vicinity would be within the range considered barely
perceivable to noticeable to humans. Animals have different sensitivity to noise frequencies than
humans. The noise impacts may be greater as many species also have a wider hearing frequency
range. However, given the distance and unweighted noise levels, impacts from noise within the
NWR during operation would be expected to be minor and limited to the area along the SH48
corridor.
Lighting within the Project site would be required during both construction and operation.
Impact of lighting is addressed above in section 4.6.1.1, where we have included a
recommendation to ensure that Annova’s proposed Facility Lighting Plan would minimize impact
of construction and operation lighting on off-site wildlife habitats. Visual impact on humans from
nighttime lighting during Project operation is evaluated in section 4.8.5.2, which includes
evaluation from two locations along SH 48 at the edge of the Bahia Grande Unit of the Laguna
Atascosa NWR - KOP 8 at a SH 48 pull-off near the Bahia Grande Channel, and KOP 9 at the
Jaime J. Zapata Memorial Boat Ramp. Animals may have different sensitivity to nighttime
lighting than humans. General impact on animals from Project lighting is discussed above.
Proposed dredging and the potential for impact on Bahia Grande is addressed in section
4.3.2.2. Dredging activities would result in increased turbidity and affect water quality in the BSC,
however modeling indicates that water quality impacts on the Bahia Grande from the proposed
dredging would be minor.

Lower Rio Grande National Wildlife Refuge

The Lower Rio Grande Valley NWR comprises both FWS-owned and FWS-leased lands.
Established in 1979 to protect biodiversity along the Rio Grande, the Lower Rio Grande Valley
NWR is a 102,000-acre coastal refuge that borders the Project site and the main access road. The
NWR connects lands managed by private landowners, nonprofit organizations, the State of Texas,
and two other NWRs (Laguna Atascosa and Santa Ana) along the last 275 river miles of the Rio
Grande (FWS 2013a). The management goals in the Comprehensive Conservation Plan for the
Lower Rio Grande Valley NWR include protecting biological diversity and wildlife and habitat
management; water rights, water quality, and wetlands; cultural resources; and public use,
recreation, and wildlife interpretation and education (FWS 1999).
Impacts on the portion of the Lower Rio Grande Valley NWR that is south of the Project
site would occur during construction and operation, including disturbance from increased noise
and nighttime lighting. During construction, the most prevalent noise-generating equipment and
activity is anticipated to be pile driving, although general construction equipment and dredging
would also produce sound levels that would be perceptible in the vicinity of the site. The noise
impact could continue periodically, depending on the phase of construction, for up to four years.
Because the most prevalent noise-generating equipment and activity is anticipated to be pile
driving, we have included a recommendation in section 4.11.2.3 to ensure that noise generated
from pile driving would not be greater than predicted.
During operation, noise from the Project is predicted to be less than 40 dBA at the edge of
the portion of the Lower Rio Grande Valley NWR that lies south of the Project site (see figure
4.11.2-2). As indicated previously, animals have different sensitivity to noise frequencies than
humans. The noise impacts may be greater as many species also have a wider hearing frequency
range. However, the sound level would be at or below the measured existing sound levels in the
vicinity of the NWR, therefore impact on the NWR from noise during operation would be expected
to be minor.
Lighting within the Project site would be required during both construction and operation.
Impact of lighting is addressed above in section 4.6.1.1, where we have included a
recommendation to ensure that Annova’s proposed Facility Lighting Plan would minimize impact
of construction and operation lighting on off-site wildlife habitats.
Loma Ecological Preserve

The Project site was formerly managed by the FWS on behalf of the BND as part of
mitigation for a canceled project. Under COE Permit 13942 issued to the BND in 1982 (COE
1982), an area associated with the Loma del Potrero Cercado was set aside as mitigation for a
project to deepen the BSC and facilitate construction of multipurpose docks at the deepwater
turning basin. Under COE Permit 13942, mitigation of impacts from the deepwater project
included setting aside 4,837 acres as a loma ecological preserve, which now includes the Project
site. The BND and the FWS entered into a lease for management of the preserve; however, the
BND did not implement the project to deepen the BSC and the permit expired in 1987. The BND
has notified the FWS that it intends to withdraw the proposed Annova site from the lease
agreement. In comments on the draft EIS the FWS made recommendations for the creation of

additional conservation easements related to Project impacts on lomas and ocelot habitat. See
additional discussion in section 4.7.1.2.
After consulting with the FWS, Annova modified the site layout to minimize potential
impacts on mature dense thornshrub vegetation and to maintain a wildlife corridor on the western
boundary of the site for potential wildlife movement through the area. The modified layout
requires an additional area of the loma ecological preserve.
South Bay Coastal Preserve

South Bay Coastal Preserve, a Texas Gulf Ecological Management Site, is located adjacent
to the Boca Chica Tract, approximately 3 miles from the Project site. The water connection
between the BSC and South Bay would be about 5 miles from the Project site. The TPWD
currently leases the preserve from the Texas General Land Office. The lands adjacent to the South
Bay Coastal Preserve are privately, locally, state, or federally owned or administered. The preserve
was originally held by the BND, but the area was transferred to the Texas General Land Office in
February of 1986 and was subsequently leased to the TPWD (TPWD 1989). The preserve contains
the southernmost bay in Texas and comprises approximately 3,500 surface acres of water. Habitats
within the bay are characterized primarily by emergent and submergent vegetation and extensive
algal flats. The area is used more frequently for recreation activities such as hunting and fishing
and is the location of extensive commercial oyster landings. Potential impacts on the South Bay
Coastal Preserve would generally be similar, but less than, those described above for the Boca
Chica Tract of the Lower Rio Grande Valley NWR because the South Bay Coastal Preserve is a
greater distance from the Project site, which would reduce both noise and light impacts. Potential
impacts on water quality and aquatic resources within South Bay are described in section 4.3.2.
South Texas Coastal Corridor

The Project site is located within a region considered by the FWS as being particularly
important to the travel and dispersal of the endangered ocelot. Within the region, the FWS has
developed a strategic habitat conservation plan, referred to as the South Texas Coastal Corridor
that has a goal of creating a wildlife corridor connecting the Laguna Atascosa NWR and Lower
Rio Grande Valley NWR (FWS 2015b). The FWS holds a conservation easement directly south
of the Laguna Atascosa NWR, between SH 48 and the BSC. This easement is 1,000 feet wide and
2,900 feet long and is considered a wildlife corridor for the endangered ocelot. The corridor
connects the Laguna Atascosa NWR to the BSC via a wildlife tunnel that passes under SH 48. See
additional discussion of this easement in section 4.7.1.2.
The FWS has identified as a focus for purchasing properties or obtaining easements within
Cameron County to establish the South Texas Coastal Corridor. The FWS’s goal for the
acquisition of properties and easements within this corridor is to eventually connect the main
Laguna Atascosa NWR tracts, the Bahia Grande Unit of the Laguna Atascosa NWR, Lower Rio
Grande Valley NWR units, and the Boca Chica tract, resulting in a contiguous conservation
landscape (National Fish and Wildlife Foundation [NFWF] 2015). This conservation landscape,
in turn, is linked to more than 2 million acres of private ranchland located north of the Laguna
Atascosa NWR with the 1.3-million-acre Rio Bravo Protected Area, managed by the National
Commission on Natural Protected Areas (known by its Spanish acronym CONANP) in coastal
Mexico (NFWF 2015).

As previously discussed, Annova would maintain a wildlife corridor on the west side of
the Project site, where existing dense thornshrub and other habitats would be avoided and
preserved. Annova would protect the wildlife corridor with a conservation easement for the life
of the Project. In addition, Annova would install a barrier wall along the southwest edge of the
site between the LNG terminal facilities and the wildlife corridor to reduce light and noise impacts
on wildlife. Section 4.7 provides additional information on the ocelot and other protected species
that would be impacted as a result of habitat loss and fragmentation, and section 4.7.1.2 includes
additional discussion specific to existing and potential new conservation easements for
preservation of ocelot habitat.
Pollinator Habitat
Pollinator species, including bats, bees, hummingbirds, butterflies, wasps, moths, and flies,
require the pollen and/or nectar of plants for food. About 80 percent of plant species need to be
pollinated; however, there is currently no specific FWS management of pollinator habitat (FWS
2016a). The decrease in suitable plant cover has led to concern over the state of pollinator species.
A total of 30 native pollinators (bees, butterflies, and moths) have been designated by the TPWD
as Species of Greatest Conservation Need in Texas; as such, the TPWD has developed the Texas
Monarch and Native Pollinator Conservation Plan, which outlines plans to conserve habitat,
educate the public, and conduct research on these species (TPWD 2016e).
According to the FWS (2012), the lower Rio Grande Valley is home to more than 300
butterfly species. Common butterfly species include the large orange sulphur butterfly (Phoebis
agarithe), queen butterfly (Danaus gilippus), giant swallowtail butterfly (Papilio cresphontes),
Mexican bluewing butterfly (Myscelia ethusa), and monarch butterfly (Danaus plexippus).
The monarch butterfly has gained recent attention due to extensive habitat loss and
degradation throughout its migratory ranges (FWS 2015e). A public comment was received
regarding potential impacts on monarch butterflies that could result from Project activities. Texas
is an important state in monarch butterfly migration because it is situated between the species’
principal breeding grounds to the north and its overwintering areas in Mexico (TPWD 2015a).
Monarch butterflies pass through Texas in both a fall and spring migration, and the Project site is
located within the coastal migratory range of this species. The FWS issued a notice that it planned
to conduct an ESA status review of the monarch butterfly to determine whether the species should
be proposed for federal listing (79 FR 78775-78778). The results of the ESA status review are not
yet publicly available.
Additionally, as described in the June 20, 2014, Presidential Memorandum, “Creating a

Federal Strategy to Promote the Health of Honey Bees and Other Pollinators”, “there has been a
significant loss of pollinators, including honey bees, native bees, birds, bats, and butterflies, from
the environment.” The memorandum states that “given the breadth, severity, and persistence of
pollinator losses, it is critical to expand Federal efforts and take new steps to reverse pollinator
losses and help restore populations to healthy levels.” In response to the Presidential
memorandum, the federal Pollinator Health Task Force published a National Strategy to Promote
the Health of Honey Bees and Other Pollinators in May 2015. This strategy established a process
to increase and improve pollinator habitat. Constructing the Project would temporarily and
permanently impact pollinator habitat (vegetation). The temporary loss of this habitat would

increase the rates of stress, injury, and mortality experienced by butterflies, honey bees and other
pollinators.
Milkweed (Asclepias spp.) is the primary plant species monarch butterflies use for foraging
and for reproduction; therefore, impacts and range-wide loss of this plant species has had a
potential population effect on monarch butterflies. Vegetation surveys performed in fall 2014 and
spring 2015 indicated that no milkweed species were present within the Project site; therefore,
construction and operation of the Project is not anticipated to impact the primary habitat for the
monarch butterfly.
4.6.1.3 Conclusion for Terrestrial Wildlife

Annova would minimize impact on wildlife by implementing some TPWD avoidance and
minimization measures, implementing the above-listed design measures to minimize impact from
facility lighting during operation, and develop and implement a Facility Lighting Plan, we
conclude that impacts on terrestrial wildlife and wildlife habitat would be minor.
4.6.2 Marine Resources

Marine habitats in the Project area are described in section 4.3. The BSC and associated
wetlands are the principal marine habitats within the footprint of the proposed Project where
marine species could be affected by the Project. The Gulf of Mexico is also included in this
analysis as marine species in the northern Gulf of Mexico would be exposed to LNG ship traffic.
4.6.2.1 Existing Marine Resources

Marine Mammals
Under the Marine Mammal Protection Act (MMPA; 16 USC 1361 et seq.), NOAA Fisheries
is responsible for protection of whales, porpoises, and dolphins and FWS is responsible for manatees.
Three marine mammal species known to occur in the Gulf of Mexico are federally listed as
endangered, one species is threatened, and one is proposed endangered under the ESA. All marine
mammals in the northern Gulf of Mexico are included in table 4.6.2-1; ESA-protected species are
discussed further in section 4.7.1.
TABLE 4.6.2-1
Gulf of Mexico Marine Mammal Summary with Likelihood of Occurrence in Brownsville Ship Channel
Potential Occurrence in
Common Name Species Name Status
Brownsville Ship Channel
Sei Whale Balaenoptera borealis ESA Endangered Unlikely / rare
Fin Whale Balaenoptera physalus ESA Endangered Unlikely / rare
Sperm Whale Physeter microcephalus ESA Endangered Unlikely
Gulf of Mexico Bryde’s Whale Balaenoptera edeni MMPA / Proposed Unlikely
Endangered
West Indian Manatee, Florida Trichechus manatus latirostris ESA Threatened Unlikely / rare
subspecies
Humpback Whale Megaptera novaeangliae MMPA Unlikely / rare
Pygmy Sperm Whale Kogia breviceps MMPA Unlikely / rare
Dwarf Sperm Whale Kogia simus MMPA Unlikely / rare

TABLE 4.6.2-1 (continued)
Gulf of Mexico Marine Mammal Summary with Likelihood of Occurrence in Brownsville Ship Channel
Potential Occurrence in
Common Name Species Name Status
Brownsville Ship Channel
Cuvier’s Beaked Whale Ziphius cavirostris MMPA Unlikely / rare
Blainville’s Beaked Whale Mesoplodon densirostris MMPA Unlikely / rare
Gervais’ Beaked Whale Mesoplodon europaeus MMPA Unlikely / rare
Melon-headed Whale Peponocephala electra MMPA Unlikely / rare
Pygmy Killer Whale Feresa attenuata MMPA Unlikely / rare
False Killer Whale Pseudorca crassidens MMPA Unlikely / rare
Killer Whale Orcinus orca MMPA Unlikely / rare
Short-finned Pilot Whale Globicephala macrorhynchus MMPA Unlikely / rare
Rough-toothed Dolphin Steno bredanensis MMPA Unlikely / rare
Fraser’s Dolphin Lagenodelphis hosei MMPA Unlikely / rare
Bottlenose Dolphin (multiple stocks) Tursiops truncatus MMPA Common
Risso’s Dolphin Grampus griseus MMPA Unlikely / rare
Atlantic Spotted Dolphin Stenella frontalis MMPA Common
Pantropical Spotted Dolphin Stenella attenuata MMPA Unlikely / rare
Striped Dolphin Stenella coeruleoalba MMPA Unlikely / rare
Spinner Dolphin Stenella longirostris MMPA Unlikely / rare
Clymene Dolphin Stenella clymene MMPA Unlikely / rare
Key: ESA = Endangered Species; MMPA = Marine Mammal Protection Act
A number of marine mammals are known to occur in the Gulf of Mexico; however, only
two species are considered regularly occurring in the Gulf of Mexico near the Project site—the
Atlantic spotted dolphin (Stenella frontalis) and the bottlenose dolphin (Tursiops truncatus;
multiple stocks). It is unlikely but remotely possible that the sperm whale or Bryde’s whale would
be encountered in the Gulf of Mexico near the Project site, especially in the LNG carrier transit
zone. The sperm whale is listed under the ESA; the Gulf of Mexico Distinct Population Segment
of Bryde’s whale is proposed endangered (81 FR 88639); these two ESA species are addressed in
section 4.7.1.
Atlantic Spotted Dolphin

The Atlantic spotted dolphin occurs throughout the warm temperate, subtropical, and
tropical waters of the Atlantic Ocean (NOAA Fisheries 2015a). It ranges across the U.S. East
Coast from the Gulf of Mexico to Cape Cod, Massachusetts; the Azores; and Canary Islands to
Gabon and Brazil. Its distribution may be affected by warm currents such as the Gulf Stream. In
the waters of the northern Gulf of Mexico, this species is usually observed within the shelf waters
from about 30 to 650 feet (10 to 200 meters) deep to the continental slope in waters around 1600
feet (500 meters) deep (Waring et al. 2015). The Atlantic spotted dolphin typically occurs in
groups of up to 50 individuals, but groups of up to 200 animals have been observed. However, it
does not typically enter inland waters such as the BSC.

Bottlenose Dolphin
The bottlenose dolphin occurs in oceanic waters worldwide, ranging from latitudes of 45°N
to 45°S. The Gulf of Mexico population is managed as several separate stocks (Waring et al.
2010). Coastal populations migrate into bays, estuaries and river mouths, while offshore
populations remain in open waters along the continental shelf (NOAA Fisheries 2015b). The
coastal stocks are reported throughout shallower nearshore waters up to 66 feet deep (around 56
miles from shore) in the northern Gulf of Mexico (Waring et al. 2015). The bottlenose dolphin is
known to occur in the BSC.
Fisheries Resources
Fisheries resources include managed fish and invertebrates, species of concern, and
federally designated EFH. Fisheries resources in the State of Texas are managed by the FWS,
NOAA Fisheries, and the TPWD. Fish and invertebrate communities in the Project area include
species common throughout South Texas estuaries. Table 4.6.2-2 lists the species indicated as
common in the BSC by the TPWD and local fishing reports. TCEQ has designated the BSC as a
warmwater fishery that supports aquatic life, recreational uses, and general use (TAC Title 30, Part
1, Chapter 307). The BSC is the only state-named, non-wetland, waterbody at the Project site.
The South Bay Coastal Preserve is located within the South Laguna Madre watershed with the
connection between South Bay and the BSC approximately 5 miles from the Project site; while
the Lower Laguna Madre is located approximately 5.5 miles from the Project site (see section 4.3
for details regarding waterbodies).
Seagrass beds function as nursery habitat for commercially important fishes and
crustaceans. Figure 4.3.2-3 in section 4.3 shows the locations of seagrass beds in the vicinity of
the Project site. The large open water channel of the BSC supports little submerged vegetation,
and seagrasses are not expected to occur there.
The open water habitat in the BSC is likely used by fish species predominantly in their adult
life stage. Fringe habitat along the edges of the BSC and nearby estuarine habitat (e.g., seagrass,
oysters, soft bottom) and associated connected wetlands (such as South Bay and Bahia Grande)
provide habitat for early life stages of species including, but not limited to, those listed in table 4.6.2-
2. These estuarine habitats act as spawning, nursery, and feeding grounds and are important for sea
turtle development, as well as populations of fish and shellfish (EPA 1999). An estimated 90 to 95
percent of all commercially and recreationally important fish and invertebrate species inhabit
estuaries at some point in their life cycle (Texas Aquatic Science 2015). The BSC serves as a
migration corridor by providing a conduit between connected shallow water nursery habitat and
spawning habitat offshore in the Gulf of Mexico.
Six fish listed by NOAA Fisheries as species of concern may occur in the Project vicinity
and nearshore Gulf of Mexico. These include species for which there are conservation concerns
regarding population status, but insufficient information is available to indicate a need to list the
species as threatened or endangered: Alabama shad (Alosa alabamae), dusky shark (Carcharhinus
obscurus), sand tiger shark (Carcharias taurus), Warsaw grouper (Epinephelus nigritus), speckled
hind (Epinephelus drummondhayi), and opossum pipefish (Microphis brachyurus lineatus)
(NOAA Fisheries 2012). The habitats within the Project area do not provide resources to meet
critical life needs of any of these fish species of concern.

TABLE 4.6.2-2
Common Fish and Invertebrate Species within the Project Area

Fish
Pinfish (Lagodon rhomboides) Lane snapper (Lutjanus synagris)
Snook (Centropomus undecimalis) Black drum (Pogonias cromis)
Sheepshead (Archosargus probactocephalus) Gulf flounder (Paralichthys albiguttata)
Red drum (Sciaenops ocellatus) Speckled trout (Cynoscion nebulosus)
Mangrove snapper (Lutjanus griseus) Gag grouper (Mycteroperca microlepis)
Southern flounder (Paralichthys lethostigma) Gafftopsail catfish (Bagre marinus)
Pigfish (Orthopristis chrysoptera) Hardhead catfish (Ariopsis felis)
Greater amberjack (Seriola dumerili) Atlantic cutlassfish (Trichiurus lepturus)
Red snapper (Lutjanus campechanus) Atlantic croaker (Micropogonias undulates)
Vermilion snapper (Rhomboplites aurorubens) Striped mullet (Mugil cephalus)
Ladyfish (Elops saurus) Spotted sea trout (Cynoscion nebulosus)
Florida pompano (Trachinotus carolinus) Cobia (Rachycentron canadum)
Crevalle jack (Caranx hippos) American eel (Anguilla rostrata)
Tripletail (Lobotes surinamensis)
Invertebrates
Blue crab (Callinectes sapidus) Lightening whelk (Busycon perversum)
Stone crab (Menippe adina) Brown shrimp (Farfantepenaeus aztecus)
Fiddler crab (Uca rapax) White shrimp (Litopenaeus setiferous)
Eastern oyster (Crassostrea virginica) Pink shrimp (Farfantepenaeus duorarum)
Sources: TPWD 2002, 2016e; Texas Weekend Angler 2016; Chron 2010
Managed Fisheries and Essential Fish Habitat

The MSA defines EFH as “those waters and substrate necessary to fish for spawning,
breeding, feeding, or growth to maturity” (16 USC §1802 [10]) and promotes the protection of
EFH in the review of projects conducted under federal permits, licenses, or other authorities that
affect, or have the potential to affect, such habitat. EFH has been designated for several groups of
federally managed fishes in the Gulf of Mexico, including coastal migratory pelagic resources,
reef fish, shrimp, and red drum, all of which have designated EFH within and near the Project site
(GMFMC 2007; NOAA Fisheries 2015c). Waters to the north and east of the Project site are
classified as EFH for coastal migratory pelagic species, reef fish, shrimp, and red drum.
Three species in the Project area are included in the coastal migratory pelagics FMP: king
mackerel (Scomberomorus cavalla), Spanish mackerel (Scomberomorus maculates), and cobia
(Rachycentron canadum). EFH for coastal migratory pelagics comprises all the estuarine,
nearshore, and offshore areas of the Gulf of Mexico out to the 100-fathom depth contour, including
the BSC (GMFMC 2004). An EFH Assessment, included as appendix F, provides a detailed
analysis of impacts on EFH for managed fish species, including species and life stages for which
EFH occurs within and adjacent to the Project site. On February 5, 2019, NOAA Fisheries
provided its comments on the EFH assessment, and concurred that impacts on EFH would be
temporary and minor.

4.6.2.2 Impacts and Mitigation: Marine Resources

Constructing and operating the Project would temporarily and permanently affect marine
resources within the BSC and potentially affect marine resources in the Gulf of Mexico. As
described below; excavation, dredging, vessel traffic, water withdrawals and discharges,
equipment noise, run off, pile driving, and lighting would all affect marine resources.
Excavation, Dredging, and Dredge Disposal

The marine facilities would be developed along the BSC at the Project site through a
combination of excavation and dredging as described in section 2.6.2. Excavation would occur in
two stages: a terrestrial excavation followed by a marine excavation (dredging activities) to remove
the remaining material below the water surface. The marine facilities would be dredged using a
hydraulic cutter suction dredge. Excavation and dredging would increase runoff and the
suspension of sediment, which would affect marine fish and invertebrates by decreasing visibility
and causing respiratory stress.
The effects of dredging on fish and invertebrates are a function of suspended sediment
concentration, duration of exposure, species, and life stage (Newcombe and Jensen 1996). An
increase in turbidity due to sediment suspension would reduce light penetration locally and a
a result, there may also be lower dissolved oxygen concentrations, causing a displacement of motile
organisms or stress and reduction in numbers of sessile benthic organisms (LUMCON 2016; COE
2012). Increased turbidity could also temporarily reduce predation efficiency. Extended periods
of elevated turbidities have been shown to reduce feeding rates by up to 20 percent and to reduce
the efficiency of the foraging process (Utne-Palm 2001; Gardner 1981). Increased turbidity would
limit feeding within the construction area, but prey would still be accessible in nearby unaffected
areas. During periods of increased turbidity, fish and mobile invertebrates may move away/avoid
the project vicinity (Nightingale and Simenstad 2001).
As mentioned above, increases in turbidity can also affect the level of dissolved oxygen.
Microorganisms, in response to the release of nutrients from disturbed sediments could increase
their rate of reproduction. Microorganism blooms can be followed by population crashes, which
lead to localized depletion of dissolved oxygen. Because light is not transmitted as easily in turbid
water, phytoplankton may be less able to photosynthesize and produce oxygen that would restore
the desired dissolved oxygen concentration.
An increase in turbidity would most likely have the greatest direct effects to eggs and larval
stages (Robertson et al. 2006). Because these life stages are more sensitive to such stresses and
are unable to move from the affected area, they are more susceptible to impacts than juveniles and
adults. Excess sediment in the water column could be fatal to larval or post-larval shrimp if
dredging occurs during peak abundance in early spring or summer. As described in section 4.3.2.2,
the predicted increase in sediment in the water column within the BSC could be moderate up to
about 2.5 miles downstream from the dredge area at the Project site. Sedimentation and turbidity
would decrease before reaching the entrance to South Bay, and the Laguna Madre, located over 5
miles downstream from the Project site. Construction dredging is expected to take at least 8
months, making it likely to overlap with the presence of larval and post-larval shrimp.

Impacts from dredging would be minimized with the use of BMPs to contain the turbidity
plume (see section 4.3). The maintenance dredging would mirror the maintenance dredging of the
BSC currently conducted by the COE. During maintenance dredging there may be an increase in
turbidity in the BSC; however, BMPs would be implemented to meet water quality criteria
identified in the 401 Water Quality Certification at the edge of the work zone, resulting in localized
effects. Construction-related turbidity may cause greater stress to marine species than the short-
term increases in turbidity typically associated with storms in the BSC.
Dredging would also permanently remove the soft bottom habitat of the BSC within the
footprint of the dredged area, causing a loss of habitat. Some bottom dwelling (demersal) species
such as mollusks, crustaceans, and shrimp (if present) may be entrained (and likely injured or
killed) during dredging activities. Larger, more mobile, species (e.g., blue crab) may be
temporarily displaced (Nightingale and Simenstad 2001). Although dredging activities would
affect species occupying the soft bottom habitat in the immediate Project area, effects on marine
resources in the Gulf of Mexico would be negligible.
Direct impacts from dredging on macroinvertebrates may include localized disruption of

activities, removal, turnover, burying, and crushing, all of which would increase the rates of stress,
injury, and mortality experienced by these species. As most benthic infauna live on or within the
upper 6 inches of the sediment surface, it is expected that removal of sediment and burial from
settling of sediments resulting from increased turbidity would result in some loss of these
organisms. Germano et al. (1994) found that benthic communities recover to an equilibrium
community within approximately 6 months to 1 year after a physical disturbance. Other studies
indicate recovery to this stage in 2 years or less (Murray and Saffert 1999; Rhoads et al. 1978).
Many physical and biological factors affect the recolonization process, with one of these being the
texture of the disturbed sediment. Any change in the texture of the material after the activity is
completed may result in changes in the community that was present before activities took place.
Additionally, overturned, deeper sediments may be hypoxic, resulting in longer periods to re-
establishment of former communities. Direct disturbance-related effects on benthos from the
proposed Project would be long term but mostly localized within the dredging footprint.
Sedimentation could indirectly affect some organisms downstream of the dredged area, as
discussed in section 4.3. Benthic species are likely to recolonize the dredged area but would be
disturbed by maintenance dredging at 2-year intervals. As such, the Project is expected to result
in long-term localized impacts on benthic marine species.
The potential for direct and indirect adverse effects of dredging on a given species of
invertebrate or fish would depend on its life history, habitat use, distribution, and abundance.
However, short-term impacts on older life-stages (juvenile and adult) of both pelagic and demersal
fish would be limited to temporary displacement during dredging activities. Because Annova is
proposing placement of dredged material in the adjacent DMPA 5A on BND property, no in-water
effects are expected.
Hydrostatic Testing
As described in section 2.6.3, the LNG storage tanks would be hydrostatically tested with
surface water to ensure their integrity prior to placing them into service. Hydrostatic test water
withdrawals could entrain and impinge fish eggs and juvenile fish near the intake structures in the
BSC. Entrainment and impingement could cause injury of mortality of organisms. In accordance

with its Project-specific Procedures (see appendix B), Annova would screen intake hoses to limit
the entrainment of aquatic organisms during water withdrawal. Annova would place screened
intake structures at the lowest possible elevation to reduce the impingement of biological
organisms and debris on intake screens. With the implementation of these measures, impacts on
aquatic resources as a result of water intake would be temporary and negligible.
When hydrostatic testing is complete, Annova would return the test water to the BSC. In
accordance with the EPA’s Hydrostatic Test Water Discharge Permit and the Railroad
Commission of Texas’ permit requirements, the water would be tested for total suspended
solids, oil and grease, and pH, and treated (if test results indicate that the water would not meet
requirements) prior to being discharged to the BSC. Discharge of hydrostatic test water may
cause localized, short-term turbidity in the BSC; however, potential impacts on aquatic resources
would be localized, temporary, and negligible and would be minimized through the use of energy-
dissipating devices installed at water discharge points.
Vessel Traffic
Increased traffic within the BSC and Gulf of Mexico due to LNG carrier transit to and from
the LNG terminal site could result in vessel strikes. Vessel strikes would increase the rates of
injury and mortality experienced by marine species. However, LNG carriers are generally slower
and generate more noise than typical large vessels, allowing marine mammals, sea turtles, and
fishes to more readily avoid collisions with them than with faster marine vessels.
To minimize the potential for vessel strikes, Annova would provide LNG carrier captains
with the 2008 NOAA Fisheries document entitled Vessel Strike Avoidance Measures and
Reporting for Mariners, which outlines collision avoidance measures. Based on the relatively
small increase in shipping activity relative to the total shipping traffic occurring in the Gulf of
Mexico, and because Annova would provide LNG carrier captains with NOAA Fisheries’
recommended strike avoidance measures, the potential for the Project to result in increased vessel
strikes to marine mammals or sea turtles is unlikely to occur (discountable).

LNG carriers, like other large vessels withdraw and discharge water into and out of
onboard ballast tanks to provide additional draft and improve navigational performance. During
loading, LNG carriers would discharge ballast water into the BSC. Discharge of large volumes
of ballast water can cause changes to the quality of receiving waters by affecting salinity,
dissolved oxygen, temperature, and pH (see section 4.3). In addition, nonindigenous species
transported in ballast water may be introduced to receiving waters during discharge.
As described in section 4.3, ballast discharged into the BSC would have little to no effect
on the BSC’s salinity regime. Additionally, marine species likely to occur within the project
vicinity are highly adapted to salinity variations, and any short-term increases from ballast discharge
would be well within their tolerance range. Therefore, we have determined that changes in salinity
from ballast water discharges would be temporary and negligible.
As discussed in section 4.3, depending on the oxygen levels present in both the ballast and
ambient water at the time of discharge, aquatic resources in the vicinity of the discharge point

could be exposed to dissolved oxygen levels considered unhealthy for aquatic life. Marine species
typical of warmer latitudes such as the BSC are generally habituated to fluctuations in dissolved
oxygen (Engle et al. 1999). The adaptability of resident species within the BSC to natural variation
in oxygen levels would minimize the impacts associated with low dissolved oxygen on mobile
species. Bivalves are not able to be relocated when oxygen levels drop. Instead, they simply close
their valves and wait for more favorable conditions to return. Impacts on aquatic species within
the BSC from changes in dissolved oxygen are expected to be minor and temporary in nature.
Depending on the time of year, ballast water discharges would likely be several degrees
cooler that ambient temperatures in the BSC. The pH of the ballast water would reflect conditions
where open ocean exchange occurred. The volume of ballast water discharge is small relative to
the BSC. The expected differential between ballast water discharge and the BSC is not large
enough to cause a change in pH or temperature that would significantly impact aquatic organisms.
Impacts of temperature and pH in ballast water discharge on existing marine organisms in the BSC
would be temporary and negligible.
Invasive Species
Ballast water management is specified in the National Invasive Species Act of 1996 and
international standards adopted in 2004 to minimize the release of aquatic species that were
transported from other location in ballast water. Further, the International Maritime Organization
adopted measures outlined by the BWM Convention to prevent the introduction of non-native
species through ballast water exchange in 2017, as further discussed in section 4.3.2.2. If species
that are not native to the BSC become established and outcompete native species, the ecosystem
in the BSC could be disrupted, leading to declines in native species that are important to
recreational or commercial fisheries or have other societal values. However, since the Port of
Brownville has been in operation for more than 80 years including for international trade, the
makeup of native aquatic species within the BSC has likely been altered over the years by ballast
water exchange that occurred prior to ballast water regulation.
To minimize and avoid impacts on marine resources resulting from the introduction of
invasive species, the Coast Guard would require all LNG carriers calling on the terminal to adhere
to all applicable ballast water management rules and regulations. Additionally, LNG carriers
would be required to adhere to all applicable U.S. laws, regulations, and policy documents related
to ballast water including the following:
• the Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990

(NANPCA) established a broad federal program “to prevent introduction of and to
control the spread of introduced aquatic nuisance species.” The FWS, Coast Guard,
EPA, COE, and NOAA Fisheries all were assigned responsibilities.
• the NISA reauthorized and amended the NANPCA because “Nonindigenous
invasive species have become established throughout the waters of the U.S. and are
causing economic and ecological degradation to the affected near shore regions.”
The Secretary of Transportation was charged with developing national guidelines
to prevent import of invasive species from ballast water of commercial vessels,
primarily through mid-ocean ballast water exchange, unless the exchange threatens
the safety or stability of the vessel, its crew, or its passengers.

• the NISA, amended in 2005 and again in 2007, established a mandatory National
Ballast Water Management Program. The primary requirements established under
NAISA are: 1) all ships operating in U.S. waters are required to have on board an
Aquatic Invasive Species Management Plan; 2) the Coast Guard was made
responsible for the development of standards for mid-ocean ballast water exchange
and ballast water treatment for vessels operating outside of the EEZ; and 3)
implementing the BMPs and available technology related to ballast water
treatment.
• the National Ballast Water Management Program, originally established by
NANPCA and further amended by the National Invasive Species Act of 1996
(NISA and NAISA, made the ballast water management program mandatory,
including ballast water exchange, with reporting to the Coast Guard.
• the Shipboard Technology Evaluation Program is a program authorized under the
Coast Guard Ballast Water Management Program and designed to facilitate the
development of “effective ballast water treatment technologies, through
experimental systems, thus creating more options for vessel owners seeking
alternatives to ballast water exchange.”
• the Navigation and Vessel Inspection Circular 07-04, Change 1, a program
developed by the Coast Guard for the management and enforcement of ballast water
discharge into U.S. ports and harbors.
• Vessels Carrying Oil, Noxious Liquid Substances, Garbage, Municipal or
Commercial Waste, and Ballast Water, implementing regulations for the Act to
Prevent of Pollution from Ships of 1980, which applies to all U.S.-flagged ships
anywhere in the world and to all foreign-flagged vessels operating in navigable
waters of the U.S. or while at port under U.S. jurisdiction.
Cooling Water Intake and Discharge

All ships use water to cool their boilers. The cooling water would be withdrawn along the
vessel transit routes while in route to the Project, and from the BSC marine facility while loading
LNG cargo. Depending upon engine type, LNG carriers would use between 5.5 and 11.7 million
gallons of water for engine cooling while at the LNG terminal. Intake of water can result in the
entrainment of aquatic resources. Early life stages of fish and invertebrates (ichthyoplankton)
would be most susceptible to entrainment. Quantitative data for the structure and density of the
ichthyoplankton community within the BSC are unavailable; however, we would expect the
species composition to be largely composed of the same species identified in table 4.6.2-2. As a
proxy for the density, we refer to sampling data collected within the Calcasieu River near Carlyss,
Calcasieu Parish, Louisiana. In that sampling, fish species had a larval density of 522.2 individuals
per 1,000 cubic meters and the shrimp larval density was 91.5 individuals per 1,000 cubic meters.
Using these estimated densities and estimated range of cooling water use, between 10,900 and
23,100 larval fish, and between 1,900 and 4,100 larval shrimp could be entrained by each LNG
carrier while at the Project. At full capacity, Annova would receive up to about 125 LNG carriers
per year, which would affect between 1.3 and 2.8 million larval fish and 237,000 and 512,000
larval shrimp per year by cooling water intake. It is important to realize that, due to the high
natural mortality rates in the first year of ichthyoplankton (greater than 90 percent), an incremental

loss would not significantly impact the health of the adult fish population. The impact on
ichthyoplankton from cooling water uptake would be permanent (for the life of the facility), but
we conclude these impacts would not be significant.
Water used for engine cooling would be discharged at a temperature between 2.7°F and
7.2°F warmer than the ambient water temperature (Caterpillar 2007, 2011, 2012). Using the most
conservative estimates (assuming the highest ambient temperature generally found within the BSC
[86°F], the greatest change in water temperature [7.2°F], and the largest volume of water [11.7
million gallons]), the discharged cooling water temperature would be 95.5°F. Fish and
invertebrates within the immediate vicinity of the LNG carrier could be temporarily affected by
this increase in temperature; however, many of the species present are mobile and would be
expected to relocate to more suitable conditions during discharges. Given the volume of cooling
water discharged relative to the total volume of water within the BSC, and the expectation that
mobile species would temporarily leave the area of increased temperature, we have determined
that impacts on marine and aquatic resources would be short-term and minor.
Increased Noise Levels

The effects of sound on marine fish species are pathological, physiological, and behavioral.
Pathological effects include lethal and sub-lethal physical damage; physiological effects include
primary and secondary stress responses; and behavioral effects include changes in exhibited
behaviors. Project-related acoustic stressors include pile driving and dredging during construction
and LNG carrier engines during operation.
Pile Driving
Construction of the marine facilities would require installation of pilings using land-based
and in-water equipment, as described in section 2.6.2. Pile-driving activities could result in
temporary increases in underwater noise levels in the BSC. During land-based pile driving the
earth would act as a sound buffer, thereby reducing the noise reaching the BSC. Consequently,
effects on species in the BSC from land-based pile driving would be minimal. Any pile-driving
activities conducted in the marine environment may have minor sedimentation effects to marine
species, similar to those described above with respect to dredging.
Acoustic thresholds and mitigation measures for sea turtles and bottlenose dolphin are
discussed in section 4.7.1.4. Hearing sensitivity in fish is discussed below. Mitigation measures
to protect sea turtles and dolphins would reduce acoustic stress on fish also.
Pathological effects reported in several studies indicate that sounds of 90 to 140 decibels
(dB) above the hearing threshold of a fish may potentially injure the inner ear of the fish (Hastings
et al. 1996; Enger 1981). Since many fish use their swim bladders for buoyancy, they are
susceptible to rapid expansion/decompression due to peak pressure waves from underwater noises
(Hastings and Popper 2005). The Fisheries Hydroacoustic Working Group (consisting of federal
and state transportation and rescue agencies, underwater acoustics experts, fish biologists, and
transportation specialists) was formed in 2004 to gather all available information on the effects of
sound on fish. An agreement was established with this multi-agency group on underwater noise
effects criteria for fish for in-water projects. The underwater noise interim threshold criteria for
fish injury from a single pile strike during impact pile-driving occurs at a sound pressure level of

206 dB peak pressure within a circle centered at the location of the driven pile out to a distance of
approximately 13 feet (Fisheries Hydroacoustic Working Group 2008).
A physiological effect of sound may include generalized stress (Wysocki et al. 2006).
Some studies indicate that behavioral responses at construction sites, including site avoidance,
may be as strongly tied to visual stimuli as to underwater sound (Huijbers et al. 2012; Guthrie and
Muntz 1993; Feist et al. 1992). The majority of research on this topic involves studies of the
physiological effect of impact pile-driving on fish due to changes in water pressure. Fish with
swim bladders would be more vulnerable to such pressure changes, which can cause capillaries to
rupture or the swim bladder to rapidly expand and contract (California Department of
Transportation 2001; ICF Jones & Stokes and Illingworth and Rodkin, Inc. 2009). Therefore, it is
likely that fish would alter their normal behavior, displaying a startle response during the initial
stages of pile driving, and then avoid the Project site during pile-driving activities.
Behavioral reactions to underwater noise include moving out of the way, moving to deeper
depths, or altering schooling behavior. The levels at which fish react are somewhat variable,
depending on circumstances and species.
It is anticipated that some fish would avoid the area because of levels of sound when the
hammer is operating. However, as pile driving would be a short-term, temporary action performed
only during construction, the occurrence of these species within the BSC over the long term is not
likely to change significantly. Pile driving is expected to take no more than five days.
Additionally, the area of disturbance would be small and similar habitat surrounds the Project site;
therefore, the energy expended by fish to avoid the Project area would be minimal. Disturbance
of fish close to an individual pile or within the immediate Project area would be short-term and is
not expected to result in population-level effects. Annova would protect fish and marine wildlife
from noise associated with dredging and pile driving through use of thresholds established for
marine wildlife by NOAA Fisheries and the Fisheries Hydroacoustic Working Group. Annova
would minimize impacts from in-water noise by installing noise bubble curtains and conducting
on-site monitoring in consultation with NOAA Fisheries.
The greatest potential for impacts on marine mammals from constructing and operating the
Project would be acoustic disturbance and possibly auditory injury from pile-driving during
construction.
Dredging and LNG Carrier Traffic

Engine-noise produced by dredges and LNG carriers would result in temporary increases
in underwater noise levels near the vessels (see additional discussion in section 4.11.2.4). The
noise typically emitted by an operating dredge is below 1 kHz (Todd et al. 2014). Noise generated
by LNG carriers is generally omni-directional, emitting from all sides of the vessel (Whale and
Dolphin Conservation Society 2004), but is greatest on the sides of the ship and weakest on the
bow and stern of the ship. Impacts on marine and aquatic species due to increased noise levels of
vessels would vary by species; however, the species within the BSC and LNG carrier routes are
likely accustomed to regular fluctuations in noise levels from ongoing industrial and commercial
shipping activities in the BSC and vessel transit routes. Additionally, as described above, many
of the species present within the BSC and LNG carrier transit routes are mobile and would be able
to move out of noisy areas that would startle or stress any species present. Due to the existing

industrial and shipping activities within the BSC and LNG carrier transit routes and the mobility
of resident species, we have determined impacts on aquatic species from engine-noise produced
by dredges, and LNG carriers during operation, would be intermittent and minor.
Spills
Annova developed a Project-specific Plan and Procedures (see appendix B) based,
respectively, on our Plan (FERC 2013a) and Procedures (FERC 2013b). The Annova Plan and
Procedures include pollution control measures and BMPs that would help to control erosion,
sedimentation, and pollutants in runoff from the site (including stormwater runoff and spills).
Annova would obtain an NPDES General Permit for Construction Storm Water Discharge
from the EPA prior to any site disturbance and an NPDES Industrial Waste Water Discharge
Permit for facility discharges of stormwater from an oily water separator, stormwater ponds, and
on-site packaged sanitary wastewater treatment pond. Annova would follow the SWPPP required
as part of the EPA NPDES General Permit for Construction Storm Water Discharge, as well as the
SPCC Plan for construction to prevent and respond to spills. Adherence to the Annova Plan and
Procedures would reduce the potential for spills or impacts on the waterway; therefore, impacts
on fisheries due to stormwater discharge are expected to be negligible.
Lighting
Ichthyoplankton, juvenile fish, and species of small fish may be attracted to lighting during
construction and operation. However, no subsurface lighting is planned for the LNG facilities.
Lighting impacts would be primarily associated with aggregation of planktonic organisms, with
possible increased feeding in the local area by larger species. Potential impacts from lighting
would be reduced by Annova’s use of measures designed to reduce nuisance lighting, and
development and implementation of a Facility Lighting Plan for operation of the LNG terminal.
At the request of the FWS we are also recommending that the Facility Lighting Plan also address
construction and commissioning. Overall, with the use of Annova’s proposed measures to reduce
nuisance lighting, and implementation of a Project-specific Facility Lighting Plan, no significant
impacts on ichthyoplankton or fisheries resources are expected from lighting at the Project site.
Additional information on lighting is provided in section 4.8.4.
4.6.2.3 Conclusion for Marine Resources

Construction of the Project would result in minor effects on aquatic resources due to
temporary degradation of water quality and direct mortality of some immobile individuals during
dredging. Further, noise from pile-driving would result in temporary and minor impacts on fish.
In addition, spills of hazardous materials could affect water quality and affect aquatic organisms
during construction and operations; however, implementation of measures in Annova’s SPCC
Plans and Project-specific Plan and Procedures would minimize potential effects. During
operation, the Project would have minor effects on aquatic resources due to maintenance dredging
and increased vessel traffic. Permanent effects on aquatic habitat would occur where open water
would be converted to commercial/industrial land within the BSC; however, the permanent
reduction in aquatic habitat within the Project area is not expected to result in significant adverse
effects on marine resources.

In our EFH Assessment included in appendix F, we conclude that potential impacts

resulting from Project construction and operation are expected to be short-term and highly
localized, occurring primarily during construction or shortly thereafter. On February 5, 2019,
NOAA Fisheries provided its comments on the EFH assessment, and concurred that the impacts
on EFH would be temporary and minor.

4.7 SPECIAL STATUS SPECIES

Special status species are those species for which state or federal agencies afford an
additional level of protection by law, regulation, or policy. Included in this category are federally
listed and federally proposed species that are protected under the ESA; species that are currently
candidates for federal listing under the ESA; state-listed threatened or endangered species; and
species otherwise granted special status at the state or federal level.
Federal agencies are required by Section 7 of the ESA to ensure that any actions authorized,
funded, or carried out by the agency do not jeopardize the continued existence of a federally listed
threatened or endangered species, or result in the destruction or adverse modification of designated
critical habitat of a federally listed species. As the lead federal agency, the FERC is required to
coordinate with the FWS and NOAA Fisheries to determine whether federally listed threatened or
endangered species or designated critical habitat are found in the vicinity of the Project, and to
determine potential effects on those species or critical habitats.
For actions involving major construction activities with the potential to affected ESA-listed
species or designated critical habitat, the lead federal agency must prepare a BA and submit it to
the FWS and NOAA Fisheries. If the action would adversely affect a listed species, the federal
agency must also submit a request for formal consultation. In response, the FWS and NOAA
Fisheries would issue a Biological Opinion as to whether or not the federal action would likely
jeopardize the continued existence of a listed species or result in the destruction or adverse
modification of designated critical habitat. The FERC is currently preparing a BA for the Annova
Project, which will be submitted to the FWS and NOAA Fisheries.
To assist in compliance with Section 7 of the ESA, Annova, acting as the FERC’s non-
federal representative for the Annova LNG Project, coordinated with the FWS’ Texas Coastal
Ecological Services Field Office and with NOAA Fisheries regarding the Project. In addition,
Annova also coordinated with the TPWD and requested a review of information contained within
the TPWD’s Texas Natural Diversity Database (TXNDD) regarding species and habitats
potentially affected by construction and operation of the Project. Based on this information and a
review of publicly available information, agency correspondence, and field surveys, 64 federally
and/or state-listed threatened and endangered, or candidate species may occur in Cameron County.
Federally and state-listed species known to occur or potentially occurring in the vicinity of the
Project are identified in tables 4.7.1-1 and 4.7.2-1, respectively.
Under the MMPA, NOAA Fisheries is responsible for the protection of all whales,
porpoises, and dolphins, while the FWS is responsible for manatees. Federal responsibilities
include providing overview and advice to regulatory agencies on all federal actions that might
affect marine mammals. The ESA-protected marine mammals known to occur in the northern
Gulf of Mexico are addressed herein. Other marine mammals are addressed in section 4.6.2.1.
4.7.1 Federally Listed Threatened and Endangered Species

proposed, or candidate threatened and endangered species may occur within Cameron County. Of
these, two listed plant species do not have the potential to occur in the vicinity of the Project and
are not discussed further in this EIS. The remaining 18 species include marine mammals,
4-65 Special Status Species

terrestrial mammals, birds, and sea turtles. Within Cameron County, critical habitat has been
designated for the loggerhead sea turtle in the offshore marine area transited by LNG carriers and
for the wintering piping plover in the onshore Project area.
TABLE 4.7.1-1
Federally Listed and Candidate Species Known to Occur or Potentially Occurring in Cameron County, Texas
Listed Species
Project Preliminary Impact
Common Name Scientific Name Listing Status Jurisdiction Component Determination a/
Mammals
Blue whale Balaenoptera Endangered NOAA Fisheries Marine facilities NLAA
musculus
Fin whale Balaenoptera Endangered NOAA Fisheries Marine facilities NLAA
physalus
Sei whale Balaenoptera Endangered NOAA Fisheries Marine facilities NLAA
borealis
Sperm whale Physeter Endangered NOAA Fisheries Marine facilities NLAA
macrocephalus
Gulf of Mexico Balaenoptera edeni Proposed NOAA Fisheries Marine facilities NLAA
Bryde’s whale Endangered
West Indian Trichechus manatus Threatened FWS Marine facilities NLAA
manatee
Ocelot Leopardus pardalis Endangered FWS LNG facilities and LAA
access road
Gulf Coast Herpailurus Endangered FWS LNG facilities and LAA
jaguarundi yagouaroundi access road
cacomitli
Birds
Northern aplomado Falco femoralis Endangered FWS LNG facilities and NLAA
falcon septentrionalis access road
Piping plover Charadrius melodus Threatened FWS LNG facilities and NLAA
access road
Red-crowned parrot Amazonia Candidate FWS LNG facilities and Would not contribute
viridigenalis access road to a trend toward
federal listing
Red knot Calidris canutus rufa Threatened FWS LNG facilities and NLAA
access road
Whooping crane Grus Americana Endangered FWS LNG facilities and NLAA
access road
Eastern black rail Laterallus Proposed FWS LNG facilities and NLAA
jamaicensis Threatened access road
jamaicensis
Reptiles
Green sea turtle Chelonia mydas Threatened FWS; NOAA Marine facilities NLAA
Fisheries
Kemp’s ridley sea Lepidochelys kempii Endangered FWS; NOAA Marine facilities NLAA
turtle Fisheries
Loggerhead sea Caretta caretta Threatened FWS; NOAA Marine facilities NLAA
turtle Fisheries
Hawksbill sea turtle Eretmochelys Endangered FWS; NOAA Marine facilities NLAA
imbricata Fisheries
Leatherback sea Dermochelys Endangered FWS; NOAA Marine facilities NLAA
turtle coriacea Fisheries
Special Status Species 4-66

Federally Listed and Candidate Species Potentially Occurring in Cameron County, Texas
Listed Species
Project Preliminary Impact
Common Name Scientific Name Listing Status Jurisdiction Component Determination a/
Flowering Plants
South Texas Ambrosia Endangered FWS Suitable habitat NE
ambrosia cheiranthifolia is present within
the Project site,
but no evidence
of occurrence
Texas ayenia Ayenia limitaris Endangered FWS Suitable habitat NE
is present within
the Project site,
but no evidence
of occurrence
a/ Preliminary impact determinations: NLAA = may affect but is not likely to adversely affect; LAA = likely to adversely
affect; NE = no effect because the species is not expected to occur in the Project vicinity
4.7.1.1 Marine Mammals

Whales
The blue whale occurs in all oceans of the world. It inhabits sub-polar to sub-tropical
oceans and rarely occurs in the Gulf of Mexico off the coast of Texas. The only two records of a
blue whale in the Gulf of Mexico are for strandings: one near Sabine Pass, Louisiana, in 1926 and
one near Freeport, Texas, in 1940 (Texas Tech University 1997). Both identifications have been
questioned. The current North Atlantic population of 100 to 1,500 individuals represents a small
portion of the worldwide population of 11,000 to 12,000 blue whales.
The fin whale occurs in deep offshore waters of all major oceans (NOAA Fisheries 2011b)
but is rarely encountered in the Gulf of Mexico. A young individual was stranded on the beach at
Gilchrist in Chambers County on February 21, 1951 (Texas Tech University 1997). This highly
migratory species forages in high latitudes during spring and summer and migrates to temperate
waters for mating and calving during fall and winter.
The sei whale is a medium-sized baleen whale occurring primarily in offshore waters from
the Gulf of Mexico and Caribbean Sea northward to Nova Scotia and Newfoundland. This
migratory species tends to occur in groups of two to five individuals. No occurrences of sei whales
have been reported in the waters off Texas (Schmidly 2004).
The sperm whale typically inhabits waters about 2,000 feet (600 meters) or greater in depth,
and is uncommon in waters less than 1,000 feet (300 meters) deep (NOAA Fisheries 2011b). The
sperm whale occurs in all oceans between approximately 60 degrees north and 60 degrees south
latitudes. This species is the most abundant whale in the Gulf of Mexico, and sightings in Texas
near the coast are relatively common (Texas Tech University 1997). The sperm whale is
encountered most often at depths of 655 feet or greater, along submarine canyons on the edge of
the continental shelf. Threats to this species in the Gulf of Mexico include entanglement in
longline fishing gear and vessel strikes. However, serious injuries or mortalities of sperm whales
were reported in the northern Gulf of Mexico during the most recent stock assessment period
(2009–2013) (NOAA Fisheries 2016a).

The Gulf of Mexico Bryde’s whale was determined to be a genetically distinct subspecies
of the Bryde’s whale and proposed for listing as endangered in December 2016 (81 FR 88639-
88656). It is the only baleen whale that occurs in the Gulf of Mexico year-round. Based on
sightings, the De Soto Canyon area in the northeastern Gulf of Mexico has been identified as a
biologically important area for the Bryde’s whale. This subspecies is most often reported in the
De Soto Canyon area along the continental shelf break between about 300 and 1,000 feet in depth.
While the Gulf of Mexico Bryde’s whale may occur in other portions of the Gulf of Mexico, its
distribution and abundance are not known (81 FR 88639-88656).
Impacts and Mitigation: Whales

Although no whale species are expected to venture into the relatively shallow waters of the
BSC, individual whales occurring in the Gulf of Mexico may be subjected to strikes by LNG
carriers transiting to and from the Project. The Coast Guard LOR indicated that a maximum of 80
LNG carriers per year would visit the Project, depending on vessel size. LNG carriers operating
within the U.S. EEZ in the Gulf of Mexico are generally slower and generate more noise than
typical large vessels and would therefore be more readily avoided by these mobile species. The
probability of any whale encountering an LNG carrier in the open Gulf is low because (1) whales
are generally able to detect and avoid large vessels and (2) NOAA Fisheries and the Coast Guard
provide educational materials to vessel operators to increase awareness of whales in sensitive
areas. An increase in LNG carrier traffic as a result of the Project (see section 4.9.10) would
increase the potential for risk of strikes; however, we conclude based on the frequency of both
whale occurrences and shipping traffic that this increase would be minimal Vessel strikes would
be mitigated and minimized by vessel operators watching for and avoiding strikes, as described in
NOAA Fisheries’ most recent Vessel Strike Avoidance Measures and Reporting for Mariners
(revised February 2008). Unlike sea turtles, discussed in section 4.7.1.4 below, whales are less
likely to be struck because they are more visible to vessel operators and typically do not enter the
BSC where maneuverability is more constrained.
Based on the relatively small increase in shipping activity when compared to the total
shipping traffic in the Gulf of Mexico, and because Annova would provide LNG carrier captains
with NOAA Fisheries’ recommended strike avoidance measures, the potential for the Project to
result in increased vessel strikes to any whale species is minimal. Therefore, we have determined
that constructing and operating the Project may affect, but is not likely to adversely affect whale
species.
West Indian Manatee

The West Indian manatee includes two distinct subspecies: the Florida manatee
(Trichechus manatus latirostris) and the Antillean manatee (Trichechus manatus manatus). This
species was previously listed as endangered, but was downlisted to threatened status on May 5,
2017, based on significant improvements in its population and habitat conditions (82 FR 16668
16668-16704).
The manatee is a rotund, slow-moving herbivorous marine mammal that reaches up to

about 13 feet in length. It ranges throughout the southeastern United States in nearshore coastal
marine, brackish, and freshwater habitats. The Florida manatee occurs in very shallow water
(about 6 to 13 feet deep) close to shore where it forages on seagrasses (FWS 2013b and 2007).

Manatees often congregate near natural springs, power plants, or other industrial sites that
discharge warm water in Florida during the winter. During the warmer months, the Florida
manatee may range as far north as Massachusetts and as far west as Texas; however, occurrences
outside of the primary range are irregular (FWS 2013b and 2007). The manatee is rare in Texas,
but has been sighted in Corpus Christi Bay, Laguna Madre, Cow Bayou near Sabine Lake, Copano
Bay, along Bolivar Peninsula, and at the mouth of the Rio Grande (Texas Tech University 1997).
Impacts and Mitigation: Manatee

Occurrence of the manatee in the Project area is considered possible but unlikely. Sightings
in the BSC are very rare and typically involve only a single animal that does not remain long in
the vicinity. To address the possibility of a transient manatee, Annova would provide recognition
and orientation training on the manatee to all personnel associated with the Project. Posters and
other information would provide assistance in identification of manatees and would instruct
personnel not to feed or otherwise engage the manatees. Given the rare occurrence of the manatee
in the BSC and the conservation measures described above, we have determined that constructing
and operating the Project may affect, but is not likely to adversely affect this species.
4.7.1.2 Terrestrial Mammals

The ocelot (Leopardus pardalis) and Gulf Coast jaguarundi (Herpailurus yagouaroundi
cacomitli) could occur in the Project area. Suitable habitat is present in the Project area for both
of these species. No critical habitat has been designated by the FWS for the ocelot or jaguarundi.
Annova conducted a camera-trapping survey for ocelot and jaguarundi on BND and private
land in the Project vicinity from January 2016 through January 2017. The objective of the survey
was to augment the existing database of ocelot/jaguarundi observations in the survey area, which
could provide information on the current ocelot/jaguarundi use of the potential habitats in the
survey area. Over the course of the survey, 121 camera trap sets were installed in the survey area
and operated for over 40,000 trap-nights. No ocelots or jaguarundis were observed during the
camera-trapping survey.
Ocelot
The ocelot is federally listed as endangered. This species is a medium-sized, spotted cat
about 30 to 41 inches in length and weighing from 14 to 30 pounds (Campbell 2003). Its pelage
is grayish or buffy and is heavily marked with black spots, small rings, blotches, and short bars
(Schmidly 2004). The ocelot has a long tail that is ringed or marked with dark bars on the upper
surface, parallel stripes running down the nape of the neck, and a shorter pelage (Campbell 2003;
Schmidly 2004). Ocelots are primarily nocturnal and solitary, normally beginning their activity at
dusk when they begin their nightly hunt for rodents, rabbits, and other small mammals, as well as
birds, snakes, and lizards (Schmidly 2004; Tewes and Hughes 2001). Ocelots prefer dense
thornshrub and rocky areas (FWS 1990a) and require large unbroken blocks of habitat for
movement. During denning season, which is mid-April through December (Laack et al. 2005),
ocelots give birth to and care for one to two kittens that are unable to travel for a period of time
without being moved by the adult female.
Historically, dense thornshrub habitat preferred by ocelots occurred throughout south

Texas, but in the 20th century ocelot habitat was reduced to less than one percent of its former

distribution by agricultural, suburban, and urban development (Tewes and Everett 1986; Grassman
2006). In addition, the FWS estimated that the amount of suitable ocelot habitat available in the
Laguna Atascosa NWR and the surrounding area (within a 13.7-mile buffer around the refuge, the
Project site being located just outside this buffer) is 19,200 acres (FWS 2010). Fragmentation and
loss of dense brush habitat, combined with vehicle road mortalities, are the greatest threats to
ocelot persistence in south Texas (Haines et al. 2005; FWS 2013d).
Two verified breeding ocelot populations occur in the United States, one in Cameron
County, Texas, at the Laguna Atascosa NWR and one in Willacy County, Texas, on private
ranches (Tewes 2017). The Laguna Atascosa NWR population is the closest resident
subpopulation to the Project area and is located approximately 11 miles north of the Project.
However, in 1998 a dispersing male ocelot was captured, radio-collared, and tracked in dense
thornscrub on lomas in and around the Project area. Based on tracking, this ocelot eventually
travelled north to the Laguna Atascosa NWR. Ocelots have previously been documented in and
around the Project area. The current size and distribution of loma thornshrub in the vicinity of the
Project site may support transient or resident ocelots, although surveys have only documented the
one transient individual.
The Project is located within a region considered by the FWS as being an important
component of the coastal ocelot corridor connecting Texas and Mexico. This corridor is referred
to by the FWS as the South Texas Coastal Corridor. The FWS believes that this corridor is
essential for the movement and the genetic viability of the ocelot. Within the region, the FWS has
developed a strategic habitat conservation plan, referred to as the South Texas Coastal Corridor,
which has a goal of creating a wildlife corridor connecting the Laguna Atascosa NWR and the
Lower Rio Grande Valley NWR (FWS 2015c).
The FWS has identified the South Texas Coastal Corridor as a focus for purchasing
properties or obtaining easements within Cameron County to establish protected wildlife habitat.
The goal of the acquisition of properties and easements within this corridor is to eventually connect
the main Laguna Atascosa NWR tracts, the Bahia Grande Unit of the Laguna Atascosa NWR,
Lower Rio Grande Valley NWR units, and Boca Chica State Park, If successful, the acquistions
would create a contiguous conservation landscape (NFWF 2015). This conservation landscape, in
turn, is linked to more than 2 million acres of private ranchland located north of the Laguna
Atascosa NWR with the 1.3-million-acre Rio Bravo Protected Area, managed by The National
Commission on Natural Protected Areas (known by its Spanish acronym CONANP) in coastal
Mexico (NFWF 2015).
Gulf Coast Jaguarundi

The Gulf Coast jaguarundi is federally listed as endangered throughout its range, which
was historically limited to the Lower Rio Grande Valley in southern Texas in the United States
and eastern Mexico in the States of Coahuila, Nuevo Leon, Tamaulipas, San Luis Potosi, and
Veracruz (FWS 2013c). Only a small portion of the Gulf Coast jaguarundi’s range and habitat
occur in the United States. The last confirmed sighting of Gulf Coast jaguarundi within the United
States was in April 1986, when a roadkill specimen was collected 2 miles east of Brownsville,
Texas, and positively identified as a jaguarundi (FWS 2013c). Numerous unconfirmed sightings
have been reported since then, including some sightings with unidentifiable photographs, but no
United States reports since April 1986 have been confirmed as jaguarundi. Known jaguarundis

closest to the United States border are found approximately 95 miles southwest in Nuevo Leon,
Mexico. There are no documented occurrences of jaguarundi within the Project area.
The Gulf Coast jaguarundi uses dense, thorny shrublands or woodlands and bunchgrass
pastures adjacent to dense brush or woody cover. Caso (2013) found that radio-collared
jaguarundis spent up to 40 percent of their time in tall, dense grass habitats, but habitat analysis
indicates that the preferred habitat is natural undisturbed forest. Primary known threats to the Gulf
Coast jaguarundi are habitat destruction and degradation, habitat fragmentation due to agriculture
and urbanization and, to some extent, human disturbance including border security activities.
Mortality from collisions with vehicles is also a threat. Competition with bobcats may be a limiting
factor in the northern portion of the jaguarundi’s range (Sanchez-Cordero et al. 2008). Increases
in temperature and decreases in precipitation resulting from climate change are also believed to
affect Gulf Coast jaguarundi populations by altering their preferred habitat (FWS 1990b).
Impacts and Mitigation: Terrestrial Mammals

Constructing and operating the Project would result in the loss of suitable ocelot and
jaguarundi habitat, which could affect their movement resulting in avoidance and displacement.
The Project would result in the permanent loss of 127 acres of Loma Evergreen Shrubland and 85
acres of South Texas Loma Grassland/Shrubland, which is considered preferred habitat for ocelots
and jaguarundis. This includes Loma del Potrero Cercado within the site, which represents one of
the 22 named lomas located in the vicinity of the Project. Loma del Divisadero and an unnamed
smaller loma would be within the undisturbed travel corridor that Annova would maintain to the
southwest of the site. The loss of habitat within Loma del Potrero Cercado within the Project site
would represent about 6 percent of the approximately 2,075 acres of named lomas in the immediate
Project area and less than 1 percent of the dense thornscrub habitat within a 13.7-mile radius
around the Laguna Atascosa NWR. Because this habitat is part of the South Texas Coastal Corridor
identified by the FWS, this habitat loss could decrease the effectiveness of this habitat linkage
(resulting in habitat fragmentation) and affect the ability of ocelots to use this area as a potential
travel corridor. Habitat loss and fragmentation eliminates areas that may be used for ocelot
breeding, feeding, and sheltering. Large-scale fragmentation could result in reduced dispersal and
isolation. In a small population, inbreeding due to reduced dispersal and/or isolation could reduce
fitness of individuals and loss of genetic variability which could reduce the ability of an animal to
adapt to a changing environment (Lande 1988). The FWS has indicated that the Project would
sever the remaining coastal ocelot corridor to the Rio Grande River and Mexico (FWS 2015h). To
address this impact and as discussed further below, Annova designed the Project layout to include
an undisturbed wildlife corridor on the Project’s western boundary.
Increased human disturbance could discourage ocelot and jaguarundi use of the Project
area, although use of the site by jaguarundi is expected to be minimal to none based on the absence
of a known population in South Texas. Construction and operation activities would increase noise
levels in the Project area. These noise impacts, especially impulsive noise such as pile driving,
would affect use by ocelots and jaguarundis, if present.
Artificial lighting would disrupt ocelot and jaguarundi dispersal movements (Beier 2005).
Project-related vehicle traffic would increase wildlife collision potential. Vehicle collisions are
the leading cause of death of ocelots in Texas. Vehicle collisions from Project traffic could affect
jaguarundis, although the possibility is considered minimal given the absence of a known

population of jaguarundis in South Texas. Construction of fencing and wildlife crossings along
the access road and the establishment of speed limits is expected to further reduce the possibility
of vehicle collisions.
To avoid direct impacts on the ocelot and jaguarondi during construction, clearing of dense
thornshrub communities and adjacent shrub communities that are present on the lomas within the
Project site would be conducted outside the denning season (i.e., from January to mid-April).
Alternatively, if clearing could not be conducted during this timeframe, a survey would be
conducted for at least a month immediately preceding clearing and biologists would monitor the
clearing to ensure that these species are not impacted.
In coordination with the FWS, Annova identified the following conservation measures that
would minimize Project impacts on the ocelot and jaguarundi.
• Conservation of Off-Site Lands. Annova is evaluating lands for purchase or
conservation easement in the Project region to aid in ocelot conservation. Annova
would transfer the land to the FWS, or provide funding for conservation lands that
may benefit ocelots and jaguarundis.
• Preservation of a Wildlife Corridor. Annova modified its initial design for the
Project to accommodate a wildlife corridor on the west side of the Project site,
where existing dense thornshrub and other habitats would be preserved. Annova is
proposing to protect the wildlife corridor with a conservation easement for the life
of the Project. Annova would install a barrier wall along the southwest edge of the
site between the LNG terminal facilities and the wildlife corridor to reduce light
and noise impacts on wildlife. The barrier wall would consist of posts drilled into
the ground and approximately 25-foot-tall concrete panels between the posts, and
would include three-inch-high cut outs spaced along the base of the wall to allow
for stormwater drainage.
• Time Extension of Existing Redhead Ridge Conservation Easement. Annova
is working with the BND to extend the duration of a BND-owned conservation
easement located on the north side of the BSC (Puerta de Trancas Loma). This
conservation easement consists of a 1,000-foot-wide easement encompassing three
tracts of land extending from the SH 48 southerly right-of-way line to the BSC.
The conservation easement was established in 2004 in association with the Texas
Department of Transportation’s proposed improvements to SH 48 and is adjacent
to a wildlife crossing bridge under SH 48. Currently, the conservation easement is
scheduled to expire in September 2023. If approved by the BND, Annova is
proposing to extend the conservation easement for the life of the Project in order to
connect the proposed wildlife corridor on the west side of the Project site to
additional conservation lands farther north.
In its comments on the draft EIS, the FWS recommended that Annova establish perpetual
conservation easements, instead of easements for the life of the Project, and finalize the easement
agreements with the BND, for three specific areas; the wildlife corridor within the west side of the
Project site (181 acres); the Redhead Ridge Conservation Easement (containing the Puerta de
Trancas Loma, 42 acres); and an area parallel to the proposed Project access road (189 acres). In

an EIR dated March 15, 2019, we asked Annova to respond to this recommendation. In its March
25, 2019 response (FERC accession number 20190325-5179) Annova stated that it cannot commit
to a perpetual conservation easement as a lessee to the BND because Annova does not own or
control the property. If the Project continues to operate beyond the term of the existing lease,
Annova can commit to extend the term of those existing conservation easements. If the FWS
grants the right-of-way for the use of proposed access road, Annova would not develop the
alternative access road location (see section 3.5), in which case Annova has committed to work
with the BND to establish a new conservation easement on BND property that would protect dense
thornshrub habitat on the 189-acre area that encompasses Loma de la Jauja.
We received a number of comments on the draft EIS, including from Friends of the Wildlife
Corridor, contending that Annova’s proposed wildlife corridor along the western edge of the
Project site would be unlikely to function as a wildlife corridor because it would be heavily affected
by noise and lights from the facility, and from the outer security fence and traffic along the access
road. Predicted maximum time averaged construction noise within the corridor would range from
55 to 60 dBA. As indicated in Section 4.11.2 Pile Driving, during installation of the larger piles
there may be potential noise impacts between 85-100 dBA Lmax. However, we are recommending
that Annova limit pile driving to daytime only.
Predicted sound levels in the wildlife corridor during operation would range from 50 to 65
dBA. See additional discussion in section 4.11.2.4 and figure 4.11.2.2, and Annova’s response to
our March 8, 2019, Environmental Information Request (on the FERC docket under accession
number 20190325-5179). The barrier wall between the facility and the corridor would be expected
to reduce light and noise impacts within the corridor, however its unclear when during the
construction process this would be constructed. We acknowledge that conditions within the
corridor would be influenced by being immediately adjacent to the LNG facililty and that actual
use by ocelots of the corridor is an unknown.
In its comments on the draft EIS the FWS also stated that Annova will need to provide to
the FWS details for the design of the access road, including number of wildlife crossings,
dimensions of size of openings, and fencing on both sides of the wildlife crossings to keep cats
and other wildlife off the road. In its comments on the draft EIS the FWS also recommended that
dense ocelot habitat be established or revegated along the access road in areas leading up to the
wildlife crossings. Annova has not proposed this specific measure but has stated that it would
continue to consult with the FWS regarding potential impacts on the ocelot and jaguarondi and
potential measures to mitigate for those impacts.
The past documented occurrences of ocelots in and around the Project site are limited and
distant enough in time to provide little support that the species is likely to be encountered. Suitable
habitat is present within the Project site; however, the site would likely only be used by transient
individuals, possibly from the known ocelot subpopulation in Laguna Atascosa NWR. However,
Annova has agreed to establish a wildlife corridor along the southwest boundary of the Project site
that may be utilized in the event transient individuals attempt to traverse the site. In light of all of
these considerations we have consulted closely with the FWS regarding an appropriate
determination of effect and conclude that constructing and operating the Project may affect, and is
likely to adversely affect the ocelot.

The current size and distribution of loma thornshrub in and around the Project site, and
within the larger region, may support jaguarundis if they still exist in Texas, and the FWS typically
treats the jaguarundi in a similar manner to the ocelot; therefore, we have determined that
constructing and operating the Project may affect, and is likely to adversely affect the jaguarundi.
4.7.1.3 Birds
The listed northern aplomado falcon, piping plover, and red knot, the candidate red-
crowned parrot, and the proposed Eastern black rail are known to occur or potentially occur in
Cameron County (table 4.7.1-1). Suitable habitat is present in the Project area for all of the
federally listed and candidate bird species with the exception of the red-crowned parrot. The FWS
has also identified designated critical habitat for the wintering piping plover in the Project area.
Northern Aplomado Falcon

The northern aplomado falcon (Falco femoralis septentrionalis) is federally listed as
endangered. This species is a medium-sized falcon that ranges in length from 15 to 18 inches and
in wingspan from 32 to 36 inches (Campbell 2003). Although it is difficult to precisely determine
former abundance of the species in the U.S., most observers in the latter half of the 19th century
described northern aplomado falcons as fairly common (FWS 1990c). Dramatic decreases of the
U.S. population of northern aplomado falcons occurred between 1890 and 1910 (Oberholser 1974).
Reintroduction of the northern aplomado falcon into the U.S. began in the mid-1980s at the Laguna
Atascosa NWR in south Texas. In conjunction with the FWS, the Peregrine Fund has raised and
released northern aplomado falcons at the Laguna Atascosa NWR and other sites in Texas and
New Mexico, with more than 1,500 captive-bred northern aplomado falcons released through the
Northern Aplomado Falcon Restoration Project (Peregrine Fund 2012). Today, the U.S.
population consists of two nesting subpopulations located along the Gulf Coast in South Texas.
The northern aplomado falcon occurs in open plains or grassland habitats with scattered
trees or shrubs. The northern aplomado falcon hunts prey individually, in pairs, and in family
groups (Burnham et al. 2002). Small birds and insects are common prey items pursued in flight,
though pursuit is readily continued on foot through trees, brush, or dense grass (FWS 1990c).
Northern aplomado falcons do not construct their own nests but appropriate stick platforms
built by other raptors and corvids (Campbell 2003). In south Texas, nests have been found in
Spanish dagger (Yucca treculeana), honey mesquite (Prosopis glandulosa), Texas ebony
(Ebenopsis ebano), and on artificial structures such as electric transmission poles. Surveys have
also found northern aplomado falcons nesting on the ground (Burnham et al. 2002). Aplomado
falcons usually lay two to three brown speckled eggs, and both parents provide incubation
(Campbell 2003).
Aplomado falcons are year-round residents in the Project area. The northern aplomado
falcon nesting season (egg-laying through fledging) in the Project vicinity could extend from
March through August. Northern aplomado falcons are known to use the Project site, although no
nests have been recorded. However, nests have been recorded within one mile of the Project (FWS
2014b; Peregrine Fund 2015).

A safe harbor program was initiated in 1996 that provides landowners, including the BND,
a safe harbor (i.e., permission to cause incidental take of the northern aplomado falcon at the
Project site, so long as the level of incidental take does not cause the Action Area’s environmental
baseline for the northern aplomado falcon to fall below conditions existing at the time BND
became a sub-permittee). The baseline responsibilities for BND under the safe harbor permit are
one pair of northern aplomado falcons, which was determined at the time they signed a Cooperative
Agreement and received a Certificate of Inclusion from the Peregrine Fund. Therefore, BND’s
obligations are to maintain one nesting pair. In addition, they would give the Peregrine Fund
advance notice and an opportunity to salvage any nestlings and/or eggs for any activities that may
result in incidental taking of northern aplomado falcons on BND property. In comments on the
draft EIS, the FWS stated that although incidental take would be covered by the agreement, it
encourages northern aplomado falcon habitat conservation across the landscape.
Impacts and Mitigation: Northern Aplomado Falcon

Within Annova’s proposed site and access road, potentially suitable habitat for the northern
aplomado falcon includes vegetation characterized as Gulf Coast Salty Prairie and Coastal Sea Ox-
eye Daisy Flats (see section 4.5 for description of these vegetation types). Approximately 183
acres of potentially suitable habitat for the northern aplomado falcon would be affected by
construction and 146 acres would be affected by operation of the Project. Land clearing could
adversely impact northern aplomado falcons, which rely on larger plants to perch and nest, such
as yuccas. Human disturbance could cause northern aplomado falcons to be flushed and displaced
and may interrupt foraging and roosting. Northern aplomado falcons would likely avoid areas
where active construction and operation activities are occurring.
Construction and operation activities would increase noise levels in the Action Area (see
section 4.11). Birds demonstrate startle effects when exposed to a sound pressure level (SPL) of
108 dBA (Burger 1981). Noise levels exceeding that level are not expected during construction
or operation of the Project (see tables 4.11.2-4 and 4.11.2-7 in section 4.11). High-noise events
may cause birds to avoid the Project area, and if present, would be flushed, both of which could
affect bird behavior including feeding, preening, and caring for their young (NoiseQuest 2015).
Although Project lighting could cause northern aplomado falcons to be disoriented and
collide with buildings or other structures at the Project site, lighting is expected to have a minimal
effect on northern aplomado falcons as this species is not nocturnal or migratory. Annova would
evaluate lighting schemes to reduce potential lighting effects. Furthermore, whenever possible,
lights would be placed so they do not shine directly towards adjacent undisturbed habitats or the
beach, and lighting would be extinguished upon completion of work in an area. In addition,
injuries or mortality from flaring has been documented.
An increase in vehicle traffic may result in a corresponding increase in avian mortality.

Some fencing would be incorporated along the access road as part of the design for wildlife
crossings, and the FWS has recommended that design of the fencing take into account the potential
to serve as perches for aplomado falcons and whether this would be a potential hazard. However,
given the commonplace nature of fencing, we conclude that fencing could serve as a perch, but
any resulting risk would not be substantial. Direct mortality from collisions with vehicles or
construction equipment may occur, though the potential for collisions with vehicles and equipment
is expected to be low for aplomado falcons.

To minimize potential effects on the northern aplomado falcon, when possible, clearing of
vegetation would be scheduled from September through February, outside the nesting season for
northern aplomado falcons. If vegetation clearing is conducted during the nesting season (March
through August), Annova would conduct a nest survey prior to the clearing. If an active northern
aplomado nest is found on the Project site, Annova, in coordination with the BND, would notify
the Peregrine Fund and allow them to survey for nests/offspring in the Project area in order to
relocate nests out of the Project area prior to habitat removal. Annova would also follow the FWS
recommendation to have a biologist trained in bird identification available to survey the work area
to identify and avoid active nests prior to and during clearing or ground-disturbing activities.
Although northern aplomado falcons have been documented in and near the Project site,
no nests have been documented at the Project site. This species is highly mobile and typically
departs at the approach of humans. Approximately 146 acres of suitable habitat would be
permanently lost as a result of Project construction and operation. Annova would implement
measures, including minimization of impacts on suitable nesting habitat as well as clearing outside
the nesting season or otherwise conducting nest surveys prior to construction. Therefore, we have
determined that constructing and operating the Project may affect, but is not likely to adversely
affect the northern aplomado falcon.
Piping Plover and Red Knot

Piping Plover
The piping plover (Charadrius melodus) is federally listed as threatened. This species is a
small shorebird about 7 inches in length with a wingspan of approximately 15 inches (Campbell
2003). In Texas, habitat preferred by piping plovers includes mud, sand, or algal flats and
mainland or barrier island beaches, all of which are areas that are periodically covered with water
and then exposed either by tides or wind (Campbell 2003).
Piping plovers spend 3 to 4 months of the year on their breeding grounds in the northern
United States and Canada and the remainder of the year on their wintering grounds. One of their
primary wintering areas is the Texas coast, which is estimated to winter more than 35 percent of
the known piping plover population (Campbell 2003). These plovers arrive in Texas between late
July and late October and depart for their breeding grounds between early March and mid-May
(Oberholser 1974).
Piping plovers usually disperse to feed and are typically observed singly or in small flocks
foraging or roosting on barrier islands and mainland beaches, sand, mud and algal flats, washover
passes, salt marshes, and coastal lagoons. A common feeding trait is its habit of run-and-halt
foraging wherein the plover sprints along the beach, stops suddenly to inspect the surrounding
territory, and then sprints on (Oberholser 1974). Typical prey of the piping plover includes marine
worms, flies, beetles, spiders, crustaceans, mollusks, and other small marine animals and their eggs
and larvae (Campbell 2003).
Habitat in the Project area (which includes the Coastal Salt and Brackish High Tidal Marsh,
Coastal Tidal Flat/Washover, and South Texas Wind Tidal Flats 9) may support foraging, roosting,
9
Coastal Salt and Brackish High Tidal Marsh occurs in the Project area, but would not be affected by the Project

and sheltering piping plovers. In addition, the sparsely vegetated areas at DMPA 5A may provide
suitable wintering habitat. There are no documented occurrences of piping plovers within the
Project site; however, this species has been recorded in the Rio Grande Valley.
Piping Plover Critical Habitat

The FWS designated 7,217 acres of the south Texas coast (i.e., Unit TX-1) as wintering
piping plover critical habitat (FWS 2000). The boundaries of this unit include wind tidal flats that
are infrequently inundated by seasonal wind-driven tides and serve as preferred piping plover
habitat. Based on the description of piping plover critical habitat, we have assumed that the Project
site includes a portion (13.4 acres) of the designated critical habitat. This is approximately 0.2
percent of the critical habitat included in the 7,217-acre Unit TX-1 and 0.02 percent of the total
piping plover critical habitat designated in Texas.
Red Knot
The red knot (Calidris canutus rufa) is federally listed as threatened. This species is a
long-distance migrant bird with a wingspan of 20 inches. Red knots can fly more than 9,300 miles
from south to north every spring and repeat the trip in reverse every autumn (FWS 2015g). Surveys
of wintering red knots along the coasts of southern Chile and Argentina and during spring
migration in Delaware Bay on the United States coast indicate that a serious population decline
occurred in the 2000s. Recent information suggests that red knots may spend more than three-
fourths of each year along the Texas coast, occurring from late July or early August to mid-May,
from Matagorda Island south to the state of Tamaulipas in Mexico.
The wintering habitat for red knots along the Texas Gulf Coast is similar to piping plover
habitat and includes barrier island beaches, exposed tidal flats, washover passes, and mud flats
(Port Isabel Economic Development Corporation 2015). Red knots forage on beaches, oyster
reefs, and exposed bay bottoms, and roost on high sand flats, reefs, and other sites protected from
high tides (FWS 2014c). A study at Laguna Madre found that red knots prefer bay habitats when
they are available, and are sensitive to high water levels in bays. In general, red knots are
associated with lower sand flat habitats (FWS 2014d).
Red knots depend on favorable habitat, food, and weather conditions within narrow
seasonal windows as they move between migration stopovers between wintering and breeding
areas. For example, the red knot population decline that occurred in the 2000s has been attributed
to reduced food availability from increased harvests of horseshoe crabs, exacerbated by small
changes in the timing that the red knots arrived at the Delaware Bay. Horseshoe crab harvests are
now managed with explicit goals to stabilize and recover red knot populations.
Habitat in the Project area that may support foraging roosting, and sheltering red knots
include Coastal Salt and Brackish High Tidal Marsh, Coastal Tidal Flat/Washover, and South
Texas Wind Tidal Flats 10. In addition, as described above for the piping plover, suitable habitat
for red knots may also occur within sparsely vegetated areas at DMPA 5A. There are no
documented occurrences of red knots within the Project site; however, this species has been
10
Coastal Salt and Brackish High Tidal Marsh occurs in the Project area, but would not be affected by the Project

recorded in the Rio Grande Valley region and the Project site includes suitable habitat for red
knots.
Impacts and Mitigation: Piping Plover, Red Knot, and Piping Plover Designated Critical Habitat
Excavating the marine berth would permanently remove approximately one acre of suitable
piping plover and red knot habitat along the BSC. In addition, dredging activities planned for the
DMPA 5A site would modify potentially suitable habitat that currently exists for piping plovers.
The Project has been designed to avoid the wind-tidal flats and piping plover designated critical
habitat located on the east side of the Project site.
Human disturbance could cause overwintering piping plovers and red knots to be flushed
from the area and displaced, and may interrupt foraging and roosting. Because piping plovers and
red knots exhibit a high degree of fidelity to wintering areas, it is expected that birds in the vicinity
of the Project site would be permanently displaced to nearby areas of suitable habitat. High quality
wintering habitat occurs nearby within the Laguna Atascosa NWR and Designated Critical Habitat
Unit TX-1.
As discussed for northern aplomado falcons, noise levels during construction and operation
of the Project are not expected to reach a level where birds would demonstrate startle effects.
However, high-noise events may cause birds to engage in avoidance behavior, flush or and spend
less time engaged in necessary activities like feeding, preening, and caring for their young
(NoiseQuest 2015). Construction and operation activities would increase noise levels in the
Project area. These noise impacts, especially impulsive noise such as pile driving, would affect
use by piping plovers and red knots. However, noise effects are anticipated to be temporary, and
once the Project begins operation noise levels would be reduced and piping plovers are expected
to return to the area.
As discussed previously, lighting associated with the Project could cause birds to be
disoriented and collide with buildings or other structures at the Project site. In addition, birds
disoriented by lights can circle structures for extended periods of time, leading to exhaustion and
reduced fitness for migration which can lessen migration survival and decrease breeding season
productivity (FWS 2017). Piping plovers and red knots could be affected by light from the Project,
particularly if they are migrating through the area at night or roosting in habitats in or adjacent to
the Project site. As previously indicated, Annova has stated it would evaluate lighting schemes to
reduce effects of light on remaining habitats and minimize lighting on the access road to that
required to address safety concerns. Also, whenever possible, lights would be placed so they do
not shine directly towards adjacent undisturbed habitats or the beach, and lighting would be
extinguished upon completion of work in an area. As discucessed previously, injuries or mortality
from flaring have been documented.
Direct mortality from collisions with vehicles or construction equipment may occur.
Vehicles would generally be restricted to the access road and roads within the Project site,
minimizing the potential for collisions or creating ruts in suitable bird habitat. However, ruts could
be created along the BSC beach during construction activities and piping plovers or red knots using
ruts to rest would be susceptible to vehicle and/or equipment collisions during construction.
Driving is currently allowed in many areas in the Project vicinity on existing access roads and
paths, along shorelines, and on mudflats.

As discussed for the northern aplomado falcon, Annova anticipates that the use of gas flares
would only occur intermittently. These types of collisions would increase the rates of stress, injury,
and mortality experienced by birds. Although this occasional flaring could impact piping plovers
and red knots if present during the flaring event, we conclude that occasional flaring during
operation would not substantially impact bird populations.
To address concerns regarding piping plovers and red knots, immediately prior to, during,
and immediately following construction, Annova would have qualified biologists conduct surveys
and monitoring for piping plovers and red knots in and immediately adjacent to the Project site
during the months when overwintering piping plovers and red knots are expected to occur in Texas
(i.e., from approximately July through May).
Although suitable piping plover and red knot habitat would be permanently affected as a
result of the Project, only one acre of habitat would be removed, and there is abundant high-quality
wintering habitat in the vicinity of the Project site within the Laguna Atascosa NWR and
Designated Critical Habitat Unit TX-1. Therefore, we have determined that constructing and
operating the Project may affect, but is not likely to adversely affect the piping plover and red knot.
As noted above, the Project has been designed to avoid impacts on the wind-tidal flats and
designated critical habitat located on the east side of the Project site. Therefore, we have
determined that constructing and operating the Project would not significantly destroy or adversely
modify piping plover critical habitat.
Red-crowned Parrot
The red-crowned parrot (Amazona viridigenalis) is a candidate for federal listing under the
ESA. The parrot is green with a striking red forehead. It has a blue post-ocular stripe that extends
down the sides of its neck, a red speculum, and dark blue primaries. The outer-tail feathers have
yellow tips. Females and immature parrots have less red on the crown. Red-crowned parrots are
nonmigratory, but are apparently nomadic during the winter (nonbreeding) season when large
flocks range widely to forage.
The red-crowned parrot is endemic to northeastern Mexico. Several introduced

populations occur in urban areas of the United States, including the Lower Rio Grande Valley.
However, evidence suggests populations in the Lower Rio Grande Valley consist, at least partly,
of naturally occurring populations. The red-crowned parrot generally occurs in lush areas in arid
lowlands and foothills, particularly tropical deciduous forest, gallery forests, evergreen floodplain
forest, Tamaulipan thornscrub, and semi-open areas. In the Lower Rio Grande Valley, red-
crowned parrots occur primarily in urban areas. Although little information on urban habitat use
specific to the Lower Rio Grande Valley is available, in cities where the species is introduced, red-
crowned parrots reportedly prefer areas with large trees such as palms that provide both food and
nesting sites (76[194] FR 62016-62034).
The red-crowned parrot usually forages in the crowns of trees, but will occasionally feed
on low-lying bushes (76[194] FR 62016-62034). Foraging appears to be opportunistic and its diet
includes a variety of seeds and fruits, and also buds and flowers. Red-crowned parrots nest in pre-
existing tree cavities, including those created by other birds and those resulting from tree decay.
Nesting occurs between March and August, and clutch size ranges from two to five eggs.

Impacts and Mitigation: Red-crowned Parrot

There are no documented occurrences of red-crowned parrots within the Project site
(TPWD 2015b); however, there are numerous recorded sightings in the vicinity of the Project. The
closest documented recent sighting occurred approximately 2.3 miles west of the Project site near
San Martin Lake, north of the BSC (eBird 2015). The Project site does not contain tropical
deciduous forests and palm habitats that the parrot usually prefers. However, due to the foraging
habits of the red-crowned parrot, this species may occasionally occur within the thornscrub or
semi-open areas within Project site, although no suitable nesting habitat is present. If red-crowned
parrots are present at the Project site, they would likely relocate to nearby suitable habitat;
therefore, we have concluded that constructing and operating the Project would not contribute to
a trend toward federal listing of the red-crowned parrot.
Whooping Crane
The federally endangered whooping crane has three wild populations, including the
Aransas-Wood Buffalo National Park population, which is the only remaining self-sustaining wild
population. This population breeds at and near the Wood Buffalo National Park in Canada and
winters in coastal marshes at the Aransas NWR near Rockport, Texas (FWS 2018a). Migrations
to the Aransas NWR begin in mid-September, arriving around November, and leave the NWR in
late March or early April. Wintering habitat includes estuarine marshes, shallow bays, and tidal
flats. Whooping cranes may also spend time feeding in croplands during migration. Whooping
Cranes eat invertebrates, small vertebrates, and plant material found in shallow water. The biggest
threats to the species are power lines, illegal hunting, and habitat loss (TPWD 2018).
The Aransas NWR, more than 80 miles northeast of the proposed Project, is the closest
area of whooping crane critical habitat. Although the species is generally noted as potentially
occurring only in counties north of the Project site, FWS staff have observed (multi-year sightings)
this species near the proposed Rio Grande LNG Terminal site, located directly northeast of the
Annova Project site, indicating a potential expansion of the species’ range (FWS 2016b).
Habitat within the Project area that may provide suitable wintering habitat for whooping
cranes include Coastal Salt and Brackish High Tidal Marsh, Coastal Tidal Flat/Washover, South
Texas Wind Tidal Flats, Coastal Salty Flat/Depression, Salt and Brackish Wetland, and South
Texas Saline Grassland. 11
Impacts and Mitigation: Whooping Crane

If whooping cranes were present, the birds would be temporarily displaced to nearby
habitat. Operation of the Project would result in the permanent conversion of potentially suitable
habitat to developed land that whooping cranes would likely avoid in favor of quieter, undisturbed
habitat in the adjacent lands. An estimated 51 acres of suitable whooping crane habitat would be
permanently removed by the Project.
Although suitable wintering whooping crane habitat would be permanently affected by the
Project, there is abundant high-quality habitat in the vicinity of the Project site. Therefore, we
11
Coastal Salt and Brackish High Tidal Marsh occurs in the Project area, but would not be affected by the Project.

have determined that constructing and operating the Project may affect, but is not likely to
adversely affect the whooping crane.
Eastern Black Rail

The eastern black rail (Laterallus jamaicensis jamaicensis) is proposed for listing as
threatened under the ESA. No critical habitat is proposed. The eastern black rail is a small, marsh
bird that is one of four subspecies of black rail, and is broadly distributed, living in salt and
freshwater marshes in portions of the U.S., Central America, and South America. Partially
migratory, the eastern subspecies winters in the southern part of its breeding range (FWS 2018b).
Along portions of the Gulf Coast, eastern black rails can be found in higher elevation wetland
zones with some shrubby vegetation. Impounded and unimpounded intermediate marshes
(marshes closer to high elevation areas) also provide habitat. Inland coastal prairies and associated
wetlands may also provide habitat for the bird but are largely uninvestigated.
There is less information for eastern black rail habitat in the winter range, but wintering
habitat is presumably similar to breeding habitat since some sites in the southern portion of the
breeding range are occupied year-round. Little is known about eastern black rails during
migration, including migratory stopover habitat, but individuals seem to appear more frequently
in wet prairies, wet meadows, or hay fields during migration than during the breeding and
wintering seasons (FWS 2018b).
Numerous conservation challenges exist for the eastern black rail, including alteration of
habitat by fire suppression, invasive species, sea-level rise, and human modifications. Changing
temperatures also have affected the natural hydrology of wetlands and have contributed to
mangrove encroachment into salt marsh habitat.
The eastern black rail is known to occur in coastal Cameron County which is considered
year-round habitat for the species, and it is considered to potentially occur within interior portions
of Cameron County (FWS 2018b). Habitat in the Project area that may support eastern black rails
year-round include Coastal Salt and Brackish High Tidal Marsh. There are no documented
occurrences of eastern black rails within the Project site, however, the Project site includes suitable
habitat for eastern black rails.
Impacts and Mitigation: Eastern Black Rail

Approximately 50.8 acres of suitable eastern black rail habitat would be permanently
removed as a result of the Project, with another 2.2 acres temporarily affected. Human disturbance
during construction and operation could also cause eastern black rail in immediately adjacent areas
to be flushed from the area and displaced. As discussed for northern aplomado falcons, noise
levels during construction and operation of the Project are not expected to reach a level where
birds would demonstrate startle effects. However, high-noise events may cause birds to engage in
escape or avoidance behavior, flush or expend energy that may affect survival or growth, or spend
less time engaged in necessary activities like feeding, preening, and caring for their young
(NoiseQuest 2015). These noise impacts, especially impulsive noise such as pile driving, would
affect use by eastern black rails; however, this effect is anticipated to be temporary lasting only
during active construction, and once the Project begins operation noise levels would be reduced.

As discussed previously, lighting associated with the Project could cause birds to be
disoriented and collide with buildings or other structures at the Project site. In addition, birds
disoriented by lights can circle structures for extended periods of time, leading to exhaustion and
reduced fitness for migration which can lessen migration survival and decrease breeding season
productivity (FWS 2017). Eastern black rails could be affected by light from the Project,
particularly if migrating through the area at night or roosting in habitats in or adjacent to the Project
site. As previously indicated, Annova has proposed measures to reduce nuisance lighting and has
stated it would evaluate lighting schemes to reduce effects of light on adjacent undisturbed habitats
and minimize lighting on the access road to that required to address safety concerns. As discussed
previously, injuries or mortality from flaring have been documented.
Direct mortality from collisions with vehicles or construction equipment may occur;
however, the potential for collisions with vehicles and equipment is expected to be low for eastern
black rails. Vehicles would generally be restricted to the access road and roads within the Project
site, minimizing the potential for collisions. There is also potential that eastern black rails could
collide with the flare stack structures or the flares. As discussed for the northern aplomado falcon,
Annova anticipates that the use of gas flares would only occur intermittently. These types of
collisions would increase the rates of stress, injury, and mortality experienced by birds. Although
this occasional flaring could impact eastern black rail if present during the flaring event, we find
that occasional flaring during operation would not substantially impact bird populations.
Although suitable eastern black rail habitat would be permanently affected as a result of
the Project, based on National Wetlands Inventory mapping there is abundant undisturbed
estuarine emergent marsh habitat in the vicinity of the Project site. Therefore, we have determined
that constructing and operating the Project would result in no effect on this species.
4.7.1.4 Sea Turtles

Sea turtles are long-lived reptiles that occur throughout the world’s tropical, subtropical,
and temperate seas. Five species of sea turtles are known to occur in the vicinity of the Project
and are listed as threatened or endangered under the ESA. Although distribution, habitat
utilization, and behavior vary among species, there are similarities among these five species of sea
turtles. Females generally return to their natal beaches to nest. Hatchlings immediately enter the
ocean, where they spend up to several years near the surface in the open ocean. After this phase,
most sea turtles occupy shallow marine environments, including coral reefs and coastal areas rich
in prey, although some may remain in the open sea environment or move between the two habitats.
Common threats to sea turtles include poaching, entanglement in fishing gear, and degradation of
nesting beaches and coastal foraging habitat.
Green Sea Turtle

The green sea turtle inhabits shallow waters with an abundance of marine algae and
seagrasses. It is most common in lagoons, bays, inlets, shoals, and estuaries, but also occurs on
coral reefs and rocky outcrops near feeding areas. The green turtle eats marine plants, mollusks,
sponges, crustaceans, and jellyfish (NOAA Fisheries 2016b).
The north Atlantic distinct population segment (DPS) of the green sea turtle, which
includes individuals in the Gulf of Mexico, is listed as federally threatened. Small numbers of

green sea turtles occur in Matagorda Bay, Aransas Bay, and the lower Laguna Madre. The
southern coast of Texas provides year-round foraging areas for juvenile and sub-adult green sea
turtles (Anderson et al. 2013). The abundance of foraging green sea turtles on the Texas coast has
been increasing since 1991 (Metz and Landrey 2013). This species may occur in the BSC year-
round, particularly as a transit corridor between seagrass beds and other foraging sites. The green
sea turtle is known to nest on the coast of the southeastern United States, but not along the Gulf of
Mexico near the Project site.
Kemp’s Ridley Sea Turtle

The Kemp’s ridley is the smallest and most endangered sea turtle (NOAA Fisheries et al.
2011). The Kemp’s ridley has one of the smallest ranges of all marine turtles, occurring primarily
in the coastal waters of the Gulf of Mexico, from the Yucatán peninsula to South Florida. Its
distribution is most concentrated in the Gulf of Mexico, with year-round occurrence throughout
the Gulf and southern Atlantic coasts of Florida, and seasonal occurrence along the Atlantic coast
as far north as Nova Scotia, Canada (NOAA Fisheries and FWS 2015). This turtle occurs in warm-
temperate to subtropical sounds, bays, estuaries, tidal passes, shipping channels, and beachfront
waters where it forages on blue crab and other invertebrate prey (Seney and Musick 2005).
Nearshore waters off Louisiana and Texas provide foraging habitat for juveniles of this species
(Landry et al. 2005); adult females have also been observed in the northwestern Gulf of Mexico
during internesting periods (Seney and Landry 2011). The Kemp’s ridley turtle is expected to
enter the BSC and vicinity to forage on blue crabs and other typical prey (NOAA Fisheries 2015e,
2004; COE 2003). The primary nesting beaches for the Kemp’s ridley turtle are in Mexico;
however, several beaches in Texas, Alabama, and Florida have reported small numbers of Kemp’s
ridleys (fewer than 10 nests per year), with Padre Island National Seashore supporting the largest
U.S. nesting aggregation (NOAA Fisheries et al. 2011).
Loggerhead Sea Turtle

The loggerhead sea turtle is reported in bays, estuaries, and lagoons and on continental
shelves in temperate, subtropical, and tropical waters. The Northwest Atlantic Ocean DPS of the
loggerhead sea turtle, which includes the GOM, is listed as threatened under the ESA. The greatest
threats to the loggerhead are coastal development, commercial fisheries, and pollution.
Female loggerhead sea turtles nest on open, sandy beaches above the high tide mark and
seaward of well-developed dunes, predominantly on steeply sloped beaches with gradually sloped
offshore approaches. Most Atlantic nesting sites are on the east coast of Florida; some nests are
reported in Georgia, the Carolinas, and on the Gulf Coast of Florida (NOAA Fisheries 2016c; COE
2003). Nesting occurs throughout the summer. Loggerhead hatchlings enter the sea and often
associate with floating Sargassum for three to five years. Subadults are more common in near-shore
and estuarine habitats, while adults are distributed among diverse habitats both near and offshore.
Young loggerheads forage on gastropods, crustaceans, and Sargassum. Adults feed on benthic
organisms but also take jellyfish from surface waters.
The loggerhead is the most abundant sea turtle in Texas waters, especially in shallow, inner
continental shelf waters. It is present in Texas year-round, but is reported most frequently during
the spring when Portuguese man-of-war jellyfish are abundant (COE 2003). Most loggerhead
sightings in the northern Gulf of Mexico are near jettied passes and in open water.

Loggerhead Sea Turtle Critical Habitat

On July 10, 2014, NOAA Fisheries designated 38 occupied marine areas within the range
of the Northwest Atlantic Ocean DPS of loggerhead sea turtles as critical habitat (NOAA Fisheries
2014; 79 FR 39857‐39912).
The physical or biological feature of loggerhead Sargassum habitat is described as

developmental and foraging habitat for young loggerheads where surface waters form
accumulations of floating material, especially Sargassum. The following primary constituent
elements support this habitat:
1. convergence zones, surface‐water downwelling areas, the margins of major

boundary currents (Gulf Stream), and other locations where there are concentrated
components of the Sargassum community in water temperatures suitable for the
optimal growth of Sargassum and inhabitance of loggerheads;
2. Sargassum in concentrations that support adequate prey abundance and cover;
3. available prey and other material associated with Sargassum habitat including, but
not limited to, plants and cyanobacteria and animals native to the Sargassum
community such as hydroids and copepods; and
4. Sufficient water depth and proximity to available currents to ensure offshore
transport (out of the surf zone), and foraging and cover requirements by Sargassum
for post‐hatchling loggerheads, i.e., >30 feet in depth.
No loggerhead critical habitat occurs in the Project area, but LNG carriers are likely to
transit through Sargassum that is designated as critical habitat in offshore Gulf of Mexico waters.
Atlantic Hawksbill Sea Turtle

The hawksbill sea turtle occurs on coastal reefs and in bays, rocky areas, estuaries, and
lagoons at depths up to 70 feet. Hatchlings are often associated with masses of floating marine
algae while juveniles, subadults, and adults are more common on coral reefs. Typical prey items
include sponges, mollusks, sea urchins, seagrasses, and algae. Adults in the Atlantic/Gulf of
Mexico population transition to foraging almost exclusively on sponges as they mature. All
populations of the hawksbill sea turtle are listed as endangered.
Female hawksbills come ashore to nest on undisturbed, deep sand beaches. Preferred
beaches may range from high-energy to small pocket beaches bounded by crevices of cliff walls
with woody vegetation near the waterline (NOAA Fisheries 2016d; COE 2003). The Atlantic
population nests along the Yucatan Peninsula, the U.S. Virgin Islands, Puerto Rico, and the Florida
Keys. Post-hatchlings and juveniles are reported in Texas and Florida, primarily in areas with
stone jetties and other hard surfaces where sponges are attached (NOAA Fisheries 2016d).
Leatherback Sea Turtle

The leatherback sea turtle spends most its life in pelagic waters and undergoes extensive
migrations across entire ocean basins; however, individuals may enter coastal waters to forage and
reproduce. Although the leatherback populations in the Caribbean and Atlantic Ocean (including

the Gulf of Mexico) are generally stable or increasing, this species is listed as endangered
throughout its range (NOAA Fisheries 2016e).
In the southeastern United States, the leatherback nests on beaches on the Florida Atlantic
coast, the U.S. Virgin Islands, and in Puerto Rico (FWS 2012e). It prefers sandy beaches with a
deepwater approach for nesting (NOAA Fisheries 2016e; COE 2003). Although the leatherback
sea turtle has been reported in Corpus Christi Bay, this species is rare along the Texas coast. No
nests have been recorded in Texas in more than 60 years (NOAA Fisheries 2016e; COE 2003).
Impacts and Mitigation: Sea Turtles

No adult or hatchling sea turtles are likely to occur in the onshore portion of the Project
site because beaches in the vicinity are not suitable for nesting. Juvenile, sub-adult, and adult
loggerhead, green, hawksbill, and Kemp’s ridley sea turtles are likely to occur in the BSC and
vicinity. Leatherback sea turtles are less likely to occur in the Project area.
Vessel Strikes
Increased vessel traffic within the BSC and Gulf of Mexico would increase the potential
for turtle strikes. Sea turtles are vulnerable to vessel strikes while traveling, foraging, and resting
on or near the water surface. A sea turtle could be injured or killed by a direct collision with a
vessel (NOAA Fisheries and FWS 2013a, b; 2015).
LNG carriers operating within the U.S. EEZ in the Gulf of Mexico are generally slower
and generate more noise than typical large vessels, and would therefore be more readily avoided
by sea turtles. Sea turtles typically move away from vessels approaching at slower speeds (up to
2.2 knots), but avoidance behavior decreases as vessel speed increases (Hazel et al. 2007). To help
reduce the risk of strikes or other potential disturbances associated with the presence of LNG
carriers, Annova would adopt the NOAA Fisheries Vessel Strike Avoidance Measures and
Reporting for Mariners (revised February 2008). However, Annova cannot ensure that all vessels
calling at the facility adhere to the vessel speed limits. Of the 355 sea turtles reported by the Sea
Turtle Stranding and Salvage Network (STSSN) in the statistical zone covering the Project area,
approximately 16 were identified as potentially being struck by vessels; all of the potential strike
victims were green sea turtles. Recognizing that the STSSN provides the most comprehensive
data on sea turtle injuries in the Gulf of Mexico, precise numbers of injuries cannot be estimated.
Uncertainties in the numbers arise from loss of sea turtles that sank to the bottom after injury, those
that were struck in one zone and stranded in another zone, and those too decomposed for cause of
death to be determined. Because sea turtles may not be able to avoid being struck by a vessel
travelling faster than 2.2 knots, vessel strikes may occur. However, Annova anticipates up to 125
LNG carriers per year would visit the terminal, representing a discountable addition to the already
high volume of commercial and recreational vessel traffic in the BSC and Gulf of Mexico transit
corridor.
Acoustic Stressors: Vessels and Pile Driving

Construction-related noise including vessel noise and pile driving, could adversely affect
sea turtles. Cues preceding the commencement of the noise event (such as vessel presence and
movement) may result in some sea turtles departing the immediate area even before active sound
sources begin transmitting.

The duration and frequency of LNG carrier movement in the Project area would be so low
as to represent an insignificant effect of vessel noise on sea turtles. Noise from LNG carriers is
not expected to cause behavioral responses to sea turtles. The NOAA Fisheries has indicated that
sea turtles and other protected animals experience vessel activity from the time they are young and
although it is not known if they become habituated to the noise, individuals are able to function
somewhat normally when exposed to vessel noise (NOAA Fisheries 2013). Disturbances from
vessel noise would be short term and similar to the existing baseline noise levels in the marine
environment. Pile-driving noise sources vary by type of pile (steel, wood, or concrete) and type
of driving (impulse or vibratory) (see section 2.6 for a description of the proposed pile driving).
Pile driving would create an impulsive source (pulsed noises) audible both within and above the
water. Standard ESA protections would be in place, including having observers check for animals
in the immediate vicinity and pausing activities until the animals leave the area. Disturbances from
pile driving would be short term (approximately five days) and localized.
Sedimentation
Dredging may adversely affect water quality during construction of the marine facilities.
Dredging activities could temporarily disrupt potential foraging grounds for turtles. Dredging
effects would be temporary and local in nature because dredging would be confined to the
proposed turning basin, access channel, and marine berth. Disposal of the dredged material would
cause a local, temporary increase in turbidity, but effects on sea turtles would be discountable.
The green, Kemp’s ridley, loggerhead, and Atlantic hawksbill sea turtle are likely to occur
in the vicinity of the Project (particularly in the transit path of LNG carriers). Although these
individual sea turtles species are likely to enter the BSC and could be exposed to stressors
associated with construction and operation of the Project, the use of mechanical and hydraulic
dredges are expected to minimize adverse effects on sea turtles and not result in any take of
protected species (Hanson et al. 2004; GMFMC 2010). The leatherback sea turtle is so uncommon
in the northern Gulf of Mexico that effects to it are discountable. Therefore, we have determined
that constructing and operating the Project may affect but is not likely to adversely affect any sea
turtle species listed in table 4.7.1-1.
Determination of Effect on Loggerhead Sea Turtle Critical Habitat

LNG carriers transiting to and from the Project may pass through and disrupt the
Sargassum. However, this traffic is not anticipated to scatter Sargassum mats to the point of
affecting the functionality of the loggerhead critical habitat primary constituent elements.
Therefore, we have determined that constructing and operating the Project would not significantly
destroy or adversely modify loggerhead sea turtle critical habitat.
4.7.1.5 Plants
Two federally listed endangered plant species, South Texas ambrosia (Ambrosia
cheiranthifolia) and Texas ayenia (Ayenia limitaris), have the potential to occur within the Project
area. However, there are no documented occurrences of South Texas ambrosia within the Project
site or within Cameron County (TPWD 2015b), and the closest known population of Texas ayenia
is located approximately 30 miles to the northwest of the Project site (FWS 2010a; TPWD 2015b).
Although suitable habitat for both of these species is present within the Project site, neither of these
species were observed during presence/absence surveys conducted within the Project site in 2015.

Because listed plant species were not observed within the Project site and are not expected to occur
in the area affected by the Project, we have determined that constructing and operating the Project
would have no effect on federally listed plant species.
4.7.2 State-Listed Threatened and Endangered Species

The TPWD has designated protected species under state law and prohibits the take,
possession, transportation, or sale of any of the animal species designated by state law as
endangered or threatened without the issuance of a permit. Texas laws and regulations prohibit
commerce in threatened and endangered plants and the collection of listed plant species from
public land without a permit issued by the TPWD. Listing and recovery of endangered species in
Texas is coordinated by the TPWD Wildlife Division.
The TPWD database indicates that 54 state-listed species occur in Cameron County (table
4.7.2-1; TPWD 2016f). Of these, 12 species are also federally protected and were addressed above.
The smalltooth sawfish is not discussed because no suitable habitat occurs in the Project area.
Potentially suitable habitat is present in the Project area for 45 of the state-listed species.
TABLE 4.7.2-1
State-Protected Species and Habitat Potentially Occurring Within the Project Area
State
Species Status Habitat Description Potential for Occurrence a/ Project Component
Mammals
West Indian manatee E b/ Gulf and bay system near aquatic Suitable habitat is present Marine facilities
(Trichechus manatus) vegetation. within the Project site.
Coue’s rice rat (Oryzomys T Cattail-bulrush marsh with a shallower Suitable habitat is present LNG facilities
couesi) zone of aquatic grasses near the within the Project site. access road
shoreline. Shade trees around the
shoreline are important features. Found
in both saltwater and freshwater and
grassy areas near water.
Jaguar (Panthera onca) E Dense chaparral. Suitable habitat is not none
present within the Project
site.
Jaguarundi (Herpailurus E b/ Thick brushlands near water. FWS and TWPD reported LNG facilities
yagouaroundi) this species may occur access road
within the Project vicinity.
Ocelot (Leopardus pardalis) E b/ Dense chaparral thickets; mesquite-thorn FWS and TWPD reported LNG facilities
scrub and live oak mottes; often avoids this species may occur access road
open loma areas. within the Project vicinity.
Southern yellow bat T Associated with trees such as palm Suitable habitat is present LNG facilities
(Lasiurus ega) trees, which provide the species with within the Project site. access road
daytime roosts.
White-nosed coati (Nasua T Woodlands, riparian corridors, and Suitable habitat is present LNG facilities
narica) canyons. within the Project site. access road
Birds
Northern aplomado falcon E b/ Palm and oak savannahs, various desert Suitable habitat is present LNG facilities
(Falco femoralis grassland associations, and open pine within the Project site. access road
septentrionalis) woodlands with open terrain and low
ground cover.
Piping plover T b/ Coastal beaches, sandflats, barrier Suitable habitat is present LNG facilities
(Charadrius melodus) islands, gently sloped foredunes, within the Project site. Marine facilities
sparsely vegetated dunes, and washover
areas cut into or between dunes.

State
Zone-tailed hawk (Buteo T Arid open country, including open Suitable habitat is present LNG facilities
albonotatus) deciduous or pine-oak woodland, mesa within the Project site. access road
or mountain country, often near
watercourses and wooded canyons
and tree-lined rivers along middle-
slopes of desert mountains.
Texas Botteri's sparrow T Grassland and short-grass plains with Suitable habitat is present LNG facilities
(Peucaea botterii texana) scattered bushes or shrubs, sagebrush, within the Project site. access road
mesquite, or yucca; nests on ground
with low grass clumps.
White-tailed hawk T Near the coast on prairies, cordgrass Suitable habitat is present LNG facilities
(Buteo albicaudatus) flats, and scrub-live oak; further inland within the Project site. access road
on prairies, mesquite and oak
savannas, and mixed savanna-
chaparral.
Gray hawk T Mature riparian woodlands and nearby Suitable habitat is present LNG facilities
(Buteo nitidus) semi-arid mesquite and scrub within the Project site. access road
grasslands; breeding range formerly
extended north to southernmost Rio
Grande floodplain of Texas.
Northern beardless- T Mesquite woodlands; near Rio Grande, Suitable habitat is present LNG facilities
tyrannulet frequents cottonwood, willow, elm, and within the Project site. access road
(Camptostoma imberbe) great leadtree.
Reddish egret T Brackish marshes and shallow salt Suitable habitat is present LNG facilities
(Egretta rufescens) ponds and tidal flats; nests on ground or within the Project site. access road
in trees or bushes, on dry coastal islands Marine facilities
in brushy thickets of yucca and prickly
pear.
Cactus ferruginous pygmy- T Riparian trees, brush, palm, and Suitable habitat is present LNG facilities
owl (Glaucidium brasilianum mesquite thickets; also roosts in small within the Project site. access road
cactorum) caves during the day and recesses on
slopes of low hills.
Rose-throated becard T Riparian trees, woodlands, open forest, Suitable habitat is present LNG facilities
(Pachyramphus aglaiae) scrub, and mangroves. within the Project site. access road
Marine facilities
Tropical parula T Live-oak woodlands with high densities Suitable habitat is present LNG facilities
(Setophaga pitiayumi) of epiphytes; mixed deciduous riparian within the Project site. access road
forests adjacent to Rio Grande.
White-faced ibis T Mainly shallow marshes with emergent Suitable habitat is present LNG facilities
(Plegadis chihi) vegetation, flooded shoals and within the Project site. access road
mangrove swamps, mudflats, and along Marine facilities
rivers, lakes, and reservoirs.
Common black-hawk T Cottonwood-lined rivers and streams; Suitable habitat is present LNG facilities
(Buteogallus anthracinus) willow tree groves in lower Rio Grande within the Project site. access road
floodplains; formerly bred in south Marine facilities
Texas.
Eskimo curlew (Numenius E Grasslands, pastures, plowed fields, and Suitable habitat is present LNG facilities
borealis) occasionally marshes and mudflats. within the Project site. access road
Marine facilities
American peregrine falcon T Nests in tall cliff eyries; sometimes found Suitable habitat is present LNG facilities
(Falco peregrinus anatum) in urban areas along coastal and barrier within the Project site. access road
islands; sometimes make stopovers at Marine facilities
edges of lake shores, coastlines, and
barrier islands.
Peregrine falcon (Falco T Most often found in open areas and cliffs Suitable habitat is present LNG facilities
peregrinus) and almost always near water. within the Project site. access road
Marine facilities

State
Sooty tern (Sterna fuscata) T Generally found above flood tides and Suitable habitat is present LNG facilities
flat, sparsely vegetated, and fairly open within the Project site. access road
habitats but will nest under vegetation or Marine facilities
shrubs if aerial predation pressure exists.
Wood stork (Mycteria T Forages in prairie ponds, flooded Suitable habitat is present LNG facilities
americana) pastures or fields, ditches, and other within the Project site. access road
shallow standing water, including salt- Marine facilities
water. Usually roosts communally in tall
snags, sometimes in association with
other wading birds (e.g., active
heronries). Breeds in Mexico and birds
move into Gulf States in search of mud
flats and other wetlands, even those
associated with forested areas.
Formerly nested in Texas, but no
breeding records since 1960.
Reptiles
Atlantic hawksbill sea turtle E b/ Gulf and bay systems, warm shallow Yes – TPWD confirmed sea Marine facilities
(Eretmochelys imbricata) waters in rocky marine environments turtles may occur within the
(such as coral reefs and jetties). vicinity of the Project site.
Green sea turtle (Chelonia T b/ Gulf and bay systems; shallow-water Yes – TPWD confirmed sea Marine facilities
mydas) seagrass beds; open water between turtles may occur within the
feeding and nesting areas; barrier island vicinity of the Project site.
beaches.
Kemp’s ridley sea turtle E b/ Gulf and bay systems; adults typically Yes – TPWD confirmed sea Marine facilities
(Lepidochelys kempii) found in shallow waters of the Gulf of turtles may occur within the
Mexico. vicinity of the Project site.
Leatherback sea turtle E b/ Gulf and bay system; this species has Yes – TPWD confirmed sea Marine facilities
(Dermochelys coriacea) the widest range of any open-water turtles may occur within the
reptile. vicinity of the Project site.
Loggerhead sea turtle T b/ Juveniles are typically in Gulf and bay Yes – TPWD confirmed sea Marine facilities
(Caretta caretta) systems; adults more pelagic. turtles may occur within the
vicinity of the Project site.
Black-striped snake T Found in extreme South Texas in semi- Yes – TPWD confirmed LNG facilities
(Coniophanes imperialis) arid coastal plains with warm, moist suitable habitat is present access road
micro-habitats and sandy soils. within the Project site.
Northern cat-eyed snake T Gulf Coastal Plain south of the Nueces Yes – TPWD confirmed LNG facilities
(Leptodeira septentrionalis River; thorn brush woodlands; dense suitable habitat is present access road
septentrionalis) thickets bordering ponds and streams; within the Project site. Marine facilities
semi-arboreal.
Speckled racer (Drymobius T Dense thickets near water; Texas palm Yes – TPWD confirmed LNG facilities
margaritiferus) groves, riparian woodlands; areas with a suitable habitat is present access road
lot of vegetation litter on the ground. within the Project site. Marine facilities
Texas horned lizard T Open, arid and semi-arid regions with Suitable habitat is present LNG facilities
(Phrynosoma cornutum) sparse vegetation, including grass, cacti, within the Project site. access road
scattered brush, and scrubby trees; soil
varies from sandy to rocky; hides under
rocks or burrows into soil and enters
rodent burrows.
Texas indigo snake T Thornbush-chaparral woodlands in south Yes – TPWD confirmed LNG facilities
(Drymarchon melanurus Texas, dense riparian corridors; suitable habitat is present access road
erebennus) suburban and irrigated croplands; rodent within the Project site.
burrows.
Texas scarlet snake T Mixed hardwood scrub on sandy soils. Suitable habitat is present LNG facilities
(Cemophora coccinea lineri) within the Project site. access road
Marine facilities

State
Texas tortoise (Gopherus T Open brush with a grass understory; Suitable habitat is present LNG facilities
berlandieri) open grass and bare ground are within the Project site. access road
avoided; when inactive, the species
occupies shallow depressions at the
bases of bushes or cacti, sometimes in
underground burrows or under objects.
Amphibians
Sheep frog (Hypopachus T Predominantly grassland and savanna; Yes – TPWD confirmed LNG facilities
variolosus) moist sites in arid areas. suitable habitat is present access road
within the Project site.
White-lipped frog T Grasslands, cultivated fields, roadside Yes – TPWD confirmed LNG facilities
(Leptodactylus fragilis) ditches, under rocks, or in burrows under suitable habitat is present access road
clumps of grass. within the Project site.
Black-spotted newt T Wet or sometimes wet areas (e.g., Yes – TPWD confirmed LNG facilities
(Notophthalmus arroyos, canals, ditches, or shallow suitable habitat is present access road
meridionalis) depressions). within the Project site.
South Texas siren (large T Wet or sometimes wet areas (e.g., Yes – TPWD confirmed LNG facilities
form Siren spp.) arroyos, canals, ditches, or shallow suitable habitat is present Access Road
depressions); requires some moisture. within the Project site.
Mexican treefrog T Subtropical region of extreme southern Yes – TPWD confirmed LNG facilities
(Smilisca baudinii) Texas. suitable habitat is present access road
within the Project site.
Fish
Rio Grande silvery minnow E Historically found in Rio Grande and Suitable habitat is not none
(Hybognathus amarus) Pecos River systems and canals; pools present within the Project
and backwaters of medium to large site.
streams with low or moderate gradients
in mud, sand, or gravel bottom.
Smalltooth sawfish (Pristis E b/ Young are found close to shore in Suitable habitat is not none
pectinata) muddy and sandy bottoms, sheltered present within the Project
bays, shallow banks, and in estuaries or site.
river mouths.
Mexican goby (Ctenogobius T Southern coastal area; brackish and Suitable habitat is present Marine facilities
claytonia) freshwater coastal streams. within the Project site.
River goby (Awaous T Prefers fresh, clear, flowing, oxygenated Suitable habitat is not none
banana) streams; occasionally taken in brackish present within the Project
turbid waters site.
Opossum pipefish T Brooding adults found in fresh or low- Suitable habitat is not none
(Microphis brachyurus) salinity waters; young move or are present within the Project
carried into more saline waters after site.
birth; southern coastal areas.
Mollusks
Salina mucket (Potamilus T Lotic waters; often submerged in soft Suitable habitat is not none
metnecktayi) sediments along river banks. present within the Project
site.
Texas hornshell (Popenaias T Both ends of narrow shallow runs over Suitable habitat is not none
popeii) bedrock in areas where small-grained present within the Project
materials collect in crevices, along river site.
banks, and at the base of boulders.
Mexican fawnsfoot mussel T Endemic to the central Rio Grande Suitable habitat is not none
(Truncilla cognate) drainage in Laredo, TX; habitat present within the Project
preferences are unknown site.

State
Plants
South Texas ambrosia E b/ Grasslands and mesquite-dominated Suitable habitat is present LNG facilities
(Ambrosia cheiranthifolia) shrublands on various soils ranging from within the Project site. access road
heavy clays to lighter textured sandy
loams; in modified unplowed sites like
railroads and highway rights-of-way,
cemeteries, mowed fields, and erosional
areas along small creeks.
Star cactus (Astrophytum E Gravelly clays or loams; on gentle slopes Suitable habitat is not none
asterias) and flats in sparsely vegetated openings present within the Project
between shrub thickets within mesquite site.
grasslands or mesquite-blackbrush thorn
shrublands.
Texas ayenia (Ayenia E b/ Subtropical thorn woodland or tall Suitable habitat is present LNG facilities
limitaris) shrubland on loamy soils of the Rio within the Project site. access road
Grande delta. Known site soils include
well-drained, calcareous, sandy clay
loam and neutral to moderately alkaline
fine sandy loam.
Sources: ICUN 2015; FWS 2015d; TPWD 2016f
a/ Based on discussion with TPWD, review of literature, and presence of suitable habitat.
b/ Also federally listed. See section 4.7.1 and table 4.7.1-1.
Key:
E = Texas state-listed as endangered
T = Texas state-listed as threatened
BGEPA = Bald and Golden Eagle Protection Act
4.7.2.1 Terrestrial Mammals

There are four state-only-listed terrestrial mammals listed in Cameron County (TPWD
2016f); the Coue’s rice rat (Oryzomys couesi), southern yellow bat (Lasiurus ega), white-nosed
coati (Nasua narica) and the jaguar. The jaguar (Panthera onca) is believed to be extirpated, and
suitable habitat for the jaguar is not present within the Project site; therefore, this species is not
discussed further. The remaining three state-listed terrestrial mammals have the potential to occur
in the Project area. The Coue’s rice rat prefers cattail-bulrush marshes and aquatic, grassy zones
near resacas. The southern yellow bat prefers habitat associated with trees such as palm trees,
which provide the species with daytime roosting sites. The white-nosed coati prefers woodlands,
riparian corridors, and canyons and is most likely a transient from Mexico. Based on these habitat
preferences, the potential for occurrence of these species is minimal (TPWD 2016f).
Constructing the Project would permanently remove potential habitat for terrestrial
mammals, causing resident wildlife to relocate; however, ample similar habitat is available in the
vicinity of the Project site. Also, to reduce impacts on wildlife habitat, Annova would implement
the applicable BMPs from the TPWD Wildlife Habitat Assessment Program, which includes the
TPWD Guidelines for Revegetation of Disturbed Landscapes (TPWD 2016d).
Short-term impacts, such as increased noise and activity and nighttime construction
lighting, could cause temporary displacement of state-protected species, and long-term effects
would result from permanent habitat removal. Noise and vibration from construction activities

would be minimized by ensuring that all construction equipment have mufflers that meet current
noise regulations. Annova would minimize the effects of lighting by implementing lighting
schemes that minimize effects of light on surrounding habitats as well as minimize lighting on the
access road to the extent feasible.
Based on the implementation of Annova’s proposed design plans and avoidance,

minimization, and mitigation measures, potential impacts on Coue’s rice rat, southern yellow bat,
and white-nosed coati are expected to be minor.
4.7.2.2 Birds
Eighteen state-listed threatened or endangered bird species have the potential to occur in
the Project area (table 4.7.2-1).
Constructing and operating the Project would impact habitat that may be used by state-
protected bird species. State listed bird species may use the Project site for foraging or roosting
and could be displaced from the Project site, likely relocating to a location nearby with available
suitable habitat. In addition, birds may fly over the Project site during migratory flights. Seven
of the state- listed bird species have potential to nest at the site, including the northern aplomado
falcon, white-tailed hawk, reddish egret, tropical parula, Texas botteri’s sparrow, cactus
ferruginous pygmy-owl, and sooty tern.
Vegetation temporarily affected would be allowed to revert to pre-existing conditions or

the areas would be planted with native grasses. Those bird species that nest within the Project site
would be affected by the permanent removal of habitat and would be temporarily impacted by
increased noise levels and activity. Construction would be scheduled to avoid the nesting season
of protected species (approximately March-September), where possible. If construction during
nesting seasons cannot be avoided, Annova would follow the TPWD and FWS recommendation
to have a biologist trained to identify the species potentially affected available to survey the areas
for construction to identify and avoid nests. Based on these species characteristics and the potential
impacts on them, we conclude that these impacts would be minor.
4.7.2.3 Reptiles and Amphibians

Twelve state-listed reptiles and five state-listed amphibians have potential to occur in the
Project area (table 4.7.2-1).
Terrestrial and Freshwater Reptiles

Suitable habitat for seven state-listed threatened terrestrial and freshwater reptile species
occurs in the Project area. The Texas horned lizard (Phrynosoma cornutum), Texas indigo snake
(Drymarchon melanurus erebennus), and Texas tortoise (Gopherus berlandieri) have been
observed on the Project site. During the late fall and winter, reptiles become less active or
completely inactive by hibernating a few inches underground or occupying burrows or similar
cavities. Many reptiles, including the state-listed Texas horned lizard and Texas tortoise, and the
rare keeled earless lizard, become more active during the spring mating season (TPWD 2015b).
According to the TPWD, lomas in the Project area provide suitable habitat for the Texas
tortoise. The TPWD believes that the lomas located within the Project site are large enough to

support significant Texas tortoise populations. The TPWD recommends reviewing information
regarding appropriate surveying methodology for estimating tortoise populations and having a
biological monitor onsite during ground disturbing activities.
The northern cat-eyed snake (Leptodeira septentrionalis septentrionalis), black-striped

snake (Coniophanes imperialis), and speckled racer (Drymobius margaritiferus) may occur in
thick plant litter or debris piles, especially near waterbodies. The Texas indigo snake is typically
found in riparian corridors or near waterbodies. However, due to its large size and metabolism,
the Texas indigo snake has a large home range in which it hunts for food and therefore may be
encountered in other types of habitats (TPWD 2015b).
Reptiles could be subject to direct impacts (i.e., crushing by heavy equipment, falling into
open excavations) during construction and potentially during operation. Annova has stated it
would comply with TPWD recommendations, including any excavations or trenches that must be
left unfilled at the end of the work day would either be covered, have escape ramps placed in them
(made from boards or soil), or fenced off with an exclusion fence. Any excavations or trenches
left open overnight would be inspected the following morning for wildlife; if any state-listed
species are trapped, they would be removed by personnel permitted by the TPWD to handle listed
species. The TPWD recommends that major ground-disturbing activities such as constructing new
access roads be conducted before October, when reptiles become inactive (October through
March) and could be utilizing burrows in areas subject to disturbance. In addition, the TPWD
recommends that Annova schedule construction activities involving clearing, grading, or
bulldozing to occur outside the spring mating season for state-listed reptiles including the Texas
horned lizard and Texas tortoise. We have included a recommendation below in section 4.7.3 that
Annova continue to consult with TPWD regarding implementation of these recommendations.
As described above, temporarily disturbed areas would be restored to pre-existing

conditions or planted with native grasses. Annova would also implement applicable BMPs from
the TPWD Wildlife Habitat Assessment Program (TPWD 2016d), which includes Texas tortoise
BMPs and guidelines for revegetation of disturbed landscapes. Avoidance and minimization
measures may include having a qualified biologist(s) on site to monitor clearing of vegetation and
filling of wetlands.
Through implementation of the measures described above, we conclude that impacts on

state listed terrestrial and freshwater reptiles would be minor.
Amphibians
Suitable habitat for five state-listed threatened species occurs in the Project area (table
4.7.2-1). Black-spotted newts (Notophthalmus meridionalis) and South Texas sirens (large form
Siren spp.) occur in temporary ponds, ditches, resacas, or streams. Freshwater ponds may also
provide potentially suitable habitat for newts and sirens. The Mexican treefrog (Smilisca baudinii),
sheep frog (Hypopachus variolosus), and white-lipped frog (Leptodactylus fragilis) are tropical
frog species found only in South Texas. The Mexican tree frog typically occurs near mouths of
rivers or in wooded areas near streams and resacas; they may also occur in suburban areas where
lawns are watered regularly and contain trees. The sheep frog may occur in tropical thorn scrub,
woodlands, and pastures with short grass. The white-lipped frog favors grassy areas next to ponds
and in ditches in agricultural areas. These species are nocturnal but will seek shelter in burrows

or under dead vegetation during the day. They all breed explosively following rainfall events
throughout the year. Ponded waterbodies on the Project site may provide suitable habitat for these
species (TPWD 2015b).
Through implementation of Project design and impact minimization measures, we

conclude that impacts on state listed amphibians would be minor.
4.7.2.4 Fish
Five fish species listed under the Texas ESA may occur in Cameron County. Suitable
habitat exists at the Project site for the Mexican goby (Ctenogobius claytonia), although this
species has not been documented in the BSC (Hendrickson and Cohen 2015). The Mexican goby
occurs in a restricted range from the BSC south to Mexico in estuarine and freshwater coastal
streams. No suitable habitat exists on the Project site for the other four state-listed fish species
(i.e., the river goby, Rio Grande silvery minnow, smalltooth sawfish, or opossum pipefish; see
table 4.7.2-1).
Through implementation of Annova’s proposed design plans and avoidance, minimization,

and mitigation measures, we conclude that impacts on the state listed Mexican goby fish would be
minor. The proposed Project would have no effect on the river goby, Rio Grande silvery minnow,
smalltooth sawfish, or opossum pipefish because no suitable habitat for these species exists at the
Project site.
4.7.2.5 Mollusks
No suitable habitat for any of the three state-listed mollusks found in Cameron County
exists at the Project site, according to TPWD (2016d). The Mexican fawnsfoot mussel occurs only
in a small portion of the Rio Grande near Laredo, Texas. The Salina mucket prefers the banks of
flowing rivers. The Texas hornshell occurs in shallow flowing runs over bedrock with small-
grained substrates. Annova’s proposed design plans would have no effect on state listed mollusks
because no suitable habitat for these species exists at the Project site.
4.7.2.6 Plants
Three plant species listed under the Texas ESA may occur in Cameron County. Two of
these species are also federally listed and described above in section 4.7.1.5 (South Texas ambrosia
and Texas ayenia), where we conclude the project would have no effect on these species. For the
third species (star cactus), suitable habitat is not present within the Project site. Therefore,
Annova’s proposed Project would have no effect on state listed plants.
4.7.2.7 Significant Natural Communities and Rare Species

In addition to state-protected species, TPWD tracks special features, natural communities,
species of concern (SOC), and species of greatest conservation need (SGCN) in the TXNDD, and
actively promotes their conservation. SOC and SGCN are also referred to as rare species by the
TPWD. Twenty-one plant species are considered SOC/SGCN in Cameron County and can be
found on the Annotated County List of Rare Species (TPWD 2016f). The majority of these plants
are found adjacent to lomas or other unique habitats found in extreme south Texas and, potentially,
on the Project site. However, none of these 21 plant species were observed during field surveys
of the Project site. A SOC/SGCN identified during consultation with the TPWD is the Texas

Ebony-Snake-eyes Series vegetation community, which occurs in the lower Rio Grande Valley
and is associated with lomas in the South Bay area. The Texas Ebony-Snake-eyes Shrubland
vegetation community does not occur within the Project site. A small area of black mangrove
shrubland (another SOC/SGCN) does occur along the southern shoreline of the BSC, northeaset
of the proposed marine berth area. This area of black mangrove was included in the initial Project
footprint contemplated by Annova; however, Annova modified its proposed site footprint so that
the area of mangrove is not within the area that would be directly affected by construction or
operation (see section 4.5).
Another example of a SOC/SGCN is the keeled earless lizard (Holbrookia propinqua),

which has the potential to occur within the Project site. This small lizard typically prefers loose,
sandy habitats and can be found on sand dunes and barrier beaches within its range (Conant and
Collins 1998). Along with most other reptiles, the keeled earless lizard becomes less active or
completely inactive, hibernating during the winter months 6 to 12 inches underground or
occupying burrows or similar small cavities. As discussed above, potential impacts on reptiles
would include direct impacts (i.e., crushing by heavy equipment, falling into open excavations)
during construction and potentially during operation. The avoidance and minimization measures
described in section 4.7.2.3 for reptiles would also benefit the keeled earless lizard and other
SOC/SGCN.
4.7.3 Conclusions and Recommendations

A variety of measures have been proposed by Annova that would minimize impacts on
federally and state-listed species including implementation of conservation measures, SPCC Plan,
and providing LNG carrier captains with a NOAA-issued guidance document that outlines
collision avoidance measures to be implemented in order to minimize impacts on marine mammals
and sea turtles. Annova has identified conservation measures intended to minimize Project
impacts on the ocelot and jaguarundi, and has also identified an off-site mitigation area intended
as mitigation for the loss of wetland habitat within the site, which would include habitat for some
federally listed species. However, because consultations with the FWS and NOAA Fisheries are
ongoing, we recommend that:
• Annova should not begin construction activities until:
a. the FERC staff receives comments from the FWS and NOAA Fisheries
regarding the proposed action;
b. the FERC staff completes Section 7 ESA consultation with the FWS
and NOAA Fisheries; and
c. Annova has received written notification from the Director of OEP that
construction or use of mitigation may begin.

4.8 LAND USE, RECREATION, AND VISUAL RESOURCES
4.8.1 Land Use
The Project site is primarily located on a 731-acre property adjacent to the BSC on land
owned by the BND. The property, located at approximate mile marker 8.2 on the BSC, has direct
access to the Gulf of Mexico via the Brazos Santiago Pass. The property would be obtained
through a long-term lease with the BND. The Project site is located in unincorporated Cameron
County in an unzoned area. Presently undeveloped, the Project site is designated for heavy industrial
development by the BND (BND 2014).
Affected land use cover was identified based on interpretation of recent aerial photographs
and United States Geological Survey (USGS) National Land Cover Database land cover data
layers. The Project site would affect six land use cover types, which are defined by the USGS as
follows:
• Estuarine Emergent Marsh Wetlands – Areas where perennial herbaceous

vegetation accounts for greater than 80 percent of vegetative cover and the soil or
substrate is periodically saturated with or covered by water.
• Grassland/Herbaceous – Areas dominated by graminoid or herbaceous vegetation,
generally greater than 80 percent of total vegetation.
• Shrub/Scrub – Areas dominated by shrubs less than 5 meters tall with shrub
canopy typically greater than 20 percent of total vegetation. This class includes
true shrubs, young trees in an early successional stage, and trees stunted due to
environmental conditions.
• Barren Land – Areas where vegetation generally accounts for less than 15 percent
of total cover. Barren areas within the Project area consist of tidal flats and
dredge disposal areas.
• Open Water – Areas of open water, generally with less than 25 percent cover of
vegetation or soil.
Construction and operation of the Project would primarily affect shrub/scrub and
grassland/herbaceous land cover types (table 4.8.1-1). There are no agricultural areas, specialty
crops, mines, quarries, landfills, known hazardous waste sites, or any other known special land
uses located on or in the vicinity of the Project site.
Land Use, Recreation, 4-96

and Visual Resources
TABLE 4.8.1-1
Land Cover Types Affected by Construction and Operation

Construction Impacts Operation Impacts
Land Cover Type (acres) a/ (acres) b/
Estuarine Emergent Wetlands 53 51
Tidal Flat 3 1
Grassland/Herbaceous 183 146
Shrub/Scrub 224 211
Barren 5 2
Open Water 23 1
Total c/,d/ 491 412
_______________________
a/ Construction impacts include all areas that would be disturbed during construction of the Project.
b/ Operation impacts consist of those areas that would be maintained during operation of the Project.
c/ Does not include 59 acres of open water within the BSC that would be affected by dredging for the turning basin.
d/ Does not include 704 acres of land within DMPA5A.
Annova has indicated that it anticipates all fill material would be excavated from a borrow
area within the Project site. Following construction, the borrow area would be stabilized and
restored to native, non-maintained Gulf Coast Salty Prairie land cover in accordance with the
TPWD’s Ecological Mapping System of Texas using seed mixes approved by the Natural
Resources Conservation Service. Land cover in this area that is not currently Gulf Coast Salty
Prairie would be permanently converted to Gulf Coast Salty Prairie. The boundary fence would
temporarily disturb the existing herbaceous land cover. After construction, the land along the
boundary fence and the area along the outer edge of the limit of disturbance would be stabilized
and allowed to revert to native salt prairie.
The remaining areas disturbed by the Project would either contain permanent facilities or
be permanently maintained as either concrete or gravel, or in an herbaceous state. Following the
completion of construction, the site would shift from undeveloped to industrial land use.
Construction and operation of the Project would disturb about 53 acres of coastal wetlands
and about 3 acres of tidal flats (see table 4.8.1-1 and section 4.4). Annova sited the Project facilities
to avoid impacts on coastal wetlands to the extent practicable. Annova would submit all necessary
permits, including those needed for water appropriation and discharge.
4.8.2 Landowner and Easement Requirements
Annova signed a real estate lease option agreement with the BND for the 731-acre Project
site; subject to compliance with the terms of the real estate lease option agreement, Annova may
exercise the option and enter into the ground lease with the Port at any time. Annova proposes to
use an existing unpaved site access road for construction and incorporate a portion of the road into
the permanent site access road, a portion of which crosses the Lower Rio Grande Valley NWR (see
section 2.1.8 and figure 2.1.8-1). Use of the proposed access road would require an
appropriateness determination and a compatibility determination from the FWS. Annova has
stated it is in discussion with the FWS regarding the appropriateness determination. Alternative
access road locations are evaluated in section 3.5.
4-97 Land Use, Recreation,

4.8.3 Existing and Planned Residences and Commercial Developments
The nearest residence to the Project site is located approximately 2.7 miles to the south-
southeast on County Road 199, off of SH 4 (Boca Chica Boulevard) (see figure 4.9.9-1). The next
closest residential developments are located from approximately 4.7 miles to 5.1 miles northeast
of the Project site and include areas in Port Isabel, Laguna Heights, and Long Island. No existing
buildings are located within 50 feet of the Project site.
Long Island Village is a gated community located on Long Island. Long Island was formed
following construction of the Intra Coastal Waterway, which separated the island from the
mainland. The village has more than 2,000 residents and is accessed from Port Isabel via a swing
bridge, built in the 1950s. In addition to permanent residents, Long Island Village also provides
vacation homes (Long Island Village 2019). Writing on behalf of the Long Island Village Owners
Association, one comment expressed concern regarding potential LNG carrier safety and the
ability of the community to effectively evacuate were an incident to occur while a carrier was
transiting the BSC to the Project. Potential reliability and safety issues are discussed in section
4.12 of this EIS. The comment also noted that the LNG carriers transiting the BSC could indirectly
affect bridge access to their community, as commercial and recreational vessels temporarily
displaced from the BSC would seek an alternate route via the Intra Coastal Waterway, resulting in
the swing bridge being lifted and closed to vehicular traffic. Annova estimates that up to 125 LNG
carriers per year would visit the Project once fully operational.
No residential areas or subdivisions are planned for development within 0.25 mile of the
Project site (Sepulveda 2015). The closest area zoned for residential use by the City of Brownsville
is located more than 9 miles southwest of the Project site (City of Brownsville 2015).
There is one planned commercial development located within 0.25 mile of the Project site:
Rio Grande LNG, LLC is proposing to build a natural gas liquefaction facility and LNG export
terminal on the north side of the BSC. Rio Grande LNG, LLC filed an application to site and
operate an LNG terminal for export on May 5, 2016. In addition, Texas LNG Brownsville, LLC
is proposing to construct an LNG facility on the north side of the BSC, approximately 2 miles
northeast of the Project site. Texas LNG Brownsville, LLC filed an application to site and operate
an LNG terminal for export on March 31, 2016.
The Project site is approximately 6.3 miles west-northwest of the proposed Space Exploration
Technologies Corporation (SpaceX) vertical launch area. The proposed control center facilities for
the launch area would be approximately 4 miles from the Project site. According to the FEIS prepared
by the FAA for the SpaceX Texas Launch Site in May 2014, up to 12 launches per year may occur,
as well as pre-flight activities such as mission rehearsals and static fire engine tests. According to the
SpaceX FEIS, all launch trajectories would be eastward, over the Gulf of Mexico (FAA 2014).
As part of the licensing and permitting process, SpaceX is required to implement a plan
that defines the process for restricting public access and securing land and water areas in the
vicinity of the vertical launch area (the closure area) on the day of a launch operation. The Project
site would be located within the proposed SpaceX closure area, which would include areas along
SH 4, on Boca Chica Beach, and offshore areas, as well as the entire Lower Rio Grande Valley

NWR and the Palmito Ranch Battlefield NHL (figure 4.8.3-1). SpaceX proposes to limit public
access at two pre-defined checkpoints on SH 4 (figure 4.8.3-1).
The first checkpoint would be located on SH 4, just west of the existing U.S. Customs and
Border Protection checkpoint (approximately 14 to 16 miles west of the Gulf of Mexico), and west
of the Project site (FAA 2014). This first checkpoint would be a soft checkpoint. SpaceX,
government, and emergency personnel and anyone with property beyond (east of) the checkpoint
would be allowed to pass, but the general public would be denied access. The second checkpoint
would be a hard checkpoint, just west of the control center area. No one would be permitted to
pass this checkpoint during launch operations (FAA 2014). According to the FAA (2014),
SpaceX-related closures would last up to 15 hours on a launch day, with 6 hours being the typical
closure time for a nominal launch. Annova would coordinate with SpaceX and applicable agencies
to arrange for efficient movement of workers through the planned FAA soft checkpoint west of
the Project access road on SH 4 (figure 4.8.3-1).
Construction of the Project would not conflict with any zoning laws or future plans of the
BND or Cameron County. Construction and operation of the Project is not expected to affect existing
or planned residential or commercial land uses. Construction and operation of the Project is also not
expected to restrict land use on adjacent properties or displace any residences or businesses.
4.8.4 Recreation and Special Interest Areas
4.8.4.1 Public and Conservation Lands

The Project site was formerly managed by the FWS on behalf of the BND as part of
mitigation for a project that was canceled. The canceled project would have deepened the BSC
and facilitated construction of multipurpose docks at the deepwater turning basin. Under COE
Permit 13942 issued to the BND in 1982 (COE 1982), mitigation for the project included setting
aside 4,837 acres as a loma ecological preserve (lomas are low, rounded mounds of wind-blown
clay; see sections 4.1 and 4.5 for more details). The BND and the FWS entered into a lease for
management of the preserve, which included the proposed Project site. However, as noted above,
the BND did not implement the project to deepen the BSC and the permit expired in 1987.
After consulting with the FWS, Annova modified its initial site layout to reduce potential
impacts on mature dense thornshrub vegetation and maintain a wildlife corridor on the site’s western
boundary. The modified layout required that the Project site be altered to include an additional area
of the loma ecological preserve. The FWS has agreed to terminate their lease for this additional area
if the Project is approved; however, the FWS would continue to retain their lease at this time.
There are no lands on the Project site that are administered by federal, other state (other
than the BND), or local agencies, or private conservation agencies. However, a portion of the
proposed access road would cross the Lower Rio Grande Valley NWR, and the proposed dredged
material placement area (DMPA 5A) is on lands controlled by the COE. Public and conservation
lands in the vicinity of the Project site include the Laguna Atascosa NWR, Lower Rio Grande
Valley NWR, South Bay Coastal Preserve, Palmito Ranch Battlefield NHL site, and Palo Alto
Battlefield National Historical Park (including the Resaca de la Palma Battlefield). These areas
and potential impacts from Project construction and operation are discussed below.

Figure 4.8.3-1 Proposed SpaceX Launch Facilities

4.8.4.2 Existing Recreational Resources
The lands surrounding the Project site are largely undeveloped providing a variety of outdoor
recreational activities. Fishing and bird/wildlife watching are the main recreational activities in the
vicinity of the Project site. Recreational fishing and bird/wildlife watching are discussed separately
below. In addition to dispersed recreation activities, there are also designated recreation sites and
facilities located in the Project vicinity (figure 4.8.4-1). These designated areas include the five
public and conservation land areas identified above: the Laguna Atascosa NWR, Lower Rio Grande
Valley NWR, South Bay Coastal Preserve, the Palmito Ranch Battlefield NHL site, and the Palo
Alto Battlefield National Historical Park, as well as the Jaime J. Zapata Memorial Boat Ramp
Fishing Pier and Kayak Launch Area, the Padre Island National Seashore, South Padre Island, and
Brazos Island State Park. These areas are discussed below. A separate discussion is also provided
for the Laguna Madre.
During construction and operation of the Project, residents and tourists using recreational
sites in the Project area may be aware of construction and operation activities and increased traffic.
People using recreational sites may experience increased levels of dust, noise, and traffic, as well
as visual impacts. Construction activities would produce dust primarily during the initial phase of
clearing and grading the site. Annova would implement dust control measures as necessary to
reduce dust emissions from construction activities (see appendix F and summary in section
4.11.1.4). Recreationists could also experience localized increases in the ambient sound
environment, with increases ranging from unnoticeable to intrusive. Potential noise impacts are
addressed in section 4.11; visual impacts associated with project construction and operation are
discussed below in section 4.8.5.
Laguna Atascosa NWR
The Laguna Atascosa NWR, located across the BSC from the Project site provides
recreational opportunities for visitors and residents (figure 4.8.4-1). From north to south, the
97,000-acre Laguna Atascosa NWR extends almost three quarters of the length of Cameron
County, and encompasses a portion of South Padre Island across the bay from the Project site. A
portion of the NWR is open to the public for wildlife related activities, including wildlife and bird
watching, nature trails, hunting, fishing, kayak tours, photography and environmental education
(FWS 2016c). The NWR, including the Adolph Thomae Jr. County Park, hosts approximately
350,000 visitors each year, with peak visitation occurring from November through March (FWS
and Federal Highway Administration 2017).
All visitor facilities and recreational activities in the Laguna Atascosa NWR, with the
exception of fishing, occur in the northern half of the refuge or in the South Padre Island unit. The
NWR includes fishing areas on South Padre Island, San Martin Lake in the Bahia Grande, and the
Arroyo Colorado. San Martin Lake is accessible from SH 48 via the Jaime J. Zapata Memorial
Boat Ramp (figure 4.8.4-1), while the fishing areas in Arroyo Colorado and South Padre Island
are further north, more than 5 miles from the Project site (FWS 2016c).

Figure 4.8.4-1 Recreational Resources

The Bahia Grande is a 6,500-acre tidal basin connected to the BSC by a pilot channel that
was constructed in the early 2000s to provide a natural tidal flow and help restore the basin to its
original state. The Bahia Grande is shallow and hypersaline, and accessible only by kayak or
wading. In addition, a newly funded project, the Bahia Grande Coastal Corridor (BGCC) project,
has been initiated. Land acquisition proposed as part of this project would connect over 2 million
acres of private ranchland located north of the Laguna Atascosa NWR with the 1.3 million-acre Rio
Bravo Protected Area, which is managed by the Commission Nacional De Areas Naturales
Protegidas in Mexico (Gulf Coast Ecosystem Restoration Council 2015). All lands initially
identified as the FWS Refuge acquisition boundary are north of the BSC, and all lands currently
identified for acquisition are located north of the Bahia Grande. Land acquired as part of the BGCC
project would become part of the Laguna Atascosa NWR or Lower Rio Grande Valley NWR.
The FWS holds a conservation easement directly south of the Laguna Atascosa NWR,
between SH 48 and the BSC. Approximately 1,000 feet wide and 2,900 feet long, the easement is
maintained as a wildlife corridor for the federally listed, endangered ocelot. The corridor connects
the Laguna Atascosa NWR to the BSC via a wildlife tunnel that passes under SH 48.
Construction and operation of the Project would not be expected to affect most visitors to
the Laguna Atascosa NWR, because most visitor activities, trails, and facilities are located in the
northern half of the refuge or in the South Padre Island unit, away from the Project site. San Martin
Lake and Bahia Grande are accessible from SH 48. Project construction and operation would not
affect access to these locations, but the southern portion of the refuge along SH 48 would be
affected by construction noise, and the Project would likely be visible to anglers, birders, and
others during some part of their travel to and from San Martin Lake and Bahia Grande, or to users
of the NWR that stop along SH 48. The potential visual impacts of the Project are discussed below
in section 4.8.5, and potential impact from noise is discussed in section 4.11.12.
All of the lands currently identified for acquisition as part of the BGCC project are located
north of the Annova Project site, with the closest area approximately 5.4 miles from the Project
site. Construction and operation of the proposed Project is, therefore, not expected to conflict with
current land acquisition plans for the BGCC project.
Lower Rio Grande Valley NWR
Established in 1979 to protect biodiversity along the Rio Grande, the Lower Rio Grande
Valley NWR is a 102,000-acre coastal refuge that consists of lands owned and leased by the FWS.
The NWR borders the Project site and SH 4 (figure 4.8.4-1). The Lower Rio Grande Valley NWR
connects lands managed by private landowners, nonprofit organizations, the State of Texas, and
two other NWRs (Laguna Atascosa and Santa Ana) along the last 275 river miles of the Rio
Grande. Not all of the refuge property is contiguous or near the Rio Grande itself (figure 4.8.4-1).
Visitor activities at the Lower Rio Grande Valley NWR include wildlife watching and hunting.
The Boca Chica Tract is the closest wildlife watching area in the NWR to the Project site
(figure 4.8.4-1). Located at the eastern end of SH 4, the Boca Chica Tract is considered a typical
coastal environment with beach front, saline flats, mangrove marshes, shallow bays, and lomas.
This area connects habitats along the Gulf Coast to the Rio Grande and allows wildlife to travel

unimpeded. Other recreational activities within the tract include beach activities, hiking, and
birdwatching.
The Lower Rio Grande Valley NWR does not have any trails or visitor facilities in close
proximity to the Project site. The Boca Chica Tract, located across South Bay from the Project
site, is approximately 4.5 miles east of the Project site. Visitors to the tract and the beach, which
fronts onto Laguna Madre, away from the Project site, are not expected to be affected by Project
construction or operation. The Project may, however, be visible to visitors during some part of
their travel to and from the NWR. The potential visual impacts of the Project are discussed below
in section 4.8.5.
South Bay Coastal Preserve
The South Bay Coastal Preserve is a Texas Gulf Ecological Management Site that
encompasses the southernmost bay in Texas, near Port Isabel, east of the Project site (figure 4.8.4-
1). Bordered to the north by the BSC and associated spoil banks, the bay includes approximately
3,500 surface acres, and is bordered to the south by the riparian edge of the Rio Grande, and by
Brazos Island to the east. Boaters and anglers use the South Bay Coastal Preserve on an occasional
and seasonal basis for fishing and to a lesser extent waterfowl hunting. The bay also supports
commercial oyster landings (TPWD 2016a). The TPWD presently leases the preserve from the
Texas General Lands Office.
Construction and operation of the Project could delay recreational boaters attempting to
access South Bay along the BSC. Vessel traffic in the BSC would temporarily increase during
Project construction with transport of construction equipment, materials, and prefabricated
modules to the Project site expected to require an estimated 24 to 36 barge trips per year (less than
one trip per week). Impacts on recreational boaters attempting to access South Bay during Project
construction are expected to be minimal and would end following the completion of construction.
During Project operation, a maximum of up to 125 LNG carriers per year would transit the
BSC to the Project. Visitors to the South Bay Coastal Preserve presently experience visual and
other impacts from large, ocean-going commercial vessels, which call at the Port of Brownsville
at an average rate of six per week, or 312 per year (BND 2016). The increase in traffic associated
with Project operation, an average of 10 to 11 vessels per month, could potentially result in
additional delays, but is not expected to substantially affect visitation to the South Bay Coastal
Preserve.
Palmito Ranch Battlefield National Historic Landmark, Palo Alto Battlefield National
Historical Park, and Resaca de la Palma Battlefield
Three historic battlefield sites are located in the general vicinity of the Project site: the
Palmito Ranch Battlefield NHL; the Palo Alto Battlefield National Historical Park; and the Resaca
de la Palma Battlefield.
The Palmito Ranch Battlefield NHL is the closest of these sites to the Project site (figure
4.8.4-1). Identified as the location of the last major land battle of the American Civil War, the
Palmito Ranch Battlefield NHL consists of more than 5,400 acres protected under the NHPA (NPS
2010). The Palmito Ranch Battlefield NHL historic marker, noting the location of the battlefield,
is located on SH 4, approximately 3.3 miles southwest of the Project site and approximately 0.25
mile from the intersection of SH 4 and the main access road to the Project site. Facilities at the
Palmito Ranch Battlefield NHL include an observation platform that provides views over the area
where the historic battle took place. The site is open to visitors for off-trail hiking, bird/wildlife
watching, and other forms of recreation.
The Palo Alto Battlefield NHL, located approximately 12 miles west of the Project site,
preserves the grounds of the May 8, 1846 Battle of Palo Alto, which was the first conflict in a 2-
year-long war that defined the present boundary of the State of Texas. The NPS has acquired about
one-third of the designated area, with private landowners still controlling about 2,000 acres of the
battlefield. The Palo Alto Battlefield site was re-designated as a National Historic Park in 2009 and
expanded to include the Resaca de la Palma Battlefield. The Resaca de la Palma Battlefield is a
separate, 34-acre battlefield site located in Brownsville, approximately 5 miles south of the main
Palo Alto Battlefield site, and approximately 14 miles southwest of the Project site.
Land in the vicinity of the Project is generally undeveloped and natural, with the exception
of dredged material placement areas adjacent to the site on the east and west borders. The
surrounding area is generally flat to very gently rolling, and consists mainly of shallow
waterbodies, mudflats, and marshes. Because the landscape is generally flat and open, tall
structures are often visible from far distances in the region. Visual simulations were created from
key observation points (KOPs) located in proximity to the battlefields to represent views of visitors
to the battlefields. The overall visual effect of the Project at the Palmito Ranch Battlefield NHL
and the Palo Alto Battlefield site KOPs ranged from no effect or negligible in some areas to
moderate or moderately high in other areas, due to varying degrees of distance, partial screening,
and foreground vegetation. The potential visual impacts of the Project are discussed below in
section 4.8.5.
Traffic in the vicinity of Palo Alto Battlefield National Historic Park and Palmito Ranch
Battlefield NHL would temporarily increase during Project construction. Traffic increases from
workers commuting during the morning peak hour would occur before the Battlefield sites open
and would not be expected to affect visitors to the Battlefield sites. Cultural heritage tourists who
leave the battlefield sites during the afternoon peak hour may experience longer trips than average.
This potential impact would be short-term and vary depending on the number of construction
workers employed at any one time. Increases in traffic during Project construction are not expected
to deter people from visiting Palo Alto Battlefield National Historic Park or Palmito Ranch
Battlefield NHL.
Annova estimated potential noise impacts at noise-sensitive areas, including an interior

location within Palmito Ranch Battlefield NHL (modeled as Noise Sensitive Area 4 [NSA4]).
Given their distance from the Project site, the Palo Alto and Resaca de la Palma Battlefields were
not considered noise sensitive areas. Based on typical human reactions to changes in sound level,
predicted changes in sound level caused by Project construction were estimated to be “very
noticeable” at NSA4. Very noticeable is the third category on a five-level scale ranging from
“unnoticed” to “tolerable” to “very objectionable” to “intolerable.” Some visitors to the battlefield
may consider this change in sound level intrusive. Typical human reactions to the estimated
Project operation-related increases in sound level were considered “unnoticed” to “tolerable.”
These potential impacts are discussed further in section 4.11.

Jaime J. Zapata Memorial Boat Ramp Fishing Pier and Kayak Launch Area
Accessed via Highway 48, the Jaime J. Zapata Memorial Boat Ramp Fishing Pier and
Kayak Launch Area is located along a short channel connecting the BSC to San Martin Lake,
approximately 1.5 miles west of the Project site (figure 4.8.4-1). Site facilities include a public
boat ramp, two picnic pavilions, a lighted fishing pier, and a kayak launch ramp. The site offers
fisherman, boaters, bird watchers, kayakers, and others easy access to San Martin Lake and the
BSC (Cameron County Parks and Recreation 2016; Texas General Land Office 2015). Other
public boat ramps in the Project vicinity are located at Port Isabel and South Padre Island,
approximately 5 miles and 7 miles northeast of the Project site, respectively. Potential impacts on
this facility are discussed below in the Recreational Fishing subsection.
Padre Island National Seashore
The Padre Island National Seashore separates the Gulf of Mexico from the Laguna Madre,
and protects 70 miles of coastline, dunes, prairies, and tidal flats (NPS 2016a). The longest stretch
of undeveloped barrier island in the world, the National Seashore extends north from near the
Mansfield Channel in north Willacy County, and is located approximately 40 miles from the
Project site at its closest point. Recreation opportunities at the Padre Island National Seashore
include beachcombing, bicycling, birding, camping, fishing, hunting, picnicking, swimming and
windsurfing (NPS 2016a). Construction and operation of the Project would not be expected to
affect visitors to the Padre Island National Seashore based on its location and distance from the
Project site.
South Padre Island
South Padre Island is a major tourist destination known nationally for its beaches, and is
heavily developed with hotels/motels, retail shops, and entertainment venues. The closest public
beach to the Project site (Isla Blanca Beach) is located on the southern tip of the island,
approximately 7.2 miles northeast of the Project site. Several charter boats on the bay side of
South Padre Island offer daytime and sunset cruises, and dolphin watching excursions in the Lower
Laguna Madre. Many charter boats also offer “sea life” tours that involve trawling for sea
organisms and providing educational commentary about different species and habitats.
Charter boats could bring visitors to within viewing distance of the Project site, but this
impact is expected to be minimal because the Project site is located 8.7 miles inland along the
BSC, and few charter cruises and sea life viewing tours take visitors inside the BSC. Another type
of marine tour offered by charter boat companies is a cruise through the BSC that features the
maritime industrial activities at the Port of Brownsville and along the channel, including
international cargo ships, decommissioned naval vessels, and shipworks. The Project is not
expected to affect these charter trips.
Comments received during public scoping identified three recreation sites on South Padre
Island that could be potentially affected by the Project: Schlitterbahn Waterpark and Resort; Isla
Blanca Beach; and the Boy Scout camp at Dolphin Cove. Located approximately 7 miles northeast
of the Project site, Schlitterbahn Waterpark and Resort offers indoor and outdoor waterpark
facilities, river features, swimming pools, and beach access, as well as resort accommodation and

various dining options. Isla Blanca Beach is a public recreational beach located along the east side
of the southern tip of South Padre Island, approximately 7.2 miles northeast of the Project site.
The Boy Scout camp at Dolphin Cove, located on the south end of South Padre Island, is
approximately 6.7 miles northeast of the Project site. Approximately 2.5 acres in size, the Boy
Scout camp site includes tent sites, restrooms, staff quarters, first aid station/commissary space,
parking areas, trails, recreation facilities, beach and shore areas, and other natural areas.
Construction and operation of the Project would not be expected to affect visitors to the
Schlitterbahn Waterpark and Resort, based on its distance from the Project site and location on
South Padre Island. The majority of structures and areas within the waterpark and resort are
unlikely to have views of the Project due to intervening structures and vegetation, but the Project
may be visible from some locations in the parking lot on the west side of the facility and from
some of the taller waterpark and resort structures. The potential visual impacts of the Project are
discussed below in section 4.8.5.
Construction and operation would not affect beachgoers visiting South Padre Island and
Isla Blanca Beach because the beaches are on the ocean side of the island, facing away from the
Port of Brownsville and the Project site. Further, the Project is unlikely to be visible from the
beach due to intervening terrain, vegetation, buildings, and other structures.
Visitors to the Boy Scout camp at Dolphin Cove are also unlikely to be affected by
construction and operation of the Project. The Project would, however, likely be visible from
portions of the Boy Scout camp at Dolphin Cove, primarily along the camp’s west side, including
the tent camping area, nearby beaches and shoreline areas, and trails. The potential visual impacts
of the Project are discussed below in section 4.8.5.
Brazos Island State Park
Brazos Island State Park is not identified as a state park by the TPWD (2017), but online
review suggests that the south portion of Brazos Island, which borders the South Bay Coastal
Preserve to the east, is commonly referred to as a state park or recreation area. Located from 5 to
7 miles east of the Project site, the area identified as a park or recreation area generally appears to
extend north from SH 4 toward the mouth of the BSC. There are no established roads in this area,
but SH 4 provides access from the south. Public use tends to be concentrated along the beach
strand north of SH 4, with uses including camping, driving on the beach, fishing, surfing,
swimming, and nature study.
Construction and operation would not affect access to Brazos Island State Park. The beach
is on the ocean side of the island, facing away from the Port of Brownsville and the Project site,
and the Project is unlikely to be visible from this area due to the foredunes extending along the
inland side of the beach. The Project would, however, likely be visible from some inland locations,
as discussed below in section 4.8.5.
Laguna Madre
The Laguna Madre is a long, narrow hypersaline lagoon that extends the length of Padre
Island. The lagoon is approximately 130 miles long and about 4 to 6 miles wide, with an average
depth of 3.6 feet. Recreation activities on the lagoon include windsurfing, fishing, and boating
(NPS 2019). As noted above, several charter boats on the bay side of South Padre Island offer
daytime and sunset cruises, and dolphin watching excursions in the Lower Laguna Madre. In
addition, the Isla Blanca Park Boat Ramp provides an entry point for boaters to access the Laguna
Madre. Recreation use on the Laguna Madre could be affected during operation by the LNG
carriers that would transit the BSC through the Lower Laguna Madre to the Project. Impacts would
be similar to those presently experienced from the large, ocean-going commercial vessels, which
call at the Port of Brownsville at an average rate of six per week, or 312 per year (BND 2016).
Annova estimates that up to 125 LNG carriers per year would visit the Project once fully
operational. Impacts on other vessels would primarily be limited to deep draft vessels that must
remain in the dredged federal navigation channel where it crosses the southeast edge of the Lower
Laguna Madre. Shallow draft vessels that are not limited to the Federal navigation channel would
only experience minor impacts.
Recreational Fishing
Recreational fishing is an important outdoor activity in the vicinity of the Project site.
According to the TPWD, residents and visitors spent an estimated total of 41,100 hours
participating in guided fishing trips and another 461,700 hours participating in private boat fishing
trips in the estuarine waters of Cameron and Willacy counties during the 2013-2014 fishing season
(Ferguson 2015). The top public boat ramps in the general Project vicinity are Port Mansfield
(Willacy County) and Arroyo (in Cameron County), followed by the Jaime J. Zapata Memorial
Boat Ramp Fishing Pier and Kayak Launch Area (Cameron County). South Padre Island and Port
Isabel are also popular recreational fishing launch sites but are mainly occupied by private marinas
rather than public boat ramps (Ferguson 2015). Boaters and anglers use the South Bay Coastal
Preserve on an occasional and seasonal basis for fishing; with the exceptions of Port Mansfield
and Arroyo, these areas are shown on figure 4.8.4-1. Port Mansfield and Arroyo are located farther
north outside the area captured in the figure.
Fishing also occurs in the BSC via vessels or from shore, and the Project site has
historically been used as an informal fishing location, boat launch, and BSC access point for
anglers. According to the FWS, following a request from the U.S. Border Patrol, a permanent gate
with a lock was recently installed to block public access to the Project site via the existing access
road from SH 4. Access is currently limited to the FWS, U.S. Border Patrol, and the Port of
Brownsville.
Construction and operation of the Project would not permanently affect access to the
majority of regional fishing locations in the waters in the vicinity of the Project site, including the
estuarine waters of Cameron and Willacy counties and the offshore Gulf of Mexico. Project
construction may temporarily affect access to recreational fishing and boating activities along the
BSC, including the Jaime J. Zapata Memorial Boat Ramp Fishing Pier and Kayak Launch Area.
Access to some destinations may be delayed due to dredging activities and the movement of barges
delivering large equipment to the material offloading facility. Annova anticipates that the Coast
Guard would provide notices to boaters to avoid this area when these activities occur.
During Project operation, LNG carriers navigating to and from the Project site, may impact
recreational anglers who transit recreational fishing boats through the BSC, especially those who
use the Jaime J. Zapata Memorial Boat Ramp and Launch Area. These anglers may experience

delays during times when the LNG carriers are navigating the waterway. Depending on their
location, anglers fishing from boats within the BSC may be required to relocate temporarily for
safety reasons while an LNG carrier is navigating to or from the marine berth at the Project site.
It is expected that LNG carriers would have a moving security zone during transit through the BSC
per Coast Guard regulations at 33 CFR 165.805(a)(2). As a safety and security precaution,
typically no vessels are allowed to meet, cross, or overtake LNG carriers in transit or otherwise
enter the security zone without the express permission of the Coast Guard. During Project
operation up to 125 LNG carriers per year would transit the BSC to the Project. Large, ocean-
going vessels presently call at the Port of Brownsville at an average rate of six per week, or 312
per year (BND 2016). The increase in traffic associated with Project operation could potentially
result in additional delays, but is not expected to substantially affect recreational fishing in the ship
channel. The occurrence and extent of fishing vessel delays would depend on vessel orientation
and direction of travel. Small vessels traveling ahead of or behind an LNG carrier in the same
direction would not experience measurable delays as long as they remain outside the LNG carrier
safety zone. Smaller vessels heading in the opposite direction to a LNG carrier could experience
delays of a few minutes to 1.5 hours, depending on the position of the smaller vessel relative to
the LNG carrier. These potential impacts are discussed further in section 4.9.10.2 of this EIS.
Birding
The Lower Rio Grande Valley (Cameron, Hidalgo, Willacy, and Starr counties) has been
identified as the number two birdwatching destination in North America (Mathis and Matisoff
2004). Within the Valley, the World Birding Center, a network of nine birding sites stretching
from South Padre Island in the east to Roma in Starr County in the west, is a major destination for
birdwatchers visiting the region. The South Padre Island Birding and Nature Park is the closest
World Birding Center site to the Project site, located about 9.5 miles to the east. Other relatively
close World Birding Center sites are located further away in Brownsville and Harlingen (World
Birding Center 2010). Project construction and operation are not expected to affect the experience
of visitors to the World Birding Center sites.
Texas established a formal birding trail, called the Great Texas Coastal Birding Trail, in
1996 (American Birding Association 2015). The “trail” is actually 43 separate hiking and driving
trails that include 308 birding sites that covers an area extending over 500 miles from end to end.
The closest segment of this trail is the Boca Chica Loop, which consists of a grouping of five
birding locations. One of these locations, “LTC 039” (the 39th birding site in the Lower Texas
Coast portion of the Great Texas Coastal Birding Trail), is located on the south side of Bahia
Grande approximately 0.6 mile from the Project site and accessed by a parking pull-off on the
north side of SH 48. Construction and operation of the Project would not affect access to this site,
but visitors to the site may be aware of construction activities, with temporary increases in dust,
noise, and traffic, as well as visual impacts. These types of potential impacts are discussed in
sections 4.8.4.2, 4.8.5, and 4.11.12. Furthermore, construction activities may result in disturbances
to avian species, which could reduce the number of birds found at this site (see section 4.6).
4.8.5 Visual Resources
Visual resources refer to the composite of basic terrain features, geologic features,
hydrologic features, vegetation patterns, and anthropogenic features that influence the visual

appeal of an area as perceived by viewers. In general, impacts on visual resources result from
changes in landscape character and scenic quality caused by an action. Visual impacts from the
Project may occur during construction, when large equipment, excavation activities, spoil piles,
and construction materials are visible to residents and visitors, and during operation to the extent
that facilities or portions of facilities and their lighting are visible. The degree of visual impact
resulting from the Project would be determined by the general character and quality of the existing
landscape, the changes created by the visually prominent features of the proposed facilities, and
the response of viewers to those changes.
4.8.5.1 Project Facilities and Visual Description
The land in the vicinity of the Project is largely undeveloped and relatively natural in
appearance. The physical character of the area, consists of shallow waterbodies, saline mudflats,
marshes, drainages, and ditches, interspersed with lomas (clay or sandy dunes/ridges surrounded
by marshes and salt flats). Consequently, the terrain is generally flat to very gently rolling.
Vegetative cover in the area consists largely of a mix of emergent herbaceous wetlands, barren
lands, grasslands, and shrub-scrub lands, with areas of taller brush and mesquite and other trees.
Vegetation within, and immediately adjacent to, the Project site is predominantly low-growing
grasses and shrubs, with some mesquite trees and other shrubland plants. This results in generally
low visual variety in the landscape.
The Project would be constructed in a relatively undeveloped, rural area. Some occupied
residences located near County Road 199, off of SH 4, approximately 2.7 miles south of the site,
represent the closest developed land uses. The next closest developed areas are the communities
of Laguna Heights and Port Isabel, and Long Island located between 4.7 and 5.1 miles to the
northeast. There are no schools or churches within 1 mile of the Project site. Public lands managed
for conservation or recreation purposes and areas with special federal or state designations such as
natural landmarks, scenic roads, trails, or scenic rivers are typically considered visually sensitive
areas. Although the proposed site is not directly adjacent to any such resources, a number of
potentially sensitive resources are located nearby (NPS 2010b, 2010c, 2012; U.S. Department of
Transportation n.d.). These include the Laguna Atascosa NWR, the Lower Rio Grande Valley
NWR, the South Bay Coastal Preserve, and Palmito Ranch Battlefield NHL. Although located
about 12 miles from the site, the NPS has also expressed concern about visual sensitivity and
potential impact on the Palo Alto Battlefield National Historic Park. Recreational resources in the
vicinity include the boat ramps and fishing piers at the Jaime J. Zapata Memorial Boat Ramp
Fishing Pier and Kayak Launching Area, and areas within the nearby NWRs.
Both SH 48 and SH 4 are popular routes for visitors and local area residents traveling
between the coast and other destinations. Potential viewing locations can occur at numerous
informal pull-offs and more formal interpretive wayside exhibits along these highways and smaller
roads. In addition, the BSC is utilized as a commercial shipping channel as well as by recreational
boaters. Use of the area includes people engaged in wildlife viewing and traveling through the
area to visit historic sites, beaches, parks, and other nearby tourist destinations. Although not
designated as a scenic byway by the FHA, SH 48 between the city of Brownsville and Highway
100 passes through an extensive area of tidal flats and lomas, where birders regularly view
shorebirds, water birds, and other wildlife (TPWD n.d.).

Sensitive viewers in this area include recreational and residential users, both traveling to and
from coastal destinations and using nearby recreation areas. As this area is part of the Great Texas
Coastal Birding Trail, it attracts birders and others interested in wildlife viewing. Additionally, the
Lower Texas Coast Texas 48 Scenic Drive birding trail includes the portion of SH 48 that parallels
the BSC north of the Project site. Viewer sensitivity throughout the Project area is generally high
due to the large number of people traveling in the area for recreation and leisure.
4.8.5.2 Visual Impact Analysis
Annova prepared a Visual Impact Assessment (VIA) for the Project that applied selected
procedures of the BLM’s Visual Resource Management (VRM) System (1984). Specifically, the
Project VIA incorporates the VRM contrast-rating procedure in the process used to evaluate visual
impacts. In summary, the VIA identified 10 KOPs as reference locations for impact assessment.
The analysis documented existing visual conditions for each KOP and assessed visual impacts by
determining the amount of visual contrast the Project would introduce into the landscape and the
expected response of viewers to those changes. The contrast rating for each KOP was based on a
photo simulation of the with-Project condition at that KOP. The photo simulations included the
tallest and most prominent features of the LNG terminal, including the LNG storage tanks, flare
stack, gas-fired heaters, and buildings, and in one simulation an LNG carrier at dock. The contrast
ratings were combined with an assessment of visual sensitivity (i.e., a measure of viewer exposure
to changes in the landscape and viewer sensitivity to those changes) to determine the level of visual
impact at each KOP. The KOPs selected for this VIA are specific locations at representative
visually sensitive areas, including historical battlefields in the region, two NWRs in the immediate
area, other areas used for recreation and wildlife viewing, key travel routes, and other public
gathering areas. KOP locations are provided in figure 4.8.5-1 and KOP simulations are provided
in appendix E. Visual sensitivity in the Project area is generally considered to be high because it
can be assumed that a large proportion of the viewers in the area are there for recreation and leisure
activities.
Annova also prepared visual simulations of the Project’s active flaring system (i.e.,
simulations from the KOPs when flaring events are occurring). Among these were simulations
depicting both day- and night-time conditions, corresponding to previous KOP Project
simulations. Flaring events are planned to have a low frequency of occurrence, and nighttime
flaring events are not currently planned but could occur if needed. Simulations included both
warm/cold flaring events and marine flaring events. Phast modeling software was used to estimate
the flame’s dimensions (height, width, and angle), depending on gas composition, wind direction,
and other factors. This information was used to generate the graphical representation of the flame’s
shape for the simulations. Annova modeled possible worst-case non-emergency scenarios of flare
events for each KOP where flares could be visible.

Figure 4.8.5-1 Key Observation Points

The NPS expressed concerns regarding potential visual impact on NHLs, National Historic
Parks, and the Padre Island National Seashore. To address this, Annova prepared simulations to
evaluate visual effects on these resources identified by the NPS. A simulation was prepared for
the Palo Alto Battlefield National Historical Park, located approximately 12 miles west of the
Project, to assess visibility and visual impacts on historical areas at this background viewing
distance. The landscape in this view is predominantly natural in appearance and Project
components would not be concealed by vegetation. An additional simulation for this view was
prepared using a 55-millimeter (mm) digital lens setting (a 50-mm lens setting is used to
approximate the human view for the standard KOP analysis) at the request of the NPS.
Additionally, a night view was simulated for a KOP at the boat ramp on South Padre Island, to
address NPS concerns about potential night sky pollution from the Project. Flaring events were
also simulated with these conditions.
The most prominent visual features at the Project site would be two domed, cylindrical
LNG storage tanks, each 186 feet in height from the finished grade to the top of the dome.
Additional vertical structures at the Project site would include a 160-foot-high flare stack and three
gas-fired heaters. The flare stacks would be visible when in use in both day and night conditions.
When flaring is not occurring, the coloration of the tall flare stack (160 feet elevation) would cause
it to blend in with the surrounding landscape. Furthermore, the galvanized steel of the LNG trains,
pipes, and pipe rack would be treated to minimize glare. In comments on the draft EIS, the NPS
requested additional detail on the paint color that would be used for the LNG storage tanks and
other tall structures. On March 15, 2019, we requested that Annova respond to this request, and
on March 25, 2019, Annova filed information stating the color would be a dull green (“covert
green”), and confirmed that this color was used in the visual simulations included in appendix E.
Annova has included proposed lighting design measures to minimize contrast with the
night sky in the landscape. The lighting design and practices to minimize light emitted from the
Project include the following:
• installing lighting only where needed (motion sensors or timers would be

incorporated where use at night is intermittent);
• shielding bulbs and directing light downward;
• installing lamps with warmer colors and minimum blue light;
• preferentially selecting energy-efficient lamps and fixtures; and
• avoiding flaring of gas at night whenever feasible.
The visual simulations prepared for the Project incorporate these color and lighting
mitigation measures in the depiction of the Project facilities. Use of these mitigation measures is
reflected in the contrast ratings developed for the KOPs, applying the procedure from the BLM
visual resource methodology, and resulted in reduced ratings of overall visual impacts on the
surrounding landscape.
The following discussion summarizes the existing visual conditions, simulations and
contrast ratings, viewer characteristics, and visual impact ratings for the respective KOPs.

KOP 1. Palmito Ranch Battlefield Historical Marker (3.1 miles southwest from the Project
site)
KOP 1 is located at the historical marker for the Palmito Ranch Battlefield NHL along SH
4 (Boca Chica Boulevard). The federal Department of the Interior designated the Palmito Ranch
Battlefield as an NHL in 1997, to commemorate the last major land battle of the Civil War. The
landmark designation applies to an area of nearly 6,000 acres that extends south from SH 4 to the
Rio Grande and east-west for approximately 5 miles (NPS 2010a). The area includes a mixture of
private lands and federal lands within the Lower Rio Grande Valley NWR. The historical marker
wayside provides a location for people to view the landscape within the battlefield and read the
interpretive information about the battle (See also the related discussion for KOP 2).
KOP 1 provides a view to the northeast toward the Project site, which is approximately 3.1
miles from KOP 1, and is located in the foreground/middleground distance zone. Figure E-1a (in
appendix E) shows the existing view and a visual simulation of this view with the Project from
this location. Although views to the north of the highway are largely screened by vegetation in
the immediate foreground, the straight horizon line of the coastal mudflats and marshes is partially
visible through openings in the vegetation. The wayside was primarily developed to provide an
expansive view to the south that includes part of the battlefield area, which is the opposite direction
of the Project. The brown historical marker sign is the only vertical structure in the view. Due to
the largely natural appearance of the existing landscape and relative lack of development in this
view and other views from this section of SH 4, the visual integrity of the landscape surrounding
KOP 1 is relatively high. Nevertheless, as shown in figure E-1a (in appendix E), the specific view
toward the Project at KOP 1 is dominated by the dark paved highway, gravel wayside area, and
highway signs. Although Annova’s VIA did not apply the scenic quality rating component of the
BLM’s VRM methodology, the existing scenic quality at KOP 1 would appropriately be
considered as “low” because of the expanses of flat marshes and low vegetated hills provide little
visual variety and interest among the elements of form, line, color, and texture.
Figure E-1a (in appendix E) includes a visual simulation for a daytime view to the
northeast, from KOP 1. The Project facilities would be evident in this view due to gaps in the
vegetation screening at this location. The vertical lines and varied forms of the Project facilities
would be silhouetted against the sky. The introduction of new, large, and varied industrial facilities
in this largely undeveloped and natural area would be visible to an observer at this location and
could attract the attention of viewers. Because of the viewing distance and dominating influence
of the highway and the presence of foreground vegetation, however, these changes would not begin
to dominate the landscape. Annova’s VIA rated the contrast of the Project within the view of the
distant landscape as moderate. The BLM (1986) guidance for a moderate contrast rating indicates
that the “element contrast begins to attract attention and begins to dominate the characteristic
landscape.” The guidance for a weak contrast rating is that the “contrast can be seen but does not
attract attention.” Based on the conditions depicted in the simulation, the contrast created by the
Project facilities would not begin to dominate the landscape and the overall contrast rating for
KOP 1 is weak. A weak contrast rating is based on the viewing distance, the existing contrast
associated with the highway, and partial screening by the vegetation in the immediate foreground.
During operations, it is anticipated that periodic flare events would occur. To assess the
visual impacts of flare events, Annova modeled worst-case, non-emergency marine flare events

(figure E-1b in Appendix E) and warm/cold flare events (figure E-1c in Appendix E) during
daytime hours for KOP 1. Due to distance and partial screening of vegetation, there is very little
noticeable additional visual impacts from these scenarios.
The viewer sensitivity at this location is likely a mixture of moderate and high sensitivity.
Moderate sensitivity would apply to travelers on SH 4 who continue past KOP 1 without stopping
at the historical marker. Travelers who do stop at the marker presumably are interested in
battlefield views and interpretive information, and would likely have a high sensitivity to visual
change. Given the relatively low existing scenic quality, a weak contrast rating, and moderate to
high viewer sensitivity, the potential visual impact of the Project as seen from KOP 1 would be
moderate.
KOP 2. Palmito Ranch Battlefield National Historic Landmark – Observation Platform

(3.4 miles southwest from the Project)
KOP 2 is located at an observation platform for the Palmito Ranch Battlefield NHL, off
Palmito Hill Road, south of Boca Chica Boulevard (SH 4). The NHL is within the Lower Rio
Grande Valley NWR, established in 1979 and owned by the FWS. The management goals in the
Comprehensive Conservation Plan for the Lower Rio Grande Valley NWR include protecting
biological diversity and wildlife and habitat management; water rights, water quality, and
wetlands; cultural resources; and public use, recreation, and wildlife interpretation and education
(FWS 1999). The NHL is located along the south side of Boca Chica Boulevard (SH 4) and is
within five miles of the Project (see figure 4.8.5-1). The observation platform was constructed in
2014, as a partnership with the Texas Historical commission, FWS, and the NWR, within the
battlefield area, with interpretive signs, parking area, and monument. This platform and parking
area provide a location for people to view the landscape from the battlefield area and read
interpretive information about the battle.
KOP 2 provides a view to the northeast toward the Project site, which is approximately 3.4
miles away and located in the foreground/middleground distance zone. Figure E-2 (in appendix
E) shows the existing view and a visual simulation of this view with the Project from this location.
The existing view from the platform is enclosed by foreground vegetation and is dominated by the
constructed features (i.e., a metal fence, concrete walkway, and stone interpretive monument) and
dense, green, low and medium height vegetation in the immediate foreground. Views of the
landscape to the northeast are blocked by vegetation, although expansive views of the battlefield
area are present to the east, west, and south of the viewing platform. Due to the largely natural
appearance of the existing landscape, and the lack of intrusive development in this view, the visual
integrity of the landscape surrounding KOP 2 is relatively high. Although Annova’s VIA did not
apply the scenic quality rating component of the BLM’s VRM methodology, the existing scenic
quality at KOP 2 would appropriately be considered as “low” because of the dominance of
vegetation, and low vegetated terrain that provide little visual variety and interest among the
elements of form, line, color, and texture.
Figure E-2 (in appendix E) includes a visual simulation for a daytime view to the northeast
from KOP 2. The simulation indicates that the dense vegetation enclosing the view to the north
would fully screen views toward the Project site and the facilities would not be visible from this
KOP (consequently, no additional simulations of flare events were prepared). This means that

construction and operation of the Project, including flaring events, would not result in any visual
contrast or visual impact from this location, and there would be no reduction in visual integrity
and scenic quality from this KOP. However, other areas along Boca Chica Boulevard, such as
where it borders the Palmito Ranch Battlefield NHL, would have unscreened views to the north,
which would likely result in some Project visibility along the portion of Boca Chica Boulevard
that borders the NHL (see KOP 3).
KOP 3. Lower Rio Grande Valley National Wildlife Refuge – Pull-off along Boca Chica
Boulevard (2.4 miles southeast from the Project)
KOP 3 is located at a pull-off along Boca Chica Boulevard (SH 4) within the Boca Chica
Unit of the Lower Rio Grande Valley NWR (see KOP 2). The area is very secluded and
characterized as a typical coastal environment, interspersed with miles of beach front, saline flats,
mangrove marshes, shallow bays, and lomas (FWS 2012a). Primary recreational activities within
the tract include beach activities, hiking, and birdwatching. The KOP is also located on the
northern boundary of the Palmito Ranch Battlefield NHL and therefore also represents views from
a portion of this historic area (see KOPs 1 and 2 for additional information on the NHL).
KOP 3 provides a view to the north towards the Project site, which is approximately 2.4
miles from KOP 3 and is located in the foreground/middle ground distance zone. Figure E-3a (in
appendix E) shows the existing view and a visual simulation of this view of the Project from this
location. The existing view is dominated by the dense, green, medium height vegetation along the
edge of the pull-off in the immediate foreground and bright sky and low clouds. The straight, level
horizon line of the coastal mudflats and marshes is visible beyond the vegetation. An area of
shallow, open water is also visible. Although a portion of the sandy pull-off is visible, there are no
structures or other development in the view. Due to the largely natural appearance of the existing
landscape and relative lack of development in this view and other views from this section of SH
4, the visual integrity of the landscape surrounding KOP 3 is relatively high. Although Annova’s
VIA did not apply the scenic quality rating component of the BLM’s VRM methodology, the
existing scenic quality at KOP 3 would appropriately be considered as “low” or possibly
“moderate.” The expanses of flat marshes and low vegetated hills provide little visual variety and
interest among the elements of form, line, color, and texture; however, the water element is a
significant feature that adds interest to the landscape.
Figure E-3a (in appendix E) includes a visual simulation for a daytime view to the north-
northwest from KOP 3. The simulation indicates that the Project facilities would be clearly visible
from this viewpoint silhouetted against the sky above the vegetation in the foreground. Clearing
of vegetation at the Project site would alter the form, line, and color of the vegetation at this site,
although that likely would not be noticeable from KOP 3 because of the viewing distance. The
introduction of new, large, and varied industrial facilities in this largely undeveloped and natural-
appearing area would be noticeable to an observer at this location and could attract the attention
of viewers. Annova’s VIA rated the contrast of the Project within the view of the distant landscape
as moderate to moderately strong. The BLM (1986) guidance for a moderate rating indicates that
the “element contrast begins to attract attention and begins to dominate the characteristic
landscape.” The guidance for a strong contrast is that the “element contrast demands attention,
will not be overlooked, and is dominant in the landscape.” Based on the conditions depicted in the
simulation, the contrast created by the Project would be likely to attract attention and potentially

begin to dominate the view, but would not demand attention nor dominate the view, resulting in
an overall contrast of moderate. A moderate contrast rating is based on viewing distance and
dominant presence of, and partial screening of the view by, vegetation in the immediate
foreground.
(figure E-3b in appendix E) and warm/cold flare events (figure E-3c in appendix E) during daytime
hours for KOP 3. The visual impact from the flaring events is noticeable but reduced by distance
and other visual features, such as the road reflectors, in the foreground. The light from the flare
stacks would be noticeable to a casual observer but would not demand attention in the view.
The visual sensitivity at this location is likely moderate to moderately high. Moderate
sensitivity would apply to travelers on SH 4 who continue past KOP 3 without stopping at the pull-
off to view the landscape. Higher sensitivity would likely apply to travelers who stop to look at
the view or hope to see wildlife using the refuge. Views of the NHL from this KOP largely face
away from the Project and focus to the south, or inward to the core interpretive area of the
battlefield. Given the low to moderate scenic quality, moderate to high viewer sensitivity, and
moderate contrast rating, the potential visual impact of the Project as seen from KOP 3 would be
moderate.
KOP 4. Palmetto Pilings Historic Marker (approximately 5.9 miles east from the Project)
KOP 4 is located at the Palmetto Pilings Historical Marker wayside along Boca Chica
Boulevard (SH 4), near the eastern edge of the Boca Chica Unit of the Las Palomas Wildlife
Management Area (WMA). The pilings, seen from the historical marker, are the remains of the
railroad crossing of the Boca Chica inlet to White’s Ranch on the Rio Grande, constructed between
1864 and 1865 for transport of military supplies (THC 2017b). The Las Palomas WMA was
established to preserve habitat associated with white-winged doves. It is contiguous with the Boca
Chica Unit, and the Lower Rio Grande Valley NWR. Boca Chica Beach borders the unit on the east.
KOP 4 provides a view west to the Project site, which is approximately 5.9 miles from
KOP 4 in the background distance zone. Figure E-4a (in appendix E) shows the existing view and
a visual simulation of this view of the Project from this location. The existing view includes
expanses of low-growing light and medium green vegetation extending to the nearly level horizon.
There are some areas of light tan, barren mudflat interspersed with vegetation in the foreground,
and some clusters of taller, dark green vegetation, including a few palm trees, line portions of the
horizon in the distance. The light gray, stone historical marker and portions of the dark paved
roadway and gravel pull-off are prominent in the immediate foreground. A line of short wood
posts strung with cable extends across the view in the foreground and several taller structures
associated with residences and agricultural operations are visible along the horizon in the
background. Although the light colors of the residential and agricultural structures are somewhat
noticeable, they are not dominant elements in the view because of their distance and low profiles.
The wood posts are noticeable in the view but are not dominant. The predominance of natural
features and the small number of structures in this view and other views from along SH 4 provide
relatively high visual integrity for this portion of the highway. The existing scenic quality at KOP
4 would appropriately be considered as “low” or possibly “moderate.” The expanses of flat

marshes and low vegetated hills provide little visual variety and interest, although the presence of
features with historical context provides some degree of added interest to the view.
Figure E-4a (in appendix E) includes a visual simulation for a daytime view at this location.
This view is looking west toward the Project site. The simulation indicates that the Project would
be visible in the background from this viewpoint. The visible Project components from this
viewpoint would primarily include the two LNG storage tanks and flare stacks. Because of the
viewing distance and color similarity with the existing vegetation, the Project facilities would not
be prominent. The presence of the new facilities may attract some attention from people stopping
to visit the historical marker and surrounding landscape, but the Project would not begin to
dominate the view. A weak contrast rating is appropriate based on the viewing distance, the
existing contrast associated with the highway, and the presence of vertical elements in the
foreground/middle ground and background distances.
(figure E-4b in appendix E) and warm/cold flare events (figure E-4c in Appendix E) during
daytime hours for KOP 4. The visual impact from the flaring events is noticeable but largely
reduced by distance and other visual features, such as the road reflectors, in the foreground. The
light from the flare stacks, particularly for the warm/cold flare, would be noticeable to a casual
observer but would not demand attention in the view.
The viewer sensitivity at this location is moderate to moderately high. Moderate sensitivity
would apply to travelers on SH 4 who continue past KOP 4 without stopping at the wayside to
view the landscape and historical marker. Higher sensitivity would apply to travelers who stop to
look at the view or wildlife using the refuge or those viewing the historical interpretive area. Given
the low to moderate scenic quality and weak contrast introduced by the Project, the Project would
have a low to moderate potential visual impact from this location.
KOP 5. Isla Blanca Park Boat Ramp (6.7 miles northeast from the Project)
KOP 5 is located at the Isla Blanca Park Boat Ramp, which is located near the southern
end of South Padre Island. Isla Blanca Park is administered by Cameron County Parks and
Recreation. The boat ramp is located within the park, and is near an extensive recreational vehicle
park, marina, and other facilities. The Park includes over a mile of beachfront on the Gulf of
Mexico. The boat launch is on the landward side of the southern end of South Padre Island,
providing an entry point for boaters to access the Laguna Madre.
KOP 5 provides a view to the southwest toward the Project site, which is approximately 6.7
miles from KOP 5 and located in the background distance zone. Figure E-5a (in appendix E) shows
the existing view and a visual simulation of this view with the Project from this location during the
daytime. The most prominent element of the existing daytime view is the expanse of deep blue water
of the Lower Laguna Madre stretching from the shore in the immediate foreground almost to the
horizon in the background. The immediate foreground includes a portion of disturbed ground with
some sparse grass and various small structures (e.g., a wooden kiosk, a metal trash can, short wood
posts with signs, a wood bench, a small concrete dock, a short rock jetty, and other signs). A tall,
marine navigation structure protrudes from the water in the foreground and, silhouetted against the

broad, light blue-gray sky, is a prominent element in this view. Several buoys, including two bright
orange ones, are also visible in the water. In the distance, along the generally level horizon, are areas
of low landforms with some low vegetation on the left side of the view and more distant development
with numerous low-profile structures on the right side of the view. The tall structure visible on the
right side of the view, likely an offshore oil platform, is a dominant element silhouetted against the
sky on the horizon. A tall communication tower, also in the right side of the view, extends high
above the horizon, but its thin frame and light gray color is not readily noticeable or a dominant
feature in the view. The combination of marine structures and the broad expanse of open water give
this view moderately high visual coherence and integrity and moderately high scenic quality.
Figures E-5a and E-5d (in appendix E) include visual simulations for daytime and
nighttime views, respectively, from this location to the southwest from KOP 5. The Project
facilities would be visible in both daytime and nighttime views due to unobstructed views of the
horizon as a result of open water and flat terrain between the KOP and the Project. The majority
of the Project facilities would be visible from this viewpoint, silhouetted against the sky above the
water. From this view, the clearing of vegetation at the Project site would not be noticeable due
to the distance from the Project site. The new facilities would be visible and could attract some
attention from viewers at this location. Because of the viewing distance and existing contrast from
other industrial structures visible in the distance, as well as the presence of various structures in
the foreground, however, these facilities would not begin to dominate the landscape. Annova’s
VIA rated the contrast of the Project within the view of the distant landscape as weak to moderate.
Based on the conditions depicted in the simulation, the contrast rating for KOP 5 is weak.
The nighttime view and simulation at KOP 5 (Figure E-5d in appendix E) show ambient
and direct lighting both in the background and foreground viewing distances. The Project would
be silhouetted against the night sky above the horizon from this location. Project elements might
appear faintly noticeable during certain atmospheric and lighting conditions, such as around dusk
or dawn or with bright moonlight. However, other elements in the immediate foreground and
silhouetted above the horizon in the background of this view are more dominant. Lights associated
with the Project would increase the number of lights and lighted elements in this area. However,
these new lights and lighted elements would not add substantially to the amount of light and
number of lighted elements visible along the horizon, and the contrast would be weak.
visual impacts of flare events, Annova modeled daytime worst-case, non-emergency marine flare
events and warm/cold flare events (figures E-5b and E-5c, respectively, in appendix E) and
nighttime worst-case scenario marine flare events and warm/cold flare events (figures E-5e and
5f, respectively, in appendix E) for KOP 5. The visual impact from the daytime flaring event and
the marine nighttime flare event is difficult to detect in the simulations, and minimally visible for
the nighttime warm/cold flare event (figure E-5f). The minimal contrast between the flare and the
bright daytime sky and distance from the viewer result in minimal, if any, additional daytime
impact from the flare events. The presence of multiple lights along the horizon and distance from
the viewer result in minimal nighttime visual impacts from flare events, with a slight elevated
impact from the warm/cold flares over the lower profile marine flare stacks.
The viewer sensitivity at this location is considered high, as it represents a recreational area
on South Padre Island and the Lower Laguna Madre. This public park and boat launch area is

used regularly by a variety of visitors and local residents for recreational and leisure activities that
include boating, fishing, and wildlife watching within the Lower Laguna Madre and surrounding
areas. The Project facilities silhouetted against the sky above the horizon would attract some
attention but would not be a dominant element in views from this area during the day. At night,
the Project would introduce new lights and lighted elements along the horizon line in the distance;
however, Project structures and lighting against the horizon would not substantially reduce the
visual integrity or scenic quality of nighttime views from this location. Although we do not know
the typical orientation of observations from this KOP, recreational viewers would likely focus on
the landscape to the east, which contains the beaches and ocean, rather than to the southwest in the
direction of the BSC and the Project. For these reasons, construction and operation of the Project
would have low visual impact at this location during both day- and night-time conditions.
KOP 6. Port Isabel Lighthouse (5.1 miles northeast from the Project)
KOP 6 is located at the observation deck of the Port Isabel Lighthouse in Port Isabel. The
lighthouse is operated by the City of Port Isabel and is the only lighthouse originally constructed
along this coastal area that is open to the public. Area visitors and local residents come to this
historic lighthouse for recreational and leisure activities that include learning about the history of
the area and viewing the surrounding landscape.
KOP 6 provides a view to the southwest toward the Project site, which is approximately 5.1
miles from KOP 6, and is located in the background distance zone. Figure E-6a (in appendix E)
shows the existing view and a visual simulation of this view with the Project from this location. The
existing view is dominated by expansive urban development interspersed with dark vegetation and
several prominent port, infrastructure, and industrial facilities. This is a modified landscape, with
only the very distant background zone representing natural scenic conditions. The eye is immediately
drawn to the drill platform to the left of the view, as well as other commercial and industrial
developments. The existing scenic quality at KOP 6 would appropriately be considered as “low” due
to extensive development that lacks historical context and limited extent of natural features.
Figure E-6a (in appendix E) includes a visual simulation for a daytime view to the
southwest, from KOP 6. This represents the view from the Port Isabel Lighthouse observation
deck. From this location, the Project would be visible as silhouetted above the flat horizon.
Changes to the Project site from grading and vegetation removal are unlikely to be visible due to
the distance to the Project. While the vertical Project elements would contrast with the horizon
line, the fairly dark and subdued “covert green” color of the facilities would help them recede and
blend with surrounding landscape elements. In the distant background view, the Project would
introduce new industrial elements to the horizon in a portion of the view without any other breaks
in the horizon line. Annova’s VIA rated the contrast of the Project within the view of the distant
landscape as moderate. Based on the conditions depicted in the simulation, the contrast created
by the Project facilities would be subordinate to the existing contrast associated with other vertical
background elements, and dominance of urban and industrial features in the foreground/
middleground distance zones and would not begin to dominate the landscape. Therefore, the
appropriate contrast rating for KOP 6 is weak.
To assess the visual impacts of flare events, Annova modeled worst-case, non-emergency
marine flare events (figure E-6b in appendix E) and warm/cold flare events (figure E-6c in

appendix E) during daytime hours for KOP 6. The visual impact from the marine flaring event is
reduced due to distance and lower profile; however, the warm/cold flare event would be visible
and attract the attention of the casual observer. The addition of the flare would increase the visual
impact of the Project during the periodic active flaring as it provides novel visual content to the
view and would draw attention to the rest of the Project components.
Viewer sensitivity for this KOP is moderately high because of the unique opportunity
provided by this viewing location and the use of KOP 6 for recreation. Overall, the Project would
introduce a small number of new structures that are industrial in character; however, numerous
other industrial structures are also visible in this view of a highly urbanized landscape. Given the
relatively low existing scenic quality, a weak contrast rating, and moderately high viewer
sensitivity, the potential visual impact as seen from KOP 6 would be low to moderate.
KOP 7. Port Isabel High School Tarpon Stadium (4 miles north from the Project)
KOP 7 is in the upper level of the elevated seating at the Port Isabel High School Tarpon
Stadium in Port Isabel, and provides a view looking south toward the Project site. The stadium is
used for activities such as school sports and other events, which occur at night as well as during
the day. Viewers at KOP 7 are typically focused on the athletic fields or the track in the stadium,
which is in the opposite direction of the view south toward the Project.
The Project site is approximately 4.0 miles from KOP 7 and is located in the distant
foreground/middleground zone. Figure E-7a (in appendix E) shows the existing view and a visual
simulation of this view with the Project from this location. The existing view includes the strong
uninterrupted horizontal feature created by the low, vegetated terrain on the horizon line,
accentuated by the narrow band of medium green vegetation between the much lighter colored
water and sky. The foreground/middleground area is occupied by the expanse of dark green trees,
blue-gray open water, bands of low landforms covered with light and medium green vegetation,
and narrow bands of tan barren areas along shorelines. Structures (such as school buildings,
vertical utility structures, fences, athletic field elements) and school buses are dominant elements
in the immediate foreground. Several other large structures are faintly visible in the distance on
the right side of the view protruding above the horizon. Because they are distant, these structures
appear small in scale and very light gray in color and are subordinate and barely noticeable in the
overall view. Although Annova’s VIA did not apply the scenic quality rating component of the
BLM’s VRM methodology, the existing scenic quality at KOP 7 would appropriately be
considered as “moderate” because of the low level of variation in horizontal forms, but presence
of expansive water view from this location. Overall, the expanse and variety of natural features
give this view moderate visual integrity and scenic quality.
Figure E-7a (in appendix E) also provides a visual simulation for a daytime view to the south
from KOP 7. The Project facilities would be visible due to the lack of any screening vegetation or
structures from this location. The vertical lines and varied forms of the Project facilities would be
visible in the distant middleground and silhouetted above the flat horizon. Changes to the Project
site from grading and vegetation removal would likely be unnoticeable due to the distance. The
introduction of new, large, and varied industrial facilities to the nearly unbroken horizon line would
be noticeable to the casual observer at this location and could attract the attention of viewers.
Because of the viewing distance and dominating influence of existing contrast created by structures

and other development elements in the foreground, however, Project facilities would not dominate
the landscape. Annova’s VIA rated the contrast of the Project within the view of the distant
landscape as moderately strong, based primarily on its prominent forms and lines silhouetted above
the horizon and the relative lack of other structures readily noticeable along or protruding above the
horizon. Based on the BLM (1986) guidance for moderate and strong contrast ratings and the
conditions depicted in the simulation, the contrast created by the Project facilities would not
dominate the landscape and the appropriate contrast rating for KOP 7 is moderate.
marine flare events (figure E-7b in appendix E) and warm/cold flare events (figure E-7c in
appendix E) during daytime hours for KOP 4. The daytime visual impact from the flaring events
is largely indistinguishable in the distance from the other Project impacts. Distance, bright daytime
sky, and haze along the horizon as well as presence of multiple vertical structures adjacent to, and
partially obscuring the view of, the Project reduce the additional visual contrast and impact from
the daytime flare events.
Viewer sensitivity at this location is likely a mix of low and moderate. Low sensitivity is
due to the focus of users at this location being toward athletic fields in the stadium and away from
the Project, while moderate sensitivity could apply to viewers who are interested in viewing the
landscape from this elevated location. Overall, the Project would introduce new structures that
appear industrial in character, where no other large industrial structures are easily noticeable in
this view. Because of the moderate contrast introduced by the Project and low to moderate viewer
sensitivity, construction and operation of the Project would have a low to moderate potential visual
impact from this location.
KOP 8. State Highway 48 Pull-off near Bahia Grande Channel (0.6 mile northwest from
the Project)
KOP 8 is located at a pull-off along SH 48 bordering the Laguna Atascosa NWR near the
Bahia Grande Channel. North of this location is the Bahai Grande wetland restoration site, within
the NWR. The approximately 10,000-acre restoration site consists generally of the inundation
areas for Bahia Grande, Laguna Larga, Little Laguna Madre, and the channels connecting these
shallow bays to each other and the BSC (NOAA Fisheries 2016f; FWS 2003). Restoration of the
Bahia Grande began in 2005 with the reintroduction of water from the BSC. While land access to
the site is limited to two highway pull-offs (one off of SH 100 and this one off of SH 48), guided
seasonal bird walks are provided by the refuge staff from the pull-off where KOP 8 is located.
KOP 8 provides a view looking southeast toward the Project site, which is approximately
0.6 mile from KOP 8 and in the near foreground/middleground distance zone. Figures E-8a, E-
8b, and E-8e (in appendix E) show the existing daytime and nighttime views and visual simulations
of these views with the Project from this location, respectively. The view is dominated by the
expanse of varied green, low-growing vegetation extending from the pull-off to the nearly level
horizon. Barren mudflats are interspersed with the vegetation in the foreground, and much of the
horizon is lined with taller, dark green vegetation. No existing structures are visible in the view
shown by the existing conditions in figures E-8a, E-8b, and E-8d (in appendix E). No exposed
lights, lighted elements, reflected lights, or noticeable ambient light in the atmosphere are visible
in the existing nighttime view due to the lack of development in the area. Due to the predominance

of natural features and lack of any encroaching structures in this view, the visual integrity for KOP
8 is high. The scenic quality of this view is low or possibly moderate, however, because there is
little variety of plant forms and color, and a lack of noticeable relief, water, or other landscape
features that may provide interest.
Figures E-8a and E-8e (in appendix E) include simulations of the Project for daytime and
nighttime views, respectively. Figure E-8b (in appendix E) includes a simulation of the Project
with daytime views with an LNG carrier at dock. Due to low ground elevations, changes on the
Project site from grading and vegetation removal might appear somewhat noticeable from this
viewpoint. The simulations indicate that because of the open landscape and lack of tall, screening
vegetation, much of the Project facilities would be visible from this location. The geometric,
angular, and rounded forms of the tall structures, primarily the LNG storage tanks, liquefaction
trains, and flare stacks, would be noticeable elements silhouetted against the sky above the flat
horizon. The straight vertical and horizontal lines of the structures would contrast with the strong
horizontal lines and forms of the vegetation and mudflats and the irregular rounded lines and forms
of the mounded shrubs in the foreground and vegetation lining the horizon in the distance. These
components of the Project silhouetted above the horizon would be dominant and strongly
noticeable elements in the landscape that would likely attract the attention of viewers. Nighttime
simulations show that the Project would introduce new lighting features as vertical elements both
illuminated and silhouetted against the sky, which would dominate the view and demand viewer
attention. The contrast created by the Project would be strong due to the close viewing distance
to it, the strong forms and large scale of the Project facilities, and the lack of existing contrast from
other vertical features or other industrial elements in the landscape.
visual impacts of flare events, Annova modeled daytime worst-case, non-emergency marine flare
events and warm/cold flare events (figures E-8c and E-8d, respectively, in appendix E) and
nighttime worst-case scenario marine flare events and warm/cold flare events (figures E-8f and
8g, respectively, in appendix E) for KOP 8. Flare events would be visible and demand attention
from the casual viewer. Contrast would be moderate to strong as the flares would add a novel
element into the landscape. Nighttime flare events, although anticipated to be rare, would
contribute additional visual contrast with the night sky, providing novel visual input that adds
additional contrast with the industrial lighting and calls further attention to the Project structures.
Overall, the Project would change the character of the view from this KOP from natural to
industrial and reduce the scenic quality from low-moderate to low. The addition of the intermittent
and regular presence of the LNG carriers to the view would increase the already strong contrast of
the views. The Project would introduce new lighting and lighted elements into an otherwise dark
environment. The form and line of large structures silhouetted above the horizon and the addition
of new lights and lighted elements would produce strong contrasts that would substantially reduce
the scenic quality of nighttime views from this KOP.
The viewer sensitivity level at this location is likely a mixture of moderate and high.
Moderate sensitivity would apply to travelers on SH 48 who continue past KOP 8 without stopping
at the pull-off. For travelers interested in stopping along the highway, this pull-off near the Bahia
Grande Channel is one of only a few places available along this stretch of highway to safely pull
off the highway to observe wildlife and the surrounding landscape. This KOP is also representative

of views experienced by people who frequent the general area to fish and boat along the BSC to
the south. Given the low or low-moderate existing scenic quality, moderate and high viewer
sensitivity, and a strong contrast rating, the potential visual impact of the Project as seen from KOP
8 would be moderately high.
KOP 9. Jaime J. Zapata Memorial Boat Ramp (1.4 miles west from Project)
KOP 9 provides a view looking east toward the Project site from the Jaime J. Zapata
Memorial Boat Ramp located on the south side of SH 48 and north of the ship channel. The
Laguna Atascosa NWR is located immediately to the north across the highway from the boat ramp
area. The boat ramp is managed by Cameron County Parks & Recreation Department. This public
boat launch and nearby areas are used regularly by a variety of visitors and local residents for
recreational and leisure activities that include boating, fishing, and wildlife watching. The state
highway is frequently traveled by people for purposes of recreation, leisure, and exploring nearby
historical areas, wildlife refuges, and natural areas.
KOP 9 provides a view to the east toward the Project site, which is approximately 1.4 miles
from this KOP, and is located in the foreground/middleground distance zone. Figures E-9a, E-9b,
and E-9e (in appendix E) show the existing daytime and nighttime views and visual simulations
of this view with the Project from this location. The boat ramp location provides an expansive
view of the nearby waterway, beaches, and marshlands. The existing view from the KOP shows
the parking area and associated facilities, open water, and exposed gravel and sandy shoreline
areas in the immediate foreground. Exposed shoreline and barren areas with low, undulating
dunes, or lomas, mostly covered with dense, dark green vegetation, extend to the horizon.
Structures in the foreground include multiple light posts, trash receptacles, shelters, and signs.
There is a distinct horizon line forming an undulating, horizontal edge between the sky and the
vegetation along the flat landscapes and lomas. The light standards in the immediate foreground
are prominent vertical elements protruding well above the horizon and are silhouetted against the
blue sky. The expanse of gray-blue water, exposed shoreline, and vegetated lomas are prominent
natural features in the view, although there is relatively little visual variety among these elements.
The structures associated with the parking area in the immediate foreground are encroaching
elements that attract viewers’ attention and tend to reduce the visual coherence and integrity of
this view. As a result, the existing scenic quality is appropriately considered moderate.
Figures E-9a, E-9b, and E-9e (in appendix E) include visual simulations for daytime and
nighttime views to the east, from KOP 9. Additionally, figure E-9b includes a simulation of the
LNG carrier at dock with the Project from this location. The daytime simulations indicate that the
Project would be visible in the foreground/middleground distance zone, silhouetted against the
sky, with vertical Project elements contrasting with the horizon and low rolling forms of vegetation
and lomas. Although the silhouetted forms and straight vertical lines would be prominent, the
Project’s overall contrast would be moderate due to the existing contrast created by forms and lines
of elements associated with the parking area in the immediate foreground. In addition, the fairly
dark green color of the Project structures would blend, to a degree, with the surrounding colors in
the landscape (see figure E-9a in appendix E). Although the Project would be co-dominant with
the structures of the parking area, the Project contrast would be greater as viewed from nearby
points without the parking area in the immediate foreground; in such cases, the Project might
appear highly noticeable to viewers and dominate the view, and the contrast could conceivably be

moderately strong. The intermittent and periodic presence of LNG carriers with their angular,
geometric forms, varied lines, and often contrasting colors would slightly increase the contrast in
views (see figure E-9a in appendix E). The nighttime simulation suggests that the Project would
be slightly visible at night from KOP 9, introducing industrial elements into the horizon landscape.
The vertical illuminated structures, however, would be subordinate to the dominant boat ramp
lighting at this KOP. The street lights, in the immediate foreground of this view would appear
more dominant, and the Project contrast would remain moderate. However, visitors sitting at the
beach would have unobstructed views of the Project.
To assess the visual impacts of flare events, Annova modeled daytime worst-case, non-
emergency marine flare events and warm/cold flare events (figures E-9c and E-9d, respectively,
in appendix E) and nighttime worst-case scenario marine flare events and warm/cold flare events
(figures E-9f and 9g, respectively, in appendix E) for KOP 5. The flares would be visible to the
casual observer in all simulated conditions. The daytime impacts are reduced due to distance and
presence of multiple vertical and light-colored structures present in the view. The novel form of
the flame may still attract additional attention to the Project but would not demand attention. The
warm/cold flare event is more likely to attract attention of the casual observer, due to being located
in an area of the view without additional distractions from the flat horizon line. The nighttime
impacts would be moderated by the dominating presence of streetlamps in the view. Distance
would further reduce additional impacts; however, the presence of the flares in the relative dark
background between the foreground structures would draw attention to the presence of the Project.
Viewer sensitivity at this location is likely moderate to high. Users of the boat launch may
immediately leave the area and not be affected by the surroundings, while people using this
location to access the surrounding wetlands for activities such as bird-watching or fishing would
have more unobstructed views and would be sensitive to the intrusion of industrial features. Based
on low existing scenic quality, moderate contrast moderate to high viewer sensitivity, construction
and operation of the Project would result in moderate potential visual impact on the daytime view
from KOP 9.
KOP 10. Palo Alto Battlefield National Historical Park – Visitor Overlook (12.4 miles west
from the Project)
KOP 10 is situated at the interpretive outlook at the visitor center for the Palo Alto
Battlefield National Historical Park located north of Brownsville. This is the only National Park
dedicated to the U.S.–Mexican War, and the Park includes interpretive services documenting the
entire conflict, its origins, and aftermath.
KOP 10 provides a view looking east toward the Project site, which is approximately 12.4
miles from KOP 10, and is in the background distance zone. Figures E-10a and E-10b (in appendix
E) show the existing view and a visual simulation of this view of the Project from this location.
The view includes interpretive signs and a railing at the overlook with low vegetation extending
to the nearly level horizon dominating the existing view. The vegetation exhibits a variety of
textures and shades of green with some areas of yellow and brown intermixed. A few tall, vertical,
pale-gray industrial structures are faintly visible, silhouetted against the sky, along the horizon.
The visitor center overlook focuses viewers’ attention toward the historic battlefield and provides
important information about the history of the site and the surrounding area. The visitor center is

also the start of short walking paths and the Brownsville Historic Battlefield Hike and Bike Trail.
Due to the largely natural appearance of the existing landscape, with few structures affecting the
condition of the view, the visual integrity is high. The scenic quality of this view is low, however,
based on the low diversity of landforms and lack of waterbodies or other features of interest.
Figures E-10a and E-10b (in appendix E) include a visual simulation of the Project for a
daytime view to the northeast from KOP 10. Figure E-10b provides a more focused view towards
the Project, as requested by the NPS. Changes to the Project site from grading and vegetation
removal would appear unnoticeable from this KOP due to distance. From this KOP, the geometric
forms and straight vertical and horizontal lines of the Project’s structures would be barely visible
along the landscape’s horizon, contrasting slightly against the horizontal form and sky. From this
KOP, existing industrial structures that are visible as light gray forms silhouetted against the sky
in several locations would appear taller, but more noticeable than the Project. Because of the
distance, the small scale, and the green color of the structures that would blend with the
surrounding colors in the landscape, the contrast created by the Project would be weak at most.
No nighttime simulations were requested for this KOP. Although the lighted elements of the
Project would likely be visible from this location at night, visitors to the Park are not likely to
utilize the battlefield viewing areas during the night.
marine flare events (figure E-10c in appendix E) and warm/cold flare events (figure E-10d in
appendix E) during daytime hours for KOP 10. The daytime visual impact from the flaring events
is largely indistinguishable in the distance from the other Project impacts. Distance, bright daytime
sky, and vegetation along the horizon as well as the presence of multiple vertical structures of the
Project would reduce any additional visual contrast and impact from the daytime flare events.
Viewer sensitivity from this KOP would be high because the overlook focuses recreational
visitors’ attention toward the historic battlefield and provides important information about the
history of this site and the surrounding area. Therefore, viewers would be sensitive to changes in
the landscape that would detract from the historical characteristics of the view. From this KOP,
the Project would appear subordinate in the broader landscape and would be unlikely to attract
viewers’ attention. Construction and operation of the Project would result in a low potential impact
on the view from KOP 10.
In general, Annova’s Visual Impact Assessment showed that visual impacts can potentially
occur at all KOPs and ranged from low to moderate at most locations. However, the visual impacts
at KOP 8 at the State Highway 48 pull-off near Bahia Grande Channel would be moderately high
at this one isolated location. In considering the totality of these impacts, we conclude that visual
impacts from the Project would only be of moderate impact and not be significant.
4.8.6 Coastal Zone Management
The CZMA calls for the “effective management, beneficial use, protection, and
development” of the nation’s coastal zone and promotes active state involvement in achieving
those goals. As a means to reach those goals, the CZMA requires participating states to develop
management programs that demonstrate how those states will meet their obligations and
responsibilities in managing their coastal areas.

The Project would be located within the Texas coastal zone boundary. The Combined
Coastal Management Program and FEIS for the State of Texas identifies 16 Coastal Natural
Resource Areas. The Project area contains four of these areas: coastal wetlands, special hazard
areas, tidal sand or mud flats, and waters under tidal influence. The federal CZMA requires a
federal consistency review for actions taken or authorized by federal or state agencies that may
affect an approved state coastal zone. For oil and gas projects within the Texas coastal zone
boundary, the RRC administers the CZMA and is the lead state agency that performs federal
consistency reviews for such facilities.
Annova submitted a request to the RRC on July 21, 2016, for a determination of
consistency with the Texas Coastal Management Program. On August 30, 2017, Annova
submitted a supplemental filing to their July 21, 2016 request. This supplemental filing updated
text previously filed with the RRC to reflect changes to the Project design and impacts on waters
of the U.S. A determination from the RRC that the Project is consistent with the Texas Coastal
Zone Management Plan must be received before we could issue a notice to proceed with
constructing the Project. Annova has not yet obtained this authorization, therefore, we
recommend that:
• Prior to construction, Annova should file with the Secretary a determination

from the Texas Coastal Coordination Advisory Committee that the Project is
consistent with the laws and regulations of the state’s Coastal Zone
Management Program.
The FERC would not approve construction until all federal authorizations, including a
consistency determination with the CZMA, have been granted.
4.8.7 Conclusion
Construction and operation of the Project would permanently convert about 412 acres of
undeveloped land along the BSC to an industrial use but would not conflict with any zoning laws
or future plans of the BND or Cameron County. Construction and operation of the Project would not
be expected to affect existing or planned residential or commercial land uses and would not be
expected to restrict land use on adjacent properties or displace any residences or businesses. The
Project site was formally part of a wildlife preserve managed by the FWS under a lease agreement
with the BND, however that lease has expired and there are currently no public lands directly
affected by the site. The proposed access road would cross a portion of the Lower Rio Grande
Valley NWR which would require an appropriateness determination and a compatibility
determination from the FWS, for which a decision has not been made.
Based on our analysis, Project construction and operation would not result in significant
impacts on current land use, visual impacts, and recreation. However, in its comments on the draft
EIS, the NPS indicated that it believes the visual effects of the Project on Palmito Ranch Battlefield
NHL and Palo Alto Battlefield NHP would be adverse.

4.9 SOCIOECONOMICS
The new facilities for the Project would be located entirely within Cameron County, Texas.
Cameron County is part of the Brownsville-Harlingen-Raymondville Consolidated Statistical
Area, which also includes Willacy County to the north. These two counties form the primary
socioeconomic impact area for this analysis. Cities and towns in the vicinity of the Project include
Brownsville, Cameron Park, Los Fresnos, Port Isabel, Laguna Heights, Laguna Vista, Long Island,
and South Padre Island.
Cameron County is located in the southeast corner of the Lower Rio Grande Valley. The
Lower Rio Grande Valley includes Cameron, Hidalgo, Willacy, and Starr Counties, which lie
along the South Texas border, separated by the Rio Grande River from the Mexican state of
Tamaulipas. These four counties along with the neighboring Mexican cities of Matamoros,
Reynosa, and Rio Bravo have a total combined population of approximately 2.7 million
(Brownsville Economic Development Council 2015).
4.9.1 Population
Cameron and Willacy Counties had estimated populations of 420,392 and 21,903 in 2014,
respectively (see table 4.9.1-1). The population in both counties increased between 2010 and 2014
at a slower rate than the state of Texas as a whole, with Willacy County actually losing population
over this period. The population in Cameron County increased at a slightly faster rate than the
statewide average from 2000 to 2010, with Willacy County growing at about half the statewide
average. Population is projected to increase statewide and in both counties over the next two
decades (Texas State Data Center 2014). Projected increases as a percentage of existing population
in both counties are expected to be larger than the statewide average increase (see table 4.9.1-1).
TABLE 4.9.1-1
Population by County and State
Population Change Projected Population

(Percent) Change (Percent)
2014 Population
2014 Density (persons/ 2000 to 2010 to 2010 to 2020 to
Geographic Area Population square mile) 2010 2014 2020 2030
Cameron County 420,392 471.9 21.2% 3.5% 14.3% 13.8%
Willacy County 21,903 37.1 10.2% -1.0% 12.0% 10.5%
State of Texas 26,956,958 103.2 20.6% 7.2% 8.3% 6.4%
Sources: Texas State Data Center 2014; U.S. Census Bureau 2000, 2016a
Cameron County is more densely populated than Willacy County and the state of Texas,
with almost 5 times as many people per square mile than the state average (table 4.9.1-1). This
primarily reflects the presence of the cities of Brownsville and Harlingen, which combined, had a
total estimated population of 248,960 in 2014 (U.S. Census Bureau 2016a).
The city of Brownsville is the closest large city to the Project, with an estimated 2014
population of 183,046 (U.S. Census Bureau 2016a). Other nearby municipalities include Los
Fresnos, South Padre Island, La Feria, and San Benito, with respective estimated 2014 populations
of 6,447, 2,889, 7,308, and 24,506 (U.S. Census Bureau 2016a). The nearby municipalities of Port
Socioeconomics 4-128
Isabel and Laguna Vista had total respective estimated populations of 5,033 and 3,197 in 2014
(U.S. Census Bureau 2019). According to comments received on the draft EIS, the gated
community of Long Island Village has more than 2,000 residents.
The Rio Grande Valley is also home to a large seasonal winter population, with retirees
temporarily relocating to the region from their homes mainly in the Midwest and Canada. An
estimated 53,000 households temporarily relocated to the region between November 1, 2013, and
March 31, 2014 (the 2013-2014 season), the majority of which own a seasonal residence, mainly
mobile homes or recreational vehicles (RVs) (The University of Texas-Pan American 2014).
Project construction would result in a short-term increase in population in the Project area.
Construction is expected to be completed over a 48-month period, with an average of 700 workers
employed on-site during this period. A total of 1,200 workers would be employed during peak
construction, which is expected to last 6 months starting mid-way through the second year.
The duration of each worker’s employment would vary depending on individual skillsets
and Project needs, with workers moving in and out of the Project as it advances through
construction. A management team would likely be employed for the duration of construction, with
the remainder of the workers hired during construction likely employed for shorter periods. Very
few, if any, of the non-local workers employed during the construction phase of the Project are
expected to permanently relocate to the Project area or be accompanied by their families.
An average of 253 non-local workers (36 percent) are expected to be employed to perform
the specialized jobs needed to complete the Project, while the remaining 447 workers (64 percent)
are expected to be local hires from Cameron County, with a much smaller share potentially residing
in Willacy County. During peak construction, up to 780 non-local workers (65 percent of the total
labor force) may temporarily relocate to the region. The temporary relocation of non-local workers
during average and peak construction conditions would be equivalent to 0.1 percent and 0.2
percent of the existing population in Cameron County. These potential impacts on the regional
population are expected to be short-term and minor.
Operation and maintenance of the Project is expected to require approximately 165

personnel when fully operating. Annova anticipates that approximately 110 of these positions
would be filled by non-local workers who would permanently relocate to the area. The relocation
of approximately 110 workers and their families to the Project area is not expected to have a
noticeable effect on the population in the area, based on the existing population sizes.
4.9.2 Economy and Employment
A summary of economic information for 2014 is presented in table 4.9.2-1. The statewide
annual unemployment rate in Texas (5.1 percent) was lower than the U.S. average (6.2 percent) in
2014. Annual unemployment rates in Cameron and Willacy Counties were 8.3 percent and 12.3
percent, respectively, which is noticeably higher than the state and national averages (table 4.9.2-1).
Statewide per capita income in 2014 in Texas ($45,699) was similar to the national per
capita ($46,409). Per capita income in Cameron and Willacy Counties was equivalent to just 55
percent and 56 percent of the state per capita in 2014, respectively, with per capita incomes of
$25,211 and $25,480 (table 4.9.2-1). Based on 2014 data by U.S. Bureau of Economic Analysis
4-129 Socioeconomics
(2015a), the top three economic sectors in the U.S. by employment were: government and
government services; health care and social assistance; and retail trade. These sectors were also
the major employers statewide in Texas, as well as Cameron and Willacy Counties (table 4.9.2-1).
TABLE 4.9.2-1
Economic Characteristics, 2014

Unemploy- Percent of
Civilian Labor ment Rate Per Capita State/US Per
State/County Force a/ (Percent) a/ Income a/ Capita b/ Top Economic Sectors by Employment c/
Texas 13,112,000 5.1 $45,669 99% Government (12.4%), Retail Trade
(9.7%), Health Care (9.5%)
Cameron 167,645 8.3 $25,211 55% Health Care (19.9%), Government
(16.8%), Retail Trade (11.7%)
Willacy 7,250 12.3 $25,480 56% Government (20.0%), Retail Trade
(8.8%), Health Care (8.3%)
United States 155,922,000 6.2 $46,049 100% Government (12.9%), Health Care
(11.2%), Retail Trade (10.1%)
a/ Civilian labor force, unemployment rate, and per capita income are annual average figures for 2014.
b/ County per capita income is shown as a percent of the corresponding state average; the state figure is shown as a percent
of the national average.
c/ Top industries by employment are identified from annual data compiled for 2014 by the U.S. Bureau of Economic Analysis.
The full names of the identified sectors are: government and government services; health care and social assistance; and
retail trade. Percentages indicate the share of total employment that each sector accounts for.
Source: U.S. Bureau of Economic Analysis 2015a, 2015b, U.S. Bureau of Labor Statistics 2015a, 2015b
Ernst & Young (2015) prepared an economic impact analysis of the Project on behalf of
Annova. Annova estimated that it would spend $3 billion to construct the Project, of which an
estimated $1.5 billion would be spent on construction of the Project and shared infrastructure in
Texas, with $1.5 billion spent elsewhere. Project expenditures in Cameron County would include
as estimated $130 million on construction materials. Materials expected to be purchased locally
may include concrete, sand, gravel/rock, lumber, erosion and sediment control devices (e.g., silt
fences, erosion control blankets, seeding, mulch), personal protective equipment, welding
consumables (gases, rods, etc.), and other miscellaneous items and services.
Project expenditures would generate economic activity and support employment and
income elsewhere in the state and local economy through the multiplier effect, as initial changes
in demand “ripple” through the local economy and support indirect and induced impacts. Indirect
and induced impacts are defined as follows:
• Indirect impacts are generated by the expenditures on goods and services by
suppliers to the construction project. Indirect effects are often referred to as
“supply-chain” impacts because they involve interactions among businesses.
• Induced impacts are generated by the spending of households associated either
directly or indirectly with the project. Workers employed during construction, for
example, use their income to purchase groceries and other household goods and
services. Workers at businesses that supply the facility during construction or
operation do the same. Induced effects are sometimes referred to as “consumption-
driven” impacts.
Ernst & Young (2015) developed estimates of total (direct, indirect, and induced) economic
impact for Cameron County and the State of Texas. These estimates were developed using
separate IMPLAN models for each geographic area and were based on projected spending.
Statewide, construction of the Project was estimated to support 2,753 total jobs, $1.1 billion in
labor income, and $3.9 billion in economic output (table 4.9.2-2). The average annual wage of
workers hired directly to support construction of the Project was estimated to be the equivalent of
$77,220, or $6,435 per month. In Cameron County, the Project was estimated to support 2,011
total jobs, $688.2 million in total labor income, and $3.0 billion in associated economic output.
(Ernst & Young 2015). These estimates are one-time economic impacts that would be generated
during the 48-month construction period.
TABLE 4.9.2-2
Estimated One-Time Economic Impacts of Project Construction

Type of Impact Average Employment Labor Income ($ million) Output ($ million)
Texas Statewide Impacts
Direct 675 $323.8 $1,545.5
Indirect 1,132 $591.2 $1,795.9
Induced 946 $183.5 $527.5
Total a/ 2,753 $1,098.5 $3,868.9
Cameron County Impacts
Direct 447 $245.3 $1,423.3
Indirect 993 $368.7 $1,373.7
Induced 571 $74.1 $228.5
Total a/ 2,011 $688.2 $3,025.5
a/ Columns may not sum due to rounding
Source: Ernst & Young 2015
Ernst & Young (2015) also developed estimates of annual economic impacts associated
with operation and maintenance of the Project. Operation and maintenance of the Project would
require 165 personnel once all six liquefaction trains are fully operating, as indicated in table 4.9.2-
3. This direct employment would generate approximately $17.3 million in annual labor income in
Cameron County, with an estimated average salary per worker of $105,000, including benefits
(Ernst & Young 2015). Operations and maintenance was estimated to support 446 total (direct,
indirect, and induced) jobs in Cameron County, $30.8 million in total labor income and $522
million in economic output. Statewide, the Project was estimated to support 2,855 total jobs,
$334.3 million in labor income, and $1.2 billion in economic output annually.
TABLE 4.9.2-3
Estimated Annual Economic Impacts of Project Operation

Type of Impact Average Employment Labor Income ($ million) Output ($ million)
Texas Statewide Impacts
Direct 165 $17.3 $463.6
Indirect 1,185 $244.2 $478.0
Induced 1,504 $72.7 $208.9
Total a/ 2,855 $334.3 $1,150.6
Cameron County Impacts
Direct 165 $17.3 $463.6
Indirect 106 $7.8 $40.9
Induced 175 $5.7 $17.5
Total a/ 446 $30.8 $522.0
a/ Columns may not sum due to rounding.
4.9.2.1 Ports
The Port of Brownsville handled an estimated 9.1 million tons of cargo in 2015, the highest
amount in the last 10 years (Port of Brownsville 2016). Commodities moving through the Port
included steel, aluminum, lumber, minerals, gasoline, diesel, and windmill components. More
than 230 companies were located in the BND in 2012 (Martin Associates/John C. Martin
Associates, LLC [Martin Associates] 2012). According to a study by Martin Associates (2012),
activity at the Port of Brownsville contributed an estimated $926.7 million to the regional economy
in 2011, with direct employment of 4,393 jobs and total (direct, indirect, and induced) employment
of 11,230 jobs in the region.
The Port of Port Isabel is located approximately 3 miles west of the Brazos-Santiago Pass
and is primarily accessed from the BSC. Due to the location of the entrance to Port Isabel, the
Port of Brownsville commercial vessel traffic data recorded by the harbor master includes data for
Port Isabel (Bearden 2015). The Port of Port Isabel has five business and industry lessees,
including an offshore pipe manufacturer, a freezer food packing operation, federal administrative
buildings, and seven shrimp boats; and handled approximately 13,000 tons of cargo in 2014
(Bearden 2015).
Construction of the Project is expected to indirectly support jobs and industries associated
with the Port of Brownsville, with a portion of the indirect employment and labor income
supported during construction expected to occur with suppliers and support vessel companies who
regularly do business with port industries and are equipped to serve the needs of the Project during
construction (Ernst & Young 2015). The Port of Port Isabel is less likely to be affected by Project
construction due to its much smaller size.
Annova would lease the Project site from the BND. Lease payments and property taxes
paid to the Brownsville Navigation District would generate revenues during the Project’s
operation. As with the Project’s construction, a portion of the indirect employment and labor
income estimated to be generated by the Project would occur with suppliers and transportation
related companies who regularly do business at the Port of Brownsville and are equipped to serve
the needs of the Project during operation (Ernst & Young 2015). The Port of Port Isabel may also
be positively affected by operation of the Project, but the majority of Project impacts on local area
ports would be expected to be on the Port of Brownsville.
4.9.2.2 Recreation and Tourism
Recreation and tourism contribute to state and local economies. Visitors generate local
revenue and support employment and income through spending on accommodations, food, local
transportation and gas, arts, entertainment, recreation, and other retail purchases. In 2014, travelers
spent an estimated $70.6 billion in Texas, including $804 million in Cameron County and $26
million in Willacy County (table 4.9.2-4). In 2014, Cameron County ranked 11th out of 254 Texas
counties in terms of total annual visitor spending (Dean Runyan Associates 2015).
Travel-related employment accounted for about 3.9 percent of total employment in Texas,
4.5 percent in Cameron County, and 2.4 percent in Willacy County. These estimates developed
by Dean Runyan Associates (2015) include business, as well as leisure travel, and do not
distinguish between the two. However, separate studies found that leisure travel accounted for 94
percent of travel to and within Cameron County measured in visitor days, and 73.3 percent of all
travel to and within Texas (D.K. Shifflet & Associates, Ltd. 2015a, 2015b).
TABLE 4.9.2-4
Tourism-Related Economic Impacts by County and State

Employment (Jobs Earnings ($ million)
Travel Spending Travel as a Travel as a %
Geographic Area ($ million) Travel % of Total Travel of Total
Cameron County $803.5 8,480 4.5% $186.3 2.9%
Willacy County $26.4 150 2.4% $3.7 1.6%
Texas $70,594.0 629,700 3.9% $21,781.0 2.3%
Source: Dean Runyan Associates 2015
Primary attractions in the region include beach and waterfront usage, visiting national and
state parks, wildlife viewing, and other outdoor sports, including fishing, biking, and sailing (D.K.
Shifflet & Associates 2015). Nature tourism in the region includes birding, with the Lower Rio
Grande Valley (Cameron, Hidalgo, Willacy, and Starr Counties) identified as the number two
birdwatching destination in North America (Mathis and Matisoff 2004). Nature tourism in the
Valley supported an estimated 6,613 total (direct, indirect, and induced) jobs and $163 million in
total labor income in 2011 (Texas A&M University 2012). The majority of the visitors surveyed
as part of this study were most likely birders, as data were collected at seven locations, five of
which were designated birdwatching sites, with additional survey data collected at a birding
festival in Harlingen (Texas A&M University 2012).
Existing recreational resources in the vicinity of the Project site are discussed in section
4.8 of this EIS. Recreational resources include birding sites, such as the World Birding Center and
part of the Great Texas Birding Trail; recreational fishing locations, such as the Jaime J. Zapata
Memorial Boat Ramp Fishing Pier and Kayak Launch Area; the Laguna Atascosa NWR and Lower
Rio Grande Valley NWRs; the South Bay Coastal Preserve; the Padre Island National Seashore;
and three historic battlefields (see section 4.8). As discussed in sections 4.8.4.2, 4.8.5.2, and
4.11.12, the greatest impact would be on the southern edge of the Laguna Atascosa NWR,
including a popular birding stop along SH 48, as a result of noise during construction and visual
impacts during operation.
In addition, South Padre Island, a major tourist destination known nationally for its
beaches, is heavily developed with hotels/motels, retail shops, and entertainment venues. Tourism
and tourism-related industries are the main economic activities on the island, with more than a
million visitors annually, and total estimated visitor spending of $360 million in 2014 (Aaron
Economic Consulting 2015). As discussed in section 4.8, Project construction and operation
would not affect beachgoers visiting South Padre Island because the beaches are on the ocean side
of the island, facing away from the Port of Brownsville and the Project site.
The City of South Padre Island and the COE work together to use dredged sand from the
Brazos-Santiago Pass to nourish the South Padre Island beaches (Trevino 2016). Dredging in the
BSC conducted for the Project is not expected to displace any sand that would otherwise be used
for South Padre Island beach nourishment (i.e., the Project would not interfere with existing
sources of sand used for beach nourishment). Annova has indicated that it is evaluating the
potential for beneficial use of dredged and excavated material (Black & Veatch 2016f).
Impacts on recreational resources and use during Project construction and operation are
discussed in section 4.8. Project-related impacts from construction and operation are generally
expected to be short-term and site-specific and are not expected to affect regional tourism patterns
or the overall level of visitation to the region.
4.9.2.3 Conservation Initiatives
Comments received on the draft EIS expressed concern that the EIS failed to address the
financial impact of past or ongoing local, state, and federal investments in local ecological
initiatives, including the Lower Rio Grande NWR, Laguna Atascosa NWR, Loma Ecological
Preserve, and Bahia Grande Restoration. These investments, the commenter notes, are indicative
of the social and cultural values that citizens and government organizations assign to the
preservation of native land and habitat. While the EIS does not quantify past or ongoing local,
state, and federal investments in conservation of native habitat and wildlife species, these
investments and associated efforts are implicitly recognized in the baseline environmental
characterizations provided on a resource-by-resource basis in the EIS. Impacts on native and other
habitats, wildlife and aquatic resources, and special status species are discussed in sections 4.3 to
4.7. Impacts on public and conservation lands are addressed in section 4.8.
4.9.2.4 Commercial Fishing
Commercial fishing near the Project mainly takes place in the Gulf of Mexico, with some
fishing also taking place in estuarine waters, along with shrimp boats that trawl in the BSC for
marketable bait shrimp. The Ports of Brownsville and Port Isabel together were the 12th largest
port in the Gulf of Mexico by landing weight in 2014 and the second largest based on value. A
total of 12.1 million pounds were landed in 2014, with a landed value of $84.2 million (in 2014
dollars) (National Ocean Economics Program 2016a). The main catch landed at the Ports of
Brownsville and Port Isabel is shrimp, almost all of which is caught offshore in the Gulf of Mexico.
Shrimp boats are prohibited from fishing in many of the area’s estuarine waters to protect
seagrasses and because few areas are deep enough for trawling (Ferguson 2015). Landed weight
at the Ports of Brownsville and Port Isabel fluctuates from year-to-year, but has generally declined
since 2009, with the largest decrease occurring from 2013 to 2014, with a drop of 8.6 million
pounds (from 20.7 million pounds to 12.1 million) (National Ocean Economics Program 2016b).
The commercial fishing that does occur in the estuarine waters of Cameron and Willacy
Counties is dominated by bait fisheries, with a small black drum (Pogonias cromis) commercial
fishery also present (Fisher 2015). The bait fisheries are almost exclusively shrimp, with most
shrimping occurring in and around the Intracoastal Waterway where the water is deep enough for
the gear to deploy (Fisher 2017). In 2013, the total commercial fish catch in estuarine waters of
Cameron and Willacy Counties weighed approximately 0.7 million pounds, accounting for about
3 percent of the total catch of 20.7 million pounds landed at the Ports of Brownsville and Port
Isabel that year (Fisher 2015).
The total shrimping fleet operating out of the Ports of Brownsville and Port Isabel has
decreased from a high of around 350 vessels in the 1990s to approximately 160 vessels in the late
2000s (Nelsen 2008). The majority of the shrimping fleet in the Project area docks along the BSC,
primarily in the Port of Brownsville Fishing Harbor. A recent survey conducted by the Port of
Brownsville identified a total of 127 shrimp vessels operating out of the Port of Brownsville
Fishing Harbor (Rosenbaum 2016). Approximately 50 shrimp boats dock in marinas in or near
Port Isabel (Bearden 2015).
Dredging activities during Project construction would temporarily affect those shrimpers
who operate adjacent to the Project site. Annova estimates that in-water dredging would require
approximately 176 working days. Temporarily displaced shrimpers would be able to trawl
elsewhere in the BSC or nearby Gulf of Mexico. Access to the portion of the BSC adjacent to the
Project site would be restored following the completion of dredging, subject to any security
measures in place while LNG carriers are present. Construction barge traffic is not expected to
affect the passage of shrimp boats or other commercial fishing vessels through the BSC.
Commercial fishermen who dock along the BSC may experience delays when LNG
carriers are making ports of call at the Project site. The presence of an LNG carrier could delay
commercial fishing vessels leaving or returning to the docks at the Port of Brownsville Fishing
Harbor. In addition, for safety reasons, the shrimp boats that trawl for bait shrimp in the BSC may
be required to delay or postpone shrimping activities when an LNG carrier is moving through the
fairway due to the moving safety zone located around the LNG carriers (see section 4.9.10.2).
Annova estimates that up to 125 LNG carriers per year would visit the Project once fully
operational. Potential impacts on fishery resources are discussed in section 4.6 of this EIS.
4.9.3 Property Values
The Project is not expected to affect surrounding residential or commercial property values.
Presently undeveloped, the Project site is located entirely on property owned by the Brownsville
Navigation District and designated for industrial use. Factors expected to influence the potential
for a facility to impact property values include the presence of similar industrial or commercial
uses and the distance to the potentially affected properties. Visual impacts, noise, traffic
congestion, and odors have been identified as conditions with the potential to affect property values
(Yellow Wood Associates 2004). Industrial and similar developments have been found to affect
property values within an approximate 2-mile radius (Yellow Wood Associates 2004).
Land in the vicinity of the Project is generally undeveloped and natural, with the exception
of dredged material placement areas adjacent to the site on the east and west borders. The
surrounding area is generally flat to very gently rolling, and consists mainly of shallow
waterbodies, mudflats, and marshes. Because the landscape is generally flat and open, tall
structures are often visible from far distances in the region (see section 4.8.4). While these factors
suggest the potential for impacts on residential property values, the closest residences to the Project
site boundary are located more than 2 miles from the Project, with the nearest residences located
approximately 2.3 miles to the south, on County Road 199, off of SH 4. These residences are
separated from the Project site by the Lower Rio Grande Valley NWR. The next closest residential
developments are located from about 4.7 to 5.1 miles northeast of the Project site and include Port
Isabel, Laguna Heights, and Long Island. As noted in section 4.8.2, no residential areas or
subdivisions are planned for development within a 0.25-mile radius of the site, and the closest area
zoned for residential use by the City of Brownsville is located more than 9 miles southwest of the
Project site. As a result, the Project is not expected to affect residential property values.
The only planned commercial development located within 0.25 mile of the Project site is
another potential LNG facility and export terminal proposed by Rio Grande LNG, LLC, and
located on the north side of the BSC. A third potential LNG facility, proposed by Texas LNG
Brownsville, LLC, would also be located on the north side of the ship channel, approximately 2
miles northeast of the Project site. Development of the proposed Annova facility is not expected
to affect the value of these properties or potential developments, or the value of other surrounding
commercial property owned by the BND.
4.9.4 Construction Payroll and Material Purchases
Annova plans to invest approximately $3 billion to construct the Project and develop the
surrounding infrastructure, with in-state construction costs expected to total $1.546 billion (Ernst
& Young 2015). The Project would have an estimated statewide total construction payroll of
approximately $323.8 million over the 48-month construction period. As noted in section 4.9.2,
an estimated $130 million would be spent on construction materials within Cameron County.
Once construction is complete, the Project would generate an estimated annual payroll of
$17.3 million during operation. Ernst & Young (2015) estimate that operation of the Project would
involve $446 million in annual expenditures, with $330 million of these purchasers from Texas
suppliers. The majority of these in-state purchases are expected to be for utilities ($152 million)
and pipeline transportation ($150 million).
4.9.5 Tax Revenues
Revenues and expenditures for fiscal year (FY) 2015 are presented for Cameron County in
table 4.9.5-1. Taxes were the main source of revenue in Cameron County, followed by
Intergovernmental revenue, accounting for 53 percent and 25 percent of total revenues,
respectively. Total assessed values for real property and personal property in Cameron County in
FY 2015 were $14.346 billion and $2.217 billion, respectively, for a combined total of about $16.5
billion. The property tax rate was $0.399291 per $100 assessed taxable valuation, and the total
property tax levy was $66.1 million (Cameron County 2016).
The Project site is owned by the BND, a political subdivision of the State of Texas.
Property taxes for BND properties are billed and collected by Cameron County for a fee and
remitted to the BND. Annova would lease the Project site from the BND, with property taxes
charged against improvements on Port of Brownsville property and the value of the leasehold.
Improvements on BND land are not subject to city property taxes (BND 2015b).
TABLE 4.9.5-1
Revenues and Expenditures in Cameron County for FY 2015

Category Revenues/Expenditures ($ million)
Taxes $65.4
Licenses, Permits, Charges, Fees, and Fines $20.1
Intergovernmental Revenue $30.9
Other Revenue $6.8
Total Revenue $123.2
General Government $18.5
Public Safety $68.8
Highways and Streets/Public Works $11.7
Health and Welfare $19.1
Other Expenditures $18.6
Total Expenditures $136.8
Sources: Cameron County 2016
Construction of the Project would generate an estimated $192 million in state and local
taxes, with approximately 60 percent of this total paid directly by Annova (Ernst & Young 2015).
This total estimate ($192 million) also includes estimated state and local taxes that would result
from economic activity supported elsewhere in the state economy (indirect and induced effects),
with indirect and induced activity estimated to generate $50.1 million and $15.6 million of the
total, respectively (Ernst & Young 2015).
The facility would be located in an unincorporated part of Cameron County that is not
subject to local sales taxes. As a result, purchases of construction materials and facility equipment
would not generate local sales tax revenues for the county. However, according to Ernst & Young
(2015), Project construction would still generate approximately $17 million in local taxes for
Cameron County, with the majority of this total expected to be generated by taxes on indirect
($11.5 million) and induced ($2.3 million) economic activity.
Operation of the Project would also generate state and local tax revenues, with total (direct,
indirect, and induced) economic activity supported by Project operation estimated to generate an
estimated $13.5 million and $47.8 million in annual state and local tax revenues, respectively (table
4.9.5-2). These estimates include approximately $34.2 million in state and local tax revenues that
would be generated in local jurisdictions in Cameron County, including the Cameron County
government, City of Brownsville, and the BND. Direct property tax payments to the Brownsville
Navigation District are expected to account for 77 percent ($24.2 million) of the estimated
payments to local jurisdictions in Cameron County (Ernst & Young 2015).
Annova had initially explored the option of obtaining property tax abatement agreements
from the Point Isabel Independent School District (ISD) and Cameron County; however, the Point
Isabel ISD did not approve an abatement agreement for the Project (Chapa 2015). Annova
discontinued exploring a property tax abatement with Cameron County. As a result, no tax
abatements would apply to the Project.
TABLE 4.9.5-2
Estimated Annual State and Local Tax Revenues by Tax Type

Estimated Annual Tax Revenues ($000) a/
Tax Type Direct Indirect Induced Total
State Taxes
Sales and Excise Tax $587 $8,269 $2,463 $11,319
Texas Margin Tax – $1,016 $302 $1,318
Other State Taxes $44 $624 $186 $854
Total State Taxes $631 $9,909 $2,951 $13,491
Local Taxes
Property Taxes $33,681 $8,861 $2,639 $45,181
Other Local Taxes $78 $1,941 $578 $2,597
Total Statewide Local Taxes $33,759 $10,802 $3,217 $47,778
Total State and Local Taxes $34,390 $20,711 $6,168 $61,269
a/ Tax estimates are based on estimated total (direct, indirect, and induced) economic activity supported
by operation of the Project.
4.9.6 Housing
Available housing is summarized by geographic area in table 4.9.6-1 using estimates for
2014, as prepared by the U.S. Census Bureau (2016b, 2016c). The Census Bureau defines a
housing unit as a house, apartment, mobile home or trailer, group of rooms, or single room
occupied or intended to be occupied as separate living quarters. The rental vacancy rate in
Cameron County was higher than the state average, with almost 5,000 housing units available for
rent, approximately 1,300 of which were located in the city of Brownsville (table 4.9.6-1).
TABLE 4.9.6-1
Housing
Housing Units 2014 Hotels and Motels 2015
For Seasonal, Number of RV

Total Rental Units Recreational, or and Mobile
Housing Vacancy Available Occasional Number of Number of Home Parks
Geographic Area Units Rate for Rent Use a/ Facilities Rooms 2015 b/
Texas 10,187,189 8.5 318,661 241,679 4,771 415,485 na
Cameron County 144,180 11.0 4,943 10,736 103 6,911 110
Willacy County 7,073 8.1 98 605 6 198 4
City of Brownsville 55,618 6.3 1,283 1,706 36 1,649 25
na = not available
a/ Housing units for seasonal, recreational, or occasional use are generally considered to be vacation homes. They are
not included in the estimated number of housing units available for rent.
b/ RV and mobile home parks are counted together because most parks have a mix of both.
Sources: Marchex, Inc. 2015, Source Strategies 2016b, The Winter Texas Connection 2015, U.S. Census Bureau 2016b, 2016c
Data on hotels and motels are also presented in table 4.9.6-1. Almost 7,000 hotel rooms
are located in Cameron County, approximately 1,650 of which are located in the city of
Brownsville. More than half of the hotel rooms in Cameron County are located in South Padre
Island. The supply and availability of hotel and motel rooms varies seasonally. Viewed by quarter,
5-year average hotel occupancy rates in Cameron County (2011 to 2015) ranged from 41.2 percent
in the fourth quarter to 61.7 percent in the third quarter, with the estimated number of rooms
typically unoccupied and available for rent ranging from approximately 2,900 (third quarter) to
about 3,375 (fourth quarter), with an annual average of 3,200 available rooms (Source Strategies
2016a). In Brownsville, 5-year average hotel occupancy rates (2011 to 2015) ranged from 53.6
percent (fourth quarter) to 65.0 percent (third quarter), with the estimated number of rooms
typically unoccupied and available for rent ranging from approximately 560 (third quarter) to about
720 (fourth quarter), with an annual average of approximately 680 available rooms (Source
Strategies 2016a).
Temporary accommodation is also available in the form of RV and mobile home parks in
the Project vicinity. Comprehensive data are not available for these types of resources, but
information compiled by Annova indicates that an estimated 110 RV and mobile home parks are
located in Cameron County, with 25 of these parks located in Brownsville (table 4.9.6-1).
According to a study of Winter Texans by the University of Texas-Pan American (2014), the
average RV and mobile home park in the Rio Grande Valley region has approximately 193 sites,
with RV sites comprising an average of 61 percent or 118 of these sites, and 62.1 percent of all
RV sites occupied by Winter Texans during the winter months. In the absence of comprehensive
data, these estimates may be used to approximate the number of RV sites potentially available in
Cameron County. Based on the average number of sites, the RV share of these sites, and the
portion occupied by Winter Texans, RV and Mobile Home parks in Cameron County include an
estimated 13,000 RV sites, with Winter Texans occupying more than 8,000 of these sites during
the winter months, leaving almost 5,000 sites available for other users.
The temporary relocation of non-local workers to the Project area during construction
would likely result in an increase in demand for temporary housing. An average of 253 non-local
workers are expected to be employed for the duration of the Project, with up to 780 non-local
workers expected during peak construction. Review of available temporary housing resources
suggests that almost 5,000 housing units were available for rent in Cameron County, including
approximately 1,300 in the city of Brownsville. An estimated annual average of 3,200 hotel rooms
are usually unoccupied in Cameron County, including an estimated 680 units in Brownsville, with
several thousand RV sites also likely to be available. This suggests that sufficient temporary
housing resources likely exist within daily commuting distance of the Project site, and the
temporary relocation of non-local workers is unlikely to displace tourists or other seasonal visitors.
Operation and maintenance of the Project is expected to require approximately 165

personnel once all six liquefaction trains are fully operating. Annova anticipates that
approximately 110 of these positions would be filled by non-local workers who would permanently
relocate to the area. The relocation of approximately 110 workers and their families to the Project
area is not expected to affect the supply of regional housing resources.
4.9.7 Removal of Agricultural, Pasture, or Timberland from Production
Construction and operation of the Project would not require the removal of agricultural
land, pasture, or timberland from production; therefore, no adverse impacts on these resources
would occur.
4.9.8 Public Services
4.9.8.1 Public Safety
Cameron County is divided into 10 “fire zones,” each of which is under the responsibility
of a fire department. Unincorporated areas of the county are included in these zones so that no
area of the county is outside a fire department’s area of responsibility. The Project site is located
in Zone 1 (Brownsville) and the Brownsville Fire Department is responsible for dispatching first
responders to a fire or related emergency in the area. Cameron County has a total of 12 fire
departments and 29 fire stations (table 4.9.8-1). Brownsville and Harlingen have multiple fire
stations, commensurate with their geographic size and population, staffed primarily by career
firefighters. Willacy County is served by six fire departments, each consisting of one fire station
and, in the case of Santa Monica, one fire truck with on-call firefighters (Gutierrez 2015).
TABLE 4.9.8-1
Public Safety Services: Fire Departments and Law Enforcement Agencies

Municipal and County
Fire Law Enforcement
Geographic Area Departments Fire Stations Agencies a/
Cameron County 12 29 11
Willacy County 6 7 2
Total 18 36 13
a/ Does not include university or port-affiliated police departments, or other private enforcement agencies.
Sources: FireDepartment.Net 2015a, 2015b; Gutierrez 2015; USA Cops 2015a, 2015b; Cameron County 2009
Cameron County has a total of 11 county and municipal law enforcement agencies; another
two agencies are located in Willacy County (table 4.9.8-1). Both counties have a county sheriff
department, with local offices in cities and towns. Raymondville is the only city in Willacy County
with a municipal police department. The Willacy County Sheriff’s Department is responsible for
the remainder of the county.
Construction of the Project facilities could result in increased demand for emergency
services due to the temporary relocation of non-local workers and family members to local
communities during construction. However, given the short-term nature of most of the
construction jobs and the relatively small temporary increase in population, the temporary influx
of non-local workers is not expected to affect the levels of service provided by existing law
enforcement and fire protection personnel.
Annova would work directly with local law enforcement, fire departments, and emergency
medical services to coordinate for effective emergency response at the Project site (medical
services are discussed further in section 4.9.8.2). Police personnel may also be called upon to
assist in traffic control, but these impacts would be short-term and minor.
Annova does not anticipate the need for additional local emergency services and facilities
during normal Project operations. The potential relocation of approximately 110 workers and their
families to the Project area would have a negligible impact on the population in the area and
demand for services. Project facilities would include independent fire protection systems, with
water from the BSC used for the firewater supply and distribution system. Annova has initiated
consultation with the Texas Department of Public Safety and the BND, and would continue to
consult with the appropriate authorities to ensure that fire protection and other safety systems meet
all applicable codes and standards. Public safety is discussed further in section 4.12.
4.9.8.2 Medical Facilities
Sixteen hospitals and medical centers provide emergency and generalized care in Cameron
County. The closest major hospitals to the Project site are Valley Regional Medical Center and
Valley Baptist Medical Center Brownsville, both located within the city limits of Brownsville.
Both hospitals provide comprehensive medical services and are designated Advanced Level III
Trauma Centers by the Texas Department of Health, providing emergency coverage 24 hours a
day (Valley Baptist Medical Center 2015; Valley Regional Medical Center 2015). Willacy County
has one hospital, with additional medical services provided by walk-in health care clinics
(Marchex, Inc. 2015).
Construction of the Project is not expected to have significant adverse impacts on local and
regional medical facilities and services. Temporary relocation of non-local workers and families
during construction, and the permanent relocation of some during operation, is not expected to
affect existing levels of health care and medical services. Annova would work directly with local
law enforcement, fire departments, and emergency medical services to coordinate for effective
emergency response in the event of an incident during the Project’s construction or operation.
4.9.8.3 Schools
The Project site is located in the Point Isabel ISD. Schools in this ISD are located in and
near the town of Port Isabel north of the BSC. Port Isabel Junior High and High School are the
closest schools, located approximately 4.0 miles to the north-northeast of the Project site. The
closest schools in the neighboring Brownsville ISD are located about 10 miles southwest of the
Project site. Table 4.9.8-2 identifies all of the public ISDs in Cameron and Willacy Counties,
along with the number of schools and estimated number of students by ISD. As shown in table
4.9.8-2, approximately 103,200 students were enrolled in 147 schools in Cameron County for the
2013-2014 school year, with a further 4,500 students enrolled in 14 schools in Willacy County.
Few of the non-local workers temporarily relocating to the Project area would be expected
to be accompanied by their families, therefore the temporary workforce would not be expected to
affect existing average student/teacher ratios. During operation, assuming an average family size
of 3.3 consisting of 1.3 school-aged children, the potential relocation of approximately 110
workers and their families to the Project area would add approximately 144 students to area
schools. 12 This addition would be equivalent to approximately 0.3 percent of current enrollment
in the Brownsville ISD and 0.1 percent of total enrollment in Cameron County. The potential
addition of these students would have a minor impact on existing student/teacher ratios.
12
According to the 2010 Census, the average family size in Texas is 3.31 (U.S. Census Bureau 2010).
TABLE 4.9.8-2
Public School Inventory in the Project Area

School District Total Schools Total Students
Cameron County
Brownsville ISD 58 49,314
Harlingen CISD 30 18,745
La Feria ISD 7 3,597
Los Fresnos CISD 14 10,523
Point Isabel ISD 4 2,637
Rio Hondo ISD 4 2,168
San Benito CISD 19 11,010
Santa Maria ISD 3 727
Santa Rosa ISD 3 1,170
South Texas ISD 5 3,353
Cameron County Total 147 103,244
Willacy County
Lyford CISD 3 1,586
Lasara ISD 3 487
Raymondville ISD 5 2,154
San Perlita ISD 3 276
Willacy County Total 14 4,503
CISD = Consolidated Independent School District

ISD = Independent School District
Source: Texas Education Agency 2015
4.9.8.4 Public Utilities
The Brownsville Municipal Solid Waste Landfill serves Brownsville and surrounding areas
and is located approximately 8.5 miles southwest of the Project site. The landfill has
approximately 38 years of waste disposal capacity remaining (City of Brownsville Public Works
2016). The landfill accepts household waste, construction waste, and certain special wastes.
The Brownsville Public Utilities Board, a municipally owned utility, provides electrical,
water, and wastewater services to at least 46,000 customers in and around the City of Brownsville,
including the BND (Brownsville Public Utilities Board 2016). The Brownsville Public Utilities
Board’s potable water infrastructure includes three water treatment plants with a combined rated
capacity that exceeds the peak demand of its current customer base (Brownsville Public Utilities
Board 2013). The American Electric Power Service Corporation (AEP) and STEC also provide
electricity in the Brownsville area. STEC provides wholesale electric power to member
cooperatives in South Texas, including the Magic Valley Electric Cooperative, which has over
4,800 miles of power lines and more than 90,000 members. Annova would be a retail customer
of the Magic Valley Electric Cooperative. Texas Gas Service provides local natural gas
distribution services in the Brownsville area.
The temporary relocation of construction workers and their families to the Project area is not
expected to affect the service capacities of the local public utilities that serve the Project area.
Construction-related solid waste would be disposed of at the Brownsville Municipal Solid Waste
Landfill. As stated above, the landfill has approximately 38 years of waste disposal capacity
remaining, and it is expected to be able to accommodate the addition of Project construction-related
solid waste. Potable water would be provided by the BND, which obtains water from the
Brownsville Public Utilities Board. Estimated Project water requirements during construction and
operation would be equivalent to approximately 0.34 percent and 0.07 percent of the Brownsville
Public Utilities Board’s rated capacity for potable water (40 million gallons per day), respectively.
Temporary wastewater services would be provided during construction, with Annova renting
temporary sanitary facilities through a third party to serve the construction crew on-site. Following
construction, wastewater services would be provided by the Brownsville Public Utilities Board.
The potential relocation of approximately 110 workers and their families to the Project area
during operation would not be expected to affect the service capacities of local public utilities.
4.9.9 Environmental Justice
For projects with major aboveground facilities, FERC regulations (18 CFR 380.12(g)(1))
direct us to consider the impacts on human health or the environment of the local populations,
including impacts that would be disproportionately high and adverse for minority and low-income
populations. The EPA’s Environmental Justice Policies (which are directed, in part, by Executive
Order 12898: Federal Action to Address Environmental Justice in Minority Populations and Low-
Income Populations) focus on enhancing opportunities for residents to participate in decision
making. The EPA (2011) states that Environmental Justice involves meaningful involvement so
that: “(1) potentially affected community residents have an appropriate opportunity to participate
in decisions about a proposed activity that would affect their environment and/or health; (2) the
public’s contributions can influence the regulatory agency’s decision; (3) the concerns of all
participants involved would be considered in the decision-making process; and (4) the decision-
makers seek out and facilitate the involvement of those potentially affected.” CEQ also has called
on federal agencies to actively scrutinize a number of important issues with respect to
environmental justice (CEQ 1997a).
As part of our NEPA review, we have evaluated potential environmental justice impacts
related to the Project taking into account the following:
• the potential presence of minority and/or low-income communities;

• the potential for high and adverse human health or environmental effects to
disproportionately affect identified minority and/or low-income populations; and
• public participation strategies, including community or tribal participation in the
NEPA process (CEQ 1997a).
4.9.9.1 Minority and Low-Income Communities
Guidelines provided by the CEQ (1997) and EPA (1998) indicate that a minority community
may be defined as one where the minority population comprises more than 50 percent of the total
population or comprises a meaningfully greater share of total population than the share in the general
population. Minority communities consist of individuals who are members of non-White population
groups. Minority population groups include the following: Hispanic; African American/Black;
Asian; American Indian and Alaska Native; Native Hawaiian and Other Pacific Islander; and Some
Other Race (see table 4.9.9-1). Minority communities may consist of a group of individuals living
in geographic proximity to one another, or a geographically dispersed set of individuals who
experience common conditions of environmental effect. Further, a minority population exists if
there is “more than one minority group present and the minority percentage, as calculated by
aggregating all minority persons, meets one of the above-stated thresholds” (CEQ 1997).
The CEQ and EPA guidelines suggest low-income populations should be identified based
on annual statistical poverty thresholds established by the U.S. Census Bureau. Low-income
communities may consist of individuals living in geographic proximity to one another, or a
geographically dispersed set of individuals who would be similarly affected by the proposed action
or program. The U.S. Census Bureau defines a poverty area as a census tract or other area where
at least 20 percent of residents are below the poverty line (U.S. Census Bureau 2016d).
Large populated geographic areas may have the effect of “masking” or “diluting” the
presence of minority and/or low-income populations (CEQ 1997; EPA 1998). Therefore, we
reviewed data at the census block group level. 13 Two census block groups are located within 1
mile of the Project site: Block Group 2, Census Tract 127 and Block Group 1, Census Tract 142
(see figure 4.9.9-1), both of which are potential environmental justice populations because the total
minority population exceeds 50 percent and more than 20 percent of households are below the
poverty level (table 4.9.9-1). It may be noted that this is also the case with Census Tracts 127 and
142, as well as with Cameron County as whole (table 4.9.9-1).
13
A census block group is a statistical subdivision of a census tract, generally defined to contain between 600 and
3,000 people and 240 and 1,200 housing units.
Figure 4.9.9-1 Environmental Justice Study Area
TABLE 4.9.9-1
Race and Ethnicity and Poverty by Geographic Area, 2014

Percent of Total
African Total Below

Total Hispanic American/ Other Minority Poverty
Geographic Area Population White a/ Origin Black a/ Race a/, b/ Population Level
Texas 26,092,033 44% 38% 12% 6% 55% 16%
Cameron County 415,103 10% 88% 0% 1% 90% 31%
Census Tract 127 5,544 7% 93% 0% 0% 93% 37%
Census Tract 142 5,258 9% 91% 0% 0% 91% 39%
Block Group 2, Census
801 28% 72% 0% 0% 72% 31%
Tract 127
Block Group 1, Census
3,806 2% 98% 0% 0% 98% 43%
Tract 142
Numbers may not sum due to rounding.

a/ Non-Hispanic only. The federal government considers race and Hispanic/Latino origin to be two separate and distinct
concepts. People identifying Hispanic or Latino origin may be of any race. The data summarized in this table present
Hispanic/Latino as a separate category.
b/ The “Other Race” category presented here includes census respondents identifying as “Asian,” “American Indian and
Alaska Native,” “Native Hawaiian and Other Pacific Islander,” “Some Other Race,” and “Two or more races.”
Source: U.S. Census Bureau 2016e, 2016f
4.9.9.2 Disproportionate Human Health or Environmental Effects
Construction and operation of the Project would not be expected to have high and adverse
human health or environmental effects on any nearby communities. The Project site is entirely
located on property owned by the BND and designated for industrial use. The closest residences
to the Project site boundary are located approximately 2.3 miles to the south, on County Road 199,
off of SH 4. These residences are separated from the Project site by the Lower Rio Grande Valley
NWR. The next closest residential developments are located from about 4.7 miles to 5.1 miles
northeast of the Project site and include Port Isabel, Laguna Heights, and Long Island. Review of
the EPA’s Environmental Justice Screening and Mapping Tool (EJSCREEN) confirmed that there
are no residents within 1 mile of the Annova site.
Elsewhere in this document, we identify impacts on environmental resources that

potentially may have a direct or indirect effect on the local population, including air quality and
noise (see section 4.11), water resources (see section 4.3), and hazardous materials (see section
4.2). Impacts during construction would be temporary and localized and are not expected to be
high. In addition, Annova would implement a series of measures to minimize these types of
potential impacts.
4.9.9.3 Public Participation
All public documents, notices, and meetings were made readily available to the public
during FERC’s review of the Project. Public outreach activities by Annova have included
meetings with interested individuals, local associations, community leaders, public groups, and
other non-governmental associations. In addition, Annova held a community open house on April
21, 2015, at the Brownsville Event Center, with English- and Spanish-speaking representatives of
the Project available to hold one-on-one discussions with meeting attendees and address questions.
Annova used a variety of communication and advertisement methods to notify all potentially
affected residents and property owners of the open house, including direct mailing, advertisements
in the English- and Spanish-language press, radio advertisements on Spanish-language radio, and
targeted online advertisements.
Annova also used the FERC’s pre-filing process (see section 1.3 of this EIS). One of the
major goals of this process is to increase public awareness and encourage public input regarding
every aspect of the project before a formal application is filed with the FERC. FERC staff
participated in the April 21, 2015, community open house in Brownsville (discussed above), and
also held a public scoping meeting in Port Isabel, Texas on August 11, 2015. Interested parties
have had, and will be given, opportunities to participate in the NEPA review process. To date, this
has included the opportunity to participate in the public scoping meetings within the Project area
to identify concerns and issues that should be covered in the EIS, and the opportunity to submit
written comments about the Project to the FERC. Stakeholders will have the opportunity to review
this draft EIS, participate in public meetings, and provide comments directly to the FERC staff in
person or in writing.
4.9.9.4 Conclusion
disproportionate adverse effects on minority and low-income residents in the area.
4.9.10 Transportation and Traffic
4.9.10.1 Land Transportation
Roadway Traffic
SH 48 (Padre Island Highway) is the major principal arterial roadway in the Project
vicinity. SH 48 extends east from Brownsville and Interstate 69E (I-69E) passing north of the
Project site and the BSC to intersect with SH 100 just west of Port Isabel. Average annual daily
traffic (AADT) volumes on SH 48 in 2013 ranged from 15,100 to 29,660 (table 4.9.10-1). AADT
volumes represent the total volume of traffic passing a point or segment of a highway facility in
both directions for 1 year divided by the number of days in the year.
A network of state and local roads and port facilities would provide access to the site.
Workers commuting and trucks delivering materials to the Project site would use the existing road
network during construction and operation, with SH 4 (Boca Chica Boulevard) providing main
access to the site. AADT volumes on Boca Chica Boulevard in 2013 ranged from a high of 38,980
near I-69E to 285 near the Project site (table 4.9.10-1).
TABLE 4.9.10-1
Major Existing Roadways Near the Project Site

Posted
Speed
Street Name Functional Class Typical Section (mph) AADT
SH 48/SH 4 (Boca Chica Principal Arterial Five-lane to two-lane 40-55 285 (near the project
Boulevard) a/ (west of FM 511), Minor undivided site)–38,980 (near I -
Arterial 69E)
(between FM 511 and
FM 1419), and Major
Collector (east of FM 1419)
SH 48 (S. Padre Island Principal Arterial Five-lane to four-lane divided 45-55 15,100–29,660
Highway)
FM 511 (Indiana Avenue) Principal Arterial Two-lane frontage road (north 55 8,130–9,410
of SH 48) to two-lane
undivided
FM 802 (Ruben Torres Principal Arterial Five-lane with two-way left-turn 45 6,480–19,300
Boulevard) lane
FM 3248 (Dr Hugh Principal Arterial Five-lane with two-way left-turn 45 6,070–19,840
Emerson Road) lane
FM 1847 (Paredes Line Principal Arterial Five-lane with two-way left-turn 45 11,640
Road)
SH Toll 550 Principal Arterial – Four-lane divided 65 NA
Limited Access Toll
Route
a/ The initial stretch of Boca Chica Boulevard extending east from I-69E is SH 48; Boca Chica Boulevard subsequently
becomes SH 4 and SH 48 trends northeast and becomes S. Padre Island Highway.
AADT = Average Annual Daily Traffic obtained from Texas Department of Transportation are for 2013, and rounded to the
nearest 10; FM = Farm to Market; NA = Not Available; SH = State Highway
Source: Traffic Impact Group, LLC 2015
Annova commissioned a study of potential land transportation impacts that evaluated how
construction and operation of the Project would likely affect traffic volumes, circulation patterns,
and levels of service (LOS) on roadways within the Project area (Traffic Impact Group, LLC
[Traffic Impact Group] 2015). The analysis was based on existing conditions in 2015, with peak
construction assumed to occur in 2019, and normal operations taking place in 2022. The analysis
also employed the following assumptions:
• a background growth factor of 1.0 percent (based on discussions with Texas
Department of Transportation [TxDOT] and Cameron County) was used to account
for regional growth in traffic volumes;
• a distribution of trips that reflects existing traffic patterns, engineering judgment,
and discussion with TxDOT and Cameron County;
• a peak workforce of 1,000 construction workers, 200 support and management
staff, a carpooling rate of 20 percent, and staggered shifts during construction to
reduce impacts; and
• an operations workforce of 165 employees in three shifts, including 75 workers in
the day shift, 50 workers in a swing shift, and 40 workers in the night shift.
On June 30 and July 1, 2015, existing traffic volumes were measured at 11 key intersections
(figure 4.9.10-1) during the morning and evening peak hours, analyzing road and intersection
capacities, and identifying the LOS for each intersection under existing conditions, peak
construction conditions, and normal operational conditions. The preliminary analysis indicated
that the addition of 1,000 Project-related vehicles during morning and evening peak hours would
cause failing conditions at the intersections nearest to the Project access road. In order to address
this issue, the analysis assumed that construction shifts would be staggered, with half the
workforce (500 vehicles) arriving and departing during peak hours, and subsequently
recommended that half of the employees (500 trips) work from 6:30 a.m. to 5:00 p.m., with the
remaining half (500 trips) working from 7:30 a.m. to 6:00 p.m. Operation shifts were also assumed
to be staggered in this analysis, resulting in a total of 115 vehicles entering (75 trips) and exiting (40
trips) the site during the morning peak hour, with the same overall number (115 vehicles) entering
(40 trips) and exiting (75 trips) in the evening peak hour.
The traffic impact analysis assessed potential changes to intersection LOS based on the
addition of Project construction and operation worker trips to existing trips. LOS refers to how
traffic operates in intersections using six levels of service ranging from A to F, with A representing
the best conditions, and F representing the worst. Conditions that could result in an intersection
operating at LOS E or worse are considered an adverse impact. Overall LOS ratings for existing
conditions, peak construction, and normal Project operations are summarized for each key
intersection in table 4.9.10-2. Intersections 5, 6, 7, 8, 9, and 11 (as identified in table 4.9.10-2)
would not experience any change in peak hour LOS during construction or operations. Intersection
10 would experience temporary reductions in LOS but would function at acceptable conditions
and would not require improvements (table 4.9.10-2).
The results of the analysis (Traffic Impact Group 2015) may be summarized for the other
four study intersections (1 through 4) as follows. Potential mitigation measures identified as part
of this analysis are discussed below and summarized in table 4.9.10-3.
• Intersection 1 is the intersection of the Project site access road with SH 4 (Boca
Chica Highway). The Boca Chica Highway in this location is a two-lane undivided
roadway with an AADT of approximately 200 vehicles per day. The intersection
is expected to operate at an acceptable LOS during Project construction and
operation, but improvements were recommended as a result of the analysis to meet
TxDOT Roadway Design Manual guidelines (table 4.9.10-3 describes the
recommended improvements).
Figure 4.9.10-1 Traffic Impact Study Intersections Map
TABLE 4.9.10-2
Measured and Calculated Overall Levels of Service at Intersections During Construction and Operation
Levels of Service a/
2015 2019 Peak 2022 Normal
Existing Construction Operation
Street Name a.m./p.m. a.m./p.m. a.m./p.m.
1 (A) Project Site Access and SH 4 (Boca Chica Boulevard) NA NA NA
2 (B) SH 4 (Boca Chica Boulevard) and FM 1419 (Oklahoma EB A/A A/A A/A
Avenue)
WB A/A A/A A/A
NB B/B D/E C/C
SB B/B E/E C/C
3 (C) SH 4 (Boca Chica Boulevard) and FM 511 (Indiana Avenue) C/C E/C C/C
4 (D) SH 4/48 (Boca Chica Boulevard) and SH 48 (S Padre Island Highway)/ SH 4 D/E E/E E/E
(East 14th Street)
5 (E) FM 511 (Indiana Avenue) and FM 802 (Ruben Torres Boulevard) B/B B/B B/B
6 (F) FM 802 (Ruben Torres Boulevard) and SH 48 (S Padre Island Highway) C/C C/C C/C
7 (G) FM 511 (Indiana Avenue) and SH 48 (Brownsville-Port Isabel Highway) A/B A/B A/B
South Ramp
8 (H) FM 511 (Indiana Avenue) and SH 48 (Brownsville-Port Isabel Highway) A/A A/A A/A
North Ramp
9 (I) FM 3248 (Dr Hugh Emerson Road) and FM 511 Northbound A/A A/A A/A
10 (J) FM 3248 (Dr Hugh Emerson Road) and FM 511 Southbound A/A B/A B/A
11 (K) FM 3248 (Dr Hugh Emerson Road/Alton Gloor Boulevard) and FM 1847 C/C C/C C/C
(Paredes Line Road)
a/ Levels of Service refers to how traffic operates in intersections using six levels of service ranging from A to F, with A
representing the best conditions, and F representing the worst.
Key:
EB = Eastbound SB = southbound
FM = Farm-to-Market Road SH = State Highway
NA = Not applicable WB = Westbound
NB = north bound
Source: Traffic Impact Group 2015
• Intersection 2 – SH 4 (Boca Chica Boulevard) and FM 1419 (Oklahoma Avenue)

– is an unsignalized intersection with stop sign control for northbound and
southbound traffic. The eastbound and westbound approaches have a left-turn lane,
and a shared through-right lane. The northbound and southbound approaches both
consist of a single lane. During peak construction, the northbound and southbound
approaches to this intersection would be expected to see LOS D or LOS E in both
peak hours (table 4.9.10-2).
These reductions in LOS would be temporary, with the intersection expected to

function at acceptable levels (LOS C) following construction during normal
operations (table 4.9.10-2). Further, the study found that despite this drop in LOS
during peak construction, the intersection would not be expected to meet traffic
volumes that would warrant signalized control. Based on these expected
conditions, the study did not recommend improvements for this intersection.
• Intersection 3 – SH 4 (Boca Chica Boulevard) and FM 511 (Indiana Avenue) – is a

signalized intersection with protected-permitted phasing for eastbound and westbound
left-turns, and split phasing for northbound and southbound. During peak
construction, this intersection would see LOS E for the southbound left-turn
movement in the morning peak hour, with significant backups (table 4.9.10-2). The
study indicated that this impact could be mitigated by changing the existing timing
and phasing plan for the intersection (see table 4.9.10-3).
• Intersection 4 – SH 4/SH 48 (Boca Chica Boulevard) and SH 48 (S Padre Island

Highway)/SH 4 (E 14th Street) – is signalized with protected phasing for all left
turn movements. All approaches consist of two left-turn lanes, two through lanes,
and a channelized right-turn lane with yield control (Traffic Impact Group 2015).
The study found that this intersection currently sees LOS D overall in the morning
peak hour and LOS E overall in the afternoon peak hour, with some movements
experiencing delays ranging into LOS F.
During peak construction, the intersection would see LOS E overall in both peak
hours. This would also be the case for normal operating conditions (2022),
indicating continued congestion and delays. The study noted that signal timing
optimization may improve existing and future traffic flows at this intersection. The
analysis also recommended that the Project avoid using Boca Chica Boulevard as
a truck route, and instead use SH Toll 550 as the preferred truck route to and from
the north (table 4.9.10-3).
TABLE 4.9.10-3
Potential Mitigation Measures for Construction-Related Traffic

as Identified in Annova’s Traffic Impact Analysis
Intersection a/ Mitigation Measures
1. (A). Project Site Access Road and SH 4 – Construct an eastbound left-turn lane with a storage length of 100 feet, a
(Boca Chica Boulevard) deceleration length of 510 feet, and a taper length of 100 feet.
– Construct a westbound right-turn acceleration lane with an acceleration
length of 930 feet and a taper length of 250 feet.
3. (C). SH 4 (Boca Chica Boulevard) and FM – Revise northbound and southbound timing from split phasing to protected-
511 (Indiana Avenue) permitted phasing.
4. (D). SH 48/4 (Boca Chica Blvd) and SH 48 – Based on existing traffic congestion, this intersection may benefit from
(S Padre Island Hwy)/SH 4 (E 14th Street) signal timing optimization.
– Avoid SH 48/4 (Boca Chica Boulevard) as a truck route. Use SH Toll 550
as the preferred truck route for routes to/from the north.
Source: Traffic Impact Group (2015)

a/ Intersection numbers 1, 3, and 4 correspond with those shown in table 4.9.10-2.
In its comments on the draft EIS, the NPS requested additional details on the possible
construction of an eastbound left-turn lane and the westbound right-turn acceleration lane on SH4,
as listed under Intersection 1. (A) in the above table 4.9.10-3. The NPS noted that the addition of
these turn lanes would likely require widening of SH 4 along the Palmito Ranch Battlefield NHL
boundary, and that such widening may deter visitors from viewing roadside interpretive exhibits
along SH 4. We agree that these potential mitigation measures would likely require widening of
SH 4 which could impact visitors to the roadside interpretive exhibits. However, these measures
have been identified only as potential measures, are not part of the proposed action, and we have
no further details. If road improvements are proposed, coordination would be conducted by the
Texas Department of Transportation.
Annova proposes to transport construction workers to and from the construction site from
a centralized location via passenger buses. Depending on the location of the centralized site, the
use of buses would reduce the potential impacts assessed in the Traffic Impact Analysis as
summarized above. The use of buses would reduce the number of commuter vehicles considered
in the analysis and the corresponding impacts at the U.S. Border Patrol (Border Patrol) checkpoint
(see below) and one or more intersections assessed in the Traffic Impact Analysis, such as
Intersection 1 (Project Site Access Road and SH 4 [Boca Chica Boulevard]) and Intersection 2
(SH 4 [Boca Chica Boulevard] and FM 1419 [Oklahoma Avenue]) (see above).
Border Patrol
The Border Patrol operates a checkpoint on SH 4 (Boca Chica Boulevard), west of the
proposed access road to the Project site. The checkpoint requires vehicles to stop and show photo
identification. Vehicles traveling to and from the Project site would pass through this checkpoint,
with significant potential delays anticipated during construction. The checkpoint consists of a
trailer and is not equipped to handle the estimated amount of peak construction traffic (Traffic
Impact Group 2015). Annova would coordinate with the Border Patrol to establish procedures for
workers to move through border security checkpoints during facility construction and operation.
Annova also proposes to transport construction workers to and from the construction site
from an off-site centralized location via passenger buses. Support and management staff would
drive their vehicles directly to the Project site. Use of an off-site centralized location and passenger
buses would reduce the number of individual vehicles passing through the Border Patrol
checkpoint. Consultation with the United States Border Patrol indicated that U.S. citizenship
checks could be performed at this centralized location as craftsmen board the bus, which would
allow the buses to move through the checkpoint without stopping, further reducing delays at the
checkpoint. Depending on the stage of construction, six to eight, 40- to 44-passenger buses would
transport construction workers to and from the Project site.
In response to our recommendation in the draft EIS, on March 20, 2019, Annova filed
information on three potential locations for the centralized off-site parking, stating that because it
is in the process of negotiations with the property owners it will not disclose the exact locations.
In general, Annova applied the following criteria in identifying the three potential sites:
• limiting the size of the parking area to a maximum of 10 acres;
• locating the site west of the U.S. Border Patrol checkpoint on SH 4 to avoid creating
a chokepoint;
• utilizing land that is currently disturbed, or in similar use as a parking area; and
• avoiding impacts on waterbodies and NWI mapped wetlands; 100-year floodplain;

threatened and endangered species habitat; previously-recorded archaeological
sites; NRHP-recorded historic properties, districts, and landmarks; and Texas
Historic Landmarks.
We considered the use of these parking areas when determining potential impacts on traffic
and visitors to the Palmito Ranch Battlefield NHL. Therefore, to ensure that Annova establishes
an off-site centralized parking area(s), and to ensure potential impacts from these areas are
evaluated before use, we recommend that:
• Prior to construction, Annova should file the specific location(s) of the

off-site centralized parking sites that would be used to reduce impacts
from commuter construction traffic. For each location, Annova should
identify: the existing environment and land use at those locations; an
evaluation of potential impacts that would result from use as an off-site
parking facility; and a description of how the use of the specific site(s)
would mitigate the impacts at Intersections 1 through 4 as identified in
the Traffic Impact Group 2015 report.
Heavy Trucks
Annova and their transportation consultant have identified three general delivery truck
routes, and routes from four local concrete plants in Brownsville and San Benito that could supply
the Project during construction (Traffic Impact Group 2015). The three identified truck routes are
the Port Isabel Truck Route, the North Truck Route, and the Alternate North Truck Route (figure
4.9.10-2), which was developed following discussion with TxDOT and Cameron County staff.
Based on this analysis, Annova’s transportation consultant identified the Alternate North Truck
Route as the recommended truck route to and from the north, and indicated that overheight or
overweight trucks would be required to the follow the North Truck Route (Traffic Impact Group
2015). Analysis of potential routes from the four identified concrete plants found that some detours
would be necessary from the initially identified routes for overheight or overweight trucks. Many
of the roads near the Project site are designated as truck routes and designed to withstand heavier
vehicles.
Tourism and Recreation
Traffic in proximity to Palo Alto Battlefield National Historic Park and Palmito Ranch
Battlefield NHL would temporarily increase during the Project’s construction. Traffic increases
from workers commuting during the morning peak hour would occur before the Battlefield sites
open and would not be expected to affect visitors to the Battlefield sites. Cultural heritage tourists
who leave the battlefield sites during the afternoon peak hour may experience longer trips than
average. This potential impact would be highest during peak construction, becoming less
pronounced during less intensive construction periods, and stopping once construction is complete.
Increases in traffic during Project construction are not expected to deter people from visiting Palo
Alto Battlefield National Historic Park or Palmito Ranch Battlefield NHL.
Figure 4.9.10-2 Potential Truck Routes During Construction
4.9.10.2 Marine Transportation
The majority of commercial vessels that transit the BSC call at the Port of Brownsville.
Commercial vessel calls are identified by type of vessel in table 4.9.10-4. Vessel counts include
commercial vessels that called at Port Isabel, which represented a very small share of the overall
total (Bearden 2015). Data are presented as annual averages over a three-year period from 2012
to 2014. These totals do not include commercial fishing vessels or recreational boats.
TABLE 4.9.10-4
Average Annual Commercial Vessel Calls at the Port of Brownsville, 2012 to 2014
Average Calls Average Trips per
Type of Vessel (2012-2014) Week Percent of Total
River Vessels
River Barges 652 12.5 62%
Tugs 93 1.8 9%
Subtotal 745 14.3 70%
Ocean-going Vessels
Cargo Vessels 108 2.1 10%
Ocean Barge 80 1.5 8%
Tankers 78 1.5 7%
Scrap Vessels/Barges 25 0.5 2%
Container/Bulk/Cargo 7 0.1 1%
Government 7 0.1 1%
Deck Barge 4 0.1 <1%
Drilling Rig 3 0.1 <1%
Subtotal 312 6 30%
Grand Total 1,057 20.3 100%
Numbers may not sum due to rounding.

Source: BND 2016
Average annual volumes of waterborne cargo transported through the Port of Brownsville
for the period 2012 to 2014 are identified in table 4.9.10-5. Almost half (45 percent) of all
waterborne cargo that moved through the Port came in from international ports via ocean-going
vessels (“deep sea in”).
TABLE 4.9.10-5
Average Annual Volume of Waterborne Cargo Transported via the Port of Brownsville, by
Direction of Vessel Movement, 2012 to 2014
Annual Average
Direction (metric tons) Percent
Coastwise In 1,144,112 20%
Coastwise Out 526,323 9%
Deep Sea In 2,572,341 45%
Deep Sea Out 242,979 4%
Intracoastal In 675,040 12%
Intracoastal Out 541,793 10%
Total Waterborne Cargo 5,702,586 100%
Source: BND 2016
An average annual total of 745 river vessels and 312 ocean-going vessels called at the port
from 2012 to 2014, approximately 14.3 river vessels and 6 ocean-going vessels a week (table 4.9.10-
4). Of the large, ocean-going vessel class, cargo vessels were the most frequent visitors (35 percent
of the total), followed by ocean barges (26 percent), and tankers (25 percent) (table 4.9.10-4). Other
ocean-going vessels entering the BSC include government vessels, scrap vessels, and drilling rigs
(floating objects that must be towed, similar to barges). In almost all cases, a local pilot affiliated
with the Brazos Santiago Pilots Association must pilot the ocean-going vessel through the Brazos-
Santiago Pass, into the BSC, and ultimately to the Port of Brownsville turning basin or directly to a
berth. The channel is effectively one-way because ocean-going commercial vessels generally do not
pass each other in opposite direction. Commercial vessel traffic going in and out of the channel is
managed by the harbormaster, in coordination with the pilots. A large number of river barges travel
through the BSC. Depending on the circumstances, the harbormaster may arrange for a river barge
to meet an ocean-going vessel if passing is considered safe (Wilson 2015).
Large vessels provide at least 96 hours’ notice to the Coast Guard and harbormaster prior
to approaching the BSC. Cargo vessels or tankers entering the channel and beginning to transit
toward the Port are highly visible, giving commercial and recreational fishing vessels visual notice
to stay at berth or harbor if headed in the opposite direction. The BND advises smaller vessels not
to pass ocean-going, commercial vessels, because the amount of water they displace creates strong
surge and suction effects to the sides and rear (Duke 2015). However, there are no regulations
under ordinary circumstances that restrict small vessels from overtaking and passing an ocean-
going vessel, or passing an ocean-going vessel in the opposite direction (Wilson 2015). Typical
smaller vessels in the BSC include shrimping and other commercial fishing vessels, recreational
motorboats, and kayaks. Once a large vessel passes by, smaller vessels can immediately begin
their transits in the opposing direction, and small vessels heading in the same direction as a larger
vessel can travel in front of or well behind the larger vessel, usually with little or no delay.
Most local Gulf-shrimping vessels dock at the Port of Brownsville Shrimp Basin (Duke
2015). Bay shrimping vessels primarily dock at Port Isabel, with those that come into the BSC
to trawl for bait shrimp generally operating between sunrise and noon (Ferguson 2015; Wilson
2015). BSC-based bait shrimpers have noted that when large vessels transit the channel it takes
about 2 hours for the turbidity to settle. Most bait shrimping occurs around sunrise, so a large
vessel transit in the early morning can disrupt shrimping for the day. 14 A typical Gulf-shrimping
vessel exits or enters the BSC a limited number of times per season because shrimp harvesting
trips in the Gulf of Mexico generally last for several weeks or more. As a result, the potential for
a Gulf-shrimping vessel to interact with a large ocean-going vessel in the BSC is limited to the
few times the shrimping vessel enters or exits the channel. If a shrimping vessel waits in the
Shrimp Basin for a large, ocean-going vessel to transit the channel, the delay is typically several
hours.
On days when multiple vessels are escorted in or out of the channel in sequence, the required
coordination and limited number of tugs and pilots serving the Port create breaks, allowing smaller
vessels, such as shrimp boats, sufficient time to enter or exit the channel between the transits of
14
Annova facilitated a meeting between the Coast Guard, the Port of Brownsville, the Brazos Santiago
Pilots, and shrimping and fishing industry representatives on January 29, 2019 to address shrimping and
fishing industry concerns about impacts from LNG carrier traffic.
large vessels (Duke 2015). In practice, shrimping vessels and other small vessels frequently choose
to meet ocean-going vessels and pass them in the BSC. Shrimping vessels, other fishing vessels,
and recreational vessels are, however, prevented from passing when a drilling rig is being towed in
or out the BSC or a unique vessel like an aircraft carrier is transiting through with a moving security
zone (this would also apply to the LNG carriers; see further discussion below). Coordination and
advance communication regarding LNG carrier traffic would help reduce potential impacts on the
shrimping and fishing industry, as would scheduling LNG carrier traffic to minimize impacts
where possible, by, for example, scheduling a caravan when more than one carrier is scheduled to
transit.
Vessel traffic in the BSC would temporarily increase during Project construction with
transport of construction equipment, materials, and prefabricated modules to the Project site
expected to require an estimated 24 to 36 barge trips per year, less than one trip per week. From
2012 to 2014, an annual average of 652 river barges and 80 ocean barges transited the ship channel
for a combined total of 732 barge trips (table 4.9.10-4). The estimated 24 to 36 Project-related
barge trips would be equivalent to 3.3 percent to 4.9 percent of the average annual total from 2012
to 2014, with minimal impacts on other vessel traffic or recreational fishing vessels anticipated.
During Project operation, up to 125 LNG carriers per year would transit to the Project.
LNG carriers calling at the Project would enter the Santiago Pass from the Brazos Santiago Pass
Fairway of the Gulf of Mexico, and then turn into the BSC. The inland navigation route would be
about 8.7 miles from the Brazos Santiago Pass Fairway to the Project site. Smaller vessels,
including supply vessels, tugboats, and barges, would also call at the Project site, and would be
similar in size to many of the vessels currently using the BSC.
To minimize interference with existing BSC vessel traffic, the Project’s marine transfer
facilities would be recessed into the southern bank of the BSC. The Project berth’s size, location,
and orientation would ensure safe navigable approach and departure conditions and safe distances
from the influence of passing vessels.
LNG carrier transits through the BSC and Brazos-Santiago Pass would be similar to current
large vessel transits. Local pilots would board and steer the LNG carriers, and the BSC would
function as a one-way channel for all other large vessels during LNG carrier transits. The current
notification requirements that apply to large commercial vessels would also apply to all LNG
carriers. In addition, LNG carriers calling at the proposed Annova facility would have a Coast
Guard-enforced safety/security zone that would impact the transits of other waterway users while
the zone is being enforced.
Large ocean-going commercial vessels currently call at the Port of Brownsville at an

average rate of six per week, or 312 per year (BND 2016). The addition of up to 125 LNG carriers
per year with 2-hour transits in each direction per carrier is not expected to create adverse impacts
on inbound and outbound transits of large vessels, which are already accustomed to queues and
early scheduling requirements. Delays to small vessels may occur when an LNG carrier is in
transit between the Brazos-Santiago Pass jetty entrance and the Project berth. The occurrence and
extent of small vessel delays would depend on vessel orientation and direction of travel. Small
vessels traveling ahead or behind an LNG carrier in the same direction would not experience
measurable delays as long as they remain outside the LNG carrier safety zone. Smaller vessels
heading in the opposite direction to a LNG carrier could experience delays of a few minutes to 1.5
hours, depending on the position of the smaller vessel relative to the LNG carrier.
Estimated potential delays for small vessels when an LNG carrier transits inbound or
outbound are summarized in table 4.9.10-6. These estimates are based on vessel simulation
modeling of LNG carrier movements between the Project and the Gulf of Mexico conducted by
Annova. The estimated hours of delay represent the total hours that portions of the channel would
be restricted during an LNG carrier’s transit to and from the Project’s berth. Actual delays incurred
by small vessels would depend on individual vessel positions relative to the LNG carrier. The
total estimated annual delay for small vessels ranges from 2.7 to 8.4 percent of daylight hours
(table 4.9.10-6). Impacts are based on 125 LNG carrier visits per year (125 inbound transits and
125 outbound transits) and estimated delays of 0.5 hours to 1.5 hours delay per carrier transit.
TABLE 4.9.10-6
Estimated Small Vessel Delay Times During LNG Carrier Transit

Estimated Delay Time per Estimated Total Annual Delay
Percent of
Carrier Transit (hours) Time (hours) b/
Daylight
LNG Carrier Small Vessel Carrier Carrier Carrier Carrier Hours per
Location a/ Location Inbound Outbound Inbound Outbound Year
Brazos Santiago
Any Location 0.5 to 1.5 0.5 to 1.5 63 to 187 63 to 187 2.8 to 8.4%
Pass Jetty
a/ Transit destination is Gulf of Mexico.

b/ Estimated annual delay time is based on 125 LNG carrier visits to the Project per year.
4.9.11 Conclusion
The Project would result in a short-term, moderate increase to the local population during
construction, would result in a negligible, long-term increase during operation. Construction and
operation would generate local and state tax revenues from sales and payroll taxes, and support
some local employment. The Project would not be expected to have high and adverse human
health or environmental effects on any nearby communities. During operation, relocation of some
families to the area would have a minor impact on existing student/teacher ratios. During
construction a moderate impact on local traffic would be expected, however Annova has proposed
some measures to minimize that impact. Construction and operation would result in an increase
in marine traffic in the area, with the maximum of 125 ships resulting in minor impacts on large
vessels using the BSC, and moderate impacts on small vessels, such as shrimp boats, using the
BSC. If the Annova LNG Project does not receive the maximum number of ship-calls, the
resulting impacts on small vessel operators would be reduced proportionally.
4.10 CULTURAL RESOURCES
Section 106 of the NHPA, as amended, requires the FERC take into account the effects of
its undertakings on properties listed in or eligible for listing in the NRHP, and afford the ACHP
an opportunity to comment on the undertaking. Annova, as a non-federal party, is assisting the
FERC in meeting our obligations under Section 106 by preparing the necessary information,
analyses, and recommendations, as authorized by 36 CFR 800.2(a)(3).
Construction and operation of the Project could have the potential to affect historic
properties (e.g., cultural resources listed in or eligible for listing in the NRHP). Historic properties
include prehistoric or historic archaeological sites, districts, buildings, structures, and objects, as
well as locations with traditional value to Native Americans or other groups. Historic properties
generally must possess integrity of location, design, setting, materials, workmanship, feeling, and
association, and must meet one or more of the criteria specified in 36 CFR 60.4.
4.10.1 Cultural Resource Survey
The direct area of potential effect (APE) for the Project is defined as the boundaries of the
1,132-acre parcel of land upon which the proposed LNG terminal would be constructed as well as
the areas that would be temporarily affected by construction of the LNG terminal. The APE also
includes the approximately 668-acre LNG lease at Port of Brownsville, the 2.8-mile-long proposed
access road (Access Road Alternative 2), and the 263-acre dredge material placement area. The
direct APE extends to the maximum depth of disturbance within each of these areas. The indirect
APE for the facility is a 0.5-mile area around the boundaries of the Project site, and a 300-foot area
on either side of the access roads.
Annova’s consultant, Blanton and Associates, Inc.’s (B&A) consulted with the Texas
Historical Commission (THC), which serves as the SHPO, regarding the cultural resources survey
of the APE. B&A completed a records review and cultural resource survey of the Project. The
investigations covered both archaeological and architectural resources. In addition, iLinks
Geosolutions, LLC conducted a bathymetric survey and Ecology & Environment, Inc. conducted
a visual impact assessment (VIA) under Section 106 of the NHPA.
Regionally significant sites in the general area include the Palmito Ranch Battlefield NHL
(which abuts the southern boundary of the APE), the Palo Alto Battlefield NHL (which is located
approximately 12 miles west of the Project area), and the Brazos Santiago Depot (which is located
at the entrance of the BSC, northeast of the APE). The Palmito Ranch Battlefield NHL, located
on the south side of SH 4 at the intersection with the main access road, is the only non-
archeological historic-age resource within the 300-foot-radius indirect APE for the Project access
road. It is outside the indirect APE of the Project site. Based on field investigations, we
determined that the Project would have no direct or indirect effect on this historic property.
The Palo Alto Battlefield NHL is outside of the direct and indirect APEs; however, the
NPS has expressed concern for the landmark (as well as the Palmito Ranch Battlefield NHL and
the Brazos Santiago Depot). The Project would have no direct or indirect effect on this historic
property. The Brazos Santiago Depot primarily exists as a submerged historic resource. Like the
Palo Alto Battlefield NHL, the site is outside the Project’s direct and indirect APE but is a concern
Cultural Resources 4-160

for cooperating agencies. We have determined that the Project would have no direct or indirect
effect on this historic property.
4.10.1.1 Archaeological Survey
Between April 27 and May 29, 2015, B&A conducted an archaeological survey of the APE.
Portions of the APE were not surveyed due to the presence of sensitive thornshrub habitat and
historical tidal flats. Conducting archaeological investigations within this area, which includes
site 41CF48, requires clearing of vegetation. Archaeological investigations of this area would
occur prior to construction (if the Project is approved).
In addition, the proposed dredge material placement area was not surveyed. In a letter
dated November 17, 2016, the SHPO concurred that the proposed dredge material placement area
was historically tidal flat that is unlikely to contain archaeological resources and no historic
properties would be affected by the proposed activities at this location. Annova would consult
with the SHPO if it identifies other sites for dredged material placement, including for beneficial
use of dredged material.
Archaeological investigations identified four previously recorded archeological sites

(41CF49, 41CF50, 41CF87, and 41CF102), four newly recorded sites (41CF219, 41CF220,
41CF221, and 41CF222) and two isolated finds. B&A recommended that those sites investigated
within the APE (41CF49, 41CF50, 41CF87, 41CF102, 41CF219, 41CF220, 41CF221, and
41CF222) lack significant research potential and are not eligible for listing in the NRHP.
In a letter dated October 1, 2015, the SHPO concurred that sites 41CF49, 41CF50, 41CF87,
41CF102, 41CF219, 41CF220, 41CF221, and 41CF222 are not eligible for listing in the NRHP.
These resources therefore do not warrant further work. The SHPO also recommended that the area
around site 41CF48 in the Zone 1 Texas Thornbush Protected Habitat is considered unevaluated
due to the inability to survey the area. The SHPO recommended that if this site cannot be avoided
the SHPO must be consulted and the area surveyed prior to construction to determine the eligibility
of site 41CF48. If the Commission authorizes the Project, Annova would then complete the
investigation of site 41CF48 and provide results to the SHPO and FERC prior to the start of
construction.
In November 2015, B&A conducted a survey of an additional 71.4 acres added to the APE.
No cultural resources were identified. In a letter dated September 13, 2016, the SHPO stated that
the Project activities in the additional 71.4 acres would have no effect on archaeological resources.
In addition, 39.1 acres associated with the proposed permanent access road (i.e., Access
Road Alternative 2) have been surveyed (Griffith and Sanchez 2017). This part of the APE was
subjected to surface and subsurface investigations. The 36 shovel tests conducted within the APE
of the access road ranged between 35 and 65 centimeters in depth. No cultural resources were
identified. Further, the southern end of the Access Road Alternative 2 was found to have been
significantly disturbed by subsurface utilities in the area closest to the Palmito Ranch Battlefield
NHL. Based on results of the survey, Access Road Alternative 2 is believed to have little to no
potential for unidentified archaeological resources. It is unclear if the report has been filed with
SHPO for concurrence with this finding.
4-161 Cultural Resources

4.10.1.2 Architectural (Non-archaeological) Resources
The APE for architectural (non-archaeological) historic resources was defined in

accordance with the SHPO’s standards for infrastructure that is less than 200 feet tall. Using these
standards, the indirect APE is defined as 0.5 mile from the boundaries of the Annova LNG facility
site, and 300 feet on either side of the 3.3-mile-long access road. Annova conducted a non-
archaeological resource survey of this APE on May 28, 2015, and June 3, 2015. No previously
recorded non-archaeological historic properties were identified within the direct APE. One
previously recorded historic resource (the Palmito Ranch Battlefield NHL) was identified within
1 mile of the access road and within the indirect APE. In addition to the Palmito Ranch Battlefield
NHL, the NPS has expressed concern for the visual impact of the Project on the Palo Alto
Battlefield NHL and the NRHP-listed Brazos Santiago Depot. The NPS manages all three
properties.
Annova consulted with the NPS including staff from the Inter-Mountain Region (IMR)
Environmental Quality Division, the IMR Natural Resources Division, the Palo Alto Battlefield
NHL and National Historic Park, and members of the Heritage Partnership Program. Annova
prepared a VIA to address concerns regarding visual impacts on the Palmito Ranch Battlefield
NHL, the Palo Alto Battlefield NHL, and the NRHP-listed Brazos Santiago Depot. The VIA was
prepared in accordance with procedures of the BLM’s Visual Resource Management (VRM)
System (1984). FERC requested that Annova also assess the visual effect of the Project under
Section 106 of the NHPA for the two NHLs and the Brazos Santiago Depot.
On April 5, 2017 Annova submitted to the SHPO an assessment of the Project’s visual
effect on the Palmito Ranch Battlefield NHL, the Palo Alto Battlefield NHL, and the Brazos
Santiago Depot. The NPS also received a copy of the visual assessment. The study found that
while the Project would introduce a new visual component to the setting outside of the NHLs and
NRHP-listed properties’ boundaries, each property would retain its overall integrity such that each
would continue to convey the characteristics and qualities that made it eligible for the NHL and/or
NRHP. The SHPO concurred on May 4, 2017 that the Project would have no adverse effect on
these properties with regard to potential visual effects. We agree with the SHPO’s findings.
Annova sent letters to SHPO and NPS again on April 26, 2018 requesting comment on visual
effects to historic properties. The SHPO concurred that the Project would have no major visual
impact on nearby historic resources or historic properties. We agree with the SHPO’s
recommendations. On August 22, 2018, NPS notified Annova that the reports are adequate and
meet professional standards. In a March 13, 2019 letter, NPS provided comments on the draft EIS
indicating that the agency disagrees with the definition of the indirect APE and believes the visual
effects of the Project on Palmito Ranch Battlefield NHL and Palo Alto Battlefield National
Historical Park (NHP) would be adverse. The effects to the viewsheds of all three properties
(Palmito Ranch Battlefield NHL, Palo Alto Battlefield NHL, and Brazos Santiago Depot) are
discussed below. Additional analysis of the aesthetic impacts is presented in section 4.8.4.
Annova also sent letters to SHPO and NPS on April 26, 2018, regarding auditory effects
to the Palmito Ranch Battlefield NHL. The SHPO concurred that the Project would have minimal
audible impact on the NHL. We agree with the SHPO’s findings. On August 22, 2018, NPS
notified Annova that the reports are adequate and meet professional standards. In the same March
13, 2019 comment letter described above, NPS indicated that they also believe the Project’s

auditory effects to the Palmito Ranch Battlefield NHL and Palo Alto Battlefield NHP would be
adverse.
Palmito Ranch Battlefield NHL

The Palmito Ranch Battlefield NHL, which is located on the south side of SH 4 at the
intersection with the main access road, is the only historic property within the indirect APE for the
Project. The NPS and American Battlefield Protection Program have stated that that while the
Project would have no direct effect on the Palmito Ranch Battlefield NHL, a potential indirect
visual effect is a concern.
The Palmito Ranch Battlefield originally was listed in the NRHP under Criteria A (Events)
and D (Information Potential). The battleground is the location of the last engagement of the U.S.
Civil War and dates to an event in 1865. The NHL includes a Core Battlefield Area, which is the
primary area of interpretation and is the focal point of activities associated with the Civil War
event. An observation platform in this location provides visitors with a 360-degree view of the
battlefield. The Core Battlefield Area is located along Palmito Hill Road and is approximately 3.6
miles from the Project site.
Information from the analysis of KOPs 1, 2, and 3 in the VIA was used to help determine
the potential effects of the Project on the NHL. At KOP 1, a roadside marker 3 miles to the
southwest of the Project, vertical components of the Project would be visible within 3 to 5 miles
and silhouetted against the sky above a flat horizon. At KOP 2, the Palmito Ranch Battlefield
Observation Platform 3.4 miles south of the Project, project components would not be visible due
to dense vegetation. If the vegetation were to be removed, the Project would be visible. At KOP
3, the Rio Grande Valley NWR 2.4 miles southeast of the Project and adjacent to the NHL, Project
components would also be obscured by vegetation. Although simulations prepared for the VIA
did not include the wildlife corridor barrier wall at the southwest edge of the Project site, the
proposed 25-foot-high wall would be significantly shorter than other project components that were
included in the visual simulations, and the barrier wall would be expected to be obscured by
vegetation from KOPs 1, 2, and 3.
Due to the distance of the primary Project components (i.e., built structures), the
relationships of open space within the NHL would remain unchanged, along with the topographic
and natural features that comprise it. Visible changes, however, would occur in the setting
surrounding the property because the Project would be among the limited infrastructure that breaks
above the horizon line; it would be visible from within the NHL, especially if vegetation is absent.
The addition of the proposed access road also would add to the presence of the existing
infrastructure and detract from the natural appearance of the battlefield at its boundaries. The
access road would be built on a raised berm with a paved asphalt and limestone surface. The
roadway itself would not be as visible from within the NHL due to the lack of a vertical dimension
and the presence of roadside vegetation. During construction of the access road, activity would be
more apparent in this location and, once in operation, lighting and signage may be present that
would affect the setting of the NHL.
Since the battlefield is large and the presence of vegetation is variable, the addition of the
Project, while introducing new elements to the setting, does not diminish the overall quality of it.

This is, in part, due to the manner in which one experiences the NHL. Views of the NHL largely
face away from the Project and focus inward to the core interpretive area of the battlefield (i.e.,
the Core Battlefield Area), which is screened in part by existing vegetation.
The Project would not affect the essential features of the Palmito Ranch Battlefield for the
period of significance (the Civil War) and its overall integrity would remain intact.
Palo Alto Battlefield National Historical Park and NHL

The Palo Alto Battlefield NHP and NHL is located approximately 6.3 miles north of
Brownsville in Cameron County, and approximately 9.1 miles west of the Project site (measured
to the eastern boundary of the NHL). As previously noted, the Palo Alto Battlefield NHP and
NHL is located outside the established direct and indirect APEs. However, given concerns voiced
by cooperating agencies, it is included here.
This battlefield was the site of one of only two important battles fought on American soil
during the Mexican War. Its period of significance is from 1800 to 1899 with a specific date of
1846. The property is listed in the NRHP and NHL for its association with an event (Criterion A)
significant in our nation’s history. The setting of the property has largely remained intact due to
the lack of extensive development within its vicinity, and the Palo Alto Battlefield conveys a strong
visual sense of the area as it might have appeared during its period of significance and retains its
integrity of location, setting, feeling, and association. The Palo Alto Battlefield NHP and NHL is
managed by the NPS as an historical park and includes an interpretive center, trails, and outlook
area.
Information from the analysis of KOP 10 in the VIA was used to help determine the
potential effects of the Project on the property. At KOP 10, a visitor overlook viewing platform
approximately 12.4 miles west of the Project site, project components would be minimally visible
just above the horizon. However, changes to the Project site as a result of grading and vegetation
removal would not be visible.
No part of the NHP or NHL would be physically moved or directly altered. Due to the
distance of over 12 miles between the property and the primary Project components (i.e., built
structures), the relationships of open space within the NHP and NHL would remain unchanged,
along with the topographic and natural features that comprise it. Visible changes would occur in
the setting outside the boundaries of the property, as the Project would be among the limited
infrastructure that breaks above the horizon line. The Project would appear faintly visible from
locations within and at the borders of the NHP and NHL. Due to the large size of the battlefield
(and its associated historic park) and the variable presence of vegetation, the addition of the Project
would not diminish its setting.
The Project would not affect the essential features of the Palo Alto Battlefield for the period
of significance (the Mexican War) and its overall integrity would remain intact.

Brazos Santiago Depot

The Brazos Santiago Depot is located approximately 5.5 miles to the east of the Project
site. The NRHP-listed historic property is located outside the direct and indirect APEs. However,
given concerns voiced by cooperating agencies, it is included here.
The Brazos Santiago Depot is recorded as archaeological site 41CF4. The site consists of
the remains of a 19th century historic military depot. It was listed in the NRHP in 1971 for its
association with significant national themes of historic commerce, non-aboriginal history, historic
military, and historic transportation (Criteria A) as well as the site’s potential to yield additional
information significant to the nation’s history (Criterion D). It is classified as a submerged
archaeological site due to the deflation of the land mass upon which it was originally sited.
Information from the analysis of KOP 5 in the VIA was used to help determine the potential
effects of the Project on the Brazos Santiago Depot, as an historic property. At KOP 5, the Isla
Blanca Park Boat Ramp approximately 6.7 miles east of the Project, some project components
would be visible above the flat horizon. However, landform grading and vegetation removal
would not likely be visible. In general, the Project would appear subordinate to or co-dominant
with other structures within the view.
The historic property is significant for its ability to convey information and to yield data to
help address important research questions. The Project would not affect these qualities, as no
direct effects would occur. Since the site is primarily submerged, the aboveground setting is not
a primary consideration when assessing effects to this site. While the Project may be visible from
the location of the Brazos Santiago Depot, the construction and operation of the Project would not
affect the site’s potential to provide information about its period of significance or to yield
information about the past.
4.10.1.3 Geophysical Underwater Survey
The SHPO has identified a shipwreck within the BSC near the Project area, known locally
at the PT Brownsville. The SHPO indicated in a letter on November 17, 2016, that the wreck is
within the APE. However, the letter also states that the wreck is no longer listed in the Automated
Wrecks and Obstruction Information System, which suggests it may no longer be present.
Annova commissioned a combined bathymetric, geophysical, and archaeological survey

of a 204-acre area within the BSC to provide detailed information about the existing underwater
conditions where installation of sheet piles and tubular piles would occur to construct the marine
berth and marine transfer facilities. No major magnetic signatures were identified nor were any
archaeological sites of cultural significance identified during the bathymetric survey, suggesting
the wreck is not in the work area (as noted in the SHPO’s November 17, 2016 letter). However,
the SHPO also noted there is a possibility that it could still exist. The SHPO requested that the
State Marine Archaeologist be contacted in the event the wreck is encountered during construction.
Annova has proposed that if future dredging activity must extend outside the currently
identified area, a certified archaeologist with training in historic vessel and artifact recognition as
well as the use of navigation survey software would monitor the dredging activities. The monitor

would have the authority to halt or alter the location of dredging operations in the event the remains
of an historic shipwreck are identified.
4.10.2 Unanticipated Discovery Plan
Annova prepared an Unanticipated Discovery Plan (UDP) that would be implemented in

the event that cultural resources or human remains are encountered during construction. In a letter
dated August 3, 2015, the SHPO concurred with the proposed plan. On November 9, 2016,
Annova summited a revised plan in response to comments of FERC staff. We find the revised
plan to be acceptable.
4.10.3 Native American Consultation
On March 27, 2015, Annova wrote to the following federally recognized tribes: the
Alabama Coushatta Tribe of Texas, the Comanche Nation of Oklahoma, and the Tonkawa Tribe
of Oklahoma. Annova also wrote to the Lipan Apache Tribe of Texas and the Tap Pilan
Coahuiltecan Nation, both state-recognized tribes. On April 2, 2015, the Comanche Nation of
Oklahoma responded and on April 17, 2015, the Tonkawa Tribe of Oklahoma responded. Both
tribes emphasized the need for coordination with the SHPO and compliance with the Native
American Graves Protection and Repatriation Act. The Tonkawa Tribe of Oklahoma stated they
have no historical or cultural interest in the Project. On July 9, 2015, Annova contacted the Lipan
Apache Tribe of Texas via telephone and a tribal representative indicated that their ancestors were
not culturally affiliated with the prehistoric people of South Texas, but would assist Annova with
the compliance protocols associated with the UDP, if needed. Annova submitted the UDP to the
Alabama Coushatta Tribe of Texas, the Comanche Nation of Oklahoma, the Lipan Apache Tribe
of Texas, and the Tonkawa Tribe of Oklahoma on July 23, 2015. Subsequently, on December 7,
2015, Annova wrote to the Kickapoo Tribe of Oklahoma, to the Kickapoo Traditional Tribe of
Texas, and to the American Indians in Texas at the Spanish Colonial Missions. To date, no
additional responses have been received from the tribes.
The FERC sent its July 23, 2015 NOI for the Project to the same federally recognized tribes
as above, and on August 27, 2015 we wrote letters to the same federally recognized tribes
requesting their comments on the Project. No responses have been received to date.
4.10.4 Impacts and Mitigation
Construction and operation of the Project could potentially affect historic properties (i.e.,
cultural resources listed in or eligible for listing in the NRHP). Direct effects could include
destruction or damage to all, or a portion, of an historic property. Indirect effects could include
the introduction of visual, atmospheric, or audible elements that affect the setting or character of a
historic property.
If NRHP-eligible resources are identified which cannot be avoided the applicants would
prepare treatment plans for review and approval by the appropriate parties including the FERC,
the SHPOs and Indian tribes. The FERC would afford the ACHP an opportunity to comment in
accordance with 36 CFR 800.6. Implementation of a treatment plan would only occur after
certification of the project and the FERC provides written notification to proceed.

4.10.5 Conclusions and Recommendation
Compliance with Section 106 of the NHPA has not been completed for the project. Annova
has not completed cultural resources surveys of some sensitive shrub habitat to avoid clearing in
this area prior to Project authorization, as well as in some historical tidal flat areas, or NRHP
eligibility testing of archaeological site 41CF48. Additionally, consultation with the SHPO,
Federal Land Managers, Indian tribes and other parties is incomplete.
To ensure that the FERC’s responsibilities under the NHPA and its implementing
regulations are met, we recommend that:
• Annova should not begin construction of facilities and/or use of staging, storage,
or temporary work areas and new or to-be-improved access roads until:
a. Annova files with the Secretary:

(i) remaining cultural resources survey report(s);
(ii) site evaluation report(s) and avoidance/treatment plan(s), as
required; and
(iii) comments on all cultural resources reports and plans from the
Texas State Historic Preservation Office, and NPS for reports
and plans that affect NPS properties.
b. the Advisory Council on Historic Preservation is afforded an
opportunity to comment if historic properties would be adversely
affected; and
c. the FERC staff reviews and the Director of OEP approves the cultural
resources reports and plans, and notifies Annova in writing that
treatment plans/mitigation measures (including archaeological data
recovery) may be implemented and/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
relevant pages therein clearly labeled in bold lettering: CUI/PRIV
“CONTAINS PRIVILEGED INFORMATION - DO NOT RELEASE."

4.11 AIR QUALITY AND NOISE

4.11.1 Air Quality
Air quality would be affected by construction and operation of the Project. Though air
emissions would be generated by operation of equipment during construction of the Project
facilities, most air emissions associated with the Project would result from the long-term operation
of the Project. As indicated in section 2.1.2, the liquefaction facilities would be primarily
electrically powered; however, this section identifies the estimated direct and indirect emissions
from construction and operation of the Project and identifies the associated impacts.
Operation of the Project’s three medium fired heaters and its thermal oxidizer, as well as
some minor contributions from other equipment, would involve the combustion of fossil fuels.
Combustion of natural gas would produce criteria air pollutants such as ozone (O3), carbon
monoxide (CO), sulfur dioxide (SO2), and inhalable particulate matter (PM2.5 and PM10). PM2.5
includes particles with an aerodynamic diameter less than or equal to 2.5 micrometers, and PM10
includes particles with an aerodynamic diameter less than or equal to 10 micrometers. Combustion
of fossil fuels also produces volatile organic compounds (VOC), a large group of organic
chemicals that have a high vapor pressure at room temperature; and oxides of nitrogen (NOx).
VOCs react with nitrogen oxides, typically on warm summer days, to form ozone. Other
byproducts of combustion are greenhouse gases (GHG) and hazardous air pollutants (HAP). HAPs
are chemicals known to cause cancer and other serious health impacts.
GHGs produced by fossil-fuel combustion are CO2, methane (CH4), and nitrous oxide
(N2O). The status of GHGs as a pollutant is not related to toxicity. GHGs are non-toxic and non-
hazardous at normal ambient concentrations. Elevated levels of GHG emissions are the primary
cause of warming of the global climate system since the 1950s. Emissions of GHGs are typically
expressed in terms of CO2 equivalents (CO2e).
Other pollutants, not produced by combustion, are fugitive dust and fugitive emissions.
Fugitive dust is a mix of PM2.5, PM10, and larger particles thrown up by vehicles, earth movement,
or wind erosion. Fugitive emissions, in the context of this EIS, would be fugitive emissions of
methane from operational pipelines and aboveground facilities.
4.11.1.1 Regional Climate

The Project area climate – humid subtropical – is significantly influenced by its location in
the Texas Coastal Zone (i.e., proximity to the Gulf of Mexico). In general, the Port Isabel area has
very short, mild winters and long hot summers, although the sea breeze can help moderate peak
temperatures. Climate data obtained from NOAA for the period 1981 to 2010 show an annual
average temperature of 74°F. Daily average high temperatures range from 68°F during January to
91°F during August. Daily average low temperatures range from 52°F during January to 77°F
during July and August. The record minimum and maximum temperatures are 17°F and 103°F,
respectively (NOAA 2016a). The region experiences relatively high dew point values (about 75°F
in summer), resulting in higher relative humidity for the June through September period.
Monthly total rainfall tends to be highest (greater than 2 inches) during the early summer
and autumn months. The annual average precipitation amounts to approximately 29 inches, with
Air Quality and Noise 4-168

a monthly maximum of 6.3 inches in September (NOAA 2016a). Much of this precipitation comes
from thunderstorm activity, although the majority of days that receive precipitation experience
light rain. Tropical storms or hurricanes, although uncommon, can also enhance summer and
autumn rainfall in this region.
The overall predominant wind pattern for the year in the extreme southern Texas Coastal
Zone is southeasterly winds, with northwesterly winds dominating at times in the cooler part of
the year, particularly December. The annual average wind speed is approximately 10 mph, with
the highest average monthly wind speeds occurring during spring (NOAA 2016a). The prevailing
southeast wind is further enhanced during spring and early summer by thermal winds which
develop when the air over the heated land farther west from the coast is warmer than the air over
the relatively cooler waters of the Gulf of Mexico.
4.11.1.2 Existing Air Quality

Ambient Air Quality Standards
The EPA has established National Ambient Air Quality Standards (NAAQS) for six criteria
pollutants: SO2, CO, O3, nitrogen dioxide (NO2), PM10, PM2.5, and lead. There are two
classifications of NAAQS, primary and secondary standards. Primary standards set limits the EPA
believes are necessary to protect human health including sensitive populations such as children,
the elderly, and asthmatics. Secondary standards are set to protect public welfare from detriments
such as reduced visibility and damage to crops, vegetation, animals, and buildings.
Individual state air quality standards cannot be less stringent than the NAAQS. The federal
NAAQS for criteria pollutants are the same as the state standards established by the TCEQ in
accordance with Section 30 of the TAC, Rule §101.21. The TCEQ has also established 30-minute
average property line standards for SO2 and H2S in 30 TAC §112. The federal NAAQS and Texas-
specific standards (referenced as net ground-level concentrations) are summarized in table 4.11.1-1.
As with any activity that involves combustion of fossil fuels and processing of natural gas,
the Project would contribute GHG emissions. The principal GHGs that would be produced by the
Project are CO2, CH4, and N2O. Emissions of GHGs are quantified and regulated in units of carbon
dioxide equivalents (CO2e). The GHG CO2e unit of measure takes into account the global
warming potential (GWP) of each GHG. The GWP is a ratio relative to CO2 that is based on the
particular GHG’s ability to absorb solar radiation as well its residence time within the atmosphere.
Based on this definition, CO2 has a GWP of 1, CH4 has a GWP of 25, and N2O has a GWP of 298.
To obtain the CO2e quantity, the mass of the particular GHG compound is multiplied by the
corresponding GWP, the product of which is the CO2e for that compound. The CO2e value for
each of the GHG compounds is summed to obtain the total CO2e GHG emissions.
4-169 Air Quality and Noise

TABLE 4.11.1-1
Ambient Air Quality Standards

Pollutant Averaging Period Primary NAAQS Secondary NAAQS Texas NGLC
Ozone (O3) 8-Hour (2008) a/ 0.075 ppm 0.075 ppm -

1-Hour b/ 35 ppm - -
Carbon monoxide (CO) 8-Hour b/ 9 ppm - -
1-hour c/ 100 ppb - -
Nitrogen dioxide (NO2) Annual d/ 53 ppb 53 ppb -
24-Hour e/ 35 µg/m3 35 µg/m3 -
PM2.5 Annual f/ 12 µg/m3 15 µg/m3 -
PM10 24-Hour g/ 150 µg/m3 150 µg/m3 -
Lead 3-Month h/ 0.15 µg/m 3

0.15 µg/m 3
-
Sulfur dioxide (SO2) 1-Hour i/, j/ 75 ppb - -
3-Hour b/ - 0.5 ppm -
30-minute - - 0.4 ppm k/
Hydrogen sulfide (H2S) 30-minute - - 0.08/0.12 ppm l/
______________________
a/ Annual fourth-highest daily maximum 8-hour concentration, averaged over 3 years.
b/ Not to be exceeded more than once per year.
c/ The 98th percentile of daily maximum 1-hour average concentrations, averaged over 3 years.
d/ Annual arithmetic mean.
e/ The 98th percentile of 24-hour concentrations, averaged over 3 years.
f/ Annual arithmetic mean, averaged over 3 years.
g/ Not be exceeded more than once per year on average over 3 years.
h/ Not to be exceeded.
i/ The 99th percentile of daily maximum 1-hour concentrations, averaged over 3 years.
j/ The 24-hr and annual SO2 NAAQS were revoked in 2010 (75 Federal Register 35520); however, standards remain
in effect until one year after an area is designated attainment or nonattainment for the 1-hour standard, except in
areas designated nonattainment for the 1971 standard, where the 1971 standards remain in effect until
implementation plans to attain or maintain the 2010 standard are approved.
k/ Net ground-level concentration not to be exceeded at the property boundary.
l/ Net ground-level concentration of 0.08 ppm not to be exceeded on property normally occupied by people and net
ground-level concentration of 0.12 ppm not to be exceeded on property that are not normally occupied by people.
µg/m3 = micrograms per cubic meter; ppm = parts per million; ppb = parts per billion; NAAQS = National Ambient Air Quality
Standards; NGLC = net ground-level concentration; PM2.5/10 = particulate matter less than 2.5 or 10 microns in diameter
Air Quality Control Regions and Attainment Status

Air Quality Control Regions (AQCR) are areas established for air quality planning
purposes in which implementation plans describe how ambient air quality standards will be
achieved and maintained. AQCRs were established by the EPA and local agencies, in accordance
with Section 107 of the CAA and its amendments, as a means to implement the CAA and comply
with the NAAQS through State Implementation Plans (SIP). The AQCRs are intrastate and
interstate regions such as large metropolitan areas where the improvement of the air quality in one
portion of the AQCR requires emission reductions throughout the AQCR. The entire Project area
is located in the Brownsville Laredo Intrastate AQCR (AQCR 213).
An AQCR, or portion thereof, is designated based on compliance with the NAAQS. There
are three AQCR designations: attainment (areas in compliance with the NAAQS); nonattainment
(areas not in compliance with the NAAQS); or unclassifiable. AQCRs that were previously
designated nonattainment but have since met the requirements to be classified as attainment are
classified as maintenance areas. The Brownsville Laredo Intrastate AQCR is designated as better
than national standards, as unclassifiable, or as attainment for all criteria pollutants.

Transport of construction materials associated with the Project could occur within the
Houston-Galveston-Brazoria (HGB) area, which is a marginal nonattainment area for the 2008 8-
hour ozone standard. Construction emissions from the Project occurring within the HGB area
would not be expected to result in an exceedance of applicable general conformity thresholds for
the HGB area.
Air Quality Monitoring and Existing Air Quality

Air quality monitors are located throughout the state to determine existing levels of various
air pollutants. Air quality monitoring data obtained from the EPA AirData and the TCEQ Air
Quality Data databases can be used to characterize ambient air quality for regulated criteria
pollutants in the vicinity of the Project. Data for 2012 to 2014 for SO2, CO, NO2, O3, PM10, PM2.5,
and lead from representative Project area monitors are summarized in table 4.11.1-2.
4.11.1.3 Regulatory Requirements for Air Quality

The Project would be potentially subject to a variety of federal and state regulations
pertaining to the construction or operation of air emission sources. The TCEQ has the primary
jurisdiction over air emissions produced by stationary sources associated with the Project. The
TCEQ is delegated by the EPA to implement federal air programs. The following sections
summarize the applicability of various state and federal regulations.
Federal Air Quality Requirements

The CAA, 42 USC 7401 et seq., as amended in 1977 and 1990, and 40 CFR Parts 50
through 99 are the basic federal statutes and regulations governing air pollution in the U.S. The
following federal requirements have been reviewed for applicability to the Project.
• New Source Review (NSR) / Prevention of Significant Deterioration;

• Title V Operating Permits;
• New Source Performance Standards (NSPS);
• National Emission Standards for Hazardous Air Pollutants (NESHAP);
• Greenhouse Gas Reporting;
• Chemical Accident Prevention Provisions; and
• General Conformity.
New Source Review/Prevention of Significant Deterioration

Separate preconstruction review procedures for major new sources of air pollution (and
major modifications of major sources) have been established for projects that are proposed to be
built in attainment areas versus nonattainment areas. The preconstruction permit program for new
or modified major sources located in attainment areas is called PSD. This review process is
intended to keep new air emission sources from causing existing air quality to deteriorate beyond
acceptable levels codified in the federal regulations. Construction of major new stationary sources
in nonattainment areas must be reviewed in accordance with the nonattainment NSR regulations,
which contain stricter thresholds and requirements.

TABLE 4.11.1-2
Existing Ambient Air Concentrations for the Project Area

Monitor Information
Averaging Measured Air Quality Control Location
Pollutant Period Concentration a/ Units Region (AQCR) b/ - County Site ID No.
1-hour 5.3 ppb
3-hour 0.0032 ppm 48-355-0025 (Corpus
Sulfur Dioxide (SO2) AQCR 214 Nueces
24-hour c/ 1.4 ppb Christi West)
Annual c/ 0.0003 ppm
1-hour 1.6 ppm 48-061-0006
Carbon Monoxide (CO) AQCR 213 Cameron
8-hour 1.0 ppm (Brownsville)
1-hour 19.7 ppb 48-039-1016 (Lake
Nitrogen Dioxide (NO2) AQCR 216 Brazoria
Annual 1.8 ppb Jackson)
48-061-0006
Ozone 8-hour 58.7 ppb AQCR 213 Cameron
(Brownsville)
48-061-0006 e/
Particulate Matter (PM10) 24-hour 50.3 d/ µg/m3 AQCR 213 Cameron
(Brownsville)
4-hour 24.0 µg/m3 48-061-2004 f/ (Isla
Particulate Matter (PM2.5) AQCR 213 Cameron
Annual 10.3 µg/m3 Blanca)
Rolling 3- 48-061-0006
Lead (Pb) 0.078 g/ µg/m3 AQCR 213 Cameron
month (Brownsville)
______________________
a/ Measured concentration shown matches the statistic of the NAAQS, as noted in table 4.11.1-1. Three-year averages are
derived from 2012 to 2014 data. For CO, value shown is the highest occurring in the 2012 to 2014 period.
b/ AQCRs: AQCR 213: Brownsville-Laredo Intrastate; AQCR 216: Metropolitan Houston-Galveston Intrastate; AQCR 214:
Corpus Christi-Victoria Intrastate
c/ The 24-hour and annual SO2 standards were revoked in 2010. However, these standards remain in effect until one year
after an area is designated for the 1-hour SO2 standard.
d/ Value shown is maximum second highest average from 2010 to 2012 data.
e/ Data for PM10 at the Brownsville station is from 2010-2012.
f/ Data for PM2.5 at the Isla Blanca station is from 2011-2013.
g/ Three-month rolling averages are not yet available for Pb from AQS Data Mart. In lieu of this value, the highest 24-hour first
maximum value for the 2012 to 2014 period is shown.
µg/m3 = micrograms per cubic meter; ppm = parts per million; ppb = parts per billion
The PSD rule defines a major stationary source as any source with a potential to emit (PTE)
100 tons per year (tpy) or more of any criteria pollutant for source categories listed in 40 CFR
§52.21(b)(1)(i) or 250 tpy or more of any criteria pollutant for source categories that are not listed.
If a new source is determined to be a major source for any (non-GHG) PSD pollutant, then other
remaining criteria pollutants (including GHG) would be subject to PSD review if those pollutants
are emitted at rates that exceed the following significant emission thresholds: 100 tpy for CO; 40
tpy each for nitrogen oxides (NOx), volatile organic compound (VOC), and SO2; 25 tpy for total
suspended particulate; 15 tpy for PM10; 10 tpy for (direct) PM2.5; and 75,000 tpy for GHG as CO2e.
Sources that exceed the major source threshold are then subject to a PSD review.
The EPA defined air pollution to include the mix of six long-lived and directly emitted
GHGs, finding that the presence of the following GHGs in the atmosphere may endanger public
health and welfare through climate change: CO2, CH4, N2O, hydrofluorocarbons,
perfluorocarbons, and sulfur hexafluoride. The PSD GHG Tailoring Rule intends to account for
facilities that represent an estimated 70 percent of GHG emissions. This rule applies to all
industrial sources that are major sources of any NSR-regulated pollutant other than GHGs and
emit or have the potential to emit 75,000 tpy or more of CO2e.

As shown in table 4.11.1-4 (in section 4.11.1.4), the stationary sources associated with the
Project would have operating emissions that are less than the PSD major source thresholds for all
(non-GHG) pollutants. Although potential emissions of GHG are above the PSD significant
emission threshold, the requirements of PSD are not triggered if GHG is the only pollutant above
this threshold. Therefore, the Project would not be subject to PSD review.
An additional factor considered in PSD permit review is potential impact on protected

Class I areas. Class I areas were designated as pristine natural areas or areas of natural significance
and have the lowest increment of permissible deterioration, which precludes development near
these areas. Class I areas are given special protection under the PSD program. However, as
described in section 4.11.1.6, because the proposed Project site is more than 300 kilometers (186.4
miles) from the nearest Class I area, and because the Project’s potential emissions would make it
a minor source with respect to PSD, a Class I analysis is not required for the Project.
Title V Operating Permits

Title V of the CAA requires states to establish an air quality operating permit program.
The requirements of Title V are outlined in the federal regulations in 40 CFR Part 70 and in state
regulations at 30 TAC §122. The operating permits required by these regulations are often referred
to as Title V or Part 70 permits.
Major sources (i.e., sources with a PTE greater than a major source threshold level) are
required to obtain a Title V operating permit. Title V major source threshold levels are 100 tpy
for CO, SO2, PM10, or PM2.5; 10 tpy for an individual HAP; or 25 tpy for any combination of
HAPs. The recent Title V GHG Tailoring Rule also requires facilities that have the potential to
emit GHGs at a threshold level of 100,000 tpy CO2e be subject to Title V permitting requirements.
The Project would be subject to the Title V program because the stationary source
emissions would exceed the major source thresholds for CO and GHGs. Therefore, Annova would
need to apply for and obtain a Title V operating permit.
New Source Performance Standards

NSPS regulations (40 CFR Part 60) establish pollutant emission limits and monitoring,
reporting, and recordkeeping for emission sources based on source type and size, and apply to
new, modified, or reconstructed sources. The following NSPS requirements are potentially
applicable to the specified proposed stationary sources at the Annova LNG terminal.
Subpart Db of 40 CFR Part 60, Standards of Performance for Industrial-Commercial-

Institutional Steam Generating Units, applies to steam generating units constructed after June 19,
1984, and that have a maximum heat input capacity of greater than 100 million British thermal
units per hour (MMBtu/hr). The three natural gas–fired heaters for the liquefaction trains would
each have a maximum heat input rating of 143.6 MMBtu/hr and would be subject to Subpart Db.
Gas-fired boilers are subject to a NOx rate of either 0.20 lb/MMBtu (for boilers with a high heat
release rate, defined as a heat input per cubic foot of furnace volume of greater than 70,000 Btu/hr),
or 0.10 lb/MMBtu (for boilers with a low heat release rate, defined as a heat input per cubic foot
of furnace volume of 70,000 Btu/hr or less). The heaters would use ultra-low NOx burners to

achieve an emission rate of 0.035 lb/MMBtu, in compliance with Subpart Db. The SO2 and PM
emission limits in Subpart Db do not apply to boilers that only burn natural gas.
Subpart Kb of 40 CFR Part 60, Standards of Performance for Volatile Organic Liquid
Storage Vessels, applies to storage vessels containing volatile organic liquids depending on
construction date, size, vapor pressure, and contents of the storage vessel. Subpart Kb applies to
new tanks, unless otherwise exempted, that have a storage capacity between 75 m3 (19,813 gallons)
and 151 m3 (39,890 gallons) and contain VOCs with a maximum true vapor pressure greater than
or equal to 15.0 kilopascals (kPa). Subpart Kb also applies to tanks that have a storage capacity
greater than or equal to 151 m3 and contain VOCs with a maximum true vapor pressure greater
than or equal to 3.5 kPa. Pressure tanks are exempt from the requirements of Subpart Kb.
The two LNG storage tanks would have a capacity of 160,000 m3, which would meet the
volume criteria for Subpart Kb. The LNG is considered a volatile organic liquid because a small
portion of the LNG would consist of VOCs. The LNG storage tanks would operate at
approximately -260°F and the true vapor pressure of the VOC (assumed to be propane) at this
temperature is 0.0007 kPa. This would be well below the applicability threshold of 3.5 kPa;
therefore, Subpart Kb would not apply to the LNG storage tanks. The condensate storage tank at
the Project would have a capacity of 282,000 gallons (1,067 m3), which is greater than 151 m3;
however, the material stored would have a true vapor pressure of less than 3.5 kPa, and therefore
Subpart Kb would not apply. Additionally, there would be three diesel fixed-roof storage tanks
located at the Project. The tanks would each have a capacity less than 75 m3, and therefore would
be exempt from Subpart Kb based on size.
Subpart JJJJ of 40 CFR Part 60, Standards of Performance for Stationary Spark Ignition
Internal Combustion Engines, applies to spark ignition engines with a maximum engine power
greater than 25 hp for which construction commenced by July 12, 2006, and which were
manufactured after January 1, 2009. The Project’s six natural gas-fired standby generators, each
rated at approximately 3 megawatts (MW) of electrical output, would meet these applicability
criteria and would therefore subject to the requirements of Subpart JJJJ. In order to demonstrate
compliance with the emission limits found in the rule, owners and operators may either operate a
manufacturer-certified engine according to manufacturer’s operation and maintenance procedures
or conduct performance testing. Owners/operators of emergency engines are required to keep
records of their hours of operation. Additionally, maintenance records must be kept for all engines.
Subpart IIII of 40 CFR Part 60, Standards of Performance for Stationary Compression
Ignition Internal Combustion Engines, applies to diesel-fueled stationary compression ignition
internal combustion engines of any size that are constructed, modified, or reconstructed after July
11, 2005. The rule requires manufacturers of these engines to meet emission standards based on
engine size, model year, and end use. The rule also requires owners and operators to configure,
operate, and maintain the engines according to specifications and instructions provided by the
engine manufacturer. These requirements of Subpart IIII would apply to the Project’s mission
critical diesel electric generator rated at approximately 2.5 MW of electrical output, and to the
three diesel firewater pump engines rated at 750 hp each. The record-keeping and reporting
requirements would also apply. The mission critical diesel electric generator and the firewater
pump engines would normally operate only for testing and maintenance purposes, and would be
limited to 100 hours of non-emergency operation per year.

National Emission Standards for Hazardous Air Pollutants

The NESHAP (40 CFR Parts 61 and 63) regulate HAP emissions. Part 61 (promulgated
prior to the 1990 Clean Air Act Amendments (CAAA)) regulates HAPs such as asbestos, benzene,
beryllium, coke oven emissions, inorganic arsenic, mercury, radionuclides, and vinyl chloride.
The 1990 CAAA established a list of 189 HAPs while directing the EPA to publish categories of
major sources and area sources of these HAPs, for which emission standards were to be
promulgated according to a schedule outlined in the CAAA. These standards, also known as the
Maximum Achievable Control Technology (MACT) standards, were promulgated under Part 63.
The 1990 CAAA defines a major source of HAPs as any source that has a PTE of 10 tpy for any
single HAP or 25 tpy for all HAPs in aggregate. Area sources are stationary sources that do not
exceed the thresholds for major source designation. Federal NESHAP requirements are
incorporated by reference in 30 TAC §113.55 and §113.00.
The annual PTE for HAP emissions from the stationary sources of the proposed Project
would be 5.2 tpy in aggregate (see section 4.11.1.5); therefore, the Project would not be a major
source of HAPs but would be classified as an area source of HAPs. Although an LNG liquefaction
and export terminal is not one of the source categories regulated under Part 63, NESHAP/MACT
standards could still apply for specific types of sources that support facility operations. The
NESHAP described in the following paragraphs have been identified as being potentially
applicable to specific sources at the Project.
Subpart ZZZZ of 40 CFR Part 63, NESHAP for Stationary Reciprocating Internal
Combustion Engines, applies to reciprocating internal combustion engines of all sizes located at
major and area sources of HAPs. Therefore, the six natural gas-fired standby generators, the
mission critical diesel electric generator, and the three diesel firewater pump engines would all be
subject to Subpart ZZZZ. However, as provided under 40 CFR 63.6590(c), the requirements of
Subpart ZZZZ are satisfied by meeting the applicable requirements of either 40 CFR Part 60,
Subpart IIII, or 40 CFR Part 60, Subpart JJJJ.
Greenhouse Gas Reporting Rule

Subpart W under 40 CFR Part 98, the Mandatory Greenhouse Gas Reporting Rule, requires
petroleum and natural gas systems that emit 25,000 metric tons or more of CO2e per year to report
annual emissions of GHG to the EPA. “LNG storage” and “LNG import and export equipment”
are industry segments specially included in the source category definition of petroleum and natural
gas systems. Equipment subject to reporting includes storage of LNG, regasification of LNG and
liquefaction of natural gas.
We required Annova to calculate estimated emissions of GHGs associated with the

construction and operation of the Project, including all direct and indirect emission sources. In
addition, GHG emissions were converted to total CO2e emissions based on the global warming
potential of each pollutant. The reporting rule does not apply to construction emissions; however,
we have included the construction emissions for accounting and disclosure purposes. GHG
emissions from operation of the stationary sources of the proposed Project may exceed the 25,000
metric ton threshold and therefore would be subject to the reporting rule. Annova would be
required to report actual GHG emissions in accordance with the provisions of 40 CFR Part 98.

Chemical Accident Prevention Provisions

The chemical accident prevention provisions, codified in 40 CFR Part 68, are federal
regulations designed to prevent the release of hazardous materials in the event of an accident and
minimize potential impacts if a release does occur. The regulations contain a list of substances
(including methane, propane, and ethylene) and threshold quantities for determining applicability
to stationary sources. If a stationary source stores, handles, or processes one or more substances
on this list in a quantity equal to or greater than specified in the regulation, the facility must prepare
and submit a risk management plan. A risk management plan is not required to be submitted to
the EPA until the chemicals are stored on-site at the facility.
If a facility does not have a listed substance on-site, or the quantity of a listed substance is
below the applicability threshold, the facility does not have to prepare a risk management plan.
However, if there is any regulated substance or other extremely hazardous substance onsite, the
facility still must comply with the requirements of the General Duty Clause in Section 112(r)(1)
of the 1990 CAAA. The General Duty Clause is as follows:
“The owners and operators of stationary sources producing, processing, handling

and storing such substances have a general duty to identify hazards which may result from
such releases using appropriate hazard assessment techniques, to design and maintain a
safe facility, taking such steps as are necessary to prevent releases, and to minimize the
consequences of accidental releases which do occur.”
Stationary sources are defined in 40 CFR Part 68 as any buildings, structures, equipment,
installations, or substance-emitting stationary activities which belong to the same industrial group,
that are located on one or more contiguous properties, are under control of the same person (or
persons under common control), and are from which an accidental release may occur. The Project
would have the capacity to store approximately 331,600,000 pounds of methane as LNG on-site.
However, the definition also states that the term “stationary source” does not apply to
transportation, including storage incidental to transportation, of any regulated substance or any
other extremely hazardous substance. The term “transportation” includes transportation subject to
oversight or regulation under 49 CFR Parts 192, 193, or 195. Based on these definitions, the
Project, which is subject to 49 CFR Part 193, would not require a risk management plan.
General Conformity
A conformity analysis must be conducted by the lead federal agency if a federal action
would result in the generation of emissions that would exceed the conformity threshold levels (de
minimis) of the pollutants(s) for which an AQCR is in nonattainment. According to
Section 176(c)(1) of the CAA (40 CFR §51.853), a federal agency cannot approve or support any
activity that does not conform to an approved SIP. Conforming activities or actions should not,
through additional air pollutant emissions:
• cause or contribute to new violations of the NAAQS in any area;

• increase the frequency or severity of an existing violation of any NAAQS; or
• delay timely attainment of any NAAQS or interim emission reductions.

General Conformity assessments must be completed when the total direct and indirect
emissions of a planned project would equal or exceed the specified pollutant conformity emission
thresholds per year in each nonattainment area.
A General Conformity Determination must show that the emissions would conform to the
applicable SIP and would not degrade air quality in the nonattainment area. This can be
demonstrated through acquisition of emission offsets, SIP revisions, or dispersion modeling. On-
site mitigation of emissions (i.e., controls above and beyond what is required by regulation) can
also be used to demonstrate conformity. According to 40 CFR §51.853, emissions from sources
subject to NSR or PSD requirements are exempt and are deemed to have conformed.
As discussed in section 4.11.1.2, the Project facilities would be located in an area currently
designated by EPA as better than national standards, as unclassifiable, or as in attainment for all
criteria pollutants. Operating emissions for these facilities would be located entirely within
designated unclassifiable/attainment areas for all criteria air pollutants and would be subject to
evaluation under the PSD permitting program; therefore, these emissions are not subject to General
Conformity regulations.
However, during the construction phase of the Project, barges carrying equipment and
materials could potentially travel through nonattainment areas en route to the Project site.
Although Annova has not yet determined where equipment deliveries would originate, Annova
evaluated a hypothetical scenario to estimate marine vessel construction emissions for barge travel
through the HGB ozone nonattainment area, where the Port of Houston is located. Annova
estimates a total of 24 to 36 barge deliveries to the Project site per year would be required during
construction. This hypothetical scenario assumes that up to 25 barge round trips per year of
construction would originate and terminate at the Port of Houston. The construction barge traffic
emissions associated with travel in the HGB ozone nonattainment area would be subject to
evaluation under General Conformity regulations. The relevant general conformity pollutant
thresholds for the HGB ozone nonattainment area are 100 tpy of NOx and VOC (ozone precursors).
Annova estimated emissions from tug vessels that push the barges using the methodology
and emission factors described in EPA’s Current Methodologies in Preparing Mobile Source Port-
Related Emission Inventories (ICF International 2009). The emissions assumed one tugboat per
barge, rated at 2,000 hp with an engine load factor of 0.85, and traveling at an average speed of 5
miles per hour. For the purpose of estimating the distance and duration of travel within the HGB
ozone nonattainment area, Annova selected the Barbours Cut container terminal at the Port
Authority of Houston as the origin point for barge trips. This results in a one-way travel distance
of approximately 80 miles within the HGB ozone nonattainment area, which ends at the
Brazoria/Matagorda county boundary.
Annova estimated that the total potential direct and indirect emissions from construction
barge travel in the HGB ozone nonattainment area would be 7.6 tpy of NOx and 0.3 tpy of VOCs.
Based on these emissions, a General Conformity Determination is not required for the Project.

Applicable State Air Quality Requirements

In addition to the federal regulations identified above, the TCEQ has its own air quality
regulations, codified in 30 TAC. State requirements potentially applicable to the Project include:
• 30 TAC Chapter 101, Subchapter A – General Rules.

• 30 TAC Chapter 111 – Control of Air Pollution from Visible Emissions and
Particulate Matter.
• 30 TAC Chapter 112 – Control of Air Pollution from Sulfur Compounds.
• 30 TAC Chapter 113 – Control of Air Pollution from Toxic Materials. Chapter 113
incorporates by reference the NESHAP source categories (40 CFR Part 63).
• 30 TAC Chapter 114 – Control of Air Pollution from Motor Vehicles.
• 30 TAC Chapter 115 – Control of Air Pollution from Volatile Organic Compounds.
• 30 TAC Chapter 116, Subchapter B – Control of Air Pollution by Permits for New
Construction or Modification.
• 30 TAC Chapter 118 – Control of Air Pollution Episodes. 30 TAC Chapter 122 –
Federal Operating Permits.
4.11.1.4 Construction Emissions and Mitigation
Construction of the Project would result in short-term increases in emissions of some air
pollutants due to the use of equipment powered by diesel fuel or gasoline engines and the
generation of fugitive dust due to the disturbance of soil and other dust-generating activities. More
specifically, the construction activities that would generate air emissions include:
• site preparation (vegetation clearing, trenching, land contouring, foundation
preparation, etc.);
• installation of equipment;
• operation of off-road vehicles and trucks during construction;
• operation of marine vessels (e.g., equipment barges) during construction;
• offshore dredging; and
• workers’ vehicles used for commuting to and from the construction site (i.e., on-
road vehicles).
The emission increases associated with the Project construction activities would have
short-term, localized impacts on air quality. These emissions are not subject to the air quality
permitting requirements that apply to emissions from operation of stationary sources at the Project.
We note that there are no residential or sensitive populations within one mile of the Project site.
Nevertheless, the construction-related emission rates are discussed in this section as a means of
identifying potential air quality concerns associated with the construction phase of the Project and
to assist in developing mitigation.
The amount of fugitive dust for an area under construction would depend on numerous
factors, including degree of vehicular traffic; size of area disturbed, amount of exposed soil, soil

properties (silt and moisture content); and wind speed. Construction of the Project would also
result in fuel combustion emissions from a variety of sources, including off-road sources (e.g.,
bulldozers, cranes, front-end loaders, pile drivers), on-road sources (e.g., construction worker
vehicles), and marine vessels (e.g., tugs, barges).
Site preparation would include grading, cutting of drainage ditches, placement of gravel
surfaces (e.g., lay-down areas), and construction of access roads within the Project site boundaries.
Site preparation activities would generate fugitive dust from earthmoving and movement of
construction equipment over unpaved surfaces and tailpipe emissions from construction equipment
and vehicle engines. The construction equipment and vehicles would be powered by internal
combustion engines that would generate PM10, PM2.5, SO2, NOx, VOC, and CO emissions. Site
preparation equipment would include bulldozers, front-end loaders, backhoes, excavators,
compactors, dump trucks, and other mobile construction equipment.
The construction of the Project would include installation of six liquefaction trains, two
LNG storage tanks, LNG carrier berths and LNG transfer lines, major mechanical equipment, and
piping and instrumentation, as well as construction of foundations, pipe racks, miscellaneous
storage tanks, and buildings. The Project construction equipment would include cranes, forklifts,
man lifts, drill rigs, welding machines, air compressors, and generators (for various duties, such as
pumping, lighting, etc.), which would result in fuel combustion and fugitive dust emissions.
The LNG storage tanks would include the use of perlite insulation in the space between the
outer tank shell and the inner nickel alloy wall. Perlite is a naturally occurring mineral that expands
to between 10 and 20 times its original volume when heated, giving it excellent insulating qualities.
Because expanded perlite is fragile and can be easily crushed during handling, the perlite material
would be trucked to the Project site in unexpanded form, and then expanded onsite, which involves
the use of a small natural gas-fired furnace equipped with a wet cyclone to capture particulate
emissions. Perlite expansion would occur as each LNG storage tank is constructed.
The Project would include dredging of the LNG carrier berthing area. The emissions
generated by these activities would be predominantly combustion emissions from the construction
equipment and marine vessel engines. The construction equipment used for the offshore dredging
would include a barge-mounted suction dredge. In addition, one tugboat would be used to deliver
construction materials by barge through the BSC to the Project site.
Site truck traffic (e.g., supply trucks) and worker commuter vehicles would generate
fugitive dust from travel on paved and unpaved surfaces as well as tailpipe emissions.
Construction of the Project would require a peak of approximately 1,200 workers, with an average
of approximately 700 workers on-site per month during construction. Most of the commuter
vehicles would likely burn gasoline, although supply trucks and some worker pickup trucks would
burn ultra-low-sulfur diesel fuel.
Fuel combustion emissions from off-road construction equipment were determined using
emission factors obtained from the EPA’s NONROAD Emission Factor Model, Version 2008a,
contained within the EPA Motor Vehicle Emission Simulator (MOVES) 2014 vehicle emission
modeling software. Fuel combustion emissions from on-road vehicles were determined using
emission factors obtained from MOVES 2014.

Annova would minimize emissions from off-road construction equipment using the
following measures:
• implement idling restrictions;

• commit to the use of newer-tier engines when available; and
• install add-on pollution controls on temporary stationary construction equipment.
SO2 emissions would be further reduced by the use of ultra-low-sulfur diesel. In addition,
vehicle emissions would be minimized through compliance with 30 TAC Chapter 114 – Control
of Air Pollution from Motor Vehicles. Estimated fugitive dust emissions generated by on-site
construction equipment were based on emission factors developed by the WRAP Fugitive Dust
Handbook (Countess Environmental 2006). The total estimated criteria air pollutant and GHG (as
CO2e) emissions associated with construction-related activities for the Project are summarized in
table 4.11.1-3. These totals include fuel combustion emissions as well as fugitive PM emissions.
For fuel combustion emissions from non-road and on-road engines, nearly all emitted PM is
assumed to be PM2.5.
TABLE 4.11.1-3
Total Project Construction Emissions by Year

Annual Emissions (tpy) a/
Year NOx VOC CO SO2 PM10 PM2.5 CO2e HAPs
1 23 2.6 40 0.04 293 30 7,802 <0.1
2 172 22 220 0.3 158 25 56,316 <0.1
3 152 17 224 0.25 126 21 44,492 <0.1
4 131 13 202 0.22 65 14 39,619 <0.1
5 50 6 86 0.08 59 8 15,025 <0.1
______________________
a/ Includes suction dredge, barge deliveries, and other off-road equipment; Perlite expansion equipment; construction
mobile sources, including worker commutes; fugitive dust from general site work and earth moving; and fugitive dust
from construction and use of the access road.
CO = carbon monoxide; CO2e = carbon dioxide equivalent; HAP = hazardous air pollutant; NOx = nitrogen oxides; SO2 = sulfur
dioxide; PM2.5/10 = particulate matter less than 2.5 or 10 microns in diameter; tpy = ton per year; VOC = volatile organic compound
Fugitive dust accounts for the majority of PM emissions during the construction period for
the Project. Annova has developed a Fugitive Dust Control Plan to mitigate these emissions (see
appendix G). Measures outlined in the plan include the following:
• properly maintain construction equipment and vehicles to minimize particulate

matter from exhaust;
• utilize existing public and private roads and existing right-of-way for access during
construction wherever possible;
• apply water as needed to all affected unpaved roads, unpaved haul/access roads,
and staging areas when in use;
• when appropriate, apply a water/magnesium chloride mixture as needed as a dust
suppressant;

• reduce vehicle speeds on all unpaved roads, and unpaved haul and access roads.
Speed limits would be set to 20 miles per hour for unpaved roads in all areas, or in
accordance with posted public speed limits;
• inspect paved road access points and clean up track-out and/or carry-out areas at
paved road access points at a minimum of once every 48 hours;
• gravel pads may be installed adjacent to paved roadways to limit track-out, and
clearly established and enforced traffic patterns may be used to route traffic over
track-out control devices;
• for bulk transfer operations, spray handling and transfer points with water at least
15 minutes before use;
• cover all haul truck loads or maintain at least 6 inches of freeboard space in each
cargo compartment. Ensure that all haul truck cargo compartments are constructed
and maintained to minimize spillage and loss of materials, and clean or wash each
cargo compartment at the delivery site after removal of the bulk material;
• apply water to active construction areas as needed. Areas should be pre-watered
and soils maintained in a stabilized condition where support equipment and vehicles
would operate. Water disturbed soils to form a crust; and
• for temporary surfaces during periods of inactivity, restrict vehicular access by
means of either fencing or signage, and apply water to comply with the stabilized
surface requirements.
As indicated in table 4.11.1-3, there may be localized minor to moderate elevated levels of
fugitive dust and tailpipe emissions near construction areas during the 60-month construction
period associated with the LNG terminal site. The construction emissions’ impact on ambient air
quality would vary with time due to the construction schedule, the mobility of the sources, and the
variety of emission sources. Fugitive dust and other emissions due to construction activities
generally do not pose a significant increase in regional pollutant levels; however, local pollutant
levels would increase during the construction period. Considering these factors, we determine that
construction of the Project would impact local air quality. However, construction emissions would
not have a permanent effect on air quality in the area.
4.11.1.5 Operating Emissions and Mitigation

As indicated previously, the liquefaction facilities would be primarily electrically powered;
however, certain operational emissions would be generated on-site. Operation of the Project would
result in air emissions from stationary equipment (e.g., heaters, flares, oxidizers, and emergency
generators) and mobile sources (e.g., LNG carriers and tugs). Operational-phase emissions from
a variety of sources/equipment would be permanent. These various sources and associated criteria
pollutant, GHG, and HAP emission rates are discussed in the following section. The Project would
operate up to six natural gas liquefaction trains continuously. Sources of air emissions associated
with operation of the Project include:
• three natural gas-fired heaters with a maximum heat input rating of 143.6
MMBtu/hr each;

• one thermal oxidizer to combust waste gas from the gas pretreatment facilities, as
well as BOG from the LNG storage and handling equipment;
• warm and cold gas flares (one of each) to combust gas streams during system
commissioning, cool-downs, equipment startup, and planned maintenance
shutdowns;
• one marine flare to combust gas streams produced during cooldown of LNG
carriers that arrive with warm cargo tanks filled with inert gas (estimated to be
required for two LNG carriers per year);
• six natural gas–fired standby generator engines each rated at approximately 3 MW
electrical output;
• one diesel fuel–fired mission critical electric generator engine rated at
approximately 2.5 MW electrical output, to be used in a facility black-start
scenario;
• three diesel fuel-fired firewater pump engines each rated at 750 hp;
• one 282,000-gallon vertical, fixed-roof aboveground storage tank for storage of
heavy hydrocarbon liquids condensed during the liquefaction process;
• three small fuel oil storage tanks (approximately 600 gallons each) serving the
mission critical electric generator and firewater pump engines;
• marine vessel emissions from LNG carriers and tugboats;
• fugitive VOC and GHG emission sources (e.g., valves, flanges, connectors, and
marine vessel offloading equipment);
• fugitive GHG emissions from sulfur hexafluoride leakage at electric substation; and
• planned maintenance, startup, and shutdown (MSS) activities.
Emissions of NOx, VOC, CO, PM10, PM2.5, and SO2 would be generated primarily by the
fuel combustion sources. Table 4.11.1-4 provides a summary of the estimated annual operating
emissions for criteria air pollutants, GHG (as CO2e), and HAPs from the Project stationary sources.
The estimate of annual emissions is based on the following assumptions:
• continuous operation (8,760 hours per year) for the heaters, the thermal oxidizer,
and the flare pilot flames;
• 50 hours per year for marine flare inert ship events; and
• no more than 100 hours of non-emergency operation per year for the electric
generators and fire water pumps.
The warm and cold flares would only operate intermittently, and their annual non-pilot
flame emissions are included as part of the MSS emission totals.

Annova has prepared a draft Minor Source Construction Permit Application for eventual
submittal to TCEQ, in which it has proposed the following emission limits for the Project’s
stationary sources to satisfy TCEQ’s BACT guidelines.
• for the gas-fired heaters: use of low-NOx burners meeting 0.035 pound
(lb)/MMBtu; CO limit of 50 parts per million (ppm) corrected to 3 percent oxygen
(O2); use of a continuous emission monitoring system; use of natural gas as the only
fuel; and good combustion practices;
• for the thermal oxidizer: use of low-NOx burners meeting 0.06 lb/MMBtu; VOC
emissions limited to 99.9 percent destruction and removal efficiency or 10 ppm
corrected to 3 percent O2; use of a sulfur recovery unit to initial performance test;
and monitoring of combustion chamber exit temperature;
• for the gas-fired standby generators: NOx limit of 0.5 grams per brake horsepower-
hour (g/bhp-hr); CO limit of 1.9 g/bhp-hr; VOC limit of 0.39 g/bhp-hr; use of
natural gas as the only fuel; limited hours of operation; good combustion practices;
and compliance with NSPS Subpart JJJJ;
• for the mission critical generator and firewater pump engines: use of ultra-low-
sulfur diesel fuel; limited hours of operation; good combustion practices; and
compliance with NSPS Subpart IIII;
• for the flares: compliance with 40 CFR Part 60.18 for flare tip velocity and waste
gas heat content to achieve 99.5 percent control of VOC and H2S; no flaring of
halogenated compounds; use of a flow monitor; and operation of a continuous pilot
flame;
• for the condensate tank: capture of vapor emissions for use as supplemental fuel in
the gas-fired heaters; and
• for fugitive equipment leaks: compliance with TCEQ’s 28M leak detection and
repair program to achieve 75 percent control of VOC emissions.
Table 4.11.1-5 provides a summary of the estimated annual operating emissions for criteria
air pollutants, GHG (as CO2e), and HAPs from the mobile sources associated with the Project.
The annual mobile source emissions are based on the following assumptions.
• transit emissions for 125 LNG carrier annual round-trips via the BSC. The draft
EIS assumed 78 annual round trips and we have revised the final EIS using
information provided by Annova in its March 25, 2019, filing with the Commission,
and by scaling up the previously modeled annual NO2 modeled concentration for
the 125 ships;
• Annova has assumed that all LNG carriers would be dual-fuel diesel-electric, firing
95 percent natural gas plus 5 percent diesel;
• hoteling emissions from LNG carriers while moored at the Project’s marine transfer
facility with their propulsion engines shut off;
• tugboat emissions associated with each LNG carrier trip, including one 6,000-hp
tugboat escort for the entire route, and three additional 6,000-hp tugboats to

assisting with maneuvering and mooring activities at the Project’s marine transfer
facility;
• two 800-hp security vessels to escort each LNG carrier along the entire transit route;
• one 800-hp security vessel to patrol the Project docking area (up to 8 hours per
day);
• worker commute traffic for approximately 165 full-time employees; and
• on-site traffic and truck deliveries to the Project site.

TABLE 4.11.1-4
Estimated Annual Project Operating Emissions for Onshore Stationary Sources

HAPs
Ethyl-benzene
Formaldehyde
Benzene
Toluene
Hexane
Xylene
Emission Source NOx VOC CO SO2 PM10 PM2.5 Total HAPs CO2e
Medium Fired Heaters (3) 66 11 94 0.1 15 15 0 0 0.15 3.57 0 0 3.7 208,202
Thermal Oxidizer (1) 7 0.38 5.9 83 0.53 0.53 0 0 0.01 0.13 0 0 0.13 137,709
Standby Generators (6) 1.1 0.89 4.3 0.004 0.24 0.24 0.012 0 0.59 0 0.0059 0 0.61 1,237
Mission Critical Diesel Generator 0.2 < 0.01 0.021 < 0.001 < 0.01 < 0.01 0.0002 0 0 0 0.0001 0 0.0003 36
Firewater Pumps (3) 0.5 0.02 0.13 0.001 0.01 0.01 0.0006 0 0.0007 0 0.0002 0.0002 0.0017 100
Warm Gas Flare 0.4 1.6 1.5 < 0.0001 0 0 0 0 0 0 0 0 < 0.0001 360
Cold Gas Flare 0.6 2.6 2.5 < 0.0001 0 0 0 0 0 0 0 0 < 0.0001 599
Marine Flare 6.5 27 26 0.01 0 0 0 0 0 0 0 0 < 0.001 286
Fugitive Emissions a/ 0 3.9 0 0 0 0 0 0 0 0.69 0 0 0.69 4,413
Condensate Tank 0 4.2 0 0 0 0 0 0 0 0 0 0 < 0.001 0
Planned MSS b/ 0.1 0.5 0.3 < 0.0001 0 0 0 0 0 0 0 0 0 130
Total c/ 82 52 135 83 16 16 0.02 0 0.75 4.38 0.01 0 5.2 353,072
PSD Major Source Threshold d/ 250 250 250 250 250 250 N/A N/A N/A N/A N/A N/A N/A 75,000
Subject to PSD Review? No No No No No No N/A N/A N/A N/A N/A N/A N/A No e/
______________________
a/ Includes emissions from the condensate storage tank, diesel storage tanks, and component/equipment leaks. Total includes application of current Texas Commission on
Environmental Quality Best Available Control Technology for equipment leaks.
b/ Includes worst-case annual emissions produced during planned maintenance events, and equipment startups and shutdowns associated with planned events that occur at
least annually. Per Texas Commission on Environmental Quality, does not include unplanned events. Some maintenance events occur with frequency longer than 1 year.
Emissions are produced from flaring.
c/ The heaters and thermal oxidizer would operate continuously (8,760 hours per year). The flares would operate intermittently, except that pilot/purge would operate
continuously. The standby generators and firewater pumps would operate only for routine maintenance runs and during emergency situations.
d/ Emissions of other Prevention of Significant Deterioration (PSD)-regulated air pollutants – lead, fluorides, sulfuric acid mist, H2S, total reduced sulfur, and reduced sulfur
compounds – are negligible.
e/ PSD review for GHG emissions is only required if a facility is major for a non-PSD pollutant.
CO = carbon monoxide; CO2e = carbon dioxide equivalent; HAP = hazardous air pollutant; NOx = nitrogen oxides; SO2 = sulfur dioxide; PM2.5/10 = particulate matter less than 2.5 or 10
microns in diameter; tpy = ton per year; VOC = volatile organic compound

TABLE 4.11.1-5
Estimated Annual Project Operating Emissions for Mobile Sources

HAPs c/
Ethyl-benzene
Formaldehyde
Benzene
Toluene
Hexane
Xylene
Emission Source NOx VOC CO SO2 PM10 PM2.5 Total HAPs CO2e
LNG Vessels and Tugboats c/, b/ 149 11 23 1 8 8 0.0623 0.0064 0.4990 0.0181 0.0103 0.0157 1.0447 11,636
Security Vessel Operations 18 0.48 3 0.01 0.44 0.44 0.0072 0.0007 0.0525 0.0019 0.0011 0.0017 0.1020 1,229
Worker Commuting 0.34 0.07 8.4 0.01 0.01 0.01 0.0027 0.0013 N/A 0.0014 0.0057 0.0047 0.0159 1,185
On-Site Traffic 0.02 < 0.01 0.25 < 0.01 < 0.01 < 0.01 0.0004 0.0002 N/A 0.0002 0.0008 0.0007 0.0023 20
Truck Deliveries 0.23 0.03 0.1 < 0.01 0.01 0.01 0.0001 0.0000 N/A 0.0000 0.0001 0.0001 0.0003 153
Total 167.6 11.6 34.8 1 8.5 8.5 0.0727 0.0086 0.5515 0.0216 0.0180 0.0229 1.1652 14,223
______________________
.
a/ Based on 173,000 cubic meter dual-fuel diesel electric LNG carrier, tug boats of 6,700 brake-horsepower. HAPs shown represents largest individual HAP emitted
(formaldehyde); other HAP emission rates are an order of magnitude lower.
b/ Based on a 173,000-cubic meter capacity vessel because these produce the largest short-term impacts.
c/ Total HAP includes additional speciated compounds for marine vessels that are not shown in this table.
CO = carbon monoxide; CO2e = carbon dioxide equivalent; HAP = hazardous air pollutant; NOx = nitrogen oxides; SO2 = sulfur dioxide; PM2.5/10 = particulate matter less than 2.5 or 10
microns in diameter; tpy = ton per year; VOC = volatile organic compound

Table 4.11.1-6 provides a summary of estimated emissions from MSS activities for the six
liquefaction trains. Maintenance would include replacement of dust filters (every 6 months),
molecular sieve filters (every 2 to 4 years), dehydrators (every 2 to 4 years), pump seals (every 2
to 4 years), and replacement of propane and isopentane drying beds (every 10 years). Emissions
from MSS activities would result from flaring of process gases (primarily methane), which would
be sent to the warm flare or the cold flare as appropriate as they are flushed from the equipment
undergoing maintenance. It is estimated that worst-case annual MSS emissions would occur every
4 years, when the annual, 2-year, and 4-year maintenance schedules overlap. These worst-case
MSS emissions are included in the Project-wide annual emissions shown in table 4.11.1-4 above.
Emissions from grid-supplied electricity are discussed in Alternatives section 3.6.1.
TABLE 4.11.1-6
Estimated Maintenance, Startup, and Shutdown Emissions

Interval NOx VOC CO CO2
Annual 0.002 0.02 0.02 4
Two Years a/ 0.005 0.04 0.04 8
Three Years b/ 0.05 0.4 0.5 91
Four Years c/ 0.1 0.5 0.3 131
Ten Years d/ 0.02 0.07 0.05 14
______________________
a/ MSS 2-year emissions include annual and 2-year recurring events.
b/ MSS 3-year emissions include annual and 3-year recurring events.
c/ MSS 4-year emissions include annual, 2-year, and 4-year recurring events.
d/ MSS 10-year emissions include annual, 2-year, and 10-year recurring events.
CO = carbon monoxide; CO2 = carbon dioxide; MSS = maintenance, startup, and shutdown; NOx = nitrogen
oxides; tpy = ton per year; VOC = volatile organic compound
4.11.1.6 Operational Impact Assessment

The stationary sources associated with the proposed Project are considered a new minor
stationary source, as defined under 30 TAC §116.12, and TCEQ therefore requires that Annova
perform state-level air quality dispersion modeling to demonstrate that the Project would not cause
or contribute to a violation of any applicable NAAQS, or adversely affect public health or welfare.
In addition, we requested that Annova perform modeling that includes both the Project’s stationary
sources and emissions from the marine vessels that would operate as part of the Project’s activities.
The methodology and results for these modeling analyses are discussed in the following section.
Overall Modeling Methodology

Annova conducted dispersion modeling using the latest version of the American
Meteorological Society/EPA Regulatory Model (AERMOD, Version 15181), in accordance with
TCEQ modeling guidance, as well as guidance provided by FERC. Annova submitted a modeling
protocol describing the approach for both the TCEQ and the FERC modeling analyses. AERMOD
was run in the regulatory default mode for all pollutants. Total ambient impacts were calculated
by adding modeled facility impacts on existing air pollutant background concentrations. Receptors
were placed along the proposed fence line, and in a grid extending out to 50 kilometers (31 miles)
from the center of the Project site. Separate analyses were conducted including only the Project
stationary sources and including both the stationary sources and mobile source emissions from one
LNG carrier docked at the loading berth with one tugboat on stand-by near the LNG carrier.

Because the Project would be a minor source with respect to PSD, and because the nearest
Class I area is more than 300 kilometers (186.4 miles) away, no evaluation of impacts on Class I
areas is required. However, we did request that Annova assess air quality impacts for the Lower
Rio Grande NWR, due to its proximity to the Project. Because the Project would be a minor PSD
source with respect to emissions of the ozone precursor pollutants NOx and VOC, an ozone impact
assessment is also not required.
Modeling Results
Table 4.11.1-7 presents the results of modeling of total ambient impacts for the proposed
stationary sources, which demonstrate that the stationary sources would not cause or contribute to
an exceedance of a NAAQS. Annova is revising its SO2 dispersion modeling as part of an update
of the TCEQ minor source permit application and states it will provide in a future filing to FERC
revised potential emissions from the heaters, thermal oxidizers, and flares.
TABLE 4.11.1-7
Stationary Source Ambient Impact Analysis Results

Total Impact
Modeled Background (Modeled +
Concentration Concentration Background) NAAQS Exceed
Pollutant Averaging Period (µg/m3) (µg/m3) (µg/m3) (µg/m3) NAAQS?
Sulfur Dioxide 1-hour, 4th high 0.1 13.2 13.3 196 No
(SO2) 3-hour, 2nd high 7.7 8.4 16.1 1,300 No
Carbon Monoxide 1-hour, 2nd high 19,163 1,258 20,421 40,000 No
(CO) 8-hour, 2nd high 6,378 800 7,178 10,000 No
Nitrogen Dioxide 1-hour, 8th high 16 36.4 52.4 188 No
(NO2) Annual, 1st high 0.71 3.4 4.1 100 No
Particulate Matter
24-hour, 6th high 0.48 49.0 49.48 150 No
(PM10)
Particulate Matter 24-hour, 8th high 0.47 25.5 25.97 35 No
(PM2.5) Annual, 1st high 0.15 10.1 10.25 12 No
µg/m3 = microgram per cubic meter; NAAQS = National Ambient Air Quality Standards
Table 4.11.1-8 presents the results of modeling of total ambient impacts for the proposed
stationary sources plus mobile source emissions from one docked LNG carrier and one tugboat on
standby. The analysis assumed that the LNG carrier would operate in hoteling mode while docked,
with a single engine operating at low load to supply power for essential ship functions. It was also
assumed the standby tugboat would be floating nearby with its propulsion engines shut off, and
the other three tugboats serving the Project would be docked with engines off while an LNG carrier
is berthed. These results also demonstrate compliance with the NAAQS. Annova’s March 25,
2019, filing with the Commission provided updated annualized NO2 and PM2.5 emission rates to
reflect the increase from 78 to 125 LNG carrier annual round trips. However, the annualized
emission rates for the LNG carrier and tugboats only increased by 4 percent, which is too small a
change to be apparent in the valued presented for modeled concentrations and total impacts.
Annova is revising its SO2 dispersion modeling as part of an update of the TCEQ minor source
permit application and states it will provide in a future filing to FERC revised potential emissions
from the heaters, thermal oxidizers, and flares.

TABLE 4.11.1-8
Stationary Source Ambient Impact Analysis Results with LNG Ship

Total Impact
Modeled Background (Modeled +
Concentration Concentration Background) NAAQS Exceed
Pollutant Averaging Period (µg/m3) (µg/m3) (µg/m3) (µg/m3) NAAQS?
Sulfur Dioxide 1-hour, 4th high 1.7 13.2 14.9 196 No
(SO2) 3-hour, 2nd high 7.7 8.4 16.1 1,300 No
Carbon Monoxide 1-hour, 2nd high 19,163 1,258 20,421 40,000 No
(CO) 8-hour, 2nd high 6,378 800 7,178 10,000 No
Nitrogen Dioxide 1-hour, 8th high 16 36.4 52.4 188 No
(NO2) Annual, 1st high 1 3.4 4.4 100 No
Particulate Matter
24-hour, 6th high 0.66 49.0 49.66 150 No
(PM10)
Particulate Matter 24-hour, 8th high 0.64 25.5 26.14 35 No
(PM2.5) Annual, 1st high 0.16 10.1 10.26 12 No
µg/m3 = microgram per cubic meter; NAAQS = National Ambient Air Quality Standards
The Lower Rio Grande NWR is located within the 50-kilometer (30-mile) grid used for the
air modeling. Therefore, the above modeling results also demonstrate that impacts at the Lower Rio
Grande NWR would be in compliance with the NAAQS.
Combined Operational/Construction Emissions
According to the schedule included in its FERC application, Annova would commission
the first stage (2 trains) beginning in the second quarter of year 4, the second stage in the third
quarter of year 4, and the third stage in the fourth quarter of year 4. Commercial operation for the
first stage would begin in the fourth quarter of year 4 for the second stage in the first quarter of
year 5, and for the third stage in second quarter of year 5.
• Emissions year 1 = construction only

• Emissions year 4 = construction plus 6 train commission + ¼ operation of 2 trains
• Emissions year 5 = construction + 100% operation of 4 trains + ¾ operation of 2
trains
As indicated in section 2, commissioning of the first 2 trains would begin while
construction of the later stages would still be underway. These overlapping emissions are shown
in table 4.11.1-9 and would occur during the final two years of construction. The emissions shown
for year 6 are the maximum potential annual emissions from stationary and mobile operating
sources for the completed facility, and do not include any construction or commissioning
emissions. During the years of simultaneous commissioning, construction, and operation, a higher
level of emissions may occur and potentially result in exceedances of the NAAQS. Due to its
variability, we do not believe these rare occurrences would result in a significant air quality impact
on the local residents or the regional air quality.

TABLE 4.11.1-9
Estimated Combined Construction, Commissioning, and Operational Emissions

of the Annova LNG Project
Emissions (tons per year)
Total
Year NOx CO SO2 PM10 PM2.5 VOC CO2e a/ HAPs
1 23 40 0.04 293 30 2.6 7,802 0.1
2 172 220 0.3 158 25 22 56,316 0.1
3 152 224 0.25 126 21 17 44,492 0.1
4 146.6 215.7 7.2 66.7 15.7 18.1 69,923 0.6
5 222 236.2 77.1 77.8 26.8 61.6 348,364 5.5
6 249.6 169.8 84 24.5 24.5 63.6 367.295 6.4
NOx = nitrogen oxides; CO = carbon monoxide; SO2 = sulfur dioxide; PM2.5 = particulate matter less than 2.5 microns; PM10 =
particulate matter less than 10 microns; VOC = volatile organic compound; CO2e = carbon dioxide equivalent; HAPs =
hazardous air pollutants
4.11.1.7 Conclusion for Air Quality

During the construction period, residents in the vicinity of the Project may experience local
impacts on air quality. During the period of construction and operation, nearby location would
experience larger air quality impacts, however we do not expect these impacts would be
significant. During operation, we have determined the Project would have minor impacts on the
local and regional air quality but would not result in regionally significant impacts on air quality.
4.11.2 Noise
The noise environment can be affected during both construction and operation of the
Project. The magnitude and frequency of environmental noise may vary considerably over the
course of the day, throughout the week, and across seasons, in part due to changing weather
conditions and the effects of seasonal vegetative cover. This section identifies the potential sources
of noise, the magnitude of noise, and discusses the change in noise attributable to construction and
operation of the Project.
Sound is a sequence of waves of pressure that propagates through compressible media such
as air or water. When sound becomes excessive, annoying, or unwanted, it is referred to as noise.
Construction and operation of the proposed projects would affect overall noise levels in the vicinity
of project components. The ambient sound level of a region is defined by the total noise generated
within the specific environment and usually comprises natural and man-made sounds.
Two measures used by some federal agencies to relate the time-varying quality of
environmental noise with its known effect on people are the equivalent continuous sound level
(Leq) and the day-night average sound level (Ldn). The preferred single value figure to describe
sound levels that vary over time is Leq, which is defined as the sound pressure level of a noise
fluctuating over a period of time, expressed as the amount of average energy. Ldn is defined as the
24-hour average of the equivalent average of the sound levels during the daytime (Ld – from 7:00
a.m. to 10:00 p.m.) and the equivalent average of the sound levels during the nighttime (Ln – 10:00
p.m. to 7:00 a.m.). Specifically, in the calculation of the Ldn, late night and early morning (10:00

p.m. to 7:00 a.m.) noise exposures are increased by 10 decibels (dB) to account for people’s greater
sensitivity to sound during nighttime hours. In general, if the sound energy does not vary over the
given time period, the Ldn level will be equal to the Leq level plus 6.4 dB. The 6.4 dB difference
between the Ldn and the Leq is a result of the 10 dB nighttime addition for the Ldn calculation.
Decibels are the units of measurement used to quantify the intensity of noise. To account
for the human ear’s sensitivity to low level noises the decibel values are corrected to weighted
values known as decibels on the A-weighted scale (dBA). The A-weighted scale is used because
human hearing is less sensitive to low and high frequencies than mid-range frequencies.
Decibels are relative units that compare two pressures: the sound pressure and a reference
pressure. The reference pressures typically used for air and water are not the same, and a direct
comparison of values between in-air and underwater noises is not appropriate. Underwater sounds
use a reference pressure of 1 µPa while in air sounds have a reference pressure of 20 µPa. For in-
air sound levels, the reference pressure is often not explicitly stated, as is the case in this text. The
reference pressure of underwater sounds is typically stated, and is presented in this text. This is
done to remind readers of the different reference pressures between underwater and in air sound
levels, and avoid direct comparison. Therefore, in this text, in air sound levels are presented in
decibels while underwater sound levels are presented as “dB referenced to (re) 1 µPa.” Underwater
sound levels may also include a distance to indicate setback from the sound source. For example,
a setback distance of 1 meter would be expressed as “dB (re 1 µPa) at 1 meter.” Propagation
distances in water are farther than in air because water is denser; however, loudness underwater
diminishes quickly with distance from the sound source.
Table 4.11.2-1 lists relative dBA noise levels of common sounds measured in the
environment and industry. A 3 dB change of sound level is considered to be barely perceivable
by the human ear, a 5 or 6 dB change of sound level is considered noticeable, and a 10 dB increase
is perceived as if the sound intensity has doubled.
TABLE 4.11.2-1
Sound Levels and Relative Loudness

Sound Level Relative Loudness
Noise Source or Activity (dBA) Subjective Impression a/ (perception of change)
Jet aircraft takeoff from carrier (50 feet) 140 Threshold of pain 64 times as loud
Loud rock concert near stage 120 Uncomfortably loud 16 times as loud
Jet takeoff (2,000 feet) 100 Very loud 4 times as loud
Garbage disposal / food blender (2 feet) 80 Loud Reference loudness
Vacuum cleaner (10 feet) 70 Moderate 1/2 as loud
Light auto traffic (100 feet) 50 Quiet 1/8 as loud
Quiet library, soft whisper (15 feet) 30 Very quiet 1/32 a loud
Wilderness with no wind or animal activity 25 Extremely quiet No perceptible change
a/ Barnes et al. 1977; EPA 1971

4.11.2.1 Regulatory Requirements

Federal Regulations
In 1974, the EPA published Information on Levels of Environmental Noise Requisite to
Protect Public Health and Welfare with an Adequate Margin of Safety (EPA 1974). This document
provides information for state and local governments to use in developing their own ambient noise
standards. The EPA has determined that, to protect the public from activity interference and
annoyance outdoors in residential areas, noise levels should not exceed an Ldn of 55 dBA. We
have adopted this criterion and have used it to evaluate the potential noise impacts from the Project
at noise sensitive areas (NSA). NSAs can be residences, hospitals, places of worship, temporary
residences, and other areas that may have a greater sensitivity to noise than other locations. Due
to the 10 dBA nighttime penalty added prior to calculation of the Ldn, for a facility to meet the Ldn
55 dBA limit, it must be designed such that actual constant noise levels on a 24-hour basis do not
exceed 48.6 dBA Leq at any NSA.
The Project would be located near the Palmito Ranch Battlefield NHL, which is managed
by the NPS. NPS management policies include a requirement to “preserve, to the greatest extent
possible, the natural soundscapes of parks” (NPS 2006). While the NPS management polices do
not include specific quantitative requirements, preserving the natural soundscape can be
interpreted as minimizing the sound level increase in lands and public facilities managed by the
NPS. To facilitate this, the NPS completed a prediction of ambient sound levels nationwide
(Mennitt et al. 2014). For the Palmito Ranch Battlefield NHL, which is 3.3 miles from the Project
site, the NPS indicated that the median predicted daytime ambient sound level is 37 to 38 dBA.
State and Local Regulations

The state of Texas, Cameron County, and BND do not have noise regulations in place. The
Project is located outside the city of Brownsville; therefore, the Brownsville Noise Ordinance
(Chapter 46, Article III, Brownsville, TX, Code of Ordinances n.d.) is not applicable to the Project.
4.11.2.2 Existing Sound Levels and Noise Sensitive Areas

To determine the existing noise levels, an ambient sound level survey was conducted at
locations representative of the nearest NSAs, shown on figure 4.11.2-1 and described below.
• NSA1 is 4.2 miles north of the Project site. It is a residential area near Port Isabel
High School in Port Isabel, Texas. SH 100 is adjacent to NSA1 and SH 48 is less
than 1 mile to the southeast. The nearby homes are a mix of single-family homes
and apartment buildings.
• NSA2 is 4.6 miles east of the Project site. It is a small residential area north of SH
4 consisting of single-family, single-story homes.
• NSA3 is 2.3 miles south of the Project site. It is a small residential area north of
SH 4 consisting of single-family, single-story homes, and is also representative of
other nearby residences, including a residence about 1,300 feet east of NSA3 on the
south side of SH 4, because of its similar distance from the Project boundary. It is
also representative of the Palmito Ranch Battlefield NHL, which is across SH 4.
• NSA4 is 3.3 miles southwest of the Project site. It is the Palmito Ranch Battlefield
NHL.

Figure 4.11.2-1 Noise Sensitive Areas and Noise Monitoring Locations

Sound levels were measured at four noise monitoring locations (NMLs), two that are
representative of sound levels at the NSAs and two locations on the Project property boundary for
informational purposes. The NMLs are shown on figure 4.11.2-1 and the measured sound levels
are presented in table 4.11.2-2. To effectively quantify the existing sound levels, the survey
included continuous sound level monitoring for 36 hours or more (including two nighttime periods,
10:00 p.m. to 7:00 a.m.). The continuous sound level monitors captured a variety of sound pressure
level parameters, including the Leq, which is used to determine the Ldn. The Ambient Sound Level
Survey Report includes a detailed description of the survey methodology and the results of these
surveys (Black and Veatch 2016g).
TABLE 4.11.2-2
Existing Sound Levels

Noise Monitoring NSA Represented Daytime Sound Nighttime Sound Average Day-Night
Location Description by NML Level (dBA) Level (Leq dBA) Sound Level (Ldn)
NML1 Residential area, Beacon Leq = 50 50 56 c/
NSA1
Bay Drive cul-de-sac
NML2 Residential area, southwest NSA2, NSA3, Leq = 44 40 46
end of Weens Road NSA4
NML3 Southern project site Leq = 45 49 a/ 54
NSA4
boundary
NML4 Northeastern project site Leq = 47 54 a/ 61 b/
NA
boundary
a/ Nighttime sound levels were higher than daytime sound levels at NML3 and NML4 due to increased insect activity.
b/ The existing Ldn at NML1, which is representative of NSA 1, and NML4 exceeds the FERC regulatory limit of 55 dBA Ldn for
noise resulting from a gas compression facility.
dBA = A-weighted decibel; Ldn = day-night average sound level; Leq = equivalent continuous sound level; NA = not applicable; NML =
noise monitoring location; NSA = noise sensitive area
The acoustic environment at all NMLs included the sounds of wind and insects. In
particular, nighttime insect sounds influenced existing sound levels at NML3 and NML4. The
acoustic environment at NML1 was typical of a busy suburban area, with sounds from traffic,
children playing, and building ventilation equipment. The existing Ldn at NML1, which is
representative of NSA 1, and NML4 exceeds 55 dBA Ldn. The acoustic environment at NML2
was typical of a rural residential area and included sound from traffic on SH4.
Existing vessel traffic in the BSC contributes to background underwater noise levels. In
2015, 194 port calls for vessels approximately 33,000 gross register tons were made at the Port of
Brownsville (MARAD 2015). Three types of vessels dominate ship traffic in the BSC: bulk
carriers, cargo ships, and chemical tankers. The underwater sound levels associated with these
vessels are 184, 181, and 182 dB re 1 µPa at 1 meter, respectively. Therefore, background
underwater noise levels in the BSC are expected to periodically exceed 120 dB re 1 µPa at 1 meter.
4.11.2.3 Construction Noise Impacts and Mitigation

Annova anticipates that construction activities would occur over a 48-month period.
Annova states that construction would occur for 50 hours per week Monday through Friday (about
10 hours a day), and work would not take place on federal holidays. However, to conduct a
conservative noise analysis, construction was assumed to occur 24 hours per day. Dredging for
the marine berth is estimated to occur in two, 10-hour shifts, 6 days per week. Pile driving is
estimated to occur in two, 10-hour shifts, 5 days per week.

The Project would include construction of both land-based and marine facilities. Land-
based construction activities would include clearing and grading associated with site preparation;
foundation work (e.g., installation of piles and underground utilities); construction of aboveground
facilities (e.g., major equipment, process equipment, and buildings); and site restoration.
Construction of marine facilities would include construction of the marine berth, including
dredging and pile driving; construction of the MOF and LNG carrier loading platform; and
installation of shoreline protection features (i.e., riprap). Construction activities are described in
detail in section 2.6.
During construction, sound levels at the property boundary and NSAs would vary
depending on the phase of construction and the types of construction equipment required for each
phase. Major construction phases for the Project would generally consist of site preparation,
foundation construction, equipment and building assembly, and site cleanup and facility startup.
Sound levels are generally highest during the site preparation phase and lowest during the site
clean-up and facility start-up phases.
The most prevalent noise-generating equipment and activity during construction of the
Project is anticipated to be pile driving, although internal combustion engines associated with
general construction equipment and dredging would also produce sound levels that would be
perceptible in the vicinity of the site. The various types of construction activities and estimated
noise impacts are described below.
Facility Construction Activities

The estimated sound levels of common construction equipment that would be used are
shown in table 4.11.2-3. The site preparation phase typically requires the use of heavy, diesel-
powered earth-moving equipment such as backhoes, bulldozers, compactors, dump trucks,
graders, and front-end loaders. Sound levels during this phase are typically dominated by diesel
engine noise. The foundation construction phase primarily involves concrete-handling equipment
such as concrete trucks, mixers, pumps, and pile-driving equipment; however, some earth-moving
equipment is required to backfill the foundations. The equipment and building assembly phase
uses equipment such as diesel-powered earth-moving equipment, mobile cranes, delivery trucks,
drills, and air compressors.
TABLE 4.11.2-3
Sound Levels of Common Construction Equipment

Average Sound Average Sound
Construction Equipment Construction Equipment
Level at 50 feet Level at 50 feet
Air compressor 76 Fork / Man lift 71
Backhoe 85 Front end loader 77
Roller / Compactor 79 Grader 79
Pump 74 Crane 80
Diesel generator 71 Pile driving 101
Dozer 77 Trucks 81
Drill 83 Welding machine 81
Hydraulic excavator 71 Tugboat 86
Dredging vessel 85 Light plants 71
Bus 80
Source: Barnes et al. 1977; FHWA 2006; EPA 1971

To analyze noise impacts during construction, the predicted changes in sound level were
calculated for each NSA. To provide for a conservative analysis, the calculations assumed there
would be no attenuation (lessening) of sound due to ground absorption, atmospheric absorption,
or shielding. Further, the calculations assumed that all equipment for each phase of construction
would operate simultaneously at similar distances from the receptor. Due to the high sound levels
associated with pile driving (with a maximum sound level of 101 dBA), a usage factor was
calculated for each planned piling activity, and the worst-case usage factor determined was
conservatively applied for the entire duration of pile-driving activities. Effects of start-up venting
and blowdown/blowoff events were considered, but due to their intermittent nature and short
duration, they would not influence the 24-hour Ldn values and thus were not included in the
calculations. Because the assumptions for the calculations were conservative, actual construction
sound levels could be lower than those calculated.
Table 4.11.2-4 lists predicted changes in sound level at each NSA during construction.
Although the majority of construction would not occur at night, in order to provide a conservative
analysis, all construction equipment listed in table 4.11.2-3 was assumed to operate 24 hours per
day. Construction sound levels at the property boundary are anticipated to average 74 dBA Ldn.
TABLE 4.11.2-4
Predicted Changes to Sound Levels during Construction

Distance from Property Existing Sound Predicted Construction Cumulative Sound Predicted Sound
Location Boundary to NSA (mi) Level (Ldn dBA) Sound Level (Ldn dBA) Level (Ldn dBA) Level Increase (dBA)
NSA1 4.2 56 49 57 1
NSA2 4.6 46 48 50 4
NSA3 2.3 46 54 55 9
NSA4 3.3 43 52 53 10
For the purpose of this analysis assumes construction would occur 24 hours per day.
dBA = A-weighted decibel; Ldn = day-night average sound level; NSA = noise sensitive area
Construction sound levels attributable to the Project would be less than the 55 dBA Ldn
threshold. In addition to the construction noise, traffic noise generated during construction would
also add to overall sound levels. Construction activity would generate traffic resulting in potential
noise effects, such as trucks traveling to and from the Project site on public roads.
NSA4 is the Palmito Ranch Battlefield NHL 3.3 miles southwest of the Project site. In a
November 2015 letter to Annova, the NPS noted that existing noise levels at its sites vary. For
example, traffic on Highway 4 is not continuous and more quiet periods may exist than those
reported for NSA4. In addition, interior areas of its sites may be quieter than other portions. To
accurately reflect these conditions, NPS requested that Annova conduct ambient sound level
monitoring at interior areas of the NHL sites or use the NPS’ geospatial ambient model data if
interior sound level data are not available. To accommodate the NPS request, the existing ambient
daytime sound level at NSA4 is conservatively assumed to be equivalent to 37 dBA Leq (43 dBA
Ldn) based on the NPS survey (Mennitt et al. 2014), which indicated that the daytime median sound
level for the Palmito Ranch Battlefield NHL is 37 to 38 dBA Leq or 43 to 44 dBA Ldn. Annova
contacted the NPS and THC and requested comments on the noise assessment for the Project.

Typical construction noise would be audible at off-site locations. The noise would be
clearly audible at NSA 4, and would be a doubling of ambient noise at NSAs 3 and 4. While noise
levels are at or near 55 dBA Ldn, residents and visitors to the Palmito Ranch Battlefield NHL may
experience increased noise annoyance considering the duration of construction. The noise impacts
from standard construction should not result in interference with speech intelligibility or hearing.
Comments on the draft EIS suggested that construction noise impacts within the proposed
wildlife corridor along the southwest side of the site would prevent use of the corridor by wildlife.
Predicted maximum time-averaged construction noise within the corridor would range from 55 to
60 dBA Ldn. See further discussion of wildlife use of the corridor in section 4.7.1.2. Annova
would construct a 25-foot-tall concrete barrier wall on the western side of the site as part of the
proposed wildlife corridor; however, construction may occur prior to completion. Once complete,
the barrier wall would reduce sound transmission beyond the property boundary to the southwest.
If completed before the majority of construction, noise to the southwest within the wildlife corridor
would likely be less than those predicted.
Pile-Driving Activities
Annova would install pilings using land-based and in-water equipment, as described in
chapter 2. Pile driving would create an impulsive source (pulsed noises) audible both on land and
underwater. The sound levels associated with pile driving would vary depending on the type of
pile (e.g., monopile, steel pile, concrete, or steel sheet pile) and installation method (e.g., impact
hammer or vibratory hammer). Although most pile-driving activities for construction of the
marine transfer facilities would be isolated from the estuarine environment, pile driving could
result in periodic increases in underwater noise levels in the BSC for approximately 6 months.
Land-Based Pile Driving

Land-based pile driving would produce an impulsive sound that would be audible at off-
site locations. Land-based pile driving is estimated to occur in two, 10-hour shifts, 5 days per
week. Pile driving is accounted for in combination with other construction equipment in table
4.11.2-4. A usage factor was calculated for each planned piling activity, and the worst-case usage
factor determined was conservatively applied for the entire duration of pile-driving activities to
determine the resulting sound levels at the NSAs in Ldn. As shown in table 4.11.2-4, which
includes noise from pile driving, time-averaged sound levels would be at or near 55 dBA Ldn and
would not increase by more than 10 dBA Leq at any NSA.
Annova has indicated that pile-driving noise has a maximum sound level [Lmax] of 101
15
dBA. However, for large-diameter concrete and steel piles, available data show Lmax levels at
50 feet between 110 and 115 dBA Lmax. This has the potential to increase Lmax noise levels above
60-70 dBA with multiple simultaneous hammer blows at the NSAs.
The impact sound level events from pile-driving activities are expected to cause at most a
moderate impact at nearby NSAs during day time hours. The predicted Lmax levels are below 60
dBA, and the predicted Lmax levels are less than 10 dB above the existing ambient. To ensure that
15
WSDOT. 2016. Underwater Sound Level Report: Colman Dock Test Pile Project 2016. Washington State
Department of Transportation Pile Driving Reports. Website:
https://www.wsdot.wa.gov/sites/default/files/2017/12/12/ENV-FW-AirPileDrivingNoise.pdf

actual noise from pile-driving activities are not significantly greater than predicted noise, we
recommend that:
• Annova should monitor pile-driving activities, and file weekly noise data with
the Secretary following the start of pile-driving activities that identify the noise
impact on the nearest NSAs. If any measured noise impacts (Lmax) at the
nearest NSAs are greater than 10 dBA over the Leq ambient levels, Annova
should:
a. cease pile-driving activities and implement noise mitigation measures;
b. file with the Secretary evidence of noise mitigation installation and
request written notification from the Director of OEP that pile driving
may resume.
Due to the expected duration of pile-driving activities during construction, there would be
moderate impacts on the daytime sound levels at nearby NSAs, but late evening and nighttime pile
driving may increase annoyance with impulsive noise above acceptable levels. Pile-driving events
would likely be audible, especially when activities are taking place at the closest pile driving
locations to the NSAs. Annova has proposed pile driving in two 10-hour shifts, so late night pile
driving may cause a potential for sleep disturbance. Given the predicted noise levels associated
with pile driving, we conclude that pile-driving activities, without further noise mitigation, would
be a significant impact.
The wildlife corridor area could temporarily experience sound levels between 85-100 dBA
Lmax when pile-driving takes place, depending upon the number of simultaneous piles and the
location on the construction pad. Our recommendations above would limit pile-driving impacts
on the wildlife corridor. If completed before pile-driving commenced, the 25-foot-tall barrier wall
between the terminal facilities and wildlife corridor would mitigate a portion of this noise impact.
See further discussion of wildlife use of the corridor in section 4.7.1.2.
With the implementation of these recommendations, we conclude that noise from pile-
driving activities would be partially mitigated but would result in moderate noise impacts at the
NSAs during daytime construction, but would constitute a significant impact during nighttime
operation.
In-Water Pile Driving

In-water pile driving would contribute to underwater sound levels and could occur up to
24 hours per day. The most applicable data regarding sound source levels available are for 96-
inch-diameter steel piles in water depths of approximately 39 to 49 feet (12 to 15 meters) for the
Benicia-Martinez Bridge crossing in the Carquinez Strait in Contra Costa County, California (ICF
Jones & Stokes, and Illingworth and Rodkin, Inc. 2009). Underwater measurements for hydraulic
impact-hammer pile driving from installation of steel piles at the Benicia-Martinez Bridge, which
are comparable to those expected during construction, are shown in table 4.11.2-5.

TABLE 4.11.2-5
Unattenuated Underwater Sound Pressure Levels Measured for Pile Driving at the Benicia-Martinez Bridge
Sound Pressure Levels (decibels re 1 µPa at 10 meters a/)
Pile Type Sound Pressure Level Root Mean Squared Sound Exposure Level
42-inch steel 208 195 180
96-inch steel 220 205 194
a/ Distance measured from the pile at about mid-depth (10 to 15 meters deep).
µPa = micropascal
Source: ICF Jones & Stokes, and Illingworth and Rodkin, Inc. 2009
The impacts of noise from pile driving on underwater species including marine mammals,
sea turtles, and fish, and associated mitigation measures, are presented in section 4.7.
Vibration
Construction equipment, particularly impact activities such as pile driving, also generates
vibrations that can pass through the ground and cause damage to structures. The vibration velocity
at the nearest NSA is expected to be less than 0.1 millimeters per second (Attewell and Farmer
1973). This is less than the vibration criterion for structural effects on residential buildings, which
is 0.2 millimeter per second (Attewell and Farmer 1973; Ungar et al. 1990); therefore, no structural
effects are anticipated from vibration during construction.
Dredging Activities
Construction would require dredging, as described in section 2. Annova proposes to use a
combination of land-based excavation and hydraulic cutter dredging for construction of the marine
berth. Dredging for the marine berth is estimated to occur in two, 10-hour shifts, 6 days per week.
To provide a conservative analysis, for the noise assessment dredging was assumed to occur
24 hours per day.
Dredging would typically generate ambient sound levels of 89 dBA at distance of 50 feet
for hydraulic dredging and 81 dBA at 50 feet for mechanical dredging (Port of Oakland 1999).
The equivalent noise levels at the nearest NSA (i.e., NSA3) would be 38 dBA for hydraulic
dredging and 30 dBA for mechanical dredging, given the attenuation over distance. These levels
are well below the 55 dBA Ldn FERC criterion. In addition, dredging operations would be of short-
term duration at any given location along the BSC. As a result, noise impacts associated with
dredging would be minor and short term.
Dredging would also produce underwater noise. The hydraulic cutter dredge is
conservatively estimated to produce underwater sound levels of 172 to 185 dB (re 1 µPa) at 1
meter in the 100 to 500 frequency range (CEDA 2011) and 100 to 110 dB (re 1 µPaRMS ) at 1 meter
in the 70 to 1,000 Hz range (Clarke et al. 2002). Underwater sound levels are likely to be lower
than this due to the clay substrate that is likely found at the proposed berthing and turning basin.
The predominant frequencies associated with large vessels are low, below several hundred hertz.
The predominantly low-frequency noise from vessels in the Project area has the potential to affect
the ambient (background) noise over a much larger area than higher frequencies that may exist
near individual sources (e.g., smaller vessels or various industrial activities within the BSC). The

impacts of noise from dredging on underwater species including marine mammals, sea turtles, and
fish, and associated mitigation measures are presented in section 4.7.
4.11.2.4 Operation Noise Impacts and Mitigation

Operation of the LNG terminal would produce noise on a continual basis. Information
about the major operational sound sources associated with the Project is provided in table 4.11.2-
6. Estimated sound levels were compiled from manufacturer data, from the Institute of Electrical
and Electronics Engineers, and Annova LNG’s in-house data.
TABLE 4.11.2-6
Major Operational Equipment and Estimated Sound Levels

Height of Sound Source Estimated Sound Level of One Unit,
(feet above ground or Per Fan where indicated by
Equipment Quantity level) Asterisk (dBA at 3 feet)
LNG compressor 6 23 83
Compressor inlet piping For 6 compressors 50 83 to 88
Compressor discharge piping For 6 compressors 50 92 to 93
Cooling units 12 (48 fans per unit) 66 97*
Boil-off gas compressor 2 17 115
Boil-off gas compressor motor 2 12 104
Transformers 42 13 68
Transformers 22 13 62
Powerhouses 16 33 85
Gas conditioner units 3 (26 fans per unit) 69 85*
Maintenance flaring 1 160 124
dBA = A-weighted decibel

* Sound level per fan
Estimated operational sound levels were calculated using the environmental noise
prediction software Cadna/A version 4.5.151. The model simulates the outdoor propagation of
sound from equipment and accounts for sound wave divergence, atmospheric and ground
absorption, sound directivity, and shielding due to interceding barriers and terrain. Table 4.11.2-
7 provides the predicted changes in sound level at each NSA during Project operation.
TABLE 4.11.2-7
Predicted Changes to Sound Levels during Operation

Distance from
Property Predicted Project- Predicted Future Predicted Sound
Boundary to Existing Sound Only Sound Level Sound Level Level Increase
Location NSA (miles) Level (dBA Ldn) (dBA Ldn) (dBA Ldn) (dBA)
NSA1 4.2 56 ≤ 39 56 <1
NSA2 4.6 46 ≤ 39 47 1
NSA3 2.3 46 ≤ 46 49 3
NSA4 3.3 46 ≤ 42 47 1
dBA = A-weighted decibel; Ldn = day-night average sound level; NSA = noise sensitive area
As shown in table 4.11.2-7, the predicted sound levels at the NSAs during Project operation
range from 47 to 56 dBA Ldn. Sound levels at NSA1 would be unchanged. Sound levels at NSA2
and NSA4 would increase 1 dBA Ldn, and sound levels would increase by 3 dBA Ldn at NSA3.
Operational sound levels at all NSAs would be equal to existing noise levels (NSA1) and/or below

the 55 dBA Ldn FERC criterion (at NSA2, NSA3, and NSA4). Because the assumptions for the
calculations were conservative, actual operational sound levels could be lower than those
calculated.
To ensure that the actual noise resulting from operation of the Project is not significant, we
recommend that:
• Annova should file a full power load noise survey with the Secretary for the
LNG terminal no later than 60 days after each liquefaction train is placed into
service. If the noise attributable to operation of the equipment at the LNG
terminal exceeds an Ldn of 55 dBA at the nearest NSA, within 60 days Annova
should modify operation of the liquefaction facilities or install additional noise
controls until a noise level below an Ldn of 55 dBA at the NSA is
achieved. Annova should confirm compliance with the above requirement by
filing a second noise survey with the Secretary no later than 60 days after it
installs the additional noise controls.
In addition, we recommend that:
• Annova should file a noise survey with the Secretary no later than 60 days
after placing the entire LNG terminal into service. If a full load condition
noise survey is not possible, Annova should provide an interim survey at the
maximum possible horsepower load within 60 days of placing the LNG
terminal into service and provide the full load survey within 6 months. If the
noise attributable to operation of the equipment at the LNG terminal exceeds
an Ldn of 55 dBA at the nearest NSA under interim or full horsepower load
conditions, Annova should file a report on what changes are needed and
should install the additional noise controls to meet the level within 1 year of
the in-service date. Annova should confirm compliance with the above
requirement by filing an additional noise survey with the Secretary no later
than 60 days after it installs the additional noise controls.
Flaring Noise Impacts

Flaring events would also produce noise. The purpose of a flare system is to protect plant
systems from overpressure during start-up, shutdown, plant upsets, emergency conditions, and
during certain LNG transfer conditions (described below). Flaring produces noise with a low-
pitched “roaring” character that nearby residents or visitors would distinctly notice.
As described in section 2.1.5, the Project would include two flares: a 45-foot-tall marine
flare and a 160-foot-tall combined warm and cold flare stack. The marine flare would operate only
during the transfer of LNG to an LNG carrier that arrives with warm inert cargo tanks, which
typically occurs when the LNG carrier arrives at its first port following dry dock maintenance.
Annova estimates that the marine flare at the Project would operate about twice per year. The
marine flare may operate for up to 25 hours per flaring event for an annual total of up to 50 hours
per year. During this time, active flaring may occur for approximately 4 hours during each event,
for an annual total of up to 8 hours. The combined warm and cold flare stack would only operate
during start-up, shutdown, plant upsets, and emergency conditions. Sound generated from the

combined warm and cold flare stack during these conditions, and by blowdown orifices during
emergency blowdown events, were also considered, but due to their intermittent nature and short
duration, they would not influence the 24-hour Ldn values and thus were not included in the
operational sound calculations.
As shown in table 4.11.2-6, the peak sound pressure level for a flaring event is expected to
be approximately 124 dBA Leq at 3 feet. The estimated sound pressure level during a flaring event
would be 52 dBA Leq or less at the identified NSAs (NSAs 1 through 4).
Steady-State Operational Noise Impacts
Noise would be generated during standard operating conditions without flaring. Sound
level contours of predicted steady-state sound levels (not Ldn sound levels) from Project operation
are shown in figure 4.11.2-2. The contours represent only Project sound sources and do not include
background sound. As shown in figure 4.11.2-2, the areas where steady-state sound levels would
be greater than or equal to 55 dBA Ldn are predominately within the Project site boundaries.
Comments on the draft EIS suggested that operational noise impacts within the proposed wildlife
corridor along the southwest side of the site would prevent use of the corridor by wildlife.
Predicted sound levels in the wildlife corridor during operation would range from 50 to 65 dBA.
Annova would construct a 25-foot-tall concrete barrier wall on the western side of the site as part
of the proposed wildlife corridor. The barrier wall would further reduce sound transmission
beyond the property boundary to the southwest, so sound levels to the southwest and at NSA4
would likely be less than those shown in figure 4.11.2-2. See further discussion of wildlife use of
the corridor in section 4.7.1.2.
Marine Vessel Activities

In addition to plant operations, some additional sound would be generated by the increased
traffic in the BSC as LNG carriers, escort vehicles, and tugs travel to and from the facility
(including passage by South Padre, Long, Brazos, and Clark Islands) and maneuver within the
turning basin and berth. The Project would add approximately 125 LNG carrier visits per year, as
well as intermittent security vessels and tugs, to the existing shipping channel traffic.
Assuming these vessels produce sound levels similar to that of the existing shipping
channel traffic, the average sound level increase at the nearest NSA would be less than or equal to
1 dBA. A person’s threshold of perception for a perceivable change in loudness is approximately
3 dBA, so this change would generally not be perceptible.

Figure 4.11.2-2 Operational Steady-State Noise Contours

Maintenance Dredging Activities

During operation, maintenance dredging would be required to remove accumulated
sediments from the marine berth and turning basin. Maintenance dredging is not expected to cause
a significant noise impact. Maintenance dredging would occur approximately every 2 years for 1
week (24 hours per day) and would be similar in technique to those conducted during construction.
Maintenance dredging would use one dredge vessel that would be similar in size and type to the
vessel anticipated to be used for construction of the marine berth. The average sound level increase
at the nearest NSA from maintenance dredging would be less than or equal to 1 dBA Ldn, which
would generally not be perceptible. In addition, dredging operations would be of short-term
duration at any given location along the BSC. As a result, noise impacts associated with
maintenance dredging would be minor and short term.
4.11.2.5 Conclusion for Noise

Based on the construction noise estimates provided by Annova, the maximum noise levels
attributable to Project construction activities, with the exception of pile-driving activities, would
be equal or similar to existing noise levels or less than or equal to the 55 dBA Ldn threshold at the
NSAs. We have included recommendation to mitigate daytime pile driving. However, nighttime
pile driving would result in unavoidable significant noise impacts during construction.
Based on the operation noise analysis, noise levels during Project operation would not
exceed the 55 dBA Ldn FERC criterion at any of the NSAs. As shown in table 4.11.2-4, noise level
increases during construction would range from 1 dBA at NSA 1 to 9 to 10 dBA at NSAs 3 and 4,
respectively. As shown in table 4.11.2-7, steady-state operational noise level increases would
range from less than 1 dBA at NSA 1 to 3 dBA at NSA 3. We conclude that operation and
maintenance of the Project would not cause significant noise impacts although certain short-term
activities such as flaring would be distinctly noticeable to residents or the public in the vicinity of
the Project.

4.12 RELIABILITY AND SAFETY

LNG Facility Reliability, Safety, and Security Regulatory Oversight
LNG facilities handle flammable and sometimes toxic materials that can pose a risk to the
public if not properly managed. These risks are managed by the companies owning the facilities,
through selecting the site location and plant layout as well as through suitable design, engineering,
construction, and operation of the LNG facilities. Multiple federal agencies share regulatory
authority over the LNG facilities and the operator’s approach to risk management. The safety,
security, and reliability of the Annova LNG Project would be regulated by the DOT, the Coast
Guard, and the FERC.
In February 2004, the DOT, the Coast Guard, and the FERC entered into an Interagency
Agreement to ensure greater coordination among these three agencies in addressing the full range
of safety and security issues at LNG terminals and LNG marine vessel operations, and maximizing
the exchange of information related to the safety and security aspects of LNG facilities and related
marine operations. Under the Interagency Agreement, the FERC is the lead federal agency
responsible for the preparation of the analysis required under NEPA for impacts associated with
terminal construction and operation. The DOT and the Coast Guard participate as cooperating
agencies but remain responsible for enforcing their regulations covering LNG facility siting,
design, construction, operation, and maintenance. All three agencies have some oversight and
responsibility for the inspection and compliance during the LNG facility’s operation.
The DOT establishes and has the authority to enforce the federal safety standards for the
location, design, installation, construction, inspection, testing, operation, and maintenance of
onshore LNG facilities under the Federal Pipeline Safety Laws (49 USC 60101 et seq.). The
DOT’s LNG safety regulations are codified in 49 CFR 193, which prescribes safety standards for
LNG facilities used in the transportation of gas by pipeline that are subject to federal pipeline
safety laws (49 USC 60101 et seq.), and 49 CFR 192. On August 31, 2018, DOT and FERC signed
a memorandum of understanding (MOU) regarding methods to improve coordination throughout
the LNG permit application process for FERC jurisdictional LNG facilities. In the MOU, DOT
agreed to issue a Letter of Determination (LOD) stating whether a proposed LNG facility would
be capable of complying with location criteria and design standards contained in Subpart B of Part
193. The Commission committed to rely upon the DOT determination in conducting its review of
whether the facilities would be consistent with the public interest. The issuance of the LOD does
not abrogate DOT’s continuing authority and responsibility over a proposed project’s compliance
with Part 193 during construction and future operation of the facility. The DOT’s conclusion on
the siting and hazard analysis required by Part 193 is based on preliminary design information
which may be revised as the engineering design progresses to final design. DOT regulations also
contain requirements for the design, construction, installation, inspection, testing, operation,
maintenance, qualifications and training of personnel, fire protection, and security for LNG
facilities as defined in 49 CFR 193, which would be completed during later stages of the Project.
If the Project is authorized, constructed, and operated, the LNG facilities as defined in 49 CFR
193, would be subject to the DOT’s inspection and enforcement programs to ensure compliance
with the requirements of 49 CFR 193.
The Coast Guard has authority over the safety of an LNG terminal’s marine transfer area
and LNG marine vessel traffic, as well as over security plans for the waterfront facilities handling
4-205 Reliability and Safety

LNG terminal and LNG marine vessel traffic. The Coast Guard regulations for waterfront facilities
handling LNG are codified in 33 CFR 105 and 33 CFR 127. As a cooperating agency, the Coast
Guard assists the FERC staff in evaluating whether an applicant’s proposed waterway would be
suitable for LNG marine vessel traffic and whether the waterfront facilities handling LNG would
be operated in accordance with 33 CFR 105 and 33 CFR 127. If the facilities are constructed and
become operational, the facilities would be subject to the Coast Guard inspection program to
ensure compliance with the requirements of 33 CFR 105 and 33 CFR 127.
The FERC authorizes the siting and construction of LNG terminals under the NGA and
delegated authority from the DOE. The FERC requires standard information to be submitted to
perform safety and reliability engineering reviews. FERC’s filing regulations are codified in 18
CFR 380.12 (m) and (o), and requires each applicant to identify how its proposed design would
comply with the DOT’s siting requirements of 49 CFR 193 Subpart B. The level of detail
necessary for this submittal requires the applicant to perform substantial front-end engineering of
the complete project. The design information is required to be site-specific and developed to the
extent that further detailed design would not result in significant changes to the siting
considerations, basis of design, operating conditions, major equipment selections, equipment
design conditions, or safety system designs. We use this information from the applicant to assess
whether the proposed facilities would have a public safety impact and to recommend additional
mitigation measures for incorporation as conditions in the order. If the facilities are approved and
the suggested mitigation measures are incorporated into the order as conditions, FERC staff would
review material filed to satisfy the conditions of the order and conduct periodic inspections
throughout construction and operation.
In addition, the Energy Policy Act of 2005 requires FERC to coordinate and consult with
the U.S. Department of Defense (DOD) on the siting, construction, expansion, and operation of
LNG terminals that would affect the military. On November 21, 2007, the FERC and the DOD
(http://www.ferc.gov/legal/mou/mou-dod.pdf) entered into a MOU formalizing this process. In
accordance with MOU, the FERC sent a letter to the DOD on August 4, 2015 requesting their
comments on whether the planned project could potentially have an impact on the test, training, or
operational activities of any active military installation. On September 18, 2015, the FERC
received a response letter from the DOD Siting Clearinghouse stating that Annova LNG Project
would have a minimal impact on military training and operations conducted in Cameron County,
Texas.
DOT Siting Requirements and 49 CFR 193 Subpart B Determination

Siting LNG facilities as defined in 49 CFR 193, with regard to ensuring that the proposed
site selection and location would not pose an unacceptable level or risk to public safety is required
by DOT’s regulations in 49 CFR 193 Subpart B. The Commission’s regulations under
18 CFR 380.12 (o) (14) require Annova to identify how the proposed design complies with the
siting requirements in DOT’s regulations under 49 CFR 193 Subpart B. The scope of DOT’s siting
Reliability and Safety 4-206

authority under 49 CFR 193 applies to LNG facilities used in the transportation of gas by pipeline
subject to the federal pipeline safety laws and 49 CFR 192. 16
The regulations in 49 CFR 193 Subpart B require the establishment of an exclusion zone
surrounding an LNG facility in which an operator or government agency must exercise legal
control over the activities where specified levels of thermal radiation and flammable vapors may
occur in the event of a release for as long as the facility is in operation. Approved mathematical
models must be used to calculate the dimensions of these exclusion zones. The siting requirements
specified in NFPA 59A (2001), an industry consensus standard for LNG facilities, are incorporated
into 49 CFR 193 Subpart B by reference, with regulatory preemption in the event of conflict. The
following sections of 49 CFR 193 Subpart B specifically address siting requirements:
• Section 193.2051, Scope, states that each LNG facility designed, replaced,
relocated or significantly altered after March 31, 2000, must be provided with siting
requirements in accordance with Subpart B and NFPA 59A (2001). In the event of
a conflict with NFPA 59A (2001), the regulatory requirements in Part 193 prevail.
• Section 193.2057, Thermal radiation protection, requires that each LNG container
and LNG transfer system have thermal exclusion zones in accordance with section
2.2.3.2 of NFPA 59A (2001).
• Section 193.2059, Flammable vapor-gas dispersion protection, requires that each
LNG container and LNG transfer system have a dispersion exclusion zone in
accordance with sections 2.2.3.3 and 2.2.3.4 of NFPA 59A (2001).
• Section 193.2067, Wind forces, requires that shop fabricated containers of LNG or
other hazardous fluids less than 70,000 gallons must be designed to withstand wind
forces based on the applicable wind load data in American Society of Civil
Engineers (ASCE) 7 (2005). All other LNG facilities must be designed for a
sustained wind velocity of not less than 150 mph unless the DOT Administrator
finds a lower wind speed is justified or the most critical combination of wind
velocity and duration for a 10,000-year mean return interval.
As stated in 49 CFR 193.2051, LNG facilities must meet the siting requirements of
NFPA 59A (2001), Chapter 2, and include but may not be limited to:
• NFPA 59A (2001) section 2.1.1 (c) requires consideration of protection against
forces of nature.
• NFPA 59A (2001) section 2.1.1 (d) requires that other factors applicable to the
specific site that have a bearing on the safety of plant personnel and surrounding
public be considered, including an evaluation of potential incidents and safety
measures incorporated in the design or operation of the facility.
• NFPA 59A (2001) section 2.2.3.2 requires provisions to minimize the damaging
effects of fire from reaching beyond a property line, and requires provisions to
16
49 CFR 193.2001 (b) (3), Scope of part, excludes any matter other than siting provisions pertaining to marine cargo
transfer systems between the LNG marine vessel and the last manifold (or in the absence of a manifold, the last valve)
located immediately before a storage tank.

prevent a radiant heat flux level of 1,600 British thermal units per square foot per
hour (Btu/ft2-hr) from reaching beyond a property line that can be built upon. The
distance to this flux level is to be calculated with LNGFIRE3 or with models that
have been validated by experimental test data appropriate for the hazard to be
evaluated and that have been approved by DOT.
• NFPA 59A (2001) section 2.2.3.4 requires provisions to minimize the possibility
of any flammable mixture of vapors from a design spill from reaching a property
line that can be built upon and that would result in a distinct hazard. Determination
of the distance that the flammable vapors extend is to be determined with
DEGADIS or approved alternative models that take into account physical factors
influencing LNG vapor dispersion. 17
Taken together, 49 CFR 193 Subpart B and NFPA 59A (2001) require that flammable LNG
vapors from design spills do not extend beyond areas in which the operator or a government agency
legally controls all activities. Furthermore, consideration of other hazards which may affect the
public or plant personnel must be evaluated as prescribed in NFPA 59A (2001) section 2.1.1 (d).
Title 49 CFR 193 Subpart B and NFPA 59A (2001) also specify three radiant heat flux
levels which must be considered for LNG storage tank spills for as long as the facility is in
operation:
• 1,600 Btu/ft2-hr - This level can extend beyond the plant property line that can be
built upon but cannot include areas that are used for outdoor assembly by groups
of 50 or more persons; 18
• 3,000 Btu/ft2-hr - This level can extend beyond the plant property line that can be
built upon but cannot include areas that contain assembly, educational, health care,
detention or residential buildings or structures; 19 and
• 10,000 Btu/ft2-hr - This level cannot extend beyond the plant property line that can
be built upon. 20
17
DOT has approved two additional models for the determination of vapor dispersion exclusion zones in accordance
with 49 CFR 193.2059: FLACS 9.1 Release 2 (Oct. 7, 2011) and PHAST-UDM Version 6.6 and 6.7 (Oct. 7, 2011).
18
The 1,600 Btu/ft2-hr flux level is associated with producing pain in less than 15 seconds, first degree burns in 20
seconds, second degree burns in approximately 30-40 seconds, 1 percent mortality in approximately 120 seconds, and
100 percent mortality in approximately 400 seconds, assuming no shielding from the heat, and is typically the
maximum allowable intensity for emergency operations with appropriate clothing based on average 10 minute
exposure.
19
seconds, second degree burns in approximately 10-15 seconds, 1 percent mortality in approximately 50 seconds, and
100 percent mortality in approximately 180 seconds, assuming no shielding from the heat, and is typically the critical
heat flux for piloted ignition of common building materials (e.g., wood, PVC, fiberglass, etc.) with prolonged
exposures.
20
seconds, second degree burns in approximately 3 seconds, 1 percent mortality in approximately 10 seconds, and 100
percent mortality in approximately 35 seconds, assuming no shielding from the heat, and is typically the critical heat
flux for unpiloted ignition of common building materials (e.g., wood, PVC, fiberglass) and degradation of unprotected
process equipment after approximate 10 minute exposure and to reinforced concrete after prolonged exposure.

The requirements for design spills from process or transfer areas are more stringent. For
LNG spills, the 1,600 Btu/ft2-hr flux level cannot extend beyond the plant property line onto a
property that can be built upon. In addition, section 2.1.1 of NFPA 59A (2001) requires that factors
applicable to the specific site with a bearing on the safety of plant personnel and the surrounding
public must be considered, including an evaluation of potential incidents and safety measures
incorporated into the design or operation of the facility. DOT has indicated that potential incidents,
such as vapor cloud explosions and toxic releases should be considered to comply with Part 193
Subpart B. 21
In accordance with the August 31, 2018 MOU, DOT issued an LOD to FERC on the 49
CFR 193 Subpart B regulatory requirements. 22 The LOD provides PHMSA’s analysis and
conclusions regarding 49 CFR 193 Subpart B regulatory requirements for the Commission to
consider in its decision to authorize, with or without modification or conditions, or deny an
application.
Coast Guard Safety Regulatory Requirements and Letter of Recommendation

4.12.3.1 LNG Marine Vessel Historical Record
Since 1959, marine vessels have transported LNG without a major release of cargo or a
major accident involving an LNG marine vessel. There are more than 370 LNG marine vessels in
operation routinely transporting LNG between more than 100 import/export terminals currently in
operation worldwide. Since U.S. LNG terminals first began operating under FERC jurisdiction in
the 1970s, there have been thousands of individual LNG marine vessel arrivals at terminals in the
U.S. For more than 40 years, LNG shipping operations have been safely conducted in U.S. ports
and waterways.
A review of the history of LNG maritime transportation indicates that there has not been a
serious accident at sea or in a port which resulted in a spill due to rupturing of the cargo tanks.
However, insurance records, industry sources, and public websites identify a number of incidents
involving LNG marine vessels, including minor collisions with other vessels of all sizes,
groundings, minor LNG releases during cargo unloading operations, and mechanical/equipment
failures typical of large vessels. Some of the more significant occurrences, representing the range
of incidents experienced by the worldwide LNG marine vessel fleet, are described below:
• El Paso Paul Kayser grounded on a rock in June 1979 in the Straits of Gibraltar
during a loaded voyage from Algeria to the United States. Extensive bottom
damage to the ballast tanks resulted; however, no cargo was released because no
damage was done to the cargo tanks. The entire cargo of LNG was subsequently
transferred to another LNG marine vessel and delivered to its U.S. destination.
21
The US DOT PHMSA’s “LNG Plant Requirements: Frequently Asked Questions” item H1,
https://www.phmsa.dot.gov/pipeline/liquified-natural-gas/lng-plant-requirements-frequently-asked-questions,
accessed Aug 2018.
22
March 20, 2019 letter “Re: Annova LNG Brownsville Project, Docket No. CP16-480-000, 49 CFR Part 193, Subpart
B, Siting – Letter of Determination” from Massoud Tahamtani to Rich McGuire. Filed in Docket Number CP16-480-
000 on March 21, 2019. FERC eLibrary accession number 20190321-3021.

• Tellier was blown by severe winds from its docking berth at Skikda, Algeria in
February 1989 causing damage to the loading arms and the LNG marine vessel and
shore piping. The cargo loading had been secured just before the wind struck, but
the loading arms had not been drained. Consequently, the LNG remaining in the
loading arms spilled onto the deck, causing fracture of some plating.
• Mostefa Ben Boulaid had an electrical fire in the engine control room during
unloading at Everett, Massachusetts on February 5, 1996. The ship crew
extinguished the fire and the ship completed unloading.
• Khannur had a cargo tank overfill into the LNG marine vessel’s vapor handling
system on September 10, 2001, during unloading at Everett, Massachusetts.
Approximately 100 gallons of LNG were vented and sprayed onto the protective
decking over the cargo tank dome, resulting in several cracks. After inspection by
the Coast Guard, the Khannur was allowed to discharge its LNG cargo.
• Mostefa Ben Boulaid had LNG spill onto its deck during loading operations in
Algeria in 2002. The spill, which is believed to have been caused by overflow
rather than a mechanical failure, caused significant brittle fracturing of the
steelwork. The LNG marine vessel was required to discharge its cargo, after which
it proceeded to dock for repair.
• Norman Lady was struck by the USS Oklahoma City nuclear submarine while the
submarine was rising to periscope depth near the Strait of Gibraltar in November
2002. The 87,000 m3 LNG marine vessel, which had just unloaded its cargo at
Barcelona, Spain, sustained only minor damage to the outer layer of its double hull
but no damage to its cargo tanks.
• Tenaga Lima grounded on rocks while proceeding to open sea east of Mopko,
South Korea due to strong current in November 2004. The shell plating was torn
open and fractured over an approximate area of 20 by 80 feet, and internal breaches
allowed water to enter the insulation space between the primary and secondary
membranes. The LNG marine vessel was refloated, repaired, and returned to
service.
• Golar Freeze moved away from its docking berth during unloading on
March 14, 2006, in Savannah, Georgia. The powered emergency release couplings
on the unloading arms activated as designed, and transfer operations were shut
down.
• Catalunya Spirit lost propulsion and became adrift 35 miles east of Chatham,
Massachusetts on February 11, 2008. Four tugs towed the LNG marine vessel to a
safe anchorage for repairs. The Catalunya Spirit was repaired and taken to port to
discharge its cargo.
• Al Gharrafa collided with a container ship, Hanjin Italy, in the Malacca Strait off
Singapore on December 19, 2013. The bow of the Al Gharrafa and the middle of
the starboard side of the Hanjin were damaged. Both ships were safely anchored
after the incident. No loss of LNG was reported.
• Al Oraiq collided with a freight carrier, Flinterstar, near Zeebrugge, Belgium on
October 6, 2015. The freight carrier sank, but the Al Oraiq was reported to have

sustained only minor damage to its bow and no damage to the LNG cargo
tanks. According to reports, the Al Oraiq took on a little water but was towed to
the Zeebrugge LNG terminal where its cargo was unloaded using normal
procedures. No loss of LNG was reported.
• Al Khattiya suffered damage after a collision with an oil carrier off the Port of
Fujairah on February 23, 2017. Al Khattiya had discharged its cargo and was
anchored at the time of the incident. A small amount of LNG was retained within
the LNG marine vessel to keep the cargo tanks cool. The collision damaged the
hull and two ballast tanks on the Al Khattiya but did not cause any injury or water
pollution. No loss of LNG was reported.
• Aseem collided with a very large crude carrier (VLCC) Shinyo Ocean off the Port
of Fujairah on March 26, 2019. The VLCC suffered severe portside hull height
breach and Aseem had damage to its bow. Both marine vessels were unloaded at
the time of the collision and subsequently no LNG or oil was released. Aseem was
moved to port for anchorage and Shinyo Ocean was relocated to another point of
anchorage.
4.12.3.2 LNG Marine Vessel Safety Regulatory Oversight
The Coast Guard exercises regulatory authority over LNG marine vessels under 46 CFR
154, which contains the United States safety standards for self-propelled LNG marine vessels
transporting bulk liquefied gases. The LNG marine vessels visiting the proposed facility would
also be constructed and operated in accordance with the IMO Code for the Construction and
Equipment of Ships Carrying Liquefied Gases in Bulk and the International Convention for the
Safety of Life at Sea. All LNG marine vessels entering U.S. waters are required to possess a valid
IMO Certificate of Fitness and either a Coast Guard Certificate of Inspection for U.S. flag vessels
or a Coast Guard Certificate of Compliance for foreign flag vessels. These documents certify that
the LNG marine vessel is designed and operating in accordance with both international standards
and the U.S. regulations for bulk LNG marine vessels under 46 CFR 154.
The LNG marine vessels that would deliver or receive LNG to or from the proposed facility
would also need to comply with various U.S. and international security requirements. The IMO
adopted the International Ship and Port Facility Security Code in 2002. This code requires both
ships and ports to conduct vulnerability assessments and to develop security plans. The purpose
of the code is to prevent and suppress terrorism against ships; improve security aboard ships and
ashore; and reduce the risk to passengers, crew, and port personnel on board ships and in port
areas. All LNG marine vessels, as well as other cargo vessels (e.g., 500 gross tons and larger),
and ports servicing those regulated vessels, must adhere to the IMO standards. Some of the IMO
requirements for marine vessels are as follows:
• marine vessels must develop security plans and have a Vessel Security Officer;
• marine vessels must have a security alert system to transmit ship-to-shore security
alerts identifying the marine vessel, its location, and an indication of whether the
security of the marine vessel is under threat or has been compromised;
• marine vessels must have a comprehensive security plan for international port
facilities, focusing on areas having direct contact with marine vessels; and

• marine vessels must have equipment onboard to help maintain or enhance the
physical security of the marine vessel.
In 2002, the Maritime Transportation Security Act (MTSA) was enacted by the U.S.
Congress and aligned domestic regulations with the maritime security standards of the
International Ship and Port Facility Security Code and the Code for the Construction and
Equipment of Ships Carrying Liquefied Gases in Bulk and the International Convention for the
Safety of Life at Sea. The Coast Guard’s regulations in 33 CFR 104 require marine vessels to
conduct a vessel security assessment and develop a vessel security plan that addresses each
vulnerability identified in the vessel security assessments. All LNG marine vessels servicing the
facility would have to comply with the MTSA requirements and associated regulations while in
U.S. waters.
The Coast Guard also exercises regulatory authority over LNG facilities that affect the
safety and security of port areas and navigable waterways under Executive Order 10173; the
Magnuson Act (50 USC section 191); the Ports and Waterways Safety Act of 1972, as amended
(33 USC section 1221, et seq.); and the MTSA of 2002 (46 USC section 701). The Coast Guard
is responsible for matters related to navigation safety, LNG marine vessel engineering and safety
standards, and all matters pertaining to the safety of facilities or equipment located in or adjacent
to navigable waters up to the last valve immediately before the receiving tanks. The Coast Guard
also has authority for LNG facility security plan review, approval, and compliance verification as
provided in 33 CFR 105.
The Coast Guard regulations in 33 CFR 127 apply to the marine transfer area of waterfront
facilities between the LNG marine vessel and the last manifold or valve immediately before the
receiving tanks. Title 33 CFR 127 applies to the marine transfer area for LNG of each new
waterfront facility handling LNG and to new construction in the marine transfer areas for LNG of
each existing waterfront facility handling LNG. The scope of the regulations includes the design,
construction, equipment, operations, inspections, maintenance, testing, personnel training,
firefighting, and security of the marine transfer area of LNG waterfront facilities. The safety
systems, including communications, emergency shutdown, gas detection, and fire protection, must
comply with the regulations in 33 CFR 127. Under 33 CFR 127.019, Annova would be required
to submit two copies of its Operations and Emergency Manuals to the Coast Guard Captain of the
Port (COTP) for examination.
Both the Coast Guard regulations under 33 CFR 127 and FERC regulations under 18 CFR
157.21, require an applicant who intends to build an LNG terminal facility to submit a Letter of
Intent (LOI) to the Coast Guard no later than the date that the owner/operator initiates pre-filing
with FERC, but, in all cases, at least 1 year prior to the start of construction. In addition, the
applicant must submit a Preliminary WSA to the COTP with the LOI.
The Preliminary WSA provides an initial explanation of the port community and the
proposed facility and transit routes. It provides an overview of the expected impacts LNG
operations may have on the port and the waterway. Generally, the Preliminary WSA does not
contain detailed studies or conclusions. This document is used by the COTP to begin his or her
evaluation of the suitability of the waterway for LNG marine traffic. The Preliminary WSA must
provide an initial explanation of the following:

• port characterization;
• characterization of the LNG facility and the LNG marine vessel route;
• risk assessment for maritime safety and security;
• risk management strategies; and
• resource needs for maritime safety, security, and response.
A Follow-On WSA must be provided no later than the date the owner/operator files an
application with FERC, but in all cases at least 180 days prior to transferring LNG. The Follow-
on WSA must provide a detailed and accurate characterization of the waterfront facilities handling
LNG, the LNG marine vessel route, and the port area. The Follow-on WSA provides a complete
analysis of the topics outlined in the Preliminary WSA. It should identify credible security threats
and navigational safety hazards for the LNG marine vessel traffic, along with appropriate risk
management measures and the resources (i.e., federal, state, local, and private sector) needed to
carry out those measures. Until a facility begins operation, applicants must also annually review
their WSAs and submit a report to the COTP as to whether changes are required. This document
is reviewed and validated by the Coast Guard and forms the basis for the agency’s Letter of
Recommendation (LOR) to the FERC.
In order to provide the Coast Guard COTPs/Federal Maritime Security Coordinators,

members of the LNG industry, and port stakeholders with guidance on assessing the suitability of
a waterway for LNG marine traffic, the Coast Guard has published a Navigation and Vessel
Inspection Circular – Guidance on Assessing the Suitability of a Waterway for Liquefied Natural
Gas (LNG) Marine Traffic (NVIC 01-11).
NVIC 01-11 directs the use of the three concentric Zones of Concern, based on LNG
marine vessels with a cargo carrying capacity up to 265,000 m³, used to assess the maritime safety
and security risks of LNG marine traffic. The Zones of Concern are:
• Zone 1 – impacts on structures and organisms are expected to be significant within

500 meters (1,640 feet). The outer perimeter of Zone 1 is approximately the
distance to thermal hazards of 37.5 kilowatts per square meter (kW/m2) (12,000
Btu/ft2-hr) from a pool fire.
• Zone 2 – impacts would be significant but reduced, and damage from radiant heat
levels are expected to transition from severe to minimal between 500 and
1,600 meters (1,640 and 5,250 feet). The outer perimeter of Zone 2 is
approximately the distance to thermal hazards of 5 kW/m2 (1,600 Btu/ft2-hr) from
a pool fire.
• Zone 3 – impacts on people and property from a pool fire or an un-ignited LNG
spill are expected to be minimal between 1,600 meters (5,250 feet) and a
conservative maximum distance of 3,500 meters (11,500 feet or 2.2 miles). The
outer perimeter of Zone 3 should be considered the vapor cloud dispersion distance
to the lower flammability limit from a worst case un-ignited release. Impacts to
people and property could be significant if the vapor cloud reaches an ignition
source and burns back to the source.

Once the applicant submits a complete Follow-On WSA, the Coast Guard reviews the
document to determine if it presents a realistic and credible analysis of the public safety and security
implications from LNG marine traffic both in the waterway and when in port. As required by its
regulations (33 CFR 127.009), the Coast Guard is responsible for issuing a LOR to the FERC regarding
the suitability of the waterway for LNG marine traffic with respect to the following items:
• physical location and description of the facility;

• the LNG marine vessel’s characteristics and the frequency of LNG shipments to or
from the facility;
• waterway channels and commercial, industrial, environmentally sensitive, and
residential areas in and adjacent to the waterway used by LNG marine vessels en
route to the facility, within 25 kilometers (15.5 miles) of the facility;
• density and character of marine traffic in the waterway;
• locks, bridges, or other manmade obstructions in the waterway;
• depth of water;
• tidal range;
• protection from high seas;
• natural hazards, including reefs, rocks, and sandbars;
• underwater pipes and cables; and
• distance of berthed LNG marine vessels from the channel and the width of the
channel.
The Coast Guard may also prepare an LOR Analysis, which serves as a record of review
of the LOR and contains detailed information along with the rationale used in assessing the
suitability of the waterway for LNG marine traffic.
4.12.3.3 Annova’s Waterway Suitability Assessment

On February 23, 2015, Annova submitted a LOI and a Preliminary WSA to the COTP,
Sector Corpus Christi to notify the Coast Guard that it proposed to construct an LNG export
terminal. Annova submitted the Follow-On WSA to the Coast Guard on May 24, 2016.
4.12.3.4 LNG Marine Vessel Routes and Hazard Analysis

An LNG marine vessel’s transit to and from the terminal would begin when it enters the U.S.
Exclusive Economic Zone from well-established shipping lanes through the Gulf of Mexico. The
LNG marine vessel would then enter the U.S. Territorial Sea limit (State Waters) to arrive at the
Brazos Santiago Pass ocean buoy. At the Santiago Pass ocean buoy, pilots would board the LNG
marine vessel before entering the Brownsville Ship Channel. Inland navigation from the Brazos
Santiago Pass to the Project site would be about 8.7 miles. Pilotage is compulsory for foreign vessels
and U.S. vessels under registry in foreign trade when in U.S. waters. All deep draft marine vessels
currently entering the shared waterway would employ a U.S. pilot. The National Vessel Movement
Center in the U.S. would require a 96-hour advance notice of arrival for deep draft vessels calling
on U.S. ports. During transit, LNG marine vessels would be required to maintain voice contact with
controllers and check in on designated frequencies at established way points.

NVIC 01-11 references the “Zones of Concern” for assisting in a risk assessment of the
waterway. As LNG marine vessels proceed along the intended transit route, no hospitals, cultural
centers, city centers, or military installations would be located within any of the three zones of
concern. Hazard Zone 1 would encompass coastal areas along South Padre Island, Port Isabel,
and the Brownsville Navigation District, including a public boat ramp and approximately 30
Recreational Vehicles (RV) hook-ups on South Padre Island, and the marine facilities associated
with the proposed Texas LNG and Rio Grande LNG projects. Commercial vessels, recreational
and fishing vessels may also fall within Zone 1, depending on their course. Transit of such vessels
through a Zone 1 area of concern can be avoided by timing and course changes, if conditions
permit. Zone 2 would cover a wider swath of coastal areas along South Padre Island, Port Isabel,
and the Brownsville Navigation District, including the Coast Guard Station at South Padre Island,
multiple residential buildings, commercial buildings, industrial buildings, a church, a university
lab building, Schlitterbahn Water Park, and Long Island. Zone 3 would span larger portions of
South Padre Island, Port Isabel, and the Brownsville Navigation District, including the Port Isabel
Police and Fire Departments, multiple residential, commercial, and industrial buildings, 9
churches, 2 elementary schools, and the causeway between Port Isabel and South Padre Island.
The areas impacted by the three different hazard zones are illustrated for accidental and
intentional events in figures 4.12-1 and 4.12-2, respectively.

Annova LNG Facility

Ship Transit Route
Accidental Sandia Hazard Zone 1 (0 to 250 m)
Figure 4.12-1 Accidental Hazard Zones along LNG Marine Vessel Route

Annova LNG Facility

Ship Transit Route
Intentional Sandia Hazard Zone 1 (0 to 500 m)
Figure 4.12-2 Intentional Hazard Zones along LNG Marine Vessel Route
4.12.3.5 Coast Guard Letter of Recommendation and Analysis

In a letter dated February 13, 2018, the Coast Guard issued an LOR and LOR Analysis to
FERC stating that the Brownsville Ship Channel would be considered suitable for accommodating
the type and frequency of LNG marine traffic associated with this Project. Although the WSA
was based on a maximum of 125, the Coast Guard's LOR for the Annova Project states that the
BSC would be suitable for 80 ships. The LOR also considered impacts related to the adjacent
SpaceX rocket launch facility. As part of its assessment of the safety and security aspects of this
project, the COTP Sector Corpus Christi consulted a variety of stakeholders including
representatives from Port of Brownsville Navigation District, Port Isabel Navigation District, local
facility security, the Brazos Santiago Pilots Association, and Signet Maritime. The LOR was based
on full implementation of the strategies and risk management measures identified by the Coast
Guard to Annova in its WSA. Annova indicates that up to 125 vessels per year may visit the
terminal, depending on the storage capacity. The LOR currently evaluates 80 vessels sized at
178,000 m3. Annova is coordinating with the Coast Guard to determine if a larger number of

smaller vessels, or a mix of vessel sizes, would require any modification to the LOR. Our analysis
in this EIS assumes that up to 125 vessels per year may visit the Project.
Although Annova has suggested mitigation measures for responsibly managing the
maritime safety and security risks associated with LNG marine vessel marine traffic, the necessary
vessel traffic and/or facility control measures may change depending on changes in conditions
along the waterway. The Coast Guard regulations in 33 CFR 127 require that applicants annually
review WSAs until a facility begins operation. The annual review and report to the Coast Guard
would identify any changes in conditions, such as changes to the port environment, the LNG
facility, or the LNG marine vessel route, that would affect the suitability of the waterway.
The Coast Guard’s LOR is a recommendation, regarding the current status of the waterway,
to the FERC, the lead agency responsible for siting the on-shore LNG facility. Neither the Coast
Guard nor the FERC has authority to require waterway resources of anyone other than the applicant
under any statutory authority or under the ERP or the Cost Sharing Plan. As stated in the LOR,
the Coast Guard would assess each transit on a case by case basis to identify what, if any, safety
and security measures would be necessary to safeguard the public health and welfare, critical
infrastructure and key resources, the port, the marine environment, and the LNG marine vessel.
Under the Ports and Waterways Safety Act, the Magnuson Act, the MTSA, and the Security
and Accountability For Every (SAFE) Port Act, the COTP has the authority to prohibit LNG
transfer or LNG marine vessel movements within his or her area of responsibility if he or she
determines that such action is necessary to protect the waterway, port, or marine environment. If
this Project is approved and if appropriate resources are not in place prior to LNG marine vessel
movement along the waterway, then the COTP would consider at that time what, if any, vessel
traffic and/or facility control measures would be appropriate to adequately address navigational
safety and maritime security considerations.
LNG Facility Security Regulatory Requirements

The security requirements for the proposed project are governed by 33 CFR 105, 33 CFR
127, and 49 CFR 193 Subpart J. Title 33 CFR 105, as authorized by the MTSA, requires all
terminal owners and operators to submit a Facility Security Assessment (FSA) and a Facility
Security Plan (FSP) to the Coast Guard for review and approval before commencement of
operations of the proposed project facilities. Annova would also be required to control and restrict
access, patrol and monitor the plant, detect unauthorized access, and respond to security threats or
breaches under 33 CFR 105. Some of the responsibilities of the applicant include, but are not
limited to:
• designating a Facility Security Officer with a general knowledge of current security

threats and patterns, security assessment methodology, vessel and facility
operations, conditions, security measures, emergency preparedness, response, and
contingency plans, who would be responsible for implementing the FSA and FSP
and performing an annual audit for the life of the Project;
• conducting a FSA to identify site vulnerabilities, possible security threats and
consequences of an attack, and facility protective measures; developing a FSP
based on the FSA, with procedures for: responding to transportation security

incidents; notification and coordination with federal, state, and local authorities;
prevention of unauthorized access; measures to prevent or deter entrance with
dangerous substances or devices; training; and evacuation;
• defining the security organizational structure with facility personnel with
knowledge or training in current security threats and patterns; recognition and
detection of dangerous substances and devices, recognition of characteristics and
behavioral patterns of persons who are likely to threaten security; techniques to
circumvent security measures; emergency procedures and contingency plans;
operation, testing, calibration, and maintenance of security equipment; and
inspection, control, monitoring, and screening techniques;
• implementing scalable security measures to provide increasing levels of security at
increasing maritime security levels for facility access control, restricted areas, cargo
handling, LNG marine vessel stores and bunkers, and monitoring; ensuring that the
Transportation Worker Identification Credential (TWIC) program is properly
implemented;
• ensuring coordination of shore leave for LNG marine vessel personnel or crew
change out as well as access through the facility for visitors to the LNG marine
vessel;
• conducting drills and exercises to test the proficiency of security and facility
personnel on a quarterly and annual basis; and
• reporting all breaches of security and transportation security incidents to the
National Response Center.
Title 33 CFR 127 has requirements for access controls, lighting, security systems, security
personnel, protective enclosures, communications, and emergency power. In addition, an LNG
facility regulated under 33 CFR 105 and 33 CFR 127 would be subject to the TWIC Reader
Requirements Rule issued by the Coast Guard on August 23, 2016. This rule requires owners and
operators of certain vessels and facilities regulated by the Coast Guard to conduct electronic
inspections of TWICs (e.g., readers with biometric fingerprint authentication) as an access control
measure. The final rule would also include recordkeeping requirements and security plan
amendments that would incorporate these TWIC requirements. The implementation of the rule
was first proposed to be in effect August 23, 2018. In a subsequent notice issued on June 22, 2018,
Coast Guard indicated delaying the effective date for certain facilities by 3 years, until August 23,
2021. On August 2, 2018, the President of the United States signed into law the Transportation
Worker Identification Credential Accountability Act of 2018 (H.R. 5729). This law prohibits the
Coast Guard from implementing the rule requiring electronic inspections of TWICs until after the
Department of Homeland Security (DHS) has submitted a report to the Congress. Although the
implementation of this rule has been postponed for certain facilities, the company may need to
consider the rule when developing access control and security plan provisions for the facility.
Title 49 CFR 193 Subpart J also specifies security requirements for the onshore
components of LNG facilities, as defined in 49 CFR 193, including requirements for conducting
security inspections and patrols, liaison with local law enforcement officials, design and
construction of protective enclosures, lighting, monitoring, alternative power sources, and warning
signs. If the Project is authorized, constructed, and operated, compliance with the security

requirements of 33 CFR 105, 33 CFR 127, and 49 CFR 193 Subpart J would be subject to the
respective Coast Guard and DOT inspection and enforcement programs.
Annova provided preliminary information as well as data request responses on these

security features and indicated additional details would be completed in the final design. Annova
also indicated that plant lighting would be in accordance with American Petroleum Institute (API)
Standard 540. We recommend in section 4.12.6 that Annova provide final design details on these
security features for review and approval including: lighting coverage drawings that illustrate
photometric analyses demonstrating the lux levels at the interior of the terminal are in accordance
with API 540, including lighting along the perimeter fence line and along paths/roads of access
and egress; camera coverage drawings that illustrate coverage areas of each camera such that the
entire perimeter of the plant is covered with redundancy and the interior of plant is covered,
including a camera be provided at the top of each LNG storage tank, within pretreatment areas,
within liquefaction areas, within truck transfer areas, within marine transfer areas, and buildings;
fencing drawings that demonstrate a fence would deter or mitigate entry along the perimeter of the
entire facility, including metering station, and is set back from exterior structures and vegetation,
and from interior hazardous piping and equipment by at least 10 feet; vehicle barrier and controlled
access point drawings that demonstrate crash rated barriers are provided to prevent uncontrolled
access, inadvertent entry, and impacts to components containing hazardous fluids from vehicles.
Furthermore, in accordance with the February 2004 Interagency Agreement among FERC, DOT,
and Coast Guard, FERC staff would collaborate with Coast Guard and DOT on the Project’s
security features.
FERC Engineering and Technical Review of the Preliminary Engineering Designs

4.12.5.1 LNG Facility Historical Record
The operating history of the U.S. LNG industry has been free of safety-related incidents
resulting in adverse effects on the public or the environment with the exception of the October 20,
1944, failure at an LNG plant in Cleveland, Ohio. The 1944 incident in Cleveland led to a fire that
killed 128 people and injured 200 to 400 more people. 23 The failure of the LNG storage tank was
due to the use of materials not suited for cryogenic temperatures. LNG migrated through streets
and into underground sewers due to inadequate spill impoundments at the site. Current regulatory
requirements ensure that proper materials suited for cryogenic temperatures are used in the design
and that spill impoundments are designed and constructed properly to contain a spill at the site.
To ensure that this potential hazard would be addressed for proposed LNG facilities, we evaluate
the preliminary and final specifications for suitable materials of construction and for the design of
spill containment systems that would properly contain a spill at the site.
Another operational accident occurred in 1979 at the Cove Point LNG plant in Lusby,
Maryland. A pump electrical seal located on a submerged electrical motor LNG pump leaked
causing flammable gas vapors to enter an electrical conduit and settle in a confined space. When
a worker switched off a circuit breaker, the flammable gas ignited, causing severe damage to the
building and a worker fatality. With the participation of the FERC, lessons learned from the 1979
23
For a description of the incident and the findings of the investigation, see “U.S. Bureau of Mines, Report on the
Investigation of the Fire at the Liquefaction, Storage, and Regasification Plant of the East Ohio Gas Co., Cleveland,
Ohio, October 20, 1944,” dated February 1946.

Cove Point accident led to changes in the national fire codes to better ensure that the situation
would not occur again. To ensure that this potential hazard would be addressed for proposed
facilities that have electrical seal interfaces, we evaluated the preliminary design and recommend
in section 4.12.6 that Annova provide, for review and approval, the final design details of the
electrical seal design at the interface between flammable fluids and the electrical conduit or wiring
system, details of the electrical seal leak detection system, and the details of a downstream physical
break (i.e., air gap) in the electrical conduit to prevent the migration of flammable vapors.
On January 19, 2004, a blast occurred at Sonatrach’s Skikda, Algeria, LNG liquefaction
plant that killed 27 and injured 56 workers. No members of the public were injured. Findings of
the accident investigation suggested that a cold hydrocarbon leak occurred at Liquefaction Train
40 and was introduced into a high-pressure steam boiler by the combustion air fan. An explosion
developed inside the boiler firebox, which subsequently triggered a larger explosion of the
hydrocarbon vapors in the immediate vicinity. The resulting fire damaged the adjacent
liquefaction process and liquid petroleum gas separation equipment of Train 40, and spread to
Trains 20 and 30. Although Trains 10, 20, and 30 had been modernized in 1998 and 1999, Train
40 had been operating with its original equipment since start-up in 1981. To ensure that this
potential hazard would be addressed for proposed facilities, we evaluated the preliminary design
for mitigation of flammable vapor dispersion and ignition in buildings and combustion equipment
to ensure they would be adequately covered by hazard detection equipment that could isolate and
deactivate any combustion equipment whose continued operation could add to or sustain an
emergency. We also recommend in section 4.12.6 that Annova provide, for review and approval,
the final design details of hazard detection equipment, including the location and elevation of all
detection equipment, instrument tag numbers, type and location, alarm indication locations, and
shutdown functions of the hazard detection equipment.
On March 31, 2014, a detonation occurred within a gas heater at Northwest Pipeline
Corporation’s LNG peak-shaving plant in Plymouth, Washington 24. This internal detonation
subsequently caused the failure of pressurized equipment, resulting in high velocity projectiles.
The plant was immediately shut down, and emergency procedures were activated, which included
notifying local authorities and evacuating all plant personnel. No members of the public were
injured, but one worker was sent to the hospital for injuries. As a result of the incident, the
liquefaction trains and a compressor station located onsite were rendered inoperable. Projectiles
from the incident also damaged the control building that was located near the pre-treatment
facilities and penetrated the outer shell of one of the LNG storage tanks. All damaged facilities
were ultimately taken out of service for repair. The accident investigation showed that an
inadequate purge after maintenance activities resulted in a fuel-air mixture remaining in the
system. The fuel-air mixture auto-ignited during startup after it passed through the gas heater at
full operating pressure and temperature. To ensure that this potential hazard would be addressed
for proposed facilities, we recommend in section 4.12.6 that Annova provide a plan for purging,
for review and approval, which addresses the requirements of the American Gas Association
Purging Principles and Practice and to provide justification if not using an inert or non-flammable
gas for purging. In evaluating such plans, we would assess whether the purging could be done
safely based on review of other plans and lessons learned from this and other past incidents. If a
For a description of the incident and the findings of the investigation, see Root Cause Failure Analysis, Plymouth
24
LNG Plant Incident Investigation under CP14-515.

plan proposes the use of flammable mediums for cleaning, dry-out or other activities, we would
evaluate the plans against other recommended and generally accepted good engineering practices,
such as NFPA 56, Standard for Fire and Explosion Prevention during Cleaning and Purging of
Flammable Gas Piping Systems.
We also recommend in section 4.12.6 that Annova provide, for review and approval,
operating and maintenance plans, including safety procedures, prior to commissioning. In
evaluating such plans, we would assess whether the plans cover all standard operations, including
purging activities associated with startup and shutdown. Also, in order to prevent other sources of
projectiles from affecting occupied buildings and storage tanks, we recommend in section 4.12.6
that Annova incorporate mitigation into their final design with supportive information, for review
and approval, that demonstrates it would mitigate the risk of a pressure vessel burst or boiling
liquid expanding vapor explosion (BLEVE) from occurring.
4.12.5.2 FERC Preliminary Engineering Review

FERC requires an applicant to provide safety, reliability, and engineering design
information as part of its application, including hazard identification studies and front-end-
engineering-design (FEED) information for its proposed Project. FERC staff evaluates this
information with a focus on potential hazards from within and nearby the site, including external
events, which may have the potential to cause damage or failure to the Project facilities, and the
engineering design and safety and reliability concepts of the various protection layers to mitigate
the risks of potential hazards.
The primary concerns are those events that could lead to a hazardous release of sufficient
magnitude to create an offsite hazard or interruption of service. Further, the potential hazards are
dictated by the site location and the engineering details. In general, FERC staff considers an
acceptable design to include various layers of protection or safeguards to reduce the risk of a
These layers of protection are generally independent of one another so that any one layer would
perform its function regardless of the initiating event or failure of any other protection layer. Such
design features and safeguards typically include:
• a facility design that prevents hazardous events, including the use of inherently
safer designs; suitable materials of construction; adequate design margins from
operating limits for process piping, process vessels, and storage tanks; adequate
design for wind, flood, seismic, and other outside hazards;
• control systems, including monitoring systems and process alarms, remotely-
operated control and isolation valves, and operating procedures to ensure that the
facility stays within the established operating and design limits;
• safety instrumented prevention systems, such as safety control valves and
emergency shutdown systems, to prevent a release if operating and design limits
are exceeded;
• physical protection systems, such as appropriate electrical area classification,
proper equipment and building spacing, pressure relief valves, spill containment,

and cryogenic, overpressure, and fire structural protection, to prevent escalation to

a more severe event;
• site security measures for controlling access to the plant, including security
inspections and patrols, response procedures to any breach of security, and liaison
with local law enforcement officials; and
• onsite and offsite emergency response, including hazard detection and control
equipment, firewater systems, and coordination with local first responders, to
mitigate the consequences of a release and prevent it from escalating to an event
that could impact the public.
The inclusion of such protection systems or safeguards in a plant design can minimize the
potential for an initiating event to develop into an incident that could impact the safety of the offsite
public. The review of the engineering designs for these layers of protection is initiated in the
application process and carried through to the next phase of the proposed Project in final design if
authorization is granted by the Commission.
The reliability of these layers of protection is informed by occurrence and likelihood of

root causes and the potential severity of consequences based on past incidents and validated hazard
modeling. As a result of the continuous engineering review, we recommend mitigation measures
and continuous oversight to the Commission for consideration to include as conditions in the order.
If a facility is authorized and recommendations are adopted as conditions to the order, FERC staff
would continue its engineering review through final design, construction, commissioning, and
operation.
4.12.5.3 Process Design

In order to liquefy natural gas, most liquefaction technologies require that the feed gas
stream be pre-treated to remove components that could freeze out and clog the liquefaction
equipment or would otherwise be incompatible with the liquefaction process or equipment,
including H2S, CO2, water, mercury, and heavy hydrocarbons. For example, mercury is typically
limited to concentrations less than 0.01 micrograms per normal cubic meter because it can cause
embrittlement and corrosion resulting in a catastrophic failure of equipment.
The inlet gas would be conditioned to remove solids and water droplets and for pressure
regulation prior to entering feed gas pretreatment processes. Once the inlet gas is conditioned, the
feed gas would then contact an amine-based solvent solution in the amine contactor column to
remove the H2S and CO2 (i.e., acid gas) present in the feed gas. Once the acid gas components
accumulate in the amine solution, the amine solution is routed to an amine stripper column that
utilizes a reboiler to create hot amine vapor. Contact with the hot amine vapor would regenerate
the amine solution by using heat to release the acid gas. The regenerated amine solution would be
recycled back to the amine contactor column and the removed acid gas would be sent through a
sulfur removal unit to remove H2S. Then this stream is routed to a thermal oxidizer, where CO2,
trace amounts of H2S not removed in the sulfur removal unit, and trace amounts of hydrocarbons
would be incinerated. The feed gas exiting the amine contactor column then enters a knock out
drum where bulk water would be recovered and recycled back to the amine contactor column.
After the knock out drum, any remaining water in the feed gas would be removed using
regenerative molecular sieve beds. During the molecular sieve regeneration process, heated

regeneration gas would release water from the molecular sieve beds. Water would then be
separated from the regeneration gas and would be routed back to the amine contactor column.
After water removal, the feed gas enters a mercury removal vessel that uses an activated carbon
bed to remove trace amounts of mercury. The treated dry gas would then flow to the liquefaction
unit.
Heavy hydrocarbon removal would be integrated into the liquefaction process. The first
pass through the refrigeration process would be used to remove heavy hydrocarbons at
intermediate temperatures. The feed gas would flow into a heavy hydrocarbon separator to remove
the liquids. The vapor portion would reenter the refrigeration process and would be sub-cooled
into LNG. The liquid portion from the heavy hydrocarbon separator would flow into the stabilizer
to further separate the condensate product (C4+) from the lighter hydrocarbons. The liquid
condensate product exiting the stabilizer would be sent to the condensate storage tank and fuel gas
system and the lighter hydrocarbons would be returned to the refrigeration process where it would
also be sub-cooled into low pressure LNG. The LNG exiting the refrigeration process would flow
to an LNG expander to reduce pressure, then into an LNG flash vessel before being pumped to
two single containment LNG storage tanks.
In order to achieve the cryogenic temperatures needed to liquefy the natural gas stream in
the above process, the gas would be cooled by a thermal exchange process driven by a closed loop
refrigeration system using mixed refrigerants comprised of a mixture of nitrogen, methane,
ethylene, propane, and pentane. Methane would be provided from the boil off gas (BOG) system
and the other refrigerants required for the liquefaction process would be delivered by truck and
stored onsite for initial filling and use, as needed, for make-up. Truck loading/unloading facilities
would be provided to unload make-up refrigerants and to load condensate for offsite disposal.
As part of its engineering review, FERC staff evaluated the process flow diagrams (PFDs)
and heat and material balances (HMBs) to determine the liquefaction capacities relative to the
requested capacity in the application. While the application requests export with peak liquefaction
rates of up to 6.95 million mtpa, the PFDs and HMBs do not cover this liquefaction range and
suggest a maximum liquefaction rate of 6.47 mtpa. This is important as the PFDs and HMBs
provide the flow rates, pressures, and temperatures that form the basis of design for other
engineering documents, including piping and instrumentation diagrams (P&IDs), piping
specifications, hazard analyses, and other pertinent engineering information. Therefore, we
recommend in section 4.12.6 that Annova provide updated PFDs and HMBs and any other
engineering documentation that demonstrate they would be capable of liquefying up to 6.95 mtpa.
During export operations, LNG stored within the LNG storage tanks would be sent out
through multiple in-tank pumps (the pump discharge piping would penetrate through the roof and
is an inherently safer design when compared to penetrating the side of an LNG storage tank) and
would be routed through a marine transfer line and multiple liquid marine transfer arms connected
to an LNG marine vessel. In order to keep the marine transfer line cold between LNG export
cargoes, an LNG recirculation line would keep the marine transfer line cold and avoid cool down
prior to every LNG marine vessel loading operation. The LNG transferred to the LNG marine
vessel would displace vapors from the marine vessel, which would be sent back through a vapor
marine transfer arm, a vapor return line, and into the boil-off gas (BOG) header. Once loaded, the
LNG marine vessel would be disconnected and leave for export. Low pressure BOG generated

from stored LNG (LNG is continuously boiling) as well as vapors returned during LNG marine
vessel filling operations would be compressed and would be split and routed to the fuel gas system
and to the liquefaction process. The closed BOG system would prevent the release of BOG to the
atmosphere and would be in accordance with NFPA 59A. This would be an inherently safer design
when compared to allowing the BOG to vent to the atmosphere.
The Project would include many utilities and associated auxiliary equipment. The major
auxiliary systems required for the operation of the liquefaction facility include BOG, fuel gas, hot
oil, flares, instrument and utility air supply, water supply, demineralized water, aqueous ammonia,
nitrogen, and backup power. Hot oil would provide heat to the regeneration gas heater, steam
exchanger, stabilizer reboiler, and fuel gas superheater. Three flare systems would be designed to
handle and control the vent gases from the process areas. The warm and cold flare would be routed
to a common flare stack and the marine flare would be routed to a separate stack. Electric power
would be generated off-site. A small diesel tank would be provided to supply a black start diesel
generator that would support the start-up of the backup natural gas generators. In addition, three
diesel tanks would supply three diesel firewater pumps. Trucks would fill a liquid nitrogen storage
tank and vaporizers would supply gaseous nitrogen for various uses in the plant including pre-
commissioning, start-up, and refrigerant make-up. In addition, aqueous ammonia would be used
for pH adjustment in the steam system.
The failure of process equipment could pose potential harm if not properly safeguarded
through the use of appropriate engineering controls and operation. Annova would install process
control valves and instrumentation to safely operate and monitor the facilities. Alarms would have
visual and audible notification in the control room to warn operators that process conditions may
be approaching design limits. Annova would design their control systems and human machine
interfaces to the International Society for Automation (ISA) Standards 5.3, 5.5, 60.1, 60.3, 60.4,
and 60.6, and other standards and recommended practices. We also recommend in section 4.12.6
that Annova develop and implement an alarm management program, for review and approval to
ensure the effectiveness of the alarms. FERC staff would evaluate the alarm management program
against recommended and generally accepted good engineering practices, such as ISA Standard
18.2.
Operators would have the capability to take action from the control room to mitigate an
upset. Annova would develop facility operation procedures after completion of the final design;
this timing is fully consistent with accepted industry practice. We recommend in section 4.12.6
that Annova provide more information, for review and approval, on the operating and maintenance
procedures, including safety procedures, hot work procedures and permits, abnormal operating
conditions procedures, and personnel training prior to commissioning. We would evaluate these
procedures to ensure that an operator can operate and maintain all systems safely, based on
benchmarking against other operating and maintenance plans and comparing against
recommended and generally accepted good engineering practices, such as American Institute of
Chemical Engineers (AIChE) Center for Chemical Process Safety (CCPS), Guidelines for Writing
Effective Operating and Maintenance Procedures, AIChE CCPS, Guidelines for Management of
Change for Process Safety, AIChE CCPS, Guidelines for Effective Pre-Startup Safety Reviews,
AGA, Purging Principles and Practice, and NFPA 51B, Standards for Fire Prevention During
Welding, Cutting, and Other Hot Work. In addition, we recommend in section 4.12.6 that Annova

tag and label instrumentation and valves, piping, and equipment and provide car-seals/locks to
address human factor considerations and improve facility safety and prevent incidents.
In the event of a process deviation, emergency shutdown (ESD) valves and instrumentation
would be installed to monitor, alarm, shutdown, and isolate equipment and piping during process
upsets or emergency conditions. The Project would have a plant-wide emergency shutdown
system to initiate closure of valves and shutdown of the process during emergency situations as
well as the ability to shutdown specific areas to address local emergency conditions. Safety-
instrumented systems would comply with ISA Standard 84.00.01 and other recommended and
generally accepted good engineering practices. We also recommend in section 4.12.6 that Annova
file information, for review and approval, on the final design, installation, and commissioning of
instrumentation and emergency shutdown equipment to ensure appropriate cause-and-effect alarm
or shutdown logic and enhanced representation of the emergency shutdown system in the plant
control room and throughout the plant.
In developing the FEED, Annova conducted a Preliminary Hazard and Operability (Pre-
HAZOP) study on the project’s preliminary design based on the proposed piping and
instrumentation diagrams. The Pre-HAZOP study identifies potential hazards or environmental
issues in the early stage of the project’s design that could produce undesirable consequences
through the occurrence of an incident by evaluating the materials, systems, process, and plant
design.
A more detailed hazard and operability review (HAZOP) analysis would be performed by
Annova during the final design to identify the major process hazards that may occur during the
operation of the facilities. The HAZOP study would be intended to address hazards of the process,
engineering, and administrative controls and would provide a qualitative evaluation of a range of
possible safety, health, and environmental consequences that may result from the process hazard,
and identify whether there are adequate safeguards (e.g., engineering and administrative controls)
to prevent or mitigate the risk from such events. Where insufficient engineering or administrative
controls were identified, recommendations to prevent or minimize these hazards would be
generated from the results of the HAZOP review. We recommend in section 4.12.6 that Annova
file the HAZOP study on the completed final design for review and approval. We would evaluate
the HAZOP to ensure all systems and process deviations are addressed appropriately based on
likelihood, severity, and risk values with commensurate layers of protection in accordance with
recommended and generally accepted good engineering practices, such as American Institute of
Chemical Engineers, Guidelines for Hazard Evaluation Procedures. We also recommend in
section 4.12.6 that Annova file the resolutions of the recommendations generated by the HAZOP
review be provided for review and approval by FERC staff. Once the design has been subjected
to a HAZOP review, the design development team would track, manage, and keep records of
changes in the facility design, construction, operations, documentation, and personnel. Annova
would evaluate these changes to ensure that the safety, health, and environmental risks arising
from these changes are addressed and controlled based on its management of change procedures.
If our recommendations are adopted into the order, resolutions of the recommendations generated
by the HAZOP review would be monitored by FERC staff. We also recommend in section 4.12.6
that Annova file all changes to their FEED for review and approval by FERC staff. However,
major modifications could require an amendment or new proceeding.

If the Project is authorized, constructed, and operated, Annova would install equipment in
accordance with its design. We recommend in section 4.12.6 that Project facilities be subject to
construction inspections and that Annova provide, for review and approval, commissioning plans,
procedures and commissioning demonstration tests that would verify the performance of
equipment. In addition, we recommend in section 4.12.6 that Annova provide semi-annual reports
that include abnormal operating conditions and planned facility modifications. Furthermore, we
recommend in section 4.12.6 that the Project facilities be subject to regular inspections throughout
the life of the facilities to verify that equipment is being properly maintained and to verify basis of
design conditions, such as feed gas and sendout conditions, do not exceed the original basis of
design.
4.12.5.4 Mechanical Design

Annova provided codes and standards for the design, fabrication, construction, and
installation of piping and equipment and specifications for the facility. The design specifies
materials of construction and ratings suitable for the pressure and temperature conditions of the
process design. Piping would be designed, fabricated, assembled, erected, inspected, examined,
and tested in accordance with the American Society of Mechanical Engineers (ASME) Standards
B31.3, B31.5, B36.10, and B36.19. Valves and fittings would be designed to standards and
recommended practices such as API Standards 594, 598, 600, 602, 603, 607, 608, and 609; ASME
Standards B16.5, B16.10, B16.20, B16.25, and B16.34; and ISA Standards 75.01.01, 75.05.01,
and 75.08.01. Portions of the facility regulated under 33 CFR 127 for the marine transfer system,
including piping, hoses, and loading arms should also be tested in accordance with 33 CFR
127.407.
Pressure vessels must be designed, fabricated, inspected, examined, and tested in

accordance with ASME Boiler and Pressure Vessel Code (BPVC) Section VIII and must be code-
stamped per NFPA 59A (2001), as incorporated by reference in 49 CFR 193 Subparts C, D, and
E. LNG storage tanks must be designed, fabricated, tested, and inspected in accordance with 49
CFR 193 Subpart D, NFPA 59A (2001 and 2006), and API Standard 620. In addition, Annova
would design, fabricate, test, and inspect the LNG storage tanks in accordance with API Standard
625. Other low-pressure storage tanks such as the amine and condensate storage tanks, would be
designed, inspected, and maintained in accordance with the API Standards 650 and 653. All LNG
storage tanks would also include boil-off gas compression to prevent the release of boil-off to the
atmosphere in accordance with NFPA 59A (2001) for an inherently safer design. Heat exchangers
would be designed to ASME BPVC Section VIII standards; API Standards 660, 661, and 662; and
the Tubular Exchanger Manufacturers Association standards. Rotating equipment would be
designed to standards and recommended practices, such as API Standards 610, 613, 614, 617, 670,
671, 675, 676, and 682; and ASME Standards B73.1 and B73.2. Fired heaters would be specified
and designed to standards and recommended practices, such as API Standards 530, 556 and 560,
and NFPA 85.
Pressure and vacuum safety relief valves and flares would be installed to protect the storage
containers, pressure vessels, process equipment, and piping from an unexpected or uncontrolled
pressure excursion. The safety relief valves would be designed to handle process upsets and
thermal expansion, per NFPA 59A (2001), ASME Standard B31.3, and ASME BPVC Section
VIII; and would be designed in accordance with API Standards 520, 521, 526, 527, 537, 2000, and

other recommended and generally accepted good engineering practices. In addition, the operator
should verify the set pressure of the pressure relief valves meet the requirements in 33 CFR
127.407. We recommend in section 4.12.6 Annova provide final design information on pressure
and vacuum relief devices, for review and approval, to ensure that the final sizing, design, and
installation of these components are adequate and in accordance with the standards reference and
other recommended and generally accepted good engineering practices.
Although many of the codes and standards were listed as ones the project would meet,
Annova did not make reference to all codes and standards required by regulations or are
recommended and generally accepted good engineering practices. Annova plans to evaluate the
missing codes and standards and update its list accordingly. Therefore, we recommend in section
4.12.6 that Annova provide the final specifications for all equipment and a summarized list of all
referenced codes and standards for review and approval. If the Project is authorized, constructed,
and operated, Annova would install equipment in accordance with its design and FERC staff would
verify equipment nameplates to ensure equipment is being installed based on the approved design.
In addition, FERC staff would conduct construction inspections including reviewing quality
assurance and quality control plans to ensure construction work is being performed according to
proposed Project specifications, procedures, codes, and standards. We recommend in section
4.12.6 Annova provide semi-annual reports that include equipment malfunctions and abnormal
maintenance activities. In addition, we recommend in section 4.12.6 that the Project facilities be
subject to inspections to verify that the equipment is being properly maintained during the life of
the facility.
4.12.5.5 Hazard Mitigation Design

If operational control of the facilities were lost and operational controls and emergency
shutdown systems failed to maintain the Project within the design limits of the piping, containers,
and safety relief valves, a release could potentially occur. FERC regulations under 18 CFR 380.12
(o) (1) through (4) require applicants to provide information on spill containment, spacing and
plant layout, hazard detection, hazard control, and firewater systems. In addition, 18 CFR 380.12
(o) (7) require applicants to provide engineering studies on the design approach and 18 CFR 380.12
(o) (14) requires applicants to demonstrate how they comply with 49 CFR 193 and NFPA 59A.
As required by 49 CFR 193 Subpart I and by incorporation of section 9.1.2 of NFPA 59A (2001),
fire protection must be provided for all DOT regulated LNG plant facilities based on an evaluation
of sound fire protection engineering principles, analysis of local conditions, hazards within the
facility, and exposure to or from other property. NFPA 59A (2001) also requires the evaluation
on the type, quantity, and location of hazard detection and hazard control, passive fire protection,
emergency shutdown and depressurizing systems, and emergency response equipment, training,
and qualifications. If authorized, constructed, and operated, LNG facilities as defined in 49 CFR
193, must comply with the requirements of 49 CFR 193 Subpart I and would be subject to DOT’s
inspection and enforcement programs. However, NFPA 59A (2001) also indicates the wide range
in size, design, and location of LNG facilities precludes the inclusion of detailed fire protection
provisions that apply to all facilities comprehensively and includes subjective performance-based
language on where ESD systems and hazard control are required and does not provide any
additional guidance on placement or selection of hazard detection equipment and provides minimal
requirements on firewater. Also, the project marine facilities would be subject to 33 CFR 127,
which incorporates sections of NFPA 59A (1994), which have similar performance-based

guidance. Therefore, FERC staff evaluated the proposed spill containment and spacing, hazard
detection, emergency shutdown and depressurization systems, hazard control, firewater coverage,
structural protection, and onsite and offsite emergency response to ensure they would provide
adequate protection of the LNG facilities as described more fully below.
Annova performed a preliminary fire protection evaluation to ensure that adequate

mitigation would be in place, including spill containment and spacing, hazard detection,
emergency shutdown and depressurization systems, hazard control, firewater coverage, structural
protection, and onsite and offsite emergency response. We recommend in section 4.12.6 that
Annova provide a final fire protection evaluation for review and approval, and to provide more
information on the final design, installation, and commissioning of spill containment, hazard
detection, hazard control, firewater systems, structural fire protection, and onsite and offsite
emergency response procedures.
Spill Containment
In the event of a release, sloped areas at the base of storage and process facilities would
direct a spill away from equipment and into the impoundment system. This arrangement would
minimize the dispersion of flammable vapors into confined, occupied, or public areas and
minimize the potential for heat from a fire to impact adjacent equipment, occupied buildings, or
public areas if ignition were to occur.
Title 49 CFR 193.2181, under Subpart C specifies that each impounding system serving an
LNG storage tank must have a minimum volumetric liquid capacity of 110 percent of the LNG
tank’s maximum design liquid capacity for an impoundment serving a single tank, unless surge is
accounted for in the impoundment design. If authorized, constructed, and operated, LNG facilities
as defined in 49 CFR 193 must comply with the requirements of 49 CFR 193 Subpart C and would
be subject to DOT’s inspection and enforcement programs. Annova proposes two single
containment LNG storage tanks surrounded by dike walls that would serve as the impoundment
system. FERC staff verified that the dike walls would have a liquid capacity of at least 110 percent
of the inner LNG tank’s maximum liquid capacity.
Annova proposes to install curbing, paving, and trenches to direct potential LNG, mixed
refrigerant, or condensate liquid releases in each liquefaction area to either the North Process Area
Impoundment Basin or the East Process Area Impoundment Basin. LNG releases from the
rundown header, on top of each LNG storage tank, or during LNG marine vessel loading
operations would be collected in a trench system and would be routed to the Marine Area
Impoundment Basin. Releases in the refrigerant storage area or from refrigerant delivery trucks
would be collected in curbed areas and directed to the Refrigerant Makeup Impoundment Basin.
This basin capacity would be sized to be greater than the largest refrigerant storage tank. Local
bunds would be provided to contain liquid releases from the amine make-up tank and the
condensate storage tank. In addition, local curbing would be provided around pretreatment
equipment that would direct amine releases to the amine sump pit. Local curbing would also be
provided for the flare knockout drums, inlet gas HP separator, liquid nitrogen storage tanks, Fuel
Gas Scrubber, Condensate Flash Drum, and equipment handling hot oil. These curbed areas would
direct process releases to trenches that drain to either the Heat Medium Impoundment Basin or the
East Process Area Impoundment Basin. The Aqueous Ammonia Tank would be installed within

a concrete sump equipped with a steel plate lid. Each diesel firewater pump would be provided
with a double containment diesel storage tank.
Under NFPA 59A (2001) section 2.2.2.2, the capacity of impounding areas for
vaporization, process, or LNG transfer areas must equal the greatest volume that can be discharged
from any single accidental leakage source during a 10-minute period or during a shorter time
period based upon demonstrable surveillance and shutdown provisions acceptable to the DOT. If
authorized, constructed, and operated, LNG facilities as defined in 49 CFR 193, must comply with
the requirements of 49 CFR 193 Subpart C and would be subject to DOT’s inspection and
enforcement programs. The impoundment system design for the marine facilities would be subject
to the Coast Guard’s 33 CFR 127, which does not specify a spill or duration for impoundment
sizing. However, we evaluate whether all hazardous liquids are provided with spill containment
based on the largest flow capacity from a single pipe for 10 minutes accounting for de-inventory
or the liquid capacity of the largest vessel served, whichever is greater and whether providing spill
containment reduces consequences from a release. In addition, the details on how the spill trench
system would cross roadways would be provided in final design. Therefore, we recommend in
section 4.12.6 that Annova provide additional information on the final design of the impoundment
systems for review and approval.
Annova indicated that all piping, hoses, and equipment that could produce a hazardous
liquid spill would be provided with spill collection and/or spill conveyance systems. Furthermore,
Annova indicates that the stormwater pumps would be automatically operated by level control and
interlocked using low temperature detectors to prevent pumps from operating if LNG is present.
However, Annova’s stormwater removal system would be designed to remove bulk water from
each spill basin and may not ensure complete removal of residual water from each spill basin floor.
Therefore, we recommend in section 4.12.6 that Annova provide spill basin details, for review and
approval, to show that the spill basin floor would slope to a sump pit that would be equipped with
a small water removal pump. In addition, low temperature detectors would not stop the stormwater
removal pumps from operating in the event a warm refrigerant, hot oil, or heavy hydrocarbon
release reaches the Process Area Impoundment Basins. Therefore, we recommend in section
4.12.6 that if applicable, Annova provide additional interlocks to prevent the stormwater removal
pumps from operating if warm refrigerant, heavy hydrocarbon, or hot oil releases reach the Process
Area Impoundment Basins.
Furthermore, stormwater removal pumps would be proposed for the large impoundment
basins and bunded areas described above, however Annova also proposes to install normally-
closed valves on local curbed areas to allow analysis of stormwater prior to routing it to the
drainage channels. Annova is consulting with DOT on the use of normally-closed valves instead
of stormwater removal pumps required in 49 CFR 193 Subpart C. Therefore, we recommend in
section 4.12.6 that Annova provide DOT correspondence accepting the use of normally closed
valves to remove stormwater from curbed areas. If authorized, constructed, and operated, final
compliance with the requirements of 49 CFR 193 Subpart C would be subject to DOT’s inspection
and enforcement programs.
If the Project is authorized, constructed, and operated, Annova would install spill
impoundments in accordance with its design and FERC staff would verify during construction
inspections that the spill containment system including dimensions, slopes of curbing and trenches,

and volumetric capacity matches final design information. In addition, we recommend in section
4.12.6 that Project facilities be subject to regular inspections throughout the life of the facility to
verify that impoundments are being properly maintained.
Spacing and Plant Layout

The spacing of vessels and equipment between each other, from ignition sources, and to
the property line must meet the requirements of 49 CFR 193 Subparts C, D, and E, which
incorporate NFPA 59A (2001). NFPA 59A (2001) includes spacing and plant layout requirements
and further references NFPA 30, NFPA 58, and NFPA 59 for additional spacing and plant layout
requirements. If the LNG facilities as defined in 49 CFR 193 are authorized, constructed, and
operated, Annova must comply with the requirements of 49 CFR 193 and would be subject to
DOT’s inspection and enforcement programs.
In addition, FERC staff evaluated the spacing to determine if there could be cascading
damage and to inform what fire protection measures may be necessary to reduce the risk of
cascading damage. If spacing to mitigate the potential for cascading damage was not practical, we
evaluated whether other mitigation measures were in place and evaluated those systems in further
detail as discussed in subsequent sections in section 4.12.5.5. We evaluated the spacing of
buildings in line with Guidelines for Evaluating Process Plant Buildings for External Explosions
and Fires (AIChE CCPS 1996), API 752, and API 753 which provide guidance on identifying and
evaluating explosion and fire impacts to plant buildings and occupants resulting from events
external to the buildings. In addition, FERC staff evaluated other hazards associated with releases
and whether any damage would likely occur at buildings or would result in cascading damage.
To minimize the risk of cryogenic spills causing structural supports and equipment from
cooling below their minimum design metal temperature, Annova would cold proof structural steel
and pipe racks. In addition, Annova would generally locate cryogenic equipment away from non-
cryogenic process areas and would direct cryogenic releases to remote impoundment basins. In
addition, we recommend in section 4.12.6 that Annova file drawings and specifications for
structural passive protection systems to protect equipment and supports that could be exposed to
cryogenic releases.
To minimize risk for flammable or toxic vapor ingress into buildings and flammable vapors
reaching areas that could result in cascading damage from explosions, Annova would generally
locate buildings away from process areas and would locate fired equipment and ignition sources
away from process areas. Annova provided hazard analysis that shows flammable and toxic vapor
dispersion and 1 psi overpressures from vapor cloud explosions reaching buildings. However, we
note that the hazard analysis used software for some of the vapor dispersion scenarios and
overpressure scenarios that is expected to over-predict vapor dispersion distances and
overpressures and that more refined and accurate modeling may be filed that demonstrates lesser
dispersion distances and overpressures at the buildings. Therefore, we recommend in section
4.12.6 that Annova conduct a technical review of facility, for review and approval, identifying all
combustion/ventilation air intake equipment and the distances to any possible flammable gas or
toxic release; and verify that these areas would be adequately covered by hazard detection devices
that would isolate or shut down any combustion or heating ventilation and air conditioning
equipment whose continued operation could add to or sustain an emergency. We also recommend
in section 4.12.6 that Annova file an analysis, for review and approval, that demonstrates that the

side on overpressures would be less than 1 psi at the buildings or that the buildings would be able
to withstand overpressures from explosions within the terminal.
To minimize overpressures from vapor cloud explosions, we evaluated how flammable

vapors would be prevented from accumulating within confined areas. The LNG storage tanks
would be located away from process equipment and process facilities are relatively unconfined
and uncongested. Annova provided hazard analysis that shows flammable vapor releases could
disperse underneath the elevated LNG storage tanks and 1 psi overpressures from vapor cloud
explosions could reach the LNG storage tanks. However, we note that the hazard analysis used
modeling software for some vapor dispersion and overpressure scenarios that is expected to over-
predict the dispersion and overpressure distances and that more refined modeling software may
demonstrate lesser dispersion distances and overpressures at the LNG storage tanks. Therefore,
we recommend in section 4.12.6 that Annova file an analysis, for review and approval, to
demonstrate that the side on overpressures would be less than 1 psi at the LNG storage tanks or
that the LNG storage tanks would be able to withstand overpressures within the terminal. We also
recommend in section 4.12.6 that Annova file an analysis, for review and approval, to demonstrate
that the flammable vapor dispersion from design spills would be prevented from dispersing
underneath the elevated LNG storage tanks or detail how the LNG storage tanks would be able to
withstand an overpressure due to ignition of the flammable vapors that disperse underneath the
elevated LNG storage tanks.
To minimize the risk of pool fires from causing cascading damage, Annova would locate
spill impoundments such that the radiant heats would have a minimal impact on most areas of the
plant. To mitigate radiant heat impacts, Annova relocated their LNG storage tanks and associated
impoundments such that a pool fire from the LNG storage tank dike would result in less than 4,000
Btu/ft2-hr in most other areas of the plant with the exception of the seawater firewater house which
would have a sprinkler system and would shield the seawater firewater pumps for some time. A
pool fire within one LNG storage tank’s dike would result in high radiant heats at the adjacent
LNG storage tank. Annova proposes to install a remotely operated water deluge system on each
LNG storage tank to protect each LNG storage tank shell from high radiant heats. However, we
note that the seawater firewater house that supplies the water deluge system on each LNG storage
tank would also be within the high radiant heat from tank dike pool fire. Therefore, we recommend
in section 4.12.6 that Annova demonstrate that a LNG dike fire would not fail the seawater
firewater equipment within the time it would take for the fire to burn out. In addition, we
recommend in section 4.12.6 that Annova file the final design of these mitigation measures, for
review and approval, to demonstrate cascading events would be mitigated.
A pool fire in the Marine Area Impoundment Basin would be spaced such that there would
not be radiant heat in excess of 4,000 Btu/ft2-hr on any equipment with the exception of the
seawater firewater house which would have a sprinkler system and would shield the seawater
firewater pumps. Therefore, we recommend in section 4.12.6 that Annova demonstrate that a pool
fire within the Marine Area Impoundment Basin would not fail the seawater firewater equipment
within the time it would take for the pool fire to burn out or alternately relocate the seawater
firewater equipment.
A pool fire within the Heat Medium Impoundment Basin would result in high radiant heats
at the nearby condensate storage tank and surrounding equipment. Annova did not propose any

mitigation for the high radiant heats on the condensate tank. Therefore, we recommend in section
4.12.6 that Annova demonstrate the radiant heat would not result in damage to the condensate tank
and surrounding equipment, relocate the Heat Medium Impoundment Basin, and/or provide
mitigation to prevent cascading damage to the condensate storage tank. Similarly, we recommend
in section 4.12.6 that Annova analyzes fires originating from the amine sump pit and the
condensate storage area berm and as applicable, demonstrate how the resulting radiant heat would
not result in cascading damage to surrounding equipment. In addition, a pool fire within the
Refrigerant Makeup Impoundment Basin would potentially expose the refrigerant makeup vessels
to radiant heats in excess of 4,000 Btu/ft2-hr. To mitigate the potential impact to the refrigerant
make up vessels, Annova would provide thermal insulation on the refrigerant makeup vessels and
would install a firewall between the vessels and the spill basin. In addition, Annova provided
modeling to demonstrate that the firewall would mitigate the radiant heat from causing damage to
the refrigerant makeup vessels.
To minimize the risk of jet fires from causing cascading damage that could exacerbate the
initial hazard, Annova would generally locate flammable and combustible containing piping and
equipment away from buildings and process areas that do not handle flammable and combustible
materials. However, the jet fire distances to 1,600 Btu/ft2-hr from the inlet feed gas piping could
reach the Plant Control Building, Administration Building, and the Maintenance Building. Jet fire
distances to 4,000 Btu/ft2-hr and 4,900 Btu/ft2-hr from piping and equipment could also impact
other components handling or supporting hazardous fluids. Given the radiant heats at the
buildings, they may necessitate shelter in place until the fire is isolated, extinguished, or otherwise
mitigated. Annova has indicated that these buildings would be rated for a two-hour fire. Annova
would also install emergency shutdown systems that would limit the duration of a jet fire event,
depressurization systems that would reduce the pressure in equipment, and would install firewater
systems to cool equipment and structures. We also recommend in section 4.12.6 that Annova file
calculations or test results that demonstrate the effectiveness of the passive protection in areas
where pool or jet fires may result in failure of structural supports.
If the Project is authorized, Annova would finalize the plot plan and we recommend in
section 4.12.6 that Annova provide any changes for review and approval to ensure capacities and
setbacks are maintained. If the facilities are constructed, Annova would install equipment in
accordance with the spacing indicated on the plot plans. In addition, we recommend in section
4.12.6 that Project facilities be subject to periodic inspections during construction to verify
equipment is installed in appropriate locations and the spacing is met in the field to verify
flammable/toxic gas detection equipment and other mitigation is installed in heating, ventilation,
and air condition intakes of buildings at appropriate locations. We also recommend in section
4.12.6 that Project facilities be subject to regular inspections throughout the life of the facilities to
verify that equipment setbacks from other equipment and ignition sources are being maintained
during operations and to continue to verify that flammable/toxic gas detection equipment installed
in building air intakes and other mitigation function as designed and are being maintained and
calibrated.
Ignition Controls
Annova’s plant areas would be designated with an appropriate hazardous electrical
classification and process seals commensurate with the risk of the hazardous fluids being handled

in accordance with NFPA 59A (2001), 70, 497, and API RP 500. If authorized, constructed, and
operated, LNG facilities as defined in 49 CFR 193, must comply with the requirements of 49 CFR
193 and would be subject to DOT’s inspection and enforcement programs, which require
compliance, by incorporation by reference, with NFPA 59A (2001) and NFPA 70 (1999). The
marine facilities must comply with similar electrical area classification requirements of NFPA 59A
(1994) and NFPA 70 (1993), which are incorporated by reference into the Coast Guard regulations
in 33 CFR 127. Depending on the risk level, these areas would either be unclassified or classified
as Class 1 Division 1, or Class 1 Division 2. Electrical equipment located in these classified areas
would be designed such that in the event a flammable vapor is present, the equipment would have
a minimal risk of igniting the vapor. We evaluated Annova’s electrical area classification drawings
to determine whether Annova would meet these electrical area classification requirements and
good engineering practices in NFPA 59A, 70, 497, and API RP 500. FERC staff recognizes that
Annova appears to meet NEPA 59A (1994 and 2001), NFPA 70 (1993 and 1999) and most of
NFPA 497 and API 500, and recommends in section 4.12.6 that Annova provide final electrical
area classification drawings that reflect additional hazardous classification areas where the heat
transfer fluid would be processed above its flash point (e.g., near the heat medium heaters) and at
areas of fuel gas (e.g., backup generators and surrounding equipment), including areas where
equipment could be exposed to flammable gas during a purge cycle of a flammable heater.
If the Project is authorized, Annova would finalize the electrical area classification
drawings and would describe changes made from the FEED design. We recommend in section
4.12.6 that Annova file the final design of the electrical area classification drawings for review and
approval. If facilities are constructed, Annova would install appropriately classed electrical
equipment, and we recommend in section 4.12.6 that project facilities be subject to periodic
inspections during construction for FERC staff to spot check electrical equipment and verify
equipment is installed per classification and are properly bonded or grounded in accordance with
NFPA 70. In addition, we recommend in section 4.12.6 that project facilities be subject to regular
inspections throughout the life of the facility to ensure electrical equipment is maintained
(e.g., bolts on explosion proof equipment properly installed and maintained, panels provided with
purge, etc.), and electrical equipment are appropriately de-energized and locked out and tagged
out when being serviced.
In addition, submerged electric motor pumps and instrumentation must be equipped with
electrical process seals, and instrumentation in accordance with NFPA 59A (2001) and NFPA 70.
Annova committed to meeting NFPA 59A and NFPA 70, but did not provide preliminary
drawings. We recommend in section 4.12.6 that Annova provide, for review and approval, final
design drawings showing process seals installed at the interface between a flammable fluid system
and an electrical conduit or wiring system that meet the requirements of NFPA 59A (2001) and
NFPA 70. In addition, we recommend in section 4.12.6 that Annova file, for review and approval,
details of an air gap or vent equipped with a leak detection device that should continuously monitor
for the presence of a flammable fluid, alarm the hazardous condition, and shut down the
appropriate systems. In addition, we recommend in section 4.12.6 that Project facilities be subject
to regular inspections throughout the life of the facility to ensure electrical process seals for
submerged pumps continue to conform to NFPA 59A and NFPA 70 and that air gaps are being
properly maintained.

Hazard Detection, Emergency Shutdown, and Depressurization Systems

Annova would also install hazard detection systems to detect cryogenic spills, flammable
and toxic vapors, and fires. The hazard detection systems would alarm and notify personnel in the
area and control room to initiate an emergency shutdown, depressurization, or initiate appropriate
procedures, and would meet NFPA 72, ISA Standard 12.13.01, Performance Requirements for
Combustible Gas Detectors, and other recommended and generally accepted good engineering
practices. We note that Annova does not make reference to other ISA 12.13 standards and
recommended practices in their codes and standards list or specifications, such as ISA RP
12.13.02, Recommended Practice for the Installation, Operation and Maintenance of Combustible
Gas Detection Instruments, and ISA TR 12.13.04, Performance Requirements for Open Path
Combustible Gas Detectors, ISA 92.00.01, Performance Requirements for Toxic Gas Detectors,
ISA 92.00.02, Installation, Operation, and Maintenance of Toxic Gas-Detection Instruments,
ISA 92.03.01, Performance Requirements for Ammonia Detection Instruments (25-500 ppm),
ISA 92.03.02, Installation, Operation, and Maintenance of Ammonia Detection Instruments
(25-500 ppm), ISA 92.04.01 Performance Requirements for Instruments Used to Detect Oxygen
Deficient/Oxygen Enriched Atmospheres, and ISA 92.04.02, Installation, Operation, and
Maintenance of Instruments Used to Detect Oxygen Deficient/Oxygen Enriched Atmospheres. We
recommend in section 4.12.6 that Annova provide specifications, for review and approval, of the
final design of fire safety specifications, including hazard detection, hazard control, and firewater
systems to verify it would meet these and other recommended and generally accepted good
engineering practices, or equivalents (e.g., ISA 60079-29-1, ISA 60079-29-2, ISA 12.15.01,
ISA 12.15.02, etc.). However, in response to a data request Annova has committed to meeting
ISA 12.13.04 and provided a certificate of compliance indicating it would meet ISA 12.13.04 for
open path gas detectors and the example manufacturer’s data make reference to ISA 92.00.01 and
EN 60079-29-1 for its toxic and flammable and combustible gas detectors, respectively. We also
recommend in section 4.12.6 that Annova file a list of final hazard detection equipment, including
the selected manufacturer and model that would allow FERC staff to verify whether it would
generally meet these and other recommended and generally accepted good engineering practices,
or equivalents (e.g., ISA 60079-29-1, ISA 60079-29-2, ISA 12.15.01, ISA 12.15.02, etc.).
FERC staff also evaluated the adequacy of the general hazard detection type, location, and
layout to ensure adequate coverage to detect cryogenic spills, flammable and toxic vapors, and
fires near potential release sources or in spill containment systems (i.e., pumps, compressors,
sumps, trenches, flanges, and instrument and valve connections). Annova submitted spill
containment drawings that noted the impoundment systems would have low temperature detection,
but did not illustrate the locations they would be installed or set points and the hazard detection
drawings indicated a few areas where there was a lack of flammable and combustible gas detection
or flame and heat detection. In response to a data request, Annova clarified or committed to
additional flammable and combustible gas detection and flame detection in some of these areas,
but the spacing and layout of the flammable and combustible gas detection and flame and heat
detection systems was not clearly justified. Therefore, we recommend in section 4.12.6 that
Annova file a hazard detection study to evaluate the effectiveness of their flammable and
combustible gas detection, and flame and heat detection systems in accordance with ISA 84.00.07
or equivalent methodologies. This evaluation would need to demonstrate that 90 percent or more
of releases (unignited and ignited) that could result in an offsite or cascading impact would be

detected by two or more detectors and result in isolation and de-inventory within 10 minutes. The
analysis should take into account the set points, voting logic, wind speeds, and wind directions.
In addition, Annova did not propose to install low oxygen detectors in the liquid nitrogen
storage area. Therefore, we recommend in section 4.12.6 that Annova to provide low oxygen
detectors in the liquid nitrogen storage area to notify operators of potential liquid nitrogen releases.
In addition, the battery rooms did not indicate whether hydrogen detectors would be installed.
Given the propensity of hydrogen to ignite and generate damaging overpressures, we recommend
in section 4.12.6 that Annova demonstrate adequate ventilation and detection in the battery rooms
to mitigate hydrogen build up from battery off-gas and to install hydrogen detectors.
FERC staff would have also reviewed the cause and effect matrices to evaluate how various
mitigation systems would be employed after an incident is detected. However, Annova did not
provide the fire and gas system cause and effect matrices that indicate how each detector would
initiate an alarm, shutdown, depressurization, or conduct other action. Therefore, we recommend
in section 4.12.6 that Annova provide, for review and approval, the cause and effect matrices for
process instrumentation, fire and gas detection system, and emergency shutdown system.
Furthermore, we recommend in section 4.12.6 that Annova provide additional information, for
review and approval, on the final design of all hazard detection systems (e.g., manufacturer and
model, elevations, set points, etc.) and hazard detection layout drawings.
If the Project is authorized, constructed, and operated, Annova would install hazard
detectors according to its final specifications and drawings, and we recommend in section 4.12.6
that Project facilities be subject to periodic inspections during construction to verify hazard
detectors and ESD pushbuttons are appropriately installed per approved design and functional
based on cause and effect matrixes prior to introduction of hazardous fluids. In addition, we
recommend in section 4.12.6 that Project facilities be subject to regular inspections throughout the
life of the facility to verify hazard detector coverage and functionality is being maintained and are
not being bypassed without appropriate precautions.
Hazard Control
If ignition of flammable vapors occurred, hazard control devices would be installed to
extinguish or control incipient fires and releases, and would meet NFPA 59A (2001), 10, 12, 17,
and 2001; API 2510A; and other recommended and generally accepted good engineering practices.
We evaluated the adequacy of the number and availability of handheld, wheeled, and fixed fire
extinguishing devices throughout the site based on the FEED. FERC staff also evaluated whether
the spacing of the fire extinguishers would meet NFPA 10 and agent type and capacities meet
NFPA 59A (2009 and later editions). The hazard control plans appeared to meet NFPA 10 travel
distances to nearly all components containing flammable or combustible fluids (Class B) for hand-
held fire extinguishers (30-50 feet) but did not originally indicate any wheeled extinguishers (100
feet) or hand-held fire extinguishers (75 feet) for ordinary combustible (Class A) hazards or
electrical (Class C) hazards. Upon a data request, Annova added wheeled and hand-held
extinguishers for Class C electrical hazards and committed to providing hand-held fire
extinguishers for ordinary combustible (Class A) hazards in all buildings in accordance with NFPA
10 requirements, including placement at each entry/exit. The agent storage capacities for hand-
held (minimum 20 pounds [lb]) and wheeled (minimum 125 lb) also appear to meet NFPA 59A
requirements, but Annova did not yet indicate the agent type (e.g., potassium bicarbonate, sodium

bicarbonate, etc.). In addition, travel distances, installation heights, visibility, flow rate capacities,
and other requirements should be confirmed in final design and in the field where design details,
such as manufacturer, obstructions, and elevations, would be better known. Therefore, we
recommend in section 4.12.6 that Annova files, for review and approval, the final design of these
systems (e.g., manufacturer and model, elevations, flowrate, capacities, etc.) demonstrating they
would meet NFPA 10 and where the final design could change as a result of these details or other
changes in the final design of the Project.
In addition, FERC staff evaluated whether fire protection systems would be installed in gas
turbine enclosures. Annova indicated that depending on enclosure details and vendor proposals,
the fire suppression system may be carbon dioxide in accordance with NFPA 12, water mist in
accordance with NFPA 750, or clean agent in accordance with NFPA 2001. In addition, we
recommend in section 4.12.6 that clean agent systems be installed in all instrumentation buildings
systems in accordance with NFPA 2001. If the Project is authorized, constructed, and operated,
Annova would install hazard control equipment, and we recommend in section 4.12.6 that Project
facilities be subject to periodic inspections during construction to verify hazard control equipment
is installed in the field and functional prior to introduction of hazardous fluids. In addition, we
recommend in section 4.12.6 that Project facilities be subject to regular inspections throughout the
life of the facility to verify in the field that hazard control coverage and is being properly
maintained and inspected.
Passive Cryogenic and Fire Protection

If cryogenic releases or fires could not be mitigated from impacting facility components to
insignificant levels, passive protection (e.g., fireproofing structural steel, cryogenic protection,
etc.) should be provided to prevent failure of structural supports of equipment and pipe racks. The
structural fire protection would comply with NFPA 59A (2001), API 2218, and other
recommended and generally accepted good engineering practices. NFPA 59A (2001) section 6.4.1
requires pipe supports, including any insulation systems used to support pipe whose stability is
essential to plant safety, to be resistant to or protected against fire exposure, escaping cold liquid,
or both, if they are subject to such exposure. However, NFPA 59A (2001) does not provide the
criteria for determining if they are subject to such exposure or the level of protection needed to
protect the pipe supports against such exposures. In addition, NFPA 59A (2001) does not address
cryogenic or structural protection of pressure vessels or other equipment.
Therefore, FERC staff evaluated whether passive cryogenic and fire protection would be
applied to pressure vessels and structural supports to facilities that could be exposed to cryogenic
liquids or to radiant heats of 4,000 Btu/ft2-hr or greater from fires with durations that could result
in failures 25 and that they are specified in accordance with recommended and generally accepted
good engineering practices, such as ISO 20088, API 2001, API 2010A, API 2218, ASCE/SFPE
29, ASTM E 84, ASTM E 2226, IEEE 1202, ISO 22899, NACE 0198, NFPA 58, NFPA 255,
NFPA 290, OTI 95 634, UL 723, UL 1709, and/or UL 2080, with a cryogenic temperature and
duration and fire protection rating commensurate to the exposure.
25
Pool fires from impoundments are generally mitigated through use of emergency shutdowns, depressurization
systems, structural fire protection, and firewater, while jet fires are primarily mitigated through the use of emergency
shutdowns, depressurization systems, and firewater with or without structural fire protection.

To minimize the risk of cryogenic spills causing structural supports and equipment from
cooling below their minimum design metal temperature, Annova would have spill containment
systems surrounding cryogenic equipment and would generally locate cryogenic equipment away
from process areas that do not handle cryogenic materials. In addition, Annova indicated they
would cold proof structural steel and pipe racks or use concrete sleepers that would withstand
cryogenic temperatures. However, no other information or drawings were provided on the
proposed system. Therefore, we recommend in section 4.12.6 that Annova file drawings and
specifications for the cryogenic structural protection and calculations or test results that
demonstrate the effectiveness of the cryogenic structural protection.
Jet fire distances to 1,600 Btu/ft2-hr from the inlet feed gas piping could reach the Plant
Control Building, Administration Building, and the Maintenance Building. Jet fire distances to
4,000 Btu/ft2-hr and 4,900 Btu/ft2-hr from piping and equipment could also impact other
components handling or supporting hazardous fluids. Annova proposes passive thermal radiation
mitigation measures to prevent cascading events in the design, including thermal protection
insulation of pressure vessels and fire proofing of structural steel columns supporting critical
equipment. We recommend in section 4.12.6 that Annova file drawings and specifications of the
passive structural fire protection for review and approval for structural supports and equipment
that could result in a failure when exposed to a pool or jet fire. We also recommend in section
4.12.6 that Annova file a detailed quantitative analysis to demonstrate that adequate mitigation
would be provided for each significant component within the 4,000 Btu/ft2-hr zone from pool or
jet fires that could cause failure of the component (including fires in the amine sump pit and
condensate storage tank berm). Trucks at the truck loading/unloading areas should be included in
the analysis. A combination of passive and active protection for pool fires and passive and/or
active protection for jet fires should be provided and demonstrate the effectiveness and reliability.
Effectiveness of passive mitigation should be supported by calculations for the thickness limiting
temperature rise and active mitigation should be justified with calculations demonstrating flow
rates and durations of any cooling water would mitigate the heat absorbed by the vessel. In
addition, we recommend in section 4.12.6 that Annova file the final design of these mitigation
measures, for review and approval, to demonstrate cascading events would be mitigated.
In addition, Annova would install a firewall between the refrigerant storage tanks and the
Refrigerant Makeup Impoundment Basin to prevent cascading damage (i.e., BLEVEs) by
protecting the refrigerant storage tanks from excessive radiant heat. In addition, Annova provided
modeling to demonstrate that the firewall would mitigate the radiant heat from causing damage to
the refrigerant makeup vessels. We also note that Annova has not finalized whether certain
electrical transformers would require firewalls. Therefore, we recommend in section 4.12.6 that
Annova separate or provide firewalls for electrical transformers in accordance with NFPA 850 or
equivalent that would prevent cascading damage.
If the Project is authorized, constructed, and operated, Annova would install structural
cryogenic and fire protection according to its design, and we recommend in section 4.12.6 that
Project facilities be subject to periodic inspections during construction to verify structural
cryogenic and fire protection is properly installed in the field as designed prior to introduction of
hazardous fluids. In addition, we recommend in section 4.12.6 that Project facilities be subject to
regular inspections throughout the life of the facility to continue to verify that passive protection
is being properly maintained.

Firewater Systems
Annova would also provide firewater systems, including remotely operated firewater
monitors, sprinkler systems, fixed water spray systems, and firewater hydrants and hoses for use
during an emergency to cool the surface of storage vessels, piping, and equipment exposed to heat
from a fire. These firewater systems would be designed, tested, and maintained to meet NFPA
59A (2001), 13, 14, 15, 20, 22, 24, 25, and 750 requirements. FERC staff evaluated the adequacy
of the general firewater and foam system coverage and verified the appropriateness of the
associated firewater demands of those systems and worst-case fire scenarios to size the firewater
and foam pumps. Annova provided firewater coverage drawings for the firewater monitors,
hydrants, and deluge systems throughout the plant that seemed to adequately cover facilities
handling flammable and combustible materials. In addition, Annova provided firewater demand
calculations based on the most demanding scenario and a hose allowance of 1,000 gallons per
minute (gpm) in accordance with NFPA 59A. The scenarios were largely based on water spray
system design densities and surface areas, including deluge water coverage on each LNG storage
tank roof and wall portions facing the adjacent LNG storage tank to address radiant heat from an
adjacent LNG storage tank dike fire. While the minimum capacities and pressures were provided
for the hydrants and monitors, Annova did not demonstrate the hydrants or monitors capacities
and pressures are sufficient to reach and provide sufficient flow to cool the exposed equipment.
Therefore, we recommend in section 4.12.6 that Annova provide final specifications of the system
that demonstrate the firewater monitors and hydrants provide sufficient firewater to reach and cool
exposed equipment based on the throw distance, design density, and surface areas that are needed
to be cooled. In addition, the firewater design should account for obstructions such as pipe racks,
tanks, vessels, or equipment that could obstruct firewater coverage.
Annova also indicated that the turbine enclosures may be provided with a water mist
system in accordance with NFPA 750. Annova would also install high expansion foam systems
to reduce vaporization rates from LNG pools and would meet NFPA 59A (2001) and 11.
FERC staff also assessed whether the reliability of the firewater pumps and firewater
source are appropriate. Firewater would be supplied from the channel or fresh water tank through
multiple firewater pumps, including both diesel and electric. The channel would supply firewater
for the tank deluge system and act as a backup to the fresh water tank, which would not be able to
supply the tank deluge system. Annova indicates in its codes and standards list and in its fire
protection evaluation report that it would meet NFPA 22. However, the fresh water data sheet
used for firewater supply denotes the tank would be designed to API 650, and does not make
reference to NFPA 22. Therefore, we recommend in section 4.12.6 that Annova design the
firewater tank in accordance with NFPA 22 or justify how API 650 provides an equivalent or better
level of safety.
We recommend in section 4.12.6 that Annova file additional information on the final
design of these systems, for review and approval, where details are yet to be determined
(e.g., manufacturer and model, nozzle types, etc.) and where the final design could change as a
result of these details or other changes in the final design of the Project.
If the Project is authorized, constructed, and operated, Annova would install the firewater
and foam systems based on the final specifications and drawings, and we recommend in section
4.12.6 that Project facilities be subject to periodic inspections during construction and that

companies provide results of commissioning tests to verify the firewater and foam systems are
installed and functional as designed prior to introduction of hazardous fluids. We also recommend
in section 4.12.6 that Annova equip the firewater flow test meter with a flow transmitter and a
pressure transmitter that connect to the distributed control system (DCS) and are recorded to keep
a history of flow test data. We also recommend in section 4.12.6 that the largest firewater pump
or component be able to be removed for maintenance from each firewater pump building. In
addition, we recommend in section 4.12.6 that Project facilities be subject to regular inspections
throughout the life of the facility to ensure firewater and foam systems are being properly
maintained and tested.
4.12.5.6 Geotechnical and Structural Design

Annova provided geotechnical and structural design information for its facilities to
demonstrate the site preparation and foundation designs would be appropriate for the underlying
soil characteristics and to ensure the structural design of the Project facilities would be in
accordance with federal regulations, standards, and recommended and generally accepted good
engineering practices. The application focuses on the resilience of the Project facilities against
natural hazards, including extreme geological, meteorological, and hydrological events, such as
earthquakes, tsunamis, seiche, hurricanes, tornadoes, floods, rain, ice, snow, regional subsidence,
sea level rise, landslides, wildfires, volcanic activity, and geomagnetism.
Geotechnical Evaluation
FERC regulations under 18 CFR 380.12 (h) (3) require geotechnical investigations to be
provided. In addition, FERC regulations under 18 CFR 380.12 (o) (14) require an applicant to
demonstrate compliance with regulations under 49 CFR 193 and NFPA 59A (2001). If authorized,
constructed, and operated, LNG facilities as defined in 49 CFR 193, must comply with the
requirements of 49 CFR 193 and would be subject to DOT’s inspection and enforcement programs.
DOT regulations incorporate by reference NFPA 59A (2001). NFPA 59A (2001), section 2.1.4
requires soil and general investigations of the site to determine the design basis for the facility.
However, no additional requirements are set forth in 49 CFR 193 or NFPA 59A on minimum
requirements for evaluating existing soil site conditions or evaluating the adequacy of the
foundations, therefore FERC staff evaluated the existing site conditions, geotechnical report, and
proposed foundations to ensure they are adequate for the LNG facilities as described below.
The Project would be located in the West Gulf section of the Coastal Plain physiographic
province (USGS 2000). The Coastal Plain lies along the Atlantic seaboard and Gulf Coast of the
U.S., stretching 100 to 200 miles inland and 100 to 200 miles offshore, to the edge of the
continental shelf. This belt of Late Cretaceous to Holocene sedimentary rocks comprises an
elevated sea bottom with low topographic relief dipping seaward. In Texas, the Coastal Plain
includes a system of alternating synclines (troughs) and anticlines (peaks) oriented perpendicular
to the coastline (Hosman 1996). The surficial geology underlying the region is composed of
Quaternary Holocene and Pleistocene-aged sediments made of alluvium of the Rio Grande and
coastal deposits of dune, estuary, lagoon, deltaic, tidal-flat, beach, and barrier island environments
(Page et al. 2005).
Annova contracted Black and Veatch to conduct geotechnical investigations to evaluate

the existing soil site conditions and proposed foundation design for the Project. The existing site

elevation ranges from +5 feet to +25 feet North American Vertical Datum 1988 (NAVD 88). The
site would be cleared, grubbed, and prepared using standard earthmoving and compaction
equipment. Site preparation would result in a final grade elevations of +6 feet NAVD 88 for the
LNG tank area, 36 feet above sea level (ASL) for the crest of the LNG tank earthen berms, +16.5
feet NAVD 88 for the process area, and +10 feet NAVD 88 for the marine terminal area. The
offshore berth area would be dredged to as deep as 45 feet below the mean lower low water
(MLLW) level along the Brownsville Ship Channel. All site elevations were determined to protect
critical facilities from storm surge as discussed in more detail later in this section. There is no
planned fill export (with the exception of dredge material) or import from the overall project site;
thus, any fill material required is planned to be obtained by the use of on-site borrow pits. The
onsite fill would be tested using ASTM D1557 to determine the moisture contents of any on-site
fill. Annova would, as necessary, either dry onsite fill or mix with lime or other material to ensure
the fill meets compact requirements.
Black and Veatch conducted a subsurface investigation in two phases. The Phase I
investigation was based on a proposed site arrangement that was subsequently revised. The Phase
II supplemental investigation was based on a revised site arrangement that relocated the
liquefaction trains and LNG tanks to areas which had little investigation during Phase I. In total
between both phases, Black and Veatch conducted 31 soil borings to depths ranging from 38 feet
to 200 feet below existing grade, 36 cone penetration tests (CPTs) to depths ranging from 10 feet
to 119 feet (or to refusal) below existing grade, and 4 seismic cone penetration tests (SCPTs) to
depths ranging from 90 feet to 100 feet below existing grade. Over 15 different tests were
conducted on over 200 recovered soil samples, including soil identification and classification tests
(water content, Atterberg liquid and plastic limits, sieve tests), strength and compressibility tests
(consolidation tests and triaxial shear tests), swell tests, corrosion potential tests (pH, sulfate,
chloride), CPTs, SCPTs, vane shear tests, pressure modulus tests, and dynamic cone penetrometer
tests in general accordance with pertinent ASTM standards.
FERC staff evaluated the geotechnical investigation to ensure the adequacy in the number,
coverage, and types of the geotechnical borings, CPTs, SCPTs, and other tests and found the
number borings at the new LNG tank locations to be limited. However in response to a draft EIS
recommendation, Annova provided a plan to conduct a more extensive geotechnical field
investigation, specifically beneath proposed LNG tank foundations and associated facilities (i.e.,
pipe racks). FERC staff will continue its review of the results of these additional geotechnical
investigations to ensure foundation designs are appropriate prior to construction of final design.
Based on the test borings conducted, the site is composed of approximately 0 to between
20 and 50 feet of surficial soil consisting of high to low plasticity clay, sand from 40 to 60 feet
below ground surface, clay from 60 feet to 150 feet below ground surface, and dense sand below
150 feet below the ground surface. Corrosion tests indicate there is a high potential for corrosion
of steel based on chloride ion concentration and a moderate deterioration potential of concrete
based on sulfate ion concentrations. Based on these results, Annova has considered potential for
corrosion and concrete degradation in the design.
Based on the subsurface conditions, shallow foundations would be suitable for some lightly
loaded structures; however, for heavier structures in areas with these types of soil conditions, the
LNG storage tanks, liquefaction trains, and many associated structures would require deep

foundations. Therefore, Annova is proposing to use driven precast concrete piles for facilities
including, but not limited to: LNG storage tanks, liquefaction trains, gas conditioning units,
heavies handling system, BOG compressors, pipe racks, heat medium fired heaters, and switchyard
structures. Additionally, Annova is proposing to use steel pipe drive piles for the marine areas.
Piles are proposed to be embedded between 30 and 85 feet below grade, depending on the
equipment being supported, pile spacing, pile type, and pile diameter.
Subsidence is the sudden sinking or gradual downward settling of land with little or no
horizontal motion, caused by movements on surface faults or by subsurface mining or pumping of
oil, natural gas, or ground water. The results of Annova’s geotechnical investigation at the
proposed project site indicate that subsurface conditions are generally suitable for the proposed
facilities, if adequate site preparation, foundation design, and construction methods are
implemented. Annova would monitor foundations and other critical facilities to ensure they are
maintained within acceptable limits. Site preparation activities would be monitored to ensure
adherence to the geotechnical design. Surface subsidence would be controlled by potential use of
lime stabilization of the fill materials during placement, if required, and compaction with
monitoring settlement and systematic reworking, as needed. Foundations would be constructed
with pile supports to protect equipment and interconnecting piping from differential movement.
LNG tank earthen containment embankments would be earth-supported and constricted with wide
bases with a slope ratio of 3 horizontal distance to 1 vertical distance (3H:1V) to ensure stability.
Earth-supported elements, such as plant roads, would require periodic maintenance to mitigate the
long-term effects of settlements and differential movements. Because site-specific geotechnical
mitigation has been incorporated into the Project (e.g., pile-supported foundations) in accordance
with NFPA 59A (2001) and where applicable, NFPA 59A (2006), subsidence would not be a
significant hazard to the proposed facilities.
Dredging of approximately 5.3 million cubic yards would occur to create the marine berth
area to achieve the proposed final grade of -45 feet MLLW. The existing shoreline of the BSC
would be excavated, dredged, and sloped during construction. To prevent slumping of the dredged
slope, maintain the berthing line position, and provide structural integrity support to the landside
facilities, the excavated shoreline would be reinforced with rip-rap armoring. The proposed rip-
rap armoring would minimize the potential for erosion where the shoreline would be excavated.
The results of Annova’s geotechnical investigation at the Project site indicate that
subsurface conditions are suitable for the proposed facilities, if proposed site preparation,
foundation design, and construction methods are implemented in addition to the satisfaction of
proposed recommendations.
Structural and Natural Hazard Evaluation

FERC regulations under 18 CFR 380.12 (m) requires that applicants address the potential
hazard to the public from failure of facility components resulting from accidents or natural
catastrophes, evaluate how these events would affect reliability, and describe the design features
and procedures that would be used to reduce potential hazards. In addition, 18 CFR 380.12 (o)
(14) require an applicant to demonstrate how they would comply with 49 CFR 193 and NFPA
59A. DOT regulations under 49 CFR 193 have some specific requirements on designs to withstand
certain loads from natural hazards and also incorporate by reference NFPA 59A (2001 and 2006)
and ASCE 7-05 and ASCE 7-93 via NFPA 59A (2001). NFPA 59A (2001) section 2.1.1 (c) also

requires that Annova consider the plant site location in the design of the Project, with respect to
the proposed facilities being protected, within the limits of practicality, against natural hazards,
such as from the effects of flooding, storm surge, and seismic activities. This is covered in
PHMSA’s LOD on 49 CFR 193 Subpart B. However, the LOD does not cover whether the facility
is designed appropriately against these hazards, which is part of 49 CFR 193 Subpart C. Unlike
other natural hazards, wind loads are covered in 49 CFR 193 Subpart B and are covered in the
LOD. If authorized, constructed, and operated, LNG facilities as defined in 49 CFR 193, must
comply with the requirements of 49 CFR 193 and would be subject to DOT’s inspection and
enforcement programs. The marine facilities would be subject to 33 CFR 127, which requires if
the waterfront facility handling LNG is in a region subject to earthquakes the piers and wharves
must be designed to resist earthquake forces. In addition, Coast Guard regulations under 33 CFR
127 incorporates by reference certain portions of NFPA 59A (1994) and ASCE 7-88 via NFPA
59A (1994). However, Coast Guard regulations do not provide criteria for a region subject to
earthquakes or the earthquake forces the piers and wharves are to withstand and NFPA 59A (1994)
section referenced in 33 CFR 127 is for seismic design only and is applicable to stationary LNG
containers, which would not be under 33 CFR 127. Therefore, we evaluated the basis of design
for all facilities for all natural hazards under FERC jurisdiction, including those under DOT and
Coast Guard jurisdiction.
If authorized, the proposed facilities would be constructed to the requirements in the 2009
International Building Code (IBC) and ASCE 7-05. These standards require various structural
loads to be applied to the design of the facilities, including live (i.e., dynamic) loads, dead (i.e.,
static) loads, and environmental loads. FERC staff evaluated the potential of the engineering
design to withstand impacts from natural hazards, such as earthquakes, tsunamis, seiche,
hurricanes, tornadoes, floods, rain, ice, snow, regional subsidence, sea level rise, landslides,
wildfires, volcanic activity, and geomagnetism. We recommend in section 4.12.6 that Annova file
final design information (e.g., drawings, specifications, and calculations) and associated quality
assurance and quality control procedures with the documents reviewed, approved, and stamped
and sealed by a professional engineer of record.
If a project is authorized, constructed, and operated, the company would install equipment
in accordance with its final design. In addition, we recommend in section 4.12.6 that Annova file,
for review and approval, settlement results during hydrostatic tests of the LNG storage containers
and periodically thereafter to verify settlement is as expected and does not exceed the applicable
criteria in API 620, API 625, and API 653.
Earthquakes, Tsunamis, and Seiche

FERC regulations under 18 CFR 380.12 (h) (5) require evaluation of earthquake hazards
based on whether there is potential seismicity, surface faulting, or liquefaction. Earthquakes and
tsunamis have the potential to cause damage from shaking ground motion and fault ruptures.
Earthquakes and tsunamis often result from sudden slips along fractures in the earth’s crust (i.e.,
faults) and the resultant ground motions caused by those movements, but can also be a result of
volcanic activity or other causes of vibration in the earth’s crust. The damage that could occur as
a result of ground motions is affected by the type/direction and severity of the fault activity and
the distance and type of soils the seismic waves must travel from the hypocenter (or point below
the epicenter where seismic activity occurs). To assess the potential impact from earthquakes and

tsunamis, Annova evaluated historic earthquakes along fault locations and their resultant ground
motions.
The Project is located within the Gulf Coast Basin geologic tectonic province. The
province’s sedimentary strata thickens toward the south, with salt domes and relatively shallow
listric growth faults that runs parallel to the Gulf of Mexico Coastline and extended outside of
Texas. The USGS maintains a database containing information on surface and subsurface faults
and folds in the United States that are believed to be sources of earthquakes greater than 6.0
magnitude occurring during the past 1.6 million years (Quaternary Period). The Annova Project
would not be near such seismographic faults, which are primarily on the West Coast. However, in
the Gulf Coastal Plains, there are several hundred growth faults that are known or suspected to be
active. Most of these growth faults are located within the Houston-Galveston (Texas) area
subsidence bowl, but many others are known to exist from Brownsville, Texas to east of New
Orleans, Louisiana. Evidence of modern activity of these growth faults includes changes in
elevation that can lead to damage to pavement, buildings, and other structures. Despite the
evidence of movement of growth faults, movement within the fault system has been classified as
a general creep as opposed to the breaking of rocks, which is often associated with earthquake
events (Stevenson and McCulloh 2001).
Annova conducted a site-specific seismic risk analysis for the proposed Project involving
field investigations and subsequent data evaluation. Annova’s Seismic Ground Motion Hazard
report includes the examination of growth faults in the region of the Project area. These growth
fault systems have previously been assessed as not being capable of generating significant
earthquakes, and these faults have not previously been considered as seismogenic sources. While
growth faults are not a source of seismic hazard for the Project site, there may be a potential source
of surface deformation. Therefore, we recommend in section 4.12.6 that Annova file design
information that would minimize the impacts of growth fault impact zones in the vicinity of the
LNG Terminal, stamped and sealed by the professional engineer-of-record registered in Texas.
And while the presence of faults can require special consideration, the presence or lack of faults
identified near the site does not define whether earthquake ground motions can impact the site
because ground motions can be felt large distances away from an earthquake hypocenter depending
on number of factors.
To address the potential ground motions at the proposed site, DOT regulations in 49 CFR
193.2101, under Subpart C require that field-fabricated LNG tanks must comply with section 7.2.2
of NFPA 59A (2006) for seismic design. NFPA 59A (2006) requires LNG storage tanks be
designed to continue safely operating with earthquake ground motions at the ground surface at the
site that have a 10 percent probability of being exceeded in 50 years (475-year mean return
interval), termed the operating basis earthquake (OBE). In addition, DOT regulations in 49 CFR
193.2101, under Subpart C require that LNG storage tanks be designed to have the ability to safely
shutdown when subjected to earthquake ground motions at the ground surface at the site that have
a 2 percent probability of being exceeded in 50 years (2,475-year mean return interval), termed the
safe shutdown earthquake (SSE). DOT regulations in 49 CFR 193.2101, under Subpart C also
incorporate by reference NFPA 59A (2001) Chapter 6, which require piping systems conveying
flammable liquids and flammable gases with service temperatures below -20 degrees Fahrenheit,
be designed as required for seismic ground motions. If authorized, constructed, and operated, the

proposed LNG facilities as defined in 49 CFR 193, would be subject to the DOT’s inspection and
enforcement programs.
In addition, FERC staff recognizes Annova would also need to address hazardous fluid
piping with service temperatures at -20 degrees Fahrenheit and higher and equipment other than
piping and LNG storage (shop-built and field fabricated) containers. We also recognize the current
FERC regulations under 18 CFR 380.12 (h) (5) continues to incorporate National Bureau of
Standards Information Report (NBSIR) 84-2833. NBSIR 84-2833 provides guidance on
classifying stationary storage containers and related safety equipment as Category I and classifying
the remainder of the LNG project structures, systems, and components as either Category II or
Category III, but does not provide specific guidance for the seismic design requirements for them.
Absent any other regulatory requirements, this guidance recommends that other LNG project
structures classified as Seismic Category II or Category III be seismically designed to satisfy the
Design Earthquake (DE) and seismic requirements of the ASCE 7-05 in order to demonstrate there
is not a significant impact on public safety. ASCE 7-05 is recommended as it is a complete
American National Standards Institute (ANSI) consensus design standard, its seismic requirements
are based directly on the National Earthquake Hazards Reduction Program (NEHRP)
Recommended Provisions, and it is referenced directly by the IBC. Having a link directly to the
IBC and ASCE 7 is important to accommodate seals by the engineer of record because the IBC is
directly linked to state professional licensing laws while the NEHRP Recommended Provisions
are not.
The geotechnical investigation of the proposed site indicates the site is classified as Site
Class D 26 based on a site average shear wave velocity that ranged between 650 and 668 feet per
second (Black and Veatch 2016a) in the upper 100 feet of strata. This is in accordance with
ASCE 7-05, which is incorporated directly into 49 CFR 193 for shop fabricated containers less
than 70,000 gallons and via NFPA 59A (2006) for field fabricated containers. This is also in
accordance with IBC (2006). Sites with soil conditions of this type could experience significant
amplifications of surface earthquake ground motions. However, due to the absence of a major
fault in proximity to the site and lower ground motions, the seismic risk to the site is considered
low.
Black and Veatch performed a site-specific seismic hazard study for the site. The study
concluded that the site would have an OBE peak ground acceleration (PGA) of 0.01 g, a SSE PGA
of 0.044 g, a DE 0.2-second design spectral acceleration (SDS) of 0.065 g, a DE 1.0-second design
spectral acceleration (SD1) of 0.039 g and a DE PGA of 0.029 g (Black and Veatch 2016c). FERC
staff independently evaluated the OBE PGA, SSE PGA, SDS, and SD1 values for the site using the
USGS Earthquake Hazards Program Seismic Design Maps 27 and Unified Hazard 28 tools for all
26
There are six different site classes in ASCE 7-05, A through F, that are representative of different soil conditions
that impact the ground motions and potential hazard ranging from Hard Rock (Site Class A), Rock (Site Class B),
Very dense soil and soft rock (Site Class C), Stiff Soil (Site Class D), Soft Clay Soil (Site Class E), to soils vulnerable
to potential failure or collapse, such as liquefiable soils, quick and highly sensitive clays, and collapsible weakly
cemented soils (Site Class F).
27
USGS, Changes to U.S. Seismic Design Maps Web Tools, https://earthquake.usgs.gov/designmaps/us/
application.php, accessed October 2018.
28
USGS, Unified Hazards Tool, https://earthquake.usgs.gov/hazards/interactive/, accessed October 2018.

occupancy categories (I through IV). We determined that the SSE PGA, OBE PGA, and 5-percent
damped spectral design accelerations (SDS and SD1) used by Annova are acceptable. These ground
motions are relatively low compared to other locations in the United States.
ASCE 7-05 also requires determination of the Seismic Design Category based on the
Occupancy Category (or Risk Category in ASCE7-10 and 7-16) and severity of the earthquake
design motion. The Occupancy Category (or Risk Category) is based on the importance of the
facility and the risk it poses to the public.29 FERC staff has identified the project as a Seismic
Design Category A based on the ground motions for the site for all Occupancy Categories (or Risk
Categories), I through IV, consistent with the IBC (2009) and ASCE 7-05 (and ASCE 7-10).
Seismic events can also result in soil liquefaction in which saturated, non-cohesive soils
temporarily lose their strength/cohesion and liquefy (i.e., behave like viscous liquid) as a result of
increased pore pressure and reduced effective stress when subjected to dynamic forces such as
intense and prolonged ground shaking. Areas susceptible to liquefaction may include saturated
soils that are generally sandy or silty. Typically, these soils are located along rivers, streams, lakes,
and shorelines or in areas with shallow groundwater. The site-specific geotechnical investigations
indicate the presence of layers of silty sands and sandy silts that are dense to very dense. These
sand layers could be liquefiable under sufficiently strong ground motions. However, due to the
low seismicity of the region, the potential for soil liquefaction to occur is low. In addition, Project
facilities would be constructed on deep foundations and would be less susceptible to the effects of
soil liquefaction soil strength by using piles in the foundation design.
Seismic events in waterbodies can also cause tsunamis or seiches by sudden displacement
of the sea floors in the ocean or standing water. Tsunamis and seiche may also be generated from
volcanic eruptions or landslides. Tsunami wave action can cause extensive damage to coastal
regions and facilities. The Terminal site’s low-lying position would make it potentially vulnerable
were a tsunami to occur. There is little evidence that the northern Gulf of Mexico is prone to
tsunami events, but the occurrence of a tsunami is possible. Two did occur in the Gulf of Mexico
in the early 20th century and had wave heights of 3 feet or less (USGS 2009), which is not
significantly higher than the average breaking wave height of 1.5 feet (Owen, 2008).
Hydrodynamic modeling conducted off the coast of south Texas in 2004 indicated that the
maximum tsunami run-up could be as high as 12 feet above mean sea level. No earthquake
generating faults have been identified that are likely to produce tsunamis, despite recorded seismic
activity in the area.
29
ASCE 7-05 defines Occupancy Categories I, II, III, and IV. Occupancy Category I represents facilities with a low
hazard to human life in even of failure, such as agricultural facilities; Occupancy Category III represents facilities
with a substantial hazard to human life in the event of failure or with a substantial economic impact or disruption of
day to day civilian life in the event of failure, such as buildings where more than 300 people aggregate, daycare
facilities with facilities greater than 150, schools with capacities greater than 250 for elementary and secondary and
greater than 500 for colleges, health care facilities with 50 or more patients, jails and detention facilities, power
generating stations, water treatment facilities, telecommunication centers, hazardous facilities that could impact
public; Occupancy Category IV represents essential facilities, such as hospitals, fire, rescue, and police stations,
emergency shelters, power generating stations and utilities needed in an emergency, aviation control towers, water
storage and pump structures for fire suppression, national defense facilities, and hazardous facilities that could
substantially impact public; and Occupancy Category II represents all other facilities. ASCE 7-10 changed the term
to Risk Categories I, II, III, and IV with some modification.

The potential for tsunamis associated with submarine landslides is more likely a source in
the Gulf of Mexico and remains a focus of government research (USGS 2009). Annova’s Seismic
Ground Motion Hazard Study included a Tsunami Hazard Assessment for the Project area. There
are four main submarine landslide hazard zones in the Gulf of Mexico including the Northwest
Gulf of Mexico, Mississippi Canyon and Fan, the Florida Escarpment, and the Campeche
Escarpment (USGS 2009). Based on modeling and limited historical data, it is estimated that
tsunamis generated from landslides would be significantly less than the hurricane design storm
surge elevations discussed below, so any tsunami hazard has been inherently considered in design.
Hurricanes, Tornadoes, and other Meteorological Events

Hurricanes, tornadoes, and other meteorological events have the potential to cause damage
or failure of facilities due to high winds and floods, including failures from flying or floating
debris. To assess the potential impact from hurricanes, tornadoes, and other meteorological events,
Annova evaluated such events historically. The severity of these events is often determined on the
probability that they occur and are sometimes referred to as the average number years that the
event is expected to re-occur, or in terms of its mean return/recurrence interval.
Because of its location, the Project site would likely be subject to hurricane force winds
during the life of the Project. Annova would design all Project facilities to withstand a 183 mph
3-second gust (150-mph sustained) with the exception of the Administration Building and
Maintenance Building, which would be designed in accordance with the design speed specified in
ASCE 7-05. A 183 mph 3-second gust would convert to a sustained wind speed of 150 mph, using
the Durst Curve in ASCE 7-05 or using a 1.23 gust factor recommended for offshore winds at a
coast line in World Meteorological Organization, Guidelines for Converting between Various
Wind Averaging Periods in Tropical Cyclone Conditions. These wind speeds are equivalent to
approximately 30,500-year mean return interval or 0.16 percent probability of exceedance in a 50-
year period for the site, based on ASCE 7-05 wind speed return period conversions. The 183 mph
3-second gust equates to a strong Category 4 Hurricane using the Saffir-Simpson scale (130-156
mph sustained winds, 166-195 mph 3-second gusts). FERC staff also utilized the ATC hazard
tool, which interpolates site specific wind speed using ASCE’s 3-second gust wind speed, to
evaluate the ASCE 7-05 the 3-second gust wind speed and found it to be 140 mph. Annova must
meet 49 CFR 193.2067, under Subpart B for wind load requirements. In accordance with the
MOU, the DOT evaluated in its LOD whether the Project meets the DOT siting requirements under
Subpart B. If the Project is authorized, constructed, and operated, LNG facilities as defined in 49
CFR 193, would be subject to the DOT’s inspection and enforcement programs. Final
determination of whether the facilities are in compliance with the requirements of 49 CFR 193
Subpart B would be made by the DOT staff.
In addition, as noted in section 6.5.4.3 of ASCE 7-05 (wind speed limitation), tornadoes
were not considered in developing basic wind speed distributions. This leaves a potential gap in
potential impacts from tornadoes. Therefore, FERC staff evaluated the potential for tornadoes.
Appendix C of ASCE 7-05 makes reference to American Nuclear Society 2.3 (1983 edition),
Standard for Estimating Tornado and Extreme Wind Characteristics at Nuclear Power Sites. This
document has since been revised in 2011 and reaffirmed in 2016 and is consistent with
NUREG/CR 4461, Tornado Climatology of the Contiguous U.S., Rev. 2 (NRC 2007). These
documents provide maps of a 100,000-year mean return period for tornadoes using 2 degree

latitude and longitude boxes in the region to estimate a tornado striking within 4,000 feet of an
area. Figures 5-8 and 8-1 from NUREG/CR-4461 indicate a 100,000-year maximum tornado wind
speeds would be approximately 114 mph 3-second gusts for the Project site location. Later editions
of ASCE 7 (ASCE 7-10 and ASCE 7-16) make reference to International Code Council (ICC) 500,
Standard for Design and Construction of Storm Shelters, for 10,000-year tornadoes. However,
the ICC 500 maps were conservatively developed based on tornadoes striking regions and indicate
a 200 mph 3-second gust for a 10,000-year event, which is higher than the 114 mph 3-second gust
in American Nuclear Society 2.3 and NUREG/CR 4461. As a result, we conclude the use of an
equivalent 183 mph 3-second gust, is adequate for the LNG storage tanks and conservative from
a risk standpoint for the other LNG and hazardous facilities. DOT provided a LOD on the Project’s
compliance with 49 CFR 193 Subpart B in regard to wind speed. This determination was provided
to the Commission for consideration in its decision to authorize or deny the Project.
ASCE 7 also recognizes the proposed site would be in a wind-borne debris region. Wind
borne debris has the potential to perforate equipment and the LNG storage tank if not properly
designed to withstand such impacts. The potential impact is dependent on the equivalent projectile
wind speed, characteristics of projectile, and methodology or model used to determine whether
penetration or perforation would occur. However, no criteria are provided in 49 CFR 193 or ASCE
7 for these specific parameters. In order to address the potential impact, we recommend in section
4.12.6 that Annova provide a projectile analysis, for review and approval, to demonstrate that the
LNG tank could withstand wind borne projectiles prior to construction of the final design and, if
the tank cannot withstand a direct impact from a wind-borne missile, that the dikes will provide
sufficient containment for any spilled LNG. The analysis should detail the projectile speeds and
characteristics and method used to determine penetration or perforation depths. FERC staff would
compare the analysis and specified projectiles and speeds to guidance published by the DOE
Ballistics Research Lab or Lee’s Loss Prevention High Pressure Safety Code.
In addition, FERC staff evaluated historical tropical storm, hurricane, and tornado tracks
in the vicinity of the project facilities using data from the Department of Homeland Security (DHS)
Homeland Infrastructure Foundation Level Data (HILFD) and NOAA Historical Hurricane
Tracker. 30,31 Brownsville has had 30 tropical storms or hurricanes hit within 65 nautical miles
since 1900, and Cameron County has been impacted by 10 hurricanes or tropical storms since
1900. The most recent major hurricane was Hurricane Bret, 1999, just north of Cameron County,
which peaked as a Category 4 hurricane with 144 mph sustained winds and made landfall as a
Category 3 hurricane with 115 mph sustained winds. 32 Prior to Hurricane Bret, Cameron County
was hit by Hurricane Allen (Cat 5 peak, Cat 3 landfall) in 1980, Hurricane Beulah (Cat 5 peak,
Cat 5 landfall) in 1967 and two unnamed hurricanes in 1933 (Cat 5 peak, Cat 3 landfall) and 1916
(Cat 4 peak, Cat 4 landfall). Hurricanes in Cameron County have been observed to have peaked
when reaching landfall with 161 mph sustained winds and to have produced storm surges up to 18
feet. The estimated return period for a major hurricane passing within 50 nautical miles of the
coast of Cameron County is about 30 years (NOAA 2016b).
30
DHS, Homeland Infrastructure Foundation Level Data, https://hifld-geoplatform.opendata.arcgis.com/, August
2018.
31
NOAA, Historical Hurricane Tracker, https://coast.noaa.gov/hurricanes/, August 2018.
32
A major hurricane is defined as a hurricane that has been classified as Hurricane Category 3 or higher.

Potential flood levels may also be informed from the FEMA Flood Insurance Rate Maps,
which identify Special Flood Hazard Areas (base flood) that have a 1 percent probability of
exceedance in 1 year to flood (or a 100-year mean return interval) and moderate flood hazard areas
that have a 0.2 percent probability of exceedance in 1 year to flood (or a 500-year mean return
interval). According to the FEMA National Flood Insurance Rate Maps for Cameron County,
Texas, the Project site would be located in the 100-year floodplain with base flood elevations
ranging between +11 and +14 feet NAVD 88. Note a portion of the channel-side area of the Project
site would not be located within either the 100-year or 500-year floodplain (FEMA 2018a). We
recognize that a 500-year flood event has been recommended as the basis of design for critical
infrastructure in publications, including ASCE 24, Flood Resistant Design and Construction.
Therefore, it is our opinion that it is good practice to design critical energy infrastructure to
withstand a 500-year event from a safety and reliability standpoint for both storm surge stillwater
elevation (SWEL) and wave crests. Furthermore, we determined the use of intermediate values
from NOAA for sea level rise and subsidence is more appropriate for design and higher projections
are more appropriate for planning in accordance with NOAA (2017) 33 which recommends defining
a central estimate or mid-range scenario as baseline for shorter-term planning, such as setting
initial adaptation plans for the next two decades and defining upper bound scenarios as a guide for
long-term adaptation strategies and a general planning envelope.
The Project site would be graded to +16.5 feet NAVD 88 for process equipment, +20 feet
NAVD 88 for the control and administration buildings, +6 feet NAVD 88 for the LNG storage
tanks, and 36 feet ASL crest elevation for the earthen berms surrounding each LNG storage tank.
Annova’s Storm Surge Study determined a 14.0 foot 100-year design storm consisting of 11.4 feet
of SWEL, 0.5 feet of sea level rise, and 2.1 feet of wave effects; similarly, the study determined a
15.4 foot 500-year storm consisting of 14.9 feet of SWEL and 0.5 feet of sea level rise (note the
500-year storm surge determined by Annova does not include wave effects). FERC independently
determined a 500-year storm surge level to compare to the storm surge provided by Annova using
two separate sources, the 2018 FEMA Flood Insurance Study (FIS) for Cameron County, Texas
(FEMA 2018b) and the maximum envelope of water (MEOW) storm surge inundation maps
generated from the Sea, Lake, and Overland Surge from Hurricanes (SLOSH) model developed
by NOAA National Hurricane Center. The FEMA FIS provides various transection lines and
associated 10-, 50-, 100-, and 500-year SWELs, 500-year wave envelopes, and 500-year wave
effects along the length of the transection lines. Transection lines 38 and 46 from the FIS transect
the Project site and have a maximum 500-year wave envelopes (which include SWEL and wave
effects) as high as 19.0 feet on the tank-side of the site transected by Line 46 and as high as 16.0
feet on the channel side of the site transected by Line 38. FERC also evaluated sea level rise using
the NOAA / COE Sea Level Rise Calculator and found the intermediate sea level rise projection
from the period of 2020 through 2050 to be 1.01 feet (NOAA 2017). As a result of FEMA FIS
data and NOAA / COE sea level rise projections, we would expect a berm height or site elevation
of between 17.0 feet NAVD 88 and 20.0 feet NAVD 88, depending on the location in the Project
site.
33
Global and Regional Sea Level Rise Scenarios for the United States. U.S. Department of Commerce. National
Ocean and Atmospheric Administration. National Ocean Service Center for Operational Oceanographic Products and
Services. January 2017.

FERC staff also evaluated the storm surge using MEOW storm surge inundation maps
generated from the SLOSH models developed by NOAA National Hurricane Center, a 500-year
event would equate to a Category 2 Hurricane and from 0 feet to over 9 feet MEOW with most
areas between 0 and 6 feet. 34 This is predominantly lower than indicated in the 500-year FEMA
maps. In addition, while NOAA seems to provide higher resolution of topographic features, it
limits its SLOSH maps to storm surge levels at high tide above 9 feet. As a result, FERC staff
evaluated the storm surge against other sources using SLOSH maps that indicate a similar upper
range of 5 to 6 feet NAVD 88 MEOW for Category 2 Hurricanes, and also indicate 8 to 10 feet
NAVD 88 MEOW for Category 3 Hurricanes, 11 to 14 feet NAVD 88 MEOW for Category 4
Hurricanes, and 15 to 18 feet NAVD 88 MEOW for Category 5 Hurricanes. 35 This data suggests
that Annova’s design could withstand a Category 5 Hurricane storm surge SWEL equivalent to
approximately a 17,000-year mean return interval. In addition, using wave heights of 0.78*SWEL
for controlling waves and 0.49*SWEL for significant wave heights based on FEMA estimates
would result in 4.7 feet controlling wave heights and 3.9 feet significant wave heights along the
Brownsville Ship Channel. We also would expect the sea level rise to be closer to the 1.01 feet
intermediate projection provided by NOAA. As a result of the SLOSH data and NOAA sea level
rise projections, we would expect a berm height or site elevation of at least 10.7 feet along the
Brownsville Ship Channel post-settlement. We recommend in section 4.12.6 that Annova employ
a settlement monitoring program to ensure the site grade is always maintained at a minimum of
16.5 feet NAVD 88 and LNG earthen impoundment berms are maintained at a minimum crest of
36 feet ASL. We also recommend in section 4.12.6 that Annova provide the monitoring and
maintenance plan prior commencement of service. Lastly, we recommend in section 4.12.6 that
Annova file a wave run up analysis to demonstrate that the Project site is protected from a 500-
year event.
The Texas and Louisiana Gulf Coast area is experiencing the highest rates of coastal
erosion and wetland loss in the United States (Ruple 1993). The average coastal erosion rate is -1.2
meters per year between 2000 and 2012 along the Texas coastal shoreline, with South Padre Island
experiencing a shoreline loss rate of -1.6 meters per year between 2000 and 2012 (McKenna 2014).
Shoreline erosion could occur at the Project site and along the opposite shoreline as a result of
waves, currents, and vessel wakes. To prevent erosion, new revetment in the form rip rap would
be installed in the dredged marine berth and maneuvering areas. Even though shoreline erosion is
a concern at the site, the proposed mitigation measures would minimize erosion and scour impacts.
Landslides and Other Natural Hazards

Due to the low relief across the Project site and absence of major seismic activity, there is
little likelihood that landslides or slope movement at the site would be a realistic hazard.
Landslides involve the downslope movement of earth materials under force of gravity due to
natural or human causes. The Project area has low relief which reduces the possibility of
landslides.
34
U.S. Department Of Commerce, National Ocean and Atmospheric Administration, National Hurricane Center,
National Storm Surge Hazard Maps, https://www.nhc.noaa.gov/nationalsurge/, August 2018.
35
Masters, J., Weather Underground, Storm Surge Inundation Maps for the U.S. Coast,
https://www.wunderground.com/hurricane/surge_images.asp, March 2018.

Volcanic activity is primarily a concern along plate boundaries on the West Coast and
Alaska and also Hawaii. Based on FERC staff review of maps from USGS 36 and DHS 37 of the
nearly 1,500 volcanoes with eruptions since the Holocene period (in the past 10,000 years) there
are no known active or historic volcanic activity within approximately several hundred miles of
the site with the closest being approximately 400 miles away across the Gulf of Mexico in Los
Atlixcos, Mexico.
Geomagnetic disturbances (GMDs) may occur due to solar flares or other natural events
with varying frequencies that can cause geomagnetically induced currents, which can disrupt the
operation of transformers and other electrical equipment. USGS provides a map of GMD
intensities with an estimated 100 year mean return interval. 38 The map indicates the Project site
could experience GMD intensities of 100-150 nano-Tesla (nT) with a 100 year mean return
interval. However, Annova would be designed such that if a loss of power were to occur the valves
would move into a fail-safe position. In addition, Annova LNG is an export facility that does not
serve any U.S. customers.
4.12.5.7 External Impacts

To assess the potential impact from external events, FERC staff conducted a series of
reviews to evaluate transportation routes, land use, and activities within the facility and
surrounding the Project site, and the safeguards in place to mitigate the risk from events, where
warranted. FERC staff coordinated the results of the reviews with other federal agencies to assess
potential impacts from vehicles and rail; aircraft impacts to and from nearby airports and heliports;
pipeline impacts from nearby pipelines; impacts to and from adjacent facilities that handle
hazardous materials under EPA’s Risk Management Plan (RMP) regulations and power plants,
including nuclear facilities under Nuclear Regulatory Commission regulations. Specific
mitigation of impacts from use of external roadways, rail, helipads, airstrips, or pipelines are also
considered as part of the engineering review done in conjunction with the NEPA review.
FERC staff uses a risk-based approach to assess the potential impact of the external events
and the adequacy of the mitigation measures. The risk-based approach uses data based on the
frequency of events that could lead to an impact and the potential severity of consequences posed
to the Project site and the resulting consequences to the public beyond the initiating events. The
frequency data is based on past incidents and the consequences are based on past incidents and/or
hazard modeling of potential failures.
Road
FERC staff reviewed whether any truck operations would be associated with the Project
and whether any existing roads would be located near the site. FERC staff uses this information
to evaluate whether the project and any associated truck operations could increase the risk along
the roadways and subsequently to the public and whether any pre-existing unassociated vehicular
36
United States Geological Survey. U.S. Volcanoes and Current Activity Alerts. Available at:
https://volcanoes.usgs.gov/index.html. Accessed August 2018.
37
Department of Homeland Security. Homeland Infrastructure. Foundation-Level data (HIFLD). Natural Hazards.
hifld-geoplatform.opendata.arcgis.com. accessed Aug 2018
38
United States Geological Survey. Magnetic Anomaly Maps and Data for North America. Available at:
https://mrdata.usgs.gov/magnetic/map-us.html#home. Accessed August 2018.

traffic could adversely increase the risk to the Project site and subsequently increase the risk to the
public. In addition, if authorized, constructed, and operated, LNG facilities as defined in 49 CFR
193, must comply with the requirements of 49 CFR 193 and would be subject to DOT’s inspection
and enforcement programs. DOT regulations under 49 CFR 193.2155 (a) (5) (ii), under Subpart C
require that structural members of an impoundment system must be designed and constructed to
prevent impairment of the system’s performance reliability and structural integrity as a result of a
collision by or explosion of a tank truck that could reasonably be expected to cause the most severe
loading if the liquefaction facility adjoins the right-of-way of any highway. Similarly, NFPA 59A
(2001), section 8.5.4, requires transfer piping, pumps, and compressors to be located or protected
by barriers so that they are safe from damage by rail or vehicle movements. However, the DOT
regulations and NFPA 59A (2001) requirements do not indicate what collision(s) or explosion(s)
could reasonably be expected to cause the most severe loading. FERC staff evaluated consequence
and frequency data from these events to evaluate these potential impacts.
FERC staff evaluated the risk of the truck operations based on the consequences from a
release, incident data from the DOT Federal Highway Administration (FHWA) 39, DOT National
Highway Traffic Safety Administration (NHTSA) 40,, DOT PHMSA41, EPA, NOAA 42, and other
reports 43,44,45, and frequency of trucks and proposed mitigation to prevent or reduce the impacts of
a vehicular incident.
Incident data from DOT’s FHWA, NHTSA, and PHMSA, indicates hazardous material
incidents are very infrequent (4e-3 incidents per lane mile per year) and nearly 75 to 80 percent of
hazardous material vehicular incidents occur during unloading and loading operations while the
other 20 to 25 percent occur while in transit or in transit storage. In addition, approximately 99
percent of releases are 1,000 gallons or less and catastrophic events that would spill 10,000 gallons
or more make up less than 0.1 percent of releases. In addition, less than 1 percent of all reportable
hazardous material incidents with spillage result in injuries and less than 0.1 percent of all
reportable hazardous material incidents with spillage result in fatalities.
The EPA and NOAA report that 80 percent of fires that lead to container ruptures results
in projectiles and that 80 percent of projectiles from liquefied petroleum gas (LPG) incidents,
which constitute the largest product involved in BLEVEs, travel less than 660 feet. The EPA also
reports that on average container ruptures would result in less than four projectiles for cylindrical
containers and 8.3 for spherical vessels. FERC staff evaluated other reports that affirmed the EPA
estimates based on data for approximately 150 experimental and accidental PVBs and BLEVEs
39
U.S. DOT FHWA, Office of Highway Policy Information, Highway Statistics 2016,
https://www.fhwa.dot.gov/policyinformation/statistics/2016/, accessed March 2019.
40
U.S. DOT NHTSA, Traffic Safety Facts Annual Report Tables, https://cdan.nhtsa.gov/tsftables/tsfar.htm, accessed
March 2019.
41
U.S. DOT PHMSA, Office of Hazardous Material Safety, Incident Reports Database Search,
https://hazmatonline.phmsa.dot.gov/IncidentReportsSearch/Welcome.aspx, accessed March 2019.
42
U.S. Environmental Protection Agency, National Oceanic and Atmospheric Administration, ALOHA®, User’s
Manual, The CAMEO® Software System, February 2007.
43
Birk, A.M., BLEVE Response and Prevention Technical Documentation, 1995.
44
American Institute of Chemical Engineers, Center for Chemical Process Safety, Guidelines for Vapor Cloud
Explosion, Pressure Vessel Burst, BLEVE, and Flash Fire Hazards, Second Edition, 2010.
45
Lees, F.P, Lees Loss Prevention in the Process Industries, Hazard Identification, Assessment, and Control, Volume
2, Second Edition, 1996.

with approximately 683 total projectiles (4.6 average fragments per incident) that showed
approximately 80 percent of fragments traveled 490 to 820 feet and within 6.25 times the estimated
or observed fireball radius. The data also showed projectiles have traveled up to 3,900 feet for
large LPG vessels and 1,200 feet for LPG rail cars. In all the documented cases, the projectiles
traveled less than 15 times the fireball diameter, but one of the reports indicated up to 30 times the
fireball diameter is possible albeit very rare.
Unmitigated consequences under average ambient conditions from releases of 1,000

gallons through a 1-inch hole would result in distances ranging from 25 to 200 feet for flammable
vapor dispersion, and 75 to 175 feet for jet fires. Unmitigated consequences under worst case
weather conditions from catastrophic failures of trucks proposed at the site generally can range
from 200 to 2,000 feet for flammable vapor dispersion, 275 to 350 feet for radiant heat of 5 kW/m2
from jet fires, 800 to 1,050 feet to a 1 psi overpressure from a BLEVE, 850 to 1,500 feet for a heat
dose equivalent to a radiant heat of 5 kW/m2 over 40 seconds from 250 to 325 feet radii fireballs
burning for 5 to 15 seconds from a BLEVE, and projectiles from BLEVEs possibly extending
farther. Based on distribution function of the projectile distances, FERC staff estimate
approximately 90 percent of all projectiles for a 10,000-gallon tanker truck would be within 0.5
mile and there is approximately a 1 percent probability they would extend beyond 1 mile and less
than 0.1 percent probability they would extend 30 times the fireball diameter. These values are
also close to the distances provided by the FHWA 46 for designating hazardous material trucking
routes (0.5 miles for flammable gases for potential impact distance) and PHMSA 47 for emergency
response (0.5 to 1 mile for initial evacuation and 1 mile for potential BLEVEs for flammable
gases).
During startup and operation of the project, approximately 1300 trucks or tanker trucks
would transport commodities (e.g., refrigerants, diesel, hot oil, liquid nitrogen, condensate product,
etc.) to or from the facility each year. FERC staff did not identify any major highways or roads
within close proximity to piping or equipment containing hazardous materials at the site. For site
access, Annova would install a new, two-lane, 3.5-mile-long road connecting existing state
highway 4 to the facility. The new access road would split to the LNG terminal entrance and to
provide access to the pipeline gas receiving and metering equipment. The roadway leading up to
the terminal entrance would employ precast concrete barriers that would require reduced speed
horizontal turns to mitigate accidental and intentional vehicle impacts. However, Annova did not
provide fencing around the pipeline gas receiving and metering equipment and also did not indicate
how this area would be protected from vehicular impacts. Therefore, we recommend in section
4.12.6 that Annova file fencing details and vehicular barrier specifications, for review and
approval, for the pipeline gas receiving and metering equipment. Also for the LNG terminal site,
we recommend in section 4.12.6 that Annova file specifications and drawings of vehicle barriers
at the access points, for review and approval, to further mitigate accidental and intentional vehicle
impacts.
Therefore, we conclude that the proposed project would not pose a significant risk or
significant increase in risk to the public due to vehicle impacts as a result of the potential
46
U.S. Department of Transportation, Federal Highway Administration, Office of Highway Safety, Guidelines for
Applying Criteria to Designate Routes for Transporting Hazardous Materials, September 1994.
47
U.S. Department of Transportation, Pipeline and Hazardous Materials Safety Administration, Emergency Response
Guidebook, 2016.

consequences, incident data, frequency of trucks, proposed mitigation by Annova and additional
mitigation measures proposed by FERC staff.
Rail
FERC staff reviewed whether any rail operations would be associated with the Project and
whether any existing rail lines would be located near the site. FERC staff uses this information to
evaluate whether the Project and any associated rail operations could increase the risk along the
rail line and subsequently to the public and whether any pre-existing unassociated rail operations
could adversely increase the risk to the Annova site and subsequently increase the risk to the
public. In addition, if authorized, constructed, and operated, LNG facilities as defined in
49 CFR 193, must comply with the requirements of 49 CFR 193 and would be subject to DOT’s
inspection and enforcement programs. DOT regulations under 49 CFR 193.2155 (a) (5) (ii), under
Subpart C state if the LNG facility adjoins the right-of-way of any railroad, the structural members
of an impoundment system must be designed and constructed to prevent impairment of the
system’s performance reliability and structural integrity as a result of a collision by or explosion
of a train or tank car that could reasonably be expected to cause the most severe loading.
Section 8.5.4 of NFPA 59A (2001), incorporated by reference in 49 CFR 193, requires
transfer piping, pumps, and compressors to be located or protected by barriers so that they are safe
from damage by rail or vehicle movements. However, the DOT regulations and NFPA 59A (2001)
requirements do not indicate what collision(s) or explosion(s) could reasonably be expected to
cause the most severe loading. Therefore, FERC staff evaluated consequence and frequency data
from these events to evaluate these potential impacts. There would be no rail transportation
associated with the Project.
FERC staff evaluated the risk of the rail operations based on the consequences from a
release, incident data from the Federal Rail Administration (FRA) and PHMSA, and frequency of
rail operations nearby Annova. Incident data from FRA and PHMSA indicates hazardous material
incidents are very infrequent (6e-3 incidents per rail mile per year). In addition, approximately 95
percent of releases are 1,000 gallons or less and catastrophic events that would spill 30,000 gallons
or more make up less than 1 percent of releases. In addition, less than 1 percent of hazardous
material incidents result in injuries and less than 0.1 percent of hazardous material incidents result
in fatalities.
As previously discussed, the EPA and NOAA report that 80 percent of fires that lead to
container ruptures results in projectiles and that 80 percent of projectiles from liquefied petroleum
gas (LPG) incidents, which constitute the largest product involved in BLEVEs, travel less than
660 feet. The EPA also reports that on average container ruptures would result in less than four
projectiles for cylindrical containers and 8.3 for spherical vessels. FERC staff evaluated other
reports that affirmed the EPA estimates based on data for approximately 150 experimental and
accidental PVBs and BLEVEs with approximately 683 total projectiles (4.6 average fragments per
incident) that showed approximately 80 percent of fragments traveled 490 to 820 feet and within
6.25 times the estimated or observed fireball radius. The data also showed projectiles have traveled
up to 3,900 feet for large LPG vessels and 1,200 feet for LPG rail cars. In all the documented
cases, the projectiles traveled less than 15 times the fireball diameter, but one of the reports
indicated up to 30 times the fireball diameter is possible albeit very rare.

Unmitigated consequences under average ambient conditions from releases of 1,000

gallons through a 1-inch hole would result in much more modest distances ranging from 25 to 200
feet for flammable vapor dispersion, and 75 to175 feet for jet fires. Unmitigated consequences
under worst-case weather conditions from catastrophic failures of rail cars containing various
flammable products generally can range from 300 to 3,000 feet for flammable vapor dispersion,
450 to 575 feet for radiant heat of 5 kW/m2 from jet fires, 1,225 to 1,500 feet to a 1 psi overpressure
from a BLEVE, 1,250 to 2,100 feet for a heat dose equivalent to a radiant heat of 5 kW/m2 over
40 seconds from 350 to 450 feet radii fireballs burning for 7 to 20 seconds from a BLEVE, and
projectiles from BLEVEs possibly extending farther. Based on distribution function of the
projectile distances, FERC staff estimate approximately 80 percent of all projectiles for a 30,000
gallon rail car would be within 0.5 mile and there is approximately a 5 percent probability they
would extend beyond 1 mile and less than 0.1 percent probability they would extend 30 times the
fireball diameter. These values are also close to the distances provided by DOT PHMSA for
emergency response (0.5 to 1 mile for initial evacuation and 1 mile for potential BLEVEs for
flammable gases).
The closest rail line is located approximately 5.3 miles to the west of the Project site. This
would be farther than the consequence distances under worst case weather conditions and events.
Given the distance and position of the closest rail lines relative to the populated areas to the east
of the LNG Terminal, we conclude that the proposed Project would not pose a significant increase
in risk to the public as a result of the proximity of the Project to the rail lines.
Air
FERC staff reviewed whether any aircraft operations would be associated with the Project
and whether any existing aircraft operations would be located near the site. FERC staff uses this
information to evaluate whether the Project and any associated aircraft operations could increase
the risk to the public and whether any pre-existing unassociated aircraft operations could adversely
increase the risk to the Project site and subsequently increase the risk to the public. In addition, if
authorized, constructed, and operated, LNG facilities as defined in 49 CFR 193, must comply with
the requirements of 49 CFR 193 and would be subject to DOT’s inspection and enforcement
programs. DOT regulations under 49 CFR 193.2155 (b), under Subpart C require an LNG storage
tank must not be located within a horizontal distance of one mile from the ends, or 0.25 mile from
the nearest point of a runway, whichever is longer and that the height of LNG structures in the
vicinity of an airport must comply with FAA requirements. In addition, FERC staff evaluated the
risk of an aircraft impact from nearby airports.
Two mixed use aviation airports, Brownsville / South Padre Island International Airport
and Port Isabel – Cameron County Airport, would be located 12.2 miles southwest and 12.3 miles
north-northwest of the proposed Project site, respectively. The four general aviation airports are
the Resaca Airstrip located 10.5 miles west-southwest of the proposed Project site, Drennan Farm
Airport located 13.0 miles northwest of the proposed Project site, Reynolds Ranch Airport located
13.2 miles northwest of the proposed Project Site, and Rancho Buena Vista Airport located 17.2
miles north of the proposed Project site. These are all farther than the 0.25-mile distance
referenced in DOT regulations.
FAA regulations in 14 CFR 77 require Annova to provide a notice to the FAA of its
proposed construction. This notification should identify all equipment that are more than 200 feet

above ground level or lesser heights if the facilities are within 20,000 feet of an airport (at 100:1
ratio or 50:1 ratio depending on length of runway) or within 5,000 feet of a helipad (at 100:1 ratio).
In addition, mobile objects, including the LNG marine vessel that would be above the height of
the highest mobile object that would normally traverse it would require notification to FAA.
Annova proposes to limit heights of permanent structures to 200 feet. On July 26, 2017, Annova
received a FAA Determination of No Hazard to Air Navigation in accordance with 14 CFR 77 for
the temporary construction cranes that would exceed 200 feet in height. Annova would also need
to file a notice to FAA for the LNG marine vessel if it would be higher than other objects that
currently traverse the waterway. Therefore, we recommend in section 4.12.6 that Annova
determines if LNG marine vessels would be above the height of the highest mobile object that
would normally traverse the waterway, and if so for Annova to file a notice to FAA for the LNG
marine vessel.
FERC staff used Department of Energy (DOE) Standard 3014, Accident Analysis for
Aircraft Crash into Hazardous Facilities, which utilizes a 22-mile threshold radius around the
hazardous facility for consideration of hazards posed by airport and heliport operations to the
Project facilities. There are three heliports, two mixed use airports (commercial, military, and
general aviation), and four general aviation airports within the 22-mile radius. Per the DOE
standard 3014, heliports need only be considered if there are local overflights associated with
facility operations and/or area operations; because the Project site does not have facility or area-
associated helicopter flights, and does not have an on-site heliport, the impact risk due to heliport
operations is considered insignificant. The methodology described in DOE Standard 3014 was
employed to assess the risk posed to the operation of the proposed Project facilities by aircraft
departing from or landing at airports within the 22-mile threshold radius and was found to be
insignificant.
Comments from the public and feedback from FAA indicated potential impacts to and from
the Project and the nearby SpaceX launch facility. FERC staff conducted internal analyses,
utilized a third-party contractor, and requested information from the applicant on the likelihood
and consequences from a potential launch failure impacting the Project. In our review of the
Falcon 9 and the Falcon Heavy launch vehicles, we determined while there would be debris above
a threshold of 3e-5 years, which is the failure rate level we evaluate the potential for cascading
damage and the failure rates used by FAA in space launch failures prior to 2017, 48 the cascading
damage at the Project site would not impact the public. In addition, the Coast Guard would
determine any mitigation measures needed on a case by case basis to safeguard public health and
welfare from LNG marine vessel operations during rocket launch activity. However, our review
determined that rocket launch failures could impact onsite construction workers and plant
personnel and did not account for conceptual launch vehicles that may launch from the SpaceX
launch facility such as the Big Falcon Rocket. Therefore in the draft EIS, we recommended in
section 4.12.6 that construction crews be positioned outside of higher risk areas during rocket
launch activity and for plant personnel to monitor the rocket launches and shut down operating
equipment in the event of a rocket launch failure.
48
FAA’s 14 CFR 417.107 (b) regulations were updated from 3e-5 casualties for three different events (in 2016 edition)
to 1e-4 casualties cumulative (in 2017 edition).

However, additional comments received after the draft EIS was issued in similarly situated
locations suggested that the recommendations should be revised to position onsite construction
crews and plant personnel in areas that are unlikely to be impacted by failed rocket launch debris
during initial moments of rocket launch activity from the Brownsville SpaceX facility. The
comments also suggested that the Project’s procedures should reference public guidance from the
FAA prior to launch activity that would more accurately reflect the risk-based assessment
performed by Annova. In addition, the comments state that the FAA will issue public notices in
advance of a rocket launch to provide information about areas likely to be impacted by falling
debris from a failed rocket launch. Finally, the comments contend that since it is the jurisdiction
and role of the FAA to ensure public safety during rocket launches, the FAA's public guidance
prior to a rocket launch would be informative in Annova’s launch-specific assessment of the
positioning of onsite construction crews and plant personnel. We agree that this approach would
mitigate the potential impacts to the construction crews and plant personnel and have modified the
recommendation in section 4.12.6 to reflect the suggested changes.
In addition, in light of comments in similarly situated locations the draft EIS

recommendation pertaining to shutting down operating equipment in the event of a rocket launch
failure has been revised in section 4.12.6 for Annova to develop and implement procedures for
plant personnel to monitor the rocket launches and take mitigative action before and after a rocket
launch failure to minimize the potential of a release reaching offsite or resulting in cascading
effects that could impact the safe operation or extend offsite. To adequately address the risk to
onsite plant personnel, plant equipment, and the public, the revised recommendation would allow
Annova to take action before a rocket launch (e.g., reducing or stopping certain operations) and
after a rocket launch failure (e.g., sheltering in place, shutting down certain operations), to mitigate
the risk of a larger hazardous fluid release.
In addition, the federal government indemnifies, subject to Congressional appropriations,

commercial space licensees from liability for any claims above the liability insurance required
under regulation. The maximum probable loss used to determine the insurance and liability uses
$3 million for each casualty from direct and indirect effects from a failed launch. Since the LNG
facilities would be valued up to approximately $25 billion, conventional LNG marine vessels
would be valued at $200-250 million, and a peak construction workforce would total over 5,000
workers, a potential exists for the federal government to be liable for a large sum of money that
could exceed the current indemnification levels by a large margin. As a result, the Project may
have possible impact to the SpaceX operation due to the insurance premiums that could increase
costs to SpaceX, limit the frequency and types of launches out of the Brownsville SpaceX launch
site. Depending on the reliance of the National Space Program on the Brownsville SpaceX launch
site, this could also have an impact on the National Space Program. There is also potential impact
to the liability of the federal government due to indemnification by the federal government for
losses above 3.1 billion dollars. However, the extent of these impacts would not be fully known
until SpaceX submits an application requesting to launch with the FAA and whether the LNG plant
is under construction or in operation.
Pipelines
FERC staff reviewed whether any pipeline operations would be associated with the Project
and whether any existing pipelines would be located near the site. FERC staff uses this information

to evaluate whether the Project and any associated pipeline operations could increase the risk to
the pipeline facilities and subsequently to the public and whether any pre-existing unassociated
pipeline operations could adversely increase the risk to the Project site and subsequently increase
the risk to the public. In addition, pipelines associated with this project must meet DOT regulations
under 49 CFR 192. If authorized, constructed, and operated, LNG facilities as defined in
49 CFR 193, must comply with the requirements of 49 CFR 192 and 49 CFR 193 and would be
subject to DOT’s inspection and enforcement programs. FERC staff evaluated the risk of a
pipeline incident impacting the Project and the potential of cascading damage increasing the risk
to the public based on the consequences from a release, incident data from PHMSA, and proposed
mitigation to prevent or reduce the impacts of a pipeline incident from Annova.
For existing pipelines, FERC staff identified an abandoned gas gathering pipeline located
0.5 miles on the opposite side of the BSC. The nearest active gas gathering pipeline would also
be on the opposite side of the BSC and would be located approximately 1.5 miles northwest of the
Project site. These pipelines would be inactive or located too far to impact the Project site in the
event of an incident.
In addition, FERC identified Enbridge’s 42-inch diameter non-jurisdictional Valley

Crossing Pipeline that is routed on the opposite side of the Brownsville Ship Channel and would
be located through the proposed Rio Grande LNG Project 49 (RG LNG) site’s 75-feet wide utility
easement. Based on a February 1, 2018 FERC information request on the RG LNG Project, FERC
in consultation with DOT indicated that the Valley Crossing Pipeline would have a Potential
Impact Radius (PIR) of 1,587 feet (based on the pipeline diameter of 42 inches and a maximum
allowable operating pressure of 3,000 pounds per square inch). 50 For Annova, a berthed LNG
marine vessel would be the closest point to the Valley Crossing Pipeline and would be
approximately 4,000 feet away.
In addition, based on the potential likelihood of pipeline incidents and potential

consequences from a pipeline incident, we conclude that the proposed Project would not
significantly increase the risk to the public beyond existing risk levels that would be present from
a pipeline leak or pipeline rupture worst-case event near the Project site. Therefore, we conclude
that the proposed Project would not pose a significant increase in risk to the public as a result of
the proximity of the Project to the Valley Crossing Pipeline.
Hazardous Material Facilities and Power Plants

FERC staff reviewed whether any EPA RMP regulated facilities handling hazardous
materials and power plants were located near the site to evaluate whether the facilities could
adversely increase the risk to the project site and whether the project site could increase the risk to
the EPA RMP facilities and power plants and subsequently increase the risk to the public.
49
On May 5, 2016, Rio Grande LNG, LLC (RG LNG) filed an application with the FERC in Docket Number CP16-
454-000 to construct and operate natural gas pipelines and a liquefaction export terminal along the Brownsville Ship
Channel about 5.5 miles inland from the channel entrance, in Cameron County, Texas.
50
Potential impact radius (PIR) is defined in 49 CFR 192.903 as the radius of a circle on either side of a pipeline
centerline which the potential failure of the pipeline could have significant impact on people or property. PIR is
determined based upon a calculation using the pipeline diameter, maximum allowable operating pressure (MAOP),
and a composition factor for natural gas.

There were no facilities handling hazardous materials or power plants identified adjacent
to the site. The closest EPA RMP regulated facilities handling hazardous materials would be the
Port Isabel Wastewater Treatment Plant located approximately 4.4 miles away, Port Isabel Water
Treatment Plant located approximately 4.5 miles away, and Texas Pack, Inc. located
approximately 4.4 miles away. The closest power plant identified would be Silas Ray Gas Plant
approximately 17 miles away with the closest nuclear plant located over 200 miles NE of the site.
In addition, the proposed Rio Grande LNG Terminal and the Texas LNG Terminal would
be located across the Brownsville Ship Channel. These proposals would be subject to 49 CFR 193
Subpart B regulatory requirements that establishes exclusion zones for safety of plant personnel
and the surrounding public. Each proposal would consider potential incidents and safety measures
that would need to be incorporated in the design or operation to ensure risk to surrounding public
is not increased. Given the distances and locations of the facilities relative to the populated areas
of the Port Isabel, South Padre Island, and Brownsville communities, we conclude that the
proposed Project would not pose a significant increase in risk to the public or that the hazardous
material facilities and power plants would pose a significant risk to the Project and subsequently
to the public.
4.12.5.8 Onsite and Offsite Emergency Response Plans

As part of its application, Annova indicated that the Project would develop a
comprehensive ERP with local, state, and federal agencies and emergency response officials to
discuss the Facilities. Annova would continue these collaborative efforts during the development,
design, and construction of the Project. The emergency procedures would provide for the
protection of personnel and the public as well as the prevention of property damage that may occur
as a result of incidents at the project facilities. The facility would also provide appropriate
personnel protective equipment to enable operations personnel and first responder access to the
area.
As required by 49 CFR 193.2509, under Subpart F, Annova would need to prepare

emergency procedures manuals that provide for: a) responding to controllable emergencies and
recognizing an uncontrollable emergency; b) taking action to minimize harm to the public
including the possible need to evacuate the public; and c) coordination and cooperation with
appropriate local officials. Specifically, 49 CFR 193.2509 (b) (3) requires “Coordinating with
appropriate local officials in preparation of an emergency evacuation plan…,” which sets forth the
steps required to protect the public in the event of an emergency, including catastrophic failure of
an LNG storage tank. DOT regulations under 49 CFR 193.2905, under Subpart J also require at
least two access points in each protective enclosure to be located to minimize the escape distance
in the event of emergency.
Title 33 CFR 127.307 also requires the development of emergency manual that
incorporates additional material, including LNG release response and emergency shutdown
procedures, a description of fire equipment, emergency lighting, and power systems, telephone
contacts, shelters, and first aid procedures. In addition, 33 CFR 127.207 establishes requirements
for warning alarm systems. Specifically, 33 CFR 127.207 (a) requires that the LNG marine
transfer area to be equipped with a rotating or flashing amber light with a minimum effective flash
intensity, in the horizontal plane, of 5000 candelas with at least 50 percent of the required effective
flash intensity in all directions from 1.0 degree above to 1.0 degree below the horizontal plane.

Furthermore, 33 CFR 127.207 (b) requires the marine transfer area for LNG to have a siren with a
minimum 1⁄3 octave band sound pressure level at l meter of 125 decibels referenced to 0.0002
microbars. The siren must be located so that the sound signal produced is audible over 360 degrees
in a horizontal plane. Lastly, 33 CFR 127.207 (c) requires that each light and siren must be located
so that the warning alarm is not obstructed for a distance of 1.6 km (1 mile) in all directions. The
warning alarms would be required to be tested in order to meet 33 CFR 127. Annova would be
required to meet the warning alarms requirements specified in 33 CFR 127.207.
In accordance with the EPAct 2005, FERC must also approve an emergency response plan
(ERP) covering the terminal and ship transit prior to construction. Section 3A (e) of the NGA,
added by Section 311 of the EPAct 2005, stipulates that in any order authorizing an LNG terminal,
the Commission must require the LNG terminal operator to develop an ERP in consultation with
the Coast Guard and state and local agencies. The final ERP would need to be evaluated by
appropriate emergency response personnel and officials. Section 3A (e) of the NGA (as amended
by EPAct 2005) specifies that the ERP must include a Cost-Sharing Plan that contains a description
of any direct cost reimbursements the applicant agrees to provide to any state and local agencies
with responsibility for security and safety at the LNG terminal and in proximity to LNG marine
vessels that serve the facility. The Cost-Sharing Plan must specify what the LNG terminal operator
would provide to cover the cost of the state and local resources required to manage the security of
the LNG terminal and LNG marine vessel, and the state and local resources required for safety and
emergency management, including:
• direct reimbursement for any per-transit security and/or emergency management

costs (for example, overtime for police or fire department personnel);
• capital costs associated with security/emergency management equipment and
personnel base (for example, patrol boats, firefighting equipment); and
• annual costs for providing specialized training for local fire departments, mutual
aid departments, and emergency response personnel; and for conducting exercises.
The cost-sharing plan must include the LNG terminal operator’s letter of commitment with
agency acknowledgement for each state and local agency designated to receive resources.
Annova submitted a draft ERP to address emergency events and potential release scenarios
in the Application. The ERP would include public notification, protection, and evacuation. As
part of FEED, FERC staff evaluate the initial draft of the emergency response procedures to assure
that it covers the hazards associated with the Project. In addition, we recommend in section 4.12.6
that Annova provide additional information, for review and approval, on development of updated
emergency response plans prior to initial site preparation. We also recommend in section 4.12.6
that Annova file three dimensional drawings, for review and approval, that demonstrate there is a
sufficient number of access and egress locations. If this Project is authorized, constructed, and
operated, Annova would coordinate with local, state, and federal agencies on the development of
an emergency response plan and cost sharing plan. We recommend in section 4.12.6 that Annova
provide periodic updates on the development of these plans for review and approval, and ensure
they are in place prior to introduction of hazardous fluids. In addition, we recommend in section
4.12.6 that project facilities be subject to regular inspections throughout the life of the facility and
would continue to require companies to file updates to the ERP.

Recommendations from FERC Preliminary Engineering and Technical Review

Based on FERC staff’s preliminary engineering and technical review of the reliability and
safety of the Annova Project, we recommend the following mitigation measures as conditions to
any order authorizing the Project. These recommendations would be implemented prior to initial
site preparation, prior to construction of final design, prior to commissioning, prior to introduction
of hazardous fluids, prior to commencement of service, and throughout the life of the facility to
enhance the reliability and safety of the facility and to mitigate the risk of impact on the public.
• Prior to initial site preparation, Annova should file with the Secretary
documentation demonstrating LNG marine vessels would be no higher than
existing ship traffic or it has received a determination of no hazard (with or
without conditions) by FAA for mobile objects that exceed the height
requirements in 14 CFR 77.9.
• Prior to initial site preparation, Annova should file with the Secretary for
review and written approval by the Director of OEP, a detailed report that
indicates the elevation of a 500-year storm surge wave run-up and that the
wave run-up would not impact project facilities that are essential for the safety
and operability of the terminal. If the wave run-up is found to reach essential
equipment/structures, Annova should provide mitigation measures to protect
these facilities.
• Prior to construction of final design, Annova should file with the Secretary
consultation with DOT on the use of normally closed valves to remove
stormwater from curbed areas.
• Prior to construction of final design, Annova should file with the Secretary the
following information, stamped and sealed by the professional engineer-of-
record registered in Texas:
a. site preparation drawings and specifications;

b. LNG terminal structures and foundation design drawings and
calculations (including prefabricated and field constructed structures);
c. seismic specifications for procured equipment; and
d. quality control procedures to be used for civil/structural design and
construction.
In addition, Annova should file, in its Implementation Plan, the schedule for
producing this information.
• Prior to construction of final design, Annova should file with the Secretary a
monitoring and maintenance plan, stamped and sealed by the professional
engineer-of-record registered in Texas, to ensure the site is maintained at a
minimum elevation of 16.5 feet NAVD 88 and the crest elevation of the earthen
berm around each LNG storage tank is maintained at a minimum crest of 36

feet above sea level for the life of the facility considering settlement,
subsidence, and sea level rise.
Information pertaining to these specific recommendations should be filed with the

Secretary for review and written approval by the Director of OEP, or the Director’s designee,
within the timeframe indicated by each recommendation. Specific engineering, vulnerability, or
detailed design information meeting the criteria specified in Order No. 833 (Docket No. RM16-
15-000), including security information, should be submitted as critical energy infrastructure
information pursuant to 18 CFR 388.113. See Critical Electric Infrastructure Security and
Amending Critical Energy Infrastructure Information, Order No. 833, 81 Fed. Reg. 93,732
(December 21, 2016), FERC Stats. & Regs. 31,389 (2016). Information pertaining to items such
as offsite emergency response, procedures for public notification and evacuation, and construction
and operating reporting requirements would be subject to public disclosure. All information
should be filed a minimum of 30 days before approval to proceed is requested.
• Prior to initial site preparation, Annova should file an overall Project

schedule, which includes the proposed stages of the commissioning plan.
• Prior to initial site preparation, Annova should file quality assurance and
quality control procedures for both the Engineering Procurement Contractor
and Annova to monitor construction activities.
• Prior to initial site preparation, Annova should file procedures for controlling
access during construction.
• Prior to initial site preparation, Annova should develop and implement

procedures to monitor rocket launch activity and to position onsite
construction crews and plant personnel in areas that are unlikely to be
impacted by rocket debris of a failed launch during initial moments of rocket
launch activity from the Brownsville SpaceX facility. Annova's procedures for
positioning of onsite construction crews and plant personnel should include
reference to any guidance from the FAA to the public regarding anticipated
SpaceX launches.
• Prior to initial site preparation, Annova should conduct and provide results of
a minimum of five equally distributed borings, cone penetration tests, and/or
seismic cone penetration tests to a depth of at least 100 feet or refusal
underneath the revised locations of each LNG storage tank to affirm or better
characterize underlying conditions.
• Prior to initial site preparation, Annova should develop an Emergency

Response Plan (including evacuation) and coordinate procedures with the
Coast Guard; state, county, and local emergency planning groups; fire
departments; state and local law enforcement; and appropriate federal
agencies. This plan should 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 public use areas that are
within any transient hazard areas along the route of the LNG marine
transit;
e. locations of permanent sirens and other warning devices; and
f. an “emergency coordinator” on each LNG marine vessel to activate
sirens and other warning devices.
Annova should notify the FERC staff of all planning meetings in advance and
should report progress on the development of its Emergency Response Plan
at 3‑month intervals.
• Prior to initial site preparation, Annova should file a Cost-Sharing Plan

identifying the mechanisms for funding all Project-specific
security/emergency management costs that would be imposed on state and
local agencies. This comprehensive plan should include funding mechanisms
for the capital costs associated with any necessary security/emergency
management equipment and personnel base. Annova should notify FERC
staff of all planning meetings in advance and should report progress on the
development of its Cost Sharing Plan at 3-month intervals.
• Prior to construction of final design, Annova should file design information

that would minimize the impacts of growth fault impact zones in the vicinity
of the LNG Terminal, stamped and sealed by the professional engineer-of-
record registered in Texas.
• Prior to construction of final design, Annova should file change logs that list
and explain any changes made from the front end engineering design provided
in Annova’s application and filings. A list of all changes with an explanation
for the design alteration should be provided and all changes should be clearly
indicated on all diagrams and drawings.
• Prior to construction of final design, Annova should file information/revisions

pertaining to its response to numbers 4, 5, 6, 10 11, 14, 17, 18, 19, 20, 21, 22,
24, 25, 26, 27, 28, 29, 31, 33, 34, 35, 36, 38, 43, and 49 of the February 14, 2017
data request; numbers 11, 12, 13, 17, 18a, 18e, 19, and 21f of the October 19,
2018 data request, and its response to number 25 filed on February 4, 2019,
which indicated features to be included or considered in the final design.
• Prior to construction of final design, Annova should file a plot plan of the final
design showing all major equipment, structures, buildings, and impoundment
systems.

• Prior to construction of final design, Annova should file three-dimensional

plant drawings to confirm plant layout for maintenance, access, egress, and
congestion.
• Prior to construction of final design, Annova should file an up-to-date

equipment list, process and mechanical data sheets, and specifications. The
specifications should include:
a. building specifications (e.g., control buildings, electrical buildings,

compressor buildings, storage buildings, pressurized buildings,
ventilated buildings, blast resistant buildings);
b. mechanical specifications (e.g., piping, valve, insulation, rotating
equipment, heat exchanger, storage tank and vessel, other specialized
equipment);
c. electrical and instrumentation specifications (e.g., power system,
control system, safety instrument system [SIS], cable, other electrical
and instrumentation); and
d. security and fire safety specifications (e.g., security, passive protection,
hazard detection, hazard control, firewater).
• Prior to construction of final design, Annova should file a list of all codes and
standards and the final specification document number where they are
referenced.
• Prior to construction of final design, Annova should file a complete

specification and drawings of the proposed LNG tank design and installation.
The specification should define the battery limits (i.e., engineering design,
structural design, supports, piping components, piping connections, electrical
power, control, and utilities) of the LNG storage tank.
• Prior to construction of final design, the LNG storage tank specification should
clearly define the roof top load requirements for the LNG pump platform as
well as other laydown areas required for maintenance activities.
• Prior to construction of final design, Annova should file drawings of the

storage tank piping support structure and support of horizontal piping at
grade including pump columns, relief valves, pipe penetrations,
instrumentation, and appurtenances.
• Prior to construction of final design, Annova should file process data sheets
that specify the start-up, operating, and shutdown conditions for the BOG
Compressors.
• Prior to construction of final design, Annova should file up-to-date process

flow diagrams (PFDs) that demonstrate the peak liquefaction rate of 6.95 mtpa
is achievable and piping and instrument diagrams (P&IDs) including vendor

P&IDs. The PFDs should include heat and material balances. The P&IDs
should include the following information:
a. equipment tag number, name, size, duty, capacity, and design

conditions;
b. equipment insulation type and thickness;
c. storage tank pipe penetration size and nozzle schedule;
d. valve high pressure side and internal and external vent locations;
e. piping with line number, piping class specification, size, and insulation
type and thickness;
f. piping specification breaks and insulation limits;
g. all control and manual valves numbered;
h. relief valves with size and set points; and
i. drawing revision number and date.
• Prior to construction of final design, Annova should file P&IDs, specifications,

and procedures that clearly show and specify the tie-in details required to
safely connect subsequently constructed facilities with the operational
facilities.
• Prior to construction of final design, Annova should file a car seal philosophy
and a list of all car-sealed and locked valves consistent with the P&IDs.
• Prior to construction of final design, Annova should file a hazard and

operability review prior to issuing the P&IDs for construction. A copy of the
review, a list of the recommendations, and actions taken on the
recommendations should be filed.
• Prior to construction of final design, Annova should file specifications and

piping and instrumentation diagrams of the Refrigerant Compressor motor
cooling system.
• Prior to construction of final design, Annova should file the safe operating
limits (upper and lower), alarm and shutdown set points for all
instrumentation (i.e., temperature, pressures, flows, and compositions).
• Prior to construction of final design, Annova should file cause-and-effect

matrices for the process instrumentation, fire and gas detection system, and
emergency shutdown system. The cause-and-effect matrices should include
alarms and shutdown functions, details of the voting and shutdown logic, and
set points.
• Prior to construction of final design, Annova should file an evaluation of

emergency shutdown valve closure times. The evaluation should account for

the time to detect an upset or hazardous condition, notify plant personnel, and
close the emergency shutdown valve(s).
• Prior to construction of final design, Annova should file an evaluation of

dynamic pressure surge effects from valve opening and closure times and
pump startup and shutdown operations.
• Prior to construction of final design, Annova should demonstrate that, for

hazardous fluids, piping and piping nipples 2 inches or less in diameter are
designed to withstand external loads, including vibrational loads in the vicinity
of rotating equipment and operator live loads in areas accessible by operators.
• Prior to construction of final design, Annova should file electrical area

classification drawings.
• Prior to construction of final design, Annova should file drawings and details
of how process seals or isolations installed at the interface between a
flammable fluid system and an electrical conduit or wiring system meet the
requirements of NFPA 59A (2001).
• Prior to construction of final design, Annova should file details of an air gap
or vent installed downstream of process seals or isolations installed at the
interface between a flammable fluid system and an electrical conduit or wiring
system. Each air gap should vent to a safe location and be equipped with a
leak detection device that should continuously monitor for the presence of a
flammable fluid, alarm the hazardous condition, and shut down the
appropriate systems.
• Prior to construction of final design, Annova should file the design

specifications and drawings for the feed gas inlet facilities (e.g., metering,
pigging system, pressure protection system, compression, etc.).
• Prior to construction of final design, Annova should include LNG storage tank
fill flow measurement with high flow alarm.
• Prior to construction of final design, Annova should include BOG flow

measurement from each LNG storage tank.
• Prior to construction of final design, Annova should specify how each LNG
storage tank dome’s vent valve HV-0014/HV-0054 will be isolated with
administrative controls in the event that the vent valve cannot be closed or
requires maintenance work.
• Prior to construction of final design, Annova should file the sizing basis and
capacity for the final design of the flares and/or vent stacks as well as the
pressure and vacuum relief valves for major process equipment, vessels, and
storage tanks.

• Prior to construction of final design, Annova should provide the Refrigerant

Surge Drum, Ethylene Make-up Drum, Propane Make-up Drum, and Iso-
pentane Make-up Drum with dual full capacity relief valves that allow the
isolation with administrative controls of individual pressure relief valves while
providing full relief capacity during pressure relief valve maintenance or
testing.
• Prior to construction of final design, Annova should file a drawing showing

the location of the emergency shutdown buttons. Emergency shutdown
buttons should be easily accessible, conspicuously labeled, and located in an
area which would be accessible during an emergency.
• Prior to construction of final design, Annova should specify that all ESD valves
are to be equipped with open and closed position switches connected to the
Distributed Control System/Safety Instrumented System.
• Prior to construction of final design, Annova should specify how the BOG
system will prevent pipeline gas from back flowing into the BOG Metering
Skid.
• Prior to construction of final design, Annova should specify how the Heat
Medium Expansion Drum pressure indicator, 1090-PI-0241, will notify
operators of excessive venting through pressure regulator, 1090-PCV-0240.
• Prior to construction of final design, Annova should file drawings and

specifications for crash rated vehicle barriers at each facility entrance for
access control.
• Prior to construction of final design, Annova should file drawings of the

security fence. The fencing should extend around the pigging and metering
equipment. The fencing drawings should provide details of fencing that
demonstrates it would restrict and deter access around the entire facility and
has a setback from exterior features (e.g., power lines, trees, etc.) and from
interior features (e.g., piping, equipment, buildings, etc.) that does not allow
the fence to be overcome.
• Prior to construction of final design, Annova should file drawings of internal

road vehicle protections, such as guard rails, barriers, and bollards to protect
transfer piping, pumps, compressors, hydrants, monitors, etc. to ensure that
they are located away from roadway or protected from inadvertent damage
from vehicles.
• Prior to construction of final design, Annova should file security camera and
intrusion detection drawings. The security camera drawings should show the
locations, areas covered, and features of each camera (e.g., fixed,
tilt/pan/zoom, motion detection alerts, low light, mounting height, etc.) to
verify camera coverage of the entire perimeter with redundancies, and

cameras interior to the facility that would enable rapid monitoring of the
facility including a camera at the top of each LNG storage tank, and coverage
within pretreatment areas, within liquefaction areas, within truck transfer
areas, within marine transfer areas, and buildings. The drawings should show
or note the location of the intrusion detection to verify it covers the entire
perimeter of the facility.
• Prior to construction of final design, Annova should file lighting drawings.

The lighting drawings should show the location, elevation, type of light fixture,
and lux levels of the lighting system and should be in accordance with API 540
and provide illumination along the perimeter of the facility, process
equipment, mooring points, and along paths/roads of access and egress to
facilitate security monitoring and emergency response operations.
• Prior to construction of final design, Annova should evaluate the terminal

alarm system and external notification system design to ensure the location of
the terminal alarms and other fire and evacuation alarm notification devices
(e.g. audible/visual beacons and strobes) would provide adequate warning at
the terminal and external off-site areas in the event of an emergency.
• Prior to construction of final design, Annova should file an updated fire

protection evaluation of the proposed facilities. A copy of the evaluation, a list
of recommendations and supporting justifications, and actions taken on the
recommendations should be filed. The evaluation should justify the type,
quantity, and location of hazard detection and hazard control, passive fire
protection, emergency shutdown and depressurizing systems, firewater, and
emergency response equipment, training, and qualifications in accordance
with NFPA 59A (2001). The justification for the flammable and combustible
gas detection and flame and heat detection should be in accordance with
ISA 84.00.07 or equivalent methodologies that would demonstrate 90 percent
or more of releases (unignited and ignited) that could result in an off-site or
cascading impact would be detected by two or more detectors and result in
isolation and de-inventory within 10 minutes. The analysis should take into
account the set points, voting logic, wind speeds, and wind directions. The
justification for firewater should provide calculations for all firewater
demands based on design densities, surface area, and throw distance and
specifications for the corresponding hydrant and monitors needed to reach
and cool equipment.
• Prior to construction of final design, Annova should file spill containment

system drawings with dimensions and slopes of curbing, trenches,
impoundments, and capacity calculations considering any foundations and
equipment within impoundments, as well as the sizing and design of the down-
comer that would transfer spills from the tank top to the ground-level
impoundment system. The spill containment drawings should show
containment for all hazardous fluids, including all liquids handled above their
flashpoint, from the largest flow from a single line for 10 minutes, including

de-inventory, or the maximum liquid from the largest vessel (or total of
impounded vessels) or otherwise demonstrate that providing spill containment
would not significantly reduce the flammable vapor dispersion or radiant heat
consequences of a spill. In addition, Annova should demonstrate that the
stainless steel piping spill trays at each LNG storage tank would withstand the
force and shock of a sudden cryogenic release.
• Prior to construction of final design, Annova should specify how residual

water within each spill basin will be removed after the stormwater removal
pumps shut down on low water level.
• Prior to construction of final design, Annova should review each Process Area
Impoundment Basin stormwater removal system. If applicable, each
stormwater removal pump should be equipped with an interlock to prevent
inadvertent discharge of warm refrigerant, heavy hydrocarbon, or hot oil
releases.
• Prior to construction of final design, Annova should file an analysis

demonstrating that the side on overpressures would be less than 1 psi at the
buildings or that the buildings would be able to withstand overpressures from
explosions within the terminal.

demonstrating the side on overpressures would be less than 1 psi at the LNG
storage tanks, or demonstrating the LNG storage tanks would be able to
withstand overpressures within the terminal.

demonstrating the flammable vapor dispersion from design spills would be
prevented from dispersing underneath the elevated LNG storage tanks, or
demonstrating the LNG storage tanks would be able to withstand the
overpressure due to ignition of the flammable vapors that disperses
underneath the elevated LNG storage tanks.

demonstrating that a LNG storage tank dike fire or a pool fire within the
Marine Area Impoundment Basin would not fail the seawater firewater
equipment within the time it would take for each pool fire scenario to burn
out. Alternatively, Annova should reposition the seawater firewater
equipment to prevent high radiant heat zones.
• Prior to construction of final design, Annova should specify how cascading

damage to the condensate storage tank would be mitigated from a pool fire in
the Heat Medium Impoundment Basin. Alternatively, Annova should
reposition the condensate storage tank or the Heat Medium Impoundment
Basin to prevent high radiant heat zones over the condensate storage tank.

• Prior to construction of final design, Annova should file complete drawings

and a list of the hazard detection equipment. The drawings should clearly
show the location and elevation of all detection equipment. The list should
include the instrument tag number, type and location, alarm indication
locations, and shutdown functions of the hazard detection equipment.
• Prior to construction of final design, Annova should file a list of alarm and
shutdown set points for all hazard detectors that account for the calibration
gas of the hazard detectors when determining the lower flammable limit set
points for methane, propane, ethylene, pentane, and condensate.
• Prior to construction of final design, Annova should file a list of alarm and
shutdown set points for all hazard detectors that account for the calibration
gas of hazard detectors when determining the set points for toxic components
such as aqueous ammonia, natural gas liquids, and hydrogen sulfide.
• Prior to construction of final design, Annova should file a technical review of

facility design that:
a. identifies all combustion/ventilation air intake equipment and the

distances to any possible flammable gas or toxic release; and
b. demonstrates that these areas are adequately covered by hazard
detection devices and indicates how these devices would isolate or
shutdown any combustion or heating ventilation and air conditioning
equipment whose continued operation could add to or sustain an
emergency.
• Prior to construction of final design, Annova should file a design that includes
hazard detection suitable to detect high temperatures and smoldering
combustion products in electrical buildings and control room buildings.
• Prior to construction of final design, Annova should provide low oxygen

detectors to notify operators of liquid nitrogen releases.
• Prior to construction of final design, Annova should file an evaluation of the

voting logic and voting degradation for hazard detectors.
• Prior to construction of final design, Annova should file an analysis of the off
gassing of hydrogen in battery rooms and ventilation calculations that limit
concentrations below the lower flammability limits (e.g., 25 percent LFL) and
should also provide hydrogen detectors that alarm (e.g., 20 to 25 percent LFL)
and initiate mitigative actions (e.g., 40 to 50 percent LFL).
• Prior to construction of final design, Annova should file facility plan drawings
and a list of the fixed and wheeled dry-chemical, hand-held fire extinguishers,
and other hazard control equipment. Plan drawings should clearly show the
location and elevation by tag number of all fixed dry chemical systems in

accordance with NFPA 17, and wheeled and hand-held extinguishers location
travel distances are along normal paths of access and egress in accordance
with NFPA 10. The list shall include the equipment tag number, type,
capacity, equipment covered, discharge rate, and automatic and manual
remote signals initiating discharge of the units.
• Prior to construction of final design, Annova should file a design that includes
clean agent systems in the instrumentation buildings.
• Prior to construction of final design, Annova should file facility plan drawings
showing the proposed location of the firewater and any foam systems. Plan
drawings should clearly show the location of firewater and foam piping, post
indicator valves, and the location and area covered by, each monitor, hydrant,
hose, water curtain, deluge system, foam system, water-mist system, and
sprinkler. The drawings should also include piping and instrumentation
diagrams of the firewater and foam systems.
• Prior to construction of final design, Annova should specify two firewater

jockey pumps and appurtenances that can operate simultaneously in the event
that the primary jockey pump cannot maintain system pressure. The flow rate
capacity from the jockey pumps shall be supported with calculations.
• Prior to construction of final design, Annova should include or demonstrate

the firewater storage volume for its facilities has minimum reserved capacity
for its most demanding firewater scenario plus 1,000 gpm for no less than 2
hours. The firewater storage should also demonstrate compliance with NFPA
22 or demonstrate how API 650 provides an equivalent or better level of safety.
• Prior to construction of final design, Annova should specify that the firewater
flow test meter is equipped with a transmitter and that a pressure transmitter
is installed upstream of the flow transmitter. The flow transmitter and
pressure transmitter should be connected to the DCS and should be recorded.
• Prior to construction of final design, Annova should file detailed calculations

to confirm that the final fire water volumes would be accounted for when
evaluating the capacity of the impoundment system during a spill and fire
scenario.
• Prior to construction of final design, Annova should specify that both

freshwater pump shelter and the firewater intake and pumps shelter are
designed to remove the largest firewater pump or other component for
maintenance with an overhead or external crane.

specifications for the structural passive protection systems to protect
equipment and supports from cryogenic releases.

• Prior to construction of final design, Annova should file calculations or test

results for the structural passive protection systems to protect equipment and
supports from cryogenic releases.

specifications for the structural passive protection systems to protect
equipment and supports from pool and jet fires.
• Prior to construction of final design, Annova should file specifications and

drawings of how cascading damage of transformers would be prevented (e.g.,
firewalls or spacing) in accordance with NFPA 850 or equivalent.
• Prior to construction of final design, Annova should file a detailed quantitative

analysis to demonstrate that adequate mitigation would be provided for each
significant component within the 4,000 Btu/ft2-hr zone from pool or jet fires
that could cause failure of the component (including fires in the amine sump
pit and condensate storage tank berm). Trucks at the truck loading/unloading
areas should be included in the analysis. A combination of passive and active
protection for pool fires and passive and/or active protection for jet fires
should be provided and demonstrate the effectiveness and reliability.
Effectiveness of passive mitigation should be supported by calculations or test
results for the thickness limiting temperature rise and active mitigation should
be justified with calculations or test results demonstrating flow rates and
durations of any cooling water would mitigate the heat absorbed by the vessel.
• Prior to construction of final design, Annova should file a projectile analysis

that demonstrates whether each LNG storage tank would withstand
projectiles from explosions and high winds, or demonstrate whether protective
measures are in place to ensure the structural integrity of each LNG storage
tank. If the analysis demonstrates the tank would be penetrated, Annova
should file an analysis indicating the containment dikes would sufficiently
contain an LNG spill.

demonstrating that each LNG storage tank’s water deluge system would
provide adequate thermal mitigation to withstand the radiant heat from an
adjacent LNG storage tank dike fire.
• Prior to construction of final design, Annova should provide an evaluation of

impacts from any size jetting releases from each LNG storage tank platform,
marine dock and trestle, and the ethylene make-up drum area. As applicable,
the evaluation should demonstrate that adequate mitigation would be
provided to prevent cascading damage.
• Prior to commissioning, Annova should file a detailed schedule for

commissioning through equipment startup. The schedule should include
milestones for all procedures and tests to be completed: prior to introduction

of hazardous fluids and during commissioning and startup. Annova should

file documentation certifying that each of these milestones has been completed
before authorization to commence the next phase of commissioning and
startup will be issued.
• Prior to commissioning, Annova should file detailed plans and procedures for:
testing the integrity of onsite mechanical installation; functional tests;
introduction of hazardous fluids; operational tests; and placing the equipment
into service.
• Prior to commissioning, Annova should file a plan for clean-out, dry-out,

purging, and tightness testing. This plan should address the requirements of
the American Gas Association’s Purging Principles and Practice, and should
provide justification if not using an inert or non-flammable gas for clean-out,
dry-out, purging, and tightness testing.
• Prior to commissioning, Annova should file the procedures for pressure/leak

tests which address the requirements of ASME VIII and ASME B31.3. The
procedures should include a line list of pneumatic and hydrostatic test
pressures.
• Prior to commissioning, Annova should file the settlement results from

hydrostatic testing of the LNG storage containers as well as a routine
monitoring program to ensure settlements are as expected and do not exceed
applicable criteria in API 620, 625, and 653. The program should specify what
actions would be taken after various levels of seismic events.
• Prior to commissioning, Annova should equip the LNG storage tank and
adjacent piping and supports with permanent settlement monitors to allow
personnel to observe and record the relative settlement between the LNG
storage tank and adjacent piping. The settlement record should be reported
in the semi-annual operational reports.
• Prior to commissioning, Annova should file the operation and maintenance

procedures and manuals, as well as safety procedures, hot work procedures
and permits, abnormal operating conditions reporting procedures,
simultaneous operations procedures, and management of change procedures
and forms.
• Prior to commissioning, Annova should tag all equipment, instrumentation,

and valves in the field, including drain valves, vent valves, main valves, and
car-sealed or locked valves.
• Prior to commissioning, Annova should file a plan to maintain a detailed

training log to demonstrate that operating, maintenance, and emergency
response staff has completed the required training.

• Prior to introduction of hazardous fluids, Annova should complete and

document all pertinent tests (Factory Acceptance Tests, Site Acceptance Tests,
Site Integration Tests) associated with the DCS and SIS that demonstrates full
functionality and operability of the system.
• Prior to introduction of hazardous fluids, Annova should develop and

implement an alarm management program to reduce alarm complacency and
maximize the effectiveness of operator response to alarms.
• Prior to introduction of hazardous fluids, Annova should develop and

implement procedures for plant personnel to monitor the rocket launches
from the Brownsville SpaceX facility and take mitigative actions before and
after a rocket launch failure to minimize the potential of release reaching
offsite areas or resulting in cascading effects that could extend offsite or impact
safe operations.

document a firewater pump acceptance test and firewater monitor and
hydrant coverage test. The actual coverage area from each monitor and
hydrant should be shown on facility plot plan(s).

document a pre-startup safety review to ensure that installed equipment meets
the design and operating intent of the facility. The pre-startup safety review
should include any changes since the last hazard review, operating procedures,
and operator training. A copy of the review with a list of recommendations,
and actions taken on each recommendation, should be filed.
• Annova should file a request for written authorization from the Director of
OEP prior to unloading or loading the first LNG commissioning cargo. After
production of first LNG, Annova should file weekly reports on the
commissioning of the proposed systems that detail the progress toward
demonstrating the facilities can safely and reliably operate at or near the
design production rate. The reports should include a summary of activities,
problems encountered, and remedial actions taken. The weekly reports should
also include the latest commissioning schedule, including projected and actual
LNG production by each liquefaction train, LNG storage inventories in each
storage tank, and the number of anticipated and actual LNG commissioning
cargoes, along with the associated volumes loaded or unloaded. Further, the
weekly reports should include a status and list of all planned and completed
safety and reliability tests, work authorizations, and punch list items.
Problems of significant magnitude should be reported to the FERC within 24
hours.
• Prior to commencement of service, Annova should label piping with fluid

service and direction of flow in the field, in addition to the pipe labeling
requirements of NFPA 59A (2001).

• Prior to commencement of service, Annova should file plans for any

preventative and predictive maintenance program that performs periodic or
continuous equipment condition monitoring.
• Prior to commencement of service, Annova should develop procedures for

offsite contractors’ responsibilities, restrictions, and limitations and for
supervision of these contractors by Annova staff.
• Prior to commencement of service, Annova should notify the FERC staff of

any proposed revisions to the security plan and physical security of the plant.
• Prior to commencement of service, Annova should file a request for written

authorization from the Director of OEP. Such authorization would only be
granted following a determination by the Coast Guard, under its authorities
under the Ports and Waterways Safety Act, the Magnuson Act, the MTSA of
2002, and the Security and Accountability For Every Port Act, that
appropriate measures to ensure the safety and security of the facility and the
waterway have been put into place by Annova or other appropriate parties.
In addition, we recommend that the following measures should apply throughout the
life of the Annova LNG terminal:
• The facility should 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,
Annova should 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 P&IDs
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, should be submitted.
• Semi-annual operational reports should be filed with the Secretary to identify

changes in facility design and operating conditions; abnormal operating
experiences; activities (e.g., ship arrivals, quantity and composition of
imported and exported LNG, liquefied and vaporized quantities, boil off/flash
gas); and plant modifications, including future plans and progress thereof.
Abnormalities should include, but not be limited to,
unloading/loading/shipping 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, non-
scheduled maintenance or repair (and reasons therefore), relative movement
of storage tank inner vessels, hazardous fluids releases, fires involving
hazardous fluids and/or from other sources, negative pressure (vacuum)

within a storage tank, and higher than predicted boil off rates. Adverse
weather conditions and the effect on the facility also should be reported.
Reports should 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)”
should be included in the semi-annual operational reports. Such information
would provide the FERC staff with early notice of anticipated future
construction/maintenance at the LNG facilities.
• In the event the temperature of any region of the LNG storage container
becomes less than the minimum specified operating temperature for the
material, the Commission should be notified within 24 hours and procedures
for corrective action should be specified.
• Significant non-scheduled events, including safety-related incidents (e.g.,

LNG, condensate, refrigerant, or natural gas releases; fires; explosions;
mechanical failures; unusual over pressurization; and major injuries) and
security-related incidents (e.g., attempts to enter site, suspicious activities)
should be reported to the FERC staff. In the event that an abnormality is of
significant magnitude to threaten public or employee safety, cause significant
property damage, or interrupt service, notification should be made
immediately, without unduly interfering with any necessary or appropriate
emergency repair, alarm, or other emergency procedure. In all instances,
notification should be made to the FERC staff within 24 hours. This
notification practice should be incorporated into the LNG terminal’s
emergency plan. Examples of reportable hazardous fluids-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. release of hazardous fluids for 5 minutes or more;
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 facility that
contains, controls, or processes hazardous fluids;
g. any crack or other material defect that impairs the structural integrity
or reliability of facility that contains, controls, or processes hazardous
fluids;
h. any malfunction or operating error that causes the pressure of a
pipeline or facility that contains or processes hazardous fluids to rise
above its maximum allowable operating pressure (or working pressure

for LNG facilities) plus the build-up allowed for operation of pressure-
limiting or control devices;
i. a leak in facility that contains or processes hazardous fluids that
constitutes an emergency;
j. inner tank leakage, ineffective insulation, or frost heave that impairs
the structural integrity of an LNG storage tank;
k. any safety-related condition that could lead to an imminent hazard and
cause (either directly or indirectly by remedial action of the operator),
for purposes other than abandonment, a 20 percent reduction in
operating pressure or shutdown of operation of a pipeline or facility
that contains or processes hazardous fluids;
l. safety-related incidents from hazardous fluids transportation
occurring at or en route to and from the 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 terminal’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 terminal to cease operations. Following the initial company
notification, the FERC staff would determine the need for a separate follow-
up report or follow up in the upcoming semi-annual operational report. All
company follow-up reports should include investigation results and
recommendations to minimize a reoccurrence of the incident.
Conclusions on LNG Facility and Marine Vessel Reliability and Safety

As part of the NEPA review and NGA determinations, Commission staff assesses the
potential impact to the human environment in terms of safety and whether the proposed facilities
would operate safely, reliably, and securely.
As a cooperating agency, the DOT assists the FERC by determining whether Annova’s
proposed design would meet the DOT’s 49 CFR 193 Subpart B siting requirements. On March
20, 2019, the DOT issued an LOD to FERC on the 49 CFR 193 Subpart B regulatory requirements.
The LOD is provided to the Commission for consideration in its decision to authorize, with or
without modification or conditions, or deny the Project. If the Project is authorized, constructed,
and operated, the facility would be subject to the DOT’s inspection and enforcement program;
final determination of whether a facility is in compliance with the requirements of 49 CFR 193
would be made by the DOT staff.
a WSA submitted by Annova that focused on the navigation safety and maritime security aspects
of LNG marine vessel transits along the affected waterway. On February 13, 2018, the Coast
Guard issued an LOR that recommended that the BSC be considered suitable for accommodating

the type and frequency of LNG marine traffic for the Project, based on the WSA and in accordance
with the guidance in the Coast Guard’s NVIC 01-11. Although the WSA was based on a maximum
of 125 ships, the Coast Guard's LOR for the Annova Project states that the BSC would be suitable
for 80 ships. Annova has requested that the number of ships be increased from about 80 to 125
ship-calls per year as indicated in the WSA. The Coast Guard is currently evaluating this to
determine if a revised LOR should be issued. As indicated previously, the safety and
environmental analysis in the final EIS has evaluated 125 ships. If the Project is authorized,
constructed, and operated, the facilities would be subject to the Coast Guard’s inspection and
enforcement program to ensure compliance with the requirements of 33 CFR 105 and 33 CFR 127.
the SpaceX rocket launch facility in Cameron County. Specific recommendations are included to
address potential impacts from rocket launch failures on the Project. However, the extent of
impacts on SpaceX operations, the National Space Program, and to the federal government would
not fully be known until SpaceX submits an application with the FAA requesting to launch and
whether the LNG Terminal is under construction or in operation at that time.
FERC staff conducted a preliminary engineering and technical review of the Annova
design, including potential external impacts based on the site location. Based on this review, we
recommend a number of mitigation measures, which would ensure continuous oversight prior to
initial site preparation, prior to construction of final design, prior to commissioning, prior to
introduction of hazardous fluids, prior to commencement of service, and throughout life of the
facility, in order to enhance the reliability and safety of the facility to mitigate the risk of impact
on the public. With the incorporation of these mitigation measures and oversight, we conclude
that Annova’s terminal design would include acceptable layers of protection or safeguards that
would reduce the risk of a potentially hazardous scenario from developing into an event that could
impact the offsite public.

4.13 CUMULATIVE IMPACTS
NEPA requires the lead federal agency to consider the potential cumulative impacts of
proposals under its review. Cumulative impacts may result when the environmental effects
associated with the proposed action (in this case the Annova LNG Project, or Project) are
superimposed on, or added to, impacts associated with other past, present, and reasonably
foreseeable future projects (project, or projects) regardless of what agency or person undertakes
such other actions. Although the individual impact of each separate project may be minor, the
additive or synergistic effects of multiple projects could be significant.
This cumulative impacts analysis uses an approach consistent with the methodology set
forth in relevant guidance (CEQ 1997b, 2005; EPA 1999b). Under these guidelines, inclusion of
actions within the analysis is based on identifying commonalities between the impacts that would
result from the Annova Project and the impacts likely to be associated with other potential projects.
The Project-specific impacts of the Annova LNG Project are discussed in detail in other
sections of this EIS. The purpose of this section is to identify and describe cumulative impacts
that would potentially result from implementation of the proposed Project along with other projects
in the vicinity that could affect the same resources during the same approximate timeframe. To
ensure that this analysis focuses on relevant projects and potentially significant impacts, the actions
included in the cumulative impact analysis include projects that:
• impact a resource potentially affected by the proposed Project;

• impact that resource within all or part of the time span encompassed by the
proposed or reasonably expected construction and operation schedule of the
proposed Project; and
• impact that resource within all or part of the same geographic area affected by the
proposed Project. The geographic area considered varies depending on the resource
being discussed, which is the general area in which the projects could contribute to
cumulative impacts on that particular resource (geographic scope of analysis).
4.13.1 Temporal and Geographic Distribution (Geographic Scope)
For the purpose of this analysis, the temporal extent of other projects would extend out for
the expected duration of the impacts caused by the Project. Some Project impacts from
construction could occur as soon as site preparation begins during construction, while operational
impacts are assumed to exist throughout the life of the facility. The Project is expected to have a
25 year life span, but the facilities would be designed and capable of operating for 50 years or
more with proper maintenance.
The geographic distribution of the area considered in the cumulative effects analysis varies
by resource. The cumulative impact analysis area, or geographic scope, for a resource may be
substantially greater than the corresponding Project-specific area of impact in order to consider an
area large enough to encompass likely effects from other projects on the same resource. The CEQ
(1997) recommends setting the geographic scope based on the natural boundaries of the resource
affected, rather than jurisdictional boundaries. We have used the Bahia Grande-Brownsville Ship
4-279 Cumulative Impacts

Channel watershed (HUC-121102080900) (HUC-12 watershed) as our basic analysis area for most
resources. The HUC-12 watershed considered here covers a large area. The Bahia Grande-
Brownsville Ship Channel watershed has a total area of about 234,353 acres. Table 4.13.1-1
provides the geographic scope considered for each resource.
TABLE 4.13.1-1
Geographic Scope by Resource for the Annova LNG Project

Resource Geographic Scope Rationale for Potential Cumulative Impact Analysis Area
Geologic Geology and soils are relatively static resources that would not be affected
Area that would be affected by
Resources and outside of the Project footprint and immediately adjacent area, with
and adjacent to the LNG terminal
Soils implementation of the Annova Plan and Procedures.
Projects within the HUC-12 watershed could contribute to downstream
HUC-12 watershed and some
impacts on water quality; therefore, the LNG terminal would result in
Water distance downstream for
additional incremental impacts on waters further downstream. Also, to
Resources consideration of turbidity and tidal
account for the potential of inadvertent spills within the watershed
influence
affecting groundwater.
Projects within the HUC-12 watershed could contribute to impacts on
Wetlands and wetlands and vegetation within the watershed; therefore, the LNG terminal
HUC-12 watershed
Vegetation would result in additional incremental impacts on wetlands and vegetation
within the HUC-12 watershed.
Impacts occurring within the construction workspaces could affect mobile
wildlife within the HUC-12 watershed, which accounts for a typical range
Wildlife and of wildlife movements off the Project site.
Aquatic HUC-12 watershed
Resources Projects within the HUC-12 watershed could contribute to downstream
impacts on aquatic species and habitat; therefore, the LNG terminal would
result in additional incremental impacts within the watershed.
Threatened & Impacts occurring within the construction workspaces could affect mobile
Endangered HUC-12 watershed wildlife within the HUC-12 watershed, which accounts for a typical range
Species (land) of wildlife movements off the Project site.
Marine/estuarine waterbodies in
Threatened and Projects within the marine/estuarine waterbodies in the HUC-12
the HUC-12 watershed and
Endangered watershed, and shipping lanes in the Gulf of Mexico, could contribute to
established shipping channels
Species (marine) impacts on listed marine species.
used by LNG carriers
Land Use and Cameron County - to encompass any large areas with specialized or
Cameron County
Recreation recreational uses.
Impacts on aesthetics or visual integrity depend on distance, setting, and
Within 5.1 miles of Annova LNG contrast. As determined in the Visual Impact Assessment, the farthest
Visuals
Project distance to a visual receptor or Key Observation Point at which the Project
impacts were Moderate, Moderately High, or High, is 5.1 miles.
Impacts occur within the Brownsville-Harlingen-Raymondville Combined
Cameron County and Willacy
Socioeconomics Statistical Area, which includes Cameron and Willacy Counties and
County
extends 59 miles from the Project site and main access road.
Major roads and intersections
Socioeconomics
that would be used during Construction and operational staff would increase traffic on a subset of
(Land
construction and operation (e.g., roads, depending on their point of origin.
Transportation)
impacts on SH 48 and SH 4)
Socioeconomics BSC and established shipping
Construction and operations would increase vessel traffic in the BSC.
(Marine Trans.) lanes
300 feet on either side of the
Cultural main access road (direct) and 0.5 Impact area is the Area of Potential Effect as defined by the FERC and
Resources mile from the Project site Texas Historical Commission (the State Historic Preservation Office).
(indirect)
Construction: within 1 mile of Localized construction impacts could occur within 1 mile of the LNG
LNG terminal sites project construction sites
Air Quality Impacts could occur within 31 miles (50 kilometers). Includes criteria
Operation: Within 31 miles (50
pollutants, HAPs and VOCs. GHG emissions do not have a localized
km) of the Annova LNG Project
cumulative impact with nearby projects.
Cumulative Impacts 4-280

Geographic Scope by Resource for the Annova LNG Project

Resource Geographic Scope Rationale for Potential Cumulative Impact Analysis Area
Impacts from noise-producing equipment and activities considered
Any facility that can cause an intrusive, other than the proposed Project, are typically limited to within 1
Noise impact at NSAs within 1 mile of mile of the Project site during construction and operation. Noise impacts
the Project from the proposed Project were evaluated at the nearest NSA (NSA #3).
NSA #3 is a residence on SH 4, located 2.3 miles south of the Project site.
4.13.2 Projects and Activities Considered
The current regional landscape in south Texas, which is a mix of large tracts of open land
that support ranch and cattle operations, NWRs, and an assortment of industrial facilities already
sited along the BSC, forms the environmental baseline described in other sections of this EIS and
against which the impacts of recent, concurrent, and reasonably foreseeable future actions are
considered. CEQ guidance states that an adequate cumulative effects analysis may be conducted
by focusing on the current aggregate effects of past actions without delving into the historical
details of individual past actions. In this analysis, we consider the impacts of past projects within
the resource geographic scopes as part of the affected environment (environmental baseline) which
was described and evaluated in the preceding environmental analysis. However, present effects
of past actions that are relevant and useful are also considered.
Reasonably foreseeable projects that might cause cumulative impacts in combination with
the proposed Project include projects that are under construction, approved, proposed, or planned.
For FERC-regulated projects, proposed projects are those for which the proponent has submitted
a formal application to the FERC, and planned projects are projects that are either in pre-filing or
have been announced but have not been officially proposed. Planned projects also include projects
not under the FERC’s jurisdiction that have been identified through publicly available information
such as press releases, internet searches, and the applicants’ communications with local agencies.
Table H-1 in appendix H lists the projects and activities that we considered in this
cumulative impact analysis, including the location, distance from the Annova LNG Project, project
timeframe, and resource(s) potentially cumulatively affected in conjunction with the Annova LNG
Project. Figure 4.13.2-1 displays these projects in relation to the Annova LNG Project.
Descriptions of potential cumulative impacts by resource category are discussed in section 4.13.3.
For some projects, we were unable to obtain quantitative information (e.g., size, area of impact,
status of permitting, etc.), and in these cases our analysis relies on qualitative information.
4.13.2.1 Non-jurisdictional Facilities Associated with the Annova LNG Project
As described in section 1.4, the Project would require certain non-jurisdictional facilities,
including an interconnect to the natural gas supply pipeline, an electrical transmission line and
switch yard, and a potable waterline. In addition, in its application, Annova described the natural
gas supply pipeline that would provide gas to the LNG terminal, and as described, the natural gas
supply pipeline would also be a non-jurisdictional facility. Each of these Project components has
been included in our cumulative impacts analysis and all are described below.

Natural Gas Supply Lateral Pipeline

The Project would receive natural gas supply from a third-party–owned and –operated
intrastate pipeline that would connect to the Valley Crossing Pipeline System. The approximately
9-mile-long, 36-inch-diameter natural gas supply lateral would begin at an existing Valley
Crossing compressor station north of Highway 48 within the Port of Brownsville, cross the BSC
using HDD, and continue generally south and then east to the Project site. Construction of the
natural gas supply lateral would affect about 110 acres of land, all of which would be located
within Cameron County, and result in a permanent footprint of about 50 acres within the right-of-
way. The supply lateral would be an intrastate pipeline and therefore would not be under the
FERC’s jurisdiction. The general location of the supply lateral is shown on figure 1.4.1-1.
In addition, Annova indicated in its March 25, 2019 filing that Valley Crossing would need
to expand its existing Compressor Station just north of Highway 48 with approximately 15,000 hp
of compression to deliver the quantity of gas to third party-owned and –operated Natural Gas
Supply Lateral Pipeline.
Natural Gas Interconnection Facilities

Annova would take custody of natural gas delivered to the LNG terminal through
interconnection and metering facilities that would be constructed and operated by the same third-
party entity that would construct, own, and operate the natural gas supply lateral. The
interconnection facilities would be located in a 200-foot by 300-foot fenced yard in the southwest
corner of the Annova LNG Project site. These facilities would include valves and gas
measurement devices, as well as related instrumentation and communications equipment. The
interconnection facilities would also provide the necessary infrastructure for the natural gas supply
lateral to measure and receive compressed BOG from the Project. The location of the natural gas
interconnection facilities is shown on figure 1.4.2-1.
Transmission Line and Switchyard

The STEC would supply power to the Project through a tie-in to STEC’s existing
transmission system and construction of a new transmission line to the Project site. The
connection and transmission system would be permitted, constructed, owned, and operated by
STEC, and would include:
• modifications of the existing Highway 511 and Waterport Electric Substations to
provide interconnection to the new 138-kV line;
• a new 138-kV switchyard on the Project site; and
• a new 138-kV line between an existing switchyard and the new switchyard on the
Project site.

Figure 4.13.2-1 Projects Included in Cumulative Impact Analysis

The new 138-kV transmission line from the existing substation to the Project site would be
approximately 15 miles long and supported by poles 90 to 110 feet high and spaced approximately
600 feet apart. The initial design calls for a right-of-way width of 100 feet. While the final route
has not been determined by STEC, Annova identified an example potential route for the
transmission line for the purpose of describing non-jurisdictional facilities and evaluating
cumulative impacts. See figure 1.4.3-1.
Potable Water Pipeline

The BND would provide potable water to the Project during construction and operation
through an extension of an existing pipeline from its current termination point to the Project site.
The total length of the potable water pipeline would be about 5.9 miles. Annova identified a
potential route for the water pipeline for the purpose of describing non-jurisdictional facilities and
evaluating cumulative impacts. See figure 1.4.4-1.
4.13.2.2 Liquefaction and LNG Export Projects
Rio Grande LNG Project and Pipeline

Rio Grande LNG, LLC is proposing to construct and operate a new LNG export terminal
that would be located along the north side of the BSC as part of its Rio Grande LNG Project. The
Rio Grande LNG Project would be capable of producing 27 mtpa of LNG for export and would
consist of six liquefaction trains, a marine berth capable of receiving two LNG carriers at a time,
and four 180,000 square meters LNG storage tanks. The Rio Grande LNG Project would be
located on a 984-acre parcel, of which about 770 acres would be affected. Additional land would
be affected the heavy haul road, offsite construction areas, and dredge disposal for a total impact
of about 1,150 acres.
The Rio Grande project includes the Rio Bravo pipeline. The Rio Bravo Pipeline Project
consists of two 130-mile-long, parallel, 42-inch-diameter natural gas pipelines from the Agua
Dulce Market Area in Kleberg County, Texas, to the proposed Rio Grande LNG Project. The Rio
Bravo Pipeline Project also includes three 180,000-hp compressor stations, two 30,000-hp
interconnect booster stations, and a 2.4-mile-long header pipeline. Construction of the Rio Bravo
pipeline and associated aboveground facilities would affect about 3,655 acres of land, and
operation would affect about 2,148 acres. Non-jurisdictional projects associated with the Rio
Grande LNG Project include LNG trucking of 12 to 15 tanker trucks per day, utilities (water,
sewer, and electric services), and widening of SH 48.
Texas LNG Terminal Project and Pipeline

Texas LNG Brownsville LLC (Texas LNG) has proposed a liquefaction and LNG export
terminal on the BSC in Cameron County bordering the northeast boundary of the Rio Grande LNG
Project site about 2.2 miles east of the Annova LNG Project. The Texas LNG Project would
impact about 300 acres of land and would include two LNG trains with an overall LNG capacity
of approximately 4.0 mtpa, two 210,000 square meters LNG storage tanks, and a marine berth to
accommodate one LNG carrier. Natural gas would be delivered to the Texas LNG Project via a
non-jurisdictional intrastate natural gas pipeline that would be constructed, owned, and operated
by a third party, separate from Texas LNG. Texas LNG anticipates that the 30-inch-diameter
pipeline would be approximately 10.2 miles long (1.3 miles of which would be within the project

site). Construction and operation of the pipeline would affect about 108 acres and 50 acres,
respectively, outside of the LNG project site. Other non-jurisdictional facilities, including
electricity and water, would be provided by AEP and BND, respectively.
Barca, Eos, and Gulf Coast LNG Projects

During scoping, we received comments about the potential Gulf Coast LNG Export, Eos
LNG, and Barca LNG projects. Barca and Eos were planning to develop an LNG export facility
at the Port of Brownsville. While the DOE authorized Eos and Barca to export to FTA nations,
the applicants have not requested to participate in the FERC pre-filing process and have not
submitted applications to any state agencies. Further, the lease option with BND has expired.
Gulf Coast LNG Export, LLC (Gulf Coast) was planning to develop a liquefaction and
LNG export facility on a 500-acre site at the Port of Brownsville. In May 2016, Gulf Coast filed
a request to withdraw its application and vacate its authorization previously received from DOE
to export to FTA nations and non-FTA nations. Gulf Coast has also not started the pre-filing
process with FERC and has not submitted an application to FERC or any state agency.
We conclude that these LNG projects are currently not reasonably foreseeable and are not
further considered in this assessment.
4.13.2.3 Gas Pipeline Projects
Valley Crossing Pipeline (also known as the Nueces-Brownsville Pipeline)

Valley Crossing Pipelineis a 165-mile-long intrastate pipeline to supply gas to the
Comisión Federal de Electricidad Tuxpan Pipeline. The pipeline originates near the Agua Dulce
Hub in Nueces County, Texas, and extends offshore east of Brownsville, Texas. Near the Project,
it is expected to have crossed the BSC via horizontal directional drilling east of the Project. The
Valley Crossing Project connects to the Marina Pipeline via proposed natural gas transmission
facilities known as the Border Crossing Project. The Border Crossing project includes 1,000 feet
of 42-inch-diameter natural gas transmission pipeline across the international boundary between
the United States and Mexico in the Gulf of Mexico. The pipeline project is expected to have
impacted more than 2,500 acres of land. Construction of the Valley Crossing Project began in
2017 and is currently in service.
Tuxpan Pipeline (Sur de Texas – Tuxpan)

The Tuxpan Pipeline will consist of 497 miles of 42-inch-diamter natural gas pipeline,
primarily located offshore in the Gulf of Mexico from its connection to the Valley Crossing
Pipeline at the Border Crossing Project to its terminus in Tuxpan, Mexico. Construction of the
project began in 2017 with full operation underway in 2019. Because the Tuxpan Pipeline would
not impact the same resources potentially affected by the proposed Project within the geographic
scopes identified in table 4.13.1-1, the Tuxpan Pipeline was not included in our cumulative impacts
analysis.
The natural gas supply lateral is discussed under non-jurisdictional facilities associated
with the Annova LNG Project (section 4.13.2.1). The Rio Bravo Pipeline and the intrastate
pipeline to the Texas LNG Project are discussed along with their associated LNG projects under

Liquefaction and LNG Export Projects, section 4.13.2.1.
4.13.2.4 Electric Transmission and Generation Projects
The 93-MW San Roman Wind Farm was completed in 2016 and includes thirty-one 3-MW
wind turbines within a 4,000-acre area in Cameron County, about 8 miles northwest of the Annova
LNG Project.
The Cameron Wind Farm was built by Apex Clean Energy in 2015. The 165-MW facility
comprises 55 turbines on 15,000 acres of leased agricultural land approximately 11 miles north of
Brownsville in Cameron County, about 16 miles from the Annova LNG Project.
The Cross Valley Project (North Edinburg - Loma Alta Transmission project) is a 95-mile-
long, 345-kV transmission line approved by Public Utility Commission of Texas in April 2014 as
part of the Cross Valley Project to ensure reliable electric service for Lower Rio Grande Valley.
The project was completed in 2016 (Sharyland 2017) and the transmission line runs from North
Edinburg (Hidalgo County) to the Loma Alta Substation adjacent to the BSC.
The Tenaska Brownsville Generating Station is proposed for construction on 270 acres in
Cameron County, about 7 miles west of the Pipeline System near MP 128. Tenaska anticipates
the facility will be placed in service in 2019.
AEP’s new 138-kV electric transmission line is planned to provide electricity to the
proposed Rio Grande LNG and Texas LNG projects on the north side of the BSC. The line would
start at an existing substation several miles from the LNG projects and would be constructed in
two phases. The total length would be about 12 miles and a portion would run along SH 48 within
a utility easement. Timing for construction would depend on the status of permitting for the two
LNG projects.
The Palmas Altas Wind Project is currently under construction and consists of the
construction of 46 new wind turbines in northern Cameron County, within an area greater than
6,500 acres. It is approximately 21 miles northwest of the Project site. Acciona Energy anticipates
that the project would generate 145 megawatts, providing power to 43,000 homes. The project is
anticipated to be completed in 2019.
The Palmas to East Rio Hondo Transmission Line is a proposed 6-mile-long 138 kilovolt
electric transmission line that would transport electricity generated by the Palmas Altas Wind
Project to the East Rio Hondo Substation and is approximately 22 miles northwest of the Project
site. Construction is anticipated to begin in March 2019 and be completed in September 2019.
4.13.2.5 Transportation Projects
The Highway 550 Connector and Toll project became operational in June of 2015 based
on a collaborative effort between TxDOT and the Cameron County Regional Mobility Authority
(TxDOT 2016). This limited access toll road provides access to the BSC and begins about 10
miles west of the Annova LNG Project.

Construction of South Padre Island Second Access roadway and bridge to Padre Island was
scheduled to begin in 2018 but is currently under review. TxDOT and the Federal Highway
Administration, in partnership with Cameron County Regional Mobility Authority, are planning
the 17.6-mile project that would be about 8 miles northeast of the Annova LNG Project at its
nearest point.
TxDOT is planning an East-Loop of Highway 32, which includes a four-lane highway that
would run from the Port of Brownsville to Veterans Bridge at Los Tomates (CCRMA 2015). The
goal of the loop is to improve traffic flow in the area around and near the Port of Brownsville,
including SH 48, and improve the route for international trade-related truck traffic. This project
would be 15 miles southwest of the Annova Project site, with an unknown construction schedule.
Associated with the Texas LNG project, a SH 48 auxiliary lane is recommended on the
northbound approach to the main driveway of the Texas LNG site. The auxiliary lane would be 6
feet wide, with a 150-foot taper, 830 feet of deceleration length, and 100 feet of storage area. The
lane would continue to approximately 1,100 feet north of the northern proposed driveway of Texas
LNG to permit acceleration by vehicles exiting the site. TxDOT would construct and own this
auxiliary lane; however, the timing is unknown.
In addition to the modifications of SH 48 associated with access to the Texas LNG Project
site, TxDOT is planning a SH 48 widening project to improve 8.7 miles of SH 48 between Farm
to Market Road (FM) 550 and SH 100. The project would widen the highway and install a raised
median. The construction schedule is currently unknown (TxDOT 2016).
TxDOT is planning multiple FM 510 rehabilitation projects on portions of the roadway

from FM 803 to FM 1847, from FM 3462 to FM 803, and from FM 1847 to FM 2480. These road
segments are located between 11 and 18 miles from the Annova LNG Project site. The timing of
these highway projects is unknown.
Cameron County West Railroad Relocation project includes the relocation of about 7 miles
of track and subgrade, a portion of new Brownsville West Bridge to facilitate freight rail crossing
over Rio Grande, and a two-story Department of Homeland Security facility for inspecting railcars.
TxDOT has installed wildlife crossings under SH 100 between Laguna Vista and Los
Fresnos. Additionally, eight permanent wildlife crossings under FM 106 are being constructed as
a part of an ongoing road project.
A new 16-inch-diameter potable water line and a new 12-inch-diameter sewer line are
planned to extend approximately 7 miles within a Port of Brownsville easement/utility corridor on
the south side of SH 48, across the BSC from the Annova LNG Project site, to serve the Rio Grande
LNG Terminal and likely the Texas LNG Terminal. Construction would require a 30-foot-wide
right–of-way within the 100-foot-wide Port of Brownsville easement.
TxDOT is also planning a 1.4-mile-long upgrade to SH 4, comprising a two-lane,

undivided highway to a planned entrance to the Port of Brownsville (TxDOT 2016). Construction
schedules are currently unknown.

A new, larger airport terminal is proposed to be built at the Brownsville South Padre Island
International Airport. Expansion of the existing airport, which is about 15 miles southwest of the
Project site, would allow additional airlines to provide service from this location, as well as
increase the airport’s overall passenger capacity (Clark 2018a).
4.13.2.6 Port of Brownsville Projects
Brownsville Liquids Terminal

The Brownsville Liquids terminal was completed in 2014 (Phase I) and comprises 21 liquid
storage tanks that can accommodate up to 221,000 barrels of liquid storage; it is located about 5
miles from the Project. Phase II expanded the facility, adding four tanks which increased the
terminal’s capacity up to 700,000 barrels with future expansions (Howard Midstream 2015).
GEOTRAC Industrial Hub

One of America’s largest private railroad and transportation management companies,
OmniTRAX, developed in 2015 a large-scale industrial park on 1,400 acres of BND-owned land
(GEOTRAC Industrial Hub). The park provides opportunities for light and heavy manufacturing,
logistics, energy services, technology development, and export/import warehousing.
Centurion Brownsville Terminal Processing and Storage Facility

The Centurion Brownsville Terminal Processing and Storage Facility is a 1.5+ million-
barrel storage facility and includes a liquid cargo dock, three-track rail spur, 10-truck lease
automatic custody transfer skids, and an initial two condensate processing towers to produce
products for local markets or export. The facility is located about 9 miles west of the Annova LNG
Project site.
Port of Brownsville Cargo Dock 16

Port of Brownsville Cargo Dock 16 became operational in 2015. The 600-foot dock can
accommodate cargo vessels with drafts up to 39.5 feet and is the second heavy-load capacity dock
in Brownsville. Dock 16 is about 6.5 miles west of the Annova LNG Project site.
Big River Steel Mill

In April of 2018, the BND voted to lease 800 acres of land between the BSC and SH 48 to
Big River Steel for construction and operation of a steel mill and distribution facility (Clark
2018b). The facility would be modeled after Big River Steel’s Arkansas plant, which is a LEED-
Certified facility, which is a green-building rating system. Scrap steel from local recyclers would
be utilized by the facility (Clark 2018b). Construction and operation of this facility would create
about 1,500 and 500 jobs, respectively (Williams 2018). Based on timing associated with
permitting requirements and engineering designs, construction could start in the second quarter of
2020 and would last about 2 years; however, Big River has not formally announced its schedule
(Williams 2018).

4.13.2.7 Waterway Improvement Projects
Several dredging and waterway maintenance projects were identified as having the
potential to contribute to cumulative impacts. Four of these projects are associated with the COE’s
ongoing maintenance efforts and include maintenance dredging of the BSC and turning basin, Port
Isabel, the Brazos Island Harbor (BIH) Channel, and the Gulf Intercoastal Waterway to facilitate
movement of vessels through these waterways (COE 2015). All of these projects, less the Bahia
Grande Channel Restoration, are currently underway or have recently been completed and similar
projects are expected to occur in the future as needed to maintain these waterways.
The Bahia Grande Estuary Channel Restoration project is part of a comprehensive

restoration plan and includes expansion of the Bahia Grande Channel from about 34 feet wide to
250 feet wide and was proposed in 2015. Dredged material, approximately 220,000 cubic yards,
would be placed in two new placement areas adjacent to the main channel. The existing channel
is located on the north side of the BSC, adjacent to the proposed Rio Grande LNG Project site.
The BND is investigating the need to modify the entrance to the BSC to provide greater
flexibility, accommodate the deeper draft of the largest vessels that transit the expanded Panama
Canal, and allow for safe navigation of deep draft vessels, especially in inclement weather. The
timing of these improvement activities is currently unknown.
The city of South Padre Island has a partnership with the COE to utilize dredged sand from
the Brazos-Santiago Pass to nourish the South Padre Island beach (via the South Padre Island
Beach Re-nourishment project). The COE is responsible for maintaining the Brazos-Santiago Pass
and the BSC and, through its partnership with South Padre Island, can repurpose some of the
removed sand for a beneficial use. The beach-quality sand retrieved during the dredging is along
the jetty channel, Brazos-Santiago Pass. This activity is about 7.1 miles northeast of the Annova
LNG Project site.
4.13.2.8 Other Projects and Activities Considered
Development of a commercial space launch facility, SpaceX, about 6.3 miles southeast of
the Annova LNG Project site, began in September 2014, and the first launch was anticipated as
soon as late 2018 (SpaceX 2014); however, launches are now expected to begin in 2019. A related
“Stargate Facility” would be located on a 2.3-acre parcel adjacent to the SpaceX facilities. The
Stargate Facility would accommodate a 12,000- square-foot research center, currently being
designed, where students and professors of the University of Texas, Rio Grande Valley can track
spacecraft (University of Texas Brownsville 2015). Construction of the facility began in 2016 and
would be fully operational in late 2018/early 2019 (University of Texas-Rio Grande Valley 2018).
United Fuel Supply submitted a rezoning application in 2014 to build a truck stop at FM 511 and
Paredes Line Road on approximately 14 acres of land. The rezoning from general retail to light
industrial was approved in 2014, but United Fuel Supply has not taken further action on the
development after the zoning was approved. Because we have not identified any further
information about this project, it is not considered reasonably foreseeable and is not further
considered in this assessment.

The U.S. Customs and Border Patrol proposed to develop a larger facility at the U.S.
Customs Highway 4 Fort Brown Checkpoint Station. The project has not been funded yet and has
been put on hold. As this project is currently unfunded, it is not further considered in this analysis.
The NPS and Palo Alto Battlefield National Historical Park developed an Integrated
Vegetation Management Plan in 2014 with the goal of restoring and maintaining the landscape
and vegetation within the battlefield for cultural and historic preservation (NPS 2016b). This effort
would be an ongoing effort on land that is about 13 miles northwest of the Annova Project site.
4.13.3 Potential Cumulative Impacts by Resource
The following sections address the potential cumulative impacts of the activities identified
within the geographic scope on specific environmental resources. Table 4.13.3-1 provides a
summary of cumulative impact for key resources where information is available.
4.13.3.1 Geologic Resources and Soils
The geographic scope for geologic resources and soils was defined as the area that would
be affected by, or immediately adjacent to, the Annova LNG Project. Other projects encompassed
by the impact area that may have impacts on geologic resources or soils include the non-
jurisdictional facilities associated with the Annova LNG Project where they occur adjacent to or
within the Project site. Large projects with ground-disturbance and excavation associated with
construction and permanent aboveground facilities would have the greatest impacts on geologic
resources and soils.
Projects that would be constructed in close proximity to one another, and require
evacuation or considerable grading, would generally have greater impacts on geological resources
and soils than projects with limited ground disturbance or those projects that are separated by time
and space. Therefore, the potential increase for erosion and impact on geological hazards would
be highly localized and limited primarily to the period of construction.

TABLE 4.13.3-1
Summary of Cumulative Impacts

Site Water Vegetation Socioeconomics Transportation
Upland Scrub/Shrub
Disturbance Area
Disturbance Area
Affected/Crossed
(Constructions)
Vehicle Traffic
(Construction)
(Construction)
(Construction)
Vessel Traffic
Vessel Traffic
Waterbodies
Employment
Employment
Project Area
(Operation)
(Operation)
(Operation)
Wetlands
vessels vessels
Map Number and Activity/Project acres acres acres No. acres acres No. of jobs No. of jobs trips per day per year per year
Annova LNG Project 731 491 412 1 58 224 700-1,200 165 2,000 36 80
Non-jurisdictional Facilities Associated with the Annova LNG Project
1. Natural Gas Interconnection U U U O 1.3 0.07 U U U U U
2. South Texas Electric Cooperative 100 U U 3 26.1 2.9 U U U U U
3. Potable Water Supply Pipeline 30 U U 1 6.3 0.5 U U U U U
20. Natural Gas Supply Lateral 110 110 49 1 42.1 6.4 U U U 0 0
LNG Facilities
4. Rio Grande LNG 1,148 1,100 770 O 236 U 2,950–5,225 270 4,750 180 312
5. Texas LNG (and pipeline) 652 420 334 1 254 87 700-1,312 110 1,454 109 75
Pipeline Facilities
21. Nueces to Brownsville Gas Pipeline U U U U U U U U 0 0 0
31. Rio Bravo Pipeline 3,094 U U 140 79 852 760 – 1,500 20 1,950 O O
34, 35. New Potable Waterline and Sewer 1 U U 6 U O U U U U U
Line in Cameron County
Electrical Transmission and Generation Projects
24. Tenaska Brownsville Generating Station 270 U U U O U 700 23 U U U
44. San Roman Wind Farm 156 U U 15 0 U 80 U U U U
43. Cameron Wind Farm (Apex Clean 10,243 U U O O O 90 U O O O
Energy Wind Energy Project)
23. Cross Valley Project 1,745 U U U 24 U U U U U U
32, 33. New Electric Transmission Line 142 U U 7 U 9 U U U U U
(American Electric Power) Phase 1 and 2
Palmas Atlas Wind Project 6,500 U U U U U 170 10 U U U
Palmas to E. Rio Hondo Transmission Line 73 U U U U U U U U U U


Upland Scrub/Shrub
Disturbance Area
Disturbance Area
Affected/Crossed
(Constructions)
Vehicle Traffic
(Construction)
(Construction)
(Construction)
Vessel Traffic
Vessel Traffic
Waterbodies
Employment
Employment
Project Area
(Operation)
(Operation)
(Operation)
Wetlands
vessels vessels
Transportation Projects
29. State Highway 32 (East Loop) U U U U U U U U U U U
28. South Padre Island 2nd Access Project U U U U U U U U U U U
39. SH 4 Upgrade Project U U U U U U U U U U U
37. Wildlife Crossings Along SH100 U U U U U U U U U U U
(between Share 27 Rd. and Palm Blvd)
38. Wildlife Crossings on FM 106 (Atascosa U U U O O O U U U U U
National Wildlife Refuge)
27. SH 550 Direct Connector Project U U U U U U 55 U U U U
30. Cameron County West Railroad U U U U U U U U O O O
Relocation Project
51. State Highway 48 Widening Project U U U 4 U U U U U U U
42. Rail Corridor Between the Port of U U U 3 U U U U U U U
Brownsville and Brownsville-South Padre
Island International Airport
45. FM 510, Texas Department of U U U O O O U U U U U
Transportation (FM 803 to FM 1847)
46. FM 510, Texas Department of U U U O O O U U O O O
47. FM 510, Texas Department of U U U 7 U U U U U U U
36. State Highway (SH) 48 Auxiliary Lane U U U 1 U U U U U U U
54. Airport Terminal U U U U U U U U U U U
Port of Brownville Projects
14. Brownsville Liquids Terminal Phase 1 U U U U U U 150 5 U U U
15. Brownsville Liquids Terminal Phase 2 U U U U U U U U U U U
17. Port of Brownsville Cargo Dock U U U U U U U U U U U


Upland Scrub/Shrub
Disturbance Area
Disturbance Area
Affected/Crossed
(Constructions)
Vehicle Traffic
(Construction)
(Construction)
(Construction)
Vessel Traffic
Vessel Traffic
Waterbodies
Employment
Employment
Project Area
(Operation)
(Operation)
(Operation)
Wetlands
vessels vessels
16. Centurion Brownsville Terminal 280 U U U U U Up to 500 35 U U U
Processing and Storage Facility
GEOTRAC Industrial Hub 1,400 U U U 81 U U U U U U
Big River Steel Mill 800 U U U U U U U U U U
Waterway Improvement Projects
7. Brazos Island Harbor Channel U U U 1 U U U U U U U
Improvement Project
6. Bahia Grande Estuary Channel U U U 1 U U U U U U U
Restoration
8. Dredging, BSC and Turning Basin U U U 1 U U U U U 140 140
9. Maintenance Dredging, Port Isabel U U U 1 U U U U U 140 140
10. Maintenance Dredging, Gulf U U U O O O O O U 140 140
Intracoastal Waterway
Other Projects and Activities Considered
18. SpaceX Commercial Spaceport 70 U U O 4 16 Up to 50 150 U U U
48. STARGATE Research Facility 2.3 U U U U U U U U U U
(University of Texas)
13. South Padre Island Beach U U U 0 O O U U U U U
Renourishment
53. Palo Alto Battlefield National Historical U U U O U U U U U U U
Park
TOTAL 27,547 2,121 1,231 194 812 1,198 --- --- --- --- ---
U=Unknown; NA=Not Applicable

Geologic Resources
Construction of the Annova LNG Project would permanently modify the topographic
contours present at the site. Projects occurring within the geographic scope include the non-
jurisdictional facilities associated with the proposed Project, consisting of the natural gas
interconnection (included within the overall facility footprint) and the STEC electrical
transmission line, and the potable water supply pipeline where they occur adjacent or within the
Project site. Within the geographic scope for cumulative impacts on geologic resources, these
non-jurisdictional facilities would likely require clearing and grading for construction. It is
anticipated that contours would be restored following the completion of construction of the
pipelines and electric transmission line. The BIH Channel Improvement Project would deepen the
BSC from -42 feet to -52 feet, which would also alter topographic contours near the proposed
Project. The BSC and Turning Basin Maintenance Dredging waterway improvement project
involves expansion of the channel from about 34 feet wide to 250 feet wide.
As described in section 4.1.3, the potential for impacts on or by the Project from a geologic
hazards perspective would be low. Hurricanes and/or storm surge are the geologic hazards with
the greatest potential to affect the Project. Annova LNG, Rio Grande LNG, and Texas LNG have
designed their respective facilities to withstand predicted maximum hurricane force winds and
storm surge. The non-jurisdictional facilities are not anticipated to exacerbate potential impacts
associated with a hurricane or storm surge; however, aboveground components, such as the electric
transmission lines, could be damaged. The deepening of the BSC associated with the BIH Channel
Improvement Project is not anticipated to affect storm surge during hurricanes or other large
storms; therefore, no cumulative impacts on geologic hazards would occur from this project (COE
2014). The risk of seismic hazards (earthquakes, faults), soil liquefaction, subsidence, and
landslides is low (see section 4.1.3 for detailed discussion).
Overall, cumulative impacts on geologic resources from construction and operation of the
Project and other projects identified in the geographic scope would primarily consist of permanent
modification to existing contours. No mineral resources would be affected by the Annova LNG
Project and potential effects associated with geologic hazards have been acceptably mitigated for
through facility design. Therefore, we have determined that the Annova Project, along with other
projects, would contribute to minor cumulative impacts on geologic resources.
Soils
Cumulative impacts on soils may occur when adjacent projects increase the area of soil
disturbance, resulting in greater potential for the adverse impacts identified above, or when
projects disturb the same area in succession. In the latter circumstance, soil disturbance may be
prolonged and revegetation delayed, so that soils are not sufficiently stabilized resulting in
increased potential for runoff and erosion. Non-jurisdictional facilities related to the Annova LNG
Project would be expected to have a similar effect on soil resources as the Project; however, the
impacts would be less due to the smaller size and scope of the projects. The BIH Channel
Improvement Project and the Bahia Grande Channel Restoration projects would also be located
adjacent to the Project site; however, because all activities would occur within the BSC or the
Bahia Grande Channel, no impacts on soils would occur. Impacts on sediments associated with
this project are also discussed in section 4.13.3.2.

The cumulative impacts of the Project on soils, when considered with other projects, would
be temporary (during construction of buried or temporary project components) to permanent
(within aboveground facility footprints), and moderate.
4.13.3.2 Water Resources
The geographic scope established for water resources is the HUC-12 watershed and the
underlying aquifers. Any projects listed in table H-1 in appendix H involving ground disturbance
or chemical use or storage within the HUC-12 watershed could result in cumulative impacts on
water resources, most likely through contamination by inadvertent spills. This includes the
majority of the current, proposed, and reasonably foreseeable projects, identified in table H-1 in
appendix H.
Groundwater
Cumulative impacts on groundwater may occur through construction activities, including

clearing and grading, dewatering, contamination through fuel and other hazardous material spills,
and groundwater withdrawal. Most of the potential impacts on groundwater resources associated
with the proposed Project would be short term and localized, primarily associated with clearing,
grading, excavating, filling, and placement of piles and foundations, with groundwater effects
limited to water table elevations in the immediate vicinity of the Project site. Most of the other
projects considered for cumulative impacts on groundwater would involve similar ground
disturbing activities that could temporarily affect groundwater levels near the projects.
Annova LNG would not directly withdraw groundwater during construction or operation
of the Project and would instead obtain water from the local utility; however, water sourced from
the local utility would include both surface water from reservoirs along the Rio Grande River and
groundwater from wells located west of Brownsville. Because the Brownsville Public Utilities
Board has stated that it has sufficient capacity to meet the construction and operational needs of
the LNG Terminal without affecting water availability for other uses, and no new groundwater
wells would be required for construction and operation of the LNG Terminal, the LNG Terminal
is not expected to affect the quantity of available groundwater. Proposed groundwater use is not
known for most of the other projects considered; therefore, a quantitative analysis of anticipated
groundwater withdrawals is not feasible. However, because groundwater is not the primary source
of potable water in the region, and the proposed Project would not directly withdraw groundwater,
cumulative impacts on groundwater are anticipated to be minor.
Annova would grade, excavate, add fill, and install foundations and underground utilities
near or adjacent to the BSC where groundwater is near the surface. These activities would have
localized and short-term effects on the shallow groundwater during construction, with effects
limited to water table elevations in the immediate vicinity of the site. Potential impacts on
groundwater recharge and elevations would be minimal due to the localized nature of the effects.
Shallow groundwater areas could be vulnerable to contamination caused by inadvertent

surface spills of hazardous materials (e.g., fuels, lubricants, and coolants) used during construction
and operation of the Annova LNG Project and other projects within HUC-12. However, Annova
would implement its project-specific Plan and Procedures, as well as its SPCC Plan, to minimize

the risk of occurrence and potential impacts. Groundwater impacts resulting from construction or
operation of the Project are not anticipated and, should they occur, would be localized and would
not affect other groundwater users. Therefore, the Project would not contribute to significant
cumulative impacts on groundwater with other projects in the geographic scope.
Surface Water
Several projects listed in table H-1 in appendix H could be under construction at the same
time as the proposed Project, including both of the other Brownsville LNG projects (Texas LNG
and Rio Grande LNG) and associated non-jurisdictional facilities, non-jurisdictional facilities
associated with the proposed Project, pipeline projects, electric transmission and generation
projects, waterway improvement projects, transportation projects, Port of Brownsville projects,
the Stargate Facility and other industrial developments. Thus, there is the potential for cumulative
impacts on water quality within the HUC-12 watershed if the proposed Project was constructed
during the same time period as these other projects or has overlapping operational effects.
In-water activities, such as dredging and open-cut pipeline crossing techniques have the
greatest potential to contribute to cumulative impacts on surface water resources. If dredging
associated with the proposed Project were to occur concurrently with other in-water activities,
especially those requiring dredging (Texas LNG Project, Rio Grande LNG Project, and waterway
improvement projects) adverse impacts on water quality associated with increased turbidity and
sedimentation could be exacerbated. Pipeline projects may also impact surface water resources
through increases of turbidity and sedimentation, if the waterbodies are crossed via an open-cut
crossing technique; however, these impacts are typically minor due to the short duration of in-
water activities and would be unlikely to reach the BSC. Further, it is anticipated that larger
waterbodies, such as the BSC, would be crossed via horizontal directional drill for pipeline projects
including the natural gas supply lateral, thereby avoiding direct impacts on the waterbodies.
Concurrent dredging of the proposed Project, Texas LNG Project, Rio Grande LNG
Project, and the BIH Channel Improvement Project, would result in the greatest cumulative
impacts on surface water resources. All of these projects currently have similar proposed
construction schedules that could overlap if all regulatory approvals and authorizations are
obtained as currently foreseen by the project proponents. Dredging associated with the proposed
Project would occur over an approximately 1-year period. It is anticipated that timelines for
dredging of the other LNG projects would be similar, though Rio Grande LNG anticipates up to 3
years. All three LNG projects are proposing to utilize hydraulic cutterhead dredges that would
minimize turbidity to the extent practicable; however, if conducted concurrently, dredging of the
Brazos Island Harbor Channel Improvement Project and the Brownsville LNG projects would
further contribute to cumulative increases in turbidity and sedimentation within the BSC. Further,
the concurrent dredging and thus concurrent placement of dredged material in confined dredged
material placement areas would also result in increased effluent discharge into the BSC. Increased
effluent discharge would likely result in increased turbidity and suspended solids in the vicinity of
the discharge structures.
Annova LNG evaluated the potential cumulative impact on sedimentation from dredging
during construction; this assessment considered the potential for contributions from the Rio
Grande LNG and Texas LNG Projects, as well as other projects occurring within the BSC. The
majority of expected sedimentation due to construction is attributed to the LNG projects, which

results in an estimated maximum sedimentation of 0.3, 0.4, and 0.2 inches for the Annova, Rio
Grande, and Texas LNG Projects, respectively. The Bahia Grande Channel Restoration Project
could also contribute an estimated 0.5 inch of additional sedimentation. The BIH Channel
Improvement project is not expected to result in long-term net sediment accumulation as the
purpose of the project is to deepen the main channel. During operation, although sedimentation
patterns may be affected by the LNG projects, overall accumulation is expected to be minor.
Increased accumulation during operation would be driven by any changes in hydrodynamic
characteristics associated with the BIH Channel Improvement Project, and would be limited to 0.4
inch within the main channel of the BSC.
Like the Annova LNG Project, each of the projects would be required to comply with water
quality standards and cumulative impacts on water quality would be temporary, with turbidity and
sedimentation levels returning to pre-dredging conditions following the cessation of dredging
activities. Therefore, the Annova LNG Project with other projects in the vicinity, would contribute
to minor to moderate, but temporary, impacts on water quality within the BSC.
The BIH Channel Improvement Project and the three Brownsville LNG projects may use
DMPA 5A for placement of dredged material during construction and maintenance dredging.
Preliminary analysis indicates that Port of Brownsville PA 5A would not have the capacity, even
if the perimeter containment levees were raised to the maximum effective/acceptable height, for
all construction- and maintenance-dredged material from the three proposed LNG projects.
However, alternative dredged material placement areas could accommodate some or all of the
material, and the final management of dredged material will be determined by the BND and COE,
in consultation with other federal, state, and local resource agencies.
Concurrent construction of other projects involving clearing, grading, or other earthwork

within the watershed may also increase the potential for cumulative impacts on water quality from
increased stormwater runoff. Several of the projects identified in table H-1 in appendix H would
require hydrostatic testing of storage tanks or pipelines. All project proponents would be required
to adhere to state and federal regulations regarding hydrostatic, construction, and industrial
stormwater and wastewater discharges. Compliance with these regulations by Annova and the
other project proponents, and implementation of BMPs in the Project-specific Plan and
Procedures, would minimize potential cumulative impacts on surface water resources from
stormwater runoff and wastewater discharges.
Surface water could be subject to contamination caused by inadvertent surface spills of

hazardous materials (e.g., fuels, lubricants, and coolants) used during construction and operation
of the LNG Terminal and other projects within the HUC-12 watershed. However, Annova would
implement its Plan and Procedures, as well as its SPCC Plan, to minimize the risk of occurrence
and potential impacts. Similarly, all projects considered in the cumulative impacts analysis for
surface water resources would likely use equipment and or materials that could be hazardous to
the environment in the event of a spill. However, it is anticipated that these projects would prepare
and implement spill prevention and response procedures to prevent spills of hazardous materials
from reaching surface water resources, as well as the measures to be implemented if such a spill
occurs. Therefore, overall cumulative impacts on surface water resources as a result of stormwater
runoff, hydrostatic test water withdrawals and discharges, as well as spills of hazardous materials
are anticipated to be minor and incidental.

Current vessel traffic in the BSC is estimated to be 1,059 vessels annually. The operation
of all three proposed Brownsville LNG projects would result in an increase in the number of large,
ocean-going vessels transiting the BSC (estimated to be about 511 LNG carriers per year
combined), which equates to a 48 percent increase in vessel traffic within the BSC. Other
industrial projects located along the BSC (i.e., the Port of Brownsville projects identified in table
H-1 in appendix H) are also anticipated to result in increased ship traffic within the BSC, although
the exact number of additional vessels is unknown.
Impacts on turbidity would be limited to the duration of each vessel’s transit time in the
BSC and would be greater for larger ships such as the LNG carriers. It is anticipated that the water
quality could return to baseline conditions once each LNG carrier docks or leaves the BSC.
Shoreline erosion would primarily occur while the LNG carriers or other large vessels requiring
the assistance of tug boats are maneuvering at each of the LNG terminals or other project docks.
Each of the three LNG projects has designed its facilities to minimize shoreline erosion through
placement of rock rip-rap along the shoreline, or similar measures. It is anticipated that other
projects along the BSC would implement similar measures to protect the shoreline. Each project
would also be responsible for maintaining the shoreline protection to prevent future erosion.
Further, the use of waterways by LNG carriers, barges, and support vessels during construction
and operation of the LNG Terminal would be consistent with the planned purpose and use of the
BSC, an active shipping channel. However, given the substantial increase in large vessel traffic
within the BSC related to the three Brownsville LNG projects, and other projects, it is expected
that cumulative impacts on surface water resources associated with shoreline erosion and turbidity
from increased vessel traffic would be persistent and moderate to significant throughout the life of
the projects, particularly along unarmored portions of the BSC and connected shallow waterbodies.
Increased vessel traffic would also result in increased cooling and ballast water exchanges.
Cooling water exchanges would result in minor changes in water temperature at the point of
discharge, but these impacts are not anticipated to extend beyond the immediate vicinity of the
vessel, with temperatures quickly returning to ambient temperatures. Therefore, cumulative
impacts on water quality as a result of cooling water discharges are anticipated to be minor. The
Coast Guard requires that all vessels carry out an open-ocean ballast water exchange prior to
calling at U.S. ports. Ballast water can affect water quality by discharging water that differs in
the physiochemical properties of the ambient water, including pH, salinity, and temperature.
Based on the anticipated volumes and frequency of ballast water discharge that would occur as a
result of the proposed Project, any changes in the physiochemical properties of water within the
BSC would be localized and negligible. Similarly, it is anticipated that ballast water and cooling
water impacts associated with LNG carriers calling on the Texas LNG and Rio Grande LNG
terminals would also be localized and minor. As the discharges of these vessels for each project
are generally not anticipated to comingle, cumulative impacts on water quality as a result of the
ballast and cooling water exchanges associated with the Project and other projects in the vicinity
are anticipated to be minor.
4.13.3.3 Wetlands and Vegetation
The geographic scope established for wetlands and vegetation is the HUC-12 watershed.
Projects that could potentially contribute to cumulative impacts on wetlands and vegetation include
the majority of the current, proposed, and reasonably foreseeable projects identified in table H-1

in appendix H. Other projects located within the geographic scope for wetlands and vegetation
resources that are included in the cumulative impacts analysis include the Rio Grande LNG Project
and associated non-jurisdictional facilities, Texas LNG Project and associated non-jurisdictional
facilities, non-jurisdictional facilities associated with the proposed Project, Valley Crossing
Pipeline, San Roman Wind Farm, Cross Valley Project, transportation projects, Port of
Brownsville projects, SpaceX Commercial Spaceport Project, Stargate Facility, and Palo Alto
Battlefield Cultural Landscape Restoration..
Wetlands
As described in section 4.4.2, construction and operation of the Project would result in the
temporary and permanent disturbance of 56 and 52 acres of wetlands, respectively. Wetlands that
would be affected by the Project include estuarine emergent marsh and palustrine emergent
wetlands. Most of these impacts would be to palustrine emergent wetlands. Annova had
developed a draft Conceptual Mitigation Plan, including a wetlands functional assessment, and is
consulting with the COE to finalize the wetland functional assessment and the compensatory
mitigation that would be required to offset cumulative impacts on wetlands.
The wetland impacts of the non-jurisdictional natural gas interconnection facilities are
included in the Project impacts. Construction of the three non-jurisdictional facilities would
impact about 75 additional acres of wetlands within the HUC-12 watershed.
As identified in table 4.13.3-1, several other projects in this area could contribute to
cumulative impacts on wetlands including both of the other Brownsville LNG projects (Texas
LNG and Rio Grande LNG) and associated non-jurisdictional facilities, non-jurisdictional
facilities associated with the proposed Project, pipeline projects, electric transmission and
generation projects, transportation projects, Port of Brownsville projects, and other industrial
developments.
Any of the other projects within the HUC-12 watershed that impact wetlands would
contribute incrementally to the impacts from the Annova LNG Project, including the other two
LNG projects. The Rio Grande LNG Project would permanently affect about 182 acres of
wetlands by converting them to uplands for the terminal and an additional 54 acres associated with
its non-jurisdictional facilities. Another 79 acres of wetlands would be affected by the associated
Rio Bravo pipeline. Similarly, the Texas LNG Project would permanently affect about 45 acres
of wetlands. Other projects considered for cumulative effects for which wetland impacts are
available include the SpaceX Commercial Spaceport (4 acres affected) and the Cross Valley
Pipeline Project (24 acres affected) and the GEOTRAC Industrial Hub Phases I and II (62 acres
and 19 acres affected, respectively).
Development of the Bahia Grande Estuary Channel Restoration project would expand the
Bahia Grande Channel, increasing tidal exchange and improving estuary function, and resulting in
positive cumulative impacts on estuarine wetlands within the HUC-12 watershed.
The total known wetland impacts associated with the other projects, as identified above
and in table 4.13.3-1, is about 812 acres, including the proposed Project impacts. The HUC-12
watershed has a total area of 234,353 acres. Based on National Wetlands Inventory data developed
by the FWS, approximately 49,220 acres of wetlands are present within the Bahia Grande-

Brownsville Ship Channel HUC-12 watershed; therefore, it is anticipated that, at a minimum,

approximately 1.6 percent of the wetlands within the watershed would be affected by the projects
considered in our cumulative impacts analysis.
Wetlands provide important ecosystem functions due to their ability to retain water,
minimizing flooding and improving water quality by filtering contaminants before reaching
surface waterbodies. Therefore, conversion of wetlands to uplands or developed land can affect
water quality, as well as flooding, within a watershed. Wetlands also provide valuable wildlife
habitat. Several of the projects identified in table H-1 in appendix H are not anticipated to result
in significant permanent impacts on wetlands. For example, the majority of pipeline and electric
transmission projects would only temporarily impact wetlands during construction. These types
of projects may result in a permanent conversion of cover type within wetlands such as forested or
scrub shrub to herbaceous; however, following completion of construction, areas affected by these
types of projects typically maintain their functionality as a wetland. In addition, all projects and
activities would be required to comply with the CWA by avoiding, minimizing, or mitigating
wetland impacts. Therefore, while the proposed LNG Terminal would contribute to cumulative
impacts on wetlands, along with other projects in the area, this impact would not be significant.
Vegetation
The geographic scope for vegetation and wildlife was determined to be the HUC-12
watershed. The projects listed in table H-1 in appendix H would disturb thousands of acres of
habitat. Projects with permanent aboveground facilities (such as the Brownsville LNG terminals),
wind energy projects, and roads would have greater impacts on vegetation than buried utilities,
which allow for restoration of vegetation following construction. Therefore, with the exception of
aboveground facilities and the permanent right-of-way, pipeline projects typically only have
temporary impacts on vegetation and wildlife. The majority of long-term or permanent impacts
are associated with vegetation clearing and maintenance of the pipeline right-of-way.
Construction and operation of the Project would temporarily and permanently impact
vegetation. About 407 acres of upland vegetation would be affected during construction of the
Annova LNG Project. Most of these impacts would be to the following vegetative communities:
South Texas: Loma Evergreen Shrubland; Gulf Coast: salty prairie; South Texas: Loma
Grassland/Shrubland; and Coastal: Sea Ox-eye Daisy Flats. Temporary workspaces would be
replanted with native grasses with the goal of restoring grassland/herbaceous wildlife habitat. No
state-designated rare, threatened, or endangered plants are known to occur on the Project site.
The non-jurisdictional facilities associated with the Project would contribute to cumulative
impacts on vegetation. The effects of the interconnection facility are included in this EIS with the
overall Project effects.
Several linear projects included in the cumulative impacts analysis extend outside of the
HUC-12 watershed, including the Valley Crossing Pipeline, Rio Bravo Pipeline, Cross Valley
Project, and South Padre Island Second Access Project. While information is available for the
total impacts associated with most of these projects, data is not presented for impacts within
individual HUC-12 watersheds (with the exception of the Rio Bravo Pipeline). Therefore, we
calculated the percent of the project impacts in the HUC-12 watershed based on the length of each
project within the watershed. We then applied this percentage to the total project impacts to

estimate the acres of vegetation that would be affected by each project in the HUC-12 watershed.
Overall, an estimated total of approximately 5,544 acres of vegetation would be affected

by the projects identified above within the Bahia Grande-Brownsville Ship Channel watershed
HUC-12. This accounts for approximately 2 percent of the total watershed area (234,353 acres).
Certain projects such as the South Padre Island Beach Re-nourishment and the Palo Alto
Battlefield Cultural Landscape Restoration are focused on maintenance or enhancement of the
natural environment; as such, these projects may result in positive effects on vegetation in the
geographic scope.
Vegetation plays an important role in an ecosystem, providing wildlife habitat, stabilizing

soils, assisting in drainage, and providing filtration of stormwater within the watershed. Removal
of vegetation can lead to loss or degradation of wildlife habitat, increased stormwater runoff,
decreased water quality, increased erosion, and increased flooding. In addition, the proposed
Project, Rio Grande LNG Project, and Texas LNG Project would all impact rare or unique plant
communities, including those associated with the loma landforms. While sufficient information
is unavailable to accurately quantify the extent that all projects considered for cumulative impacts
on vegetation would impact rare or unique plant communities, it can be reasonably assumed that
at least some of the projects, in addition to the FERC-regulated projects for which information is
available, would impact these resources.
All projects potentially contributing to cumulative impacts on vegetation would be required

to adhere to applicable federal, state, and local regulations regarding water quality, erosion control,
and construction within floodplains. In addition, most of the projects considered for cumulative
impacts on vegetation are located within the eastern portion of the watershed, where coastal
processes have a greater impact on the vegetation communities, as well as the soil characteristics
and revegetation potential. Due to dry weather conditions and saline soils characteristic of the
region, revegetation is anticipated to be difficult for the proposed Project, as well as most other
projects considered. However, linear utilities may be required to meet restoration requirements
per agency consultations. As discussed above, several of the projects considered for cumulative
impacts on vegetation consist of large industrial developments that would result in the permanent
loss of vegetation.
Due to the relatively large proportion of the HUC-12 watershed that would be affected by
the projects considered, as well as the low revegetation potential and presence of rare or unique
plant communities in the HUC-12 watershed, we have determined that the Project would
contribute to moderate cumulative impacts on vegetation with other projects in the geographic
scope.
4.13.3.4 Wildlife and Aquatic Resources
The geographic scope established for wildlife and aquatic resources is the HUC-12
watershed. Table H-1 in appendix H identifies numerous projects or activities within the HUC-12
watershed that could contribute to cumulative impacts on wildlife and aquatic resources.
Wildlife
Impacts on wildlife associated with the Annova Project include disturbance, loss, and/or

conversion of approximately 465 acres of wildlife habitat. In addition, direct mortality of less
mobile individuals such as small mammals, amphibians, or reptiles may occur during the initial
clearing and grading activities. Other impacts on wildlife include impacts from elevated structures
(bird strikes), construction and operation noise, facility lighting, and increased road traffic.
It is anticipated that most of the projects identified above that were considered for
cumulative impacts on wildlife would result in similar impacts as those described for the proposed
Project. The waterway improvement projects are anticipated to directly impact aquatic wildlife,
as further discussed below; however, the impact on other wildlife is anticipated to be more indirect,
likely associated with temporary increases in noise and light. As detailed in table H-1 in appendix
H, construction and/or operation of many of the projects identified above are anticipated to be
concurrent with the Project.
Habitat (vegetation) loss and conversion associated with the projects identified above
accounts for the primary direct impact on wildlife species. Increased development and loss of
habitat within the HUC-12 watershed would cause wildlife to either adapt to new conditions (in
the case of some generalist species) or relocate to undisturbed suitable habitat. Displacement of
wildlife could result in additional stress and increased competition in available habitats. Further,
the projects considered are located within bird migration routes. Development, construction
activities, and removal of habitat could require migrating birds to travel greater distances to locate
suitable stopover habitat or stop in less suitable habitat. Depending on the additional distances
traveled and/or quality of habitat found this could result in increased energy expenditure,
competition, and/or predation.
Alternatively, conservation and restoration projects, such as the Palo Alto Cultural
Landscape Restoration, and ongoing management and acquisition of National Wildlife Refuge and
state preserve lands, would have a positive cumulative impact on wildlife habitat. Conservation
of these areas in perpetuity ensures that no future development would occur. Thus, these areas
will continue to serve as suitable wildlife habitat in the area. Nevertheless, as discussed above,
given the number of large-scale developments in the area, cumulative impacts on wildlife habitat
(vegetation) are anticipated to be moderate.
Cumulative impacts on wildlife as a result of increased noise, lighting, road traffic, and
general human activity, would be greatest during the concurrent construction of the proposed
Project and other projects considered; however, due to operational noise and permanent facility
lighting associated with the three LNG terminals and several of the other projects that have
permanent facilities, permanent cumulative impacts would also occur. While portions of the HUC-
12 watershed are already developed and characterized by industrial activities such as those projects
closer to Brownsville, other areas such as the northern and eastern portions of the watershed,
including the proposed terminal site, are less developed (see figure 4.13.1-1). In general, projects
located in areas characterized by more extensive existing development are anticipated to have less
of an impact on wildlife than projects located in areas where there is less development. Wildlife
inhabiting developed areas is likely to consist of human commensal species or individuals that
have otherwise become acclimated to human activity.
Cumulative impacts on wildlife resulting from noise would be greatest during the
concurrent construction of the projects considered, but would also occur to a lesser degree during

operation. Quantitative cumulative noise impacts are further discussed in section 4.13.3.9. While
noise contributions from the proposed Project would not directly impact wildlife beyond the
geographic scope for cumulative noise impacts, an overall increase in noise associated with
projects located throughout the HUC-12 watershed could limit the available habitat not affected
by noise to which disturbed wildlife can relocate. Wildlife that cannot relocate away from noise-
emitting sources could be adversely affected by increasing stress levels and masking auditory cues
necessary to avoid predation or hunt prey and find mates.
Construction lighting requirements likely vary among the projects considered; however, it
can reasonably be assumed that several of the larger industrial projects, waterway improvement
projects, and transportation projects could require nighttime construction lighting. Most of the
projects considered are not anticipated to require operational facility lighting, with the exception
of the industrial developments (e.g., the proposed Project, Texas LNG Project, Rio Grande LNG
Project, the Port of Brownsville projects, and wind energy projects). Increased lighting can cause
more mobile wildlife such as migrating birds to become disoriented, and can increase predation
on prey species by making them more visible to predators. Artificial lighting can also adversely
affect wildlife behavior by causing individuals to avoid the area or alter sleep/activity patterns.
FERC-regulated projects would minimize impacts on wildlife as a result of lighting by
implementing project-specific facility lighting plans that incorporate the use of shielded, down-
facing lights, to the extent practicable (see section 4.6.1.2). Other facilities with federal permitting
requirements may utilize similar methods to minimize the impacts of lighting on wildlife.
Elevated structures such as storage tanks, communication towers, flares, wind turbines, and
transmission lines would also contribute to cumulative impacts on migratory birds. Annova would
minimize the likelihood of bird strikes and disturbance to birds by employing directional lighting
at the LNG terminal, following a lighting control plan, and by lowering construction crane booms
when not in use. Other projects with elevated structures and federal permitting requirements may
implement similar measures to minimize impacts on migratory birds; however, bird strikes with
elevated structures could still occur.
As discussed in section 4.6.1.2, occasional flaring could impact some migratory birds if
present during the event; however, we find that occasional flaring during operation would not
substantially impact migratory bird populations. Effects from occasional flaring associated with
the Texas LNG Project may result in additional impacts on migratory birds (the Rio Grande LNG
Project is proposing to use ground flares that reduce impacts on migratory birds). Texas LNG
would minimize flaring during the migration seasons, and for the Annova LNG Project we
recommend that Annova consult with the FWS and develop a Migratory Bird Plan.
Increased road traffic associated with the projects considered would result in cumulative
impacts on wildlife as a result of increased noise, light, and wildlife-vehicle collisions. The effects
of increased noise and light on wildlife are discussed above. However, wildlife in the area are
currently exposed to traffic along existing roads, and wildlife-crossing projects reduce the risk of
collision where they have been implemented. Further, the majority of workers would be travelling
to and from the project areas during daylight hours and, because the traffic associated with
construction and operation of the Project and other projects within the geographic scope would be
within the capacity of existing roadways, cumulative impacts on wildlife due to increased road
traffic would be minor to moderate.

Overall, cumulative impacts on wildlife would be greatest during the concurrent

construction of the projects considered, and would continue to a lesser extent during operation.
Cumulative impacts on wildlife would occur as a result of habitat disturbance and loss and
increased noise, light, and road traffic. While most projects considered are anticipated to
implement best management practices to ensure restoration of temporarily affected wildlife habitat
and minimize noise and lighting, we have determined that cumulative impacts on wildlife,
including migratory birds, would be moderate.
Marine Wildlife and Other Aquatic Resources

Impacts on marine wildlife could occur from construction and operation of the Project as
a result of dredging and excavating for the turning basin within the BSC and the adjacent marine
berth. Section 4.6.2.1 provides detailed information on marine mammals that could occur in the
BSC, including whales, dolphins, and manatee, though only the bottlenose and Atlantic spotted
dolphins are common. Five species of ESA-listed sea turtles also occur in the Project area, as well
as common fish and invertebrates, though the BSC supports little submerged vegetation, and
seagrasses that support commercially important fish and crustaceans are not expected to occur
there. Activities with the potential to affect fisheries also include hydrostatic testing of the LNG
tanks, additional vessel traffic in the BSC, discharge of ballast water, cooling water intake and
discharge, engine noise, stormwater runoff or spills, lighting, and noise from pile driving.
Construction of the marine facilities would permanently alter approximately 6 acres of currently
open water in the BSC. Direct impacts on fish resources would be limited to the BSC.
Impacts on marine wildlife associated with dredging include suspension of sediment and
increased turbidities, which can reduce feeding efficiency. Annova plans to use hydraulic cutter
dredges, which would reduce the potential for entrainment. Most aquatic species are mobile and
would be able to escape the dredge’s intake velocity. The Project impacts are expected to be short
term and minimal, with water quality returning to baseline conditions after construction activity.
Pile-driving during construction would be conducted mainly on the land, and the land would act
as a sound buffer reducing underwater noise in the BSC. Any pile-driving conducted in the water
would have minor sedimentation effects and would temporarily disturb any nearby marine wildlife,
causing them to relocate.
Vessel traffic in the BSC would increase temporarily due to transportation of construction
equipment, materials, and prefabricated modules to the Project site for construction. As described
in section 4.9, the BSC sees an average of 1,057 vessel calls per year, including river and ocean-
going vessels. The additional traffic from the Project represents up to a 3.4 percent increase in
vessel calls per year during construction and up to a 7 percent increase in vessel calls per year
during operation. Increased vessel traffic in the BSC and the Gulf Intracoastal Waterway could
pose an increased risk to marine species from vessel strikes. However, based on the relatively
small increase in shipping activity relative to the total shipping traffic occurring in the Gulf of
Mexico, the slower speed of the LNG carrier traffic, and because Annova would provide LNG
carrier captains with NOAA Fisheries’ recommended strike avoidance measures, the potential for
the Project to result in increased vessel strikes to marine mammals or sea turtles is discountable.
The Rio Grande LNG and Texas LNG projects also require dredging and pile-driving
activities that would impact marine wildlife and fish in the BSC. These projects would also
increase vessel traffic, with impacts similar to Annova’s vessel traffic impacts. If all three LNG

projects were constructed, a substantial increase in the number of large ocean-going vessels in the
BSC would occur, estimated to be about 511 LNG carriers per year combined (125, 312, and 74
vessels per year for the Annova LNG, Rio Grande LNG, and Texas LNG projects, respectively).
Although the slower speeds of the LNG carriers would reduce the potential for vessel strikes, the
opportunity would clearly increase if all three projects are operational.
Increases in turbidity and potential decreases in dissolved oxygen associated with dredging
could result in adverse effects to aquatic resources. Measures to minimize impacts during dredging
are summarized in section 4.6.2.2. The waterway improvement projects identified in table H-1 in
appendix H and the Rio Grande LNG and Texas LNG projects also require dredging table H-1 in
appendix Hand could contribute to cumulative impacts on marine wildlife and aquatic species in
the BSC. The improvement projects include the Bahia Grande Estuary Channel Widening, BIH
Channel Improvement Project, and maintenance dredging of the BSC. The maintenance dredging
for Port Isabel, and the Gulf Intracoastal Waterway would not impact the BSC. Maintenance
dredging of the BSC, the BIH Channel Improvement Project, and Bahia Grande Estuary Channel
widening activities would have impacts similar to those described for the Project. Impacts from
dredging activities that occur periodically would be short term.
Discharge of hydrostatic test water may cause localized, short-term turbidity in the BSC,
but potential impacts on aquatic resources would be localized and temporary. Ballast water
discharged by LNG carriers docked at the marine berth would have minimal effect on the salinity
regime, dissolved oxygen levels, water temperature, or pH in the BSC with temporary and minor
impacts on aquatic resources. Cooling water intake and discharge by LNG vessels would have
intermittent and minor effects on marine and aquatic resources, as would LNG carrier engine noise.
Implementation of NPDES regulations, Annova’s SPCC Plan, and its Plan and Procedures would
all reduce the potential for spills or impacts on the waterway; therefore, impacts on fisheries due
to stormwater discharge are expected to be negligible. In-water pile driving could have short-term,
temporary effects on fisheries during construction. Mitigation measures for noise-related effects
on fish would be determined based on consultation with NOAA Fisheries.
During operation, the three LNG projects would receive LNG carriers and while at the
LNG terminals the LNG carriers would withdraw and discharge water for engine cooling.
Withdrawal of cooling water would have direct effects on ichthyoplankton. Combined, engine
cooling water withdrawal by LNG carriers for all three projects would have a minor impact on
ichthyoplankton within the BSC.
The three linear non-jurisdictional facilities have the potential to impact the BSC by
temporarily disturbing soils during construction; however, with the implementation of appropriate
erosion and sediment control measures, these temporary impacts would be minimized. The natural
gas supply lateral would cross the BSC using HDD which would avoid direct impact on aquatic
habitat, fish, and marine wildlife.
Any of the other projects occurring within the HUC-12 watershed could impact aquatic
species in the BSC if they cause surface water quality impacts of great enough magnitude and
duration to adversely affect water quality in the BSC, though the likelihood of this diminishes with
distance. Aquatic species would most likely be affected by pipeline projects that can impact
surface water quality if the waterbodies are crossed via an open-cut crossing technique; however,

these impacts are typically minor due to the short duration of in-water activities. Further, it is
anticipated that larger waterbodies, such as the BSC, would be crossed via horizontal directional
drill for pipeline projects including the natural gas supply lateral and Valley Crossing Pipeline,
thereby avoiding direct impacts on aquatic species. We conclude that cumulative impacts on
marine wildlife and other aquatic species would be moderate as a result of the potential for
increased vessel strikes.
4.13.3.5 Special Status Species
The geographic scope for threatened and endangered species was generally determined to
be the HUC-12 watershed; however, due to the diversity in life history and range of threatened and
endangered species potentially affected by the proposed Project, cumulative impacts were
independently reviewed for each species. For example, threatened or endangered bird species are
more mobile with larger ranges when compared to terrestrial reptiles that may not extend beyond
a relatively small area. Discussions of cumulative impacts on threatened and endangered species
are grouped by taxa and are limited to only those threatened and endangered species identified in
section 4.7 as potentially affected by the proposed Project. Species that are not anticipated to be
present at the Project site, or otherwise affected by the proposed Project, due to a lack of suitable
habitat or species range, are not discussed further with regard to cumulative impacts.
Terrestrial Mammals
Ocelot and Jaguarundi
The geographic scope for cumulative impacts on the ocelot and jaguarundi was considered
to be terrestrial projects located within the HUC-12 watershed affected by the proposed Project.
Projects considered for cumulative impacts on the ocelot and jaguarundi include the Rio Grande
LNG Project and associated non-jurisdictional facilities, Texas LNG Project and associated non-
jurisdictional facilities, non-jurisdictional facilities associated with the proposed Project, Valley
Crossing Pipeline, San Roman Wind Farm, Cross Valley Project, transportation projects, Port of
Brownsville projects, SpaceX Commercial Spaceport Project, Stargate Facility, and Palo Alto
Battlefield Cultural Landscape Restoration.
The size and distribution of loma thornscrub in the Project area may support transient or
resident ocelots and the surrounding BND and FWS refuge properties outside the Project area
would likely provide additional protection and cover for this species. Moreover, the Project is
located within a region considered by the FWS as being an important component of the coastal
ocelot corridor connecting Texas and Mexico. This corridor is referred to by the FWS as the South
Texas Coastal Corridor. The FWS believes that this corridor is essential for the movement and
the genetic viability of the ocelot.
The Project would reduce habitat for ocelots and jaguarondi and could decrease the
effectiveness of the habitat linkage provided by the South Texas Coastal Corridor. Further, these
species could be struck by project vehicles or disturbed by increased human presence and artificial
lighting. To address effects on the South Texas Coastal Corridor, Annova proposes to maintain a
185-acre wildlife corridor along the western site boundary. While Annova has proposed measures
to minimize Project impacts on the ocelot and jaguarondi, we have determined that the proposed

Project is likely to adversely affect the ocelot and jaguarundi; however, consultations under
Section 7 of the ESA have not been completed (see our recommendation in section 4.7.3).
Not all of the projects listed above are anticipated to impact ocelot and jaguarundi habitat,
such as the Port of Brownsville projects, which are located within densely developed, previously
disturbed areas. In addition, the Highway 100 wildlife crossings project is intended to minimize
impacts from road traffic. The other two LNG projects, as well as the pipeline projects proposed
in the area, are anticipated to have the greatest impacts on ocelot habitat through removal and
conversion of habitats to industrial uses as well as fragmentation of existing habitats. In addition,
these projects along with several of the transportation projects could result in increased road traffic
and/or additional roads for transiting ocelots and jaguarundis to cross. Direct mortality as a result
of the projects considered in this cumulative impact analysis for ocelots and jaguarundi are
unlikely due to the mobility of the species; however, long-term impacts resulting from habitat
loss/fragmentation and the potential for subsequent reduced genetic diversity from inbreeding
could occur.
As discussed above, the past and continued development in and around Brownsville and
across the border in Mexico has decreased the available corridor habitat necessary to connect
ocelot and jaguarundi populations in Mexico and the U.S. While relatively small barriers such as
the BSC and SH 4 do not create a significant impediment to individual movements, ocelots and
jaguarundi require contiguous dense thornscrub for cover over longer distances (TPWD 2017b;
2017c). In addition, ocelots and jaguarundis are elusive species with relatively large home ranges
and low population densities that tend to avoid human development and activity (FWS 2010b).
The current remaining habitat corridor in the region to connect U.S. and Mexico populations is
located adjacent to and within the proposed Rio Grande LNG and Texas LNG sites north of the
BSC and within the proposed Project site south of the BSC. The area adjacent to the proposed Rio
Grande LNG Project site is a conservation easement that will not be developed in the future.
Annova LNG has been working closely with the FWS to configure their proposed project to reduce
potential impacts on ocelots and jaguarundis to the maximum extent practicable. This includes
maintaining an approximately 1,500-foot-wide corridor to the west of the Annova LNG terminal,
directly across from the existing wildlife corridor on the north side of the BSC.
While a travel corridor would be maintained to allow ocelots and jaguarundis to move
between Mexico and the U.S., the addition of three large industrial facilities in proximity to that
corridor (Annova LNG, Rio Grande LNG, and Texas LNG projects) would create additional noise,
light, and traffic, all of which could deter ocelots or jaguarundis from utilizing the corridor.
However, in an effort to minimize impacts as a result of increased light pollution on all wildlife,
including ocelots and jaguarundis, all three LNG projects have indicated that they would utilize
down-facing lights. Other impacts, such as those associated with noise, would be minimized by
the projects to the extent practicable; however, due to the proximity of the Project and Rio Grande
LNG Project to the wildlife corridors, facility-generated noise during construction and operation
would still be audible to ocelots and jaguarundis utilizing the wildlife corridor.
In addition, increased road traffic along SH 4 associated with the Annova LNG Project,
natural gas supply lateral, Valley Crossing Pipeline, SpaceX Commercial Spaceport Project, and
the Stargate Facility, as well as increased traffic along SH 48 associated with the proposed Project,
Rio Grande LNG Project, natural gas supply lateral, Valley Crossing Pipeline, and the Port of

Brownsville projects could result in increased potential for vehicle strikes on ocelots and
jaguarundis.
As described above, there is potential for the continued reduction of suitable ocelot and
jaguarundi habitat to a single, narrow corridor among industrial facilities. This loss, degradation,
and fragmentation of habitat have been cited by the FWS in its 2010 Recovery Plan, as the primary
threat to U.S. ocelot and jaguarundi populations. The further narrowing of this corridor could
result in decreased dispersal of individuals between U.S. and Mexico populations, resulting in
decreased genetic diversity. Further, the projects assessed for cumulative impacts on ocelots and
jaguarundis would result in an additional type of impact related to an increase of road traffic,
particularly during periods of concurrent construction (see table 4.13.1-1), which is the primary
cause of direct mortality on U.S. ocelot and jaguarundi populations (TPWD 2017b, 2017c). Due
to the past, present, and proposed future development throughout the geographic scope for
assessing cumulative impacts on ocelots and jaguarundis, as well as the associated increases in
road traffic, light, and noise, we have determined that past and present cumulative impacts on
ocelots and jaguarundis are significant and the future projects considered here will only increase
this impact.
Birds
Five bird species of concern have the potential to occur in the vicinity of the Project. These
include the federally listed northern Aplomado falcon, piping plover (and its critical habitat), red-
crowned parrot (candidate for federal listing), the red knot, and eastern black rail. As discussed in
section 4.7.1, we have determined that the Project would be unlikely to cause a trend towards
federal listing for the red-crowned parrot (candidate for listing) due to the lack of nesting habitat
at the Project site. The four federally listed or proposed birds with higher potential to use the
Project site are discussed further below.
The geographic scope for cumulative impacts on the northern Aplomado falcon was
considered to be terrestrial projects located within the HUC-12 watershed affected by the proposed
Project. Projects considered for cumulative impacts on the northern Aplomado falcon include the
Rio Grande LNG Project and associated non-jurisdictional facilities, Texas LNG Project and
associated non-jurisdictional facilities, non-jurisdictional facilities associated with the proposed
Project, Valley Crossing Pipeline, San Roman Wind Farm, Cross Valley Project, transportation
projects, Port of Brownsville projects, SpaceX Commercial Spaceport Project, Stargate Facility,
and Palo Alto Battlefield Cultural Landscape Restoration. Listed shorebirds are also discussed
here, however, only projects that affect their shoreline habitats are considered.
Approximately 186 acres of potentially suitable habitat for listed bird species would be
affected during construction and 147 acres would be affected during operation of the Project. Land
clearing could negatively impact some of the federally listed or candidate bird species by removing
suitable habitat, especially northern aplomado falcons that rely on larger plants to perch and nest,
such as yuccas. Loss of grassland and yuccas from within the Project site could result in loss of
habitat for the northern aplomado falcons. Listed birds could be further affected by Project noise,
lighting, and increased human activity and vehicle traffic. There is also potential that federally
listed birds could collide with the flare stack structures or the flares.

Because this species is highly mobile and typically departs at the approach of humans and
considering that Annova would implement measures to minimize effects, we have determined that
the Project may affect, but is not likely to adversely affect the northern aplomado falcon.
For the majority of projects considered, impacts on northern aplomado falcons are not
known; however, suitable habitat is also present on the Texas LNG and Rio Grande LNG sites and
would likely be crossed by the linear transmission and pipeline projects in the area, although the
Texas LNG and Rio Grande LNG projects have also determined that neither of these projects are
likely to adversely affect the norther aplomado falcon. In comments on the draft EIS the FWS
estimates that about 546 acres of suitable northern aplomado falcon habitat would be affected by
the three proposed LNG Projects. The other Port of Brownsville projects (not including the three
proposed LNG projects) are primarily located in an already industrialized area that likely does not
provide suitable habitat for northern aplomado falcons. The San Roman Wind Farm, LNG
projects, and overhead transmission line projects include elevated structures and wires that could
result in bird strikes, as well as injuries or mortality from flaring. These impacts would be similar
to those discussed in section 4.13.2.6 for migratory birds. Impacts on habitat associated with the
pipeline and transmission lines are anticipated to be temporary with construction areas restored
following the completion of activities. However, because of the past cumulative habitat loss and
Regarding listed shorebirds (piping plover and red knot), the other industrial development
projects considered, including the LNG projects and Port of Brownsville projects, are anticipated
to result in similar impacts to those of the Project. Although suitable piping plover and red knot
habitat would be permanently affected by the Project, only 1 acre of habitat would be removed.
The proposed Project, other LNG projects, and some of the Port of Brownsville projects, would
result in the permanent conversion of the existing shoreline habitat to industrial land; however, the
dredging of the Texas LNG marine berth would likely restore tidal flats north of the Project site,
potentially creating additional habitat for shorebirds. The projects considered would result in a
cumulative impact on piping plover and red knot, and eastern black rail; however, there is abundant
wintering habitat present throughout the southern Texas coast, including within the Laguna
Atascosa NWR, Lower Rio Grande Valley NWR, and the Los Lomas Ecological Preserve. Given
the availability of emergent wetlands in the vicinity of the Annova LNG Project, based on NWI
mapping, cumulative impacts on eastern black rails are not anticipated to be significant. We
conclude that cumulative impacts on bird species of concern would be less than significant.
Sea Turtles
Other projects considered for cumulative impacts on sea turtles are those that would
conduct activities within or otherwise affect the BSC. Projects considered for impacts on sea
turtles include the Rio Grande LNG Project, Annova LNG Project, Valley Crossing Pipeline,
natural gas supply lateral, four waterway improvement projects, and four Port of Brownsville
projects.
As discussed in section 4.7.1.3, we have determined that the proposed Project is not likely
to adversely affect sea turtles; however, consultations under Section 7 of the ESA have not been
completed (see our recommendation in section 4.7.3). Impacts on sea turtles associated with the
proposed Project are most likely to occur as a result of dredging and pile driving activities, as well

as increased vessel traffic during construction and operation. Annova has indicated that it would
implement measures designed to minimize potential impacts on sea turtles including conducting
the majority of pile driving from land, prior to dredging, utilizing a cutterhead suction dredge, and
providing all vessels associated with the Project guidance regarding measures to be implemented
to avoid vessel strikes. Based on the implementation of these measures, we have determined that
the proposed Project is not likely to adversely affect sea turtles; however, due to the concurrent
construction schedules and scopes of the other projects considered, cumulative impacts on sea
turtles would be likely to occur.
Impacts on sea turtles resulting from the other two LNG projects considered (Rio Grande
LNG and Texas LNG) would be similar to those discussed for the proposed Project, as would the
measures that would be implemented to minimize impacts. While the natural gas supply lateral
would cross the BSC, it is anticipated that the crossing would be conducted via HDD and would
not result in any direct impacts on the BSC. Therefore, these pipeline projects are not anticipated
to affect sea turtles. Completed Port of Brownsville projects would not overlap with construction
of the proposed Project; therefore, they would not contribute to cumulative impacts on sea turtles.
The GEOTRAC Industrial Hub consists of multiple parcels of land identified for future industrial
development, several of which are adjacent to the BSC. While development of these areas is
anticipated to be ongoing as future projects arise, it is unknown whether the development of any
of the parcels adjacent to the BSC would overlap with the Project. Similarly, the location and
schedule associated with the Big River Steel Mill is unknown. If development of these areas did
overlap with construction of the Project, impacts are anticipated to be similar, potentially requiring
dredging and/or shoreline stabilization, vessel traffic, and land disturbance. If constructed
concurrent with the Project, development of other parcels along the BSC that involve vessel transit
within the Gulf of Mexico as part of the GEOTRAC Industrial Hub or Big River Steel Mill, could
contribute to cumulative impacts on sea turtles.
Based on the biological opinion issued for the Brazos Island Channel Improvement Project,
dredging activities in the BSC utilizing hopper dredges routinely result in the direct mortality of
sea turtles (COE, 2014). While the COE would implement numerous measures to reduce sea turtle
mortality, such as pre-dredging trawls to safely remove sea turtles from the area, NOAA Fisheries
has conducted a jeopardy analysis and issued a take permit to the COE with limits on the number
of sea turtles that can be taken during dredging activities. It is anticipated that the other four
waterway improvement projects, all of which require dredging activities, would have the potential
to similarly impact sea turtles.
Publicly available information regarding the current anticipated schedules for the projects
discussed above indicate that it is possible that construction activities associated with several of
the waterway improvement projects and both of the other LNG projects would be concurrent with
the proposed Project. In general, sea turtles present in the area at the start of construction activities
are anticipated to relocate to nearby suitable habitat or avoid the area. However, the concurrent
construction activities within the BSC could limit the habitat available to which sea turtles could
relocate. For instance, a sea turtle startled into moving from one project area may relocate to
another project area, and so on until suitable habitat is found. During dredging activities in which
hopper dredges are used, such as the BIH Channel Improvement Project, this could cause sea
turtles to move into the dredging area that might otherwise have been avoided by the turtle.

Similar to the impacts discussed in section 4.13.2.6 for other wildlife species, increased
disturbance and searching for available habitat could result in increased stress and energy
expenditure for sea turtles. Further, increases in sedimentation and turbidity (see section 4.13.2.3)
as well as disturbance of benthic environments that serve as habitat for sea turtle prey species could
also result in cumulative impacts on sea turtles by reducing water quality and prey availability.
Concurrent pile driving and dredging activities could result in cumulative increases in
underwater sound pressure levels, as discussed in section 4.13.2.12. The only other projects
considered for which pile driving might overlap with the proposed Project are the other two LNG
projects. Both of these projects are anticipated to implement measures to minimize effects.
In addition to impacts on sea turtles resulting from construction activities, increased vessel
traffic associated with the LNG projects and anticipated to occur as a result of the Port of
Brownsville projects could also affect sea turtles in the area. Vessel strikes are a common cause
of sea turtle mortality; however, it is anticipated that most vessels would adhere to the NOAA
Fisheries Southeast Region’s Vessel Strike Avoidance Measures and Reporting for Mariners
(2008). Further, the BSC is an active vessel transit route to the Port of Brownsville and receives
over 1,000 ships per year (BND 2017). Therefore, the increase in ship traffic could increase the
likelihood of vessel strikes; however, this increase would be small due to implementation of
NOAA Fisheries’ guidance.
Based on the size and proximity of the projects considered, as well as the overlapping
construction schedules, a cumulative impact on sea turtles is anticipated to occur. All projects are
subject to the requirements of the ESA and are thus required to consult with NOAA Fisheries
regarding potential impacts on sea turtles. Through this consultation process, the projects
considered may be required to implement best management practices and/or other measures
recommended by NOAA Fisheries to minimize potential impacts on sea turtles. In some instances,
such as the BIH Channel Improvement Project, take of sea turtles may still be likely and NOAA
Fisheries would issue a take permit. In other cases, such as the proposed Project, implementation
of these measures may result in a determination that the project is not likely to adversely affect sea
turtles. Individually, the projects considered are anticipated to have minor impacts on sea turtles;
however, the density and nature of activities potentially occurring within the area would result in
moderate cumulative impacts on resident sea turtles; however, these impacts are not anticipated to
have population-level effects.
Marine Mammals
Whales
Other projects considered for cumulative impacts on whales (including the blue whale, fin
whale, sei whale, sperm whale, and Gulf of Mexico Bryde’s whale) are those that would include
large ocean-going vessels, such as LNG carriers, transiting in the open Gulf of Mexico. Projects
considered for cumulative impacts on whales include the Rio Grande LNG Project, Texas LNG
Project, and Port of Brownsville projects that would contribute to large vessel traffic.
As discussed in section 4.7.1.1, we have determined that the proposed Project is not likely
to adversely affect whales; however, consultations under Section 7 of the ESA have not been
completed (see our recommendation in section 4.7.3). Although no whale species are expected to

venture into the relatively shallow waters surrounding the Project, individual whales may be
subjected to strikes by LNG carriers transiting in the open Gulf of Mexico to and from the Project.
Although the whale species in the Gulf of Mexico vary in distribution, habitat, and behavior,
effects of the proposed Project are expected to be similar for any species of whale. Annova states
that up to 125 LNG carriers per year would visit the Project; however, the likelihood of collision
with a whale is low because whales are generally able to detect and avoid large vessels and Annova
would provide LNG carrier captains with NOAA Fisheries’ recommended strike avoidance
measures as described in Vessel Strike Avoidance Measures and Reporting for Mariners (revised
February 2008), which include vessel operators watching for and avoiding marine mammals.
Impacts on whales resulting from the other two LNG projects considered (Rio Grande LNG
and Texas LNG) would be similar to those discussed for the proposed Project and additive. During
operations, up to 80 LNG vessels would call on the Annova Project per year; about 312 and 75
vessels per year would call on the Rio Grande LNG and Texas LNG terminals, respectively. It is
anticipated that vessels calling on other Port of Brownsville facilities, including the Annova LNG
and Rio Grande LNG projects, would also comply with NOAA Fisheries’ measures to minimize
vessel strikes. Nevertheless, the three LNG projects would result in an increase in ship traffic by
about 722 vessels per year within the BSC during construction and 467 vessels per year during
operation, which would increase the likelihood of vessel strikes. However, the probability of any
whale encountering an LNG carrier in the open Gulf is low because whales are generally able to
detect and avoid large vessels and NOAA Fisheries and the Coast Guard provide educational
materials to vessel operators to increase awareness of whales in sensitive areas. Therefore,
cumulative impacts on marine mammals from increased vessel traffic is anticipated to be minor.
West Indian Manatee
Other projects considered for cumulative impacts on West Indian manatees are those that
would conduct activities within or otherwise affect the BSC. Projects considered for cumulative
impacts on West Indian manatee include the Rio Grande LNG Project, Texas LNG Project, Valley
Crossing Pipeline, natural gas supply lateral, four waterway improvement projects, and four Port
of Brownsville projects.
As discussed in section 4.7.1, we have determined that the proposed Project is not likely to
adversely affect the West Indian manatee; however, consultations under Section 7 of the ESA have
not been completed (see our recommendation in section 4.7.3). Impacts on West Indian manatee
resulting from the proposed Project could result from dredging and pile driving activities, as well
as increased vessel traffic during construction and operation. However, due to the rarity of
manatee occurrence in the Brownsville area, as well as the lack of suitable foraging habitat,
impacts are not anticipated.
Impacts on West Indian manatees resulting from the other two LNG projects considered
(Rio Grande LNG and Texas LNG) would be similar to those discussed for the proposed Project.
While the natural gas supply lateral would cross the BSC, it is anticipated that the crossing would
be conducted via HDD and would not result in any direct impacts on the BSC. Therefore, these
pipeline projects are not anticipated to affect West Indian manatee. In addition, most of the Port
of Brownsville projects considered were recently completed and would not overlap with
construction of the proposed Project. Therefore, the recently completed Port of Brownsville

projects are not anticipated to contribute to cumulative impacts on West Indian manatees. If
development of future Port of Brownsville projects overlaps with construction of the Project,
impacts are anticipated to be similar, potentially requiring dredging and/or shoreline stabilization,
vessel traffic, and land disturbance. If constructed concurrent with the Project, development of
other parcels along the BSC that involve vessel traffic within the Gulf of Mexico or within the
BSC as part of the GEOTRAC Industrial Hub or Big River Steel Mill, could contribute to
cumulative impacts on West Indian manatees.
Publicly available information regarding the current anticipated schedules for the projects
discussed above indicate that it is possible that construction activities associated with several of
the waterway improvement projects and both of the other LNG projects would be concurrent with
the proposed Project. All projects operating within the BSC are anticipated to implement measures
identified by FWS (see section 4.7.1.2) to minimize potential impacts on manatees. Due to the
rarity of the West Indian manatee and measures that would be implemented if a manatee were to
occur within the BSC, cumulative impacts are not anticipated to occur.
4.13.3.6 Land Use and Recreation, and Visual Resources
Land Use and Recreation

The geographic scope for land use and recreation areas for the Annova LNG Project was
determined to be Cameron County. The projects listed in table H-1 in appendix H would disturb
thousands of additional acres of land affecting a variety of land uses. The Texas LNG and Rio
Grande LNG projects and associated non-jurisdictional facilities, non-jurisdictional facilities
associated with the proposed Project, the Valley Crossing Pipeline, the San Roman and Cameron
Wind Farms, the Cross Valley Project, several transportation projects, all of the waterway
improvement projects, and the other large industrial projects identified in table H-1 in appendix H
have the most potential to contribute to cumulative impacts on land use and recreation areas.
Projects with permanent aboveground components (e.g., buildings), wind energy projects,
roads, and aboveground electrical transmission lines would generally have greater impacts on land
use than the operational impacts of a pipeline, which would be buried and thus allow for most uses
of the land following construction. Therefore, with the exception of aboveground facilities and
the permanent right-of-way, pipeline projects typically only have temporary impacts on land use.
The majority of long-term or permanent impacts from buried pipelines on land use are associated
with vegetation clearing and right-of-way maintenance.
As discussed in section 4.8, the Project site is located entirely on BND land designated for
industrial development, although it is currently undeveloped. As a result, the area that would be
affected by the Project includes open land (87 percent), non-forested wetlands (11 percent), barren
land (1 percent), and open water (1 percent). Construction and operation of the Project is not
expected to affect existing or planned residential or commercial land uses, restrict land use on
adjacent properties, or displace any residences or businesses, including the proposed SpaceX
vertical launch area or the STARGATE Research Facility, located approximately 6.3 and 4.3 miles
east-southeast of the Project, respectively.
The lands surrounding the Project site are largely undeveloped, providing a variety of
dispersed outdoor recreational activities, including fishing and bird/wildlife watching. There are

also designated recreation sites and facilities located in the Project vicinity. During construction,
some recreationists may experience short-term increases in levels of dust, noise, and traffic, as
well as visual impacts. Project construction and operation would not permanently affect access to
the majority of regional fishing locations in the waters in the vicinity of the Project site. During
Project operation, LNG carriers transiting the BSC to and from the Project site could potentially
impact recreational boaters as a result of delays.
During construction, non-jurisdictional facilities related to the Annova LNG Project would
be expected to have a similar effect on land use and recreation as the Project; however, the impacts
would be less due to the smaller size and scope of the projects. The STEC electric transmission
line servicing the Annova LNG Project would also be a new feature in an area that is currently
undeveloped. After construction, temporarily affected areas within the linear corridors would be
restored with vegetative habitat, though some vegetation may be converted from scrub-shrub to
upland grassland/herbaceous to prevent tree growth within the buried utility and gas pipeline
corridors.
Ongoing and recently completed projects, such as the San Roman Wind Farm (4,000
acres), the Cameron Wind Farm (15,000 acres), and the Palmas Altas Wind Project (>6,500 acres),
have contributed to the conversion of the land in Cameron County to industrial use; however, given
that the actual acreage of conversion within these facilities is minimal (i.e., the majority of land is
still able to be used for agricultural purposes), contributions to cumulative impacts on land use
from these projects would be permanent, but negligible, when considered with the total available
land in Cameron County. Construction of the Highway 100 Wildlife Crossings would be within
or adjacent to an existing roadway; therefore, contributions to cumulative impacts from
construction of these crossings would also be negligible.
If the Rio Grande LNG and Texas LNG projects are permitted and constructed, these
projects would convert additional land in Cameron County from the current land use to industrial
land. While cumulative impacts on land use would be permanent, these types of projects are
consistent with BND’s long-term plan for the Port of Brownsville and the BSC, which identifies
the area as intended for heavy industrial use. In total, the three Brownsville LNG terminals would
permanently affect about 1,573 acres of generally undeveloped land, including a mixture of
vegetated (herbaceous or scrub-shrub) and unvegetated land, 1,464 acres of which would be
permanently converted to developed land. Although we do not have project-specific land use
information for projects not under the jurisdiction of the FERC, we can estimate the total impact
of each project based on the length of the project and industry standards on the right-of-way width
for a given diameter pipeline. Assuming a construction right-of-way width of 125 and 150 feet,
respectively, the Valley Crossing Pipeline would impact about 2,546 acres of land and the Cross
Valley project would impact about 1,746 acres of land, of which about 751 and 867 acres,
respectively, would be in Cameron County; land crossed is assumed to be similar in cover type to
that crossed by the Rio Bravo Pipeline System. Similarly, the Rio Bravo Pipeline is anticipated to
affect about 1,357 acres, though not all of this would be in Cameron County. In addition, the
Palmas to East Rio Hondo Transmission Line is estimated to impact approximately 73 acres (based
on an assumed 100-foot-wide construction corridor) and the Big River Steel Mill would impact
800 acres. While the Project would be consistent with the BND’s long-term plan, construction
and operation of this and other projects would result in permanent changes in land use and would
contribute to a cumulative impact on land use in Cameron County.

Based on the information currently available for the other projects, the Rio Grande LNG
and Texas LNG projects, and their associated new pipelines and non-jurisdictional facilities, could
impact recreation and special use areas that would be in proximity to the Annova LNG Project.
Construction of these projects at the same time and at nearby locations as the proposed Project
would result in short-term cumulative impacts on the recreation and special use areas. However,
none of these recreation areas would be affected by the footprint of the proposed LNG facilities.
Further, given the existing inventory of recreation areas in Cameron County and their large
geographic area with multiple access points, cumulative impacts on recreation would be minor.
In summary, the Annova LNG Project would result in temporary and permanent impacts
on existing land use and short-term impacts on recreation areas. If other projects in Cameron
County are built at the same time as the proposed Project, cumulative impacts on land use and
recreation would be additive. However, certain projects such as the South Padre Island Beach Re-
nourishment, the Highway 100 Wildlife Crossings, and the Palo Alto Battlefield Cultural
Landscape Restoration are focused on maintenance or enhancement of the natural environment; as
such, these projects may result in positive effects on land use and recreation in Cameron County.
Overall, the cumulative impacts of the Project when considered with other projects would be
permanent and minor given the area of Cameron County (more than 800,000 acres) and the large
inventory of recreation areas with multiple access points. Further, the Project would be consistent
with BND’s long-term plan, which identifies the area as intended for heavy industrial use.
Visual Resources
The geographic scope for visual resources was considered to be the area within 5.1 miles
of the Annova LNG Project site, which was determined to be the farthest distance at which Project
impacts on a visual receptor or KOP would be moderate or greater.
Short-term impacts during construction would include the presence of equipment and
workers, the increase in construction related traffic (on land and in the BSC), and the installation
of large structures at the terminal sites. For land- and water-based mobile receptors, this impact
would be short, lasting only the duration of time for the vehicle or vessel to pass the site.
Visual sensitivity in the Project area is generally considered to be high because a large
proportion of the viewers in the area are there for recreation and leisure activities. Annova
evaluated 10 KOPs at representative visually sensitive areas, including areas used for recreation
and wildlife viewing, key travel routes, and other public gathering areas. Potential visual impacts
ranged from low to moderate, with the exception of the KOP at the SH 48 pull-off near Bahia
Grande Pilot Channel where impacts would be moderately high.
The towers and wires of the STEC transmission line would be visible and affect the visual
quality in portions of the area that are currently undeveloped. The natural gas and water supply
pipelines would be buried and not visible once installed. The natural gas interconnection facilities
would be on the Project site and not individually contribute to visual impacts.
Construction of the other two proposed LNG projects on existing undeveloped land on the
north side of the BSC would also contribute to changes in the visual quality in portions of the area.
The Rio Grande LNG Project would include four LNG storage tanks, combustion turbine stacks,
and flare stacks. The visual impacts would be greater than those described above for the Annova

LNG Project given the larger size and the location adjacent to SH 48. The Texas LNG Project
would include two LNG storage tanks and two flare stacks. Although the Texas LNG Project
would be smaller than the Annova LNG Project, the visual impacts could be greater than those
described above for the Annova LNG Project because the Texas LNG Project would be relatively
close to SH 48.
The five dredging activities identified in table H-1 in appendix H as overlapping with the
Project geographic scope for visual resources would use vessels in the BSC, usually for several
months during each dredging cycle. Dredging vessels would be visible to other vessels on the
BSC and from the Jaime J. Zapata Memorial Boat Ramp. However, visual impacts from these
dredging activities would be short term and negligible.
The Brownsville Liquids Terminal (Phase 1) is a completed liquids storage terminal that
includes a 10-railcar loading facility, a 4-bay rack, and 21 liquid storage tanks located on the north
side of the BSC near the turning basin in an area with similar existing facilities. Completion of
the Brownsville Liquids Terminal (Phase 1) contributes to the increased industrial character along
the BSC. The planned STARGATE facility would contribute additional changes to the visual
character and quality. The natural gas supply lateral and Nueces to Brownsville pipelines and the
gas pipelines associated with the other LNG projects would all be buried, and once constructed,
any visual impact would be limited to compressor stations and locations where the permanently
maintained pipeline right-of-way would cross wooded areas. The change in vegetation on the
pipeline rights-of way would have a minimal impact on the visual quality of the area.
Based on consultations with the NPS on the Palmito Ranch Battlefield NHL and the Palo
Alto Battlefield NHL, Annova examined potential visual impacts from the Project on these sites.
Visual simulations created from points located in proximity to the battlefields represent views of
visitors to the battlefields. The overall visual impact on the Palmito Ranch Battlefield NHL and
the Palo Alto Battlefield NHL KOPs would range from no effect or negligible in some areas to
moderate or moderately high in other areas, depending on varying degrees of distance, partial
screening, and foreground vegetation.
As multiple industrial facilities are constructed along the BSC and nearby, the visual
quality of the area would change from natural and partially developed to more industrial. Although
each project evaluated would be located within designated industrialized areas, and would be in
context with planned industrial development, the changes to visual quality would be apparent.
Views looking south or west from north of the BSC would generally be dominated by the Rio
Grande LNG and Texas LNG projects. For these views, the Project’s contribution to cumulative
aesthetic impacts would be minor. For views looking west, north, or east from south of the BSC,
and for views looking east from north of the BSC, the Project would be dominant or codominant
with the Rio Grande LNG and Texas LNG projects. For these views, the Project’s incremental
contribution to cumulative aesthetic impacts would be moderate to high.
The Annova Project would result in temporary, short-term, and permanent visual impacts.
If other projects visible from a common vantage point are constructed, cumulative impacts on the
viewshed would occur. The Project would result in a permanent change in the existing viewshed
for nearby visual receptors, in particular from the north along SH 48 and from the south along
SH4. The NPS filed a comment on the draft EIS that asserts that the cumulative impact on the

Palmito Ranch Battlefield NHL and Palo Alto Battlefield NHP would have significant impacts on
the visitor experience as a result of the construction and operation of the three Brownsville LNG
projects. Due to the relatively undeveloped nature of the Project area and the visual sensitivity of
nearby recreation areas including the Palmito Ranch Battlefield NHL, cumulative impacts on
visual resources, especially visually sensitive areas such as the Laguna Atascosa NWR to the north
and the Palmito Ranch Battlefield NHL to the south, would be the greatest.
4.13.3.7 Socioeconomics
Population and Employment

An average of 700 workers, of which 253 would be non-local, would be employed during
the 48-month construction period for the Project, with as many as 1,200 (including 780 non-local)
workers employed during the peak of construction. Non-local workers may temporarily relocate
to the region. Project-related construction impacts on the regional population would result in a
short-term, moderate increase to the local population, and Project operation would result in a
negligible, long-term increase. Operation of the LNG terminal would result in the creation of 165
permanent positions (see section 4.9).
Several of the projects listed in table H-1 in appendix H would also require construction
workers during the same period, most notably the Rio Grande LNG and Texas LNG projects. If
the three LNG projects were constructed concurrently, the construction labor requirements would
be highest during construction beginning in for the first four years when all three projects would
be under construction. Based on the average construction workforce, these projects would be
expected to employ about 4,350 construction workers in total and at peak construction the
combined workforces would be about 7,737 workers.
Following construction, the three LNG projects would result in the addition of about 545
workers. In addition to this direct employment, the projects would likely result in increased
indirect employment based on the purchases of goods and services. Collectively, the three LNG
terminals would spend an estimated $4.9 billion on direct expenditures. These expenditures and
workforce associated with construction and operation of the LNG projects would result in
cumulative positive, short-term and permanent impacts, respectively, on the local economy.
Other projects identified in table H-1 in appendix H would likely have staggered timelines
for specific labor needs, so some construction personnel working within the geographic scope may
be able to support multiple projects. This would have a cumulative effect of decreasing the overall
labor force required to meet the needs for all projects, however based on the size and types of these
other projects, as well as the temporary nature of construction, the overall impact would likely be
negligible. Finally, some of the projects identified in table H-1 in appendix H may not be permitted
and/or built, which would reduce the total labor need within the geographic scope of analysis.
The Annova LNG Project would reduce unemployment in the Project area and potentially
could result in the need to hire and train construction workers from outside the Project area to meet
the needs of all projects in the geographic scope. Positive benefits from the new jobs and workers
in the area would include increasing revenue for local business owners and generating new tax
revenue in the geographic scope of analysis. Expenditures and the workforce required for
construction of the Project, in combination with other projects in the geographic scope, would

result in temporary cumulative impacts during the construction period; operation of the proposed
Project and other projects would result in a positive, permanent impact on the local economy.
Housing and Public Services

The influx of non-local workers associated with construction of the Project would affect
the availability of housing in Cameron County. The cumulative impact on local housing may
result in increased rental rates and housing shortages if all the proposed and planned projects in
the geographic scope of analysis are implemented according to the expected timeframes. This
would benefit the local housing market but would adversely affect those seeking housing.
The combined construction workforces for the projects identified in table 4.13.3-1 would
increase the need for some public services, such as police, medical services, and schools. The
need for these services would generally be spread throughout the counties that house the workforce
for the projects, but there may be an increased cumulative need for medical and emergency services
in Cameron County where the three proposed LNG projects would be developed and associated
construction workers are expected to be concentrated. Annova would work directly with local law
enforcement, fire departments, and emergency medical services to coordinate for effective
emergency response at the Project site. Annova does not anticipate the need for additional local
emergency services and facilities during normal Project operations.
With construction of the three LNG terminal projects lasting several years, it is likely that
some non-local construction workers would relocate to the area with their families, including
school-age children. If all non-local workers associated with the Brownsville LNG projects were
to relocate to Cameron County with one school-aged child, approximately 7,200 additional
students could enroll in area schools. This would result in an estimated 5 percent temporary
increase in school enrollment. The addition of students would result in an incremental reduction
in the dollars per student invested in public schools. However, it is likely that those families would
be housed throughout many school districts in various counties and the increase in school
population would be distributed through many schools. The cumulative effect on schools would
be long-term, and moderate.
Based on the number of available rental units and motels/hotels in Project area, it is
anticipated that there would be sufficient housing available for the anticipated peak workforce for
the Annova LNG Project as well as the other two LNG projects. While the other LNG projects
may be constructed concurrently with the proposed Project, and non-local workers for these
projects are expected to find housing in similar areas, and specifically Cameron County, the county
has sufficient temporary housing to accommodate the influx of workers. Similarly, the increased
need for public services and school enrollment to support non-local workers and their families for
the Annova and other projects would be spread across the geographic scope. Further, with the
expected increase in local taxes and government revenue associated with the proposed projects,
we conclude that cumulative impacts on available housing and public services during construction
of the proposed Project would be temporary and minor. Operation of the Project would require
165 new full-time workers and would, with other projects in the vicinity, contribute to minor
cumulative impacts on housing resources and public services.

Land Transportation
Unlike other socioeconomic impacts that could occur throughout the two counties, land
transportation impacts would be more localized. For this reason, we considered a 15-mile radius
for the geographic scope in evaluating cumulative impacts on land transportation. During
construction and operation of the proposed Project and the other LNG terminal projects described
above and in table H-1 in appendix H, roadways in the area would experience a substantial increase
in daily vehicle trips as a result of material and equipment deliveries and commuting of
construction personnel to and from the LNG terminal sites. Due to staggered construction
schedules and the distance between the project sites for other projects identified in table H-1 in
appendix H, cumulative impacts on traffic from projects that are not located adjacent to the BSC
may be substantial at times, but are expected to be intermittent, short term, and localized.
Potential land transportation impacts were assessed by evaluating how construction and
operation of the Project would likely affect traffic volumes, circulation patterns, and Level of
Service (LOS, which is a qualitative measure of traffic flow) on roadways within the Project area.
The Project would increase traffic on several roadways and intersections during construction when
up to 2,000 vehicle trips would occur each day. The greatest impacts on roadway traffic from the
Annova LNG Project would occur on SH 4 and FM 511. Annova proposes to transport
construction workers to and from the construction site from a centralized location via passenger
buses to further reduce potential impacts and reduce potential delays at the Border Patrol
checkpoint on SH 4 (Boca Chica Boulevard).
The construction and operation activities of the Rio Grande LNG and Texas LNG projects
would also directly impact vehicle traffic. Roadways in the area would see a substantial increase
in daily vehicle trips as a result of material and equipment deliveries and commuting by
construction personnel. Because these two LNG projects are located on the north side of the BSC,
construction traffic accessing those sites from Brownsville would primarily use SH 48 and FM
511. The Rio Grande LNG Project proposes to reduce vehicle traffic using buses; however,
construction workers would use local roads to reach the parking and staging area for buses. Due
to the possibility of staggered construction schedules and the distance between the facilities,
impacts on traffic from construction would be substantial, short term, and localized.
We received a comment from the NPS on the draft EIS asserting that the cumulative impact
of the three LNG projects would result in cumulative impacts on traffic on SH 511 and SH 550,
which are also used to access the Palo Alto Battlefield NHP. If the three LNG projects were
constructed concurrently, the combined impact of construction traffic would be approximately
8,204 daily trips during active construction. This cumulative impact would result in increased wait
times and congestion on local roadways, including SH 48, SH 511, SH 550, and SH 100. Traffic
congestion could also impact access to business, residences, and visitor sites along SH 48 such as
the Jaime J. Zapata Memorial Boat Ramp. Wait times and congestion would return to near pre-
construction conditions during operation of the projects. The Annova LNG Project accounts for
approximately 14 percent of the estimated increase in vehicle trips.
Construction traffic for the three linear non-jurisdictional facilities may increase traffic on
many of the same roadways, including SH 48, SH 4, and FM 511. The spatial and temporal overlap
of the linear features with the Project is expected to occur over weeks or months at most. Due to
their relatively small size of construction overlap at any time, construction of the three linear non-

jurisdictional facilities and the Nueces to Brownsville pipeline would contribute negligibly to
cumulative impacts on vehicle traffic.
Most of the projects and activities listed in table H-1 in appendix H occur within 15 miles
of the Project and could contribute to cumulative impacts on vehicle traffic (excluding the dredging
or waterway improvement activities). Impacts would be greatest if construction of multiple
projects occurred concurrently. The commerce and industry activities identified in table H-1 in
appendix H as overlapping with the Project’s geographic scope for traffic would also increase
traffic conditions if the same local road network is used at the same time. However, several
infrastructure and transportation projects or activities would by design likely have a positive
impact on transportation once completed.
Based on the results of the commissioned studies for the proposed Project and other LNG
terminal projects, the Annova LNG Project and other projects would contribute to a moderate
cumulative impact on roadways during the construction period. The proposed Project would
contribute to a permanent but negligible impact on roadway transportation during operations,
because a relatively small number of new permanent employees would be required to operate the
Annova LNG Project facilities.
Marine Transportation
Only those projects or activities that could contribute to vessel traffic on the BSC were
evaluated for potential cumulative impacts. Projects or activities listed in table H-1 in appendix H
that could contribute to cumulative vessel traffic impacts on the BSC include the proposed LNG
projects and the seven dredging or waterway improvement projects.
Current vessel traffic in the BSC is about 1,059 vessels per year, which equates to an
average of about 88 vessels per month, including 61 barges (Port of Brownsville 2015b).
Construction and operation of the Annova LNG Project would result in an increase in marine
traffic in the area. During construction, the Project would generate up to 36 barge trips per year,
which represents an increase of about 3 percent of similar sized vessel calls in the BSC per year.
This represents a negligible incremental contribution to the vessel traffic. When combined with
deliveries associated with the construction of other reasonable foreseeable projects, concurrent
construction would noticeably increase the number of barges transiting the channel. Impacts on
other users of the waterway from barge traffic associated with construction would be consistent
with existing use of the waterway.
During operation, up to 125 LNG carriers would call on the Annova LNG Terminal per
year; about 312 and 74 LNG carriers per year would call on the Rio Grande LNG and Texas LNG
terminals, respectively. Because large vessel traffic in the BSC is one-way, and LNG vessels are
subject to a moving security zone during transit, LNG vessels in transit to the Annova LNG, Rio
Grande LNG, and Texas LNG projects could preclude other vessel traffic. To minimize impacts
on other users of the BSC, it is anticipated that vessels would follow required procedures including
the requirement to notify LNG terminal managers and relevant authorities of the expected arrival
of an LNG vessel in advance to ensure that the timing of LNG vessel channel transits are aligned
with other shipping schedules. The LNG vessels calling at the Rio Grande LNG and Texas LNG
terminals would be subject to similar requirements.

The LNG carriers, like other ocean-going vessels, would stage in the Gulf of Mexico until
directed to enter the BSC. This staging typically occurs as part of a port vessel traffic plan designed
to manage marine traffic and reduce delays. The total estimated corresponding annual delay time
for small vessels from the cumulative additional 511 inbound plus outbound LNG carrier trips
ranges from 12 to 35 percent of daylight hours per year. The Project’s 125 LNG carrier trips per
year would account for approximately 24 percent of this increase.
As previously described, construction of the Project and other projects are likely to
temporarily increase barge and support vessel traffic in the BSC. Concurrent construction would
likely result in a cumulative impact on vessel traffic in the waterway, primarily by increasing vessel
travel times due to congestion. During operations, LNG vessels calling on the Annova Project and
other LNG facilities along the BSC would have moving security zones that could preclude other
vessels from transiting the waterway. Prior notice of expected LNG vessel arrivals would
minimize impacts on other vessels. As a result, we conclude that there would be a moderate
cumulative impact on vessel traffic in the BSC during construction and operation of the Project.
Tourism and Commercial Fisheries

As discussed in section 4.9.2, the Annova LNG Project is not anticipated to result in
significant impacts on tourism or commercial fisheries, including the bait shrimp fleet that operates
from the Brownsville Boat Basin. Cumulative impacts on tourism would likely occur as a result
of cumulative impacts on recreation areas, visual resources, and traffic, all of which are discussed
in this section. Over 55 percent of visitors to the Brownsville-Harlingen MSA in 2014 participated
in beach activities. As the beach is directed away from the three Brownsville LNG terminals, this
activity is not likely to be affected by the projects. It would be speculative to predict how the
addition of the LNG projects would affect individual values and decisions of whether to visit
Cameron County. However, as discussed in section 4.13.3.6, the three Brownsville LNG projects
are anticipated to have a significant impact on visual resources from some recreational areas
including the Laguna Atascosa NWR, where two and possible all three terminals would be visible
from some locations. Although the land proposed to be developed for the three Brownsville LNG
projects are zoned for industrial use, the concurrent construction and operation of three large
industrial facilities as well as the associated non-jurisdictional facilities would result in a change
of the character of the landscape (see section 4.13.3.6). We can reasonably assume that this change
would cause some visitors to choose to vacation elsewhere or alter their future recreation activities,
if for example the tourists returned to the same location annually, to destinations in the region that
are farther from the project sites. As discussed further above, the concurrent operation of the three
Brownsville LNG projects would result in an up to 48 percent increase in vessel traffic transiting
the BSC annually. This increase would likely result in additional delays for commercial fishing,
including the shrimping industry, and recreational vessels that need to transit the BSC to reach the
Gulf of Mexico or fishing destinations in the Laguna Madre. Overall, we anticipate that
cumulative impacts on tourism and commercial fisheries would be permanent and moderate.
Environmental Justice
In section 4.9.9, we present the minority and low-income population percentages in the
State of Texas, Cameron County, and the corresponding census blocks groups (tables 4.9.9-1).
Because minority populations and low-income communities, as defined per the EPA guidelines,
are present in the geographic scope, they may be subject to cumulative impacts from the proposed

Project and other projects considered. The geographic scope for environmental justice was
determined to be those communities within 2 miles of the Project site because they would be the
most likely to experience effects from the Project due to proximity.
As discussed in section 4.9.9, the nearest residential areas associated with environmental
justice communities are about 2.3 miles from the proposed Project site. Although outside of the
geographic scope for cumulative impacts for environmental justice, individuals may experience
traffic delays, increased enrollment at public schools, and displacement of recreational fishermen
and other visitors to the public use areas near the Project site. These impacts would be minor and
short term, with the greatest impacts primarily occurring during construction.
Several of the projects listed in table H-1 in appendix H could contribute to potential
impacts on minority populations and low-income communities, most notably the Texas LNG and
Rio Grande LNG projects. Contractors working on these projects would be required to comply
with applicable equal opportunity and non-discrimination laws and policies. The criteria for all
positions would be based upon qualifications and in accordance with applicable, federal, state, and
local employment laws and policies. Like the proposed Project, tax revenues generated from
construction of these projects could be used to offset impacts on public schools and infrastructure.
Potential air pollutant emissions from operation of the proposed Project would be below
the threshold for unhealthy air quality. Other projects that are permitted and built would be held
to the same air quality standards. Therefore, the proposed Project’s contribution to cumulative
impacts on the low-income or minority populations in the Project area would be limited to minor
and temporary traffic delays and potential impacts on public schools during construction.
FERC and Annova LNG have made documents and notices about the Project available to
the public. FERC held public scoping and comment meetings, as described in section 4.9.9, during
which materials were provided in both English and Spanish to accommodate the local Hispanic
and Latino population. In addition, during the public scoping and comment meeting in Port Isabel
for the Rio Grande LNG, Annova LNG, and Texas LNG projects, both English and Spanish-
speakers were present to converse one-on-one with stakeholders in attendance. While one
environmental justice community has been identified just outside of the geographic scope for the
proposed Project, the Project impacts discussed in this EIS such as traffic delays during
construction, impediment of fishing/recreational opportunities at discrete locations, constraints on
public services, and impacts on air quality and noise would be the same for all communities,
regardless of race or income. Therefore, the proposed Project is not expected to contribute
discernable cumulative disproportionate, adverse effects on minority and low-income residents in
the area.
4.13.3.8 Cultural Resources
The geographic scope for cultural resources was determined to be the Annova LNG Project
site, access road, DMPA 5A, and a 0.5-mile area around the Project site. Eight other projects or
activities listed in table H-1 in appendix H would be within this geographic scope and could
contribute to cumulative impacts on cultural resources. Four of these would be located in the BSC
or on the opposite side of the BSC from the Project (Rio Grande LNG, Rio Bravo Pipeline, Bahia

Grande Estuary Channel widening, and BIH Channel Improvement projects). The projects within
0.5 mile of the Project site south of the BSC include the four non-jurisdictional facilities.
No archaeological or historic architectural resources listed in or eligible for listing in the

NRHP were identified that would be affected by the Project. A small portion of the Project has
not been surveyed for cultural resources but no other project overlaps with the footprint of the
Annova LNG Project site, therefore, we find that the Project would not contribute to cumulative
impacts on archaeological or historic resources.
The NPS provided a comment on the draft EIS asserting that the cumulative impact of the
three LNG projects would result in cumulative impacts on traffic on SH 511 and SH 550, which
are also used to access the Palo Alto Battlefield NHP. The NPS stated that the increase in traffic
on these roadways would adversely impact the quality and setting of the Palo Alto Battlefield NHP
by increasing noise and reducing air quality. We agree that concurrent construction of the projects
evaluated for cumulative impacts would increase traffic on area roadways, including those adjacent
to the Palo Alto Battlefield NHP. However, construction would be short term, lasting only several
years, and the workers are not expected to commonly use the same roadways.
Based on consultations with the NPS on the Palmito Ranch Battlefield NHL and the Palo
Alto Battlefield NHL, potential Project-related visual impacts would occur to these sites. Visual
simulations created from points located in proximity to the battlefields represent views of visitors
to the battlefields. The overall visual impact on the Palmito Ranch Battlefield NHL and the Palo
Alto Battlefield NHL KOPs would range from no effect or negligible in some areas to moderate
or moderately high in other areas, due to varying degrees of distance, partial screening, and
foreground vegetation.
4.13.3.9 Air Quality and Noise
Air Quality
Construction
The geographic scope for assessment of cumulative impacts on air quality during
construction of the Project is the area within 1.0 mile of the LNG terminal 51, because construction
emissions would be highly localized. 52 The projects within the construction geographic scope that
are most likely to contribute to cumulative air impacts include the Annova LNG and Texas LNG
Projects, non-jurisdictional facilities associated with the Rio Grande LNG Project, and waterway
improvement projects within the BSC.
Construction of the Annova LNG Terminal would affect air quality due to emissions from
combustion engines used to power construction equipment, vehicle emissions traveling to- and
from the LNG terminal site, marine deliveries of construction materials, and fugitive dust resulting
from earth-disturbing activities and equipment movement on dirt roads. Criteria, VOC, and HAPs
air emissions from projects in the vicinity of the Project would be additive.
51
Although the typical construction geographic scope for air quality is 0.25 mile, we expand this on a case-by-case
basis for large projects like LNG terminals.
52
GHGs have no localized impact.

General Conformity applicability thresholds do not apply at the LNG terminal site because
the Project area is in attainment for all the NAAQS. Table 4.13.3-2 estimates the total cumulative
emissions from concurrent construction of the Rio Grande LNG, Annova LNG, and Texas LNG
Projects. While estimates for construction emissions from non-jurisdictional projects and waterway
improvement projects within the BSC are not available, based on the intermittent and short-term
nature of construction, these projects would have a minor impact on cumulative air emissions when
considered with the proposed LNG terminals (including the Annova Project).
TABLE 4.13.3-2
Estimated Construction Emissions for the Brownsville LNG Projects

Emission Type (tons per year) a/,b/
Facility and
Year c/ NOx CO SO2 PM10 PM2.5 VOC
Rio Grande LNG Terminal
Year 1 12.0 18.6 2.0 589.4 60 0.7
Year 2 69.7 111.4 11.8 1,199.5 125.8 4.2
Year 3 127.8 174.3 23.5 1,146.6 125.8 6.4
Year 4 59.3 118.5 10.6 91.4 14.2 3.6
Year 5 45.0 106.7 8.0 56.1 9.2 2.9
Year 6 39.0 70.2 7.1 26.9 5.8 2.1
Year 7 1.2 10.4 <0.1 13.9 1.4 0.1
Year 8 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1
Annova LNG
Year 1 23 40 0.04 293 30 2.6
Year 2 172 220 0.3 158 25 22
Year 3 152 224 0.25 126 21 17
Year 4 131 202 0.22 65 14 13
Year 5 50 86 0.08 59 8 6
Texas LNG
Year 1 1.1 0.6 0.1 3.0 0.5 0.1
Year 2 62.3 35.9 4.2 177.7 28.7 4.0
Year 3 284.9 164.4 19.2 812.9 131.0 18.4
Year 4 397.9 229.6 26.8 1,135.3 183.0 25.7
Year 5 243.3 140.4 16.4 694.4 111.9 15.7
Year 6 31.9 18.4 2.2 91.1 14.7 2.1
Total Annual Construction Emissions
Year 1 36.1 59.2 2.14 885.4 90.5 3.4
Year 2 304 367.3 16.3 1,535.2 179.5 30.2
Year 3 564.7 562.7 42.95 2,085.5 277.8 41.8

Estimated Construction Emissions for the Brownsville LNG Projects

Emission Type (tons per year) a/,b/
Facility and
Year c/ NOx CO SO2 PM10 PM2.5 VOC
Year 4 588.2 550.1 37.62 1,291.7 211.2 42.3
Year 5 338.3 333.1 24.48 809.5 129.1 24.6
Year 6 70.9 88.6 9.3 118 20.5 4.2
Year 7 1.2 10.4 <0.1 13.9 1.4 0.1
Year 8 <0.1 <0.1 <0.1 <0.1 <0.1 <0.1
PA National Emissions Inventory, Cameron County d/
2008 9,366.2 52,511.8 107.0 32,165.8 4,371.8 28,884.9
2011 9,101.9 52,167.4 217.1 21,988.4 3,167.0 30,044.6
2014 7,864.3 43,352.9 82.0 11,023.3 2,340.3 24,701.4
a/ Emissions estimates include construction emissions from on- and off-road vehicle activity, truck deliveries, vessel activity,
worker commutes, and fugitive dust.
b/ RG LNG estimated annual fugitive emissions from use of the temporary haul road; to estimate annual construction
emissions, the total fugitive emissions were included for years 1, 2, and 3. In year 1, given that construction would not
commence until about 6 months into the year, annual estimated fugitive emissions from the haul road were assumed to
be half of those estimated for years 2 and 3.
c/ Assumes all three Brownsville LNG Projects would initiate emission-generating construction activities in 2020.
d/ Due to refinements and modifications in the methods used to compile each inventory, the inventory results should not
be used to describe year-to-year emissions trends.
Cumulative impacts from construction would be limited to the duration of the construction
period. However, with other projects in the vicinity, construction of the Annova LNG Project
would contribute to localized elevated emissions near construction areas during the period(s) when
construction of these activities would overlap. Due to the magnitude of the combined emissions,
the greatest potential for cumulative impacts would be during years 2 and 3 (see table 4.13.3-1).
When compared with the EPA’s most recently available national emissions inventory data, peak-
year (Year 3) cumulative construction emissions of NOx, SO2, PM10, and PM2.5, would represent
about 8.6, 61.6, 21.8, and 14.1 percent, respectively, of the 2014 inventory emissions levels.
The EPA’s national emissions inventory data include estimated emissions from on- and
off-road mobile sources (vehicle travel), point sources (such as electric power generation
facilities), and nonpoint sources (stationary sources that are individually small and numerous, such
as residential heating and commercial marine vessels; EPA 2014). Previous national emissions
inventories conducted in 2008 and 2011 documented greater total emissions for criteria pollutants
than the 2014 data; however, we have presented data from 2014 as a conservative estimate and to
present the most recent inventory data. Further, since the 2014 emissions inventory, economic
growth in Cameron County may have resulted in increased air emissions. Given the high level of
construction emissions estimated for the three LNG terminals relative to the most recently
inventoried emissions in the Project area, simultaneous construction of these projects could result
in a temporary, moderate to major increase in emissions of criteria pollutants during construction.
Construction emissions are localized, and impacts would be greatest in the immediate vicinity of
the LNG terminal sites.
Annova LNG, Rio Grande LNG, and Texas LNG would implement mitigation measures
to minimize construction impacts on air quality, including application of water to minimize

fugitive dust, limit engine idling, and using recent models of construction of equipment
manufactured to meet air quality standards. Further, transport of construction materials associated
with the Project could occur within the HGB area, which is a marginal nonattainment area for the
2015 8-hour ozone standard. Similarly, the Rio Grande LNG and Texas LNG Projects would also
receive deliveries of construction materials originating from or being transported through the HGB
area. Although cumulative emissions are not subject to General Conformity, the cumulative
construction emissions from the Annova LNG, Rio Grande LNG, and Texas LNG Projects
occurring within the HGB area would not be expected to result in an exceedance of applicable
general conformity thresholds for the HGB area.
Operation
Traditional air pollutants such as criteria pollutants, volatile organic compounds, and
hazardous air pollutants were listed for chronic and acute health impacts due to inhalation, as well
as secondary environmental effects. For these pollutants, we can consider a geographic scope for
cumulative impacts up to 50 kilometers.
GHGs were identified by the EPA as pollutants in the context of climate change. GHG
emission do not cause local impacts, it is the combined concentration in the atmosphere that causes
global climate (see Climate Change below) and these are fundamentally global impacts that
feedback to localized climate change impacts. Thus, the geographic scope for cumulative analysis
of GHG emissions is global rather than local or regional. For example, a project 1 mile away
emitting 1 ton of GHGs would contribute to climate change in a similar manner as a project 2,000
miles distant also emitting 1 ton of GHGs.
The Annova Project would be considered a minor source because its emissions would be
below regulatory thresholds defining major source emissions, thus, it is not subject to PSD review.
Modeling of emissions from the Project combined with background concentrations of air
pollutants demonstrates that the emission sources would not cause or contribute to an exceedance
of a NAAQS. Projects that are most likely to contribute to cumulative air impacts with operation
of the Project include the Rio Grande LNG and Texas LNG projects, non-jurisdictional facilities,
and waterway improvement projects. Rio Grande LNG would be a major source of air emissions
because it would exceed the regulatory thresholds defining major source emissions.
Operation of the Project would generate emissions from stationary equipment (e.g., heaters,
flares, oxidizers, and emergency generators) and mobile sources (e.g., LNG carriers and tugs,
personal vehicles). The region in the vicinity of the LNG terminal is currently in attainment with
the NAAQS; however, increases in industrial point sources could affect local and regional air
quality. During operation, stationary sources would not cause or contribute to an exceedance of a
NAAQS (see section 4.11.1.6).
Emissions from currently operational facilities, such as the Brownsville Liquids Terminal
and Port of Brownsville Marine Cargo Dock 16 and Storage Yard, are captured in ambient air
quality monitoring data. While estimates of construction emissions from non-jurisdictional
projects and waterway improvement projects within the BSC are not available, based on the
intermittent and short-term nature of construction, these projects would have a negligible impact
on cumulative air emissions if they are concurrent with operation of the Annova LNG Project.

To get a more refined cumulative impact analysis than a qualitative assessment at 50 km,
we assessed the air dispersion modeling results provided for the Annova LNG, Texas LNG, and
Rio Grande LNG Terminals and used these models to estimate the cumulative air emissions during
concurrent operation at all three facilities. Table 4.13.3-3 includes the modeled ambient pollutant
concentrations for the three Brownsville LNG terminals operating during full build-out, including
LNG carriers and support vessels operating during LNG loading at the terminal sites. The
estimated cumulative peak concentration is based on combining the predicted concentrations from
each project at each receptor location regardless of the time when is occurs. Since the timing and
location of the maximum predicted impacts from each terminal would differ, and because it is
unlikely that all three terminals would be loading LNG carriers simultaneously, the method used
to develop the peak cumulative concentrations is conservative.
Peak estimated concentration for criteria pollutants and averaging periods were compared
to the NAAQS, which represent standardized air quality criteria and were therefore used as a
benchmark for comparison against model results. For all pollutants, except for 1-hour NO2,
cumulative impacts are predicted to be below the NAAQS and would disperse before reaching
population centers in Port Isabel and Laguna Heights. Although estimated emissions for each
project individually would not exceed the NAAQS, for 1-hour NO2, the predicted maximum
cumulative impact is estimated to exceed the short-term NAAQS of 188 µg/m3. The predicted
peak cumulative impact, however, is located between the fence lines of the Rio Grande LNG and
Texas LNG terminals. This occurs because of the proximity of the two facilities to each other. It
is unlikely, but possible, that people may be exposed to the NO2 concentrations above the 1-hour
NAAQS, which would occur on property within the Port of Brownsville. Concentrations of 1-
hour NO2 in residential areas in Port Isabel and Laguna Heights are estimated to be below 75
µg/m3, which is well below the 1-hour NAAQS. While concurrent maximal operations of the
LNG facilities would result in increased concentrations of air pollutants in the immediate vicinity
of the facilities, the projects emissions are not expected to result in a significant impact on regional
air quality, nor would any exceedance of the NAAQS occur in a populated area.
While the cumulative ambient modeling assessment does not account for concurrent
construction, commissioning, and operations emissions, the greatest emissions from each LNG
terminal are associated with operations. We are aware that each LNG terminal could be
constructed within the same time period, and the concurrent construction, commissioning, and
operations emissions of the Annova LNG Project and the other proposed LNG terminals could
potentially exceed the NAAQS in local areas, and result in cumulatively greater local air quality
impacts. While these concurrent activities would result in greater ambient pollutant concentrations
than those presented in table 4.13.3-3, emissions levels would not be expected to result in a long-
term impact on regional air quality. Concurrent activities would be limited to the timeframe of
construction and commissioning and start-up.

TABLE 4.13.3-3
Peak Concentrations Estimated in Cumulative Air Dispersion Modeling for Stationary Source and LNG carriers for the Brownsville LNG Projects
Peak Concentration based on Modeled Results (µg/m3) b/
Background
Concentration a/ Rio Grande LNG Peak Cumulative NAAQS
Criteria Air Pollutant Averaging Period (µg/m3) Terminal Annova LNG Texas LNG Concentration c/ (µg/m3)
1-hour 2,175.5 276.1 247.9 470.6 2,746 40,000
CO
8-hour 1,259.5 174.0 101.7 83.4 1,453 10,000
1-hour 49.9 78.9 39.3 134.7 196 188
NO2
Annual 6.1 2.7 0.5 1.8 9 100
SO2 1-hour 10.6 2.0 3.8 10.3 23 196
PM10 24-hour 62.0 1.4 0.7 2.3 64 150
PM2.5 24-hour 22.9 1.3 0.7 2.0 25 35
Annual 9.1 0.3 0.1 0.1 9 12
a/ Background concentrations retrieved from tables 4-1 and 4-2 of the dispersion modeling report provided for the Texas LNG Project (available on FERC’s eLibrary website,
located at http://www.ferc.gov/docs-filing/elibrary.asp, by searching Docket Number CP16-116 and accession number 20170928-5165).
b/ Modeled impacts include stationary sources and LNG carriers at the LNG terminal sites.
c/ Peak concentrations predicted for each of the three projects for each receptor location were conservatively combined without regard to day or time of occurrence, and include
background concentrations. The peak cumulative concentration for each pollutant and averaging period does not equal the sum of the peak concentrations for each terminal
and background, since peak concentrations associated with each terminal occur at different locations.

In addition to operation of the LNG terminal and the vessel emissions described in section
4.11.1.3, air emissions from LNG carriers, considered mobile sources of air emissions, would
occur along the entire LNG carrier route during operations. These mobile sources would be
transitory in nature and emissions would occur over a large area; however, the cumulative ship
emissions would result in long term elevated emissions for the area. In summary, the Annova
LNG Project would result in temporary impacts on air quality during construction and long-term
impacts during operations. Cumulative impacts from construction would be limited to the duration
of the construction period. However, with other projects in the vicinity, construction of the Project
would contribute to localized moderate elevated emissions near construction areas during the
period(s) when construction of these activities would overlap.
Operational criteria, VOC, and HAPs air emissions from the Project would contribute to
cumulative emissions with other projects in the geographic scope and would be required to comply
with applicable air quality regulations. Therefore, cumulative impacts on regional air quality as a
result of the operation of the Annova LNG Project and other facilities would be permanent, but
minor. Due to the transitory nature of marine traffic associated with Project operation and the
large area covered, cumulative impacts on air quality along the carrier routes due to these
associated mobile source emissions would be temporary and minor.
Overall, impacts from the Annova LNG Project along with the other facilities would cause
elevated levels of air contaminants in the area and a potential exceedance of the 1-hour NO2
NAAQS in an uninhabited area between the facilities. Therefore, cumulative impacts on regional
air quality as a result of the operation of the Annova LNG Project and other facilities would be
long-term during the operational life of the Project, but minor. We are aware that each LNG
Terminal could be constructed within the same time period, and the concurrent construction,
commissioning, and operations emissions of the proposed Brownsville LNG terminals could
potentially exceed the NAAQS in local areas, and result in cumulatively greater local air quality
impacts. In addition, emissions from LNG carriers would occur along vessel transit routes and
would be cumulative with the other ships using the ship channel. These emissions sources would
be transitory in nature and emissions would occur over a large area, however the cumulative ship
emissions would result in long term elevated emissions for the area.
Climate Change
Climate change is the variation in climate (including temperature, precipitation, humidity,
wind, and other meteorological variables) over time, whether due to natural variability, human
activities, or a combination of both, and cannot be characterized by an individual event or
anomalous weather pattern. For example, a severe drought or abnormally hot summer in a
particular region is not a certain indication of climate change. However, a series of severe droughts
or hot summers that statistically alter the trend in average precipitation or temperature over decades
may indicate climate change. Recent research has begun to attribute certain extreme weather
events to climate change (USGCRP 2018).
The leading U.S. scientific body on climate change is the U.S. Global Change Research
Program (USGCRP), composed of representatives from thirteen federal departments and

agencies. 53 The Global Change Research Act of 1990 requires the USGCRP to submit a report to
the President and Congress no less than every four years that “1) integrates, evaluates, and
interprets the findings of the Program; 2) analyzes the effects of global change on the natural
environment, agriculture, energy production and use, land and water resources, transportation,
human health and welfare, human social systems, and biological diversity; and 3) analyzes current
trends in global change, both human-induced and natural, and projects major trends for the
subsequent 25 to 100 years.” These reports describe the state of the science relating to climate
change and the effects of climate change on different regions of the U.S. and on various societal
and environmental sectors, such as water resources, agriculture, energy use, and human health.
In 2017 and 2018, the USGCRP issued its Climate Science Special Report: Fourth
National Climate Assessment, Volumes I and II (Fourth Assessment Report) (USGCRP 2017 and
USGCRP 2018, respectively). The Fourth Assessment Report states that climate change has
resulted in a wide range of impacts across every region of the country. Those impacts extend
beyond atmospheric climate change alone and include changes to water resources, transportation,
agriculture, ecosystems, and human health. The U.S. and the world are warming; global sea level
is rising and acidifying; and certain weather events are becoming more frequent and more severe.
These changes are driven by accumulation of GHG in the atmosphere through combustion of fossil
fuels (coal, petroleum, and natural gas), combined with agriculture, clearing of forests, and other
natural sources. These impacts have accelerated throughout the end 20th and into the 21st century
(USGCRP 2018).
Climate change is a global phenomenon; however, for this analysis, we will focus on the
existing and potential cumulative climate change impacts in the Project area. The USGCRP’s
Fourth Assessment Report notes the following observations of environmental impacts are
attributed to climate change in the Southern Great Plains and South Texas regions (USGCRP 2017;
USGCRP 2018):
• the region has experienced an increase in annual average temperature of 1°-2°F

since the early 20th century, with the greatest warming during the winter months;
• over the past 50 years, significant flooding and rainfall events followed drought in
approximately one-third of the drought-affected periods in the region when
compared against the early part of the 20th century;
• the number of strong (Category 4 and 5) hurricanes has increased since the early
1980s; and
• global sea level rise over the past century averaged approximately eight inches;
along the Texas coastline, sea levels have risen 5-17 inches over the past 100 years
depending on local topography and subsidence.
53
The USGCRP member agencies are: Department of Agriculture, Department of Commerce, Department of
Defense, Department of Energy, Department of Health and Human Services, Department of the Interior, Department
of State, Department of Transportation, Environmental Protection Agency, National Aeronautics and Space
Administration, National Science Foundation, Smithsonian Institution, and U.S. Agency for International
Development.

The USGCRP’s Fourth Assessment Report notes the following projections of climate
change impacts in the Project region with a high or very high level of confidence 54 (USGCRP,
2018):
• annual average temperatures in the Southern Great Plains are projected to increase
by 3.6°–5.1°F by the mid-21st century and by 4.4°-8.4°F by the late 21st century,
compared to the average for 1976-2005;
• the region is projected to experience an additional 30 to 60 days per year above
100°F than it does currently;
• tropical storms are projected to be fewer in number globally, but stronger in force,
exacerbating the loss of barrier islands and coastal habitats;
• southern Texas is projected to see longer dry spells, although the number of days
with heavy precipitation is expected to increase by mid-century; longer periods of
time between rainfall events may lead to declines in recharge of groundwater,
which would likely lead to saltwater intrusion into shallow aquifers and decreased
water availability; and
• sea level rise along the western Gulf of Mexico during the remainder of the 21st
century is likely to be greater than the projected global average of 1-4 feet or more,
which would result in the loss of a large portion of remaining coastal wetlands.
It should be noted that while the impacts described above taken individually may be
manageable for certain communities, the impacts of compound extreme events (such as
simultaneous heat and drought, wildfires associated with hot and dry conditions, or flooding
associated with high precipitation on top of saturated soils) can be greater than the sum of the parts
(USGCRP 2018).
The GHG emissions associated with construction and operation of the Project are described
in section 4.11. Construction and operation of the Project would increase the atmospheric
concentration of GHGs in combination with past, current, and future emissions from all other
sources globally and contribute incrementally to future climate change impacts.
Currently, there is no universally accepted methodology to attribute discrete, quantifiable,

physical effects on the environment to Project’s incremental contribution to GHGs. We have
looked at atmospheric modeling used by the EPA, National Aeronautics and Space Administration,
the Intergovernmental Panel on Climate Change, and others and we found that these models are
not reasonable for project-level analysis for a number of reasons. For example, these global
models are not suited to determine the incremental impact of individual projects, due to both scale
and overwhelming complexity. We also reviewed simpler models and mathematical techniques
54
The report authors assessed current scientific understanding of climate change based on available scientific
literature. Each “Key Finding” listed in the report is accompanied by a confidence statement indicating the
consistency of evidence or the consistency of model projections. A high level of confidence results from “moderate
evidence (several sources, some consistency, methods vary and/or documentation limited, etc.), medium consensus.”
A very high level of confidence results from “strong evidence (established theory, multiple sources, consistent
results, well documented and accepted methods, etc.), high consensus.”
https://science2017.globalchange.gov/chapter/front-matter-guide/

to determine global physical effects caused by GHG emissions, such as increases in global
atmospheric CO2 concentrations, atmospheric forcing, or ocean CO2 absorption. We could not
identify a reliable, less complex model for this task and we are not aware of a tool to meaningfully
attribute specific increases in global CO2 concentrations, heat forcing, or similar global impacts to
project-specific GHG emissions. Similarly, it is not currently possible to determine localized or
regional impacts from GHG emissions from the Project.
Absent such a method for relating GHG emissions to specific resource impacts, we are not
able to assess potential GHG-related impacts attributable to this project. Additionally, we have
not been able to find any GHG emission reduction goals established either at the federal level 55 or
by the State of Texas. Without either the ability to determine discrete resource impacts or an
established target to compare GHG emissions against, we are unable to determine the significance
of the Project’s contribution to climate change.
Noise
The geographic scope for construction noise typically includes other identified projects
within 0.25 mile of the Project. However, due to the duration of construction and similar timelines,
we have included the Texas Grande LNG and Annova LNG projects in this cumulative
construction noise impact analysis (described further below). Cumulative noise impacts on
residences and other NSAs are related to the distance from the disparate noise sources as well as
the timing of each noise source. Projects within the construction and operational noise geographic
scopes are identified in table H-1 in appendix H.
The geographic scope for operational noise from long-term projects includes any facilities
that can cause an impact at NSAs within 1 mile of the Project. The Texas LNG and Rio Grande
LNG projects have been included in the cumulative effect impact assessment, as well as other
existing and proposed projects in the area.
After construction is completed for the non-LNG projects, including the gas and water
pipeline projects, power line projects, channel improvements and maintenance dredging, and road
projects, there would be minimal operational noise impacts. Therefore, these projects are not
expected to have any significant long-term operational cumulative impacts.
Construction noise from the non-jurisdictional facilities associated with the Rio Grande
LNG and Texas LNG projects is expected to be localized and limited in duration and would occur
on the opposite side of the BSC from the Annova LNG Project. These projects are small compared
to the scope of the proposed three LNG projects, and are generally linear activities with
construction moving through the length of the right-of-way with limited durations near any given
location. These projects are not expected to occur within 0.25 mile of any of the Project NSAs;
therefore, the construction activities associated with the non-jurisdictional facilities are not
expected to result in cumulative noise impacts at NSAs.
Maintenance dredging and channel improvement activities would result in periodic small
increases in the sound level impacts due to operation of dredging equipment. Sound levels from
55
The national emissions reduction targets expressed in the EPA’s Clean Power Plan and the Paris climate accord
are pending repeal and withdrawal, respectively.

the maintenance dredging are not expected to cause a significant impact at the NSAs.
The SpaceX Commercial Spaceport Project, located approximately 6.3 miles southeast of the
Project, anticipates rocket launches starting as soon as late 2018. Once they commence, commercial
spaceflight launches would be a significant noise source at the NSAs. However, spaceflight launches
are not expected to cause a significant cumulative environmental noise impact because they are short-
duration events lasting only a few minutes from start to finish, they are typically scheduled during the
daytime, and each launch would be well publicized, so nearby residents would be ready for the short-
term intense noise of the rocket launch. During the launches, noise from the launch would dominate
the sound levels at the nearby residences and low-frequency noise would likely cause noise-induced-
structural vibration. Project-related noise contributions would not be significant during this brief
period because the sound field would be dominated by launch noise.
As significant cumulative noise impacts are not expected from the non-LNG projects
considered, as discussed above, the cumulative assessment for noise impacts focuses on the two
other LNG projects in the planning and permitting stages in the general vicinity of the Project: the
Texas LNG and Rio Grande LNG projects. The potential cumulative noise impact of these three
LNG projects has been evaluated for construction and facility operations, for both airborne and
underwater sound. Construction noise impacts would be cumulative only if construction activities
occur simultaneously. Given the current schedule for the three Brownsville LNG projects, it is
likely that there would be some overlap in construction activities because of the long duration of
construction for the three projects. For the purposes of this analysis, we have assumed that peak
construction of all three projects would overlap; however, the construction phases may not
coincide, so maximum construction sound levels may not occur at all projects simultaneously.
Construction – Airborne Noise
Construction activities for the three LNG projects would be similar and would include
heavy equipment operation, pile driving, dredging, and other activities such as those described in
section 4.11.2.3. To evaluate the potential cumulative impact of construction activities, basic
sound propagation calculations were used to estimate the combined construction sound levels at a
set of standardized NSAs and calculation point (CP) locations. The process is summarized below
and described in greater detail in appendix I.
The standardized NSA and CP locations were selected using the common NSAs for each
of the three proposed projects. NSAs and CPs in close proximity were combined into single
representative NSA or CP positions for the cumulative analysis. Three CP locations were included
for each project: the Palmito Ranch Battlefield (CP-1), a central CP location (CP-2) in the Laguna
Atascosa National Wildlife Refuge (LANWR), and at the location in the LANWR at the closest
approach to the given LNG project. CP-1 and CP-2 were the same for all projects.
In order to quantify the highest sound level contribution from each project in the LANWR,
the closest location in the LANWR for each of the projects was specified as a calculation point.
Each was given a unique designation for each project: CP-TX, CP-AN, and CP-RG for Texas
LNG, Annova LNG, and Rio Grande LNG projects, respectively. Each project reported the project
operations sound level contribution at the project-specific CP. These three CPs have not been used
to calculate impacts in the cumulative tables; rather, they are presented separately for each project

to indicate the highest expected project sound level contributions in the LANWR for operations
noise. A list of the standardized NSAs and CPs is presented in table 4.13.3-4. A map showing the
location of the standardized cumulative NSAs and CPs is shown in figure 4.13.3-1.
Cumulative effects of construction noise were analyzed by combining the predicted

construction sound levels for each project. Each of the three LNG projects used a slightly different
methodology for calculating construction noise impacts. These variations were normalized during
the cumulative assessment process, and all predicted values were compared on an Ldn basis (day-
night average sound level). For those cumulative NSAs at which the construction noise had not
been calculated by a project in their FERC application, a hemispherical spreading calculation was
used to estimate the construction contributions based on reported construction sound levels at other
NSAs. The existing ambient sound levels for each NSA, as reported in table 4.13.3-4, was
determined by using the lowest measured ambient level at a corresponding project NSA for the
three projects. For example, if the measured ambient sound level at NSA C2 differed among FERC
applications for the three projects, the lowest ambient sound level reported was used as the ambient
for the cumulative analysis. The source of ambient sound level data is provided in table 4.13.3-5.

Figure 4.13.3-1 Cumulative Impact NSAs and Calculation Point Locations

TABLE 4.13.3-4
Standardized NSAs and Calculation Point Locations for Cumulative Noise Analysis
NSA Location Coordinates
Laguna Heights neighborhood, Lincoln Ave. 26.077312°
NSA C1
and Pennsylvania Ave. -97.249653°
Residences, Mobile home park, on Port Rd., southeast of 26.067031°
NSA C2
Woodys Ln. -97.217732°
26.063153°
NSA C3 Residences, Northwest end of West Scallop
-97.208717°
25.993437°
NSA C4 Residences, Weems Rd. and LBJ St.
-97.182485
25.965084°
NSA C5 Residences, North end of 199, north of Boca Chica Blvd.
-97.245563°
25.952706°
NSA C6 Residence located east of Palmito Hill Rd. on private drive
-97.289272°
CP Locations Coordinates
25.959536°
CP-1 Palmito Ranch Battlefield
-97.303490°
26.028053°
CP-2 Laguna Atascosa NWR, Calculation Point
-97.265482°
CP-AN,
CP-TX, Laguna Atascosa NWR, Closest location to given Facility Varies
CP-RG a/
____________________
a/ The CP-AN, CP-TX, and CP-RG points represent the locations of the highest sound level contribution from each
individual facility in the nearby LANWR. These are reported for operational effects only.
TABLE 4.13.3-5
Summary of Cumulative LNG Construction Impacts at Standardized NSA and CP Locations, All Levels are dBA Ldn
Predicted Construction Sound Level Contributions a/ Predicted
Combined Increase
Rio Grande Texas Cumulative Existing Ambient Ambient plus over
Location Annova LNG LNG LNG LNG Ambient Data b/ Cumul. LNG Ambient
NSA C1 49.0 49.2 50.3 54.3 56.0 AN NSA 1 58.2 2.2
TX NSAs
NSA C2 47.1 43.1 54.9 55.8 50.2 56.9 6.7
1&2
NSA C3 46.8 42.7 54.6 55.5 50.2 TX NSA 3 56.6 6.4
NSA C4 48.0 46.7 46.0 51.8 46.0 AN NSA 2 52.8 6.8
NSA C5 54.0 47.9 44.2 55.3 46.0 AN NSA 2 55.8 9.8
NSA C6 49.8 46.0 41.7 51.7 46.0 AN NSA 2 52.8 6.8
CP-1 52.0 39.9 41.6 52.6 43.0 AN NSA 4 53.1 10.1
TX
CP-2 56.9 48.7 59.0 62.1 2.7
51.0 58.4 LANWR
a/ The bold values highlight the highest individual LNG facility contributions, as used in table 4.13.3-6.
b/ The existing ambient sound levels shown are the lowest reported levels at project NSAs near the standardized NSAs.
AN = Annova LNG, RG = Rio Grande LNG, and TX = Texas LNG.
There was some variation in the assumptions included in the three projects for construction
activities. For example, Annova LNG assumed 24-hour construction activities while Rio Grande
LNG and Texas LNG used 12-hour daytime shifts for general construction and pile driving, and
24-hour operations for dredging. These assumptions were carried into the cumulative assessment.
Annova LNG and Texas LNG reported construction sound levels as 24-hour Ldn values, while Rio
Grande LNG reported construction contributions as daytime Leq. In order to directly compare the

construction sound level contributions, the sound level metrics were standardized to the 24-hour
Ldn and the reported sound levels for Rio Grande LNG were adjusted to the 24-hour Ldn. In
addition, the pile driving noise was estimated using Leq and Ldn, not Lmax.
Table 4.13.3-4 shows the individual project and cumulative construction noise
contributions of the three LNG projects at the NSAs and CPs. The individual sound level
contribution predictions from all construction activities are lower than 55 dBA Ldn at all NSAs.
However, the cumulative construction sound level from the three projects ranges from 51.7 to 55.8
dBA Ldn, and exceeds 55 dBA Ldn at NSAs C2, C3, and C5. The cumulative sound levels are also
expected to exceed 55 dBA Ldn at locations in the LANWR, with cumulative sound levels at CP-
2 of 58.4 dBA Ldn. Construction sound levels would be expected to exceed 55 dBA Ldn at locations
in the LANWR within about 0.75 mile of SH 48. The predicted increase in the ambient sound
levels would range from 2.2 to 9.8 dBA at the NSAs, and from 3.1 to 10.1 dBA at the two CP
locations. An increase of greater than 10 dBA is typically perceived as a doubling of loudness. In
addition, we have estimated that nighttime pile-driving noise could exceed acceptable levels.
The evaluation above is a very conservative estimate of the potential cumulative impact of
construction noise because it combines the maximum and simultaneous construction sound levels
from the three projects. This would require that all three project schedules align so that pile
driving, dredging, and site preparation occur at full intensity at the same time. To obtain a more
realistic and likely evaluation of the construction impact, an incremental analysis was made by
comparing the increase in sound level at each NSA and CP due to only the highest predicted
individual project contribution to the additional increase due to the other two projects. This
analysis shows the potential cumulative impact of all three projects compared to the most
significant single project. The impacts derived from this analysis represent a more likely scenario
in which the three project construction schedules do not align exactly.
Table 4.13.3-6 shows the incremental effect of cumulative construction noise at each NSA
and CP, compared with the highest predicted individual project contribution affecting each NSA.
This table shows that cumulative construction noise causes an incremental increase of between 0.7
and 2.7 dB at the NSAs and CPs, compared to the highest individual project construction noise.
NSA C4, with an increase of 2.7 dBA Ldn, shows the largest cumulative effect. A 3 dB increase
is generally considered perceptible to most people, so the cumulative impact of construction noise
at NSA C4 would be considered perceptible. At other NSAs, the cumulative increases are 1.5 dBA
Ldn or lower and would generally be considered imperceptible. At these NSAs, due to the distance
between the projects, the closest construction activity sound levels would typically dominate the
acoustical environment at the NSA. Thus, as indicated previously, we determined that typical
cumulative construction noise would not be construction
The sound levels at the project-specific CPs during construction were an Annova LNG
contribution of 60.6 dBA Ldn at CP-AN, a Rio Grande LNG contribution of 48.7 dBA Ldn at CP-
RG (based on 12-hour per day construction and 51.7 Lmax dBA), and a Texas LNG contribution of
63.5 dBA Ldn at CP-TX. This demonstrates that construction sound levels in the Laguna Atascosa
NWR would be dominated by contributions from Texas LNG.

TABLE 4.13.3-6
Calculation of the Incremental Impact of Cumulative LNG Construction Noise at Standardized NSA and CP Locations,
Measured as dBA Ldn
Increase over Ambient
Highest Individual Highest Due to only the Single Additional Increase
Existing LNG Construction Contribution Plus Highest LNG Caused by Cumulative
Location Ambient a/ Contribution Ambient Contribution Construction Noise
NSA C1 56.0 50.3 57.0 1.0 1.2
NSA C2 50.2 54.9 56.2 6.0 0.7
NSA C3 50.2 54.6 55.9 5.7 0.7
NSA C4 46.0 48.0 50.1 4.1 2.7
NSA C5 46.0 54.0 54.6 8.6 1.2
NSA C6 46.0 49.8 51.3 5.3 1.5
CP-1 43.0 52.0 52.5 9.5 0.6
CP-2 59.0 56.9 61.1 2.1 0.6
a/ The existing ambient sound levels shown are the lowest reported levels at project NSAs near the standardized NSAs.
See table 4.13.3-5 for the data source.
Construction – Vessel Traffic
During construction of the three LNG projects, the area would experience an increase in
noise due to marine traffic delivering construction supplies. The Texas LNG Project is not
anticipated to contribute significantly to the cumulative noise impact because only a small amount
of the anticipated construction supplies would arrive via barges or ships (109 deliveries over the
5-year construction period). Rio Grande LNG estimates that barges would make 880 marine
deliveries to the Project site during construction. Marine deliveries to the Rio Grande LNG site
would occur about 15 times per month during the first 5 years of construction; no deliveries are
currently anticipated during the remainder of the construction period, though sporadic deliveries
could occur as needed. Annova estimates that a total of 24 to 36 barge deliveries to the project
site per year would be required during construction. If these construction periods overlap, the total
expected construction barge traffic is approximately 20 visits a month, or one barge visit every 1.5
days. This is only slightly more than the one barge visit every 2 days estimated for the Rio Grande
LNG Project, and the cumulative effects would not be significant.
Construction – Underwater Noise
Underwater noise would be produced by construction activities including in-water pile

driving and dredging, and increased vessel traffic associated with equipment delivery. Cumulative
impacts for underwater construction noise would be limited due to the large distance between the
various project marine facilities.
The marine facilities closest to each other are the proposed Texas LNG and Rio Grande
LNG facilities, with a center to center distance of about 4,400 feet. As an example of the distance
effects, underwater pile driving sound levels would be expected to decrease by 32 decibels re 1
µPa at a distance of 4,400 feet compared to reference levels at 32 feet. The LNG sites are so far
apart that pile driving activities at any single facility would have a limited cumulative effect on
underwater noise at locations close to either of the other construction areas.

Due to the short impulsive nature of pile driving noises, it is very unlikely that the peak
sound pressure levels from multiple pile drivers would occur at exactly the same instant, so there
would be no increase in the predicted pile driving peak sound pressure levels. Rather, the number
of pile driving events would increase due to the multiple active construction areas.
At locations midway between two active pile driving projects, the sound exposure levels
would be expected to increase during simultaneous pile driving activities. The threshold distances
for permanent and temporary injury for marine mammals, fish, and sea turtles would not be
expected to increase significantly in size. However, during simultaneous pile driving at the three
projects, the behavioral disturbance area for most species would increase. In some cases, the
behavioral disturbance distances for some marine wildlife and fish for the projects would overlap
and would likely encompass much of the BSC and increase the total continuous behavioral
disturbance areas. Cumulative impacts on aquatic resources as a result of underwater noise are
discussed further in sections 4.13.3.4 and 4.13.3.5.
As a mitigating factor, the expected durations of the marine pile-driving activities for the
three projects are limited. Annova LNG expects to perform in-water pile driving over the course
of 5 days. Texas LNG plans to drive only 12 piles in-water. Rio Grande LNG expects that marine
pile-driving would be required for sheet piling, which is anticipated to occur over 25 days and for
installation of four in-water piles, which would take 4 days. Due to the long construction schedules
for the projects, and the limited duration of in-water pile driving, it is unlikely that there would be
significant overlap in the in-water pile driving schedules. Even with complete overlap in pile-
driving activity schedules, there could possibly be only 4 days in which all three projects would
be driving (non-sheet) piles.
Dredging activities at all three projects would have the potential to produce underwater
noise. The proposed dredging activities would be far enough apart that generally there would be
no cumulative impacts expected for underwater dredging noise for species other than mid-
frequency cetaceans. However, the BSC is an active waterway that already has ongoing and
regular maintenance dredging activities. The additional construction dredging activities associated
with the projects is not expected to be significantly different than the existing maintenance
dredging and is not expected to cause a significant cumulative underwater noise impact in the BSC.
Operations – Airborne Noise
To consistently analyze the potential cumulative impact of airborne operational noise from
the three proposed LNG projects, the noise models for each project were used to predict the sound
levels due to facility operation at the standardized NSAs and at the three CPs located close to
points of interest. The methodology behind the noise model development for the Annova LNG
Project is presented in section 4.11.2 of this EIS. The methodology for the other two LNG projects
is described in their FERC Applications. Generally, each project used three-dimensional
environmental noise modeling software to predict the sound levels from the respective project
equipment. To combine the sound level predictions for operational noise, each project submitted
the noise model results in a standardized grid format as outlined in the August 10, 2017
Environmental Information Request issued for the Annova LNG Project. The standardized grid
results used the same spacing and nominally the same boundaries. The grid maps were overlaid
and logarithmically summed and the overall cumulative impact of operations noise from the three

projects was calculated. Figure 4.13.3-2 shows the predicted sound levels as 24-hour Ldn values
for the three projects in simultaneous operation at full project completion. In addition to the grid
map results, predicted operations sound levels were calculated by each project for the cumulative
NSAs and CP locations described in table 4.13.3-4. The predicted sound levels were
logarithmically summed for the cumulative NSAs and for CPs 1 and 2.
Each project also reported predicted sound levels at the location in the LANWR closest to
the project, with these unique CPs labeled as CP-TX, CP-RG, and CP-AN, for the Texas LNG,
Rio Grande LNG, and Annova LNG, projects respectively. These project specific calculation
points were used to evaluate the highest predicted individual project sound level in the LANWR.
Cumulative sound levels were not calculated for these points as the levels were predicted by each
project for only that respective project CP.
Table 4.13.3-7 presents a summary of the predicted operation sound levels at the
cumulative NSA and CP locations for each of the individual LNG projects. As shown in this table,
the expected increases in the sound levels at the standardized NSA locations range from 0.3 to 1.5
dB. These are very small increases and would be considered imperceptible to most listeners. The
small difference in the overall cumulative increases and those increases predicted for each separate
project is due to the large distances between the noise generating equipment at the project sites,
and the small impact of the more distant projects to the overall sound levels at each NSA location.
Sound levels at CP-1, representing the Palmito Ranch Battlefield NHL are predicted to
have a cumulative increase of 1.3 dB, which would be imperceptible for most listeners. At CP-2
in the LANWR, the sound level impact is somewhat higher, with a predicted cumulative increase
of 4.8 decibels and an overall cumulative sound level of 62 dBA Ldn. As shown on figure 4.13.3-
2, there would be areas in the LANWR in which the cumulative sound levels exceed 55 dBA Ldn.
The predicted sound levels in the LANWR are generally dominated by contributions from the Rio
Grande LNG facility.
TABLE 4.13.3-7
Cumulative Operational Noise Impacts from LNG Facilities

Predicted Sound Level Contributions, dBA Ldn
Combined Predicted
Annova Rio Grande Texas Cumulative Existing Ambient Data Ambient plus Increase
Location LNG LNG LNG LNG Ambient a/ Cumulative LNG over Ambient
NSA C1 31.4 41.9 40.2 44.4 56.0 AN NSA 1 56.3 0.3
NSA C2 30.4 40.2 44.8 46.2 50.2 TX NSAs 1 & 2 51.7 1.5
NSA C3 30.4 39.7 44.4 45.8 50.2 TX NSA 3 51.5 1.3
NSA C4 31.4 38.7 34.7 40.7 46.0 AN NSA 2 47.1 1.1
NSA C5 39.4 41.0 32.2 43.6 46.0 AN NSA 2 61.4 0.1
NSA C6 34.4 37.3 28.7 39.5 46.0 AN NSA 2 46.9 0.9
CP 1 33.4 36.1 28.5 38.4 43.0 AN NSA 4 44.3 1.3
CP 2 46.4 61.8 41.0 62.0 59.0 TX 63.8 4.8
a/ The existing ambient sound levels shown are the lowest reported levels at project NSAs near the standardized NSAs.
The sound levels at the project-specific CPs during operation were an Annova LNG
contribution of 55.4 dBA Ldn at CP-AN, a Rio Grande LNG contribution of 69.7 dBA Ldn at CP-
RG, and a Texas LNG contribution of 52.9 dBA Ldn at CP-TX. This demonstrates that operational

sound levels in the LANWR would be dominated by contributions from the Rio Grande LNG
Project, due to its proximity to the LANWR. Cumulative impacts resulting from increased noise
on wildlife is further discussed in section 4.13.2.3.
Flaring
There would be flaring noise associated with all three projects. However, all three projects
report that flaring would not be part of standard operations. The maximum sound levels predicted
for flaring were 59 dBA, 52 dBA, and 43 dBA for Rio Grande LNG, Annova LNG, and Texas
LNG Projects, respectively, at the worst-case NSAs for each project. Although possible, it is
unlikely that flaring would occur simultaneously at all three projects. In the event of simultaneous
flaring at all three projects, the highest predicted sound levels would be at cumulative NSA C1,
with a predicted cumulative flaring sound level of 59.6 dBA, or 0.6 dBA higher than the individual
impact of the Rio Grande LNG flare operating alone. This is not a noticeable difference indicating
that the cumulative impact of flaring events would be minimal. However, with three facilities in
operation, the frequency of occurrence of flaring events would be approximately tripled, so flaring
events would occur more often, though the overall sound level from each flaring event would be
similar or lower than predicted by each project.
Maintenance Dredging
Occasional maintenance dredging would be required during the operational lifespan of the
three LNG projects to maintain the channel, turning basin, and other marine facilities associated
with the projects. Generally, the projects anticipate that maintenance dredging would be necessary
every few years. Maintenance dredging activities would be substantially quieter than the sound
levels reported with construction sound level predictions, as the predicted construction levels also
include pile-driving, general construction, and dredging activities. The BSC is an active waterway
that already has ongoing and regular maintenance dredging. The additional maintenance dredging
activities associated with the projects are not expected to cause a significant cumulative airborne
noise impact at the NSAs.
Noise Conclusions
For simultaneous construction activities at all of the three LNG projects, the predicted
sound level increase over the existing ambient ranges from 2.2 to 9.8 dBA Ldn at the NSAs and
sound levels of slightly over 55 dBA Ldn are predicted for NSAs C2, C3, and C5. These noise
level increases range between less than noticeable increases in ambient noise to a doubling of noise
at specific NSAs. For construction activities that are not simultaneous but incremental, the
predicted sound level increase ranges from 1.0 to 8.6 dBA Ldn at the NSAs. These increases would
be minor to moderate; however, all levels would be below the FERC criterion of 55 dBA Ldn. For
CP-1, the predicted cumulative construction increase was 10.1 dBA Ldn over the existing ambient
which could result in periods of perceived doubling of noise. At CP-2 in the Laguna Atascosa
NWR there is a higher ambient sound level so the predicted increase due to cumulative
construction noise would be 2.7 dBA Ldn, which would be a less than noticeable increase.
However, for the duration of Annova’s night time pile driving, we have estimated significantly
higher levels of noise (see section 4.11.2) and this would result in significant cumulative noise
impacts.

The predicted sound level impacts for simultaneous operation of all three LNG projects are
much lower than construction impacts, with potential increases over the existing ambient sound
level between 0.3 and 1.5 dBA Ldn at NSAs, resulting in a negligible to minor impact. Construction
and operation of the pipeline facilities would not contribute to significant cumulative noise impacts
on nearby NSAs. Operational impacts are slightly higher at CP-1 and CP-2, with possible
increases in sound levels due to operations of between 1.3 and 4.8 dBA Ldn. This is generally
considered barely noticeable to minor long-term impact. Construction and operation of the
pipeline facilities would not contribute to significant cumulative noise impacts on nearby NSAs.

5.0 CONCLUSIONS AND RECOMMENDATIONS
5.1 SUMMARY OF THE ENVIRONMENTAL ANALYSIS

The conclusions and recommendations presented in this section are those of the FERC
environmental and engineering staff. Our conclusions and recommendations are based on input
from the FWS, FAA, NPS, NMFS, COE, Coast Guard, DOE, DOT, and EPA as cooperating
agencies in the preparation of this draft EIS. However, the cooperating agencies will present their
own conclusions and recommendations in their respective Records of Decision and
determinations, and can adopt this draft EIS consistent with 40 CFR 1501.3 if, after an independent
review of the document, they conclude that their requirements have been satisfied. Otherwise,
they may elect to conduct their own supplemental environmental analysis.
We conclude that construction and operation of the Annova Project would result in
temporary and short-term impacts on numerous resources. However, the Project would result in
permanent impacts on geological conditions, soils, vegetation, wetlands , and visual resources; and
long-term impacts on air quality. As part of our analysis, we developed specific mitigation
measures that are practical, appropriate, and reasonable for construction and operation of the
Project. We are, therefore, recommending that these mitigation measures be attached as conditions
to any authorization issued by the Commission. Implementation of the mitigation proposed by
Annova and our recommended mitigation would ensure that Project impacts would be avoided or
minimized and would not be significant. A summary of the Project impacts and our conclusions
are presented below by resource.
5.1.1 Geologic Resources

The Project site would be graded to the extent necessary to construct Project facilities, and,
as a result, the LNG facilities would permanently alter the existing surface conditions at the site.
The final Project site would include asphalt- and gravel-surfaced roads, general gravel surfacing,
and application of top soil, seed, and mulch for planned vegetated areas. Construction and
operation of the Project would not significantly affect mineral resources. Blasting is not
anticipated during Project construction.
Based on Annova’s proposal, and in consideration of its proposed mitigation and design
criteria, we conclude that potential impacts on geological conditions would be adequately
minimized and would not be significant.
5.1.2 Soils
Project site soils would be permanently impacted by Project facilities, paved or gravel
roads, stormwater retention and evaporation ponds, or other impervious surfaces. Construction at
the Project site would involve grading and raising the site elevation with fill material, excavating
for building foundations, compacting soils, creating impermeable surfaces, and trenching to install
necessary piping and utilities. Clearing, grading, and construction activities associated with the
Project could cause a temporary loss of soil structure, and increase the potential for erosion,
compaction, and mixing of topsoil. Annova would adhere to the BMPs contained in its Plan and
Procedures, as well as the preliminary draft Construction SPCC Plan, which were developed in
accordance with applicable regulations and permit requirements to minimize soil impacts.
5-1 Conclusions and Recommendations

Adherence to these measures would minimize soil impacts during construction and operation
through sedimentation control and workspace restoration. Annova would also develop and
implement a separate Operation SPCC Plan. We have included a recommendation that, prior to
construction, Annova file its final Spill Prevention and Response Procedures, Construction SPCC
Plan, and the Operation SPCC Plan for review and written approval by the Director of OEP.
There are no known contaminated soils in either the Project site or the BSC and it is not
expected that contaminated sediments would be found during construction based on the on-site
soil investigation results and previous studies. Dredging does, however, have the potential to
expose unidentified contaminated soils. Annova has developed a Dredged Area Sampling and
Analysis Plan for dredging activities as part of the COE permit application and would implement
the proposed plan following COE guidance for dredged material sampling and testing to minimize
the potential for the release of contaminated soils.
Based on Annova’s proposal, and in consideration of its proposed mitigation measures and
design criteria, we conclude that the Project would have a permanent effect on soils within the
terminal site but that potential impacts would be minimized to the extent practical and would not
result in significant soil impacts.
5.1.3 Water Resources

No potable water supply wells are located within the Project site or within 150 feet of
Project. The nearest domestic water supply well is located over 4 miles north of the Project. The
majority of Project-related excavation would occur adjacent to the BSC where groundwater is
located near the surface. Excavation, the addition of fill, and the installation of foundations and
underground utilities would have localized and short-term effects on the groundwater during
construction with effects to local water table elevations. The shallow aquifer could sustain minor,
temporary indirect impacts from changes in overland water flow and recharge caused by clearing
and grading of the work areas. Implementation of mitigation measures included in Annova’s Plan
would reduce the potential for groundwater contamination. Annova would not use or withdraw
groundwater during construction or operation of the Project. Because of the temporary localized
effects of construction on groundwater, implementation of mitigation, and the relatively large
distance between the Project site and any water supply wells, we conclude that the potential
impacts on groundwater resources due to Project-related construction activities would be minimal.
Dredging during construction and maintenance dredging during Project operation, as well
as vessel traffic, site modification and stormwater runoff, and hydrostatic testing, would result in
decreased water quality of the BSC within the vicinity of the site. The majority of the excavation
during construction would occur on land, thereby minimizing suspension of sediment and turbidity
impacts on water quality that could occur due to direct dredging within the BSC. Impacts on water
quality from dredging would be further reduced by the use of a hydraulic cutter suction dredge,
which suctions excavated material into a pipeline, minimizing the loss of material and
resuspension of sediments into the water column. Periodic maintenance dredging would occur
only in areas previously disturbed during Project construction, with impacts further minimized by
the use of hydraulic cutter suction dredges. Annova would prepare a Dredging Water Quality
Monitoring Plan that would outline the use of BMPs during dredging and disposal activities, and
require monitoring of turbidity, flow rate, pH, and TSS at locations near dredging operations. In
Conclusions and Recommendations 5-2

addition, dredging activities would be permitted by the COE and required to comply with
applicable permit conditions.
The potential for shoreline erosion would be unlikely to increase significantly from LNG
vessel traffic for the Project, provided the LNG carriers avoid shoreline erosion from propeller
scour when traveling to and from Project facilities. In addition, rock rip-rap protection would be
placed along the terminal shoreline at the Project facilities to prevent erosion due to vessel propellers
or bow thrusters. Entrainment of non-consolidated substrate would result in a short-term, but
minor, impact on water quality as LNG carriers transit the BSC.
Ballast water discharged by LNG carriers docked at the marine berth would have minimal
effect on the salinity regime, dissolved oxygen levels, water temperature, or pH in the BSC.
Federal oversight and the applicable Coast Guard regulatory requirements that govern ballast water
discharges into U.S. waters would apply to all LNG carriers calling at the Project site. Cooling
water intake and discharge by LNG vessels would have temporary and minor effects on water
quality in the vicinity of the vessel.
Through implementation of NPDES regulations, Annova’s SPCC Plan, and its Plan and
Procedures, potential impacts resulting from stormwater runoff would be adequately minimized
or avoided. Annova would obtain an EPA Hydrostatic Test Water Discharge Permit and an RRC
permit to discharge the water that would be used for hydrostatic testing of pipes and LNG storage
tanks during construction. Discharge of hydrostatic test water may cause localized, short-term
turbidity in the BSC.
Surface water impacts resulting from the construction and operation of the Project could
result from site grading activities, fill activities, dredging and construction activities associated
with the marine facilities, vessel traffic, hydrostatic testing, and spills or leaks of hazardous
materials. With implementation of the mitigation measures identified for each of the proposed
activities, we have determined that construction and operation of the Project would result in
primarily temporary and less than significant impacts on surface waters.
5.1.4 Wetlands
Construction and operation of the Project would result in the disturbance of 57.7 acres of
wetlands, with 52.8 acres of permanent wetland loss. This includes disturbance to 53.0 acres of
vegetated wetlands and 4.7 acres of non-vegetated tidal flats and open water, with permanent loss
of 50.8 acres of vegetated wetlands and 2.0 acres of non-vegetated tidal flats and open water. The
entirety of impact on vegetated wetlands would occur to estuarine emergent marsh wetlands.
Annova is consulting with the COE and other relevant agencies regarding impacts on
wetlands and non-wetland waters of the U.S. In addition, Annova has prepared a draft Conceptual
Mitigation Plan that has identified preliminary Project mitigation requirements and proposed
compensation for the Project’s impacts on wetlands and waters under the COE’s jurisdiction. The
acceptability of any proposed compensatory mitigation measures would be determined by the COE
prior to construction. Annova is still refining the mitigation plan, which has not yet been approved
by the COE.

Adherence to measures contained in Annova’s Procedures would adequately address

wetlands that are only temporarily affected by Project construction, such that impacts on
temporally affected wetlands would be less than significant. Construction of the Project would
result in the permanent loss of 50.8 acres of emergent vegetated wetlands and 2 acres of
unvegetated open water and tidal flat. This loss of nearly 53 acres of wetland would be a permanent
impact. Annova is working with the COE to finalize required mitigation for permanent wetland
impacts. We anticipate that if the COE issues a Section 404/Section 10 permit for the Project, it
would be conditioned upon Project-related adverse impacts on waters of the U.S. being effectively
offset by mitigation similar to what Annova has identified in its draft Conceptual Mitigation Plan;
therefore, the permanent impacts on wetlands would be reduced to less than significant levels.
5.1.5 Vegetation
Construction of the Project would temporarily impact approximately 462 acres of
vegetation, with approximately 409 acres permanently impacted during Project operation. The
majority of these impacts would be to the following vegetative communities: South Texas Loma
Evergreen Shrubland, Gulf Coast Salty Prairie, South Texas Loma Grassland/Shrubland, and
Coastal Sea Ox-eye Daisy Flats. No state-designated rare, threatened, or endangered plants are
known to occur within the Project site. However, approximately 212 acres of South Texas Loma
Evergreen Shrubland and Grassland/Shrubland vegetation, and 98 acres of Gulf Coast Salty Prairie
vegetation would be permanently affected. The FWS considers these vegetation communities to
be of special concern because of their importance to the federally listed ocelot and northern
aplomado falcon, and because less than 5 percent of this vegetation remains in the Rio Grande
Valley. At the request of the FWS, Annova has modified the original Project layout to minimize
clearing of South Texas Loma Evergreen Shrubland and South Texas Loma Grassland/Shrubland.
The current site layout reduces Project impacts on these vegetation communities on the western
and eastern boundaries of the Project site. Additionally, Annova would comply with any Project-
specific recommendations and mitigation requirements associated with the Section 404 and
Section 10 permits issued by the COE, which would be expected to include implementation of
compensatory wetland mitigation similar to what Annova has identified in a draft Compensatory
Mitigation Plan.
Of the approximately 409 acres of vegetation communities that would be permanently

affected by the Project (lost), about 310 acres (76 percent) would be vegetation communities
identified as special concern (dense loma shrub and coastal salt prairie) by the FWS. However,
because this impact would represent only about 6 percent of the lomas in the immediate Project
area and less than 1 percent of the dense shrub vegetation within a 13.7-mile radius around the
Laguna Atascosa NWR, we have determined that construction and operation of the Project would
not significantly impact vegetation. Annova is evaluating off-site lands for conservation, either
through purchase or conservation easement, which may compensate for loss of loma and coastal
salt prairie vegetation and wildlife habitat.
5.1.6 Wildlife and Aquatic Resources

Construction and operation of the Project would result in the removal and/or conversion of
wildlife habitats at the site, with the permanent conversion of some habitat to industrial land.
About 310 acres (76 percent) of the Project impact would be to wildlife habitat considered special
concern by the FWS (dense loma shrub and coastal salt prairie). However, because this impact

would represent only about 6 percent of the lomas in the immediate Project area and less than 1
percent of the dense shrub vegetation within a 13.7-mile radius around the Laguna Atascosa NWR,
we have determined that construction and operation of the Project would not significantly impact
this habitat. Temporary workspaces would be temporarily disturbed during construction, then
planted with native grasses with the goal of restoring a grassland/herbaceous wildlife habitat.
Annova would also minimize impacts on wildlife through implementation of some TPWD
recommendations during construction and restoration, including some recommendations made by
TPWD in its comments on the draft EIS, as well as through use of measures designed to reduce
nuisance lighting, and development and implementation of a Facility Lighting Plan for operation
of the LNG terminal. Because Annova has not yet developed the Facility Lighting Plan we
recommend that, prior to construction, Annova file its Facility Lighting Plan for operation of the
LNG terminal with the Secretary for review and written approval by the OEP. At the request of
the FWS we recommend that the Facility Lighting Plan also address construction and
commissioning.
Construction and operation of the Project could affect migratory bird species through
permanent and temporary removal of habitat and Project lighting. In accordance with FWS
recommendations, Annova would attempt to limit clearing on the Project site to between
September 1 through and February 28 to avoid impacts on migratory bird nesting. If construction
during the nesting season cannot be avoided, Annova would follow the FWS recommendation to
identify and avoid active nests prior to and during the clearing activity. The occasional use of
warm/cold gas flares could impact some migratory birds if present during the flaring event but is
not expected to substantially impact migratory bird populations. The MBTA is under the
jurisdiction of the FWS. Therefore, we recommend that prior to construction, Annova consult
with the FWS to develop a Project-specific Migratory Bird Plan that includes measures to avoid
and minimize impacts on migratory birds, including details from the Facility Lighting Plan that
are intended to reduce impacts on wildlife and birds.
LNG carrier traffic along the BSC could impact colonial waterbirds if they are nesting on
an island located along the BSC at the confluence with the Port Isabel Channel, approximately 5
miles from the site, that has been known to be used in the past as a colonial waterbird nesting
rookery. This potential impact is not expected to be significant but could cause minor to moderate
impacts.
Constructing the Project would temporarily and permanently impact pollinator habitat
(vegetation). Milkweed is the primary plant species monarch butterflies use for foraging and for
reproduction and impacts and range-wide loss of this plant species has had a potential population
effect on monarch butterflies. Vegetation surveys performed at the Project site indicated that no
milkweed species were present within the Project site; therefore, construction and operation of the
Project is not anticipated to impact the primary habitat for the monarch butterfly.
Construction and operation activities with the potential to affect aquatic resources include
excavation and dredging of the marine berth, hydrostatic testing of the LNG tanks, additional
vessel traffic in the BSC, discharge of ballast water, cooling water intake and discharge, increased
noise levels, stormwater runoff or spills, and lighting. Construction of the marine facilities would
permanently alter the shoreline and adjacent uplands, resulting in more open water habitats in the
BSC as well as modify existing benthic areas encompassed by the turning basin.

Construction of the Project would result in minor effects on aquatic resources, including
managed species and EFH, due to temporary degradation of water quality and direct mortality of
some immobile individuals during dredging. Further, noise from limited in-water pile-driving
would result in temporary and minor impacts on fish. In addition, spills of hazardous materials
could affect water quality and affect aquatic organisms during construction and operations;
however, implementation of measures in Annova’s SPCC Plans and Project-specific Plan and
Procedures would minimize potential effects. During operation, the Project would have minor
effects on aquatic resources, including managed species and EFH, due to maintenance dredging
and increased vessel traffic. Permanent effects on aquatic habitat would occur where open water
would be converted to commercial/industrial land within the BSC; however, the permanent
reduction in aquatic habitat within the Project area is not expected to result in significant adverse
effects on marine resources, including managed species and EFH. On February 5, 2019, NOAA
Fisheries commented on the EFH assessment and concurred that impacts on EFH would be
temporary and minor.
5.1.7 Special Status Species

proposed, and candidate threatened and endangered species could potentially be impacted by the
Project. This total includes 18 federally listed, two proposed, and one candidate species. Of the
federally listed species, we have determined that construction and operation of the Project: would
have no effect on 2 of the federally listed species (South Texas ambrosia and Texas ayenia). We
have determined that the Project may affect, but is not likely to adversely affect 14 of the federally
listed species (blue whale, fin whale, sei whale, sperm whale, West Indian manatee, northern
aplomado falcon, piping plover, red knot, whooping crane, green sea turtle, Kemp’s ridley sea
turtle, loggerhead sea turtle, hawksbill sea turtle, and leatherback sea turtle), or the two proposed
species (Gulf of Mexico Bryde’s whale and Eastern black rail). We also determined that the
Project would not contribute to a trend toward federal listing for the identified candidate species
(red-crowned parrot). Finally, we have determined that the Project may affect, and is likely to
adversely affect 2 of the federally listed species (ocelot and Gulf Coast jaguarondi). Potentially
suitable habitat is present in the Project area for 45 of the 54 state-listed species in Cameron
County.
The potential exists for listed species to be affected by pile driving. Disturbances from pile
driving would be short term (approximately five days) and localized. Annova would reduce
impacts on listed species from pile driving by implementing a series of pile driving protocols that
would include visual monitoring and not starting pile driving during nighttime hours.
Measures proposed by Annova to minimize impacts on federally and state-listed species

include implementation of conservation measures and SPCC plans. Measures also include
providing LNG carrier captains with a NOAA-issued guidance document that outlines collision
avoidance measures to be implemented in order to minimize impacts on marine mammals and sea
turtles. Consultation with NOAA Fisheries and the FWS is ongoing; therefore, we recommend
that Annova should not begin construction until the FERC staff completes section 7 consultation
with the FWS and NOAA Fisheries.

5.1.8 Land Use, Recreation, and Visual Resources

Construction of the Project would result in temporary impacts on 491 acres, with 412 acres
of this total permanently affected during operation. Lands permanently affected during operation
would either contain permanent facilities or be permanently maintained as concrete, paved, or
gravel surfaces, or maintained in an herbaceous state. The Project site is located entirely on land
owned by the BND and designated for heavy industrial development. Following the completion
of construction, the site would shift from undeveloped to industrial land use. Construction and
operation of the Project is not expected to affect existing or planned residential or commercial land
uses. Construction and operation of the Project is also not expected to restrict land use on adjacent
properties or displace any residences or businesses. The Project is not expected to affect the
proposed SpaceX vertical launch area that would be located approximately 6.3 miles east-southeast
of the Project. To ensure compliance with the CZMA, we are recommending that Annova not
begin construction until it files with the Secretary a determination from the Coastal Coordination
Advisory Committee that the Project is consistent with the laws and regulations of the state’s
Coastal Zone Management Program.
The lands surrounding the Project site are largely undeveloped providing a variety of
dispersed outdoor recreational activities, including fishing and bird/wildlife watching. There are
also designated recreation sites and facilities located in the Project vicinity. Increases in dust,
noise, and traffic during construction would likely affect some recreationists, but would be short-
term and temporary. Project construction and operation would not permanently affect access to
the majority of regional fishing locations in the waters in the vicinity of the Project site; however,
fishing would be restricted from the shoreline of the BSC within the Project site. The increase in
the number of large vessels transiting the BSC during Project operation with the addition of LNG
carriers navigating to and from the Project site, could potentially result in additional delays for
other traffic within the BSC, but is not expected to substantially affect recreational fishing in the
ship channel.
The most prominent visual features at the Project site would be the two 186-feet-high
domed, cylindrical LNG tanks, and the 160-foot-high flare stack. Materials would be colored and
treated to blend in with the surrounding landscape and reduce glare, and the Project’s lighting
would be designed to minimize contrast with the night sky. Viewer sensitivity in the Project area
is generally considered to be high because a large proportion of the viewers in the area are there
for recreation and leisure activities.
Annova’s Visual Impact Assessment evaluated 10 KOPs at representative visually

sensitive areas, including areas used for recreation and wildlife viewing, key travel routes, the
Palmito Ranch Battlefield NHL and Palo Alto Battlefield NHP, and other public gathering areas.
Potential visual impacts occurred at all KOPs and ranged from low to moderate at most locations.
However, the visual impacts at KOP 8 at the State Highway 48 pull-off near Bahia Grande Channel
would be moderately high. Based on our analysis, Project construction and operation would not
result in significant impacts on current land use and recreation, or overall visual resources.
However, in its comments on the draft EIS, the NPS indicated that it believes the visual effects of
the Project on Palmito Ranch Battlefield NHL and Palo Alto Battlefield NHP would be adverse.

5.1.9 Socioeconomics
Construction of the Project is expected to be completed over a 48-month period, with an
average of 700 workers employed on-site during this period. A total of 1,200 workers would be
employed during peak construction, which is expected to last 6 months starting mid-way through
the second year. An average of 253 non-local workers are expected to be employed to perform
the specialized jobs needed to complete the Project. During peak construction, up to 780 non-local
workers may temporarily relocate to the region. Project construction would result in a short-term,
moderate increase to the local population, and Project operation would result in a negligible, long-
term increase to the local population.
Construction and operation of the Project would generate local and state tax revenues from
sales and payroll taxes, and support some local employment. Construction and operation of the
Project would not be expected to have high and adverse human health or environmental effects on
any nearby communities. The Project site is entirely located on property owned by the BND and
designated for industrial use; however, the access road would cross federal lands managed by the
FWS. The closest residences to the Project site boundary are located approximately 2.3 miles to
the south, on County Road 199, off of SH 4.
Potential land transportation impacts were assessed by evaluating how construction and
operation of the Project would likely affect traffic volumes, circulation patterns, and LOS on
roadways within the Project area. Preliminary analysis indicated that the addition of 1,000 Project-
related vehicles during morning and evening peak hours would cause failing conditions at the
intersections nearest to the Project access road. Subsequent analysis assumed that construction
shifts would be staggered, with half the workforce (500 vehicles) arriving and departing during
peak hours and the other half arriving and departing one hour later. With this assumption in place,
additional mitigation measures were identified for 3 of 10 affected intersections. In addition,
Annova proposes to transport construction workers to and from the construction site from a
centralized location via passenger buses, which would further reduce potential impacts on one or
more intersections, as well as reduce potential delays at the Border Patrol checkpoint on SH 4
(Boca Chica Boulevard). In response to our recommendation in the draft EIS, Annova filed
information on three potential locations for the off-site parking; however, it states that because it
is in the process of negotiations with the property owners it will not disclose the exact locations.
We considered the use of these parking areas when determining impacts on traffic and visitors to
the Palmito Ranch Battlefield NHL. Therefore, to ensure that Annova establishes these parking
areas and to ensure that potential impacts from use of these areas is evaluated prior to use, we
recommend that, prior to construction, Annova should file the specific location(s) of the off-site
centralized parking sites, and for each location identify: the existing environment and land use at
those locations; an evaluation of potential impacts that would result from Project use; and a
description of how the use of the specific sites would mitigate the impacts identified in its
construction traffic analysis.
Construction and operation of the Project would result in an increase in marine traffic in
the area. During operation, Annova anticipates that up to 125 LNG carriers per year would visit
the Project once fully operational. LNG carriers would require a moving safety and security zone
that would limit deep draft traffic while LNG carriers are in the channel. Large ocean-going
commercial vessels currently call at the Port of Brownsville at an average rate of six per week, or

312 per year. The addition of up to 125 LNG carriers per year with 2-hour transits in each direction
per carrier is not expected to create adverse impacts on inbound and outbound transits of large
vessels, which are already accustomed to queues and early scheduling requirements. Smaller
vessels heading in the opposite direction to a LNG carrier could experience delays of a few minutes
to 1.5 hours, depending on the position of the smaller vessel relative to the LNG carrier. The total
estimated annual delay for small vessels could range from 2.7 to 8.4 percent of daylight hours.
disproportionate adverse effects on minority and low-income residents in the area.
5.1.10 Cultural Resources

Cultural resource surveys were conducted for the Project APE. The investigations were
under Antiquities Permit No. 7040, in compliance with SOI professional standards and in
accordance with federal and THC standards and guidelines. The surveys covered both
archaeological and architectural (non-archaeological) resources. The archaeological report
(Sanchez et al. 2015) and architectural report (Wallisch and Russo 2015) were submitted to the
FERC and the THC. In addition, a bathymetric survey was also conducted for the Project and a
report detailing the results was submitted to FERC and the THC (iLinks Geosolutions LLC 2015).
In a letter dated October 1, 2015, the Executive Director of the THC agreed that sites 41CF49,
41CF50, 41CF87, 41CF102, 41CF219, 41CF220, 41CF221, and 41CF222 are not eligible for
listing on the NRHP or as State Antiquities Landmarks.
The SHPO also determined that the area around site 41CF48 is considered unevaluated due
to the inability to survey the area. Therefore, the eligibility of site 41CF48 is considered
undetermined. If the Project is approved, we recommend that Annova survey the area prior to
construction. If this site cannot be avoided, SHPO must be consulted and a survey plan for this
area will be implemented prior to construction in order to ascertain the eligibly of site 41CF48.
Annova contacted several Native American tribes to identify properties of traditional,

religious, or cultural importance that may be affected by the proposed Project in March 2015, with
follow-up calls in July 2015; additional tribes were notified in December 2015. To date, only two
tribes have responded: the Tonkawa Tribe of Oklahoma responded on April 17, 2015 that they
have no historical or cultural interest in the Project, and on July 9, 2015, the Lipan Apache Tribe
of Texas responded that the tribe does not have any sacred sites in the Project area. The
Unanticipated Discovery Plan for the Project has been submitted to the tribes. To date, no
additional responses have been received.
Annova prepared a visual impact assessment for three historic resources in the vicinity of
the site: the Palmito Ranch Battlefield NHL, the Palo Alto Battlefield NHL, and the NRHP-listed
Brazos Santiago Depot. We used this assessment to evaluate potential visual effects on the
viewshed from these three properties. We conclude that the Project would not affect the essential
features of the Palmito Ranch Battlefield for the period of significance (the Civil War) or the Palo

Alto Battlefield for the period of significance (the Mexican War), and the overall integrity of these
properties would remain intact. While the Project may be visible from the location of the Brazos
Santiago Depot, construction and operation would not affect the site’s potential to provide
information about its period of significance or to yield information about the past.
In its comments on the draft EIS, the NPS indicated that it disagrees with the definition of
the indirect APE used in our analysis and believes the visual and auditory effects of the Project on
Palmito Ranch Battlefield NHL and Palo Alto Battlefield NHP and NHL would be adverse.
Compliance with Section 106 of the National Historic Preservation Act is not complete for
the Project. Therefore, we recommend that Annova file all outstanding reports and agency
comments with the FERC and that FERC staff complete the Section 106 consultation process
before construction may begin.
5.1.11 Air Quality and Noise

Air quality impacts associated with construction of the Project would include emissions
from fossil-fueled construction equipment and fugitive dust. During construction the Project
would result in short-term, localized impacts on air quality. These impacts would transition to
permanent operational-phase emissions after commissioning and initial start-up. Annova would
incorporate fugitive dust control measures during construction to minimize emissions. Emissions
from off-road construction equipment would be minimized by implementing idling restrictions,
using newer-tier engines, when available, and installing add-on pollution controls on temporary
stationary construction equipment. Vehicle emissions would be further reduced through the use
of ultra-low-sulfur diesel and compliance with 30 TAC Chapter 114 – Control of Air Pollution
from Motor Vehicles.
Operation of the Project would result in permanent air quality impacts. Annova would
minimize operation emissions through implementation of BACT, as required by Annova’s
operating air permits. Annova would apply for all applicable air permits and would comply with
all air permit requirements for the Project. Air dispersion modeling that included both the Project’s
stationary sources and emissions from the marine vessels that would operate as part of the Project’s
activities demonstrated that the stationary sources plus mobile source emissions would not cause
or contribute to an exceedance of a NAAQS.
With the exception of pile-driving activities, the maximum noise levels attributable to
Project construction would be equal or similar to existing noise levels. No structural effects to
structures are anticipated from vibration during construction. We are recommending that Annova
monitor pile-driving activities and file weekly noise data. If measured noise impacts at the nearest
noise-sensitive areas are greater than 10 dBA over the Leq ambient levels, we recommend that
Annova cease pile driving and implement noise mitigation measures, and not resume pile-driving
activities until receipt of written notification from the Director of OEP. However, we have
determined that nighttime construction pile-driving noise impacts from construction would result
in significant noise impacts.
Operation of the LNG terminal would produce noise on a continual basis. Operational
sound levels at all NSAs would be equal to existing noise levels (NSA1) and/or below the 55 dBA
Ldn FERC criterion (at NSA2, NSA3, and NSA4). Operation and maintenance of the Project would

not cause significant noise impacts although certain short-term activities such as flaring would be
distinctly noticeable to residents or the public in the vicinity of the Project. To ensure that noise
resulting from operation of the Project is not significant, we recommend that Annova file a noise
survey with the FERC no later than 60 days after placing each liquefaction unit and the entire
Project in service. With the inclusion of our recommended pile-driving noise measures and
terminal noise surveys, we conclude that Project noise would not result in a significant impact on
any nearby noise sensitive areas.
5.1.12 Reliability and Safety

We assessed the potential impact on the human environment in terms of safety and whether
the Project would operate safely, reliably, and securely. As a cooperating agency, the DOT
assisted the FERC staff by determining whether Annova’s proposed design would meet the DOT’s
49 CFR 193 Subpart B siting requirements. On March 20, 2019, the DOT issued a LOD on the
Project’s compliance with 49 CFR 193 Subpart B. This determination is provided to the
Commission for consideration in its decision to authorize or deny the Project. If the Project is
authorized, constructed, and operated, the facility would be subject to the DOT’s inspection and
enforcement program; final determination of whether a facility is in compliance with the
requirements of 49 CFR 193 would be made by the DOT staff.
a WSA submitted by Annova that focused on the navigation safety and maritime security aspects
of LNG marine vessel transits along the affected waterway. On February 13, 2018, the Coast
Guard issued an LOR that recommended that the BSC be considered suitable for accommodating
the type and frequency of LNG marine traffic for the Project based on the WSA and in accordance
with the guidance in the Coast Guard’s NVIC 01-11. Annova requested that the number of ships
be increased from about 80 to 125 ship-calls per year as indicated in the WSA. The Coast Guard
is currently evaluating this to determine if a revised LOR should be issued. If the Project is
authorized, constructed, and operated, the facilities would be subject to the Coast Guard’s
inspection and enforcement program to ensure compliance with the requirements of 33 CFR 105
and 33 CFR 127.
the SpaceX rocket launch facility in Cameron County. We are including specific
recommendations to address potential impacts from rocket launch failures on the Project.
However, the extent of impacts on SpaceX operations, the National Space Program, and to the
federal government would not fully be known until SpaceX submits an application with the FAA
requesting to launch and whether the LNG terminal is under construction or in operation at that
time.
We conducted a preliminary engineering and technical review of the Annova design,

including potential external impacts based on the site location. Based on this review, we
recommend a number of mitigation measures, to ensure continuous oversight prior to initial site
preparation, prior to construction of final design, prior to commissioning, prior to introduction of
hazardous fluids, prior to commencement of service, and throughout life of the facility, in order to
enhance the reliability and safety of the facility to mitigate the risk of impact on the public. With

the incorporation of these mitigation measures and oversight, we conclude that Annova’s terminal
design would include acceptable layers of protection or safeguards that would reduce the risk of a
5.1.13 Cumulative Impacts

We considered the contributions of the proposed Project in conjunction with other projects
in the Project area to determine the potential for cumulative impact on the resources affected by
the Project. As part of that assessment, we identified existing projects, projects under construction,
projects that are proposed or planned, and reasonably foreseeable future projects – including
proposed LNG terminals, currently operating and future oil and gas projects, land transportation
projects, commercial and industrial developments, and dredging projects. Reasonably foreseeable
projects that might cause cumulative impacts in combination with the proposed Project include the
Rio Grande LNG Project and the Texas LNG Project. Many of the identified cumulative impacts
would be temporary and minor. Cumulative impacts have the potential to be more substantial for
water resources, protected wildlife, visual resources, air quality, noise, and transportation, as
discussed below.
The greatest potential for cumulative impacts associated with surface water resources
would be during dredging activities, as well as during operation. Concurrent dredging of the
maneuvering basin for the proposed Project as well as the Rio Grande LNG, Texas LNG, Bahia
Grande Estuary Channel Widening/Restoration, and Brazos Island Harbor Channel Improvement
Project would result in increased turbidity and sedimentation, resulting in short-term impacts on
water quality. The Brazos Island Harbor Channel Improvement project is not expected to result
in sediment accumulation during dredging as the purpose of the project is to deepen the main
channel and any accumulated sediments would likely be accounted for with the allowed over-
dredge depth to achieve the final design depth. While the BSC is a routinely maintained, manmade
channel, concurrent dredging activities and other impacts on surface water resources during
construction activities, as described above, are anticipated to be temporary and moderate.
The operation of all three proposed Brownsville LNG projects would also result in a
substantial increase in the number of large, ocean-going vessels transiting the BSC (estimated to
be about 511 LNG carriers per year combined). During operation, increased vessel traffic would
result in a cumulative impact on surface water resources from increases in turbidity and shoreline
erosion. Each of the three LNG projects has designed its respective facilities to minimize shoreline
erosion through placement of rock riprap along the shoreline, or similar measures. Cumulative
impacts on surface water quality during operation would be permanent and moderate to significant
due to the persistent transit of LNG carriers and other large vessels within the BSC resulting in the
potential increased erosion of the shoreline along unarmored portions of the BSC.
The proposed Project, Rio Grande LNG, and Texas LNG Projects, as well as the pipeline
projects proposed in the area, are anticipated to have the greatest cumulative impacts on ocelot
habitat through removal and conversion to industrial uses and fragmentation, respectively. In
addition, these projects along with several of the transportation projects could result in increased
road traffic and/or additional roads for transiting ocelots and jaguarundis to cross, thus increasing
the potential for vehicle strikes. The current remaining habitat corridor in the region to connect
U.S. and Mexico populations of these federally listed species is within and adjacent to the proposed

Annova Project site on the south side of the BSC, and adjacent to and within the proposed Rio
Grande LNG and Texas LNG Project sites north of the BSC. Other impacts, such as those
associated with noise, would be minimized by the projects to the extent practicable; however, due
to the proximity of the proposed Annova Project and Rio Grande LNG Project to the wildlife
corridors, facility-generated noise during construction and operation would still be audible to
ocelots and jaguarundis utilizing the wildlife corridor. Impulsive noise, like pile driving and
intermittent construction noise, is especially disruptive to members of the Family Felidae. Due to
the past, present, and proposed future development throughout the geographic scope for assessing
cumulative impacts on ocelots and jaguarundis, as well as the associated increases in road traffic,
light, and noise, we have determined that cumulative impacts on ocelots and jaguarundis would be
permanent and significant.
The proposed Project, Rio Grande LNG Project, and Texas LNG Project are anticipated to
have the greatest cumulative impacts on the northern aplomado falcon. In comments on the draft
EIS the FWS estimates that about 546 acres of suitable northern aplomado falcon habitat would
be affected by the three proposed LNG Projects. Because of the past cumulative habitat loss and
Projects with permanent aboveground components, such as the proposed Texas LNG and
proposed Rio Grande LNG terminals, have the most potential to contribute, along with the
proposed Project, to cumulative impacts on visual resources. In particular, motorists on State
Highway 48 and visitors to the nearby recreation areas where two or three LNG terminals would
be visible (including the NWRs, Loma Ecological Preserve, and South Bay Coastal Preserve and
South Bay Paddling Trail) would experience a permanent change in the existing viewshed during
construction and operation of the projects. The proposed Annova LNG Project would have a low
to moderate impact on visual resources in the area. However, due to the proximity of the Rio
Grande LNG and Texas LNG Projects to the same visual receptors as the Annova LNG Project,
significant cumulative impacts on visual resources are anticipated.
Cumulative air quality impacts could occur as a result of concurrent construction and
operation of the Annova LNG Brownsville, Rio Grande LNG, and Texas LNG Projects.
Concurrent construction of these projects could result in temporary, moderate to major increases
in emissions of air pollutants during construction. The potential impacts of these localized elevated
emissions would be greatest in the immediate vicinity of the LNG terminal sites; however, the
implementation of mitigation measures (e.g., water application) would minimize such impacts.
The operation of the Rio Grande LNG and Texas LNG terminals would have the greatest potential
to contribute to cumulative impacts on air quality with the operating Annova LNG terminal, given
the proximity of the projects. A conservative air quality modeling analysis of the emissions from
these three projects operating concurrently shows that for all criteria pollutants and averaging
periods, except for short-term (1-hour) NO2, cumulative impacts would be below the NAAQS.
The predicted maximum cumulative 1-hour NO2 impact would exceed the 1-hour average
NAAQS, although this impact is between the fence lines of the Texas LNG and Rio Grande LNG
ES-15 terminals, on Port of Brownsville property. This occurs because of the proximity of the two
facilities to each other. NO2 concentrations would disperse to levels of less than 40 percent of the
1-hour NO2 NAAQS before reaching nearby communities. While concurrent maximum
operations of the three LNG terminals would result in increased concentrations of air pollutants in

the vicinity of the terminals, the emissions from the projects are not expected to result in a
significant impact on regional air quality, nor would any exceedance of the NAAQS occur in a
populated area.
Currently, there is no universally accepted methodology to attribute discrete, quantifiable,

physical effects on the environment to the Project’s incremental contribution to GHG emissions.
Absent such a method for relating GHG emissions to specific resource impacts, we are not able to
assess potential GHG-related impacts attributable to the Project. Additionally, we have not been
able to find any GHG emission reduction goals established either at the federal level 56 or by the
State of Texas. Without either the ability to determine discrete resource impacts or an established
target to compare GHG emissions against, we are unable to determine the significance of the
Project’s contribution to climate change.
Cumulative noise impacts would primarily occur as a result of the concurrent construction
and operation of the Annova LNG Project, and the Texas LNG and Rio Grande LNG Projects.
For simultaneous construction activities at all three LNG projects, the predicted sound level
increase over the existing ambient ranges from 2.2 to 9.8 dBA Ldn at the noise sensitive areas and
sound levels of slightly over 55 dBA Ldn are predicted for several noise sensitive areas, and range
from less than noticeable increases in ambient noise to a doubling of noise at specific noise
sensitive areas. For construction activities that are not simultaneous but incremental, the predicted
sound level increase ranges from 1.0 to 8.6 dBA Ldn at the noise sensitive areas. These increases
would result in a minor to moderate impact; however, all levels would be below 55 dBA L dn.
However, during Annova’s 6 months of nighttime pile-driving, we have determined that impulsive
noise levels (Lmax) would result in cumulative significant noise impacts.
For the Palmito Ranch Battlefield National Historic Landmark, the predicted cumulative
construction increase was 10.1 dBA Ldn over the existing ambient, which could result in periods
of perceived doubling of noise. At the Laguna Atascosa NWR there is a higher ambient sound
level so the predicted increase due to cumulative construction noise would be 2.7 dBA Ldn,
resulting in a minor impact.
For operational noise with all three LNG projects fully operational, the predicted sound
level impacts are much lower than construction impacts, with potential increases over the existing
ambient of between 0.3 and 1.5 dBA Ldn at noise sensitive areas, resulting in minor impacts.
Operational impacts would be slightly higher at the Palmito Ranch Battlefield National Historic
Landmark and the Laguna Atascosa NWR, with possible increases in sound levels due to operation
of all three LNG projects of between 1.3 and 4.8 dBA Ldn. This is generally considered a minor
to moderate long-term impact.
If the three LNG projects were constructed concurrently, the combined impact of
construction traffic would be approximately 14,624 daily trips during active construction, with the
Annova LNG Project accounting for approximately 14 percent of this total. This cumulative
impact would result in increased wait times and congestion on local roadways during construction.
If all three proposed LNG projects were authorized and go into operation, and the other identified
dredging projects also occur, there would be a substantial increase of large and ocean-going vessel
56
The national emissions reduction targets expressed in the EPA’s Clean Power Plan and the Paris climate accord are pending
repeal and withdrawal, respectively.

traffic on the BSC. The three LNG projects combined would support an estimated 511 LNG carrier
trips per year, with periodic channel maintenance dredging activities, on average, contributing
about 420 vessel trips per year. This cumulative impact would represent a substantial increase in
the number of large and ocean-going vessels in the BSC, and small vessels and recreational boaters
attempting to access South Bay and the BSC would likely experience delays, ranging from 12 to
35 percent of daylight hours per year.
5.1.14 Alternatives
In accordance with NEPA and our policies, we evaluated alternatives to the Project to
determine whether an alternative would be environmentally preferable, reasonable, and/or
technically and economically feasible. As part of the alternatives analysis we considered: a no
action alternative; system alternatives; alternative sites; site layout alternatives; access road
alternatives; process alternatives; and marine berth excavation and dredging alternatives. Using
the evaluation criteria stated above and subsequent environmental comparisons, we considered
each alternative to the point where it was clear that the alternative could not meet the Project’s
objectives, offered no significant environmental advantage over the proposed action, or was not
reasonable from a technical or economic standpoint.
While the no action alternative would avoid the environmental impacts identified in this
EIS, the objectives of the Project would not be met. Further, any need for the import and export
of natural gas could potentially be met by LNG export and import projects developed elsewhere,
which would result in similar or greater impacts at other locations. For these reasons, the no action
alternative is not preferable to and does not provide a significant environmental advantage over
the proposed action.
Energy conservation and alternative energy sources have been proposed by commenters as
a replacement for the Project. However, energy conservation and alternative energy technology
would not meet the Project’s purpose to prepare natural gas for export to overseas markets, and
would, therefore, not be a reasonable alternative to the proposed action.
System alternatives considered in this analysis are those alternatives to the proposed action
that would make use of other existing, modified, or proposed facilities to meet the stated purpose
and need of the proposed action. To be considered a viable system alternative, the existing or
proposed project would need to be located in the Texas Gulf Coast region and provide LNG send-
out capacities similar to Annova’s proposal, in addition to current or planned expansion capacities
for the other terminals. Our evaluation of potential system alternatives did not identify any
existing, proposed, or planned LNG export facilities in the region that could be considered a viable
system alternative.
period regarding the need for an evaluation of alternative sites such as industrial areas that are not
in proximity to communities and important wildlife habitat. Based in part on the information
provided by Annova, we evaluated alternative sites that may also meet the stated objectives of the
Annova LNG Project. We applied screening criteria to identify sites that would be reasonable and
most likely to provide some environmental advantage over the proposed terminal site. Based on
this analysis, we conclude that the proposed site represents an acceptable site for the proposed

LNG terminal, and that the alternative sites are either not feasible or are not environmentally
preferable to the proposed site.
Based on scoping comments, Annova (in consultation with the FWS) identified two
alternatives to its proposed access road from SH 4 to the Project site. The two alternative routes
(Access Road Alternatives 1 and 3) reflect possible modifications to minimize potential impacts
on wildlife movement through the area. Based on a detailed evaluation of the three access road
locations (the proposed access road and two alternatives), we conclude that the proposed access
road location is the environmentally preferable alternative. However, use of the proposed access
road would require an appropriateness determination and a compatibility determination from the
FWS. Annova has stated it is in discussion with the FWS regarding the appropriateness
determination for use of the proposed access road. Annova states that it would construct and
operate its access road on the route identified as Access Road Alternative 1 in the event the FWS’
regulatory process precludes use of the proposed access road.
At our request, Annova evaluated process and design alternatives that include an on-site
power plant versus grid-supplied power as proposed, gas-fired compressors versus electric
compressors as proposed, and several flare design alternatives. We conclude that neither an on-
site power plant alternative or gas-fired compressors would provide a significant environmental
advantage over the proposed design when comparing local air quality impacts. We conclude that
a Totally Enclosed Ground Flare design would not result in an environmental advantage over the
proposed combined warm/cold flare stack.
Annova proposes to use the existing DMPA 5A located along the BSC just west of the
Project site for placement of dredged material not used as fill on site. Annova’s proposed Dredged
Material Transport Plan includes evaluation of three alternative placement areas also located
along the BSC which we summarize in our EIS. We conclude that none of the three alternative
placement areas would provide an environmental advantage over the proposed placement area.
5.2 FERC STAFF’S RECOMMENDED MITIGATION

If the Commission authorizes the Project, we are recommending that the following
measures be included as specific conditions in the Commission’s Order. These measures would
further mitigate the environmental impacts associated with the construction and operation of the
proposed Project. The section number in parentheses at the end of a condition corresponds to the
section number in which the measure and related resource impact analysis appears in the EIS.
1. Annova shall follow the construction procedures and mitigation measures described in its
applications and supplemental filings (including responses to staff data requests), and as
identified in the EIS, unless modified by the Order. Annova 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 OEP before using that
modification.
2. The Director of OEP, or the Director’s designee, has delegated authority to address any
requests for approvals or authorizations necessary to carry out the conditions of the Order,
and take whatever steps are necessary to ensure the protection of life, health, property, and
the environment during construction and operation of the Project. This authority shall
include:
a. the modification of conditions of the Order;
b. stop-work authority and authority to cease operation; and
c. the imposition of any additional measures deemed necessary to ensure continued
compliance with the intent of the conditions of the Order as well as the avoidance
or mitigation of unforeseen adverse environmental impact resulting from Project
construction and operation.
3. Prior to any construction, Annova shall 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.
4. The authorized facility location shall be as shown in the EIS, as supplemented by filed site
plans. As soon as they are available, and before the start of construction, Annova shall
file with the Secretary any revised detailed site plan drawings 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 site
plan drawings.
5. Annova shall file with the Secretary detailed site plan drawings identifying all changes in
site plan layout and staging areas, 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, 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. All areas shall be clearly identified on the maps/sheets/aerial photographs. Each
area must be approved in writing by the Director of OEP before construction in or near
that area.
Examples of alterations requiring approval include all 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

-15
d. agreements with individual landowners that affect other landowners or could affect
sensitive environmental areas.
6. Within 60 days of the acceptance of the Authorization and before construction

begins, Annova shall file an Implementation Plan with the Secretary for review and written
approval by the Director of OEP. Annova must file revisions to the plan as schedules
change. The plan shall identify:
a. how Annova will implement the construction procedures and mitigation measures
described in its application and supplements (including responses to staff data
requests), identified in the EIS, and required by the Order;
b. how Annova will 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, and how the company will ensure that sufficient
personnel are available to implement the environmental mitigation;
d. company personnel, including EIs and contractors, who will receive copies of the
appropriate material;
e. the location and dates of the environmental compliance training and instructions
Annova 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 Annova’s organization
having responsibility for compliance;
g. the procedures (including use of contract penalties) Annova will follow if
noncompliance occurs; and
h. for each discrete facility, a Gantt or PERT chart (or similar Project scheduling
diagram), and dates for:
i. the completion of all required surveys and reports;
ii. the environmental compliance training of onsite personnel;
iii. the start of construction; and
iv. the start and completion of restoration.
7. Annova shall at least one EI for the Project. 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 authorizing
documents;
b. responsible for evaluating the construction contractor’s implementation of the
environmental mitigation measures required in the contract (see condition 6 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.
8. Beginning with the filing of its Implementation Plan, Annova shall file updated status
reports with the Secretary on a monthly basis until all construction and restoration
activities are complete. Problems of a significant magnitude shall be reported to the FERC
within 24 hours. 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 Annova’s efforts to obtain the necessary federal authorizations;
b. Project schedule, including current construction status of the Project and work
planned for the following reporting period;
c. a listing of all problems encountered, contractor nonconformance/deficiency logs,
and each instance of noncompliance observed by the EI 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 and remedial actions implemented in response to all
instances of noncompliance, nonconformance, or deficiency;
e. the effectiveness of all corrective and remedial 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 Annova from other federal, state, or local
permitting agencies concerning instances of noncompliance, and Annova’s
response.
9. Annova must receive written authorization from the Director of OEP before commencing
construction of any Project facilities. To obtain such authorization, Annova must file
with the Secretary documentation that it has received all applicable authorizations required
under federal law (or evidence of waiver thereof).
10. Annova must receive written authorization from the Director of OEP prior to introducing
hazardous fluids into the Project facilities. Instrumentation and controls, hazard
detection, hazard control, and security components/systems necessary for the safe
introduction of such fluids shall be installed and functional.
11. Annova must receive written authorization from the Director of OEP before placing the
Project into service. Such authorization will only be granted following a determination
that the facilities have been constructed in accordance with the FERC approval, can be

expected to operate safely as designed, and the rehabilitation and restoration of the areas
affected by the Project are proceeding satisfactorily.
12. Within 30 days of placing the authorized facilities in service, Annova shall 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 Annova 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 construction, Annova shall file with the Secretary, for review and written
approval by the Director of the OEP, its final Spill Prevention and Response Procedures
and Construction SPCC Plan, and the Operation SPCC Plan. (section 4.2.3)
14. Prior to construction, Annova shall file with the Secretary, for review and written
approval by the Director of OEP, its Facility Lighting Plan for operation of the LNG
terminal. In addition, Annova shall include in its Facility Lighting Plan measures to reduce
the effects of light during construction and commissioning of the Project. (section 4.6.1)
15. Prior to construction, Annova shall consult with the FWS to develop a Project-specific
Migratory Bird Plan that includes measures to avoid and minimize impacts on migratory
birds, including details from the Facility Lighting Plan that are intended to reduce impacts
on wildlife and birds. Annova shall file the Migratory Bird Plan and evidence of
consultation with the FWS with the Secretary. (section 4.6.1)
16. Annova shall not begin construction activities until:
a. the FERC staff receives comments from the FWS and NOAA Fisheries regarding
the proposed action;
b. the FERC staff completes Section 7 ESA consultation with the FWS and NOAA
Fisheries; and
c. Annova has received written notification from the Director of OEP that
construction or use of mitigation may begin. (section 4.7.3)
17. Prior to construction, Annova shall file with the Secretary a determination from the Texas
Coastal Coordination Advisory Committee that the Project is consistent with the laws and
regulations of the state’s Coastal Zone Management Program. (section 4.8.6)
18. Prior to construction, Annova shall file the specific location(s) of the off-site centralized
parking sites that will be used to reduce impacts from the commuter construction work
force. For each location, Annova shall identify: the existing environment and land use at
those locations; an evaluation of potential impacts that would result from use as an off-site
parking facility; and a description of how the use of the specific site(s) would mitigate the
impacts at Intersections 1 through 4 as identified in the Traffic Impact Group 2015 report.
(section 4.9.10.1)

19. Annova shall not begin construction of facilities and/or use of staging, storage, or
temporary work areas and new or to-be-improved access roads until:
a. Annova files with the Secretary:
i. remaining cultural resources survey report(s);
ii. site evaluation report(s) and avoidance/treatment plan(s), as required; and
iii. comments on all cultural resources reports and plans from the Texas State
Historic Preservation Office, and the NPS for reports and plans that affect
NPS properties.
b. the Advisory Council on Historic Preservation is afforded an opportunity to
comment if historic properties would be adversely affected; and
c. the FERC staff reviews and the Director of OEP approves the cultural resources
reports and plans, and notifies Annova in writing that treatment plans/mitigation
measures (including archaeological data recovery) may be implemented and/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 relevant pages therein
clearly labeled in bold lettering: CUI/PRIV “CONTAINS PRIVILEGED
INFORMATION - DO NOT RELEASE.” (section 4.10.4)
20. Annova shall monitor pile-driving activities, and file weekly noise data with the Secretary
following the start of pile-driving activities that identify the noise impact on the nearest
NSAs. If any measured noise impacts (Lmax) at the nearest NSAs are greater than 10 dBA
over the Leq ambient levels, Annova shall:
a. cease pile-driving activities and implement noise mitigation measures;
b. file with the Secretary evidence of noise mitigation installation and request written
notification from the Director of OEP that pile driving may resume. (section
4.11.2)
21. Annova shall file a full power load noise survey with the Secretary for the LNG terminal
no later than 60 days after each liquefaction train is placed into service. If the noise
attributable to operation of the equipment at the LNG terminal exceeds an Ldn of 55 dBA
at the nearest NSA, within 60 days Annova shall modify operation of the liquefaction
facilities or install additional noise controls until a noise level below an L dn of 55 dBA at
the NSA is achieved. Annova shall confirm compliance with the above requirement by
filing a second noise survey with the Secretary no later than 60 days after it installs the
additional noise controls. (section 4.11.2)
22. Annova shall file a noise survey with the Secretary no later than 60 days after placing the
entire LNG terminal into service. If a full load condition noise survey is not possible,
Annova shall provide an interim survey at the maximum possible horsepower load within
60 days of placing the LNG terminal into service and provide the full load survey within
6 months. If the noise attributable to operation of the equipment at the LNG terminal
exceeds an Ldn of 55 dBA at the nearest NSA under interim or full horsepower load
conditions, Annova shall file a report on what changes are needed and shall install the

additional noise controls to meet the level within 1 year of the in-service date. Annova
shall confirm compliance with the above requirement by filing an additional noise survey
with the Secretary no later than 60 days after it installs the additional noise controls.
(section 4.11.2)
23. Prior to initial site preparation, Annova shall file with the Secretary documentation
demonstrating LNG marine vessels would be no higher than existing ship traffic or it has
received a determination of no hazard (with or without conditions) by FAA for mobile
objects that exceed the height requirements in 14 CFR 77.9. (section 4.12.6)
24. Prior to initial site preparation, Annova shall file with the Secretary for review and
written approval by the Director of OEP, a detailed report that indicates the elevation of a
500-year storm surge wave run-up and that the wave run-up would not impact project
facilities that are essential for the safety and operability of the terminal. If the wave run-up
is found to reach essential equipment/structures, Annova shall provide mitigation measures
to protect these facilities. (section 4.12.6)
25. Prior to construction of final design, Annova shall file with the Secretary consultation
with DOT on the use of normally closed valves to remove stormwater from curbed areas.
(section 4.12.6)
26. Prior to construction of final design, Annova shall file with the Secretary the following
information, stamped and sealed by the professional engineer-of-record registered in
Texas:
a. site preparation drawings and specifications;
b. LNG terminal structures and foundation design drawings and calculations
(including prefabricated and field constructed structures);
c. seismic specifications for procured equipment; and
d. quality control procedures to be used for civil/structural design and construction.
In addition, Annova shall file, in its Implementation Plan, the schedule for producing this
information. (section 4.12.6)
27. Prior to construction of final design, Annova shall file with the Secretary a monitoring
and maintenance plan, stamped and sealed by the professional engineer-of-record
registered in Texas, to ensure the site is maintained at a minimum elevation of 16.5 feet
NAVD 88 and the crest elevation of the earthen berm around each LNG storage tank is
maintained at a minimum crest of 36 feet above sea level for the life of the facility
considering settlement, subsidence, and sea level rise. (section 4.12.6)
Conditions 28 through 127 shall apply to the Annova LNG terminal facilities. Information
pertaining to these specific conditions shall be filed with the Secretary for review and written
approval by the Director of OEP, or the Director’s designee, within the timeframe indicated by
each condition. Specific engineering, vulnerability, or detailed design information meeting the
criteria specified in Order No. 833 (Docket No. RM16-15-000), including security information,
shall be submitted as critical energy infrastructure information pursuant to 18 CFR 388.113. See
Critical Electric Infrastructure Security and Amending Critical Energy Infrastructure Information,
Order No. 833, 81 Fed. Reg. 93,732 (December 21, 2016), FERC Stats. & Regs. 31,389 (2016).

Information pertaining to items such as offsite emergency response, procedures for public
notification and evacuation, and construction and operating reporting requirements would be
subject to public disclosure. All information shall be filed a minimum of 30 days before approval
to proceed is requested.
28. Prior to initial site preparation, Annova shall file an overall Project schedule, which
includes the proposed stages of the commissioning plan. (section 4.12.6)
29. Prior to initial site preparation, Annova shall file quality assurance and quality control
procedures for both the Engineering Procurement Contractor and Annova to monitor
construction activities. (section 4.12.6)
30. Prior to initial site preparation, Annova shall file procedures for controlling access
during construction. (section 4.12.6)
31. Prior to initial site preparation, Annova shall develop and implement procedures to
monitor rocket launch activity and to position onsite construction crews and plant
personnel in areas that are unlikely to be impacted by rocket debris of a failed launch during
initial moments of rocket launch activity from the Brownsville SpaceX facility. Annova's
procedures for positioning of onsite construction crews and plant personnel shall include
reference to any guidance from the FAA to the public regarding anticipated SpaceX
launches. (section 4.12.6)
32. Prior to initial site preparation, Annova shall conduct and provide results of a minimum
of five equally distributed borings, cone penetration tests, and/or seismic cone penetration
tests to a depth of at least 100 feet or refusal underneath the revised locations of each LNG
storage tank to affirm or better characterize underlying conditions. (section 4.12.6)
33. Prior to initial site preparation, Annova shall develop an Emergency Response Plan
(including evacuation) and coordinate procedures with the Coast Guard; state, county, and
local emergency planning groups; fire departments; 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 public use areas that are within any
transient hazard areas along the route of the LNG marine transit;
e. locations of permanent sirens and other warning devices; and
f. an “emergency coordinator” on each LNG marine vessel to activate sirens and other
warning devices.
Annova shall notify the FERC staff of all planning meetings in advance and shall report
progress on the development of its Emergency Response Plan at 3‑month intervals.
(section 4.12.6)

34. Prior to initial site preparation, Annova shall file a Cost-Sharing Plan identifying the
mechanisms for funding all Project-specific security/emergency management costs that
would be imposed on state and local agencies. This comprehensive plan shall include
funding mechanisms for the capital costs associated with any necessary
security/emergency management equipment and personnel base. Annova shall notify
FERC staff of all planning meetings in advance and shall report progress on the
development of its Cost Sharing Plan at 3-month intervals. (section 4.12.6)
35. Prior to construction of final design, Annova shall file design information that would
minimize the impacts of growth fault impact zones in the vicinity of the LNG Terminal,
stamped and sealed by the professional engineer-of-record registered in Texas. (section
4.12.6)
36. Prior to construction of final design, Annova shall file change logs that list and explain
any changes made from the front end engineering design provided in Annova’s application
and filings. A list of all changes with an explanation for the design alteration shall be
provided and all changes shall be clearly indicated on all diagrams and drawings. (section
4.12.6)
37. Prior to construction of final design, Annova shall file information/revisions pertaining
to its response to numbers 4, 5, 6, 10 11, 14, 17, 18, 19, 20, 21, 22, 24, 25, 26, 27, 28, 29,
31, 33, 34, 35, 36, 38, 43, and 49 of the February 14, 2017 data request; numbers 11, 12,
13, 17, 18a, 18e, 19, and 21f of the October 19, 2018 data request, and its response to
number 25 filed on February 4, 2019, which indicated features to be included or considered
in the final design. (section 4.12.6)
38. Prior to construction of final design, Annova shall file a plot plan of the final design
showing all major equipment, structures, buildings, and impoundment systems. (section
4.12.6)
39. Prior to construction of final design, Annova shall file three-dimensional plant drawings
to confirm plant layout for maintenance, access, egress, and congestion. (section 4.12.6)
40. Prior to construction of final design, Annova shall file an up-to-date equipment list,
process and mechanical data sheets, and specifications. The specifications shall include:
a. building specifications (e.g., control buildings, electrical buildings, compressor
buildings, storage buildings, pressurized buildings, ventilated buildings, blast
resistant buildings);
b. mechanical specifications (e.g., piping, valve, insulation, rotating equipment, heat
exchanger, storage tank and vessel, other specialized equipment);
c. electrical and instrumentation specifications (e.g., power system, control system,
safety instrument system [SIS], cable, other electrical and instrumentation); and
d. security and fire safety specifications (e.g., security, passive protection, hazard
detection, hazard control, firewater). (section 4.12.6)
41. Prior to construction of final design, Annova shall file a list of all codes and standards
and the final specification document number where they are referenced. (section 4.12.6)

42. Prior to construction of final design, Annova shall file a complete specification and
drawings of the proposed LNG tank design and installation. The specification shall define
the battery limits (i.e., engineering design, structural design, supports, piping components,
piping connections, electrical power, control, and utilities) of the LNG storage tank.
(section 4.12.6)
43. Prior to construction of final design, the LNG storage tank specification shall clearly
define the roof top load requirements for the LNG pump platform as well as other laydown
areas required for maintenance activities. (section 4.12.6)
44. Prior to construction of final design, Annova shall file drawings of the storage tank
piping support structure and support of horizontal piping at grade including pump columns,
relief valves, pipe penetrations, instrumentation, and appurtenances. (section 4.12.6)
45. Prior to construction of final design, Annova shall file process data sheets that specify
the start-up, operating, and shutdown conditions for the BOG Compressors. (section
4.12.6)
46. Prior to construction of final design, Annova shall file up-to-date process flow diagrams
(PFDs) that demonstrate the peak liquefaction rate of 6.95 mtpa is achievable and piping
and instrument diagrams (P&IDs) including vendor P&IDs. The PFDs shall include heat
and material balances. The P&IDs shall include the following information:
a. equipment tag number, name, size, duty, capacity, and design conditions;
b. equipment insulation type and thickness;
c. storage tank pipe penetration size and nozzle schedule;
d. valve high pressure side and internal and external vent locations;
e. piping with line number, piping class specification, size, and insulation type and
thickness;
f. piping specification breaks and insulation limits;
g. all control and manual valves numbered;
h. relief valves with size and set points; and
i. drawing revision number and date. (section 4.12.6)
47. Prior to construction of final design, Annova shall file P&IDs, specifications, and
procedures that clearly show and specify the tie-in details required to safely connect
subsequently constructed facilities with the operational facilities. (section 4.12.6)
48. Prior to construction of final design, Annova shall file a car seal philosophy and a list of
all car-sealed and locked valves consistent with the P&IDs. (section 4.12.6)
49. Prior to construction of final design, Annova shall file a hazard and operability review
prior to issuing the P&IDs for construction. A copy of the review, a list of the
recommendations, and actions taken on the recommendations shall be filed. (section
4.12.6)

50. Prior to construction of final design, Annova shall file specifications and piping and
instrumentation diagrams of the Refrigerant Compressor motor cooling system. (section
4.12.6)
51. Prior to construction of final design, Annova shall file the safe operating limits (upper
and lower), alarm and shutdown set points for all instrumentation (i.e., temperature,
pressures, flows, and compositions). (section 4.12.6)
52. Prior to construction of final design, Annova shall file cause-and-effect matrices for the
process instrumentation, fire and gas detection system, and emergency shutdown system.
The cause-and-effect matrices shall include alarms and shutdown functions, details of the
voting and shutdown logic, and set points. (section 4.12.6)
53. Prior to construction of final design, Annova shall file an evaluation of emergency
shutdown valve closure times. The evaluation shall account for the time to detect an upset
or hazardous condition, notify plant personnel, and close the emergency shutdown valve(s).
(section 4.12.6)
54. Prior to construction of final design, Annova shall file an evaluation of dynamic pressure
surge effects from valve opening and closure times and pump startup and shutdown
operations. (section 4.12.6)
55. Prior to construction of final design, Annova shall demonstrate that, for hazardous fluids,
piping and piping nipples 2 inches or less in diameter are designed to withstand external
loads, including vibrational loads in the vicinity of rotating equipment and operator live
loads in areas accessible by operators. (section 4.12.6)
56. Prior to construction of final design, Annova shall file electrical area classification
drawings. (section 4.12.6)
57. Prior to construction of final design, Annova shall file drawings and details of how
process seals or isolations installed at the interface between a flammable fluid system and
an electrical conduit or wiring system meet the requirements of NFPA 59A (2001).
(section 4.12.6)
58. Prior to construction of final design, Annova shall file details of an air gap or vent
installed downstream of process 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, alarm the hazardous condition, and shut
down the appropriate systems. (section 4.12.6)
59. Prior to construction of final design, Annova shall file the design specifications and
drawings for the feed gas inlet facilities (e.g., metering, pigging system, pressure protection
system, compression, etc.). (section 4.12.6)
60. Prior to construction of final design, Annova shall include LNG storage tank fill flow
measurement with high flow alarm. (section 4.12.6)
61. Prior to construction of final design, Annova shall include BOG flow measurement from
each LNG storage tank. (section 4.12.6)

62. Prior to construction of final design, Annova shall specify how each LNG storage tank
dome’s vent valve HV-0014/HV-0054 will be isolated with administrative controls in the
event that the vent valve cannot be closed or requires maintenance work. (section 4.12.6)
63. Prior to construction of final design, Annova shall file the sizing basis and capacity for
the final design of the flares and/or vent stacks as well as the pressure and vacuum relief
valves for major process equipment, vessels, and storage tanks. (section 4.12.6)
64. Prior to construction of final design, Annova shall provide the Refrigerant Surge Drum,
Ethylene Make-up Drum, Propane Make-up Drum, and Iso-pentane Make-up Drum with
dual full capacity relief valves that allow the isolation with administrative controls of
individual pressure relief valves while providing full relief capacity during pressure relief
valve maintenance or testing. (section 4.12.6)
65. Prior to construction of final design, Annova shall file a drawing showing the location
of the emergency shutdown buttons. Emergency shutdown buttons shall be easily
accessible, conspicuously labeled, and located in an area which would be accessible during
an emergency. (section 4.12.6)
66. Prior to construction of final design, Annova shall specify that all ESD valves are to be
equipped with open and closed position switches connected to the Distributed Control
System/Safety Instrumented System. (section 4.12.6)
67. Prior to construction of final design, Annova shall specify how the BOG system will
prevent pipeline gas from back flowing into the BOG Metering Skid. (section 4.12.6)
68. Prior to construction of final design, Annova shall specify how the Heat Medium
Expansion Drum pressure indicator, 1090-PI-0241, will notify operators of excessive
venting through pressure regulator, 1090-PCV-0240. (section 4.12.6)
69. Prior to construction of final design, Annova shall file drawings and specifications for
crash rated vehicle barriers at each facility entrance for access control. (section 4.12.6)
70. Prior to construction of final design, Annova shall file drawings of the security fence.
The fencing shall extend around the pigging and metering equipment. The fencing
drawings shall provide details of fencing that demonstrates it would restrict and deter
access around the entire facility and has a setback from exterior features (e.g., power lines,
trees, etc.) and from interior features (e.g., piping, equipment, buildings, etc.) that does not
allow the fence to be overcome. (section 4.12.6)
71. Prior to construction of final design, Annova shall file drawings of internal road vehicle
protections, such as guard rails, barriers, and bollards to protect transfer piping, pumps,
compressors, hydrants, monitors, etc. to ensure that they are located away from roadway
or protected from inadvertent damage from vehicles. (section 4.12.6)
72. Prior to construction of final design, Annova shall file security camera and intrusion
detection drawings. The security camera drawings shall show the locations, areas covered,
and features of each camera (e.g., fixed, tilt/pan/zoom, motion detection alerts, low light,
mounting height, etc.) to verify camera coverage of the entire perimeter with redundancies,
and cameras interior to the facility that would enable rapid monitoring of the facility
including a camera at the top of each LNG storage tank, and coverage within pretreatment
areas, within liquefaction areas, within truck transfer areas, within marine transfer areas,

and buildings. The drawings shall show or note the location of the intrusion detection to
verify it covers the entire perimeter of the facility. (section 4.12.6)
73. Prior to construction of final design, Annova shall file lighting drawings. The lighting
drawings shall show the location, elevation, type of light fixture, and lux levels of the
lighting system and shall be in accordance with API 540 and provide illumination along
the perimeter of the facility, process equipment, mooring points, and along paths/roads of
access and egress to facilitate security monitoring and emergency response operations.
(section 4.12.6)
74. Prior to construction of final design, Annova shall evaluate the terminal alarm system
and external notification system design to ensure the location of the terminal alarms and
other fire and evacuation alarm notification devices (e.g. audible/visual beacons and
strobes) would provide adequate warning at the terminal and external off-site areas in the
event of an emergency. (section 4.12.6)
75. Prior to construction of final design, Annova shall file an updated fire protection
evaluation of the proposed facilities. A copy of the evaluation, a list of recommendations
and supporting justifications, and actions taken on the recommendations shall be filed. The
evaluation shall justify the type, quantity, and location of hazard detection and hazard
control, passive fire protection, emergency shutdown and depressurizing systems,
firewater, and emergency response equipment, training, and qualifications in accordance
with NFPA 59A (2001). The justification for the flammable and combustible gas detection
and flame and heat detection shall be in accordance with ISA 84.00.07 or equivalent
methodologies that would demonstrate 90 percent or more of releases (unignited and
ignited) that could result in an off-site or cascading impact would be detected by two or
more detectors and result in isolation and de-inventory within 10 minutes. The analysis
shall take into account the set points, voting logic, wind speeds, and wind directions. The
justification for firewater shall provide calculations for all firewater demands based on
design densities, surface area, and throw distance and specifications for the corresponding
hydrant and monitors needed to reach and cool equipment. (section 4.12.6)
76. Prior to construction of final design, Annova shall file spill containment system drawings
with dimensions and slopes of curbing, trenches, impoundments, and capacity calculations
considering any foundations and equipment within impoundments, as well as the sizing
and design of the down-comer that would transfer spills from the tank top to the ground-
level impoundment system. The spill containment drawings shall show containment for
all hazardous fluids, including all liquids handled above their flashpoint, from the largest
flow from a single line for 10 minutes, including de-inventory, or the maximum liquid from
the largest vessel (or total of impounded vessels) or otherwise demonstrate that providing
spill containment would not significantly reduce the flammable vapor dispersion or radiant
heat consequences of a spill. In addition, Annova shall demonstrate that the stainless steel
piping spill trays at each LNG storage tank would withstand the force and shock of a sudden
cryogenic release. (section 4.12.6)
77. Prior to construction of final design, Annova shall specify how residual water within
each spill basin will be removed after the stormwater removal pumps shut down on low
water level. (section 4.12.6)

78. Prior to construction of final design, Annova shall review each Process Area
Impoundment Basin stormwater removal system. If applicable, each stormwater removal
pump shall be equipped with an interlock to prevent inadvertent discharge of warm
refrigerant, heavy hydrocarbon, or hot oil releases. (section 4.12.6)
79. Prior to construction of final design, Annova shall file an analysis demonstrating that the
side on overpressures would be less than 1 psi at the buildings or that the buildings would
be able to withstand overpressures from explosions within the terminal. (section 4.12.6)
80. Prior to construction of final design, Annova shall file an analysis demonstrating the side
on overpressures would be less than 1 psi at the LNG storage tanks, or demonstrating the
LNG storage tanks would be able to withstand overpressures within the terminal. (section
4.12.6)
81. Prior to construction of final design, Annova shall file an analysis demonstrating the
flammable vapor dispersion from design spills would be prevented from dispersing
underneath the elevated LNG storage tanks, or demonstrating the LNG storage tanks would
be able to withstand the overpressure due to ignition of the flammable vapors that disperses
underneath the elevated LNG storage tanks. (section 4.12.6)
82. Prior to construction of final design, Annova shall file an analysis demonstrating that a
LNG storage tank dike fire or a pool fire within the Marine Area Impoundment Basin
would not fail the seawater firewater equipment within the time it would take for each pool
fire scenario to burn out. Alternatively, Annova shall reposition the seawater firewater
equipment to prevent high radiant heat zones. (section 4.12.6)
83. Prior to construction of final design, Annova shall specify how cascading damage to the
condensate storage tank would be mitigated from a pool fire in the Heat Medium
Impoundment Basin. Alternatively, Annova shall reposition the condensate storage tank
or the Heat Medium Impoundment Basin to prevent high radiant heat zones over the
condensate storage tank. (section 4.12.6)
84. Prior to construction of final design, Annova shall file complete drawings and a list of
the hazard detection equipment. The drawings shall clearly show the location and elevation
of all detection equipment. The list shall include the instrument tag number, type and
location, alarm indication locations, and shutdown functions of the hazard detection
equipment. (section 4.12.6)
85. Prior to construction of final design, Annova shall file a list of alarm and shutdown set
points for all hazard detectors that account for the calibration gas of the hazard detectors
when determining the lower flammable limit set points for methane, propane, ethylene,
pentane, and condensate. (section 4.12.6)
86. Prior to construction of final design, Annova shall file a list of alarm and shutdown set
points for all hazard detectors that account for the calibration gas of hazard detectors when
determining the set points for toxic components such as aqueous ammonia, natural gas
liquids, and hydrogen sulfide. (section 4.12.6)
87. Prior to construction of final design, Annova shall file a technical review of facility
design that:

a. identifies all combustion/ventilation air intake equipment and the distances to any
possible flammable gas or toxic release; and
b. demonstrates that these areas are adequately covered by hazard detection devices
and indicates how these devices would isolate or shutdown any combustion or
heating ventilation and air conditioning equipment whose continued operation
could add to or sustain an emergency. (section 4.12.6)
88. Prior to construction of final design, Annova shall file a design that includes hazard
detection suitable to detect high temperatures and smoldering combustion products in
electrical buildings and control room buildings. (section 4.12.6)
89. Prior to construction of final design, Annova shall provide low oxygen detectors to notify
operators of liquid nitrogen releases. (section 4.12.6)
90. Prior to construction of final design, Annova shall file an evaluation of the voting logic
and voting degradation for hazard detectors. (section 4.12.6)
91. Prior to construction of final design, Annova shall file an analysis of the off gassing of
hydrogen in battery rooms and ventilation calculations that limit concentrations below the
lower flammability limits (e.g., 25 percent LFL) and shall also provide hydrogen detectors
that alarm (e.g., 20 to 25 percent LFL) and initiate mitigative actions (e.g., 40 to 50 percent
LFL). (section 4.12.6)
92. Prior to construction of final design, Annova shall file facility plan drawings and a list
of the fixed and wheeled dry-chemical, hand-held fire extinguishers, and other hazard
control equipment. Plan drawings shall clearly show the location and elevation by tag
number of all fixed dry chemical systems in accordance with NFPA 17, and wheeled and
hand-held extinguishers location travel distances are along normal paths of access and
egress in accordance with NFPA 10. The list shall include the equipment tag number, type,
capacity, equipment covered, discharge rate, and automatic and manual remote signals
initiating discharge of the units. (section 4.12.6)
93. Prior to construction of final design, Annova shall file a design that includes clean agent
systems in the instrumentation buildings. (section 4.12.6)
94. Prior to construction of final design, Annova shall file facility plan drawings showing
the proposed location of the firewater and any foam systems. Plan drawings shall clearly
show the location of firewater and foam piping, post indicator valves, and the location and
area covered by, each monitor, hydrant, hose, water curtain, deluge system, foam system,
water-mist system, and sprinkler. The drawings shall also include piping and
instrumentation diagrams of the firewater and foam systems. (section 4.12.6)
95. Prior to construction of final design, Annova shall specify two firewater jockey pumps
and appurtenances that can operate simultaneously in the event that the primary jockey
pump cannot maintain system pressure. The flow rate capacity from the jockey pumps
shall be supported with calculations. (section 4.12.6)
96. Prior to construction of final design, Annova shall include or demonstrate the firewater
storage volume for its facilities has minimum reserved capacity for its most demanding
firewater scenario plus 1,000 gpm for no less than 2 hours. The firewater storage shall also

demonstrate compliance with NFPA 22 or demonstrate how API 650 provides an

equivalent or better level of safety. (section 4.12.6)
97. Prior to construction of final design, Annova shall specify that the firewater flow test
meter is equipped with a transmitter and that a pressure transmitter is installed upstream of
the flow transmitter. The flow transmitter and pressure transmitter shall be connected to
the DCS and shall be recorded. (section 4.12.6)
98. Prior to construction of final design, Annova shall file detailed calculations to confirm
that the final fire water volumes would be accounted for when evaluating the capacity of
the impoundment system during a spill and fire scenario. (section 4.12.6)
99. Prior to construction of final design, Annova shall specify that both freshwater pump
shelter and the firewater intake and pumps shelter are designed to remove the largest
firewater pump or other component for maintenance with an overhead or external crane.
(section 4.12.6)
the structural passive protection systems to protect equipment and supports from cryogenic
releases. (section 4.12.6)
101. Prior to construction of final design, Annova shall file calculations or test results for the
structural passive protection systems to protect equipment and supports from cryogenic
releases. (section 4.12.6)
the structural passive protection systems to protect equipment and supports from pool and
jet fires. (section 4.12.6)
103. Prior to construction of final design, Annova shall file specifications and drawings of
how cascading damage of transformers would be prevented (e.g., firewalls or spacing) in
accordance with NFPA 850 or equivalent. (section 4.12.6)
104. Prior to construction of final design, Annova shall file a detailed quantitative analysis to
demonstrate that adequate mitigation would be provided for each significant component
within the 4,000 Btu/ft2-hr zone from pool or jet fires that could cause failure of the
component (including fires in the amine sump pit and condensate storage tank berm).
Trucks at the truck loading/unloading areas shall be included in the analysis. A
combination of passive and active protection for pool fires and passive and/or active
protection for jet fires shall be provided and demonstrate the effectiveness and reliability.
Effectiveness of passive mitigation shall be supported by calculations or test results for the
thickness limiting temperature rise and active mitigation shall be justified with calculations
or test results demonstrating flow rates and durations of any cooling water would mitigate
the heat absorbed by the vessel. (section 4.12.6)
105. Prior to construction of final design, Annova shall file a projectile analysis that
demonstrates whether each LNG storage tank would withstand projectiles from explosions
and high winds, or demonstrate whether protective measures are in place to ensure the
structural integrity of each LNG storage tank. If the analysis demonstrates the tank would
be penetrated, Annova shall file an analysis indicating the containment dikes would
sufficiently contain an LNG spill. (section 4.12.6)

106. Prior to construction of final design, Annova shall file an analysis demonstrating that
each LNG storage tank’s water deluge system would provide adequate thermal mitigation
to withstand the radiant heat from an adjacent LNG storage tank dike fire. (section 4.12.6)
107. Prior to construction of final design, Annova shall provide an evaluation of impacts from
any size jetting releases from each LNG storage tank platform, marine dock and trestle,
and the ethylene make-up drum area. As applicable, the evaluation shall demonstrate that
adequate mitigation would be provided to prevent cascading damage. (section 4.12.6)
108. Prior to commissioning, Annova shall file a detailed schedule for commissioning through
equipment startup. The schedule shall include milestones for all procedures and tests to be
completed: prior to introduction of hazardous fluids and during commissioning and
startup. Annova shall file documentation certifying that each of these milestones has been
completed before authorization to commence the next phase of commissioning and startup
will be issued. (section 4.12.6)
109. Prior to commissioning, Annova shall file detailed plans and procedures for: testing the
integrity of onsite mechanical installation; functional tests; introduction of hazardous
fluids; operational tests; and placing the equipment into service. (section 4.12.6)
110. Prior to commissioning, Annova shall file a plan for clean-out, dry-out, purging, and
tightness testing. This plan shall address the requirements of the American Gas
Association’s Purging Principles and Practice, and shall provide justification if not using
an inert or non-flammable gas for clean-out, dry-out, purging, and tightness testing.
(section 4.12.6)
111. Prior to commissioning, Annova shall file the procedures for pressure/leak tests which
address the requirements of ASME VIII and ASME B31.3. The procedures shall include
a line list of pneumatic and hydrostatic test pressures. (section 4.12.6)
112. Prior to commissioning, Annova shall file the settlement results from hydrostatic testing
of the LNG storage containers as well as a routine monitoring program to ensure
settlements are as expected and do not exceed applicable criteria in API 620, 625, and 653.
The program shall specify what actions would be taken after various levels of seismic
events. (section 4.12.6)
113. Prior to commissioning, Annova shall equip the LNG storage tank and adjacent piping
and supports with permanent settlement monitors to allow personnel to observe and record
the relative settlement between the LNG storage tank and adjacent piping. The settlement
record shall be reported in the semi-annual operational reports. (section 4.12.6)
114. Prior to commissioning, Annova shall file the operation and maintenance procedures and
manuals, as well as safety procedures, hot work procedures and permits, abnormal
operating conditions reporting procedures, simultaneous operations procedures, and
management of change procedures and forms. (section 4.12.6)
115. Prior to commissioning, Annova shall tag all equipment, instrumentation, and valves in
the field, including drain valves, vent valves, main valves, and car-sealed or locked valves.
(section 4.12.6)

116. Prior to commissioning, Annova shall file a plan to maintain a detailed training log to
demonstrate that operating, maintenance, and emergency response staff has completed the
required training. (section 4.12.6)
117. Prior to introduction of hazardous fluids, Annova shall complete and document all
pertinent tests (Factory Acceptance Tests, Site Acceptance Tests, Site Integration Tests)
associated with the DCS and SIS that demonstrates full functionality and operability of the
system. (section 4.12.6)
118. Prior to introduction of hazardous fluids, Annova shall develop and implement an alarm
management program to reduce alarm complacency and maximize the effectiveness of
operator response to alarms. (section 4.12.6)
119. Prior to introduction of hazardous fluids, Annova shall develop and implement
procedures for plant personnel to monitor the rocket launches from the Brownsville
SpaceX facility and take mitigative actions before and after a rocket launch failure to
minimize the potential of release reaching offsite areas or resulting in cascading effects
that could extend offsite or impact safe operations. (section 4.12.6)
120. Prior to introduction of hazardous fluids, Annova shall complete and document a
firewater pump acceptance test and firewater monitor and hydrant coverage test. The
actual coverage area from each monitor and hydrant shall be shown on facility plot plan(s).
(section 4.12.6)
121. Prior to introduction of hazardous fluids, Annova shall complete and document a pre-
startup safety review to ensure that installed equipment meets the design and operating
intent of the facility. The pre-startup safety review shall include any changes since the last
hazard review, operating procedures, and operator training. A copy of the review with a
list of recommendations, and actions taken on each recommendation, shall be filed.
(section 4.12.6)
122. Annova shall file a request for written authorization from the Director of OEP prior to
unloading or loading the first LNG commissioning cargo. After production of first
LNG, Annova shall file weekly reports on the commissioning of the proposed systems that
detail the progress toward demonstrating the facilities can safely and reliably operate at or
near the design production rate. The reports shall include a summary of activities,
problems encountered, and remedial actions taken. The weekly reports shall also include
the latest commissioning schedule, including projected and actual LNG production by each
liquefaction train, LNG storage inventories in each storage tank, and the number of
anticipated and actual LNG commissioning cargoes, along with the associated volumes
loaded or unloaded. Further, the weekly reports shall include a status and list of all planned
and completed safety and reliability tests, work authorizations, and punch list items.
Problems of significant magnitude shall be reported to the FERC within 24 hours. (section
4.12.6)
123. Prior to commencement of service, Annova shall label piping with fluid service and
direction of flow in the field, in addition to the pipe labeling requirements of NFPA 59A
(2001). (section 4.12.6)

124. Prior to commencement of service, Annova shall file plans for any preventative and
predictive maintenance program that performs periodic or continuous equipment condition
monitoring. (section 4.12.6)
125. Prior to commencement of service, Annova shall develop procedures for offsite
contractors’ responsibilities, restrictions, and limitations and for supervision of these
contractors by Annova staff. (section 4.12.6)
126. Prior to commencement of service, Annova shall notify the FERC staff of any proposed
revisions to the security plan and physical security of the plant. (section 4.12.6)
127. Prior to commencement of service, Annova shall file a request for written authorization
from the Director of OEP. Such authorization would only be granted following a
determination by the Coast Guard, under its authorities under the Ports and Waterways
Safety Act, the Magnuson Act, the MTSA of 2002, and the Security and Accountability
For Every Port Act, that appropriate measures to ensure the safety and security of the
facility and the waterway have been put into place by Annova or other appropriate parties.
(section 4.12.6)
In addition, conditions 128 through 131 shall apply throughout the life of the Annova
LNG terminal.
128. 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, Annova 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 P&IDs
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 submitted. (section 4.12.6)
129. Semi-annual operational reports shall be filed with the Secretary to identify changes in
facility design and operating conditions; abnormal operating experiences; activities (e.g.,
ship arrivals, quantity and composition of imported and exported LNG, liquefied and
vaporized quantities, boil off/flash gas); and plant modifications, including future plans
and progress thereof. Abnormalities shall include, but not be limited to,
unloading/loading/shipping 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, non-scheduled maintenance or repair (and reasons therefore), relative movement
of storage tank inner vessels, hazardous fluids releases, fires involving hazardous fluids
and/or from other sources, negative pressure (vacuum) within a storage tank, and higher
than predicted boil off rates. Adverse weather conditions and the effect on the facility also
shall 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 be included in the
semi-annual operational reports. Such information would provide the FERC staff with

early notice of anticipated future construction/maintenance at the LNG facilities. (section

4.12.6)
130. In the event the temperature of any region of the LNG storage container 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. (section
4.12.6)
131. Significant non-scheduled events, including safety-related incidents (e.g., LNG,
condensate, refrigerant, or natural gas releases; fires; explosions; mechanical failures;
unusual over pressurization; and major injuries) and security-related incidents (e.g.,
attempts to enter site, suspicious activities) shall be reported to the FERC staff. In the event
that 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 the FERC staff
within 24 hours. This notification practice shall be incorporated into the LNG terminal’s
emergency plan. Examples of reportable hazardous fluids-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. release of hazardous fluids for 5 minutes or more;
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 facility that contains, controls, or processes hazardous fluids;
g. any crack or other material defect that impairs the structural integrity or reliability
of facility that contains, controls, or processes hazardous fluids;
h. any malfunction or operating error that causes the pressure of a pipeline or facility
that contains or processes hazardous fluids to rise above its maximum allowable
operating pressure (or working pressure for LNG facilities) plus the build-up
allowed for operation of pressure-limiting or control devices;
i. a leak in facility that contains or processes hazardous fluids that constitutes an
emergency;
j. inner tank leakage, ineffective insulation, or frost heave that impairs the structural
integrity of an LNG storage tank;
k. any safety-related condition that could lead to an imminent hazard and cause (either
directly or indirectly by remedial action of the operator), for purposes other than
abandonment, a 20 percent reduction in operating pressure or shutdown of
operation of a pipeline or facility that contains or processes hazardous fluids;
l. safety-related incidents from hazardous fluids transportation occurring at or en
route to and from the 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
terminal’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 terminal to cease
operations. Following the initial company notification, the FERC staff would determine
the need for a separate follow-up report or follow up in the upcoming semi-annual
operational report. All company follow-up reports shall include investigation results and
recommendations to minimize a reoccurrence of the incident. (section 4.12.6)


Office of Energy Projects
Washington, DC 20426

Volume II - Appendices
Annova LNG Common Infrastructure, LLC Docket No. CP16-480-000

Annova LNG Brownsville A, LLC FERC\EIS: 0291F
Annova LNG Brownsville B, LLC April 2019
Cooperating Agencies:
U.S. Army Corps

of Engineers U.S. Environmental U.S. Fish and U.S. Coast Guard
National Wildlife Service
Protection Agency
Park Service
U.S. Department U.S. Department of National Oceanic and Federal Aviation

of Energy Transportation, Pipeline and Atmospheric Administration - Administration
Hazardous Materials Safety National Marine Fisheries Service
Administration
APPENDIX A
DISTRIBUTION LIST FOR THE NOTICE OF AVAILABILITY
APPENDIX A
DISTRIBUTION LIST FOR THE NOTICE OF AVAILABILITY
Federal Government – Elected Officials National Park Service, Intermountain Region, Christine
Whitacre
U.S. Representative Filemon Vela, TX
National Park Service, Palo Alto Battlefield National
U.S. Senator John Cornyn, TX
Historical Park, Rolando Garza
U.S. Senator Ted Cruz, TX
National Park Service, Palo Alto Battlefield National
Federal Agencies Historical Park, Mark Spier
Advisory Council on Historic Preservation, Office of Office of the Assistant Secretary of the Army for Civil
Federal Programs, Charlene Vaughn Works, Assistant for Environment, Tribal &
Bureau of Ocean Energy Management, Chief, Division Regulatory Affairs
of Environmental Assessment Dr. Jill Lewandowski Office of the Deputy Assistant Secretary of the Army
Bureau of Oceans and International Environmental & (Installations), Liaison, DoD Siting Clearinghouse
Scientific Affairs, Foreign Affairs Officer Alexander SAF/IEI
Yuan Office of the Deputy Assistant Secretary of the Army
Bureau of US Customs and Border Protection – (Energy & Sustainability), Liaison, DoD Siting
Gateway Bridge Clearinghouse
Bureau of US Customs and Border Protection - Office of the Deputy Under Secretary of Defense
Seaport (Installations & Environment), Chief, Mission
Evaluation Branch DoD Siting Clearinghouse
Council on Environmental Quality, Assoc. Director for
NEPA Oversight, Edward Boling Office of the Assistant Secretary of the Navy, Energy,
Installations, and Environment
Council on Environmental Quality, Deputy General
Counsel Manisha Patel U.S. Army Corps of Engineers, Planning and Policy
Division, John Furry
Federal Energy Regulatory Commission, Office of
Energy Projects, Division of Gas, Project Manager Eric U.S. Army Corps of Engineers, Galveston District,
Tomasi Field Office Lead, Nicholas Laskowski
Federal Bureau of Investigation U.S. Army Corps of Engineers, Policy Analysis
Branch, Galveston District, Denise Sloan
Housing and Urban Development, Office of
Environment and Energy, Community Planner Danielle U.S. Coast Guard, Rusty Wright
Schopp U.S. Coast Guard, Commandant, Deepwater Ports
National Center for Environmental Health, Centers for Standards Division, Attorney/Advisor, Curtis Borland
Disease Control, Director of Division of Emergency U.S. Coast Guard, Sector Corpus Christi, Jalyn
and Environmental Health Services Sharunda Stineman
Buchanan U.S. Coast Guard, Sector Corpus Christi, Samuel
National Marine Fisheries Service, National NEPA Creech
Coordinator U.S. Customs & Border Protection, Dept. of Homeland
National Marine Fisheries Service, Habitat Security, Branch Chief Christopher Oh
Conservation Division, Heather Young U.S. Department of Agriculture, Natural Resources
National Marine Fisheries Service, Protected Conservation Service, National Environmental
Resources Division, Kelly Shotts Coordinator, Andree DuVarney
National Marine Fisheries Service, Southeast Region, U.S. Department of Agriculture, FSA, Conservation
Mike Tucker and Environmental Program Division, National
National Oceanic and Atmospheric Administration, Environmental Compliance Manager, Nell Fuller
NEPA Policy and Compliance, Steve Kokkinakis U.S. Department of Agriculture, Gateway Bridge
National Park Service, Chief, Environmental Planning U.S. Department of Agriculture Forest Service–
and Compliance Branch, Patrick Walsh Ecosystem Management Coordination, Joe Carbone
U.S. Department of Defense Siting Clearinghouse
A-1 Distribution List for the NOA

U.S. Department of Energy, Office of Environmental U.S. Department of Transportation, PHMSA, Karen
Management, Principal Deputy Assistant Secretary Lynch
Mark Whitney U.S. Department of Transportation, PHMSA, Jeffrey
U.S. Department of Energy, Office of NEPA Policy Wiese
and Compliance, Acting Director Brian Costner U.S. Department of Transportation, PHMSA, Buddy
U.S. Department of Energy, Director, Division of Secor, Jr, PE
Natural Gas Regulatory Activities, John Anderson U.S. Environmental Protection Agency, Director,
U.S. Department of Health and Human Services, NEPA Compliance Division, Cliff Rader
Environmental Program Manager, Edward Pfister U.S. Environmental Protection Agency, Natural Gas
U.S. Department of Health and Human Services, Chief STAR, Jerome Blackman
Environmental Officer, Everett Bole, CHMM U.S. Environmental Protection Agency, Director,
U.S. Department of Interior, Bureau of Land Office of Federal Activities, Susan Bromm
Management, Senior NEPA Specialist, Kerry Rogers U.S. Environmental Protection Agency, Asst.
U.S. Department of Interior, Bureau of Land Administrator, Office of Enforcement and Compliance
Management, FERC Contact Assurance, Lawrence Starfield
U.S. Department of Interior, Bureau of Indian Affairs, U.S. Environmental Protection Agency Region 6, Keith
NEPA Coordinator, Terry L. McChlung Hayden
U.S. Department of Interior, Bureau of Indian Affairs, U.S. Environmental Protection Agency Region 6,
BJ Howerton NEPA Coordinator, Michael Jansky
U.S. Department of Interior, Bureau of Safety and U.S. Environmental Protection Agency Region 6,
Environmental Enforcement, Chief, Environmental Chief, Wetlands Section, Maria Martinez
Enforcement Division, Charles Barbee U.S. Environmental Protection Agency Region 6,
U.S. Department of Interior, Bureau of Safety and Wetlands Section, Alison Fontenot
Environmental Enforcement, Chief, Environmental US Fish and Wildlife Service, Laguna Atascosa
Compliance Division, David Fish National Wildlife Refuge
U.S. Department of Interior, director, Office of U.S. Fish and Wildlife Service, Texas Coastal
Environmental Policy and Compliance Ecological Services Field Office, Pat Clements
U.S. Department of Justice, Environment & Natural U.S. Fish and Wildlife Service, Texas Coastal
Resources Division, NEPA Coordinator Ecological Services Field Office, Dawn Gardiner
U.S. Department of Transportation, Office of Assistant U.S. Fish and Wildlife Service, Texas Coastal
Secretary for Transportation Policy, Camille Ecological Services Field Office, Charles Ardizzone
Mittelholtz
U.S. Geological Survey, Chief, Environmental Mgt.
U.S. Department of Transportation, Office of Assistant Branch, Esther Eng
Secretary for Transportation Policy, Helen Serassio
U.S. Immigration and Naturalization Service, Gateway
U.S. Department of Transportation, Surface Bridge
Transportation Board, Victoria Ruston
U.S. Marshals
U.S. Department of Transportation, PHMSA, OPS,
Bryn Karaus U.S. Senate, Energy and Natural Resources
Committee, Chairman Lisa Murkowski
U.S. Department of Transportation, PHMSA, OPS,
Melanie Stevens Texas Agencies and Elected Officials
U.S. Department of Transportation, PHMSA, OPS, Governor of Texas Gregory Abbott
Ahuva Battams Lt. Governor of Texas Dan Patrick
U.S. Department of Transportation, PHMSA, OPS, State Representative Eddie Lucio, III
Kenneth Lee
Public Utility Commission of Texas, Commissioner
U.S. Department of Transportation, PHMSA, William Kenneth Anderson
Schoonover
Public Utility Commission of Texas, Executive
U.S. Department of Transportation, PHMSA, Alan Director Brian Lloyd
Mayberry
Distribution List for the NOA A-2

Public Utility Commission of Texas, Commissioner City of Brownsville, Commissioner At-Large A Estela
Brandy Marquez Chavez
Public Utility Commission of Texas, Chair Donna City of Brownsville, Commissioner At-Large B Rose
Nelson Gowen
Railroad Commission of Texas, Chair, Christi City of Brownsville, Commissioner, District 1, Ricardo
Craddick Longoria, Jr.
Railroad Commission of Texas, David Porter City of Brownsville, Commissioner District 2, Jessica
Railroad Commission of Texas, Ryan Sitton Tetreau-Kalifa
Railroad Commission of Texas, Leslie Savage City of Brownsville, Commissioner District 3, Deborah
Portillo
Texas Commission on Environmental Quality,
Commissioner Toby Baker City of Brownsville, Commissioner District 4, John
Villarreal
Texas Commission on Environmental Quality,
Commissioner Zak Covar City of Laguna Vista, Mayor Susie Houston
Texas Commission on Environmental Quality, City of Port Isabel, Jared Hockema
Executive Director Richard Hyde City of Port Isabel, Mayor Joe Vega
Texas Commission on Environmental Quality, CAPM, City of South Padre Island, Mayor Barry Patel
NEPA Coordinator Elizabeth McKeefer County Administrator, Pete Sepulveda, Jr.
Texas Commission on Environmental Quality, Chair County Commissioner Precinct 1, Sofia Benavides
Bryan Shaw
County Commissioner Precinct 2, Alex Dominquez
Texas Commission on Environmental Quality, NSR
Air Permits Section, Kate Stinchcomb County Commissioner Precinct 3, David Garza
Texas Department of Public Safety, Tony Pena, Jr. County Commissioner Precinct 4, Dan Sanchez
Texas Department of Transportation, Pharr District Port of Brownsville, CEO & Director Eduardo
Office, Homer Brazan, Jr Campirano
Texas General Land Office, Land Commissioner Port of Brownsville, Director of Engineering Services,
George Bush Ariel Chavez
Texas Historical Commission, Mark Wolfe Port of Brownsville, Harbormaster, Michael Davis
Texas Parks and Wildlife Department, Rebecca Port of Brownsville, Director of Administrative
Hensley Services, Deborah Duke
Texas Parks and Wildlife Department, Julie Wicker Port of Brownsville, Director of Finance, Stephen
Fitzgibbons
Local Governments and Elected Officials
Port of Brownsville, Chief of Police and Security,
Brownsville Navigation District, Chair Ralph Cowen Carlos Garcia
Brownsville Navigation District, Vice Chair Carlos Port of Brownsville, Director of Maintenance, Joe
Masso Garza
Brownsville Navigation District, Commissioner & Port of Brownsville, Commissioner, Sergio Lopez
Secretary John Reed
Port of Brownsville, Human Resources Manager,
Brownsville Navigation District, Commissioner Sergio Jaime Martinez
Tito-Lopez
Port of Brownsville, Administrative Assistant to Port
Brownsville Navigation District, Commissioner John Director/CEO, Margie Recio
Wood
Port of Brownsville, Director of Cargo Services, Tony
Brownsville Navigation District/Port of Brownsville, Rodriguez
Deputy Port Director, Donna Eymard
Port of Brownsville, Director of Industrial
Cameron County Commissioners Court, Judge Carlos Development, Beatrice Rosenbaum
Cascos
Port of Brownsville Public Scale, Inc.
City of Brownsville, Mayor Tony Martinez
Libraries
Brownsville Public Library

Laguna Vista Public Library Allen, Susan

Port Isabel Public Library Almaguer, Ernesto
Media Alonzo, Lisa
Port Isabel-South Padre Press Alpert, Emily
The Brownsville Herald Altmeyer, David
Native Americans Altum, Angelika
Alabama-Coushatta Tribe of Texas, THPO, Bryant Alvarado, Arantza
Celestine Alvarado, Deborah
Carrizo/Comecrudo Nation of Texas, Juan Mancia Alvarado, Veronica
Comanche Nation of Oklahoma, THPO, Jim Arterberry Alvarez, Andy
Lipan Apachae Tribe of Texas, Chairman, Bernard Alvarez, Antonio
Barcena, Jr. Alvarez, Carmen
Tonkawa Tribe of Oklahoma, President, Donald Alvarez, Maria
Patterson
American Commercial Lines
Intervenors
American Divers
The Friends of Laguna Atascosa National Wildlife
American Diving
Refuge
American River Transportation Company
Ricardo Salinas
Anastasoff, Beverly
David Thurston
Anders, Helen
Mary Voltz
Anderson, Dianah
Affected Landowners on or Adjacent to Proposed
Facilities and Routes Anderson, Dianah
Brownsville Navigation District / Port of Brownsville Anderson, Leah
U.S. Fish and Wildlife Service Anderson, Marty
Other Interested Parties Anderson, Patrick
Andrews, Justin
Abbott, Marilyn
Andrus, Lisa
Abedor, Betty
ANGA, Frank Macchiarola
ABF Freight Systems Inc.
Angelo Inter-Logistics
Adam, Lisa
Anthony, Gail
Adler, June
Anthony, Gail
Adrian, Jan
Aquirre, Belen
Adrianita, Inc, Mauricio Chavez
Ardington, Amy
Agapie, Helen
Arellano, Daisy
Aguilar Brothers, Inc, Josue Aguilar
Arevalo, Raul
Aguilar, Virginia
Argo ES&H Services, LLC, Barry Chambers
Alamo, Carmen
Arredondo, Elma
Alamo, Carmen
Arredondo, Santiago
Albrecht, Jeff
Arroyos, Glory
Alejos, Marisol
Ashberry, William
Alexander, Kathleen
Ashley, June
Allen, Linda
Atkinson, Barbara
Allen, Loretta
Auto Lineas, Sigifredo Garcia Palacios

Avalos, Josie Bay Bridge Texas, Shailesh Vyas

Avey, Carolyn Bay, Alexis
Avila, Jane Bayne, Dalmara
Ayala, Gisela Bayside Marine, Inc, Ruben Fuentes
Ayodele, Oluwadare Michael Bea, Linda
Babberney, Cameron Bea, Linda
Babberney, Cameron Beane, Debbie
Backues, Anna Beay, William
Bacon, Kim Bechill, Debbie
Bagley, Susan Bedoli Group, Inc (All Star Metals), Nikhil Shah
Bailey, Linda Bee, Bea
Bailey, Sharon Bee, Bea
Baker, B Beemer, Sandra
Baker, B Belisle, Mavis
Baldovinos, Alicia Bell, David
Bales, Brenna Bell, Spencer
Ball, Stewart Benavidez, Alma Linda
Ballenso, Josh Bendle, Shannon
Balog, Vera Benedict, Catherine
Balogh, William Bennett, Jack
Baltrusch, Libby Bennett, Patricia
Baltrusch, Libby Benning, James
Balzrette, Erin Benno, Georgine
Banda, Terry Berg, Bill
Banks, Ann Berger, Linda
Barajas, Brooke Bergner, Christy
Bard, Greg Bernache, Marie
Barker, Wendy Bernal, Adrion
Barker-Stanton, Charlotte Berry, Elizabeth
Barnes, John Berry, Ken
Barr, Tim Berzon, Patricia
Barr, Tim Best, Bill
Barron, Jack Bethke, Linda
Basham, Lonnah Betzmane, Lupita
Bass, Judi Beverly, Robert
Bates, Riannan Bhandari, Ranjana
Bates, Stephen Bhandari, Ranjana
Batton, Karal Bhatt, Ashvin
Batton, Karal Biehl & Company, Mark Clive
Baughman, Kay Bieri, Sandra
Bautista, Justin Bigley, Kim
Bax, Alise Bigwood, David

Bills, Robert Bradford, Debra

Bilokur-Tobias, Rebecca Bramblett, Sharon
Bilokur-Tobias, Rebecca M Branch, Keri
Birdwell, Walter Brattin, Eric
Bishop Merrill, Dr Sarah Braun, Cecil
Bissett, Berenice & David Braune, Linda
Bittle, Juanita Bravo Motor Carriers, Luis Garza, Jr
Biven, Donna Braxton, Angelika
Black Dragon Pirate Ship & Thriller High Speed Boat Bray, Brent
Black, Kimberly Bray, Brent
Blackburn, Diane Brazeau, Theodore
Blackshear, Sherry Breakfield, Sandra
Blackwell, John Breaux, Misty
Blais, Darren Brennecke, Don
Blake, Frank Bresnehan, Rhonda
Blandford, Mark Brezall, Jennifer
Blanford, Julie Brian, James
Blevins, Terri Briggs Equipment Rental, Elizabeth Cantu
Bliss, Cecelia Brittain, Cindy
Blixt, Sally Brooks, Karl
Blount, James Brooks, Patricia
Blount, Mary & Sammy Brooks, Pippa
Bob's Bay Fishing Brophy, Tracy
Bode's Bay Fishing Brown, Brandye
Bogorad, Geoff & Rossane Brown, Kristen
Boling, Blake Brown, Monika
Bollinger, Jacqueline Brown, Tracy
Bond, Katherine Browning, John
Bondy, Mamie Browning, Rette
Bonilla-Leach, Yvette Brownsvile South Padre Island Board of Realtors,
Bonilla-Leach, Yvette Larry Jokl
Bonner, Tracey Brownsville Chamber of Commerce, Humphrey
Thomas, Chair
Boon, Royce
Brownsville Gulfside Warehouse, Lee Ostos
Boone, David
Brownsville Historical Association
Boswell, Brian
Brownsville Mooring, Rick Gomez
Botts, Leslie
Brumby, Val
Boward, Karen
Brunson, Robert
Bowden, Rose
Bryte, Klementyna
Bowen, Paul
Buinger, Mary
Bowling, Beth
Bulla, Dale
Bowling, Deanna
Burford, Marth
Box, Ken

Burgoon, Larry Cantu, Roel

Burke, Stephen Captain Memo Corp, Manuel Fayett
Burkett, Winifred Cardona, Sue & Gilbert
Burks, Phyllis Cardoza, Blanca
Burnell Marine & Supply, Inc, Charles Burnell Carey, Madalynn
Burnett, Billy Carnesi, Cody
Burnett, Buena Carpenter, John
Burns, Bill Carpenter, Laurie
Burns, Kathryn Carpenter, Robert
Burns, Kathryn Carr, Karen
Burson, Sandra Carr, Michael
Burt, Susan Carrion, Roxanne
Burzinski, Cindy Carrizo/Comecrudo Nation of Texas, Juan Mancias
Bush, Julie Carter, Maria
Bustillos, Raul Carter, S
Butterfield, Colleen Carter, S
Butts, Jill Carver, Bob
Byrd, Calvin Castaneda, Karen
Byrd, Sandra Castellanos Corp, Marcos Hernandez
Byrne, Elaine Castiglia, Denise
Byrne, Sean Castillo, Jesus
C&J Logistical Services, Crispin Flores Castillo, Juan
C, Adam Castillo, Sandra
Caceres, Herbert Castro, Erica
Cadwalader, Wickersham & Taft LLC, Brett & Mark Caton, Annie
Snyder, Counsel to Annova LNG Cavazos, Deborah
Cain, Linda Cavazos, Flora
Caldwell, Richard Cavazos, Vanessa
Callahan, Jayne Ceballos, Samantha
Cameron County Historical Commission Cedillo, Bernice
Cameron, Jean Celtic Marine Corporation
Campbell, David Cervantes, Marisol
Campbell, David Cervenka, Martha
Campbell, JA Cervone, Katherine
Canal Barge Company Inc Ceverra, Victoria
Canales, Susan Chaffins, Sheila
Canas, Nydia DL & Carlos Chamberlain, Clinton
Cannata Nowell, Anita Chamberlain, Jane
Cannata Nowell, Anita Chapa, Jose
Cantrell, Lyndsay Chavarria, Sr, Gus
Cantu, Elizabeth Chavez, Geneva
Cantu, Pedro Chavez, Gerardo

Chavez, J Franco Cottle, Lawrence

Chavez, Jr, Amado Couch, Georgia
Choi, Debbie Courim, Stephen
Christian, Linda Courtney, Carole
Ciarocco, Joan Courtney, Carole
Cimino, Maryrose Covington, Jace
CITGO Petroleum Corporation, Charles Milstead Cowen, Karen
Clanton, LeAnne Cox, Jeralynn
Clark, John Cox, Nonya
Clark, Sherri Cozad, Bren
Clark, Stephen Cozart, Erin
Clayton, Alexander Crabtree, Corliss
Clayton, Tom Crabtree, Corliss
Cleland-Sipfle, Kate Craddock, Kathryn
Clements, Bonnie Craig, Elizabeth
Clements, Bonnie Craig, Mark
Cloyd, Stephen Cramer, Pat
Cochran, Christina Crandall, AnaLisa
Codina, Dr Edward Crane, Stuart
Coen, Leona Crane, Stuart
Cohen, Elaine Crosby, Debbie
Coldwell, Sherilyn Cross, Dave & Rita
Cole, Donna Crunk, Jeff
Cole, Elena Crutcher, Cindy
Cole, Elena Cummings, Alyssa
Coleman, Diane Cunningham, Ian
Collins, Kristi Cunningham, Sarah
Collins, Sarah Cupit, Willy
Comacho, Tomas & Petra Curren, Leslie
Commander, Lower Rio Grande Valley Sail and Power Curry, Marcia
Squadron and Lower Laguna Madre Foundation, CG Curtis, Connie
Rakestraw
Curtis, Cynthia
Converse, Camille
Cushnie, Deborah
Co-Op Marine Railways, LLC, Raul Garcia
CVC Construction, Inc dba Welding Works
Cooper, Gary International, Alfredo De la Fuente
Copen, Terry Dabrowski, Alfred
Cordova, Sergio Dahle, Kay
Cordova, Sergio Dalmolin, Brigitte
Coronado, Alejandro Dalton, Carolyn
Cortez Castro, Diana Daly, Chrissy
Costales, Ann Dampeer, Karen
Cottenoir, Denise Dana, Sherry

Daniel B Hastings, Inc, Matthew Leyendecker Denson, Tommie

Daniels, Michael Deslaurier, Toni
Danna, David Devine, Jeanne
Danny B Fishing Charters Deykes, Lowell
Darr-Hall, Jamie DeZelle, Jessica
Dartez, Carroll Diaz, Fernandio
Dassing, Dwayne Dick, Marion
Daves, Tom Dietz, Jennielee
Davidson, Dr David Dietz, Leada
Davidson, Kathryn Dix Agency Brownsville, LP, Robert Ostos
Davidson, Steve Dix Shipping Company, Lee Ostos
Davila, Alfred Dixon, Amy
Davis, Danny Dixon, Joyce
Davis, Michael Dlc, Jill
Davis, Shonna Dobbs, Michael
Davis, Vicki DoD Siting Clearinghouse, Steve Sample
Davison, Pamela Dodaro, Raymond
Day, Joanne Dodds, Kathrin
Day, Linda Doggett Heavy Machinery Service, Greta Daniels
De Anda, Norma Dolphin Docks
De Angelis, Christine Don Nico Trawlers, Inc, Hilario Ordonez Pimienta
de Jesus Mirquez, Diana & Maria Dougherty, Janet
de la Pena, David Drake, Monica
De La Rosa, Edlyn Draper, Mallory
De Lara, Celia Dredgeservice, LLC, Charlie Ange
Dee, Wendy Drescher, Sandra
Deep Six Diving Druke, Carmen
Deep South-Tex Terminal, LP, Fred Figueroa Dubois, Merir
Defenders of Wildlife, Jason Rylander, Senior Dubrick, Michael
Attorney Ducks Unlimited, William Hunter Schnabl
DeGroff, Dorinda Duda, Tim
DeHaas, Lorraine Duesterhoeft, Diane
Del Campo, Francisco Duesterhoeft, Diane
Delaney, Janet Duke, Deborah
DeLavan, Mary Jo Duker, Yvonne
DeLay, James Dunbar Hernandez, Cecilia
Delgado, Santos Duncan, Don
Delossantos, Nicholas Duncan, Sylvia
DeMello, Cecelia Durrance, Joseph
Demobio, Angely Duval, Beth
Demoss, Aine Dwarka, Sandy
Densing, Lindsey Dwarka, Sandy

E, Cheryl Ferguson, Robert & Frieda

Easterling, Anne Ferguson, Tyler
Eckert, Barbara Fisher, Lisa
Eckes, Alexandrea Fite, Donald
Edelman, Patti Fitzpatrick, Dr Paul
Edelstein-Best, Julie Fivklkng, Sarsh
Effinger, Joaquin Fleeman, Paul
Ehemann, Barbara Fleming, Charis
EIIxondo, Ignacio Flesner, JoAnn
Ekstrom, Nicole Fletcher, Barbara
Elder, Kenneth Flores, Blanca & Jesus
Elkins, Helen Flores, Marilyn
Emerson, Judith Flores, RosaLinda
Emshoff, Arthur Flosi, Dr Alicen
England, Ctney Fly, Carol
English, Danie Fonseca, Dr Vincent
Epstein, Kelly Forbes, William
Ersson, Melanie Ann Foreign Trade Zone #62, Tony Rodriguez
Escamille, JA Foreign Trade Zone Board
ESCO Marine Inc, Richard Jaross Foreman, Charles
Escobedo, Rubie Fossom, Karen
Eskew, Candyce Foster, D
Esmaili, Abde Foster, Halima
Espinoza, Margarita Foster, Kay
Ethridge, Cole Foster, Lucy
Euler, Keith Foster, Marguerite
Eustis, Scott Foster, Will
Eustis, Scott Fouche, Jan
Evans, Pamella Fovar, Marie
Evitt, Kinney Fowler, Idell
Exelon Business Services Company, LLC, Susan B Fowler, Rick
Bergles, Assistant General Counsel Frank, Sharon
Faidley, Richard Franklin, Mary
Faile, Kay Frarnk, Lesta
Farenkopf, Nathan Frazier, Lynda
Farr, Kathy Freeman, M
Farrokhi, Farideh Freer, Judith
Faulkner, Anita Frick, Patricia
Favela, Jennifer Friedman, Diane
Fel Glo, Inc, Felipe Mendez Friends of the Wildlife Corridor, Richard Ramke
Fellows, Arthur Frost Bank, Patti Ayala
Ferchaud, Rick Fry, Kim

Fry, Pearl Garza-Birdwell, Yolanda

Fuller, Aaron Gauna, Matt
Fullerton, Nancy Gauna, Matt
Fuqua, Chad Geery, Susan
Fusinato, Robert General Steamship Corporation, Ltd, Thomas Miller
Fusinato, Robert Gianakos, Mary
G&O Shrimp Co, Inc, Gerald Pockrus Gibson, Jody
G, Jacque Gibson, Melanie
G., Jacque Gijsbers van Wijk, Helena
Gallaway, Ann Gillespie, Sharon
Galvan, Viola Gillham, Patsy
Gamez, Angie Gilliand, Jeannine
Gamez, Laura Gimblet, JR
Ganger, Patricia Givens, Vera
Garcia, A Hector Gladys Porter Zoo, Dr Patrick Burchfield
Garcia, Alex Glenberg, Laurel
Garcia, Ariana GloriaJr, Jesus
Garcia, Belen Gluntz, Carol
Garcia, Carlos Goette, Edna
Garcia, Carlos Goetz, Shane
Garcia, Hector Goff, Gayle
Garcia, Juan Carlos Gomez, Belda
Garcia, Oscar Gomez, Benjamin
Garcia, Patrick Gomez, Cynthia
Garcia, Patty Gomez, Jr, Albert
Garcia, Raul dba Garcia Bookeeping, Raul Garcia Gonzales, Patricia
Garcia, Shirley Gonzales, Toni
Garcia, Yuri Gonzalez Garcia, Thania
Garcia, Zeilha Gonzalez Trawlers, Inc, Jorge Gonzalez, Jr
Gard, Paul Gonzalez, Christina
Gardner, Robert Gonzalez, Elke
Garrett, Cecilia Gonzalez, Eva
Garrett, Sandra Gonzalez, Jaime
Garrett, Yolanda Gonzalez, Jaul
Garza, Cathy Gonzalez, Jazmin
Garza, Cathy Gonzalez, Mary
Garza, Cynthia Gonzalez, Mary
Garza, Denise Gonzalez, Nohemi
Garza, Maria Gonzalez, Nohemi
Garza, Silvia Gonzalez, Rebecca
Garza, Stefany Gonzalez, Ronando
Garza, Tina Goodman, Mark

Goodman, Mark Hanley, Katherine

Goodwin, Jodi Hanratty, Linda
Goodykoontz, Deborah Hansen, Dr Yvonne
Gordon, Rick Hansen, Edd, Yvonne
Goss, Patsy Happytide Charters
Gossett, Glenn Hardin, Andrew
Graham, Jim Hargrave, Charles
Graul, Kara Haro, Osbert
Green, Darcy Harp, Edith
Green, Earl Harrington, Rita
Greene, Susan Harris, Rhonda
Gregory, Zulma Harris, Shirlene
Griffin, Terence Harris, Shirlene
Griffith, Gloria Harrison, Karon
Griffith, Virginia Harrison, Michael
Grimaldo, Mary Harrison, Wayne
Groshardt, Joanne Hartford, Jeffrey
Gross, Emily Hartwell, Edward
Guajardo, Caroline Hawke, Kimberly
Guajardo, Hector Hawks, E Diana
Guaraldi, Thomas Head, Jonathan
Guerra, Lydia Head, Jonathan
Guffey, Carol Heare, Lorna
Guh, H Heath, William
Guitron, Luis Heggen, Sandra
Gulf Facilities, Ken & Nico Schaefer Heifner, Mary
Gulf Stream Marine, Mark Hoskins Heig, Lauren & Greg
Gunnerson, Denny Heino, Ruth
Gutierrez, Maximillian Held, Herbert
H Sáenz, Jr Inc, Beto Saenz Helton, Jeff
Haber, Arnold Henderson, Marian
Hadovsky, Linda Hendricks, Diane
Hagaman, Celeste Hendrix, Laura
Hahn, Todd Hendrix, Sunshyne
Hailey, Keith Hennen, Michael
Hall, Donna Henning, Marcus
Hall, Phyllis Herbert, Jacqueline
Hallen, Vikki Hermann, Marianne
Hamilton, Joyce Hernandez, Brenda
Hamilton, Joyce Hernandez, Cynthia
Hancock, Tommy Hernandez, Denise
Hands, Frank Hernandez, Emily

Hernandez, Jesus Houlik-Ritchey, Emily

Hernandez, Leticia Houston, Tamara
Hernandez-Barron, Brenda Howell, Laurie
Herrera, Jennifer Hradsky, Susan
Herrera, Yesenia Hradsky, Susan
Herrington, Paula Hughes, Ginger
Herting, Joshua Hughes, Ken
Herzing, Suzanne Hughes, Lisa
Hewes, William Hughes, Teran
Hibbitts, Edna Hutchings, Lee
Hickey, James Ibarra, Griselda & Saul
Hights, Sharyn Ibert, Denne
Hill, Jim Inglis, Adrienne
Hill, Toni Ingraham, E
Hilliard, Kenneth Ingraham, E
Hime, Vickie Ingram Barge Line
Hindley, Bradford Inman, Robert
Hinojosa, Maria Antonia Inspectorate
Hlad, Greg International Income Tax Service, LLC, Elmer Shull
Hockaday, Mabel International Shipbreaking, Ltd, Robert Berry
Hoenes, Bill Inter-Transfer,-TRIMAC INC
Hoggatt, Denice Ireland, Ellen
Hogle, Harriett Iron Mike Marine, Inc, Randy Chambers
Hohl, Sharon Irvine, Charles
Holcomb, James Island Outfitters
Holder, Matthew ISS Marine Services, Inc dba Inchcape Shipping
Holguin, George Services, Glenn Foster
Holguin, Mary Jacquemotte, Diane
Holler, Stephen Jacques, Sally
Holleschau, Karen Jakubik, Paul
Holleschau, Karen & Leigh James, Deborah
Hollman, Mary & Larry James, Deborah
Holtz, Steve James, Suzanne
Holtzman, Larry & Susan James, Suzanne
Homer, Michael Janavaris, Jimmy
Honel, Michael Janick, Lori
Hood, Dell Janis, Bertha
Hood, Gayle Jaramillo, Jose Raul & Johanna
Hook, Misty Jatinen, Jane
Hopkins, Davi Jaudzemis, Kathleen
Horton, Kevin Jaudzemis, Kathleen
Houlik-Ritchey, Emily Jeffery, Katheryn

Jenkins, Janell Kasper, Tanya

Jenney, Lida Kasper, Tanya
Jevric, Virginia Katzen, Ellen
Jimenez, Citlally Kaufman, Stephanie
Jimenez, Michelle Kaushik, Nagender
Jimenez, Odilia Kavanagh, Dr Kate
Johnson, Bernie Kavanaugh, Michael
Johnson, Joanne Kay, Cheryl
Johnson, Kenneth Kelcher, Patricia
Johnson, Lilli Keller, Dr John
Johnson, Matthew Kern, Edward
Johnson, Patrice Kerstetter-Kennedy, Tina
Johnson, Preciosa Kessler, Marjorie
Johnson, Shane King, Christen
Johnson, Shannon King, Judy
Johnson, Sheilla Kirby Inland Corp
Johnson, Vivian Kirkpatrick, Gabriel
Johnston, Elise Klein, James
Jolly, Karen Kline, Kristen
Jolly, Karen Knight, Mavis
Jones, Anne Knox, Richard
Jones, Cecil Kobler, Linda
Jones, Julie Kohn, Ethan
Jones, Linda Kolenovsky, Jay
Jones, Mitzi Konicek, Linda
Jones, Nancy Korab, Lela
Jones, Patricia Koreski, Patti
Jones, Patricia Kotch, Brant
Jones, Patricia Kresha, Matthew
Jonick Lopez International Transport & Warehouse, Kring, Juli
Sergio Lopez Krog, Karen
Jordan, Mel Krone, Robert
Jordan, Perry & Michael Kruse, Teresa
Jorgensen, Julia Kuretza, Monica
Jozwiak, Mary Kvapil, Samara
Juan's Electric, Juan Delgadillo L, Martha
Judd, Susanne Lagrone, Amy
Junkin, Douglas Laguna Sailing Charters
Justice, Bruce Lamberty, Jean
Kane, Jay Lamons, Kristina
Kantola, Barbara Lancaster, Stephen
Kantola, Barbara Landfield, Kathleen

Landfield, Kathleen Lehr, Karen

Landro, Inc dba S T Marine, Leonel Alejandro Leidner, Tammie
Landry, Don Leidner, Tammie
Lane, Pat Lema, Roxann
Lane, Sandra Lemon, Kerry
Lane, Veva Lents, Carla
Lane, Veva Lewis, Alexander
Lang, Jeffry Lewis, Beth & James
Langford, Jeanette Lewis, Remmic
Langley, Wayne Lewis, Trey
Langston, John Lewis, Weldon
Lankton, Jackie Lewis, Weldon
Lansdale, Joe & Karen Libby, Aida
Lansdale, Karen Lienhard, Pamela
Lara, Bethany Lienhard, Pamela
Lara, H Javier Liles, Benjamin
Lara, Stephanie Limberg, Kim
Lardy, Cheryl Limberg, Kim
Lareau, Patricia Lin, Dr Judy
Larsen, Ken Lin, Stella
Latigo, Lauren Linda Lou Boat Corporation, Jack Waller
Lauritsen, Nancy Lindley, Kenton
Law, Susan Lindqvist, Dr Annika
Lawrence, Claire Lindsey, Anne
Lawrence, Claire Lininger, Steve
Lawrence, Georgia Linwood Trawlers, Inc c/o Raul Garcia, Dolby
Lawrence, Jaen Linwood
Lawrence, Katherine Lionetti, Marc
Lawrence, Preston Lira, Kelsey
Lazell, Dr. James Liu, Sue
Lazell, James Livingston, Catherine
Leach, Stephen Llanes, Daniel
Leal, Alma Llatona, Kay
Leal, Fidencio Lloyd, Jeanne
Leal-McBride, Odilia Lobdill, Jerry
Leatherman Van Praag, Jane Lock, Dat
Leaverton, David Locke, Stephen
Lee, Bill Loe, Lee
Lee, Dr Tom Loera Customs Brokerage, Minerva Loera
Leerssen, Taryn Logan, T
Lees, Jackie Logan, T.
Leggon, Janette Lohse, Hunter

Lone Star Chapter Sierra Club, Reggie James, Interim Maher, Javad
Chapter Director Mahoney, Ruth Ann
Lone Star Charters Mahoney, Ruth Ann
Long Island Village Board of Directors, Ed McBride Mains, Robin
Long, Cheri Mane, Cathy
Long, Kay Mannchen, Brandt
Longoria, B Celeste Mannchen, Brandt
Looney Kochie, Lois Maquilogistics, Carlos Ruiz
Lopez, Alicia Marcum, Gina
Lopez, Elizabeth Marcum, Gina
Lopez, Gilberto Mares, Alfred
Lopez, Gilberto Margos, Carol
Lopez, Lourdes Marhoun, Donna
Lopez, Marco Maria Elena, Inc, Seth Sanders
Lopez, Randy Marine & Industrial Safety, Yolanda Linarte
Lopez, Stephanie Marine Metal, Omar Perez
Lorenz, Marilyn & Chuck Marine Railway, Inc, Greg Londrie
Lothe, Richard & Dorothy Marine Refrigeration Co, Andrew Jurek
Loveless, Philip Marine Salvage & Services, Inc, Billy Kenon
Lovett, Susan Marolt, Carla
Lowe, James Marone, Susan
Lower Rio Grand Group Sierra Club, Jim Chapman Mars, Elaine
Lucas, Sherry Marshall, Rebecca
Lucio, Jr, Eddie Martec Leasing LLC, Ania Mierzejewska
Lucio, Richard Martin Gas Marine
Lucko-Powell, Lisa Martin, Barbara
Ludwig, Jack Martin, Gregory
Luke, Tawnya Martin, Patricia
Luna, Epuardi Martin, Sonia
Luna, Monica Lee Martines, Elora
Lupori, Stacy Martinez Tijerina, Kathryn
M&M Mooring Services, Mark Clive Martinez, Adriana
M, J Martinez, Hector
M/V Challenge 42, Inc, Raul Cervantes Martinez, Janie
Macfarlane, Jane Martinez, Lourdes
Macias, Michael Martinez, Martha
MacKinnon, Bonnie Lynn Martinez, Rosario
Maddem, Richard Maschal, Tim
Madden, Jensie Mason, Caitlin
Madole, Richard Mason, Susan
Madrigal, Julie Massa, Ayn
Maguire, Cynthia Matcek, Vicki

Matejek, Ann McMahan, Lindsey

Mathes, Ann McMahon, Marci
Matheson, Neill McManis, Katrin
Mathis, Jesse McManus, Clyde
Matlock, Benjamin McMillan, Joy
Matlock, Benjamin McMurtrey, Michael
Matlock, Teresa McNeese, Amanda
Matteson, James McQueen, Jim
Matusoff, Cathy McRaynolds, Cindy
Maua, Marisela McReynolds, Allen
Maverick Terminals Brownsville, LLC, Canevari McVean, Nancy
Castan Mead, Barbara
May, Michele Medrano, Dalila & Ana
Maycotte, Ernesto Meeks, Dana
Mayfield, Joan Mehis, Jim
Mayfield, Maureen Meinerding, Doris
Mayo, Judy Mejia, Felipe
Mays, Frieda Mendez, Jennifer
Mcbrayer, Kay Mendieta, Vince
McBrayer, Kay Mendoza, Alma
McBride, Debbie Mercedes City Commission, Howard Wade
McBride, Ed Merrill, Rebecca
McCall, Kaye Merrill, Trish
McCollam, Clare Merz, Evelyn
McCormick, Jana Merzbacher, Mary
McCradic, Anthony Meyer, La Vina Jo
McDonald, Mary Meyers, Mickey
McDonald, Mary Meyerson, Jeff
McDowell, Clionton Meza, Alex
McElroy, Jim Meza, Miguel
McEnany, Judy Michuda, Bianca
McEwen, Bruce Michuda, Bianca
McFall, Cynthia Mick, Robert
McGaffey, Barbara Milam, Tim
McGowen, Mary Milazzo, Julia
McIntosh, Malva Miles, Toni
McIntyre, Kellen Millard, Ann
McKee, George Miller, Jesse
McKee, Jim Miller, John
McKinney, William Miller, Keena
McLean, Janyce Miller, Pamela
McLish, Rachel Miller, Rebecca

Millsap, Lisa Mueller, Ken

Milo, James Mullens, Troy
Miloy, Tyler Mullican, Mack
Mireles, Danielle Munez, Amanda
Misak, Kevin Munroe, Laura
Miss Anid, Inc, Manuel Sanchez Murphy, Michael
Mitchell, Connie Murua, Aimee
Mitchell, Crystal Muscara, Joe
Mock, T Randall Muse, Dyan
Moga, Hugo Museum of South Texas History
Monahan, Michael Musgrove, Keith
Monita, Inc c/o Garcia Bookkeeping, Benjamin Lopez Musgrove, Keith and Tracy
Monroe, Kim Myers, Dixie
Montag, Alexander Myers, Donald
Montag, Alexander N, Carter
Montalvo, Cecilia N, M
Montapert, Anthony Nash, Carol
Montgomery, Dot National Seafoods, Inc, William Kenon
Montgomery, Michael & Linda Nazor, Craig
Moore Diesel Service, Wenn Moore Nazor, Craig
Moore, Ellen Neinast, Thomas
Moore, Geroge Newfeld, David
Moore, Jr, Joseph Newfield, Myra
Moore, Linda Newman, Dr Janet
Moore, Linda Newman, Kathy
Moore, Norma Nichols, Carol
Moore, Pauline Nichols, Douglas
Mora, Thomas Nickerson, Judith
Mora, Val Nicks, Carol
Mora, Val Nicol, Deborah
Morales, Armando Nicol, Eliya Zay
Morales, Dulce Nicol, Scott
Morales, Joel Nieland, Tom
Moravek, Martha & Joe Nitishin, Lawrence
Morgan, Claudia Nolan, Sylvia
Morgan, Matt Norberto Perez, CPA, PC, Norberto Perez
Morgenstern, Bill Norrell, Marie
Morlock, Juan Norrell, Marie
Morris, Joyce Northrop, Emily
Moses, Sylvette Norton, Karen
Mosher, Haraold Norton, Karen
Mouledous, Laurey Noy, Nick

Obek, Anna Pallana, Ranjana

Obrien, Gina Palmer, Saralie
Ocean Port Maintenance, Inc, Jorge Gonzalez, Jr Pantel, Jesus
Oceanus Intl, Thomas Hayden Paquette, Cynthia
Ochoa, Marcelino, Marcelino Ochoa Paragraphs On Padre Blvd, J Montover
Ockerman, Leslie Paredes, Myra
O'Connor, Angelita Paredes, Myra
Odear, Elizabeth Parker & Company, Abel Medina
Oil Patch Fuel & Supply, Inc, Carl Gayman Parker & Company, David Dubois
Okulewicz, Kathy Parker & Company, Steve Muschenheim
Okwumabua, Verena Parker, Delores
Okwumabua, Verena Parker, Jr, Frank
Olguin, Martin Parker, Marilyn
Olguin, Martin Parrot Eyes Fishing Charters
Olivarez, Cristela Parsons, James
Olivarez, Gilbert Pasztor, Patricia
Oliveira, Rene Patch, Frances
Olschesky, Karyn Patrick, Duane
Olson, Charles Patteson, Patricia
O'Malley, Lorelei Patton, Audrey
One Cypress Terminals, Inc, Mike McCann Paukman, Joseph
O'Neal, Nancy Paul, Jeff
O'Neil, Carol Pauler, Donna
O'Neill, Catherine Pauwels, Anita
Oppenheim, Jenniferr Peace, Annalisa
O'Quinn, Blake Peace, Tom
Orloff, Michael Pearson, Rick
Orr, Carla Peck, Terry
Ortega, Nora Pena, Deanna
Ortega, Vanessa Peniche, Lori
Osborne, Suzanne Penmar Systems, Inc, Kay Krapf
Osprey Cruises Pennington, Carol
Otken, Marilyn Perez, Betty
Owen, Daina Perez, Caryn
Owen, Robert Perkins, Joel
Pace, Edgar & Cinda Perkins, Mitzi
Pacheco, Leonor Perkins, Mitzi
Packard, Karen Perry, Ed
Padgett, Robyn Perry, Joy
Padier, James Perry, Kathleen
Pagan, Leslie Perry, Robert
Palder, Evelyn Pesaresi, Martin

Pesaresi, Martin Rabb, Sharon

Peters, Lisa Race, Margery
Petrarca, John Rahbar, Asad
Pettit, Jean & Douglas Ramirez, David
Petty, Christine Ramos, Andres
Petty, Jospeh Ramos, Jannette
Pfeiffer, Karen Ramos, Richard
Pfost, Tom Ramsey, Liz
Philip T Cowen Randall, Victoria
Phillips, Pamela Raul Garcia Bookkeeping, Jorge Gonzalez
Pierce, Kristen Rausch, Carol
Piersol, Laurel Rausch, Carol
Piper, Laurie Rausch, Carol
Pittman, Casey Ray Wolf Commercial Diving Incorporated
Pizana, Jr, Jesse Ray, Yvonne
Plitt Leasing Co, Ltd, Walter Plitt Raymond, Norma
Pollo's Diesel/Mota's Refrigeration, Ramon Ortega Reardon, Julie
Ponce, Daniel Recio, Marsie
Ponder, Dr Fred Reece, Ray
Ponder, Misty Reed, Dawn
Port Isabel Chamber of Commercee, Chair Reed, Jane
Port Isabel Historical Museum Reedy, Boyd
Port Restaurant, Luis Ricardo Cortinas Reeves, Angie
Porter, Emory Regnier, Sharynn
Power, Laurel Reichel, Rhonda
Poynter, Mark Reid, Nelda
Poythress, Marianne Reinhardt, Jason
Prado, Issac Reising, Brian
Pratt, Byron Rental World, Robert Suarez
Preservation Texas Reves, Mickey
Pressgrove, Cheryl Revord, Michael
Prevost, Jennifer Reyes Marine Industries, Inc, Carlton Reyes
Prevott, Ray Reyes, James
Pride, Mark Reyes, Lonnie
Purata Trawlers, Inc, Pedro Purata Reyes, Samantha
Purdy, Patrick Reynolds, Kaileen
Putman, Holly Reynolds, Kenneth & Sharon
Putnam, Gary Reynolds, Linda
Quality Weighing Services Reynolds, Tabitha
Quenan, Joan RGV Hispanic Chamber of Commerce, Cynthia
Quezada, Francisco Sakulenzki
Quigley, Erin Rhein, Herman

Rice, Wanda Roser & Cowen Logistical Service, Neto Roser

Rich, Donna Roser Customs Service, Inc, Rico Roser
Richard, Karen Rosevelt, Ken & Linda
Richards, Gary Ross, Bruce
Richert, Barbara Ross, Nancy
Richey, Robert Roy, Randy
Richter, Dwight RSC Equipment Rental, Chris Lowery
Richter, Richard RTW Properties, LP, Bill Mallory
Riddle, Rick Ruffin, Claire
Riebeling, Andrea Ruiz, Chris
Riker, Holly Ruiz, Severo
Riley, Dr Steven Runnells, Kathryn
Rivas, Bianca Russell, Catherine
RM Walsdorf, Inc, RM Walsdorf Russo, Melissa
Roark, Dan Rust, Tom
Roberts, Lyn Rutherford, Cyndi
Roberts, Lyn S, Maria
Roberts, Mark Sabin, Sandra
Roberts, Peggy Sada, Holly
Robertson, Kathleen Saenz, Jamaila
Robinson, Dennis Saenz, Jesse
Robinson, Donald Saenz, Norma
Robinson, Staci Salamon, Mark
Roca Construction Co, Ricardo Roca, Sr Salas, Alexa
Roche, Jose Saldivar, Teresa
Rodco Marine Supply, Inc, Juan Rodriguez Salinas, Jason
Rodriguez, Bonnie & Ernie Salinas, Kenneth
Rodriguez, Cesar Sanchez, Carroll
Rodriguez, Daniel Sanchez, Elaine
Rodriguez, Priscilla Sanchez, III, Andres
Rogers, Dirk Sanchez, Manuel
Rogers, Joe Sanchez, Saul
Rogers, Judith Sanchez, Seraluna
Rogers, Robert Sanchez, Seraluna
Rohrbach, Terry Sandall, Karen
Rohwedder, Caroline Sandefar, Madeleine
Romano, Denise Sandel, Morris
Romo, Jacqueline Sanders George, Kim
Rooney, John Sands Cleary, Susan
Rosas, Jorge Sardina, Evelyn
Rose, Mary Sue Sardina, Evelyn
Roser & Cowen Logistical Service, Danny Lopez Sargeant, Sandra

Sariol, Teresa Shaffer, Tria

Saucedo, Jess Shannon, Brooke
Savage, Lois Sheats, Ned
Saxon, Rich Shelburne, GB
Sayles, Katherine Shelton, Johnna
Schaefer Stevedoring, Ken Schaefer Shenberger, Ronald
Schafer, Sharon Shephard, Phil
Schatz, Monica Sheppard, Andy
Schill, Brian Shippee, Bob
Schleicher, Dorothy Shivers, Shelly
Schlie, Darilynn Shrier, Donald
Schmidt, Charles Shuff, Janet
Schmidt, Mary Shuff, Janet
Schmidt, Melinda Shumate, Gayle
Schmoker, Henry Shurgot, Joseph
Schniederjan, Patricia Sieve, Elizabeth
Schoech, Dr D Signet Maritime Corporation, Ida Treviño
Schroeder, Black Sikes, Eddie
Schroeder, Briana Silguero, Lisa
Schroeder, Kristen Silva, Irma
Schultz, Mary Simmer, Doug
Schwarz, Carol Simmer, Doug
Sciarrillo, Loisann Simpson, Jacquelynn
Scott, Bennie Simpson, Sally
Scott, Dorinda Sivley, Steve
Scott, K Skillman, Gloria
Scott, Leticia Skillman, Gloria
Scott, Millard Smith, David
Sea Breeze Marine, Inc c/o Raul Garcia, Juan Gaona Smith, E Neil
Sea Kirk, Inc d/b/a La Manana, Fred Feurtado Smith, Horace
Sea Ranch Marina Smith, Jeannie
Sea Turtle, Inc, Shane Wilson Smith, Kate
Sears, Brenda Smith, LA
Sebesta, Emilie Smith, Lawrence
Seff, Joshua Smith, Leslie
Seibert, Roxanne Smith, Shirley
Seifert, James Smith, Thomas & Lisa
Seifert, Mike Snell, Jade
Sells, Greg Snodgrass, Inc, Sam Snodgrass
Serna, Arnoldo Snook, Helen
Serna, Joyce Snook, Helen
Shade, Grover Snyder, Gary

Soles, Thad Stuart, Peter

Solis, Mare Suarez, Mariu
Sollis, Al Suarez, Pat
South Padre Island Chamber of Commerce, Roxanne Subsea 7, Stuart Redpath
Guenzel Suissa, David
South Padre Island Watersports Sularz, Michael
Southern Wave Sullivan, Karen
Southwell, Dolly Summers, Daniel
Southwestern Motor Transport, Inc Summers, Susan
Sparks, Mary Sunbelt Transport, Inc
Speers, Susan Surfrider Foundation South Texas Chapter, Rob Nixon
Spencer, David Sustaita, Matthew
Spencer, Larry Swarts, Hilary
SPI Fish Killer Tours Swiatkowski, Ray
Spoon, Cindy Swolinski, Susan
Spottswood, Dana T Parker Host Gulf, Inc, Randy Tate
Spradlin, Michael Tamez, Emilio
Sprecher, Donyce Taque, Heather
Springfield, Juanita Tashnick, Walter
Squires, Emma Tatum, Margaret
St Clair, Laura Tave, Jeff
St Louis, Al Taylor, K
Stahl, Dennis Teague, Susan & John
Stclair, Laura Teeter, Keith
Stedman, Dr Deborah Tejas Equipment Rental, Esteban Lozano
Steele, Art Telfair, II, Ray
Stein, Terry Tellez, Michelle
Stephens, Gary Templet, Mel
Stewart, Donna Terrier Transportation, Mary Rivera
Stewart, Sharron Tetra Tech, John Crookston, Deputy Project Manager
Stierlen, Lorelei Tetra Tech, John Scott, Project Manager
Stippec, Rudy & Barbara Texas Gold Shrimp Tour
Stippec, Rudy and Barbara Texas Guld Trawling
StLouis, Al Texas Shrimp Association, Andrea Hance
Stoddart, Jacque & John Texas Southmost College, Lily Tercero, PhD, President
Stofan, Sandra Texas Sportfish
Stoker, Stephen Texas State Technical College, Stella Garcia, Interim
Stolt Transportation Services President
Stone, Lisa Tharp, Brett
Stoughton, Romlee Thaxter, John
Streb, Sandra The Los Fresnos Area Chamber of Commerce, Val
Strong, William Champion, Executive Director

The Original Dolphin Watch Valdez, Lellani & Felix

Theroux, Maureen Valdez, Nadia
Thomas, Gary Valerio, Avely
Thomas, Heather Joy Valero Brownsville Terminal, LLC, James Stegall
Thomas, Randy Valle Hernandez, Jose Antonio
Thompson, Dean Valle, Beymalda
Tillman, Henry Vallejo, Juliet & Sandra
Tischer, Jennifer Valley Lubricants, Inc, David Eymard
Tobias, Carol & Frank Valley Trucking Company
Tobin, Ralph Vallie, Margaret
Todd, David van Dalert, Marinda
Tomlinson, Barbara Van Dellen, Adrian
Tomlinson, Barbara van Dijik, Marie
Torres, Elias Van Haaften, Rene
Torres, John-Michael Van Leekwijck, Natalie
Torres, Lore Maris Vandel, Diana
Torres, Mafalda Vanderslice, Tiffany
Torres, Maria vanWert, Jane
Torres, Yolanda Vanya, Rene
Torrey, Julie Vanya, Rene
Towns, Anna Varljen, Anne
Trahn, Margaret Vassilakidis, Pat
Trammell, Rebecca Vazquez, Jessika
TRANSMONTAIGNE Operating Co, Kevin Garcia Veit, Barbara
Travis, Donna Mae Vela, Erica
Triggs, Mark Vela, Fabian
Triplett-Wilkerson, Michelle Vela, Luanne
Troxell, Shawn Velez, Jill
Troxell, Shawn Veltman, Beverly
Truesdell, Carolyn Venmar Shrimp, Inc, Jose Manuel Aponte
Tuch, Vera, Irma
Tupper, Mary Verbeke, Betty
Turner, Jessica Verein, Vejeya
Tute, Gary Villarreal, Christina
Two Fishing Friends, Inc, Emigdio Cruz Villarreal, Eloisa
Tyma, Ellen Vincentnathan, Lynn
Underwood, Ralph Vise, Pamela
Unruh, Dawn Volkerts, James
US Offshore, Inc, Robert Berry Volunteer Barge & Transport, Inc
Usrey, Tara Volz, Mary
V, Ernesto Vulcan Construction Materials, LP, David Farrar
Valdez, Denise W, Alex

Waggoner, Hope Wharton, Becky

Wagner, Hunter Wharton, Becky
Wagner, Kimberly Whistler, Marley
Wagner, Kimberly Whitaker, Penny
Wagner, Ruth White, Sue
Wagner, Stephanie White, Susan
Waits, Mark Whitener, Barbara
Waldorf, Kimberly & Robert Whitten, Darice
Walker, Lynda Whitwell, Giselle
Walker, Tatjana Whitwell, Giselle
Wallace, Cathy Wierenga, Lucinda
Wallace, Leigh Ann Wierenga, Lucinda
Wallace, Mollie Wiggins, James
Walton, JD Wigle, Jean
Ward, Dr Ralph Wilcox, Mary
Ward, Harrison Wildfong, William
Ward, Whitney Wilkinson, Quinta
Warfield, Benjamin Wilkinson, Quinta
Watenpool, Chris Willbourn, Summer
Watt, Michael Williams, Charlene
Way, Susie Williams, James
Wayte, Marilyn Williams, Maria
Weathers, Theresa Williams, Norman
Weathers, Theresa Williams, Sabine
Weathersbee, Jim Williams, Susan
Weaver, Cheyenne Williams, Terrie
Weaver, Mary Williams, Tracy
Webb, Shirley Williams, Troy
Weber, Regina Williamson, Cynthia
Weber, Regina Williamson, Mary
Webster, Dr Michael Willing, Rick
Weedman, Shawn Willis, John
Wehberg, Shelley Willis, Kimberly
Weiss, Ronnie Willmann, M'Liss
Welch, Mary Willoby, Randolph
Welch, Shane Wills, Deb
Wells, Charlotte Wilson, Grant
Wengler, Doris Wilson, John
Werchan, Meranne Wilson, Judith
Westermann, William Wilson, Nancy
Wetmore, Larry Wimberly, Siena
Wetmore, Larry Wimmer, Martin

Windham, Dallas Zwarun, Andrew

Windsor, Lucinda Zwarun, Andrew
Wing, Byron
Winnette, Laurie
Winsett, Bettie
Winstead, Annie
Wisdom, Ami
Witte, Mark
Wolfe Sandbalsting & Industrial Painting, Don Wolfe
Wong, Victor
Wood, Shelva
Woodall, Sandra
Woolverton, David
Wordlaw, Christine
Worthington, Geoge
Wren, Rebecca
Wyche, Paula
Wyrick, Brenda
Yado, Sissi
Yancey, Donald
Yarber, John
You, Sam
Youker, Katy
Youker, Rob
Young, John
Young, Ron
Youngblood, Taylor
Younger, Patricia
Yu, Christian
Zaloski, Shari
Zamarripa, Mary Jane
Zamarron, Michelle
Zambie, David
Zamora, Bertha
Zamora, Cecilia
Zamora, Rita
Zappone, MaryJo
Zarrinnam, Shirin
Zavala, Alfonso
Zavala, Rafael
Zeigler, John
Zetley, Herb

APPENDIX B
ANNOVA’S PLAN AND PROCEDURES
Upland Erosion Control, Revegetation, and

Maintenance Plan
Client: Annova LNG, LLC.
Project: Annova LNG Brownsville

Location: Brownsville, Texas
Document Number: 183169-REFF-0036

Black & Veatch Project Number: 183169
Annova Project Number: 0001
File No. 30.0000
Rev Revision Description DATE BY CHK'D APP'D

A Issued for Initial Review (DRAFT) 8/03/2015 MMS PWS DMW
B Revised for Final RR1 4/22/2016 MMS DMW
Revised to incorporate the FERC
C 10/31/2016 MMS DMW
10/20/2016 Comments
Annova LNG Brownsville Upland Erosion Control, Revegetation, Revision C

183169.30.0000 and Maintenance Plan
1.0 APPLICABILITY
A. This Plan identifies baseline mitigation measures for minimizing erosion and
enhancing revegetation. Annova LNG, LLC (Annova LNG), the Project sponsor,
have made this plan project-specific as part of the Brownsville Project (Project)
Federal Energy Regulatory Commission (FERC) Natural Gas Act (NGA) Section 3
certification process. This Plan applies to the Project site and temporary work space
areas as approved by the FERC.
The Project is a mid-scale liquefied natural gas (LNG) export terminal located on the
southern bank of Brownsville Ship Channel, approximately 8.2 miles upstream from
the channel mouth at Brazos Santiago Pass. Annova LNG will have long-term use of
approximately 731 acres to construct and operate the 6.0 million metric tons per
annum (mtpa) LNG facility. The natural gas delivered to the site via the feed gas
pipeline will be treated, liquefied, and stored on site in two single-containment LNG
storage tanks, each with a net capacity of approximately 42.3 million gallons
(160,000 cubic meters [m³]). The LNG will be loaded onto LNG carriers for export.
The coordinates of the site center are:

26° 00’ 20.09” N/longitude -97° 16’ 02.70” W.
Non-jurisdictional facilities that may be constructed and operated by third parties

(i.e., gas and water pipelines; electric and telecommunication lines) are not addressed
in this Plan.
If the Project is authorized, variances to the measures in this Plan will be submitted
to the Director of the Office of Energy Projects (Director). The Director will consider
approval of the variances if the Director agrees that a varianceOnce variances to the
measures in this Plan will be submitted to the Director of the Office of Energy
Projects (Director). Approval by the Director is expected, assuming the Director
agrees the variance:
1. provides equal or better environmental protection;
2. is necessary because a portion of this Plan is infeasible or unworkable based

on project-specific conditions; or
3. is specifically required in writing by another federal, state, or Native

American land management agency for the portion of the project on its land
or under its jurisdiction.
Project-related impacts on wetland and waterbody systems are addressed in the

Project Wetland and Waterbody Construction and Mitigation Procedures
(Procedures).
BLACK & VEATCH PAGE | 1


2.0 SUPERVISION AND INSPECTION

2.1. ENVIRONMENTAL INSPECTION
1. The number and experience of Environmental Inspectors and monitors

assigned to the construction site will be appropriate for the
number/significance of resources affected.
2. Environmental Inspectors will have peer status with all other activity
inspectors.
3. Environmental Inspectors will have the authority to stop activities that violate
the environmental conditions of the FERC’s Orders, stipulations of other
environmental permits or approvals, or landowner easement agreements; and
to order appropriate corrective action.
2.2. RESPONSIBILITIES OF ENVIRONMENTAL INSPECTORS
At a minimum, the Environmental Inspector(s) will be responsible for:
1. Inspecting construction activities for compliance with the requirements of this

Plan, the Procedures, the environmental conditions of the FERC’s Orders, the
mitigation measures proposed by Annova LNG (as approved and/or modified
by the Order), other environmental permits and approvals, and environmental
requirements in landowner lease/easement agreements.
2. Identifying, documenting, and overseeing corrective actions, as necessary to

bring an activity back into compliance;
3. Verifying that the limits of authorized construction work areas and locations
of access roads associated with the Project are visibly marked before clearing,
and maintained throughout construction;
4. Verifying the location of signs and highly visible flagging marking the
boundaries of sensitive resource areas, waterbodies, wetlands, or areas with
special requirements in the construction work area;
5. Identifying erosion/sediment control and soil stabilization needs in all areas;
6. Ensuring that the installation of slope breakers will not cause erosion or direct
water into sensitive environmental resource areas, including cultural resource
sites, wetlands, waterbodies, and sensitive species habitats;


7. Verifying that dewatering activities are properly monitored and do not result
in the deposition of sand, silt, and/or sediment into sensitive environmental
resource areas, including wetlands, waterbodies, cultural resource sites, and
sensitive species habitats; stopping dewatering activities if such deposition is
occurring and ensuring the design of the discharge is changed to prevent
reoccurrence; and verifying that dewatering structures are removed after
completion of dewatering activities;
8. Test subsoil and topsoil as appropriate to measure compaction, and determine

the need for corrective action prior to seeding:
9. Advising the Construction Manager when environmental conditions (such as

wet weather or frozen soils) make it advisable to restrict or delay construction
activities to avoid topsoil mixing or excessive compaction;
10. Ensuring the final contours are in accordance with final project grading
plans;
11. Verifying that imported soil used for revegetation, of which none is
anticipated, has been certified as free of noxious weeds and soil pests;
12. Ensuring that erosion control devices are properly installed to prevent
sediment flow into sensitive environmental resource areas (e.g., wetlands,
waterbodies, cultural resource sites, and sensitive species habitats) and onto
roads, and determining the need for additional erosion control devices;
13. Inspecting and ensuring the maintenance of temporary erosion control

measures at least:
a. on a daily basis in areas of active construction or equipment

operation;
b. on a weekly basis in areas with no construction or equipment

operation; and
c. within 24 hours of each 0.5 inch of rainfall;
14. Ensuring the repair of all ineffective temporary erosion control measures
within 24 hours of identification, or as soon as conditions allow if compliance
with this time frame would result in greater environmental impacts;
15. Keeping records of compliance with the environmental conditions of the

FERC’s Orders, and the mitigation measures proposed by Annova LNG in
the application submitted to the FERC, and other federal or state
environmental permits during active construction and stabilization activities;


16. Identifying areas that should be given special attention to ensure stabilization
after the construction phase; and
17. Verifying that locations for disposal of excess construction materials for
beneficial reuse comply with Section 3.5.
3.0 PRECONSTRUCTION PLANNING

Annova LNG or their designated project representative will perform the following before
construction:
3.1. CONSTRUCTION WORK AREAS
1. Identify all construction work areas (e.g., construction temporary facilities,

extra work space areas, material storage and contractor yards, borrow and
disposal areas, access roads) required for safe construction. Annova LNG
will ensure that appropriate cultural resources and biological surveys have
been conducted, as determined necessary by the appropriate federal and state
agencies.
2. Annova LNG will consider expanding any required cultural resources and
endangered species surveys in anticipation of the need for activities outside of
authorized work areas.
3. Plan construction sequencing to limit the amount and duration of land

disturbance, as necessary, to prevent excessive erosion or sediment flow into
sensitive environmental resource areas.
3.2. DRAIN TILE AND IRRIGATION SYSTEMS
No existing drain tiles and irrigation systems are within Project site boundaries.
3.3. GRAZING DEFERMENT
No grazing lands are within Project site boundaries.


3.4. ROAD CROSSINGS AND ACCESS POINTS
Plan for safe and accessible conditions at facility access points and related roadway
crossings during construction.
3.5. DISPOSAL PLANNING
Determine methods and locations for the regular collection, containment, and
disposal of excess construction materials and debris (e.g., timber, slash, mats,
garbage, drill cuttings and fluids, excess rock) throughout the construction process.
Disposal of materials for beneficial reuse must not result in adverse environmental
impact and is subject to compliance with all applicable survey, landowner or land
management agency approval, and permit requirements.
3.6. AGENCY COORDINATION
Annova LNG will coordinate with the appropriate local, state, and federal agencies
as outlined in this Plan and/or required by the FERC’s Orders.
1. Obtain written recommendations from the local soil conservation authorities

or land management agencies regarding permanent erosion control and
revegetation specifications.
2. Develop specific procedures in coordination with the appropriate agencies to

prevent the introduction or spread of invasive species, noxious weeds, and
soil pests resulting from construction activities.
3. Develop specific procedures in coordination with the appropriate agencies

and landowners, as necessary, to allow wildlife movement and protection
during construction.
3.7. SPILL PREVENTION AND RESPONSE PROCEDURES
Annova LNG or designee will develop project-specific Spill Prevention and

Response Procedures, as specified in the Procedures. A copy will be filed with the
Secretary of the FERC (Secretary) prior to construction and made available in the
field during construction.
3.8. RESIDENTIAL CONSTRUCTION
No properties with residences are located within 50 feet of construction work areas.

3.9. WINTER CONSTRUCTION PLANS
No winter construction is anticipated due to the humid subtropical climate of

Brownsville. If weather conditions change such winter construction becomes
necessary, Annova LNG will develop and file a project-specific winter construction
plan with the FERC in accordance with the FERC Upland Erosion Control,
Revegetation and Maintance Plan.
4.0 INSTALLATION
4.1. APPROVED AREAS OF DISTURBANCE
1. Project-related ground disturbance will be limited to the construction site,

temporary work space areas, material storage yards, borrow and disposal
areas, access roads, and other areas approved in the FERC’s Orders. Any
project-related ground disturbing activities outside these areas will require
prior Director approval. This requirement does not apply to activities needed
to comply with the Plan and Procedures (i.e., slope breakers, energy-
dissipating devices, dewatering structures) or minor field realignments and
workspace shifts per landowner needs and requirements that do not affect
other landowners or sensitive environmental resource areas. Construction
activities outside of authorized areas are subject to applicable survey and
permit requirements, and landowner easement agreements.
2. The construction site and affected areas for a project is not to extend beyond
that described in the FERC application unless otherwise modified by a FERC
Order.
Project use of additional limited areas is subject to landowner or land

management agency approval and compliance with all applicable survey and
permit requirements. When additional areas are used, each one will be
identified and the need explained in the biweekly construction reports to the
FERC, if required. The following material will be included in the reports:
a. the location of each additional area referenced to previously filed

project plans showing the additional areas;
b. identification of the filing at FERC containing evidence that the

additional areas were previously surveyed; and
c. a statement that landowner approval has been obtained and is

available in project files.
Prior written approval of the Director is required when the authorized

construction work areas would be expanded by more than 25 feet.

4.2. TOPSOIL SEGREGATION
1. Unless the landowner or land management agency specifically approves

otherwise, topsoil will not be mixed with subsoil. Topsoil will be fully
stripped from work areas specified by the landowner or land managing
agency.
2. Where topsoil segregation is required, Annova LNG will:
a. segregate at least 12 inches of topsoil in deep soils (more than 12

inches of topsoil); and
b. make every effort to segregate the entire topsoil layer in soils with less
than 12 inches of topsoil.
3. Maintain separation of salvaged topsoil and subsoil throughout all

construction activities.
4. Segregated topsoil may not be used for constructing temporary slope

breakers, improving or maintaining roads, or as a fill material, without prior
approval.
5. Stabilize topsoil piles and minimize loss due to wind and water erosion with
use of sediment barriers, mulch, temporary seeding, tackifiers, or functional
equivalents, where necessary.
4.3. DRAIN TILES – NOT APPLICABLE
4.4. IRRIGATION – NOT APPLICABLE


4.5. ROAD CROSSINGS AND ACCESS POINTS
1. Maintain safe and accessible conditions at facility access points and related
road crossings and access points during construction.
2. Minimize the use of tracked equipment on public roadways. Remove any soil
or gravel spilled or tracked onto hardtop (asphaltic or concrete) roadways
daily or more frequent as necessary to maintain safe road conditions. Repair
damages to hardtop roadway surfaces, shoulders, and bar ditches, as
identified in consult with local authorities.
4.6. TEMPORARY EROSION CONTROL
Install temporary erosion controls immediately after initial disturbance of the soil.
Temporary erosion controls must be properly maintained throughout construction (on
a daily basis) and reinstalled as necessary until replaced by permanent erosion
controls.
1. Temporary Slope Breakers
a. Temporary slope breakers are intended to reduce runoff velocity and

divert water off construction work areas. Temporary slope breakers
may be constructed of materials such as soil, silt fence, staked hay or
straw bales, or sand bags.
b. Install temporary slope breakers on all disturbed areas, as necessary to

avoid excessive erosion. Temporary slope breakers must be installed
on slopes greater than 5 percent where the base of the slope is less
than 50 feet from waterbodies and wetlands at the following spacing
(closer spacing will be used if necessary):
Slope (%) Spacing (feet)

5 - 15 300
>15 - 30 200
>30 100
c. Direct the outfall of each temporary slope breaker to a stable, well

vegetated area or construct an energy-dissipating device at the end of
the slope breaker and off the construction work areas.
d. Position the outfall of each temporary slope breaker to prevent

sediment discharge into wetlands, waterbodies, or other sensitive
environmental resource areas.

2. Sediment Barriers
Sediment barriers are intended to stop the flow of sediments and to prevent
the deposition of sediments beyond approved workspaces or into sensitive
resources.
a. Sediment barriers may be constructed of

materials such as silt fence, staked hay or straw bales, compacted earth
(e.g., driveable berms across travelways), sand bags, or other
appropriate materials.
b. At a minimum, install and maintain temporary sediment barriers in

construction work areas at the base of slopes greater than 5 percent
where the base of the slope is less than 50 feet from a waterbody,
wetland, or road crossing until revegetation is successful as defined in
this Plan. Leave adequate room between the base of the slope and the
sediment barrier to accommodate ponding of water and sediment
deposition.
c. Where wetlands or waterbodies are adjacent to and downslope of

construction work areas, install sediment barriers along the edge of
these areas, as necessary to prevent sediment flow into the wetland or
waterbody.
3. Mulch
a. Apply mulch on slopes concurrent with or immediately after seeding,

where necessary to stabilize the soil surface and to reduce wind and
water erosion. Spread mulch uniformly over the area to cover at least
75 percent of the ground surface at a rate of 2 tons/acre of straw or its
equivalent.
b. Mulch can consist of weed-free straw or hay, wood fiber hydromulch,

erosion control fabric, or some functional equivalent.
c. Mulch disturbed upland areas if:
(1) erosion and sedimentation is not controlled with installation of

erosion control measures; or
(2) construction activity is interrupted for a period of 14 days or

more, such that soil stabilization becomes necessary.


d. If mulching before seeding, increase mulch application on all slopes

within 100 feet of waterbodies and wetlands to a rate of 3 tons/acre of
straw or equivalent.
e. If wood chips are used as mulch, do not use more than 1 ton/acre and
add the equivalent of 11 lbs/acre available nitrogen (at least 50 percent
of which is slow release).
f. Ensure that mulch is adequately anchored to minimize loss due to

wind and water.
g. When anchoring with liquid mulch binders, use rates recommended by

the manufacturer. Do not use liquid mulch binders within 100 feet of
wetlands or waterbodies, except where the product is certified
environmentally non-toxic by the appropriate state or federal agency
or independent standards-setting organization.
h. Do not use synthetic monofilament mesh/netted erosion control

materials in areas designated as sensitive wildlife habitat, unless the
product is specifically designed to minimize harm to wildlife. Anchor
erosion control fabric with staples or other appropriate devices.
5.0 STABILIZATION AND CLEANUP

5.1. CLEANUP
Final facility clean-up will be conducted under the direction of Annova LNG in
consideration of long-term operation of the facility.
1. Commence cleanup operations following final grading, topsoil replacement,
and installation of permanent erosion control structures.
2. Grade the disturbed areas to direct storm water flows in accordance with
stormwater management plans and leave the soil in the proper condition for
planting.
3. Remove construction debris from all construction work areas unless the
landowner or land managing agency approves leaving materials onsite for
beneficial reuse, stabilization, or habitat restoration.
4. Remove temporary sediment barriers when replaced by permanent erosion
control measures or when revegetation is successful.


5.2. PERMANENT EROSION CONTROL DEVICES
1. Trench Breakers – Not Applicable
2. Permanent Slope Breakers
a. Permanent slope breakers are intended to reduce runoff velocity,

divert water off construction work areas, and prevent sediment
deposition into sensitive resources. Permanent slope breakers may be
constructed of materials such as soil, stone, or some functional
equivalent.
b. Construct and maintain permanent slope breakers in appropriate areas.
In the absence of written recommendations, use the following spacing

unless closer spacing is necessary to avoid excessive erosion on
construction work areas:
Slope (%) Spacing (feet)

5 - 15 300
>15 - 30 200
>30 100
c. Construct slope breakers to divert surface flow to a stable area without

causing water to pool or erode behind the breaker. In the absence of a
stable area, construct appropriate energy-dissipating devices at the end
of the breaker.
d. Slope breakers may extend slightly (about 4 feet) beyond the edge of
the construction work area to effectively drain water off the disturbed
area. Where slope breakers extend beyond the edge of construction
work areas, they are subject to compliance with all applicable survey
requirements.
5.3. SOIL COMPACTION MITIGATION
Test topsoil for compaction in areas disturbed by construction activities, as needed.

Use penetrometers or other appropriate devices to conduct tests.


5.4. REVEGETATION
1. General
a. Annova LNG is responsible for ensuring successful revegetation of

soils disturbed by project-related activities in accordance with final
project plans, except as noted in Section 5.4.1.b.
b. Restore all turf, ornamental shrubs, and specialized landscaping in

accordance with the landowner’s request, or compensate the
landowner. Restoration work must be performed by personnel
familiar with local horticultural and turf establishment practices.
2. Soil Additives
Fertilize and add soil pH modifiers in accordance with recommendations

from the local soil conservation authority.
3. Seeding Requirements
a. Prepare a seedbed in disturbed areas to a depth of 3 to 4 inches using

appropriate equipment to provide a firm seedbed. When
hydroseeding, scarify the seedbed to facilitate lodging and germination
of seed.
b. Seed disturbed areas in accordance with recommendations for seed

mixes, rates, and dates obtained from the local soil conservation
authority.
c. Perform seeding of permanent vegetation within the recommended

seeding dates. If seeding cannot be done within those dates, use
appropriate temporary erosion control measures discussed in section
IV.F and perform seeding of permanent vegetation at the beginning of
the next recommended seeding season. Dormant seeding or temporary
seeding of annual species may also be used, if necessary, to establish
cover, as approved by the Environmental Inspector.
d. In the absence of written recommendations from the local soil

conservation authorities, seed all disturbed soils within 6 working
days of completion of final grading, weather and soil conditions
permitting, subject to the specifications in Section 5.4.a through c.
e. Base seeding rates on Pure Live Seed. Use seed within 12 months of
seed testing.


f. Treat legume seed with an inoculant specific to the species using the
manufacturer’s recommended rate of inoculant appropriate for the
seeding method (broadcast, drill, or hydro).
g. In the absence of written recommendations from the local soil

conservation authorities, a seed drill equipped with a cultipacker is
preferred for seed application.
Broadcast or hydroseeding can be used in lieu of drilling at double the

recommended seeding rates. Where seed is broadcast, firm the
seedbed with a cultipacker or roller after seeding. In rocky soils or
where site conditions may limit the effectiveness of this equipment,
other alternatives may be appropriate (e.g., use of a chain drag) to
lightly cover seed after application, as approved by the Environmental
Inspector.
6.0 6.0 OFF-ROAD VEHICLE CONTROL

To each owner or manager of restricted lands, offer to install and maintain measures to
control unauthorized vehicle access to the right-of-way. These measures may include:
A. signs;
B. fences with locking gates;
C. slash and timber barriers, pipe barriers, or a line of boulders across the right-of-way;
and
D. rootballs or other appropriate trees or shrubs across the right-of-way.
7.0 POST-CONSTRUCTION ACTIVITIES AND REPORTING

Post-construction activities will be conducted under the direction of Annova LNG in
consideration of long-term operation of the facility.
7.1. MONITORING AND MAINTENANCE – NOT APPLICABLE
1. Conduct follow-up inspections of all disturbed areas, as necessary, to

determine the success of revegetation and address erosion concerns. At a
minimum, conduct inspections after the first and second growing seasons.
2. Revegetation will be considered successful if upon visual survey the density

and cover of non-nuisance vegetation are similar in density and cover to
adjacent undisturbed lands.


Continue revegetation efforts in areas formerly disturbed by construction until

ground cover provides similar pre-construction stabilization.
3. Efforts to control unauthorized off-road vehicle use, in cooperation with the

landowner, will continue throughout the life of the project. Maintain signs,
gates, and permanent access roads as necessary.
7.2. REPORTING
1. Annova LNG will maintain records that identify by construction area:
a. method of application, application rate, and type of fertilizer, pH

modifying agent, seed, and mulch used;
b. acreage treated;
c. dates of backfilling and seeding;
d. names of landowners requesting special seeding treatment and a

description of the follow-up actions; and f. any
problem areas and how they were addressed.
2. Annova LNG will file with the Secretary quarterly activity reports
documenting the results of follow-up inspections required by Section 7.1.1;
any problem areas, and corrective actions taken for at least 2 years following
construction.

Wetland and Waterbody Construction and

Mitigation Procedures
Client: Annova LNG, LLC.
Project: Annova LNG Brownsville

Location: Brownsville, Texas
Document Number: 183169-REFF-00XX

Black & Veatch Project Number: 183169
Annova Project Number: 0001
File No. 30.0000
Rev Revision Description DATE BY CHK'D APP'D

A Issued for initial review (DRAFT) 8/03/2015 MMS PWS DMW
B Revised for Final RR1 4/22/2016 MMS DMW
Revised to incorporate the FERC
C 10/31/2016 MMS DMW
10/20/2016 Comments
Annova LNG Brownsville Wetland and Waterbody Construction Revision C

183169.30.0000 and Mitigation Procedures
1.0 APPLICABILITY
A. This Procedure identifies baseline mitigation measures for minimizing the extent and
duration of project-related disturbance on wetlands and waterbodies. Annova LNG,
LLC (Annova LNG), the Project sponsor, have made this plan project-specific as part
of the Brownsville Project (Project) Federal Energy Regulatory Commission (FERC)
Natural Gas Act (NGA) Section 3 certification process. This Procedure applies to
the Project site and temporary work space areas as approved by the FERC.
The Project is a mid-scale liquefied natural gas (LNG) export terminal located on the
southern bank of Brownsville Ship Channel, approximately 8.2 miles upstream from
the channel mouth at Brazos Santiago Pass. Annova LNG will have long-term use of
approximately 731 acres to construct and operate the 6.0 million metric tons per
annum (mmtpa) LNG facility. The natural gas delivered to the site via the feed gas
pipeline will be treated, liquefied, and stored on site in two single-containment LNG
storage tanks, each with a net capacity of approximately 42.3 million gallons
(160,000 cubic meters [m³]). The LNG will be loaded onto LNG carriers for export.
The coordinates of the site center are:

26° 00’ 20.09” N/longitude -97° 16’ 02.70” W.
Non-jurisdictional facilities that may be constructed and operated by third parties

(i.e., gas and water pipelines; electric and telecommunication lines) are not addressed
in this Procedure.
If the Project is authorized, variances to the measures in this Plan will be submitted
to the Director of the Office of Energy Projects (Director). The Director will consider
approval of the variances if the Director agrees that a varianceOnce the Project is
certificated, changes from the variances to the measures in these Procedures to the
Director of the Office of Energy Projects (Director). Approval by the Director is
expected, assuming the Director agrees the variance:
1. provides equal or better environmental protection;
2. is necessary because a portion of these Procedures is infeasible or unworkable

based on project-specific conditions; or
3. is specifically required in writing by another federal, state, or Native

American land management agency for the portion of the project on its land
or under its jurisdiction.


Project-related impacts on non-wetland areas are addressed in the Project Upland

Erosion Control, Revegetation, and Maintenance Plan (Plan).


B. DEFINITIONS
1. “Waterbody” includes any natural or artificial stream, river, or drainage with

perceptible flow at the time of crossing, and other permanent waterbodies
such as ponds and lakes:
a. “minor waterbody” includes all waterbodies less than or equal to 10

feet wide at the water’s edge at the time of crossing;
b. “intermediate waterbody” includes all waterbodies greater than 10 feet

wide but less than or equal to 100 feet wide at the water’s edge at the
time of crossing; and
c. “major waterbody” includes all waterbodies greater than 100 feet wide
at the water’s edge at the time of crossing.
2. “Wetland” includes any area that is not in actively cultivated or rotated

cropland and that satisfies the requirements of the current federal
methodology for identifying and delineating wetlands.
2.0 PRECONSTRUCTION FILING

A. Annova LNG or its designee will file with the Secretary of the FERC (Secretary)
prior to the beginning of construction, for the review and written approval:
1. site-specific justifications for extra work areas that would be closer than 50
feet from a waterbody or wetland; and
2. site-specific justifications for construction greater than 75-feet-wide in

wetlands.
B. Annova LNG or its designee will file with the Secretary prior to the beginning of
construction the following information:
1. Spill Prevention and Response Procedures specified in Section 4.A;
2. a schedule identifying when dredging will occur within the Brownsville Ship
Channel. Annova LNG will revise the schedule as necessary to provide
FERC staff at least 14 days advance notice of beginning dredging operations.
3. a wetland delineation report as described in Section 6.A.1, if applicable; and


4. the hydrostatic testing information specified in Section 7.B.3.
3.0 ENVIRONMENTAL INSPECTORS

A. At least one Environmental Inspector having knowledge of the wetland and
waterbody conditions in the project area is required. The number and experience of
Environmental Inspectors assigned to each construction spread will be appropriate
for the duration of the construction and the number/significance of resources
affected.
B. The Environmental Inspector’s responsibilities are outlined in the Project’s Plan.
4.0 PRECONSTRUCTION PLANNING

A. Annova LNG will develop and implement project-specific Spill Prevention and
Response Procedures for construction in accordance with applicable federal and state
requirements. A copy of the Spill Prevention and Response Procedures will be filed
with the Secretary prior to construction and made available in the field .
1. Annova LNG and its contractors will structure construction operations in a

manner that reduces the risk of spills or the accidental exposure of fuels or
hazardous materials to waterbodies or wetlands. Annova LNG and its
contractors will, at a minimum, ensure that:
a. employees handling fuels and other hazardous materials are properly

trained;
b. equipment is in good operating order and inspected on a regular basis;
c. fuel trucks transporting fuel to on-site equipment travel only on

approved access roads upon entering the Project site;
d. equipment is parked overnight and/or fueled at least 100 feet from a

waterbody or in an upland area at least 100 feet from a wetland
boundary. These activities can occur closer only if the Environmental
Inspector determines that there is no reasonable alternative, and
Annova LNG and its contractors have taken appropriate steps
(including secondary containment structures) to prevent spills and
provide for prompt cleanup in the event of a spill;
e. hazardous materials, including chemicals, fuels, and lubricating oils,

are not stored within 100 feet of a wetland or waterbody unless the


Environmental Inspector determines that there is no reasonable

alternative, and Annova LNG and its contractors have taken
appropriate steps (including secondary containment structures) to
prevent spills and provide for prompt cleanup in the event of a spill.
This applies to storage of these materials and does not apply to normal
operation or use of equipment in these areas;
f. concrete coating activities are not performed within 100 feet of a

wetland or waterbody boundary, unless the Environmental Inspector
determines that there is no reasonable alternative, and the project
sponsor and its contractors have taken appropriate steps (including
secondary containment structures) to prevent spills and provide for
prompt cleanup in the event of a spill;
g. portable diesel engine driven pumps operating within 100 feet of a

waterbody or wetland boundary utilize appropriate secondary
containment systems to prevent spills; and
h. bulk storage (equal to or greater than 55 gallons) of hazardous

materials, including chemicals, fuels, and lubricating oils have
appropriate secondary containment systems to prevent spills.
2. Annova LNG and its contractors will structure construction operations in a

manner that provides for the prompt and effective cleanup of spills of fuel
and other hazardous materials. At a minimum, Annova LNG and its
contractors will:
a. provide a sufficient number of spill kits and supplies of absorbent and

barrier materials to allow the rapid containment and recovery of
spilled materials. Regular on-site construction personnel will be
trained on the procedure for reporting spills and unanticipated
discoveries of contamination;
b. provide tools and material sufficient to stop leaks;
c. have available the reporting protocol that includes the contact names
and telephone numbers for - local, state, and federal agencies
(including, if necessary, the U. S. Coast Guard (USCG) and the
National Response Center) and Annova LNG personnel that must be
notified of a spill; and
d. follow the procedures outlined in the Project’s Spill Prevention,

Control, and Countermeasure (SPCC) Plan in cleaning up the spill, in
excavating and disposing of soils or other materials contaminated by a

spill, and in collecting and disposing of waste generated during spill

cleanup. The SPCC Plan applies to the Project construction and does
not apply to facility operation.
B. AGENCY COORDINATION
Annova LNG will coordinate with the appropriate local, state, and federal agencies
as outlined in these Procedures and in the FERC’s Orders.
5.0 WATERWAY/WATERBODY CONSTRUCTION

A. NOTIFICATION PROCEDURES AND PERMITS
1. Apply to the U.S. Army Corps of Engineers (COE), or its delegated agency,
for the appropriate wetland and waterbody permits.
2. Since no potable surface water supply intakes are located within 3 miles
downstream of the Project, written notification to authorities responsible for
public water supply or industries withdrawing water from the Brownsville
Ship Channel for potable use is not necessary.
3. Apply for state-issued waterbody crossing permits and obtain individual or

generic section 401 water quality certification or waiver.
4. Notify appropriate federal and state authorities before beginning dredging

operations as specified in applicable permits.
B. INSTALLATION
1. Time Window for Construction
Dredging operations and installation of pilings within the Brownsville Ship

Channel will occur during the timeframe outlined in the permit issued by the
appropriate federal or state agency.
2. Extra Work Areas
a. Locate extra work areas (such as staging areas and additional spoil
storage areas) not associated with construction of the marine berth at
least 50 feet away from the Brownsville Ship Channel shoreline,
except where the adjacent upland consists of disturbed land.


b. Annova LNG will file with the Secretary for review and written
approval by the Director, site-specific justification for each extra work
area with a less than 50-foot setback from the Brownsville Ship
Channel shoreline, except where the adjacent upland consists of
disturbed land or marine berth construction. The justification shall
specify the conditions that will not permit a 50-foot setback and
measures to ensure the waterway or waterbody are adequately
protected.
c. Limit the size of extra work areas to the minimum needed to construct
the marine berth.
3. General Construction Procedures
a. Comply with the COE, USCG, EPA, Texas Railroad Commission,

Texas Commission on Environmental Quality, and other regulatory
agencies, as applicable, permit terms and conditions.
b. Waterbody buffers (e.g., extra work area setbacks, refueling

restrictions) must be clearly marked in the field with signs and/or
highly visible flagging until construction-related ground disturbing
activities are complete.
4. Spoil Pile Placement and Control
a. Excavated upland spoil material will be temporarily stored within the

Project site boundaries in construction spoil stockpiles at least 10 feet
from the water’s edge or in additional extra work areas as described in
Section 5.B.2.
b. Use sediment and turbidity barriers to prevent the flow of spoil or silt-
laden storm water into the channel.
c. Dredged spoil material will be placed on-site and into Port of

Brownsville (Port) placement areas, as authorized by applicable
regulatory agencies and the Port.


5. Equipment Bridges
a. Construct and maintain equipment bridges to allow unrestricted flow

and to prevent soil from entering the waterbody, as applicable.
Examples of such bridges include:
(1) equipment pads and culvert(s);

(2) equipment pads or railroad car bridges without culverts;
(3) clean rock fill and culvert(s); and
(4) flexi-float or portable bridges.
Additional options for equipment bridges may be utilized that achieve

the performance objectives noted above. Do not use soil to construct
or stabilize equipment bridges.
b. Design and maintain each equipment bridge to withstand and pass the
highest flow expected to occur while the bridge is in place. Align
culverts to prevent bank erosion or streambed scour. If necessary,
install energy dissipating devices downstream of the culverts.
c. Design and maintain equipment bridges to prevent soil from entering

the waterbody.
d. Remove temporary equipment bridges as soon as practicable

following completion of final grading and site stabilization.
e. Obtain any necessary approval from the COE, or the appropriate state
agency for permanent bridges.
6. Dry-Ditch Crossing Methods – Not Applicable
7. Crossings of Minor Waterbodies – Not Applicable
8. Crossings of Intermediate Waterbodies – Not Applicable


9. Construction in Major Waterways/Waterbodies
Before construction, Annova LNG will file with the Secretary for the review
and written approval by the Director a detailed, site-specific construction plan
and scaled drawings identifying areas to be disturbed by construction for the
LNG terminal, marine berth, and LNG carrier turning basin. The plan will
include extra work areas, spoil storage areas, sediment control structures, etc.,
as well as mitigation for navigational issues.
The Environmental Inspector may adjust the final placement of the erosion
and sediment control structures in the field to maximize effectiveness.
10. Temporary Erosion and Sediment Control
Install sediment barriers (as defined in Section 4.F.3.a of the Plan)

immediately after initial disturbance of the waterway or waterbody or
adjacent upland. Sediment barriers must be properly maintained throughout
construction and reinstalled as necessary (such as during excavation and
initial grading) until replaced by permanent erosion controls or stabilization
of disturbed upland areas is complete. Temporary erosion and sediment
control measures are addressed in more detail in the Plan; however, the
following specific measures are to be implemented:
a. install sediment barriers, where necessary to prevent the flow of

sediments into the waterway or waterbody. Removable sediment
barriers (or driveable berms) shall be installed across access roads,
where applicable. These removable sediment barriers can be removed
during the construction day, but must be re-installed after construction
has stopped for the day and/or when heavy precipitation is imminent;
b. where waterways or waterbodies are adjacent to the construction and

the site slopes toward the waterbody, install sediment barriers along
the edge of the construction work areas as necessary to contain spoil
within the construction right-of-way and prevent sediment flow into
the waterbody; and
c. use silt/turbidity curtains, as necessary, to minimize transport of

displaced silt, sediment or solids while construction activities are
occurring in or directly adjacent to a waterway or waterbody.


11. Construction Dewatering
Dewater the excavation or trench in a manner that does not cause erosion and
does not result in silt-laden water flowing into any waterbody. Remove the
dewatering structures as soon as practicable after the completion of
dewatering activities.
C. REVEGETATION and STABLIZATION
1. Install erosion control blankets or a functional equivalent on waterway or

waterbody banks at the time of final bank recontouring. Do not use synthetic
monofilament mesh/netted erosion control materials in areas designated as
sensitive wildlife habitat unless the product is specifically designed to
minimize harm to wildlife. Anchor erosion control blankets or matting with
staples or other appropriate devices.
2. Application of riprap for bank stabilization must comply with COE, or its
delegated agency, permit terms and conditions.
3. Unless otherwise specified by state permit, limit the use of riprap to areas
where flow conditions preclude effective vegetative stabilization techniques
such as seeding and erosion control fabric.
4. Revegetate disturbed riparian areas with native species of conservation

grasses, legumes, and woody species, similar in density to adjacent
undisturbed lands, as applicable.
5. Install permanent slope breakers, as needed, across the base of slopes greater
than 5 percent that are less than 50 feet from the waterway or waterbody to
prevent sediment transport. In addition, install sediment barriers and
silt/turbidity curtains as outlined in Section 5.B.10.
In some areas, with the approval of the Environmental Inspector, an earthen

berm may be suitable as a sediment barrier adjacent to the waterway or
waterbody.


D. POST-CONSTRUCTION MAINTENANCE
1. Do not use herbicides or pesticides in or within 100 feet of a waterway or

waterbody except as allowed by the appropriate land management or state
agency.
6.0 WETLAND CROSSINGS

A. GENERAL
1. Annova LNG will conduct a wetland delineation using the current federal
methodology and file a wetland delineation report with the Secretary before
construction.
This report will identify:
a. by Project area all wetlands that would be affected;
b. the National Wetlands Inventory (NWI) classification for each

wetland;
c. the crossing length of each wetland in feet; and
d. the area of permanent and temporary disturbance that would occur in

each wetland by NWI classification type.
2. Design the facility to avoid wetland areas to the maximum extent possible. If
a wetland cannot be avoided the facility will be designed in a manner that
minimizes disturbance to wetlands.
3. Limit disturbance to wetland areas in accordance with COE permits and

approved drawings. Early in the planning process Annova LNG will identify
site-specific areas where spoil piles could be difficult to maintain because
existing soils lack adequate unconfined compressive strength.
4. Wetland boundaries and buffers must be clearly marked in the field with
signs and/or highly visible flagging until construction-related ground
disturbing activities are complete.


5. Implement the measures of Sections 5.0 and 6.0 for construction within or
adjacent to a waterway or wetland. If all measures of Sections 5.0 and 6.0
cannot be met, Annova LNG will file with the Secretary a site-specific
construction plan for review and written approval by the Director before
construction. This crossing plan will address at a minimum:
a. spoil control;
b. restoration of waterway or waterbody banks and wetland hydrology;
c. timing of the waterway or waterbody construction;
d. method of construction; and
e. size and location of all extra work areas.
6. Do not locate aboveground facilities in any wetland, except where the

location of such facilities has been approved by the appropriate regulatory
agencies.
B. INSTALLATION
1. Extra Work Areas and Access Roads
a. Locate all extra work areas (such as staging areas and additional spoil
storage areas) at least 50 feet away from wetland boundaries, except
where the adjacent upland consists of disturbed land.
b. Annova LNG will file with the Secretary for review and written
approval by the Director, site-specific justification for each extra work
area with a less than 50-foot setback from wetland boundaries, except
where adjacent upland consists of disturbed land. The justification
must specify the site-specific conditions that will not permit a 50-foot
setback and measures to ensure the wetland is adequately protected.
c. Construction access across a wetland area is permitted when the

wetland soil is firm enough to avoid rutting or has been appropriately
stabilized to avoid rutting (e.g., with timber riprap, prefabricated
equipment mats, or terra mats).


In wetlands that cannot be appropriately stabilized, construction

equipment other than that needed to install the wetland crossing will
use access roads located in upland areas. Where access roads in
upland areas do not provide reasonable access, limit all other
construction equipment to one pass through the wetland.
d. The only access roads, other than the construction travel paths within
the Project site boundaries, that can be used in wetlands are those
existing roads that can be used with no modifications or
improvements, other than routine repair, and no impact on the
wetland.
2. Construction Procedures
a. Comply with COE, or its delegated agency, permit terms and

conditions.
b. Assemble the facility components an upland area unless the wetland is

dry enough to adequately support the construction activity.
c. Limit construction equipment operating in wetland areas to that

needed to perform the construction activity.
d. Cut vegetation just above ground level, leaving existing root systems
in place, and remove it from the wetland for disposal, where practical.
Annova LNG may burn woody debris in wetlands, if approved by the

COE and in accordance with state and local regulations, ensuring that
all remaining woody debris is removed for disposal.
e. Segregate the top 1 foot of topsoil, as appropriate, from the area

disturbed.
f. Do not use rock, soil imported from outside the wetland, tree stumps,
or brush riprap to support equipment in a wetland area.
g. If standing water or saturated soils are present, or if construction

equipment causes ruts or mixing of the topsoil and subsoil in
wetlands, use low-ground-weight construction equipment, or operate
normal equipment on timber riprap, prefabricated equipment mats, or
terra mats.


h. Remove project-related material used to support equipment, as

appropriate, upon completion of construction.
3. Temporary Sediment Control
Install sediment barriers (as defined in Section 4.F.3.a of the Plan)

immediately after initial disturbance of the wetland or adjacent upland.
Sediment barriers must be properly maintained throughout construction and
reinstalled as necessary (such as after backfilling temporary storm water
diversion ditches). Except as noted below in Section 6.B.3.c, maintain
sediment barriers until replaced by permanent erosion controls or restoration
of adjacent upland areas is complete. Temporary erosion and sediment
control measures are addressed in more detail in the Plan.
a. Install sediment barriers across the entire construction right-of-way

immediately upslope of the wetland boundary at all wetland crossings
where necessary to prevent sediment flow into the wetland.
b. Where wetlands are adjacent to the construction area, and the grade
slopes toward the wetland, install sediment barriers along the edge of
the construction right-of-way as necessary to contain spoil within the
construction area and prevent sediment flow into the wetland.
c. Install sediment barriers along the edge of construction areas as

necessary to contain spoil and sediment within the construction
workspace. Remove these sediment barriers during site cleanup
following completion of final grading.
4. Construction Dewatering
Dewater the excavation or trench in a manner that does not cause erosion and
does not result in silt-laden water flowing into any wetland. Remove the
dewatering structures as soon as practicable after the completion of
dewatering activities.
C. STABILIZATION AND CLEAN UP
1. Restore pre-construction wetland contours to maintain the original wetland

hydrology, where applicable.
2. For each wetland within or adjacent to the construction limits of disturbance,

and where the grade slopes toward the wetland, install permanent slope
breakers across the construction area at the base of slopes greater than 5

percent where the base of the slope is less than 50 feet from the wetland, or as
needed to prevent sediment transport into the wetland. In addition, install
sediment barriers as outlined in the Plan. In some areas, with the approval of
the Environmental Inspector, an earthen berm may be suitable as a sediment
barrier adjacent to the wetland.
3. Do not use fertilizer, lime, or mulch in a wetland area unless required in

writing by the appropriate federal or state agency.
4. Consult with the appropriate federal or state agencies to develop a project-

specific wetland restoration plan, as applicable. The revegetation and
stabilization plan will include measures for re-establishing herbaceous and/or
woody species, controlling the invasion and spread of invasive species and
noxious weeds (e.g., purple loosestrife and phragmites), and monitoring the
success of the revegetation and weed control efforts. The revegetation and
stabilization plan will be made available to the FERC staff upon request.
5. Until a project-specific wetland restoration plan is developed and/or

implemented, temporarily revegetate affected wetlands with annual ryegrass
at a rate of 40 pounds/acre (unless standing water is present).
6. Ensure that disturbed wetland areas temporarily disturbed by construction,

and remain as wetlands following construction are stabilized and successfully
revegetated with wetland herbaceous and/or woody plant species in
accordance with COE authorizations, and as recommended by the appropriate
regulatory agency or local soil conservation authority, where applicable, to
prevent conversion of wetlands to uplands.
7. Remove temporary sediment barriers located at the boundary between

wetland and adjacent upland areas after stabilization (and revegetation where
applicable) of adjacent upland areas are judged to be successful as specified
in Section 7.A.4 of the Plan.
D. POST-CONSTRUCTION MAINTENANCE AND REPORTING
1. Do not conduct routine vegetation mowing or clearing over wetlands outside

the LNG plant primary security boundary/fence line. However, to facilitate
perimeter patrols and security observations, a corridor external and adjacent
to the primary security fence line up to 20 feet wide may be cleared at a
frequency necessary to maintain the 20-foot corridor in an herbaceous state.
In addition, broadleaf trees within 15 feet of the corridor that could
compromise the facility security may be selectively trimmed or cut and
removed.

2. Do not use herbicides or pesticides in or within 100 feet of a wetland, except

as allowed by the appropriate federal or state agency.
3. Monitor and record the success of wetland revegetation annually until

wetland revegetation is successful, where applicable.
4. Wetland revegetation will be considered successful if all of the following

criteria are satisfied:
a. the affected wetland satisfies the current federal definition for a

wetland (i.e., soils, hydrology, and vegetation);
b. vegetation is at least 80 percent of either the cover documented for the

wetland prior to construction, or at least 80 percent of the cover in
adjacent wetland areas that were not disturbed by construction;
c. if natural rather than active revegetation was used, the plant species
composition is consistent with early successional wetland plant
communities in the affected ecoregion; and
d. invasive species and noxious weeds are absent, unless they are
abundant in adjacent areas that were not disturbed by construction.
5. Within 3 years after construction, Annova LNG will file a report with the
Secretary identifying the status of the wetland revegetation efforts and
documenting success as defined in Section 7.D.5, above.
For wetland areas where revegetation has been implemented, and is not
successful at the end of 3 years after construction, develop and implement (in
consultation with a professional wetland ecologist) a remedial revegetation
plan to actively revegetate wetlands. Continue revegetation efforts and file a
report annually documenting progress in these wetlands until wetland
revegetation is considered successful by a professional wetland ecologist.
7.0 HYDROSTATIC TESTING

A. NOTIFICATION PROCEDURES AND PERMITS
1. Apply for state-issued water withdrawal permits, as required.
2. Apply for National Pollutant Discharge Elimination System (NPDES) or


state-issued discharge permits, as required.

3. Notify appropriate state agencies of intent to use specific sources at least 48
hours before testing activities unless they waive this requirement in writing.
B. GENERAL
1. Perform testing and inspections of welded and non-welded pipeline systems

in accordance with appropriate engineering codes and standards, before
installation under waterbodies or wetlands.
2. If diesel engine driven pumps used for hydrostatic testing are within 100 feet
of a waterway, waterbody or wetland, address secondary containment and
refueling of these pumps in the project’s Spill Prevention and Response
Procedures.
3. Annova LNG will file with the Secretary before construction a list identifying
the location of waterways or waterbodies proposed for use as a hydrostatic
test water source or discharge location.
C. INTAKE SOURCE AND RATE
1. Screen the intake hose to minimize the potential for entrainment of fish.
2. Do not use state-designated exceptional value waters, waterbodies which

provide habitat for federally listed threatened or endangered species, or
waterbodies designated as public water supplies, unless appropriate federal,
state, and/or local permitting agencies grant written permission.
3. Maintain adequate flow rates to protect aquatic life, provide for all waterbody
uses, and provide for downstream withdrawals of water by existing users.
4. Locate hydrostatic test manifolds outside wetlands and riparian areas to the
maximum extent practicable.
D. DISCHARGE LOCATION, METHOD, AND RATE
1. Regulate discharge rate, use energy dissipation device(s), and install sediment
barriers, as necessary, to prevent erosion, streambed scour, suspension of
sediments, or excessive streamflow.
2. Do not discharge into state-designated exceptional value waters, waterbodies

which provide habitat for federally listed threatened or endangered species, or


waterbodies designated as public water supplies, unless appropriate federal,

state, and local permitting agencies grant written permission.

APPENDIX C
DREDGED MATERIAL TRANSPORT PLAN
Annova LNG
Brownsville Project
Dredged Material Transport Plan
July 2016
Submitted by:
4 Houston Center
1221 Lamar Street, Suite 750
Houston, TX 77010
Annova LNG Brownsville Project Dredged Material Transport Plan
TABLE OF CONTENTS
Section Page
Tables .............................................................................................................................................. ii
Figures............................................................................................................................................ iii
Acronyms and Abbreviations ..........................................................................................................v
1 INTRODUCTION ......................................................................... 1-1

1.1 Applicable Regulations and Requirements .......................................................... 1-1
1.2 Plan Implementation Responsibility .................................................................... 1-1
2 PROJECT DESCRIPTION................................................................ 2-1
2.1 Marine Transfer Facilities .................................................................................... 2-1
2.2 Excavation and Dredging..................................................................................... 2-1
2.3 Existing Conditions.............................................................................................. 2-7
2.4 Beneficial Use Options ........................................................................................ 2-7
2.5 Dredged Material Placement Areas ..................................................................... 2-8
2.5.1 DMPA 4A ................................................................................................ 2-8
2.5.2 DMPA 4B ................................................................................................ 2-9
2.5.3 DMPA 5A ................................................................................................ 2-9
2.5.4 DMPA 5B ................................................................................................ 2-9
2.5.5 Proposed Placement Area ........................................................................ 2-9
3 DREDGED MATERIAL TRANSPORT ................................................... 3-1
4 MAINTENANCE DREDGING............................................................. 4-1
4.1 Maintenance Dredging Volumes ......................................................................... 4-1
4.2 Maintenance Dredging Placement ....................................................................... 4-1
5 REFERENCES ............................................................................ 5-1
i
TABLES
Table Page
Table 1 Estimates of Excavated and Dredged Material ............................................................... 2-6

Table 2 Types and Examples of Beneficial Use Options ............................................................ 2-8
Table 3 Dredged Material Placement Area Characteristics ....................................................... 2-11
ii
FIGURES
Figure Page
1 Project Location and Vicinity (Aerial) ............................................................................ 2-2

2 Dredging Footprint Plan View ......................................................................................... 2-3
3 Dredging Area Cross-Section .......................................................................................... 2-4
4 Brownsville Navigation District Dredged Material Placement Areas ........................... 2-10
5 Proposed DMPA-5A Dike Cross-Section, Typical ....................................................... 2-13
6 Hydraulic Dredge Pipeline Route .................................................................................... 3-2
7 Typical Floating Dredge Pipe Section ............................................................................. 3-3
iii
APPENDICES
Appendix Page
Appendix A Beneficial Use Concepts for Dredged Material .................................................... A-1
iv
ACRONYMS AND ABBREVIATIONS
Annova Annova LNG Common Infrastructure, LLC, Annova LNG

Brownsville A, LLC, Annova LNG Brownsville B, LLC, and
BIH Brazos Island Harbor
CWA Clean Water Act
DMPA dredged material placement area
DMTP Dredged Material Transport Plan
m3 cubic meters
MLLW mean lower low water (0 MLLW = +0.85 NAVD88)
MOF material off-loading facility
mtpa million tonnes per annum
NAVD88 North American Vertical Datum of 1988 (0 NAVD88 = -0.85
MLLW)
USACE United States Army Corps of Engineers
yd3 cubic yards
v
1 INTRODUCTION
Annova LNG Common Infrastructure, LLC; Annova LNG Brownsville A, LLC; Annova LNG
Brownsville B, LLC; and Annova LNG Brownsville C, LLC (collectively, “Annova”) is
proposing to construct, own, and operate the Annova LNG Brownsville Project (Project) in
Cameron County, Texas. The purpose of the Project is to operate a mid-scale natural gas
liquefaction facility along the South Texas Gulf Coast for exporting natural gas to international
markets. The mid-scale size of the facility meets the requirements of multiple foreign purchasers
whose annual demand is best met with increments of 1 million tonnes per annum (mtpa). The
Project will include six liquefaction trains, each with a nameplate capacity of 1.0 mtpa, for an
aggregate nameplate capacity of 6 mtpa and a maximum output at optimal operating conditions
of 6.95 mtpa.
This Dredged Material Transport Plan (DMTP) describes the methods developed to transport and
place excavated and dredged material resulting from construction and operation of the Project in
accordance with applicable federal and state regulations.
1.1 APPLICABLE REGULATIONS AND REQUIREMENTS

A Section 10/Section 404 permit from the U.S. Army Corps of Engineers (USACE) is required
to conduct dredge/fill activities within “waters of the United States.” Several conditions must
be addressed as part of the USACE Section 10/404 permit compliance process. The permit offers
blanket coverage for the requirements of Section 10 of the Rivers and Harbors Act; Section 404
of the Clean Water Act (CWA); and Section 103 of the Marine Protection, Research, and
Sanctuaries Act. The permit also requires adherence to the Texas Coastal Zone Management
Act and Section 401 of the CWA. A Coastal Zone Management Act consistency determination
and Section 401 Water Quality Certification review will be conducted by the Railroad
Commission of Texas as part of the Section 10/404 permit review process.
1.2 PLAN IMPLEMENTATION RESPONSIBILITY

Annova is the operator/owner for this Project and has overall responsibility for implementing
this plan through the engineering, procurement, and construction implementation through various
contracts/subcontracts, subject to the USACE permit requirements and Federal Energy
Regulatory Commission and USACE acceptance.
As of the date of this Plan, not all contractors/subcontractors have been identified; however,
when contractors/subcontractors are selected, training sessions for construction personnel will be
held before and during all construction activities. While this training will focus on DMTP
implementation, it will also include instructions on the implementation of other construction
mitigation measures, as appropriate.
1-1
2 PROJECT DESCRIPTION
Annova will construct the Project on approximately 731 acres of land on the south bank of the
Brownsville Ship Channel (BSC) at approximately mile marker 8.2 (Figure 1). The Project site
is available to Annova through a real estate lease option agreement with the Brownsville
Navigation District (BND).
The Project includes two principal parts: the liquefied natural gas (LNG) facilities and the
associated marine transfer facilities. The LNG facilities will be designed to receive 0.9 billion
cubic feet per day of third-party feed gas via pipeline. The natural gas delivered to the site via the
feed gas pipeline will be treated to remove constituents that would freeze during the liquefaction or
affect the liquefaction process, primarily hydrocarbons other than methane, carbon dioxide, and
water. Annova will liquefy the treated natural gas using the Black & Veatch Poly Refrigerant
Integrated Cycle Operation (PRICO®) technology. The LNG will be stored in two single-
containment LNG storage tanks, each designed to store approximately 160,000 cubic meters (m3)
to match the capacity of typical LNG carriers. The LNG will be pumped from the storage tanks to
the marine transfer facilities. The marine transfer facilities will load LNG carriers at the berth
using cryogenic piping and associated equipment for mooring the carrier. The Project includes
the following major components: gas pretreatment facilities; liquefaction facilities; LNG storage
tanks; a boil-off gas handling system; a flare system; marine transfer facilities; control,
administration, and support buildings; access roads; and utilities (power, water, and
communication.).
2.1 MARINE TRANSFER FACILITIES

The marine transfer facilities were designed to accommodate 138,000-m3 to 177,000-m3 LNG
carriers. The berth will include a 1,500-foot-diameter turning basin, with adjacent approach area
to accommodate passage between the channel and turning basin. The LNG carriers will dock at
the LNG loading berth on the south side of the marine berth, and the material off-loading facility
(MOF) will be located on the west side of the basin. The MOF will accommodate the delivery
by barge of major equipment and modular plant components during construction. The MOF will
be maintained for use during the operational life of the facility as needed.
2.2 EXCAVATION AND DREDGING

The excavation and dredging area for the marine berth and turning basin on the north and south
sides of the BSC are shown on Figure 2, and cross-section profiles are shown on Figure 3. The
south marine berth and turning basin will be created through a combination of mechanical
dredging/excavation and hydraulic cutter suction dredge, and the north turning basin will be
created by hydraulic cutter suction dredge. The BSC has an authorized depth of -42 feet mean
lower low water (MLLW). The basins will be dredged to -45 feet MLLW and will have a 3:1
2-1
Path: M:\Houston\Annova_LNG\Maps\Mxd\USACE_Permit\Figure 1 - Project Vicinity Map.mxd
Overview
Gulf
of
Mexico
TX Gulf
of Mexico
Laguna South Padre
Madre Island
MEXICO
100
¬
« Laguna Heights
Brazos Santiago Pass

Laguna Port
Larga Isabel
Bahía Brazos
Grande Island
South
Bay
Dredged Material
Placement ¬
« 48
Area 5A
Brownsville
Ship Channel
Dredged Material
Placement ¬4
«
Area 5B
Port of
Brownsville CAMERON COUNTY,
TEXAS
TAMAULIPAS, MEXICO
Legend
Figure 1
Access Road Alternative 1
Project Location and Vicinity (Aerial)
Access Road Alternative 2 (Preferred Option) Annova LNG Brownsville Project
SCALE
Project Site Cameron County, Texas
0 1 2 3 Miles
Dredged Material Placement Area
State Highway
USACE Application # SWG-2015-00110
SOURCE: Annova LNG 2015; ESRI 2015; TX DOT
2014; NAIP 2014
20190419-3027 9/11/2017 12:29:20 PM
PLANT
NORTH TRUE
NORTH
PLAN VIEW
FIGURE 2 REV 1
DREDGING FOOTPRINT,
FIGURE 3
CROSS-SECTION
DREDGING AREA,
slope from the top to the toe of each basin, including along the MOF in locations where sheet
piling is not used. The -45 feet MLLW includes the additional 3 feet for advance maintenance
and over-depth volumes. No dredging will occur within the BSC navigation channel.
The marine berth and turning basin encompass 76 acres at the top of slope at approximately 0
feet MLLW. The south basin toe of the slope is 4,133 feet along the BSC; 1,093 along the MOF;
1,387 feet along the LNG loading berth; 766 feet along the east basin side; and 2,052 feet along
the east approach. The distance from the edge of the BSC to the LNG berth is approximately
1,050 feet. Of the 76 acres of the south basin at 0 feet MLLW, approximately 39 acres currently
are land and 37 acres currently are submerged.
The north turning basin is located directly opposite on the far side of the BSC to allow adequate
LNG carrier maneuvering and turning space. The north basin toe is a four-sided convex polygon
that extends approximately 200 feet from the BSC along the northern toe of slope. The north
basin encompasses 20 acres at the top of slope at approximately 0 feet MLLW. The north basin
toe of the slope is 3,600 feet along the BSC; 278 feet along the west side; 1,800 feet along the
north side; and 1,721 feet along the east approach.
• Excavation and dredging quantities were computed using the site plan shown on Figure 2
and topographic data provided by Black & Veatch. Hydrographic data collected in
March 2015 from the latest USACE channel survey project were used for the underwater
portion of the Project. Civil3D software was used to create the surfaces needed to calculate
the dredging volumes. Land-based material above water down to elevation +2 feet North
American Vertical Datum 88 (NAVD88), or +2.85 feet MLLW, as compared with tidal
datum 8779770 for Port Isabel, Texas, will be excavated using conventional earth-
moving equipment. The excavated material will be used as on-site fill.
• Mechanical dredging/excavation (in former land area) to -20.85 feet NAVD88 (or -20
feet MLLW) will use conventional earth-moving equipment and dewatering will use
local sumps and pumping. Material will be placed on the Project site.
• Hydraulic dredging below -20 feet MLLW (in former land area) and hydraulic dredging
of the remaining area currently under water to -45.85 feet NAVD88 (or -45 feet MLLW)
will use hydraulic cutter suction dredge equipment and will place the dredged material in
BND-owned Dredged Material Placement Areas (DMPAs). DPMA 5A located west of
the Project site is the preferred area.
Figure 3 shows a cross-section through the marine basin from the south at the LNG facility and
to the north across the shipping channel. The highest elevation on land is +24 feet NAVD88,
situated in the middle of the southern edge of the basin. At the marine slip, the elevation at the
top of the slope at the LNG trestle will be +20 feet NAVD88; however, the western and eastern
faces of the slip will be variable because of the existing terrain elevation.
2-5
Table 1 provides areas and computed quantities for the marine basin above elevation +2 feet
NAVD88 and to -45 feet MLLW. The quantities noted are the volume of topsoil and the volume
of material from the land area for the marine berth and turning basin.
The areas shown in Figure 2 will be mechanically dredged from an elevation of +2 feet NAVD88
down to -20 feet MLLW. Table 1 provides areas and computed quantities for the mechanical
dredging/excavation with dewatering. The remaining area currently under water from -20 feet
MLLW to the design depth of -45 feet MLLW will be dredged using hydraulic cutter suction
dredge equipment. Dredged material will be placed into a BND-owned DMPA (described in
Section 3 below). Table 1 provides areas and computed quantities for the hydraulic dredging and
includes 3 feet of allowable over-depth dredging.
Table 1
Estimates of Excavated and Dredged Material
Estimated
Approximate Volume Estimated Volume Proposed
Project Excavation/Dredging Area Duration (cubic by Soil Texture(a) Placement
Facility Method (acres) (days) yards) (cubic yards) Location
Marine Excavation of 39 39 60,000 Clay – 60,000 Project site
Berth and Topsoil
Turning
Basin
(South)
Excavation to +2 39 530,000 Clay – 530,000
feet NAVD88
Excavation from +2 76 113 1,125,000 Clay – 1,125,000
feet NAVD88 to
-20.85 NAVD88
Dredging to -45 76 88 3,520,000 Sand – 3,520,000 Dredged
feet MLLW(b) Material
Placement
Area 5A
Turning Dredging to -45 20 19 726,000 Clay – 573,080 Dredged
Basin feet MLLW(b) Sand – 153,920 Material
(North) Placement
Area 5A
Total excavation for placement on the Project 1,715,000 Clay – 1,715,000
site
Total material for Dredged Material Placement 4,246,000 Clay – 573,000
Area 5A Sand – 3,673,000
Total material excavated and dredged 5,961,000 Clay – 2,288,000
Sand – 3,673,000
Notes:
(a) Volume includes advance maintenance and over-depth volumes.
(b) Based on soil borings conducted at the Project site that show clay layers to -35 feet NAVD88 and sand from
-35 to -65 feet NAVD88.
Key:
MLLW = mean lower low water
2-6
2.3 EXISTING CONDITIONS

The USACE conducted sediment sampling for contaminants as part of the Brazos Island Harbor
(BIH), Texas, Channel Improvement Project. Analytical results for those samples indicated
there are no chemical or physical concerns regarding placement of BSC sediments in upland
placement areas (USACE 2014). Nevertheless, although the data indicate there are no
contaminants of concern in the BSC, soil, sediment, and water samples will be collected within
the dredging footprint for analysis of the composition and chemistry of the bottom and sub-
bottom of the dredge area before the Project is constructed. Samples will be collected and
analyzed for chemical constituents as described in Annova’s Dredge Area Sampling and
Analysis Plan (Attachment D of this Permit Application) in order to characterize the dredged
material that is proposed for placement in a BND-owned DMPA. See Annova’s Dredged Area
Sampling and Analysis Plan for a detailed description of the field sampling methods, analytical
program, and quality control procedures that will be implemented for characterizing the material
to be dredged.
2.4 BENEFICIAL USE OPTIONS

Annova is coordinating with the USACE, the U.S. Environmental Protection Agency, and state
and local entities to evaluate the potential for beneficial use of dredged material. Annova will be
generating dredged and excavated material from two sources over the life of the Project. The
initial development of the turning basin and marine berth (i.e., new work) will generate
approximately 5,961,000 cubic yards (yd3) of excavated and dredged material, with
approximately 1,715,000 yd3 of excavated material to be placed on the site, as shown in Table 1.
Maintenance dredging will be required every other year for an estimated 30 years, generating
approximately 200,000 yd3 per event. New work material composition is expected to be largely
clay with sand layers, while the maintenance material is expected to contain a higher percentage
of sand.
Annova will conduct additional characterization of the dredged material and consult with
regulatory agencies to define the potential for beneficial use of the dredged material. Ongoing
Project design and development and additional geotechnical investigations and testing will allow
refinement of existing proposed beneficial use options (on-site fill, marsh restoration, shoreline
stabilization, and habitat restoration and creation) and, potentially, other uses to be identified for
subsequent implementation.
Beneficial use of dredged material includes placing or using dredged sediments as resource
material in productive ways that provide environmental, economic, or social benefits, according
to the USACE (USACE 2015). Appendix A provides a summary of beneficial use concepts for
dredged material under consideration. Table 2 lists common types and examples of dredged
material uses. Examples of beneficial uses of dredged material include habitat development
2-7
(e.g., wetland enhancement, restoration or creation, fishery enhancement); development of parks

and recreational facilities (e.g., walking and bicycle trails, wildlife viewing areas); agricultural,
forestry, and horticultural uses; strip-mine reclamation/solid waste management (e.g., fill for
strip mines, landfill capping); shoreline construction (e.g., levee and dike construction);
construction/industrial development (e.g., bank stabilization, site filling and leveling,
brownfields reclamation); and beach nourishment (e.g., restoration of eroding beaches).
Table 2
Types and Examples of Beneficial Use Options
Engineered Uses Agricultural and Product Environmental Enhancement

• Berm Creation • Aquaculture • Agriculture, Forestry,
• Shore Protection • Construction Materials Horticulture, and
• Capping Landfills and • Decorative Landscaping Aquaculture
Industrial Sites Products • Fish & Wildlife Habitats
• Replacement fill • Topsoil • Fisheries Improvement
• Beach Nourishment • Wetland Restoration
• Land Creation • Habitat development
• Land Improvement
Annova plans to use on-site placement of mechanically excavated material as fill for the Project
as the preferred beneficial use option, excluding topsoil. Approximately one-fourth of the
material removed to develop the marine facilities is proposed to be used on-site, based on current
engineering information. The mechanically excavated material consists primarily of clay and is
intended to be used for general site landscaping and grading. Assuming moderate compaction of
the mechanically excavated material, approximately 1.3 million cubic yards of fill will be used to
raise the elevation in these receiving areas up to +8 feet NAVD88.
2.5 DREDGED MATERIAL PLACEMENT AREAS

Due to the relatively small areas available within the Project site and the area required for dredge
slurry dewatering, on-site placement of hydraulically dredged material would not be practicable.
Therefore, Annova proposes to place these materials into BND-owned DMPAs or use them for
off-site beneficial uses if feasible and practicable alternatives can be identified. There are a
number of DMPAs adjacent to the BSC that have been evaluated as potential placement areas.
The BND-owned placement areas are identified on Figure 4. Based on their proximity to the
Project area, DMPAs 4A, 4B, 5A, and 5B were evaluated.
2.5.1 DMPA 4A
DMPA 4A is approximately 469 acres in size and is located east of the Project site and south of
the Port Isabel Channel. DMPA 4A was last used for dredged material placement in 2009. The
drop-outlet structure is currently known to be silted and in need of refurbishment. DMPA 4A is
2-8
located in piping plover critical habitat unit TX-01, which places significant restrictions on the
use of this DPMA and increased liability associated with degradation of the habitat.
2.5.2 DMPA 4B
DMPA 4B is approximately 243 acres in size and is located directly east of the Project site. The
site is surrounded by a containment dike with an average height of 7 feet above the existing
grade and a length of about 16,340 linear feet. The site has not been used for maintenance
dredging for several years and the drop-outlet structure is currently not functioning. DMPA 4A
is located in piping plover critical habitat unit TX-01, which places significant restrictions on the
use of this DPMA and an increased liability associated with degradation of the habitat.
2.5.3 DMPA 5A
DMPA 5A is approximately 704 acres in size and is located directly west of the Project site.
DMPA 5A is surrounded by a containment dike with an average height of 6 feet above the
existing grade and a length of about 21,690 linear feet. The site is used for placement of
maintenance dredged material from the adjacent section of the BSC navigation channel. The
drop-outlet structure was recently refurbished and is functioning well.
2.5.4 DMPA 5B
DMPA 5B is approximately 1,020 acres in size and is located west of DMPA 5A. The site is
surrounded by a containment dike with an average height of 12 feet above the existing grade and
a length of about 29,343 linear feet (based upon post-construction surveys provided by the
BND). The site is used for placement of maintenance dredged material from the adjacent section
of the BSC navigation channel. The drop-outlet structure was recently refurbished and is
functioning well.
2.5.5 PROPOSED PLACEMENT AREA

Potential placement areas were evaluated based on three criteria: distance from the Project site,
available capacity, environmental considerations, and efficiency of placing the material. A dike
with a smaller length to area ratio provides a more efficient site than a site with a longer length to
area ratio. Sites are generally compartmentalized with internal dike “training structures” to
increase the flow path from the pipeline discharge point to the outfall structure. This provides
greater capacity for fine material to settle out of the discharge slurry before it is released back
into the BSC. Large, square-shaped areas also provide more opportunity to work the material
with dozers soon after placement without adversely affecting the settling process. Table 3
describes the respective characteristics of each DMPA.
2-9
LOWER LAGUNA MADRE
PORT ISABEL CHANNEL
TURNING BASIN
SHRIMP BASIN
BROWNSVILLE SHIP CHANNEL
8 4B 4A
7 2
5B 5A
SOUTH BAY
ANNOVA LNG SITE BOUNDARY
FIGURE 4
PLANT
NORTH TRUE BROWNSVILLE NAVIGATION
NORTH
DISTRICT DREDGED
MATERIAL PLACEMENT AREAS
Table 3
Dredged Material Placement Area Characteristics
Distance
to the
Site Dike Length DMPA Area USACE Dike Crest Levee Raising
DMPA (miles) (feet) (acres) Length:Area Ratio Requirements Requirement1
4A 3–4 33,910 469 72.3 +35 feet NAVD88 17 feet
4B Adjacent 16,338 243 67.2 +24 feet NAVD88 28 feet
5A Adjacent 21,628 704 30.7 +17 feet NAVD88 12.5 feet
5B 3 29,343 1020 28.8 +19 feet NAVD88 8.5 feet
Source: B&V File 183169-REFF-0027
1
The levee-raising requirements reflect the Project only and do not include capacity for material from the BIH
Channel Improvement Project.
Based on the assumption that material excavated to +2 feet MLLW will be kept at the Project
site, a total of 4,246,000 yd3 of dredged material will require off-site placement. Typical
capacity requirements for hydraulic dredging are 2.5 times the volume of dredged clay material
and 1.3 times the volume for a dredged slurry consisting primarily of sandy material. Assuming
a bulking factor of 1.9 to account for cohesive material, a volume of 10,200,000 yd3 is needed
within the placement areas.
Based on the dike length to area ratio of 30.7 for DMPA 5A, the dike will need to be raised 12.6
feet above the existing height to provide the capacity needed for the dredged material from the
for Annova Project and BIH Channel Improvement Project, including freeboard for the decant
slurry. Existing levee crest elevations range from +12 to +14 feet NAVD88 at DMPA 5A, which
will result in an overall elevation of +23 to +25 feet NAVD88 for placement of Annova new
work material and material from the BIH Channel Improvement Project (see Figure 5). The
USACE’s Engineering Appendix for the BIH Channel Improvement Project (2014) indicates that
the subgrade at DMPA 5A can sustainably accommodate a total levee crest elevation of +42 feet
NAVD88.
DMPA 5A is closer to the Project site than DMPA 5B, which is 3 miles away. Therefore,
Annova identified DMPA 5A as the preferred placement area for dredged material from the
Project site, with DMPA 5B serving as a suitable alternative.
Annova is consulting with the BND and the USACE regarding the use of DMPA 5A. The BND
owns and is responsible for maintenance of the DMPAs, while the USACE has an easement for
the total containment capacity. Based on consultations with the BND and the USACE,
maintenance obligations for the DMPAs will pass from the BND to the USACE following the
BIH Channel Improvement Project. Therefore, Annova is consulting with the USACE
Operations and Real Estate Divisions regarding the availability and use of DMPA 5A.
The BIH Channel Improvement Project may use DMPA 5A for dredged material from
maintenance dredging. Annova evaluated levee height for the cumulative use of DMPA 5A for
2-11
the BIH project, proposed LNG facilities on the BSC, and the Annova Project. Appendix 1H of
Resource Report 1 provides the cumulative analysis of dredged material placement.
2-12
FIGURE 5
PROPOSED DMPA-5A DIKE,
CROSS-SECTION, TYPICAL
3 DREDGED MATERIAL TRANSPORT

Upon mobilization of the dredge barge, a floating dredged material pipeline (27 inches in
diameter, depending on the barge) will be installed and anchored along the south shore of the
BSC such that no alteration to tidal flow will occur. The a p p r o x i m a t e l y 8 , 3 5 0 - foot-
long section of pipeline will be floated, marked with navigation lights and reflective signs,
and monitored to ensure the safety of area traffic. The pipe will be flushed prior to opening to
minimize turbidity released from the dredge pipe and visually monitored for leaks during
operation. Figure 6 shows the proposed placement of the floating dredged material pipeline at
DMPA 5A, and Figure 7 shows a floating dredged material pipe typical cross section. The
dredge pipe will include a wye valve, which will evenly distribute the dredged material into two
internal partitions within DMPA 5A. This distribution of the material will ensure that particle
settling upon discharge from the pipe will be able to keep pace with the production rate of the
dredge. The effluent outfall at the drop-outlet structure will be monitored for turbidity and
erosion issues. Turbidity at the outfall will be limited to 280 nephelometric turbidity units, per
40 Code of Federal Regulations § 450.22. The BSC is not impaired for turbidity and no total
maximum daily loads other than for bacteria have been established for this waterbody. It is
anticipated that the floating dredged material pipeline will be installed no more than one month
prior to the start of dredging activities and will be removed within one month following the
completion of dredging activities.
3-1
Path: M:\Houston\Annova_LNG\Maps\Mxd\USACE_Permit\Fig25_HydraulicDredgePipeRoute.mxd
y
Hw
b el
/ I sa
rt
Po
lle
sv i
wn
Bro
V
U 48
Wye
Valve
el
a nn
Ch
ip
Sh
le
vil
ns
ow 5A
Br
Internal Partitions
and Slurry Route
Legend
Figure 6
Internal Partitions and Slurry Route
Hydraulic Dredge
Hydraulic Dredge Pipeline Route
Pipeline Route
SCALE Channel Centerline Annova LNG Brownsville Project
0 1,000 2,000 Feet Channel Limit Cameron County, Texas
Dredging Footprint
SOURCE: Annova LNG 2015; ESRI 2014 Project Site

Dredged Material Placement Areas SWG 2015-00110
FIGURE 7
TYPICAL FLOATING
DREDGE PIPE SECTION
This page intentionally left blank.
3-4
4 MAINTENANCE DREDGING
4.1 MAINTENANCE DREDGING VOLUMES
With relatively low currents and few tributaries driving outflow or sediment recharge, shoaling
in the BSC is relatively low and localized. Consultation with the BND suggests that there are
several areas in the BSC where shoaling is observed. One such area is the “pilot channel” outfall
from the Bahia Grande wetland area, which outfalls directly across the channel from the marine
berth. Consultation with the Brazos Santiago Pilot’s Association; however, suggests that the
shoaling rates in this area have been decreasing over time. The pilot channel is the subject of a
proposed widening project, which would further reduce sedimentation.
The BSC’s current annual sedimentation rate is approximately 10 yd3 per linear foot (USACE
2014). However, because of the configuration of the marine slip, it will be subject to shoaling
rates in excess of that observed in the main channel. It is likely that the highest sedimentation
rates will be in the areas at the mouth of the slip, near the edge of the cut, and around the marine
berth. It is estimated that a total annual volume of 50,000 yd3 to 100,000 yd3 of maintenance
dredging will be required. As such, Annova is proposing a continual dredging operation to
remove up to 200,000 yd3 every other year. Over the Project’s design life of 30 years, this will
generate a total volume of up to 3 million yd3 of material requiring disposal.
4.2 MAINTENANCE DREDGING PLACEMENT

Placement of 3 million yd3 of material in DMPA 5A over the lifespan of the Project will require
an additional levee increase in elevation of 2.6 feet (see Figure 5). As the annual maintenance
volume is approximately 100,000 yd3, no freeboard allowance has been included in this capacity
requirement. The frequency of dredging will be either on a one-year or two-year cycle,
depending on actual accumulation rate.
4-1
5 REFERENCES
Black and Veatch. Dredged Material Management Plan for LNG Basin, Rev. C (183169-
REFF-0027).
U.S. Army Corps of Engineers (USACE). 2014. Brazos Island Harbor, Texas, Channel
Improvement Project. Final Integrated Feasibility Report–Environmental Assessment.
U.S. Army Corps of Engineers, Galveston District. July 2014.
_________. 2015. Engineering Research and Development Center (ERDC) Beneficial Uses of
Dredged Material. Available on line at http://el.erdc.usace.army.mil/dots/budm/
budm.cfm
5-1
Appendix A
Beneficial Use Concepts for Dredged Material
A-1

Annova LNG
Brownsville Project
Beneficial Use Concepts for Dredged Material
Prepared by:
TABLE OF CONTENTS
Section Page
1.0 INTRODUCTION ...................................................................................................1

2.0 LOCAL AND PROJECT SITE GEOLOGY ...........................................................1
3.0 BENEFICIAL USES OF DREDGED MATERIAL................................................2
3.1 On-Site Fill...................................................................................................3
3.2 Bird Islands ..................................................................................................3
3.3 Marsh Restoration, Beach Nourishment, and Shoreline Stabilzation ..........4
3.4 Upland Habitat Creation ..............................................................................4
4.0 SUMMARY .............................................................................................................5
5.0 REFERENCES ........................................................................................................5
i
TABLES
Table Page
2-1 Types and Examples of Beneficial Use Options................................................................. 3

3-1 Summary of Beneficial Use Options .................................................................................. 5
ii

NDT National Dredging Team
USACE U.S. Army Corps of Engineers
EPA U.S. Environmental Protection Agency
USFWS U.S. Fish and Wildlife Service
iii
1.0 INTRODUCTION
Annova is coordinating with the U.S. Army Corps of Engineers (USACE), the U.S.
Environmental Protection Agency (USEPA) and state and local entities to evaluate the potential
for beneficial use of dredged material. The USACE is responsible for maintaining the navigable
waterways in the U.S. traditionally and leads the development of beneficial use of dredged
material projects. The USACE, along with the USEPA and other federal and state resource
agencies focus on beneficial uses of dredged material because of recognized environmental
benefits and the increasing lack of disposal capacity in traditional disposal sites. The National
Dredging Team (NDT) recognizes dredged material as a valuable resource that can be used in
environmentally beneficial ways. The NDT's national guidance document, which explains the
role of the Federal Standard in implementing beneficial uses of dredged material from the
USACE’s new and maintenance navigation projects, describes a number of recommended uses
of dredged material for various productive purposes. Examples of beneficial uses of dredged
material include habitat development (e.g., wetland restoration or creation, rookery islands,
fishery enhancement); development of parks and recreational facilities (e.g., walking and bicycle
trails, wildlife viewing areas); agricultural, forestry, and horticultural uses; sanitary landfill
cover/capping; shoreline construction (e.g., levee and dike construction); construction/industrial
development (e.g., bank stabilization, brownfields reclamation); and beach nourishment (e.g.,
restoration of eroding beaches).
Annova will be generating dredged and excavated material from two sources over the life of the
Project. The initial development of the turning basin and marine berth, i.e., “ new work,” will
generate approximately 5,371,000 cubic yards. Maintenance dredging will be required every
other year for an estimated 30 years, generating approximately 200,000 cubic yards per event.
New work material composition is expected to be largely clay with sand, while the maintenance
material is expected to contain a higher percentage of sand.
Annova will conduct additional characterization of the dredged material combined with
discussions with land owners needing fill material and consultation with regulatory agencies to
define the potential for beneficial use of the dredged material. This summary represents
beneficial use options based on current field investigations and test information. Ongoing
Project design and development and additional geotechnical investigations and testing will allow
refinement of existing proposed beneficial use options (on-site fill, marsh restoration, shoreline
stabilization, and habitat restoration and creation) and, potentially, other uses to be identified for
subsequent implementation.
2.0 LOCAL AND PROJECT SITE GEOLOGY

The surficial geologic units surrounding the Project include Quaternary alluvium, tidal flat
deposits, muddy floodplain, clay dunes, and recent dredge spoils. Silty and sandy floodplain
alluvium is composed of mostly silt and sand. Tidal flat deposits consist of varying amounts of
sand, silt, clay (mud) and shells. Muddy floodplain alluvium is composed of mostly clay and silt
(mud) deposits. Clay dune deposits are composed of eolian (wind-deposited) calcareous clay
and silt deposited in lomas or low hills. These clay dunes form surrounding tidal flats and
shallow basins in areas with pronounced wet and dry seasons during the year (Bowler 1973).
1
The geotechnical investigation report indicates that the Project site subsurface stratigraphy
consists of four distinct layers (Black & Veatch 2016). The data show that Layer 1 consists of
clay material that extends from the existing ground surface to between elevations -20 to -50 feet
NAVD88. Layer 2 consists of sand material, ranging from 10 to 40 feet thick. The bottom
elevation ranges from -40 to -60 feet NAVD88, with the bottom of the stratum shallower on the
west side of the site. Layer 3 consists of a clay material with a depth up to 90 feet. This stratum
appears interlayered with sand layers, especially on the northern portion of the site. Layer 4
consists of a sand material below elevation -150 feet NAVD88 to a maximum investigated depth
of -200 feet NAVD88 (primarily identified based on the relatively high standard penetration tests
N60-values).
Outlined below are options considered for beneficial use of dredged material based on existing
knowledge of local and on-site geologic conditions and the proximity of Port Isabel, South Padre
Island, national wildlife refuges, and Bahia Grande to the Project site.
3.0 BENEFICIAL USES OF DREDGED MATERIAL

Beneficial use of dredged material includes using dredged sediments as resource material in
productive ways, which provide environmental, economic, or social benefit, according to the
USACE (USACE 2015). Dredged material can be used beneficially for engineered and
agricultural products and environmental enhancement purposes, as described on the beneficial
uses website (http://el.erdc.usace.army.mil/dots/budm/budm.cfm) and in the seven categories
described below (USACE 2006):
1. Habitat Restoration and Development: using dredged material to build and restore wildlife
habitat, especially wetlands or other water-based habitat (e.g., nesting islands and offshore
reefs).
2. Beach Nourishment: using dredged material (primarily sandy material) to restore beaches
subject to erosion.
3. Parks and Recreation: using dredged material as the foundation for parks and recreational
facilities (e.g., waterside parks) providing such amenities as swimming, picnicking, camping,
or boating.
4. Agriculture, Forestry, Horticulture, and Aquaculture: using dredged material to replace
eroded topsoil, elevate the soil surface, or improve the physical and chemical characteristics
of soils.
5. Strip-Mine Reclamation and Solid Waste Management: using dredged material to reclaim
strip mines, to cap solid waste landfills, or to protect landfills.
6. Construction/Industrial Development: using dredged material to support commercial or
industrial activities (including brownfields redevelopment), primarily near waterways (e.g.,
expanding or raising the height of the land base, providing bank stabilization). In addition,
dredged material may be used in construction material.
7. Multiple-Purpose Activities: using dredged material to meet a series of needs
simultaneously, such as habitat development, recreation, and beach nourishment, which
might all be supported with a single beneficial use project.
2
Table 2-1 lists common types and examples of dredged material use categorized by purpose:
engineered, agricultural and product, and environmental enhancement.
Table 2-1
Types and Examples of Beneficial Use Options
Engineered Uses Agricultural and Product Environmental Enhancement

• Agriculture, Forestry,
• Berm Creation • Aquaculture
Horticulture, and Aquaculture
• Shore Protection • Construction Materials • Fish & Wildlife Habitats
• Capping Landfills and • Decorative Landscaping
• Fisheries Improvement
Industrial Sites Products
• Replacement fill • Topsoil • Wetland Restoration
• Beach Nourishment • Habitat development
• Land Creation
• Land Improvement
Considerations for the selection of beneficial uses include the availability of the site, dredged
material physical and chemical compatibility, potential environmental impact, and practicability
(cost, technology, and logistics). Given that the dredged material is originating from a marine
rather than freshwater environment, certain options were eliminated from further analysis,
including aquaculture/agriculture/forestry/horticulture, decorative landscaping products, topsoil,
freshwater fisheries improvement, and solid waste management. Based on initial geotechnical
investigation data and publically available information associated with previous Brazos Island
Harbor dredging projects, the following beneficial use options were preliminarily identified for
further consideration: (1) on-site fill; (2) bird island building; (3) coastal marsh and tidal
wetland restoration, beach nourishment, and shoreline protection; and (4) upland habitat
enhancement and creation.
3.1 ON-SITE FILL

Annova plans to use on-site placement of mechanically excavated material as fill for the Project
as the preferred beneficial use option, excluding topsoil. Approximately one-fourth of the
material removed to develop the marine facilities is proposed to be used on-site, based on current
engineering information. The mechanically excavated material consists primarily of clay and is
intended to be used for general site landscaping and grading. Assuming moderate compaction of
the mechanically excavated material, approximately 1.3 million cubic yards of fill will be used to
raise the elevation in these receiving areas up to +8 feet NAVD88.
3.2 BIRD ISLANDS

Bird nesting islands have been successfully constructed using dredged material. In the late
1980s, a coalition of eight governmental agencies identified environmentally and economically
responsible ways to utilize new work and maintenance materials dredged from an expansion of
the Houston Galveston ship channel in Galveston Bay. With over 4,000 acres of marsh creation,
the agencies identified bird island construction as an appropriate beneficial use of new work
dredged material. Although restoring or creating bird nesting islands offers an opportunity for
beneficial use along the Gulf Intracoastal Waterway or in and near Bahia Grande, this option
requires further analysis of the physical and chemical characteristics of the sediments to be
dredged. In addition to suitability review, other areas to be evaluated include potential impacts
3
on road and marine traffic for transport of dredged material by truck and barge, respectively; and
schedule and cost.
3.3 MARSH RESTORATION, BEACH NOURISHMENT, AND SHORELINE

STABILZATION
Aerial imagery, studies of shoreline change, and local coastal erosion control plans indicate
eroded shorelines in the region that could benefit from placement of dredged material. Intense
hurricanes can cause significant damage to the shoreline and to constructed jetties. The sand in
the new work material from the Project may be suitable for both marsh restoration and beach
nourishment, subject to further characterization. Also, dredged material selectively placed,
shaped, and vegetated could restore eroded shorelines and provide an increased level of storm
surge reduction. Maintenance material was used in the Aransas National Wildlife Refuge to
restore marsh (ERDC 2015). There may be options to restore marsh and stabilize shoreline at
either Laguna Atascosa or Lower Rio Grande National Wildlife Refuges, along Laguna Madre
shoreline or Brownsville Ship Channel (BSC) shoreline, respectively.
The South Padre Island, ranked as one of the top beaches in the U.S., is used during the spring
(March-May), summer (June-August), and fall (September-November) for public access and
recreation as well as commercial fishing activities; therefore, the practicability and safety of
transporting and handling large volumes of material (particularly on the changing beach surface
in the tidal environment) while maintaining access for the public will require coordination with
local government and business entities. Other principle areas to be evaluated include suitability
of dredged material, viability of material transport through pipelines and pumps, and potential
impacts on road and marine traffic for possible transport of dredged material by truck or barge,
respectively.
3.4 UPLAND HABITAT CREATION

Using excavated clay material and harvesting native vegetation from the Project site to build
lomas is a beneficial use option requiring further evaluation. Lomas are brush-covered clay
dunes situated within tidal and wind-tidal flats. Lomas with dense brush cover in the proximity
of the Project area have been known to facilitate the travel of endangered cats from Mexico to
protected habitat in the Laguna Atascosa National Wildlife Refuge north of the BSC (USACE
2013). The U.S. Fish and Wildlife Service (USFWS) recovery strategy involves the
restoration/creation of habitat like that provided by these lomas (USFWS 2010 and 2012).
Important considerations for this option include the total volume of material needed, the potential
need to store or stage material and native plants until it is required for use at the designated areas,
and the practicability of supplying large volumes of water to sufficiently increase the
survivability of transplanted native species. Additionally, upland habitat creation placement
options would increase the potential environmental impacts such as vehicle and fugitive dust
emissions. Finally, this option would have potential significant Project cost implications
associated with the re-handling of the dredged material and the transport and placement of
material at the end location.
4
4.0 SUMMARY
The beneficial use options discussed above reflect preliminary information on the sediment
characteristics for the Project and the specific landscape that may benefit from use of dredged
material. Specific beneficial use options will be evaluated based on costs and consideration of
environmental and social benefits. The evaluation will consider the volume of material used in
each option, transport distances and methods, land acquisition requirements, and coordination
with stakeholders. The potential beneficial use options for the Project and the associated
logistics are summarized in Table 3-1. In each case, the engineering, economic, regulatory, and
environmental feasibility will determine the viability of the preferred concepts presented herein.
Table 3-1
Summary of Beneficial Use Options
Beneficial Use Option Material Required Federal / Non-Federal Partners
On-site Placement Clay None Necessary
U.S. Army Corps of Engineers /
Levee Raising Clay
Brownsville Navigation District
Texas General Land Office /
Beach Nourishment Sand
City of South Padre Island
Lomas Creation Clay U.S. Fish and Wildlife Service
U.S. Army Corps of Engineers /
Marsh Restoration Sand
Galveston Navigation District
5.0 REFERENCES
Black & Veatch. 2016. Geotechnical Investigation Report, Annova LNG Brownsville Project.
Document Number 183169‐STDY‐0006. March 21, 2016.
U.S. Army Corps of Engineers (USACE). 2013. Brazos Island Harbor, Texas Channel
Improvement Project, Appendix I, Endangered Species Act – Draft Biological
Assessment Cameron County, Texas. June 2013
______2015. Dredging and Dredged Material Management. Engineer Manual 1110-2-5025. U.S.
Army Corps of Engineers, Washington, DC.
______2015. Engineer Research and Development Center (ERDC). Beneficial Uses of Dredged
Material available online at: http://el.erdc.usace.army.mil/dots/budm/budm.cfm
U.S. Environmental Protection Agency (EPA). https://www.epa.gov/sites/production/files/2015-

08/documents/role_of_the_federal_standard_in_the_beneficial_use_of_dredged_material
.pdf
EPA and USACE. Identifying, Planning, and Financing Beneficial Use Projects Using Dredged
Material. October 2007
5
U.S. Fish and Wildlife Service (USFWS). 2010. Draft Ocelot (Leopardus pardalis) Recovery
Plan –First Revision. Southwest Region, Albuquerque.
_____. 2012. Endangered and Threatened Wildlife and Plants; Review of Native Species That
Are Candidates for Listing as Endangered or Threatened; Annual Notice of Findings on
Resubmitted Petitions; Annual Description of Progress on Listing Actions, Notice of
Review, 77 FR 69994 (November 12, 2012).
6
APPENDIX D
MIGRATORY BIRDS OF CAMERON COUNTY
TABLE D-1
Migratory Birds in Cameron County a/

Potential Nesting Potential Nesting
Occurrence in the Season in the Habitat at the
Species Project Area Project Area Description of Nesting Habitat Project Site?
Altamira oriole Year-round N/A Found on branch tips of trees emergent from canopy, dead branches of live or No
(Icterus gularis) dead trees, sometimes on guy wires of power poles, often on branches growing out
over water, bare ground, or low vegetation.
American oystercatcher Year-round N/A Nests are shallow depressions scraped into higher parts of sandy or rocky beaches No
(Haematopus palliatus) above the high tide line.
Audubon's oriole Year-round N/A Commonly found in mesquite trees or bushes in thickets and open woods, often 6 No
(Icterus graduacauda) to 16 feet off the ground.
Bald eagle (Haliaeetus Wintering N/A Generally nest on large trees with accessible limbs capable of holding nests. No
leucocephalus)
Bell’s vireo Breeding April-July Suspended from small, lateral or terminal forks of low, pendant branches in dense Yes
(Vireo bellii) shrubs, small trees, and sometimes herbaceous vegetation. Typically found near
the periphery of substrate plants and in association with small canopied openings
in vegetation.
Black skimmer Year-round N/A Simple nests consisting of shallow scrapes in the sand. No
(Rynchops niger)
Botteri’s sparrow Breeding July- Typically found hidden in dense grass clumps on the ground on mostly flat terrain; Yes
(Peucaea botterii) September found at the base of tufts or under projecting overhangs.
Buff-bellied hummingbird Year-round N/A Found in small trees or shrubs in horizontal branches typically 3 to 10 feet high. No
(Amazilia yucatanensis)
Burrowing owl Wintering N/A Nests in vacated prairie dog burrows where they may live in colonies. No
(Athene cunicularia)
Cassin’s sparrow Year-round N/A Primarily found in short-grass prairies with scattered shrubby mesquite, cacti, No
(Aimophila cassinii) yucca or oak.
Chestnut-collared longspur Wintering N/A Typically nests on the ground in excavated depressions, either exposed or under No
(Calcarius ornatus) clumps of grass.
Curve-billed thrasher Year-round N/A Nests are generally a deep cup but may be flat with only a slight depression for the No
(Toxostoma curvirostre) eggs. The outer layer often consists of thorny twigs, whereas the inner layers are
of smooth sticks, roots, and coarse grasses. Fine grasses, rootlets, or hair may be
used to line the cup.
Dickcissel Breeding May-August Located in dense vegetation in grasses, forbs, or low woody plants, with nearly Yes
(Spiza americana) complete overhead cover. Nests are located in low vegetation but not directly on
the ground.
Elf owl Breeding May-July Uses available holes in saguaro cacti and sometimes in trees in forests and No
(Micrathene whitneyi) woodlands along drainages and lower slopes of canyons.
D-1 Migratory Birds in Cameron County

TABLE D-1 (continued)

Species Project Area Project Area Description of Nesting Habitat Project Site
Green parakeet Year-round N/A Prefer nesting in cavities in dead Canary Island palms. No
(Psittacara holochlorus)
Gull-billed tern Year-round N/A Typically nest in small to medium-sized coastal colonies, potentially in marshes No
(Gelochelidon nilotica) and barrier beaches. Nest sites tend to be more elevated than surrounding terrain
or sites of other associated tern species; typically found in barren sand or shell
landscape.
Harris's hawk Year-round N/A Nests found in tall, sturdy structures; sometimes found in saguaro cacti. No
(Parabuteo unicinctus)
Hooded oriole Breeding April-August Typically suspended from leaves of trees in residential areas, riparian canyons, Yes
(Icterus cucullatus) parks and botanical gardens, or desert oases.
Hudsonian godwit Migrating N/A Nests in areas of mixed forest and wetland, particularly sedge meadows and boggy No
(Limosa haemastica) muskeg surrounded by coniferous forest.
Lark bunting Wintering N/A Dry short-grass prairies. No
(Calamospiza melanocorys)
Le Conte's sparrow Wintering N/A Open habitat, such as marshy meadows, hayfields, open grassy fields, sedge No
(Ammodramus leconteii) fields, rice stubble, and prairie.
Least bittern Breeding May-August Nests among dense, tall stands of emergent or woody vegetation, typically above Yes
(Ixobrychus exilis) or near open water.
Least tern Breeding April- Nests typically found close to nests of other species. Generally found in open Yes
(Sterna antillarum) September areas mostly free of vegetation, above high water levels; sandy areas with sparse
vegetation, mudflats, and graveled rooftops.
Lesser yellowlegs Wintering N/A Breeds in open boreal forest with scattered shallow wetlands. Nests in depression No
(Tringa flavipes) in ground or moss, lined with dry grass, decayed leaves, spruce needles or other
debris, placed on dry, mossy ridges or hummocks, next to fallen branches and
logs, and underneath low shrubs.
Loggerhead shrike Wintering N/A Typically found in trees with thorns, sometimes found in brush piles, tumbleweeds, No
(Lanius ludovicianus) or hardwood debris.
Long-billed curlew Wintering N/A Short-grass to mid-grass prairies on the High Plains to moist meadow-lands and No
(Numenius americanus) mowed areas.
Magnificent frigatebird Wintering N/A Lives on ocean coasts and islands. In breeding season it lives on mangrove No
(Fregata magnificens) islands.
Marbled godwit Wintering N/A Salt marsh vegetation edges. No
(Limosa fedoa)
Mountain plover Wintering N/A Short-grass prairie to cropland or barren ground. No
(Charadrius montanus)
Migratory Birds in Cameron County D-2


Northern beardless-tyrannulet Year-round N/A Riparian forest in clay soils of the Lower Rio Grande Valley and the live oak- No
(Camptostoma imberbe) dominated forest in sandy soil of Kenedy County.
Peregrine falcon Wintering N/A Prefers very tall sheer cliff faces with a commanding view, a nearby water source, No
(Falco peregrinus) and a good prey base.
Red knot Wintering N/A Nests typically built on dry, rocky arctic tundra at high elevations. Occurs year- No
(Calidris canutus rufa) round in coastal habitats. FWS confirmed the species does not nest in Texas.
Red-billed pigeon Year-round N/A Nests typically built on horizontal branches or crotches of trees or bushes; often No
(Patagioenas flavirostris) found in dead and live trees, shrubs, saplings, and fence posts.
Red-crowned parrot Year-round N/A Prefers large, thick leafy trees for roosting. No
(Amazona viridigenalis)
Reddish egret Year-round N/A Nests on ground or in vegetation or trees less than 32 feet above the ground. No
(Egretta rufescens)
Rose-throated becard Breeding, May-July Nests usually suspended at the end of a long hanging branch, under the shady Yes
(Pachyramphus aglaiae) Wintering canopy of a large tree (sycamore or cottonwood), up to 50 feet above the ground.
Sandwich tern Year-round N/A Nest colonially on flat, sandy islands close to shore. No
(Thalasseus sandvicensis)
Seaside sparrow Year-round N/A Nests at or near sea level along the Texas coast in tall spartina grass, rushes, and No
(Ammodramus maritimus) reeds growing in brackish or saltwater in tidal marshes.
Sedge wren Wintering N/A Nests in wet meadows, hayfields, old fields, and at upland edges of ponds, No
(Cistothorus platensis) marshes, and sphagnum bogs with tall growth of sedges and grasses.
Short-billed dowitcher Wintering N/A Nests are usually located on the ground near water. The nest is a shallow scrape No
(Limnodromus griseus) in a clump of moss or grass, lined with twigs, leaves, or grass.
Short-eared owl Wintering N/A Usually nests on dry sites such as small knolls, ridges, or hummocks. No
(Asio flammeus)
Snowy plover Breeding March- Bare areas such as salt flats, levees, dredge spoil piles and sand bars in rivers. Yes
(Charadrius alexandrinus) September Nests are often placed near a conspicuous object such as dried kelp, a shell
driftwood, cow dung, or tumbleweed.
Solitary sandpiper Wintering N/A Breeds in taiga, nesting in trees in deserted songbird nests. No
(Tringa solitaria)
Sprague's pipit Wintering N/A Breeds and winters in open grassland with good drainage and no shrubs or trees. No
(Anthus spragueii)
Swainson's warbler Migrating N/A Thick undergrowth in creek and river bottoms No
(Limnothlypis swainsonii)
Tropical parula Breeding April-July Nests in trees with epiphytic bromeliads, typically 6 to 42 feet off the ground, often Yes
(Setophaga pitiayumi) near the ends of branches.
D-3 Migratory Birds in Cameron County


Verdin Year-round N/A Nests often located along desert washes or at edges of vegetative boundaries, No
(Auriparus flaviceps) typically in dense foliage.
Whimbrel Wintering N/A Lives on the tundra in breeding season. No
(Numenius phaeopus)
White-collared seedeater Year-round N/A Riparian areas, especially in floodplains where herbaceous vegetation is dense. No
(Sporophila torqueola) Nest sites include small trees and bushes (black willow, anacua, catclaw acacia).
White-tailed hawk Year-round N/A Nests typically found within areas of low woody cover, and sometimes near No
(Buteo albicaudatus) standing water.
Wilson's plover Breeding April-August Nests typically found on bare soil or pavement near clumps of vegetation; typically Yes
(Charadrius wilsonia) near edges of road surfaced with rock, shells, or gravel.
Worm-eating warbler Migrating N/A Large tracts of deciduous or mixed deciduous-coniferous forests on moderate or No
(Helmitheros vermivorum) steep slopes with patches of dense understory.
N/A = Not applicable because there is no nesting habitat on site, or species does not occur on site during the nesting season.
a/ Does not include federal threatened and endangered species. See section 4.7 of this EIS.
Sources:
Cornell Lab of Ornithology. 2017. Whooping Crane. Website: https://www.allaboutbirds.org/guide/Whooping_Crane/lifehistory
Alsop, F.J. III. 2001. Smithsonian Birds of North America. Southern Lights Custom Publishing.
Sibley, D.A. 2003. The Sibley Field Guide to Birds of Eastern North America. Andrew Stewart Publishing, Inc.
FWS (U.S. Fish and Wildlife Service). 2015. Information, Planning, and Conservation System (IPaC). Website: http://ecos.fws.gov/ipac/wizard/trustResourceList!prepare.action
(accessed April 9, 2015).
Migratory Birds in Cameron County D-4

APPENDIX E
VISUAL SIMULATIONS OF THE PROJECT AREA FROM KEY OBSERVATION
POINTS
02:009110.0001.03.03\Figure 8A-2_Annova_KOP 1_Historical Marker for Palmito Ranch Battlefield.ai-3/1/18-GRA
Existing Conditions
Simulated Conditions
Proposed Project
Photo Information
View looking northeast from the Historical Marker on Boca Chica Boulevard. Annova LNG Visual Simulations
Longitude (W): -97.301718 Camera: Canon 50D DSLR Date: 9/3/2015 KOP 1. Palmito Ranch Battlefield
Latitude (N): 25.961577 Lens: Canon EF 28-135mm Time: 9:40 a.m. Historical Marker
Elevation: 43 feet Lens Setting: 35mm Weather: Cloudy, storm
Distance to Project Area: (Equivalent to 56mm on film approaching from east
approx. 3.09 miles camera) Visibility: Fair
Camera Bearing: NE
Height of Camera: 5 ft.
Figure E-1a
KOP 1
Cameron County, TX
Not to scale. Not intended to be an exact representation. Artistic rendering for demonstration purposes only. Facility colors sampled from the 2013 BLM Standard Environmental Color chart.
To properly view this simulation, print on 11"x17" paper at 100% and view 10" to 12" from eyes.
Existing Conditions
Proposed Project Marine Flare assuming
worst case conditions.
Flaring occurs for
approximately 4 hours of
the 25 hour duration of
venting of inert gas from
LNG carriers or during
loading potentially 2 times
per year.
Photo Information
Camera Bearing: NE
Figure E-1b Marine Flare
KOP 1
Cameron County, TX
Existing Conditions
Proposed Project Warm/Cold Flare
assuming worst case
conditions. Flaring occurs
intermittently for
approximately 6 hours
during planned
maintenance, start-up,
and shutdown events
typically 2 times per year.
Photo Information
Camera Bearing: NE
Figure E-1c Warm/Cold Flare
KOP 1
Cameron County, TX
02:009110.0001.02.03\Figure 8A-3 Rev Tank Location.Apr 2018 Supp_KOP 2_Palmito Ranch Battlefield NHL.ai-4/23/18-GRA
Existing Conditions Simulated Conditions
Note: The proposed project would not be seen behind vegetation from this location. The tan wireframe above shows the facility as it would appear behind the vegetation.
Photo Information
View looking northeast from observation platform at the Palmito Ranch Battlefield, south of Boca Annova LNG Visual Simulations
Chica Boulevard.
KOP 2. Palmito Ranch Battlefield National
Longitude (W): -97.301958 Camera: Canon 50D DSLR Date: 9/3/2015 Historic Landmark (Observation Platform)
Latitude (N): 25.956080 Lens: Canon EF 28-135mm Time: 9:25 a.m.
Elevation: 30.2 feet Lens Setting: 28mm (Equivalent Weather: Partly Cloudy
Distance to Project Area: to 45mm on film camera) Visibility: Good
approx. 3.39 miles Camera Bearing: NE
Height of Camera: 5 ft plus 1.5 ft
above surrounding ground level Figure E-2
KOP 2
Cameron County, TX
Not to scale. Not intended to be an exact representation. Artistic rendering for demonstration purposes only.
02:009110.0001.03.03\Figure 8A-4_Annova_KOP 3_Lower Rio Grande Valley National Wildlife Refuge.ai-4/10/18-GRA
Existing Conditions
Proposed Project
Photo Information
View looking northwest from a pull-off along Boca Chica Blvd. with views across the Lower Rio Grande Valley National Wildlife Refuge. Annova LNG Visual Simulations
Longitude (W): -97.237855 Camera: Canon 50D DSLR Date: 9/3/2015 KOP 3. Lower Rio Grande Valley National
Latitude (N): 25.965884 Lens: Canon EF 28-135mm Time: 12:30 p.m. Wildlife Refuge (Pull-off along
Elevation: 18.7 feet Lens Setting: 35mm Weather: Cloudy Boca Chica Boulevard)
Distance to Project Area: (Equivalent to 56mm on film Visibility: Good
approx. 2.4 miles camera)
Camera Bearing: NW
Figure E-3a
KOP 3
Cameron County, TX
Existing Conditions
Marine Flare assuming
Flaring occurs for
Proposed Project LNG carriers or during
per year.
Photo Information
Camera Bearing: NW
KOP 3
Cameron County, TX
Existing Conditions
Warm/Cold Flare
assuming worst case
intermittently for
during planned
Proposed Project maintenance, start-up,
and shutdown events
Photo Information
Camera Bearing: NW
KOP 3
Cameron County, TX
02:009110.0001.03.03\Figure 8A-5_Annova_KOP 4_Palmetto Pilings Historical Marker.ai-4/10/18-GRA
Existing Conditions
Proposed Project
Photo Information
View looking west from the Palmetto Pilings Historical Marker on Boca Chica Boulevard. Annova LNG Visual Simulations
LLongitude (W): -97.158690 Camera: Canon 50D DSLR Date: 9/3/2015 KOP 4. Palmetto Pilings
KOP 4 Latitude (N): 25.998294 Lens: Canon EF 28-135mm Time: 11:45 a.m. Historical Marker
Elevation: 6.9 feet Lens Setting: 35mm Weather: Cloudy
Distance to Project Area: (Equivalent to 56mm on film Visibility: Fair
Camera Bearing: W
Figure E-4a
Cameron County, TX
Existing Conditions
Flaring occurs for
Proposed Project LNG carriers or during
per year.
Photo Information
Camera Bearing: W
Cameron County, TX
Existing Conditions
Warm/Cold Flare
assuming worst case
intermittently for
during planned
Proposed Project maintenance, start-up,
and shutdown events
Photo Information
Camera Bearing: W
Cameron County, TX
02:009110.0001.03.03\Figure 8A-6_Annova_KOP 5a_Isla Blanca Park Boat Ramp.ai-4/10/18-GRA
Existing Conditions
Proposed Project
KOP 5 Photo Information

View looking southwest from the Isla Blanca Park Boat Ramp on South Padre Island. Annova LNG Visual Simulations
Longitude (W): -97.162703 Camera: Canon 50D DSLR Date: 9/2/2015 KOP 5. Isla Blanca Park Boat Ramp
Elevation: 18.4 feet Lens Setting: 35mm Weather: Sunny, clear
Camera Bearing: SW
Figure E-5a
Cameron County, TX
Existing Conditions
Flaring occurs for
Proposed Project venting of inert gas from
per year.

Camera Bearing: SW
Cameron County, TX
Existing Conditions
Warm/Cold Flare
assuming worst case
intermittently for
Proposed Project during planned
and shutdown events

Camera Bearing: SW
Cameron County, TX
02:009110.0001.03.03\Figure 8A-7_Annova_KOP 5b-NIGHT_Isla Blanca Park Boat Ramp – Nighttime.ai-4/10/18-GRA
Existing Conditions
Proposed Project

Nighttime view looking southwest from the Isla Blanca Park Boat Ramp on South Padre Island. Annova LNG Visual Simulations
Latitude (N): 26.068794 Lens: Canon EF 28-135mm Time: 8:45 p..m. – Nighttime
Elevation: 18.4 feet Lens Setting: 35mm Weather: Partly Cloudy
Camera Bearing: SW
Figure E-5d
Cameron County, TX
Existing Conditions
Flaring occurs for
per year.

Camera Bearing: SW
Figure E-5e Marine Flare
Cameron County, TX
Existing Conditions
Warm/Cold Flare
assuming worst case
intermittently for
and shutdown events

Camera Bearing: SW
Figure E-5f Warm/Cold Flare
Cameron County, TX
02:009110.0001.02.03\Figure 8A-8_Annova_KOP 6_Port Isabel Lighthouse.ai-4/10/18-GRA
Existing Conditions
Proposed Project
KOP 6
Photo Information
View looking southwest from the Port Isabel Lighthouse observation deck. Annova LNG Visual Simulations
Longitude (W): -97.207585 Camera: Canon 50D DSLR Date: 9/2/2015 KOP 6. Port Isabel Lighthouse
Camera Bearing: SW
Height of Camera: 5 ft plus
73 ft. high at top of Figure E-6a
lighthouse Cameron County, TX
Existing Conditions
Flaring occurs for
per year.
KOP 6
Photo Information
Camera Bearing: SW
73 ft. high at top of Figure E-6b Marine Flare
Existing Conditions
Warm/Cold Flare
assuming worst case
intermittently for
and shutdown events
KOP 6
Photo Information
Camera Bearing: SW
73 ft. high at top of Figure E-6c Warm/Cold Flare
02:009110.0001.02.03\Figure 8A-9_Annova_KOP 7_Port Isabel High School Tarpon Stadium.ai-4/10/18-GRA
Existing Conditions
Proposed Project

View looking south from the elevated stadium seating Annova LNG Visual Simulations
Longitude (W): -97.246986 Camera: Canon 50D DSLR Date: 9/3/2015 KOP 7. Port Isabel High School
Latitude (N): 26.074919 Lens: Canon EF 28-135mm Time: 6:15 p.m. Tarpon Stadium
Elevation: 31.5 feet Lens Setting: 35mm Weather: Partly cloudy
Camera Bearing: S
36 ft. at top of stadium Figure E-7a
seating Cameron County, TX
Existing Conditions
Flaring occurs for
per year.

Camera Bearing: S
36 ft. at top of stadium Figure E-7b Marine Flare
Existing Conditions
Warm/Cold Flare
assuming worst case
intermittently for
and shutdown events

Camera Bearing: S
36 ft. at top of stadium Figure E-7c Warm/Cold Flare
02:009110.0001.02.03\Figure 8A-10_Annova_KOP 8a_State Highway 48 Pull-off.ai-4/10/18-GRA
Existing Conditions
Proposed Project
Photo Information
View looking southeast from a pull-off along the south side of SH 48 near the Bahia Grande Channel. Annova LNG Visual Simulations
KOP 8
Longitude (W): -97.275384 Camera: Canon 50D DSLR Date: 9/2/2015 KOP 8. State Highway 48 Pull-off near
Latitude (N): 26.015456 Lens: Canon EF 28-135mm Time: 5:45 p.m. Bahia Grande Channel
Elevation: 6.2 feet Lens Setting: 35mm Weather: Sunny, few clouds - DAYTIME
Distance to Project Area: (Equivalent to 56mm on Visibility: Good
approx. 0.64 miles film camera)
Camera Bearing: SE
Figure E-8a
Cameron County, TX
02:009110.0001.03.03\Figure 8A-11_Annova_KOP 8b_State Highway 48 Pull-off - with LNG TANKER.ai-4/10/18-GRA
Existing Conditions
Proposed Project
Photo Information
View looking southeast from a pull-off along the south side of SH 48 while an LNG carrier is docked in the Annova berth. Annova LNG Visual Simulations
KOP 8
Elevation: 6.2 feet Lens Setting: 35mm Weather: Sunny, few clouds – DAYTIME WITH LNG CARRIER
Camera Bearing: SE
Figure E-8b
Cameron County, TX
Existing Conditions
Flaring occurs for
per year.
Photo Information
KOP 8
Elevation: 6.2 feet Lens Setting: 35mm (Equivalent Weather: Sunny, few clouds - DAYTIME
approx. 0.64 miles Camera Bearing: SE
Figure E-8c Marine Flare

Cameron County, TX
Existing Conditions
assuming worst case
intermittently for
during planned
and shutdown events
Photo Information
KOP 8
Elevation: 6.2 feet Lens Setting: 35mm (Equivalent Weather: Sunny, few clouds - DAYTIME
approx. 0.64 miles Camera Bearing: SE
Figure E-8d Warm/Cold Flare

Cameron County, TX
02:009110.0001.02.03\Figure 8A-12_Annova_KOP 8c NIGHT_State Highway 48 Pull-off - NIGHTTIME.ai-4/10/18-GRA
Existing Conditions
Proposed Project
Photo Information
Nighttime view looking southeast from a pull-off along the south side of SH 48 near the Bahia Grande Channel. Annova LNG Visual Simulations
KOP 8
Elevation: 6.2 feet Lens Setting: 35mm Weather: Overcast – NIGHTTIME
Camera Bearing: SE
Figure E-8e
Cameron County, TX
Existing Conditions
Flaring occurs for
per year.
Photo Information
KOP 8
Camera Bearing: SE
Figure E-8f Marine Flare
Cameron County, TX
Existing Conditions
assuming worst case
intermittently for
during planned
and shutdown events
Photo Information
KOP 8
Camera Bearing: SE
Figure E-8g Warm/Cold Flare
Cameron County, TX
02:009110.0001.03.03\Figure 8A-13_Annova_KOP 9a_Jaime J. Zapata Memorial Boat Ramp - DAYTIME.ai-3/1/18-GRA
Existing Conditions
Proposed Project
Photo Information
View looking east from a dock at the boat ramp (located near channel connecting San Martin Lake and Brownsville Ship Channel) Annova LNG Visual Simulations
Longitude (W): -97.298535 Camera: Canon 50D DSLR Date: 9/2/2015 KOP 9. Jaime J. Zapata Memorial Boat Ramp
Latitude (N): 26.001798 Lens: Canon EF 28-135mm Time: 3:45 p.m. - DAYTIME
KOP 9
Camera Bearing: E
on dock about 1.5 ft above Figure E-9a
surrounding ground level Cameron County, TX
02:009110.0001.02.03\Figure 8A-14_Annova_KOP 9b_Jaime J. Zapata Memorial Boat Ramp - with LNG TANKER.ai-3/1/18-GRA
Existing Conditions
Proposed Project
Photo Information
View looking east from the boat ramp while an LNG carrier is docked in the Annova berth Annova LNG Visual Simulations
Latitude (N): 26.001798 Lens: Canon EF 28-135mm Time: 3:45 p.m. – DAYTIME WITH LNG CARRIER
KOP 9
Camera Bearing: E
on dock about 1.5 ft above Figure E-9b
Existing Conditions
Flaring occurs for
Proposed Project
per year.
Photo Information
KOP 9
Camera Bearing: E
on dock about 1.5 ft above Figure E-9c Marine Flare
Existing Conditions
Warm/Cold Flare
assuming worst case
intermittently for
Proposed Project
during planned
and shutdown events
Photo Information
KOP 9
Camera Bearing: E
on dock about 1.5 ft above Figure E-9d Warm/Cold Flare
02:009110.0001.03.03\Figure 8A-15_Annova_KOP 9c NIGHT_Jaime J. Zapata Memorial Boat Ramp - NIGHTTIME.ai-3/1/18-GRA
Existing Conditions
Proposed Project
Photo Information
Nighttime view looking east from a dock at the boat ramp. Annova LNG Visual Simulations
Latitude (N): 26.001798 Lens: Canon EF 28-135mm Time: 9:28 p.m. - NIGHTTIME
KOP 9
Camera Bearing: E
on dock about 1.5 ft above Figure E-9e
Existing Conditions
Flaring occurs for
Proposed Project
per year.
Photo Information
KOP 9
Camera Bearing: E
on dock about 1.5 ft above Figure E-9f Marine Flare
Existing Conditions
Warm/Cold Flare
assuming worst case
intermittently for
Proposed Project
during planned
and shutdown events
Photo Information
KOP 9
Camera Bearing: E
on dock about 1.5 ft above Figure E-9g Warm/Cold Flare
02:009110.0001.03.03\Figure 8A-16_Annova_KOP 10_Palo Alto Battlefield National Historical Park (Visitor Overlook)_55mm.ai-4/10/18-GRA
Existing Conditions
Proposed Project
Photo Information
View looking east from the visitor overlook at Palo Alto Battlefield National Historical Park. Annova LNG Visual Simulations
KOP 10 Longitude (W): -97.473602 Camera: Canon EOS DSLR Date: 1/14/2016
Latitude (N): 26.021200 Lens: Canon EFS 18-55mm Time: 1:17 p.m.
Elevation: 19.7 feet Lens Setting: 55mm Weather: Partly Cloudy KOP 10. Palo Alto Battlefield National Historical Park
Distance to Project Area: (Equivalent to 88mm on film Visibility: Good (Visitor Overlook)
Camera Bearing: E
6.5 ft above surrounding Figure E-10a
ground level Cameron County, TX
To properly view this simulation, print on 11"x17" paper at 100% and view 13-15" from eyes.
Existing Conditions
Proposed Project
Photo Information
Camera Bearing: E
6.5 ft above surrounding Figure E-10b
Existing Conditions
Flaring occurs for
Proposed Project the 25 hour duration of
per year.
Photo Information
Camera Bearing: E
6.5 ft above surrounding Figure E-10c Marine Flare
Existing Conditions
Warm/Cold Flare
assuming worst case
intermittently for
Proposed Project approximately 6 hours
during planned
and shutdown events
Photo Information
Camera Bearing: E
6.5 ft above surrounding Figure E-10d Warm/Cold Flare
APPENDIX F
ESSENTIAL FISH HABITAT ASSESSMENT
APPENDIX F
ESSENTIAL FISH HABITAT ASSESSMENT
TABLE OF CONTENTS
Page
1.0 INTRODUCTION AND REGULATORY BACKGROUND ....................................F-1
2.0 PROJECT OVERVIEW ...............................................................................................F-2
3.0 FEDERALLY MANAGED SPECIES AND ESSENTIAL FISH HABITAT ..........F-2
4.0 POTENTIAL PROJECT IMPACTS ...........................................................................F-9
5.0 CUMULATIVE IMPACTS AND MITIGATION ....................................................F-30
6.0 CONCLUSION ............................................................................................................F-32

7.0 REFERENCES.............................................................................................................F-33
F-i EFH Assessment

TABLES
Table Page
Table F-1 Managed Taxa with Essential Fish Habitat Potentially Occurring Within the
Project Region of Influence .................................................................................... F-3
Table F-2 Estuarine Essential Fish Habitats, Species, and Life Stages for Gulf of
Mexico Fishery Management Council Ecoregion 5 ............................................... F-6
Table F-3 Highly Migratory Species with EFH in State Waters of Ecoregion 5 in the
Project Area ............................................................................................................ F-7
Table F-4 Summary of the Proposed Activities that May Affect Essential Fish Habitat ...... F-10
TABLE F-5 Temporary Impacts to and Permanent Loss of Tidal and Subtidal and Wetland
EFH ....................................................................................................................... F-11
Table F-6 Unattenuated Sound Pressure Levels Measured for the Benicia-Martinez
Bridge.................................................................................................................... F-21
Table F-7 Predicted Pile-Driving Noise Thresholds Limits for Fish .................................... F-23
FIGURES
Figure Page
Figure F-1 Essential Fish Habitat for Coastal Migratory Pelagics, Reef Fish, Shrimp, and
Red Drum ................................................................................................................ F-4
Figure F-2 Salinity Ranges for Adults of Estuarine Species Compared with Open Gulf
Salinities................................................................................................................ F-26
EFH Assessment F-ii


°F degrees Fahrenheit
Annova Annova LNG Common Infrastructure, LLC; Annova LNG Brownsville
A, LLC; Annova LNG Brownsville B, LLC; and Annova LNG
Brownsville C, LLC
Annova Plan Annova’s Upland Erosion Control, Revegetation, and Maintenance Plan
Annova Procedures Annova’s Wetland and Waterbody Construction and Mitigation Procedures
BMP best management practice
CFR Code of Federal Regulations
COE United States Army Corps of Engineers
Coast Guard United States Coast Guard
dB re 1 μPa decibels in reference to 1 microPascal
DMPA dredge material placement area
EEZ Exclusive Economic Zone
EFH essential fish habitat
EIS environmental impact statement
ESA Endangered Species Act
FERC Federal Energy Regulatory Commission
FMP fishery management plan
GIS geographical information system
GMFMC Gulf of Mexico Fishery Management Council
HAPC habitat area of particular concern
HMS highly migratory species
HSD Hydro Sound Damper
Hz hertz
µPa microPascal
mg/L milligram per liter
MSA Magnuson-Stevens Fishery Conservation and Management Act
NAISA National Aquatic Invasive Species Act of 2003
NANPCA Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990
NEPA National Environmental Policy Act
NMS Noise Mitigation Screen
NOAA National Oceanic and Atmospheric Administration
NOAA Fisheries National Oceanic and Atmospheric Administration, National Marine
Fisheries Service
PAH polycyclic aromatic hydrocarbon
PRICO® Poly Refrigerant Integrated Cycle Operation
ppt parts per thousand
F-iii EFH Assessment

Project Annova Liquefied Natural Gas Project

RMS root-mean-squared
ROI region of influence
SEL sound exposure level
SPL sound pressure level
TCEQ Texas Commission on Environmental Quality
TL transmission loss
TSS total suspended solids
ZOI zone of influence
EFH Assessment F-iv

1.0 INTRODUCTION AND REGULATORY BACKGROUND

The Magnuson-Stevens Fishery Conservation and Management Act of 1976 (MSA; Public
Law 94-265 as amended through October 11, 1996) was established, along with other goals, to
promote the protection of essential fish habitat (EFH) during the review of projects to be conducted
under federal permits, licenses, or other authorities that affect or have the potential to affect such
habitat. EFH is defined in the MSA as those waters and substrate necessary to fish for spawning,
breeding, feeding, or growth to maturity. Federal agencies that authorize, fund, or undertake
activities that may adversely affect EFH must consult with the National Oceanic and Atmospheric
Administration (NOAA) National Marine Fisheries Service (NOAA Fisheries). Although absolute
criteria have not been established for conducting EFH consultations, NOAA Fisheries
recommends consolidated EFH consultations with interagency coordination procedures required
by other statutes, such as the National Environmental Policy Act (NEPA), the Fish and Wildlife
Coordination Act, and the Endangered Species Act (ESA), to reduce duplication and improve
efficiency (50 Code of Federal Regulations [CFR] 600.920(e)). Generally, the EFH consultation
process includes the following steps:
1. Notification – The action agency should clearly state the process being used for
EFH consultations (e.g., incorporating EFH consultation into an EIS).
2. EFH Assessment – The action agency should prepare an EFH Assessment that
includes both identification of affected EFH and an assessment of impacts.
Specifically, the EFH Assessment should include:
• a description of the proposed action;
• an analysis of the effects (including cumulative effects) of the proposed
action on EFH, managed fish species, and major prey species;
• the federal agency’s views regarding the effects of the action on EFH; and
• proposed mitigation, if applicable.
3. EFH Conservation Recommendations – After reviewing the EFH Assessment,
NOAA Fisheries should provide recommendations to the action agency regarding
measures that can be taken by that agency to conserve EFH.
4. Agency Response – Within 30 days of receiving the recommendations, the action
agency must respond to NOAA Fisheries. The action agency may notify NOAA
Fisheries that a full response to the conservation recommendations would be
provided by a specified completion date agreeable to all parties. The response
must include a description of measures proposed by the agency to avoid, mitigate,
or offset the impact of the activity on EFH. For any conservation recommendation
that is not adopted, the action agency must explain its reason to NOAA Fisheries
for not following the recommendation.
The Federal Energy Regulatory Commission (FERC) proposes to incorporate EFH

consultation for the Annova Liquefied Natural Gas (LNG) Brownsville Project (Project) with the
interagency coordination procedures required under NEPA. As such, we requested that NOAA
Fisheries consider the draft environmental impact statement (EIS) for the Project as initiation of
EFH consultation.
F-1 EFH Assessment

The FERC often issues a final EIS with updated resource information, but consultation
between the FERC and other federal resource agencies continues beyond the issuance of the final
EIS. FERC practice is not to authorize any construction until all required federal permits and
consultations have been completed.
This report is being prepared to facilitate the FERC’s review and development of an EIS
for the Project. This EFH assessment includes the required elements defined above.
2.0 PROJECT OVERVIEW
Annova LNG Common Infrastructure, LLC; Annova LNG Brownsville A, LLC; Annova
LNG Brownsville B, LLC; and Annova LNG Brownsville C, LLC (Annova) is proposing to
construct, own, and operate the Project in Cameron County, Texas. Annova would construct the
Project on an approximately 731-acre property adjacent to the Brownsville Ship Channel (BSC),
which is available to Annova through a real estate lease option agreement with the Brownsville
Navigation District (BND). The property is located at approximate mile marker 8.2 on the BSC.
The Project includes two principal parts: the LNG facilities and the associated marine transfer
facilities. LNG would be stored in two single-containment LNG storage tanks on the site and would
be pumped from the storage tanks to the marine transfer facilities. The marine transfer facilities
would load LNG carriers that arrive at the berthing dock.
Chapters 1 and 2 of the EIS provide a Project description, including a description of Project
components, mapping, land requirements, construction and operation methods, the anticipated
construction schedule, and a summary of permits and approvals required and Annova’s
communications with stakeholders. Chapter 3 of the EIS includes an alternatives analysis, and
Chapter 4 provides resource-specific impact analysis as well as analysis of potential cumulative
impacts of the Project when combined with the impacts of other past, present, and reasonably
foreseeable future actions.
3.0 FEDERALLY MANAGED SPECIES AND ESSENTIAL FISH HABITAT

Commercial and recreational fisheries resources in the federal waters of the Gulf of Mexico
are managed by the Gulf of Mexico Fishery Management Council (GMFMC) and NOAA
Fisheries. Between 1979 and 1987, the GMFMC prepared fishery management plans (FMPs) for
seven marine groups within the Gulf of Mexico: red drum (Sciaenops oce1latus), coastal migratory
pelagics, reef fish, shrimp, spiny lobster (Panulirus argus), stone crab (Menippe adina and
Menippe mercenaria), and corals. Each FMP has been amended at least several times since then.
One important amendment that applied to all seven FMPs was implemented in 1998 and involved
the identification of EFH for each group. Additionally, the Secretarial FMP developed by NOAA
Fisheries for highly migratory species (HMS) included Amendment 1 to the Atlantic Billfish
Fishery Management Plan and the Final Fishery Management Plan for Atlantic Tuna, Swordfish,
and Sharks.
All estuarine systems of the Gulf of Mexico, including the BSC, are considered EFH, which
is managed by the GMFMC (GMFMC 2010). EFH includes all types of marine and estuarine
habitat (e.g., wetlands, coral reefs, seagrasses, and rivers) where fish spawn, breed, feed, or grow
to maturity. The MSA requires the GMFMC to identify habitats essential to managed species and
implement measures to conserve and enhance this habitat. NOAA Fisheries reviews the EFH
EFH Assessment F-2

Assessment submitted by federal project proponents and recommends conservation measures

designed to minimize, to the extent practicable, any adverse effects the project on EFH for all life
stages of managed species using the best available scientific information.
In addition to EFH, NOAA Fisheries and the Fishery Management Councils have identified
more than 100 habitat areas of particular concern (HAPCs), which are considered high priority areas
for conservation, management, or research because they are rare, sensitive, stressed by development,
or important to ecosystem function (NOAA 2016). The GMFMC has designated several HAPCs
scattered along the continental shelf in the western section of the northwestern Gulf of Mexico: West
Flower Garden Bank, East Flower Garden Bank, Stetson Bank, 29 Fathom Bank, 28 Fathom Bank,
MacNeil Bank, Rezak Bank, Sidner Bank, Rankin Bank, Bright Bank, Geyer Bank, McGrail Bank,
Bouma Bank, Sonnier Bank, Alderdice Bank, and Jakkula Bank. None of these HAPCs are within
the Project region of influence (ROI) for fish resources (defined as the BSC and adjacent connected
waterbodies, within 2 miles of the Project, which include South Bay and Bahia Grande), although
LNG carriers may transit near these areas. Because LNG transit is not considered to have discernable
adverse effects on EFH, the LNG transit aspect of the Project is not discussed further in this
assessment.
EFH has been designated for several groups of managed fishes in the Gulf of Mexico that
occur within the ROI of the Project. Based on correspondence with NOAA Fisheries Habitat
Protection personnel (Young 2015), a list of species specific to the Project was developed (see
table F-1). Generally, EFH for most of these managed species consists of estuarine waters out to
depths of 100 fathoms in the Gulf of Mexico waters (figure F-1).
TABLE F-1
Managed Taxa with Essential Fish Habitat Potentially Occurring Within the Project Region of Influence
Common Name Scientific Name
Coastal Migratory Pelagics FMP
king mackerel Scomberomorus cavalla
Spanish mackerel Scomberomorus maculates
cobia Rachycentron canadum
Red Drum FMP
Red drum Sciaenops ocellatus
Reef Fish FMP
Snappers Family Lutjanidae
Gray (mangrove) snapper Lutjanus griseus
Lane snapper Lutjanus synagris
Groupers Family Serranidae
Goliath grouper Epinephelus itajara
Shrimp FMP
Brown shrimp Penaeus aztecus
White shrimp Penaeus setiferus
Source: GMFMC 2004; 2015; Young 2015, personal communication
F-3 EFH Assessment

Figure F-1 Essential Fish Habitat for Coastal Migratory Pelagics, Reef Fish, Shrimp,
and Red Drum
EFH Assessment F-4

The two primary physical features that determine the suitability of habitat for supporting
managed species are substrate type and water depth. Using a geographical information system
(GIS), NOAA Fisheries (2009) mapped and analyzed depth and substrate throughout the Gulf of
Mexico and correlated the occurrence of both of these variables with various life stages for each
EFH species. For example, if a species and life stage were mapped in GIS according to these
preferences, when a particular substrate and depth occurred across the Gulf of Mexico the area
was considered potential supporting habitat for that species and its corresponding life stage. The
allocation of potential habitat was based on this functional relationship and was mapped out to the
100-fathom contour.
Applying this approach Gulf-wide provided an imprecise representation of the managed

species’ distribution. It also provided little information on relative density that could be used to
distinguish between all habitats occupied by a species and those that should be identified as EFH.
In order to refine the analysis, the Gulf of Mexico was divided into five sub-units, or ecoregions.
The division between the ecoregions was based primarily on logical ecosystem subdivisions of the
Gulf of Mexico. For convenience, the actual lines dividing the ecoregions were selected to
coincide with existing boundaries between units in the NOAA Fisheries statistical grid system for
depicting fishing effort (GMFMC 2004).
The boundary between Ecoregion 4 and Ecoregion 5 represents an approximate boundary

between the West Indian and Louisianan biogeographic provinces in the Western Gulf (Cowardin
et al. 1979). Ecoregion 5 is named West Texas, and extends from Freeport, Texas, to the Texas-
Mexico border, encompassing NOAA Statistical Grids 19 to 21 (GMFMC 2004). Generally,
Ecoregion 5 has a greater subtropical influence than Ecoregion 4. Ecoregion 5, generally, has
higher temperatures and lower rainfall, with accompanying higher salinities, than Ecoregion 4
(Hoese and Moore 1977). Finally, Ecoregion 5 has little marsh habitat, limited seagrass beds, and
some hypersaline habitats (Hoese and Moore 1977). The results of field surveys indicate that no
vegetation occurs in the open water in the BSC within the Project site (see figure 4.3.2-3 in the
EIS). Known seagrass beds are identified in the BCS at Port Isabel and the entrance to South Bay
over 3.1 miles (5,000 meters) downstream.
Based on information regarding the general distributions of the life stages of Gulf of
Mexico managed species, a density status, chosen to match up with the terminology in the
NOAA Gulf of Mexico Coastal and Ocean Zones Strategic Assessment Data Atlas (NOAA 1985),
was allocated for each species/life stage in each ecoregion (GMFMC 2004). Egg, larval, and
post-larval stages were designated as either “no occurrence,” “occurrence,” or “common” in an
ecoregion, representing increasing levels of abundance. For juveniles, the status of the life
stage in an ecoregion was categorized as “no occurrence,” “occurrence,” or “nursery area.” For
both adults and spawning adults, the categories used were “no occurrence,” “occurrence,”
“adult area,” or “major adult area and commercial fishing ground.” In addition to the information
recorded in the database, additional literature on ichthyofauna in the Gulf of Mexico was
consulted by NMFS to make judgments about the distribution status of species/life stages. If a
species/life stage was recorded as present within the ecoregion (i.e., density status greater
than “no occurrence”), substrates and depths with documented use for feeding, growth to
maturity, or spawning were designated as potential habitat (GMFMC 2004).
F-5 EFH Assessment

For species that may occur in the BSC and other local navigable channels, bay and estuary
habitat of the Lower Laguna Madre, areas on or inshore of Padre Island, and within nearshore
areas (i.e., marine waters 60 feet [18.3 meters] deep or less) of the Gulf of Mexico, and which
therefore may be affected by the Project, EFH includes the water column, estuarine emergent
marsh, estuarine submerged aquatic vegetation, estuarine mud/soft bottom, oyster reef, and
estuarine sand and shell bottom. EFH for coastal migratory pelagics comprises all the estuarine,
nearshore, and offshore areas of the Gulf of Mexico out to the 100-fathom depth contour, including
the BSC (GMFMC 2004).
Based on correspondence with NOAA Fisheries Habitat Protection personnel (Young

2015), a list of species (and relevant life stages) specific to the Project was developed. EFH known
or expected to occur within the Project area is shown in table F-2. Note that no EFH for spawning
adults or eggs is designated within the Project area.
TABLE F-2
Estuarine Essential Fish Habitats, Species, and Life Stages for Gulf of Mexico Fishery Management Council Ecoregion 5
Species Name Eggs Larvae Post-Larvae Early Juvenile Late Juvenile Adult Spawning Adult
Estuarine Emergent Marsh
Red drum ● ● ●
Gray snapper ●
Brown shrimp ● ●
White shrimp ● ●
Mangrove a/
Goliath grouper ● ●
Lane snapper ● ●
Estuarine Submerged Aquatic Vegetation
Red drum ● ● ● ●
Goliath grouper ● ●
Lane snapper ● ● ●
Pink shrimp ●
Estuarine Oyster Reef
Brown shrimp ●
Estuarine Sand and Shell Bottom
Red drum ● ●
Gray snapper ●
Estuarine Mud/Soft Bottom
Red drum ● ● ● ●
Gray snapper ●
White shrimp ● ●
Sources: GMFMC 1998, 2004, 2005; NOAA Fisheries 2009, 2011

a/ Mangrove would not be directly affected by the Project but would be adjacent to the Project site.
EFH Assessment F-6

LNG carriers that visit the Annova LNG terminal would transit through EFH designated
for the coastal migratory pelagics and highly migratory species (table F-3). As mentioned
previously, LNG transit would have no discernable effect on EFH. No construction or other
operational activity including vessel transit would affect EFH for HMS; therefore, effects on EFH
for this group are not discussed further in this assessment.
TABLE F-3
Highly Migratory Species with EFH in State Waters of Ecoregion 5 in the Project Area
Species Common Name Life Stage
Scalloped hammerhead shark (Sphyrna lewini) Neonate and juvenile
Blacktip shark (Carcharhinus melanopterus) Neonate, juvenile, and adult
Bull shark (Carcharhinus leucas) Neonate, juvenile, and adult
Lemon shark (Negaprion brevirostris) Neonate and juvenile
Silky shark (Carcharhinus falciformis) Neonate, juvenile, and adult
Spinner shark (Carcharhinus brevipinna) Neonate and juvenile
Tiger shark (Galeocerdo cuvier) Adult
Bonnethead shark (Sphyrna tiburo) Neonate, juvenile, and adult
Atlantic sharpnose shark (Rhizoprionodon terraenovae) Neonate, juvenile, and adult
Finetooth shark (Carcharhinus isodon) Neonate
Sources: GMFMC 1998, 2004, 2005; NOAA Fisheries 2009, 2011
The following subsections describe managed species with designated EFH in the ROI: red
drum, reef fish, shrimp, coastal migratory pelagics, and highly migratory species.
RED DRUM
The red drum (Sciaenops ocellatus) is a euryhaline fish distributed along the Atlantic and
Gulf of Mexico coasts from Cape Cod, Massachusetts, to Tuxpan, Mexico. Red drum, considered
a near-shore species, is distributed over a wide range of habitats, including estuaries, river
mouths, bays, sandy bottoms, mud flats, seagrass beds, oyster bottoms, surf zones, and
continental shelf waters. This fish generally migrates to the Gulf of Mexico in the late fall and
moves into the bays and estuaries in the spring. Estuarine wetlands are important to larval
and juvenile red drum; while adult red drum use estuaries, they tend to spend more time
offshore as they age (GMFMC 1998). Until the age of three to four years, young red drum
inhabit mainly estuaries, river mouths, and shallow coastal waters. After this age they tend to
leave the protection of estuaries, moving into open coastal waters. They occur both as
solitary individuals and in schools. They have been known to school with other species,
including black drum and tarpon. Spawning occurs from September through November over
deeper waters protected from currents, such as the mouths of bays and inlets, and on the Gulf of
Mexico side of barrier islands. They can tolerate temperatures ranging from 39 to 93 degrees
Fahrenheit (°F; 4 to 34 degrees Celsius), and can also tolerate a wide range of salinity. Although
they have been known to travel into fresh waters as well as into very high saline waters (up to 50
parts per thousand [ppt]), adults usually stay in saltwater of 30 to 35 ppt.
F-7 EFH Assessment

REEF FISH (SNAPPER AND GROUPER)

Reef fish is a term used by fishery managers to describe several species of fish that tend to
live on and are frequently caught on reefs or hard bottoms. Reef fish species are jointly managed
by state and federal agencies for the Atlantic Ocean and the Gulf of Mexico. The gray snapper
(Lutjanus griseus), lane snapper (Lutjanus synagris), and the Goliath grouper (Epinephelus
itajara), which have EFH that may be affected by the Project, are popular recreational and
economically important fish species throughout the Gulf of Mexico. Estuarine emergent marsh
habitat, mangrove marsh habitat, sand and shell bottom habitat, and mud/soft bottom habitat in the
Project area could potentially function as EFH for these three species.
Juvenile gray snapper commonly occur inshore in tidal creeks, mangroves, and seagrass
beds; adults generally occur in nearshore area consisting of coral habitat or rocky reefs to a depth
of about 300 feet (NOAA Fisheries 2015a). Inshore, the species is found over smooth bottoms,
usually near pilings, seagrass meadows, and mangrove thickets. The lifespan of a gray snapper
may be up to 21 years, and individuals may reach a length of 35 inches and weight of 25 pounds.
Young gray snapper tend to eat shrimp and other crustaceans, while adults prefer fishes, crabs, or
shrimps, and may feed on seagrass flats in the late afternoon or at night.
Juvenile lane snapper are found inshore over seagrass beds or shallow reefs. Adults are
typically found offshore and are most common off South Florida. Adult lane snappers live in a
variety of habitats, but are most commonly observed over reefs and vegetated sandy bottoms in
shallow inshore waters. This species has also been reported in offshore waters to depths of 1,300
feet (400 meters). Once established, adult snappers remain in the same area for their entire lives.
Lane snappers also occur in seagrass beds associated with shrimping areas. Juveniles live in
protected inshore areas (NOAA Fisheries 2015a).
Goliath grouper occur in shallow, inshore waters to depths of 150 feet (46 meters). They
prefer areas with bottoms of rock, coral, and/or mud. Patterned juveniles inhabit mangroves and
brackish estuaries, especially near oyster bars. The Goliath grouper is notable as one of the few
groupers found in brackish waters. Spawning, which occurs during the months of July, August,
and September throughout the species’ range, is strongly influenced by the lunar cycle (NOAA
Fisheries 2015a).
SHRIMP
Brown and white shrimp occur over soft, sedimentary bottoms throughout the northern
Gulf of Mexico. Both species have similar life history stages, are estuarine-dependent, and vary
seasonally in abundance. Young shrimp move into estuaries and spend several months feeding
before returning to the Gulf of Mexico to spawn. EFH for shrimp consists of Gulf of Mexico
waters and substrates extending from estuarine waters out to depths of 100 fathoms.
COASTAL MIGRATORY PELAGICS

The Coastal Migratory species range in coastal and continental shelf waters from the
northeastern United States through the Gulf of Mexico. Coastal pelagic fish move from one area
to another foraging on whatever prey is most abundant and available. Coastal pelagic fish feed
throughout the water column on herrings, squid, shrimp, and other fish and crustaceans. Estuaries
are considered EFH for coastal migratory species because major prey species of coastal pelagic
EFH Assessment F-8

fishes are estuarine-dependent. Thus, coastal pelagic species are indirectly estuarine-dependent
and may be affected by degradation of estuarine habitat quality (GMFMC 2004).
HIGHLY MIGRATORY SPECIES

EFH for HMS is described in separate FMPs, including the Final Fishery Management
Plan for Atlantic Tuna, Swordfish, and Sharks (NOAA Fisheries 1999a) and Amendment 1 to the
Atlantic Billfish Fishery Management Plan (NOAA Fisheries 1999b). Because these species cross
domestic and international boundaries, NOAA Fisheries’ HMS Management Division is
responsible for managing them under the MSA. In cooperation with an advisory panel, NOAA
Fisheries develops and implements FMPs for these species, taking into account all domestic and
international requirements under the Atlantic Tunas Convention Act, the Marine Mammal
Protection Act, the ESA, and the Migratory Bird Treaty Act (NOAA Fisheries 2015b).
For highly mobile pelagic species such as sharks, defining EFH is difficult. Their
distributions are usually not correlated with the areas or features commonly considered as fish
habitat and for which parameters such as bottom sediment type or vegetative density (e.g., seagrass
beds or estuarine subtidal rocky bottoms) can be described. These species most often associate
with physiographic structures of the water column (features including oceanic fronts, river plumes,
current boundaries, shelf edges, sea mounts, and temperature discontinuities, and the interactions
of these); it is these features that must be characterized as habitat for the pelagic life stages of these
species. Distributions of juveniles, adults, and especially early life stages (neonates for sharks)
may be constrained by tolerance of temperature, salinity, or oxygen levels. These physicochemical
properties may be used to define the boundaries of essential habitat in a broad sense. However,
even when these parameters and tolerances are well understood and can be used to define the limits
of a habitat, the distribution of these characteristics is not fixed in space or time, but varies over
seasons and years (NOAA Fisheries 2003).
4.0 POTENTIAL PROJECT IMPACTS

Construction, operation, and decommissioning of the Project could result in impacts on the
biological, chemical, or physical properties of the environment (all water column, habitat, and
substrate within BSC) that support the designated EFH species listed in section 3.0 of this EFH
assessment (see table F-4). The following sections address the potential impacts on EFH, and the
species supported by EFH, that could occur as a result of construction of the LNG facility and
loading berth (including dredging and pile driving), storage tank hydrostatic testing, stormwater
discharge, LNG carrier ballast exchange and uptake and discharge of cooling water while at the
Project site, minor spills, and maintenance dredging within the Project turning basin.
F-9 EFH Assessment

TABLE F-4
Summary of the Proposed Activities that May Affect Essential Fish Habitat
Proposed Action Component Effect on Water Column EFH Effect on Benthic EFH
Wetlands loss on facility site • Minor water quality effects – not • No expected effect
significant
Construction/placement of LNG carrier • Short-term increase in turbidity - not • Displacement of sediments - not
berth components significant with BMPs/controls significant
• Short-term increase in noise • Long-term effect on benthic
– not significant with mitigation community in dredged area
• Secondary effect on prey species -
not significant
Storage tank(s) hydrostatic testing • Temporary increase in turbidity - not • Displacement of sediments - not
significant significant
• Permanent loss (entrainment) of • Secondary effect on prey species -
ichthyoplankton - not significant not significant
Stormwater discharge • Impact on water quality - not • Effect on sediment quality - not
significant significant
LNG carrier ballast water discharge • Short-term water quality changes – • No expected effect
not significant
LNG carrier cooling water intake • Permanent loss (entrainment) of • No expected effect
ichthyoplankton – not significant
Terminal lighting • May attract ichthyoplankton – not • No expected effect
significant
Accidental releases • Minor release – no expected effect • Minor release – no expected effect
• Unlikely catastrophic release – • Unlikely catastrophic release
freezing of tissue, localized and – no expected effect
significant short-term effects
CONSTRUCTION
Construction of the Project may cause the following effects on managed species or EFH:
• loss of wetlands, bottom habitat, and benthic community individuals;

• resuspension of sediments during dredging and other substrate-disturbing
activities, resulting in increased turbidities, suspended sediment, and subsequent
respiratory effects and/or reduced feeding/predation efficiencies;
• smothering, crushing, and/or injury of localized benthic organisms from during
dredging;
• toxic effects from hydrocarbon spills during construction;
• entrainment of plankton during tank hydrostatic testing;
• noise-related effects resulting from dredging and pile driving during construction;
• shallow water habitat reduction and modification; and
• loss of tidal and subtidal habitat.
Loss of Estuarine Open Water and Vegetated Habitat

EFH can be affected by land-based projects that remove critical early life stage-dependent
habitat, including both emergent tidal and brackish marsh, typically (but not always) dominated
by smooth cordgrass (Spartina alterniflora) and black needlerush (Juncus roemerianus),
EFH Assessment F-10

respectively. These habitats may be affected both by direct destruction and degradation of water
quality, or other factors such as hydrologic modification. Elimination or degradation of wetlands
not immediately adjacent to EFH also may diminish the quality and productiveness of estuaries.
The precise relationship between fishery production and habitats is undetermined.

Similarly, the degree to which habitat alteration can affect fishery production is also unknown, but
is thought to be substantial. Turner and Boesch (1987) assembled and examined evidence of the
relationship between the extent of wetland habitats and the yield of fishery species that depend on
coastal bays and estuaries. Their evidence showed a correlation between fishery stock losses after
wetland losses and fishery stock gains following wetland gains. While most of the studies were
related to shrimp production, it is expected that other estuarine fisheries will also follow this trend.
During construction there would be direct adverse impacts on estuarine open water,
unvegetated tidal flats, and estuarine wetlands from facility construction and berth/turning basin
development along the shoreline of the BSC (see table F-5 below, and section 4.4.2 of the EIS for
more details). The initial Project footprint also encompassed a small area of mangrove marsh,
however Annova has modified the site footprint to avoid direct impact on mangrove marsh,
therefore it is not addressed in this EFA assessment.
TABLE F-5
Temporary Impacts to and Permanent Loss of Tidal and Subtidal and Wetland EFH
Project Site Impacts
Cowardin Wetland Temporary Permanent Impact
Wetland Type Classification Impacts (Acres) (Acres)
Open Water and Non-Vegetated Tidal Flat
Estuarine open water within Project site a/ E10W 2.0 1.0
Unvegetated tidal flat E2US3 2.7 1.0
Vegetated Wetlands
Estuarine emergent marsh E2EM1 53.0 50.8
Total 57.7 52.8
a/ Does not include 59 acres within the BSC that would be impacted by dredging for the turning basin.
Estuarine Open Waters and Tidal Flats

The Texas Commission on Environmental Quality (TCEQ) designates the BSC (which is
part of Texas stream segment 2494) as a warmwater fishery that supports aquatic life, recreational
uses, and general use (Texas Administrative Code Title 30, Part 1, Chapter 307). Construction of
the marine facilities would permanently alter approximately 5.5 acres of currently open water in
the BSC. Direct impacts on fish resources would be limited to the BSC. No impacts on fish in
South Bay or Bahia Grande are expected due to limited tidal influx to these resources from the
BSC and uncontaminated sediment present in the BSC (see below).
Open waters and tidal mudflats of the BSC in the Project vicinity support numerous
invertebrate species that are important prey for managed fishes. Construction would temporarily
affect 4.7 acres of estuarine open water and tidal flat, and operation of the Project would
permanently convert 2.0 acres of open water and tidal flat EFH to land or built infrastructure.
Specific impacts are discussed in section 4.1.2 of this EFH assessment.
F-11 EFH Assessment

Estuarine Emergent Marsh (E2EM1)

Six areas of emergent wetlands are located at higher elevations along the BSC within the
site. These wetlands are characterized as high salt marsh and are dominated by halophytic plant
species, including glassworts (Salicornia depressa and S. bigelovii), saltwort, cenicilla
(Sesuvium portulacastrum), sea purslane (S. verrucosum), sea blite, with seashore dropseed,
shoregrass, sea lavender (Limonium nashii), and seaside heliotrope (Heliotropium
curvassivicum) common above the high tide line. These wetlands are located within slight
depressions that slope downward from the bank of the BSC and are bounded by a loma to the
south. The depressions collect water from runoff and periodic washover from ship wakes, and
may also be influenced by very high tides and a tidal water table. The estuarine emergent
wetlands in the study area are considered waters of the United States because they abut the BSC.
Construction would temporarily affect 53.0 acres of estuarine emergent marsh, of which 50.8 acres
would be permanently converted to non-wetland cover type during Project operation. However,
these areas of estuarine emergent marsh are unlikely to be occupied by managed fish during most
of the year because they are not permanently connected to waters of the BSC.
Increased Turbidities and Sedimentation

The marine facilities would be developed along the BSC at the Project site through a
combination of excavation and dredging. Excavation for the marine berth would occur in two
stages: a terrestrial excavation followed by a marine excavation to remove the remaining material
below the water surface. A natural earthen berm would be retained to provide a physical barrier
between the BSC and construction activities. This construction method would allow most of the
excavation and installation of pilings to occur without direct contact with waters of the BSC, which
would help to minimize impacts on fisheries. After removal of the earthen berm, any riprap and
sheet piling installed along the shoreline would allow terrestrial habitat within the created berth to
convert to benthic habitat. In-water construction would include dredging the balance of the berth
and LNG carrier turning basin.
Impacts expected from dredging activities in the BSC during construction and maintenance
dredging include increased suspension of sediment, potentially affecting water quality and habitat,
as well as removal or displacement of bottom-dwelling species. The movement and positioning
of floating construction equipment and the marking/identification of work areas and emergent/
submergent obstructions would be performed in accordance with BND requirements. Annova is
proposing to place dredge material in the adjacent DMPA 5A on BND property. On July 21, 2016,
Annova submitted a request to the U.S. Army Corps of Engineers (COE) for a Department of the
Army permit under Section 10/404 permit for dredging and marine construction activities.
As described in section 2 of the EIS, Annova proposes to place dredged material in the Port
of Brownsville DMPA 5A, located immediately west of and adjacent to the Project site. Based on
a preliminary investigation, use of DMPA 5A would require raising the perimeter levees and
possible refurbishment of the outlet. During transport of dredged material, a wye valve would
evenly distribute the dredged material into internal partitions. The current configuration of DMPA
5A uses a series of internal berms (dewatering lanes) to guide water through the DMPA from the
discharge point to the final outfall point, at a rate that allows the fine particles to settle out, with
final discharge through the existing drop outfall structure directly to the BSC. Annova anticipates
raising the levee heights using existing material in the DMPA and re-profiling the dewatering lanes
EFH Assessment F-12

prior to the start of dredging operations to allow for appropriate residence time, such that the
discharge would be limited to constrain total suspended solids (TSS) to a maximum of 300
milligrams per liter (mg/L). Annova intends to perform column settling tests early in detailed
engineering to confirm the settling characteristics of the dredged material to ensure efficient
function of the DMPA. This distribution of the deposited material during dredging would ensure
that the rate of particle settling upon discharge and the residence time can be appropriately
managed without affecting the dredging production rate. The effluent outfall at the drop-outlet
structure would be monitored for excessive turbidity and erosion issues.
During dredging activities, direct impacts on EFH may occur from disturbing substrate and
suspension of sediments. Dredging is expected to cause major localized mortality and
displacement of benthic invertebrates and minor displacement of fish in the dredged area. Impacts
of dredging on fish and invertebrates are a function of suspended sediment concentration, duration
of exposure, species, and life stage (Newcombe and Jensen 1996). Dredging would suspend
sediments in the water column for a period of time depending on the size of the sediment particles.
Coarser sediments would fall out and resettle quickly (within hours), while finer sediments could
remain suspended longer (up to days or weeks). Although the cutter of the dredge suctions in most
of the suspended fine-grained sediments, the increase in turbidity would have a localized effect of
reduced light penetration and a corresponding reduction in the primary production of aquatic
plants, algae, and phytoplankton. As a result, there may also be lower dissolved oxygen
concentrations, causing a displacement of motile organisms or stress and reduction in numbers of
sessile benthic organisms (LUMCON 2016; COE 2012). In the absence of best management
practices (BMPs) to mitigate levels of suspended solids, turbidity may exceed water quality criteria
up to about 2.5 miles (4,000 meters) downstream from the dredge and across the width of the BSC.
A small fraction of the total habitat in the BSC would be affected by construction and maintenance
dredging of the marine berth.
Dredging activities would result in increased turbidity in the BSC, which could have
localized effects. These localized effects may include reduced light penetration and a
a result, a short-term reduction in dissolved oxygen concentrations in the BSC may occur, resulting
in temporary displacement of motile organisms or stress and reduction in numbers of sessile
benthic organisms (LUMCON 2016). Increases in turbidity may result in short-term impacts on
these organisms (see section 4.6 of the EIS). The results of field surveys indicate that no vegetation
occurs in the open water in the BSC within the Project site (see figure 4.3.2-3 in the EIS). Known
seagrass beds are identified in the BCS at Port Isabel and the entrance to South Bay over 3.1 miles
(5,000 meters) downstream; therefore, increases in turbidity would not likely extend into any
important seagrass nursery habitats.
Annova performed turbidity plume modeling using the COE’s DREDGE model, plus a
“far-field” distribution model of suspended sediment (Black & Veatch 2016). The results were
predicted using a maximum velocity of current in the BSC at 0.154 meter/second (0.5 feet/second).
To assess the impacts on the Bahia Grande, the lateral movement of particles predicted is more
pertinent due to the location of the channel. The model predicted TSS concentration of 4 to 6
mg/L above ambient within the greatest lateral extent of the plume, 328 feet (100 meters) either
side of the plume centerline, at the surface of the BSC (Black & Veatch 2016). The outgoing tide
would transport the suspended clay particles downstream of the shallow (-3.25 to [proposed] -9
F-13 EFH Assessment

feet mean sea level) Bahia Grande Pilot Channel entrance. This, combined with the tidal flow
from the Bahia Grande during an outgoing tide, would prevent particle transport into the Bahia
Grande. Particle transport would occur during an incoming tide, with clay particles moving
upstream from the Bahia Grande. Effects to the Bahia Grande would likely be greater during an
incoming tide with elevated TSS concentrations of 4 to 6 mg/L at the periphery of the plume 328
feet (100 meters) from the cutterhead, and would result in a minor impact on water quality within
proximal portions of the Bahia Grande. Similarly, although not directly modeled, particle transport
during a slack tide would be limited due to the lack of water movement, which would restrict
particle transport from the dredging area. As a result, a slack tide would also limit impacts within
the Bahia Grande.
Although benthic invertebrates would be entrained, crushed, or buried by the dredging

operation, impacts on juvenile and adult fish in the channel would be minimal because mobile
organisms are expected to move away from the area of increased activity and noise during dredging
(Nightingale and Simenstad 2001). Increased turbidities could be fatal to larval or post-larval
shrimp if dredging occurs during peak abundance in early spring or summer; however, shrimp
densities near the Project site are expected to be low.
Increased turbidities from bottom-disturbing activities could temporarily affect predation

efficiency for local fish. Extended periods of elevated turbidities have been shown to reduce
feeding rates by up to 20 percent and to reduce the efficiency of the foraging process (Utne-Palm
2002; Gardner 1981). However, most species of fish are both predator and prey, making it difficult
to predict the net effect of reduced predation on a given species. During periods of increased
turbidity, it is expected that adult and juvenile fish and crustaceans in the area would relocate to
other similar habitats that are less turbid. The increased turbidities would limit feeding within the
area of construction, but prey would still be accessible in nearby unaffected areas. Early life stages
are most likely to be directly affected by a temporary increase in turbidity and a potential decrease
in dissolved oxygen concentrations (Robertson et al. 2006). Because these life stages are more
sensitive to such stresses and are unable to emigrate from the affected area, they are more
susceptible to impacts than juveniles and adults. However, short-term elevated turbidities are not
likely to cause chronic adverse effects. Section 4.3 of the EIS assesses the downstream movement
of particles during dredging activities in detail.
Increases in turbidity can also affect the level of dissolved oxygen in the water. When
dredges disturb bottom sediments, the increase in turbidity is caused by both particles and
microorganisms, which may respond to the release of nutrients from the disturbed sediment by
increasing the rate of reproduction. Microorganism blooms can be followed by population crashes,
which lead to localized depletion of dissolved oxygen. Other changes in turbidity are more
transient, such as those that occur when storms stir up sediment in a shallow waterbody. Because
light is not transmitted as easily in turbid water, phytoplankton may be less able to photosynthesize
and produce oxygen that would restore the desired dissolved oxygen concentration.
The potential for direct and indirect adverse impacts on fisheries from substrate disruption
(i.e., turbidity and sedimentation) within the Project area would likely differ from species to
species, depending on life history, habitat use, distribution, and abundance. Sessile life stages,
such as demersal eggs, would likely be buried or destroyed during dredging. However, effects on
the juvenile and adult life stages of both pelagic and demersal species would be limited to
EFH Assessment F-14

displacement during the 8 months of dredging activities. Individuals would be expected to move
slightly upstream or downstream of the construction area to forage or spawn.
During Project operation, periodic maintenance dredging would maintain depth in the
turning basin. Impacts from this activity would be minimal because the maintenance dredging
would mirror the maintenance dredging of the BSC currently conducted by the COE. The regular
tidal flux and periodic inflow of high rainfall result in a system that continually reflects short-term,
sporadic changes to in situ physicochemical conditions. Therefore, these types of systems tend to
support species that are tolerant of changing physiochemical conditions and are not conducive to
supporting intolerant or sensitive biota. Maintenance dredging may magnify these conditions but
would not likely promote a less stable environment for species that exist either permanently or
temporarily in the BSC. As described for dredging during construction, maintenance dredging
would destroy sessile life stages and displace mobile life stages within the immediate area. Despite
the severe effects within the localized area, no population-level effects are expected because the
construction area represents a small fraction of marginal habitat within the industrialized BSC.
Notwithstanding the potential harm to some individual organisms, no significant impacts on
managed species of finfish or shellfish populations are anticipated from the maintenance dredging
and placement operations.
The need for regular maintenance dredging indicates that the system is dynamic. This
status is further accentuated by regular tidal flux and periodic inflow during periods of high
rainfall. All of these conditions result in a system that continually reflects short- term, sporadic
changes to in situ physicochemical conditions. These types of systems tend to support species that
are tolerant of disturbance. Maintenance dredging may magnify these conditions but would not
likely promote a less stable environment for taxa that exist either permanently or temporarily in
the BSC. In addition, if maintenance dredging for the proposed Project and the BSC are conducted
simultaneously, the likelihood for adverse effects from these actions to fish and invertebrates
within the BSC is minimal. Importantly, the BSC has not been shown to provide unique nursery
habitat for the various adult fish and invertebrate species that occur there.
Resuspension of Contaminated Sediments

As discussed in section 4.3 of the EIS, no contaminated sediments are known to occur in
the BSC. In 2012, the TCEQ sampled and analyzed sediment from the BSC for metals (e.g.,
mercury, zinc, silver, nickel, lead, copper, chromium, arsenic, and cadmium); all sample results
were considered to be of “no concern” (TCEQ 2012). Sediment sampling was also conducted
in 2000 in response to a nearby spill of furfural, an organic compound derived from
agricultural byproducts, into storm drains in Brownsville, Texas. Although the BSC was one
of three possible impact zones, subsequent sediment sampling showed no evidence of furfural
contamination (NOAA 2000; FWS 2000). Based on the information above and in section 4.3 of
the EIS, dredging is not expected to release any contaminants from sediments in the BSC; however,
Annova may conduct additional sediment testing specific to the Project area if warranted or
requested by the COE or applicable agencies.
Loss, Reduction, or Change of the Benthic Assemblage

Most benthic organisms occur within the top 6 inches (15 centimeters) of the sediment
surface. Therefore, it is expected that removal of sediment and burial from deposition of sediments
F-15 EFH Assessment

would result in some loss of these organisms. Generally, disturbance-related impacts on benthos
are temporary and reversible because species from adjacent undisturbed areas recolonize the
affected area.
Dredging would also remove the soft-bottom habitat of the BSC within the footprint of the
dredged area. Disturbance of substrate in the BSC during construction may result in adverse
effects to benthic and pelagic organisms that are prey of managed species. Benthic organisms may
be crushed, buried, displaced, or injured during construction. Pelagic organisms may experience
stress related to increased turbidity and water movement, causing them to relocate temporarily.
Some demersal (bottom-dwelling) species such as mollusks, crustaceans, and demersal

shrimp (if present) may be entrained during dredging activities. Larger, more mobile, demersal
species (e.g., blue crab) may be temporarily displaced (Nightingale and Simenstad 2001).
Although dredging activities would have an effect on species occupying the soft-bottom habitat in
the Project area, effects on marine fisheries and the habitat supporting various species are expected
to be local, minimal, and temporary. Habitat use by these species is expected to return to pre-
construction conditions following dredging operations.
Direct impacts from dredging activities on benthic macroinvertebrates may include

localized disruption, removal, turnover, and crushing. Additionally, dredging would result in
deposition of sediment in the immediate vicinity of the activities, which may cause direct mortality
via burial. As most benthic infauna live on or within the upper 6 inches of the sediment surface,
it is expected that removal of sediment and burial from settling of sediments resulting from
increased turbidity would result in some loss of these organisms. Germano et al. (1994) found that
benthic communities recover to an equilibrium community within approximately 6 months to 1
year after a physical disturbance. Other studies indicate recovery to this stage in 2 years or less
(Murray and Saffert 1999; Rhoads et al. 1978). Many physical and biological factors affect the
recolonization process, with one of these being the texture of the disturbed sediment. Any change
in the texture of the material after the activity is completed may result in changes in the community
that was present before activities took place. Additionally, overturned, deeper sediments may be
hypoxic, resulting in longer periods to re-establishment of former communities. Disturbance-
related impacts on benthos from the proposed Project would be long term but localized within the
dredging footprint. Benthic species are likely to recolonize the affected area, but would be
disturbed by maintenance dredging at 2-year intervals. As such, long-term localized impacts on
benthic marine species are expected.
The potential for direct and indirect adverse impacts on fisheries from substrate disruption
within the Project area would likely differ from species to species, depending on life history,
habitat use, distribution, and abundance. However, short-term impacts on older life-stages
(juvenile and adult) of both pelagic and demersal fish would be limited to temporary displacement
during dredging activities.
Germano et al. (1994) found that benthic communities recovered to an equilibrium (Stage
III) community in approximately 6 months to 1 year after a physical disturbance. Other studies
indicate recovery to this stage in 2 years or less (Murray and Saffert 1999; Rhoads et al. 1978).
Many physical and biological factors affect the recolonization process, with one being the texture
of the disturbed sediment. Any change in the texture of the material after the activity is completed
EFH Assessment F-16

may result in changes to the community that was present before the activities took place.
Additionally, overturned, deeper sediments may be hypoxic, resulting in longer periods of re-
establishment of former communities. As noted above, a resident benthic community is generally
quite resilient and typically recovers relatively quickly from disturbances. Disturbance-related
impacts on benthos from the proposed Project would be long term but localized within the dredging
footprint. Benthic species are likely to recolonize the affected area, but would be disturbed by
maintenance dredging at 2-year intervals. As such, the Project is expected to result in long-term
localized impacts on benthic marine species within the dredge area footprint.
The potential for direct and indirect adverse impacts from substrate disturbance during
construction on EFH designated in the Project area would likely differ from species to species,
depending on life history and habitat use (demersal vs. pelagic). However, it is anticipated that
short-term impacts on the juvenile and adult life- stages of both pelagic and demersal fish species
would be limited to temporary displacement during initial installation of Project components.
Entrainment and Impingement During Hydrostatic Testing

During construction, Annova would use water for hydrostatic testing of pipes and LNG
storage tanks, drinking water, and dust control. The LNG storage tanks would be hydrostatically
tested in accordance with American Petroleum Institute standards. Terminal piping would be
tested using hydrostatic (piping carrying natural gas) or pneumatic (cryogenic piping carrying
LNG) testing methods as described in section 2.6.1.5 of the EIS. Hydrostatic test water would be
discharged to surface waters in compliance with a permit issued by the Railroad Commission of
Texas. LNG storage tanks would be hydrostatically tested with surface water to ensure their
integrity. See section 2.6.3 of the EIS for discussion of the hydrostatic testing process.
Water withdrawal for hydrostatic testing could entrain fish eggs and juvenile fish near the
intake structures in the BSC. In accordance with its Project-specific Procedures, Annova would
screen intake hoses to limit the entrainment of larvae and pre-juvenile fish and invertebrates during
water withdrawal.
Intake structures located within the BSC would be fitted with appropriate screens to limit
entrainment of organisms, in accordance with withdrawal permits. Intake structures with rates of
1,500 gallons per minute (3.34 cubic feet per second) would be placed at the lowest possible
elevation to reduce the impingement of organisms and debris on intake screens. The intake of
surface water for hydrostatic testing of the LNG storage tanks would be in compliance with the
Project’s temporary TCEQ water rights permit. The hydrostatic test water for the LNG facility
piping would be supplied from the potable water line, with no added treatment chemicals,
corrosion inhibitors, or biocides. Upon completion of hydrostatic testing of the first LNG storage
tank, the water would be transferred to the second storage tank for reuse.
Annova would not use biocides, detergents, or additives in the hydrostatic test water. Prior
to discharge, in accordance with the EPA’s Hydrostatic Test Water Discharge Permit and the
Railroad Commission of Texas’ permit requirements, the water would be tested for total
suspended solids, oil and grease, and pH, and treated (if test results indicate that the water would
not meet requirements). Hydrostatic test water would first be discharged into a stormwater pond
using energy-dissipation devices to minimize erosion and scouring, and from there discharged into
the BSC via an overflow structure. The rate of discharge is expected to be approximately 1.8
F-17 EFH Assessment

million gallons per day. Discharge of hydrostatic test water may cause localized, short-term
turbidity in the BSC; however, potential impacts on aquatic resources from the discharge of
hydrostatic test water would be localized, temporary, and negligible and would be minimized
through the use of energy-dissipating devices installed at water discharge points. The BSC may
experience localized, short-term turbidity from the discharge of hydrostatic test water, as
previously described for marine berth dredging. No long-term impacts on water quality are
anticipated due to these discharges.
The withdrawal of water for hydrostatic testing may result in the permanent loss of some
larval fish and invertebrates that occur within the BSC. The level of impact would depend on the
season in which water is withdrawn. No information was found regarding larval fish densities in
the BSC. However, the BSC is not considered EFH for spawning adults or eggs, so abundance of
early life stages is assumed to be low. Moreover, annual fecundity of the lane snapper ranges from
347,000 to 995,000 eggs (Rodriguez-Pino 1962) and from 220,000 to 60,000,000 eggs for the red
snapper (Gallaway et al. 2009). Considering the fecundity potential for managed species in the
context of natural expected mortality, the absence of EFH for eggs in the BSC, and the limited
volume and duration of water withdrawal, entrainment of early life stages of managed species
during hydrostatic testing would have a negligible effect on fisheries in the Project area.
Noise Effects on Fish

Elevated noise levels associated with pile-driving activities during construction of the LNG
carrier berth and basin can affect fish and EFH. Marine fish can be affected by noise both
physiologically and behaviorally. The potential effects of exposure to continuous sound on marine
fish include temporary threshold shift, physical damage to the ear region, physiological stress
responses, and behavioral responses such as startle response, alarm response, avoidance, and
potential lack of response due to masking of acoustic cues (Hedges 2011). Much of the research
on how noise affects marine species involves studies of the physiological effects of impact pile
driving on fish due to changes in water pressure. Fish with swim bladders are more vulnerable to
such pressure changes, which can cause capillaries to rupture or the swim bladder to rapidly expand
and contract 1 (Caltrans 2001). In marine mammals, temporary loss of hearing (temporary
threshold shift or permanent threshold shift) may occur as a result of exposure to noise from impact
pile driving; it has long been assumed that similar effects occur in fish (Popper and Hastings 2009;
Popper et al. 2005). However, when caged juvenile coho salmon (Oncorhynchus kisutch) were
placed as close as 6.6 feet (2 meters) to steel piles being impacted, no mortality was observed
(Ruggerone et al. 2008). A recent review by leading experts on auditory impacts to fishes and
invertebrates suggests that attempts to evaluate effects of pile driving and other impulsive sounds
on fish are not well-supported by empirical evidence. Sound thresholds applied to fish have been
derived primarily from studies on marine mammals or in studies conducted within enclosed tanks
that do not accurately reflect open water settings. Moreover, virtually all studies of effects of
underwater sound focus on sound pressure, whereas particle motion is thought to be the more
relevant mechanism for injury to fishes. For these reasons, potential effects of pile driving on
fishes cannot be accurately predicted (Hawkins and Popper 2016). It is assumed that most fish
1
Hitting a steel pile with a large hammer produces sound that causes water pressure changes that impact fish. Sudden changes in water pressure
can cause gases such as oxygen to come out of fish blood faster than normal, leading to decompression sickness, much like the bends that divers
experience when they rise to the surface too quickly. Pressure changes also affect the fish swim bladder, an internal, air-filled sac that helps the fish
maintain weightlessness at different water depths. Alternating pressure changes cause the swim bladder to quickly expand and contract, which
causes bruising and damage to neighboring organs and can rupture the swim bladder itself (USDOE 2012).
EFH Assessment F-18

would detect and react to impulsive sounds of pile driving in a species-specific way, either by
startling, leaving the area, or accommodating to the sound and continuing their normal behavior.
Nevertheless, current practice is to estimate the reactions of fish to pulsive noise using certain
assumptions. Such estimates are provided in section 4.1.6.3 below.
Effects of construction noise (pile driving) on fish would be either temporary or

intermittent, and, therefore, would not significantly impact the fish at a population level.
Individual fish may relocate to adjacent areas within the BSC where spawning and foraging habitat
is available. Pile-driving noise would not adversely affect EFH.
Fish react to underwater noise from vessels and move out of the way, move to deeper
depths, or change their schooling behavior. The perceived noise levels at which fish react are not
known and seem to be somewhat variable, depending on circumstances and species of fish. To
assess the potential effects of underwater noise associated with the Project, noise in relation to
continuous noises routinely produced by other projects, activities such as shipping and fishing, and
pulsive noises produced by seismic exploration were evaluated (see below).
Continuous Noise
Long-term continuous noise associated with the Project would be generated at the loading
terminal. Noise levels associated with the loading terminal would be relatively low and unlikely
to have any significant adverse effect on EFH in the area. Peak spectral levels for individual
commercial ships are in the frequency band of 10 to 50 hertz (Hz) and range from 195 decibels in
reference to 1 microPascal2 (dB re µPa2)/Hz at 1 meter for fast-moving (greater than 20 knots)
supertankers to 140 dB re µPa2/Hz at 1 meter for small fishing vessels (NRC 2003). Another
activity expected to produce short periods of continuous noise is LNG carrier maneuvering at the
terminal. Although this activity would be louder, it would be less than the noise levels associated
with large ships at cruising speed. Generally, studies have used approximately 190 dB as the
expected noise level for an LNG carrier’s thrusters (LGL 2006). An LNG carrier maneuvering
using thrusters could produce short periods of louder noise (e.g., for 10 to 30 minutes while
arriving and again while leaving the terminal, up to about 125 times per year). On average, thruster
noises would be heard for about 30 hours per year. Even in the unlikely event that these two
activities caused disturbance to marine fish, the effects would be short-term.
Pulsive Sounds
The pulsive sounds from in-water pile driving expected during construction would be much
less intense than the pulses from the air guns used in Gulf of Mexico offshore seismic surveys by
the oil and gas industry. Such surveys routinely have source levels of 250 dB re 1 μPa at 1 meter.
The available information suggests that seismic exploration has minor to moderate impacts on
fisheries resources and EFH (BOEM 2014). Therefore, it is unlikely that the lower levels of pulsed
noise from pile-driving construction activities would have permanent effects on fish populations
in the area.
Approach for Estimating Pile-Driving Noise Levels

As described above, recent evaluation of methods used to estimate effects of pulsive noise
on fish concludes that standard practices are not supported by empirical evidence or biological
mechanisms. Nevertheless, current practice is to estimate effects on fishes using methods
F-19 EFH Assessment

developed in a cooperative effort between several federal and state transportation and resource
agencies along the West Coast of the United States that resulted in the establishment of interim
criteria for identifying the onset of physical injury to fish exposed to underwater sounds generated
by impact pile driving (Stadler and Woodbury 2009). NOAA Fisheries, in its administration of
the ESA and the EFH provisions of the MSA, currently uses these criteria to assess potential
impacts on the fishery resources under its purview resulting from pile driving performed in or near
aquatic environments. The new criteria use two metrics: the sound pressure level (SPL) and the
sound exposure level (SEL). A potential onset of physical injury is determined if either the peak
SPL exceeds 206 dB (re: 1 µPa) or the SEL, accumulated over all pile strikes generally occurring
within a single day, exceeds 187 dB (re: 1 µPa2/sec) for fish 2 grams or larger, or 183 dB (re: 1
µPa2/sec) for smaller fish (Stadler and Woodbury 2009).
The assessment used for this analysis was based on Stadler and Woodbury (2009). They
suggest a multi-step process that sequentially estimates: (1) the expected peak SPL and single-
strike SEL from the project; (2) the cumulative SEL; (3) the distance from the pile driver where
the peak SPL and cumulative SEL drop below the threshold values; and (4) the area that is
ensonified above threshold levels. The following describes the step-wise approach from Stadler
and Woodbury (2009):
Step 1. Estimate the expected peak SPL and the mean single-strike SEL, at a known
distance from the pile, from existing hydroacoustic monitoring data for piles of similar
size, and, if possible, driven into the same type of substrate.
Step 2. Estimate the cumulative SEL, at a known distance, using the following equation:
Cumulative SEL(dB) = 10Log10((Single-strike SE* N)/1 μPa2•sec)

or
Cumulative SEL(dB) = Single-strike SEL + 10Log10 (N)
where:
single-strike SEL = the mean sound exposure, in μPa2/sec, for a single pile strike and
N = the number of pile strikes
Step 3. Estimate the distance from the pile driver where the peak SPL and cumulative
SEL drop below threshold values. NOAA Fisheries uses the following equation to
estimate this distance:
TL(dB) = CLog10(R1/R0)
where:
TL = transmission loss, in dB, required to reach the threshold level (calculated by
subtracting the threshold level from the known sound level (peak SPL or cumulative
SEL) at R0
C = transmission loss constant
R1 = distance from pile driver to the threshold level
R0 = distance from pile driver to the known sound level
EFH Assessment F-20

The rate of transmission (or propagation) loss can vary widely from site to site, requiring
site-specific information to accurately estimate (Stadler and Woodbury 2009). However, in
most cases, site-specific data are not available, and NOAA Fisheries assumes a transmission loss
constant of 15. Because cumulative SEL increases with increasing numbers of pile strikes, the
distance from the pile driver to the threshold level also increases. If the number of pile strikes
is high, this distance can be unreasonably large. NOAA Fisheries recognizes that a single-strike
SEL below a certain level would not contribute to the overall cumulative SEL because it has
limited, if any, effect on a fish. The single-strike SEL that has no effect is referred to as
“effective quiet,” but there are no data for estimating the SEL of effective quiet. Based on this
uncertainty, NOAA Fisheries has adopted a conservative SEL for effective quiet of 150 dB.
The distance from the pile driver at which a single-strike SEL drops to 150 dB is the maximum
distance from a pile at which fish can be injured, regardless of how many times the pile is
struck. While the distance does not increase, the cumulative SEL within this distance does
increase, thereby increasing the risk to fish within that distance.
Step 4. Estimate the area that is ensonified above threshold levels. Because pile driving
rarely occurs in open water, simply calculating the area of a circle with a radius of R1
often overestimates the area that is ensonified above threshold levels. For computational
ease, NOAA Fisheries assumes that geologic features such as islands or bends in a river,
or man-made structures such as rock breakwaters, will function as barriers to sound
transmission, and only those areas with a direct line-of-sight to the pile driver will be
ensonified. Thus, estimating the area that is ensonified above threshold levels will
depend on site-specific factors that must be considered on a case-by-case basis.
Reference Sound Source Levels

The LNG terminal includes in-water installation of four 96-inch-diameter steel pipe piles.
The most applicable source levels available are for 96-inch-diameter steel piles in water depths of
approximately 39 to 49 feet (12 to 15 meters) for the Benicia-Martinez Bridge crossing in the
Carquinez Strait in Contra Costa County, California (ICF Jones & Stokes, and Illingworth and
Rodkin, Inc. 2009). In-water measurements for hydraulic impact-hammer pile driving indicate
that installation of the steel piles at the Benicia-Martinez Bridge generated a peak average sound
pressure root-mean-squared (RMS) metric, a peak SPL, and an SEL of 220, 205, and 194 dB re 1
μPaRMS, respectively, at a distance of 33 feet (10 meters) (see table F-6).
TABLE F-6
Unattenuated Sound Pressure Levels Measured for the Benicia-Martinez Bridge

Sound Pressure Levels (dB)
Approximate Distance a/ SPL RMS SEL
5 meters 227 215 201
10 meters 220 205 194
20 meters 214 203 190
50 meters 210 196 184
100 meters 204 192 180
500 meters 188 174 164
1,000 meters 180 165 155
a/ Distance measured from the pile at about mid-depth (10 to 15 meters deep).
Source: ICF Jones & Stokes, and Illingworth and Rodkin, Inc. (2009)
F-21 EFH Assessment

Background Noise Levels

Background noise, or ambient noise, is noise that already exists in the environment prior
to the introduction of another noise-producing activity. Natural sources of ambient/background
noise include biological sources (e.g., animals) and physical sounds (e.g., wind, waves, rain).
Human-generated sources include commercial ships, recreational vessels, seismic air guns, and
marine construction. One of the major contributors to background noise near the Project area is
commercial shipping traffic in the BSC. Although background noise levels were not available for
the BSC, data from a similar channelized site in California to predict what the ambient noise level
might be without the inclusion of shipping traffic were reviewed. During an evaluation of noise
levels produced by a hydraulic cutterhead dredge during maintenance dredging in the Stockton
Deepwater Shipping Channel in California, the COE measured background levels at eight channel
locations (Reine and Dickerson 2014). Maximum noise sound pressures ranged from 143.1 to
103.8 SPL RMS, with a mean of 119.5 SPL RMS. These values do not include generator noise of
ships moored at the port or sounds produced during normal day-to-day activities associated with
port operations. All sound sources combined (e.g., generator noise, port activity noise) result in
SPLs at the 50th percentile level of 118.3 dB. This was the value that the COE used for comparing
underwater sound emitted during the excavation process (Reine and Dickerson 2014).
Knowing the background noise of an area is important to understanding the overall impact
that the introduction of more noise could have on the marine fish. If background noise levels in
the vicinity of the Project exceed the NOAA Fisheries thresholds, then fish would not be affected
by any sound less than the already existing dominant noise levels. For example, if the background
noise levels average 150 dB, then levels of sound less than 150 dB would not represent harassment.
However, there is no current information regarding measurements of background noise in the
vicinity of the Project area. Therefore, it is assumed that while vessel noise associated with the
Project would not add greatly to the already existing background vessel noise in the region, it
cannot be assumed that the sound produced by pile driving would be completely masked by the
vessel noise, especially close to the hammer. For the purposes of this evaluation, background noise
levels have been assumed to be 150 dB.
Underwater Transmission Loss

To determine how noise could impact marine fishes in the Project area, it is important to
understand how the sound is transmitted from the noise source. As sound moves away from its
source, there is a loss of acoustic intensity with increasing distance from the source. This is known
as transmission loss (TL). How a sound travels away from a source depends on a variety of factors,
including the original source level, environmental factors such as local salinity and temperature,
and physical factors such as water depth, currents, and composition of bottom sediments (when
depth is a limiting factor). Transmission loss also varies based on the depth of the sound source
and the receiver. Considering all these factors can aid in better understanding how the sound will
travel away from the source; however, it is not always possible to obtain all the information
necessary to determine site-specific TL. For this analysis, TL has been set at the NOAA Fisheries
default constant of 15.
Attenuation to Effects Thresholds

To determine potential impacts on fish from Project pile driving, the ensonified area
surrounding the acoustic source and the zones of influence (ZOIs) in the ensonified area that
EFH Assessment F-22

exceed the various threshold levels noted above was determined. Based on this approach, pile
driving for the Project is predicted to produce peak sounds above the SPL (206 dB re: 1 µPa2/sec)
threshold from approximately 597 to 879 feet (182 to 268 meters) (considering mean and standard
deviation) from the source, and above the lesser cumulative SEL (183 dB) up to 777 feet (237
meters) from the source (table F-7). This ensonified area could result in physical injury to fish.
However, injury to non-auditory tissues in fish with swim bladders (e.g., juvenile spot [Leiostomus
xanthurus] and pinfish [Lagodon rhomboides]) cannot be assessed using SPLs. These fish are
typically affected by continuous sound levels (i.e., SEL) rather than by peak noise levels. Hastings
(2007) determined that an SEL as low as 183 dB (re: 1 µPa2/sec) was sufficient to injure the non-
auditory tissues of juvenile spot and pinfish having an estimated mass of 0.5 gram. Therefore,
combined cumulative SEL sound levels noted for determining effects to fish greater than and less
than 2 grams (i.e., 187 dB and 183 dB, respectively) were conservatively determined as likely to
occur throughout the BSC (see table F-7).
TABLE F-7
Predicted Pile-Driving Noise Thresholds Limits for Fish

Distance to Threshold (meters)
Onset of Physical Injury Behavioral
Cumulative SEL (dB) a
Distance from Pile-Driving Noise Source Peak (dB) Fish ≥ 2 g Fish < 2 g RMS (dB)
Effect Levels 206 187 183 >150
5 meters 43 4,288 4,288 23,208
10 meters 86 8,577 8,577 46,416
20 meters 172 17,154 17,154 92,832
50 meters 429 42,885 42,885 232,079
Zone of Influence [mean & std. deviation] 182 ± 86.3 18,226 ± 8,643 18,226 ± 8,643 98,633 ± 46,777
a/ Assumes single strike SELs less than 150 dB do not accumulate to cause injury (i.e., effective quiet)
However, for a continuous noise source such as an impact hammer, it is expected that
without the application of mitigation measures, disturbance levels resulting in behavioral effects
(greater than 150 re 1 μPaRMS) could occur throughout the zone of influence within the BSC from
the pile-driving noise source (see table F-7). It is likely that this estimate represents the most
conservative and worst-case scenario and that the actual threshold distance(s) (and associated ZOI)
may be less than the model suggests. It is also important to note that the uncertainty of the physical
factors of the environment, discussed above, cannot be accounted for in desktop analyses but must
be understood relative to using the model’s output for estimating potential injuries to fish.
It is anticipated that some fish would avoid the area because of levels of sound when the
hammer is operating. However, as pile driving would be a short-term, temporary action performed
only during construction, the occurrence of these species within the BSC over the long term is not
likely to change significantly. Additionally, the area of disturbance would be small and similar
habitat surrounds the Project site; therefore, the energy expended by fish to avoid the Project area
would be minimal. Disturbance of fish close to an individual pile or within the immediate Project
area would be short term and is not expected to result in population-level effects. Annova would
protect fish and marine wildlife from noise associated with dredging and pile driving through
consideration of and mitigation for thresholds established for marine wildlife by the Fisheries
F-23 EFH Assessment

Hydroacoustic Working Group. Mitigation measures may include noise bubble curtains and on-
site monitoring, and would be determined based on consultation with NOAA Fisheries.
Summary
With no mitigation measures employed, physical injury (all types) to fish could potentially
occur within both the determined SPL and SEL ZOIs. Generally, for the SEL ZOI, noise could
affect juveniles, small species, or benthic organisms that typically are less mobile than mid-water
or pelagic species. Fish within the RMS ZOI could experience behavioral effects. A small
number of studies investigating the possible effects of noise, primarily seismic sound, on fish
behavior have been conducted over the years. Studies looking at change in distribution are often
conducted at larger spatial and temporal scales than are typical for studies that examine specific
behaviors such as startle response, alarm response, and avoidance response. The studies that
examine those specific defined responses often involve caged fish rather than free-ranging
fish (Hirst and Rodhouse 2000). Masking of natural/ambient sounds (e.g., communication,
detection of predators and prey, gleaning of information about the surrounding environment)
also has the potential to affect fish behavior (Popper and Hastings 2009).
Cumulative in-water pile-driving activities are expected to occur for less than one week. It
is likely that most fish would avoid the area because of disturbing levels of sound when the impact
hammer is operating; noise levels exceeding the assumed background of 119 to 150 dB re 1
µPaRMS can cause fish to avoid the immediate area around a pile being driven. However, because
of the short timeframe for pile placement, it is predicted that no fish would be permanently
deterred from entering the area for foraging. Also, because the area of disturbance would be
relatively small, and similar habitat surrounds the site, any avoidance activity would not require
extra energy expenditures. Given the sound mitigation measures described in section 5.2 below,
it is expected that some acoustic disturbance of fish close to an individual pile being driven,
or within the immediate Project area, could occur. These impacts would be short-term and
negligible, and are not expected to result in population-level effects to managed species or adverse
effects on EFH.
OPERATIONS
Managed species and EFH may be exposed to stressors associated with operation of the
Project, including ballast water and cooling water discharge from LNG carriers (section 4.2.1 of this
EFH assessment) and accidental spills of hydrocarbons from the marine terminal and support vessels
(section 4.2.2 of this EFH assessment).

Large vessels withdraw water and place it in separate onboard ballast tanks to provide
additional draft and improve navigational performance. During loading, LNG carriers would
discharge ballast water into the BSC. The marine berth would accommodate LNG carriers with
cargo capacities up to 177,000 m3. Assuming that the ballast water is approximately 50 percent
of the weight of the LNG cargo to be loaded, approximately 9,950,000 gallons would discharge
from a vessel with a capacity of 177,000 cubic meters. Ballast discharge periods would vary, but
generally vessels would discharge a volume equal to 10 percent of their capacity each hour.
Therefore, a vessel of 177,000 cubic meter capacity would discharge approximately 995,000
gallons per hour. Per the United States Coast Guard (Coast Guard) guidelines discussed in section
EFH Assessment F-24

4.3 of the EIS, it is expected that ballast water in the LNG carriers entering the BSC would be from
the Gulf of Mexico or other open water locations.
Discharge of large volumes of ballast water can cause changes to the quality of receiving
waters by affecting salinity, dissolved oxygen, temperature, and pH. In addition, nonindigenous
species transported in ballast water may be introduced to receiving waters during discharge. Each
of these variables is discussed in the following paragraphs:
Salinity
Ballast water from LNG carriers would consist mainly of open ocean water collected
during ballast water exchange activities in the Gulf of Mexico. During ballast water exchange, the
water is withdrawn from below the surface where salinities are typically higher than near the
surface. Likewise, in the Project’s berth, ballast water would be discharged below the surface.
Estuarine salinities can naturally range from freshwater (0.5 ppt), near the source of freshwater
input, to full seawater (30 to 40 ppt; Patillo et al. 1995). Salinity levels within the BSC naturally
vary within this range dependent upon tidal regime and rainfall. During and immediately
following ballast water discharges, benthic aquatic species may be affected by higher salinity
levels because the higher salinity ballast water would sink to the lower portion of the channel due
to its higher specific gravity relative to the ambient water. However, ships moving into and out of
the BSC would displace water, circulating it into, around, and out of the berthing area. Therefore,
any increased salinity levels resulting from ballast water discharges would be localized and
temporary. Resident species within the BSC are euryhaline (able to live in waters with a wide
range of salinity), and the salinity of seawater is well within their tolerance range.
Common estuarine species likely to occur within the Project vicinity were evaluated to
determine whether changes in salinity from ballast water discharge would cause adverse impacts.
Salinity ranges for representative species of fish were obtained and compared with that of open
ocean salinities likely to be discharged via ballast water (see figure F-2). Results of this analysis
suggest that estuarine species likely to occur within the marine berth area are highly adapted to
salinity variations, and any short-term increases from ballast discharge would be well within their
tolerance range.
Ballast water discharged into the BSC would have little to no effect on the BSC’s salinity
regime. In fact, the ballast water salinities may be lower than ambient conditions within the BSC,
especially in the summer. Therefore, we have determined that changes in salinity from ballast
water discharges would be temporary and negligible.
F-25 EFH Assessment

Source: Patillo et al. 1995
Figure F-2 Salinity Ranges for Adults of Estuarine Species Compared with Open Gulf
Salinities
Dissolved Oxygen
Dissolved oxygen levels below 4 mg/L are generally considered unhealthy for aquatic life;
levels below 2 mg/L are considered hypoxic and inadequate to support most aquatic life. As
discussed in section 4.3, ballast water could contain low dissolved oxygen levels and could reduce
existing dissolved oxygen levels within the immediate vicinity of the discharge point. Depending
on the oxygen levels present in both the ballast and ambient water at the time of discharge, aquatic
resources in the vicinity of the discharge point could be exposed to dissolved oxygen levels
considered unhealthy for aquatic life. The adaptability of resident species within the BSC to
natural variation in oxygen levels would minimize the impacts associated with low dissolved
oxygen on mobile species. Bivalves are not able to relocate when oxygen levels drop. Instead,
they simply close their valves and wait for more favorable conditions to return.
Dissolved oxygen concentrations in ballast water are influenced by the concentration in the
water at the time of uptake, microbial activity in the ballast tanks, and residency time of ballast
water in the vessel. Ballast water discharge could have more or less dissolved oxygen than
receiving waters. Relative concentrations of dissolved oxygen in ballast water discharge and the
BSC are not subject to analysis because of the number of confounding variables that affect
dissolved oxygen concentrations in both ballast water discharge and the BSC. For example,
dissolved oxygen concentrations in ballast water discharge are affected by water temperature, type
of ballast water treatment, location and timing of last water exchange, fullness of ballast water
EFH Assessment F-26

tanks, and others. Dissolved oxygen levels in the BSC are strongly influenced by time of day,
season, and recent weather events. The volume of ballast water discharged into the BSC during
each LNG carrier visit would make up only a fraction of the approximately volume of the BSC.
The volume differential, combined with water movements, would make effects of ballast water
discharge on dissolved oxygen insignificant. Impacts on EFH within the BSC from changes in
dissolved oxygen are expected to be minor and temporary in nature.
Water Temperatures and pH

Ballast water is carried in tanks below the waterline, and ballast water is typically cooled
as a vessel transits through open waters. In winter, ballast water would likely conform to surface
water temperatures in the BSC; in summer, ballast water discharges would likely be several
degrees cooler that ambient temperatures in the BSC. The pH of the ballast water would reflect
conditions where open ocean exchange occurred. The pH of the open ocean is 8.1 (NOAA 2016),
which is within the acceptable range for the BSC of 6.5 to 9.0 (Title 30 Texas Administrative Code
§§307.01-307.10). The volume of ballast water discharge is small relative to the BSC. The
expected differential between ballast water discharge and the BSC is not large enough to cause a
change in pH or temperature that would significantly impact aquatic organisms. Impacts of
temperature and pH in ballast water discharge on EFH would be temporary and negligible (i.e.,
discountable).
Invasive Species
To minimize and avoid potential impacts on wildlife species that could result from ballast
water discharges, Annova would ensure that all visiting vessels possess documentation to
demonstrate their compliance with ballast water regulations and BMPs prior to allowing any
ballast water to be discharged at the marine transfer facilities (see section 4.3 of the EIS). As a
result, marine resources in the Project area are not expected to be impacted by the introduction of
invasive species in ballast water.
To minimize and avoid impacts on fish and other aquatic organisms resulting from ballast
water discharges, the Coast Guard, which has jurisdiction over inspection and regulatory
enforcement for all shipping in U.S. waters, would require all LNG carriers calling on the LNG
terminal to adhere to all applicable ballast water management rules and regulations. Coast Guard
regulations require that all vessels equipped with ballast water tanks which enter or operate in U.S.
waters maintain a ballast water management plan that is specific for that vessel and assigns
responsibility to the master or appropriate official to understand and execute the ballast water
management strategy for that vessel. Under these requirements, vessels must implement strategies
to prevent the spread of exotic aquatic nuisance species in U.S. waters. Examples of these
strategies include retaining ballast water on board, minimizing discharge or uptake at certain times
and locations, and exchanging ballast water with mid-ocean seawater. Ships that have operated
outside of the U.S. Exclusive Economic Zone (EEZ) must either retain their ballast water on board
or undergo a mid-ocean (greater than 200 nm from shore/water depth greater than 6,500 feet (2,000
meters) ballast water exchange in accordance with applicable regulations. Applicable U.S. laws,
regulations, and policy documents related to ballast water include the following:
• the Nonindigenous Aquatic Nuisance Prevention and Control Act of 1990

(NANPCA) established a broad federal program “to prevent introduction of and to
F-27 EFH Assessment

control the spread of introduced aquatic nuisance species.” The FWS, Coast Guard,
EPA, COE, and NOAA Fisheries all were assigned responsibilities.
• the NISA reauthorized and amended the NANPCA because “Nonindigenous
invasive species have become established throughout the waters of the U.S. and are
causing economic and ecological degradation to the affected near shore regions.”
The Secretary of Transportation was charged with developing national guidelines
to prevent import of invasive species from ballast water of commercial vessels,
primarily through mid-ocean ballast water exchange, unless the exchange threatens
the safety or stability of the vessel, its crew, or its passengers.
• the NISA, amended in 2005 and again in 2007, established a mandatory National
Ballast Water Management Program. The primary requirements established under
NAISA are: 1) all ships operating in U.S. waters are required to have on board an
Aquatic Invasive Species Management Plan; 2) the Coast Guard was made
responsible for the development of standards for mid-ocean ballast water exchange
and ballast water treatment for vessels operating outside of the EEZ; and 3)
implementing the BMPs and available technology related to ballast water
treatment.
• the National Ballast Water Management Program, originally established by
NANPCA and further amended by the National Invasive Species Act of 1996 and
NAISA, made the ballast water management program mandatory, including ballast
water exchange, with reporting to the Coast Guard.
• the Shipboard Technology Evaluation Program, a program authorized under the
Coast Guard Ballast Water Management Program and designed to facilitate the
development of “effective ballast water treatment technologies, through
experimental systems, thus creating more options for vessel owners seeking
alternatives to ballast water exchange.”
• the Navigation and Vessel Inspection Circular 07-04, Change 1, a program
developed by the Coast Guard for the management and enforcement of ballast water
discharge into U.S. ports and harbors.
• Vessels Carrying Oil, Noxious Liquid Substances, Garbage, Municipal or
Commercial Waste, and Ballast Water, implementing regulations for the Act to
Prevent of Pollution from Ships of 1980, which applies to all U.S.-flagged ships
anywhere in the world and to all foreign-flagged vessels operating in navigable
waters of the U.S. or while at port under U.S. jurisdiction.
Cooling Water Uptake and Discharge

In addition to discharging ballast water, LNG carriers would require the intake of water in
order to operate the ship and cool the ship’s engines. Ship cooling water would be withdrawn and
discharged below the water line on the sides of the ship through screened water ports, known as
“sea chests”. Water intakes could result in the impingement and entrainment of fish. These actions
could impact the rates of stress, injury and/or mortality experienced by fish. To minimize these
impacts, water intakes would be outfitted with screened sea chests that withdraw and discharge
water at a relatively slow velocity.
EFH Assessment F-28

The cooling water used by LNG carriers would be withdrawn along the vessel transit routes
and from the BSC marine facility while loading LNG cargo. Depending upon engine type, LNG
carriers would use between 5.5 and 11.7 million gallons of water for engine cooling while they are
at the LNG terminal. Early life stages of fish and invertebrates (ichthyoplankton) would be most
susceptible to entrainment. Quantitative data for the structure and density of the ichthyoplankton
community within the BSC are unavailable, however the BSC is not considered EFH for spawning
adults or eggs, so abundance of early life stages is assumed to be low. As a proxy for the density,
we refer to sampling data collected within the Calcasieu River near Carlyss, Calcasieu Parish,
Louisiana. In that sampling, fish species had a larval density of 522.2 individuals per 1,000 cubic
meters and the shrimp larval density was 91.5 individuals per 1,000 cubic meters. Using these
estimated densities and estimated range of cooling water use, between 10,900 and 23,100 larval
fish, and between 1,900 and 4,100 larval shrimp could be entrained by each LNG carrier while at
the Project. At full capacity, Annova would receive up to approximately 125 LNG carriers per
year, which would affect between 1.3 and 2.8 million larval fish and 237,000 and 512,000 larval
shrimp per year by cooling water intake. Due to the high natural mortality rates in the first year
of ichthyoplankton (greater than 90 percent), an incremental loss would not significantly impact
the health of the adult fish population. The impact on ichthyoplankton from cooling water uptake
would be permanent (for the life of the facility), but we conclude these impacts would not be
significant.
Water used for engine cooling would be discharged at a temperature between 2.7°F and
7.2°F warmer than the ambient water temperature (Caterpillar 2007, 2011, 2012). Using the most
conservative estimates (assuming the highest ambient temperature generally found within the BSC
[86°F], the greatest change in water temperature [7.2°F], and the largest volume of water [11.7
million gallons]), the discharged cooling water temperature would be 95.5°F. Fish and
invertebrates within the immediate vicinity of the LNG carrier could be temporarily affected by
this increase in temperature; however, many of the species present are mobile and would be
expected to relocate to more suitable conditions during discharges. As discussed in section 4.1.4
above, given the volume of cooling water discharged relative to the total volume of water within
the BSC, and the expectation that mobile species would temporarily leave the area of increased
temperature, we have determined that impacts on marine and aquatic resources would be
intermittent and minor.
Accidental Spills
Minor releases of hydrocarbons (e.g., diesel fuel and various lubricants) from equipment
at the marine terminal or work vessels could result in negative direct impacts on fish and
invertebrates. Evidence of these disturbances is mainly behavioral (e.g., fish excitement, increased
activity, scattering in the water). Extended exposure can lead to chronic poisoning, and cumulative
effects can occur. These effects depend on the nature of the toxin, exposure time, and
environmental conditions. Many factors determine the degree of damage from a spill, including
the composition of the organic-based compound, the size and duration of the spill, the geographic
location of the spill, and the weathering processes present. Although oil is toxic to all marine
organisms at high concentrations, certain species and life history stages of organisms appear to be
more sensitive than others. In general, the early life stages are most sensitive, juveniles are less
sensitive, and adults least sensitive (Rice et al. 2000). Even concentrations of oil that are diluted
sufficiently to not cause acute impacts on marine organisms may alter certain behavior or
F-29 EFH Assessment

physiological patterns. Sub-lethal effects that may occur with exposure to polycyclic aromatic
hydrocarbons (PAHs) include impairment of feeding mechanisms for benthic fish and shellfish;
reduced growth and development rates, energetics, reproductive output, and juvenile recruitment
rates; increased susceptibility to disease and other histopathic disorders (Capuzzo 1987); and
physical abnormalities in fish larvae (Urho and Hudd 1989). Effects of exposure to PAHs in
demersal fish include liver lesions, inhibited gonadal growth, inhibited spawning, reduced egg
viability, and reduced growth (Johnson et al. 2002).
Annova would prepare a Project-specific facility response plan that addresses the potential
for petroleum-based spills from operational equipment and describes preventive and response
measures that would be implemented in the event of a spill. Additionally, Annova would adhere
to all requirements as provided in the Coast Guard’s Navigation and Vessel Inspection Circular
Number 01-2011 for waterfront LNG facilities (Coast Guard 2011).
It is expected that immediate response actions would limit impacts on aquatic populations
to temporary, minor disturbances from these unanticipated contaminant releases. An accidental
release of LNG could potentially cause direct mortality at the population or individual level, as
well as loss or avoidance of habitat. The behavior of LNG in seawater is not well known as the
history of LNG shipping has no substantial releases. If released, it would lower the water
temperature rapidly at the air/water interface immediately near the release, but the effects would
decrease with depth and are predicted to not be significant for fish habitats. All visiting LNG
carriers would have independent oil and hazardous materials response requirements, including
requirements for shipboard oil spill response plans that are described in 33 CFR 151 and 155. The
LNG carriers also have independent requirements for vessels carrying liquefied hazardous gas
(mostly safety requirements) per other regulations (see 46 CFR 154 Subpart E).
5.0 CUMULATIVE IMPACTS AND MITIGATION
CUMULATIVE IMPACTS
Cumulative impact is the “impact on the environment which results from the incremental
impact of the action when added to other past, present, and reasonably foreseeable future
actions regardless of what agency (federal or non-federal) or person undertakes such other
actions (40 CFR 1508.7).” Cumulative impacts on EFH associated with this Project may
include similar impacts from other projects within the same geographic region. We have
addressed cumulative impacts relative to wetlands, water quality, and fisheries in section 4.13 of
the EIS.
MITIGATION MEASURES
In support of a policy to reduce impacts on EFH, Annova would commit to implementing
several mitigation measures to minimize or eliminate impacts on water quality and wetlands, and
to reduce the effects from other construction and operational activities.
Due to the general nature of the area surrounding the Project site, wetland impacts cannot
be avoided entirely. Construction would temporarily affect 4.7 acres of estuarine open water and
tidal flat, and operation of the Project would permanently convert 2.0 acres of open water and tidal
flat to upland or built infrastructure. Construction would temporarily affect 53.0 acres of estuarine
emergent marsh, of which 50.8 acres would be permanently converted to non-wetland cover type
EFH Assessment F-30

during Project operation. Annova is consulting with the COE and other cooperating agencies as
part of the wetland permitting process. In order to obtain a permit under Section 404 of the Clean
Water Act from the COE, Annova must first avoid and minimize impacts on waters of the United
States to the extent practicable. In addition, the COE will require compliance with the “no net
loss” policy through replacement of wetlands to offset the loss of wetlands resulting from
construction of the Project. For unavoidable impacts on waters of the United States, Annova is in
the process of developing a mitigation plan to offset the loss and/or wetland resource functions
within the watershed. The COE will determine the acceptability of the proposed mitigation plan
for wetland impacts.
Construction activities have the potential to introduce contaminants to stormwater runoff

through excavation, material delivery and storage, and equipment and vehicle use and storage.
Stormwater from the site would discharge directly to stormwater retention ponds, with subsequent
discharge into the BSC. Annova has developed a Project-specific Upland Erosion Control,
Revegetation, and Maintenance Plan (Annova Plan) and Wetland and Waterbody Construction
and Mitigation Procedures (Annova Procedures) based respectively on FERC’s Plan (FERC
2013a) and Procedures (FERC 2013b) for reducing water quality impacts on the BSC. The Annova
Plan and Procedures include a description of pollution control measures and best management
practices that would help to control erosion, sedimentation, and pollutants in runoff from the site.
For Project operation, Annova would prepare and implement a stormwater pollution prevention
plan and a spill prevention, control, and countermeasures plan to prevent impacts from minor
spills. Adherence to the Annova Plan and Procedures, as well as the plans listed above, would
reduce the potential for spills or impacts on the waterway, and thereby reduce impacts on EFH and
fisheries.
Based on the previous analysis, a potential risk exists to managed (and other) fish species
as a result of planned pile-driving activities for the Project. To minimize impacts, Annova would
institute impact minimization and mitigation measures throughout the course of the Project.
Although specific mitigation measures are not yet final, they may include those listed below.
• use of the lowest-noise-producing impact hammer available for pile driving to

reduce in-water noise levels;
• various operational procedures, including “soft starts.” Prior to operating at full

capacity, Annova would implement a “soft start” with several initial hammer strikes
at less than full capacity (i.e., approximately 40 to 60 percent energy levels), with
no less than a 1-minute interval between each strike;
• bubble Curtain. A bubble curtain functions to restrict sound waves from emanating
away from the noise source. Air pumped into a perforated hose lying on the seabed
escapes and produces an air bubble curtain as the bubbles rise. Sound generated by
pile-driving are attenuated as they pass through the bubbles;
• hydro Sound Damper (HSD). The HSD system consists of a fishing net on which
HSD elements of different sizes are mounted at various distances from each other.
Using a ballast ring on the seabed and a flotation system on the sea surface, the net,
including the HSD elements, can be located a short distance (less than 3.3 feet
F-31 EFH Assessment

[1 meter]) around the pile. The HSD elements can be foam plastic elements or gas-
filled balloons. The noise from the pile must cross the HSD elements and is thereby
reduced due to reflection and absorption. In principle, the HSD elements act like
air bubbles in the water, with the advantages that they cannot be drifted by currents
and, because their size can be adjusted, their resonance frequency is adjustable;
• Noise Mitigation Screen (NMS). A NMS system consists of a double-wall steel

screen tube. The pile is inserted into this system. The space between the two
screens is filled with air, and air bubbles can be fed in between the pile and NMS
system (water-air- composite). As the radiated sound crosses the internal bubble
curtain and the air-filled double-wall steel screen, it is reduced due to reflection
(impedance gap); and
• cofferdam. The cofferdam system consists of a single-wall steel tube. The pile is
inserted into this system. Near the seabed a gasket (seal ring) is installed so that
water in the space between pile and cofferdam can be evacuated by pumps. In
principal, the pile is installed in air and not in water, so sound generated by pile
driving radiates into the air and then crosses the steel tube. Due to the different
impedances, the pile-driving noise is reduced by reflection.
6.0 CONCLUSION
Potential impacts resulting from Project construction and operation are expected to be
short-term and highly localized, occurring primarily during construction or shortly thereafter.
Overall, impacts on managed species and EFH in the Project area would vary depending on the
species and different stages of their life cycles. In general, due to their mobility, pelagic species
and those with mobile early life stages would avoid the Project area during construction. Any loss
of early life stages during hydrostatic testing or dredging activities during construction, and from
cooling water uptake and discharge, and ballast water discharge during operation, would be
inconsequential to regional fish populations.
Short-term increases in turbidity would occur as a result of disturbance of bottom sediments

during construction. These impacts would likely be highly localized and thus are not expected to
be significant. Sediment disturbance within the terminal basin is expected to result in mortality of
benthic organisms within and adjacent to the Project footprint. This reduction in benthic
community densities would eliminate a small amount of the available forage for managed species
that occur locally. This impact would be short-term and minor, as the community would re-
establish over a relatively short period of time through immigration and translocation. The short-
term loss of the benthic community during construction would not be a significant adverse impact.
Impacts from pile driving are expected to be less than significant considering the short in-
water work schedule and the implementation of BMPs, mitigation measures, and conservation
measured recommended by NOAA Fisheries. The short-term nature of the proposed pile-driving
activities would not result in significant adverse effects on EFH or managed species.
EFH Assessment F-32

7.0 REFERENCES
Black & Veatch. 2016. Hydrodynamic Modeling. Document Number 183169-REFF-0027.

Prepared for Annova LNG, LLC. November 30.
BOEM (Bureau of Ocean Energy Management. 2014. Atlantic OCS – Proposed Geological and
Geophysical Activities: Mid-Atlantic and South Atlantic Planning Areas. Final
Programmatic Environmental Impact Statement. OCS EIS/EA, BOEM 2014-001.
Caltrans (California Department of Transportation). 2001. Fisheries impact assessment, pile

installation demonstration project, San Francisco-Oakland Bay Bridge, East Span
Seismic Safety Project. 59 p.
Capuzzo, J.M. 1987. Biological effects of petroleum hydrocarbons: assessment of experimental

results. In: Boesch, D.F., and N.N. Rabelais, eds. Long-term Environmental Effects of
Offshore Oil and Gas Development, 343–341. London, England: Elsevier Applied
Science.
Coast Guard (United States Coast Guard). 2011. Navigation and Vessel Inspection Circular No.
01-2011. Guidance Related to Waterfront Liquefied Natural Gas (LNG) Facilities,
COMDTPUB P16700.4.
COE (United States Army Corps of Engineers). 2012. A community-based ecosystem response
model for the Resacas (oxbow lakes) of the Lower Rio Grande. Website:
http://el.erdc.usace.army.mil/elpubs/pdf/trel12-31.pdf (Accessed in January 2016).
. 2013. Brazos Island Harbor, Texas Channel Improvement Project, Draft Integrated
Feasibility Study – Environmental Assessment. Website:
http://www.swg.usace.army.mil/Portals/26/docs/Cheryl%20Jaynes/2-BIH%20DIFR-
EA%202013.pdf (accessed in June 2015).
Cowardin, L.M., V. Carter, F.C. Golet, and E.T. LaRoe. 1979. Classification of wetlands and
deepwater habitats of the United States. U.S. Department of the Interior, Fish and
Wildlife Service, Washington, D.C. 131 pp.
EPA (United States Environmental Protection Agency). 1999. The Ecological Condition of
Estuaries in the Gulf of Mexico. EPA 620-R-98- 004, July 1999. EPA Office of Research
and Development, National Health and Environmental Effects Research Laboratory, Gulf
Ecology Division, Gulf Breeze, Florida. Website: http://www.epa.gov/ ged/gulf.htm.
FERC (Federal Energy Regulatory Commission). 2013a. Upland Erosion Control,

Revegetation, and Maintenance Plan. Office of Energy Projects, May 2013. Website:
http://www.ferc.gov/industries/gas/enviro/plan.pdf (accessed on April 1, 2015).
. 2013b. Wetland and Waterbody Construction and Mitigation Procedures. Office of

Energy Projects, May 2013. Website: http://www.ferc.gov/industries/
gas/enviro/procedures.pdf (Accessed on April 1, 2015).
F-33 EFH Assessment

FWS (United States Fish and Wildlife Service). 2000. News and Activities – Free-for-all with
Furfural Kills 9 Million Fish. Website: http://www.fws.gov/contaminants/
DisplayNews.cfm?NewsID=E2D4E08E-7448-11D4- A169009027B6B5D3 (accessed in
May 2015).
Finucane, J.H., L.A. Collins, H.A. Brusher, and C.H. Saloman. 1986a. Reproductive biology of
king mackerel, Scomberomerus cavalla, from the southeastern United States. Fish Bull
84(4):841–850.
Finucane, J.H., L.A. Collins, H.A. Brusher, and C.H. Saloman. 1986b. Reproductive biology of
Spanish mackerel, Scomberomerus maculatus, from the Gulf of Mexico and South
Atlantic Ocean of the United States. U.S. Natl Mar. Fish. Serv., Panama City, FL. 23 pp.
(unpubl. MS).
Gallaway, B.J., S.T. Szedlmayer, and W.J. Gazey. 2009. A life history review for red snapper
in the Gulf of Mexico with an evaluation of the importance of offshore petroleum
platforms and other artificial reefs, Reviews in Fisheries Science, 17(1):48–67.
Gardner, M. B. 1981. Effects of turbidity on feeding rates and selectivity of bluegills.

Transactions of the American Fisheries Society 110:446–450.
Germano, J., J. Parker, and J. Charles. 1994. Monitoring Cruise at the Massachusetts Bay
Disposal Site, August 1990. DAMOS Contribution No. 92. U.S. Army Corps of
Engineers, New England Division, Waltham, Massachusetts. 51 pp.
GMFMC (Gulf of Mexico Fishery Management Council). 1998. Generic amendment for
addressing essential fish habitat requirements in the Fishery Management plans of the
Gulf of Mexico. Tampa, Florida: Gulf of Mexico Fishery Management Council.
. 2004. Final Environmental Impact Statement for the Generic Essential fish Habitat
Amendment to the Gulf of Mexico (GOM): Shrimp Fishery of the GOM; Red Drum
Fishery of the GOM; Reef Fish Fishery of the GOM; Stone Crab Fishery of the GOM;
Coral and Coral Reef Fishery of the GOM; Spiny Lobster Fishery of the GOM; Coastal
Migratory Pelagic Resources of the GOM and South Atlantic.
. 2005. Generic amendment for addressing essential fish habitat requirements in the
Fishery Management plans of the Gulf of Mexico. Gulf of Mexico Fishery Management
Council, Tampa, Florida.
. 2015. Species Listed in the Fishery Management Plans of the Gulf of Mexico Fishery
Management Council. Website: http://gulfcouncil.org/Beta/GMFMCWeb/
downloads/species%20managed.pdf. Accessed in March 2016.
Hastings, M.C. 2007. Calculation of SEL for Govoni et al. (2003, 2007) and Popper et al. (2007)
studies. Report for Amendment to Project 15218, J&S Working Group, Applied
Research Lab, Penn State University. 7 pp.
EFH Assessment F-34

Hawkins, A.D., and A.N. Popper. 2016. A Sound Approach to Assessing the Impact of
Underwater Noise on Marine Fishes and Invertebrates. ICES Journal of Marine Science
1-17. doi:0.1093/icesjms/fsw205.
Hedges, C.J. 2011. Hydroacoustic Impacts on Fish from Pile Installation. Website:
http://onlinepubs.trb.org/onlinepubs/nchrp/nchrp_rrd_363.pdf (accessed in March 2016).
Hirst, A.G., and P.G. Rodhouse. 2000. Impacts of geophysical seismic surveying on fishing
success. Reviews in Fish Biology and Fisheries 10:113–118.
Hoese, H.D., and R.H. Moore. 1977. Fishes of the Gulf of Mexico: Texas, Louisiana, and
adjacent waters. Texas A&M University Press, College Station and London. 327 p.
ICF Jones & Stokes, and Illingworth and Rodkin, Inc. 2009. Final Technical Guidance for
Assessment and Mitigation of Hydroacoustic Effect of Pile Driving on Fish. Prepared
for California Department of Transportation. February 2009. 298 pp.
Johnson, L.L., T.K. Collier, and J.E. Stein. 2002. An analysis in support of sediment quality
thresholds for polycyclic aromatic hydrocarbons (PAH) to protect estuarine fish. Aquatic
Conservation: Marine and Freshwater Ecosystems 12 (5):517–538.
LGL Limited. 2006. Assessment of the Effects of Underwater Noise from the Proposed Neptune
LNG Project – Supplemental Biological Effects Report. LGL Report No. 4200-2a.
Prepared for Ecology and Environment, Inc., August 8, 2006. 8 pp.
LUMCON (Louisiana Universities Marine Consortium). 2016. Hypoxia in the Northern Gulf
of Mexico. Website: http://www.gulfhypoxia.net/overview/ (accessed January 2016).
Murray, P.M., and H.L. Saffert. 1999. Monitoring Cruises at the Western Long Island Sound
Disposal Site, September 1997 and March 1998. DAMOS Contribution No. 125. U.S.
Army Corps of Engineers.
Newcombe, C.P., and J.O.T. Jensen. 1996. Channel suspended sediment and fisheries: a
synthesis for quantitative assessment of risk and impact. North American Journal of
Fisheries Management 16:693–727.
Nightingale, B., and C.A. Simenstad. 2001. Dredging activities: marine issues. Washington
State Transportation Center (TRAC) Report WA-RD 507.1 for the Washington State
Transportation Commission and in cooperation with US Department of Transportation;
2001. 182 pp.
NOAA. 1985. Gulf of Mexico coastal and ocean zones strategic assessment: Data Atlas. U.S.
Department of Commerce. NOAA, NOS. December 1985.
. 2000. Incident News – Furfural Spill. Website:

http://incidentnews.noaa.gov/incident/7458/507735 (Accessed in May 2015).
F-35 EFH Assessment

. 2016. What is Essential Fish Habitat? Website:

http://www.habitat.noaa.gov/protection/efh (Accessed May 3, 2016).
NOAA Fisheries (National Oceanic and Atmospheric Administration, National Marine Fisheries
Service). 1999a. Fishery Management Plan for Atlantic Tunas, Swordfish and Sharks.
NOAA, National Marine Fisheries Service, Highly Migratory Species Management
Division, Silver Spring, Maryland. Public Document.
. 1999b. Amendment 1 to the Atlantic Billfish Fishery Management Plan, including

Revised Final Supplemental Environmental Impact Statement, Regulatory Impact
Review Final Regulatory Flexibility Analysis, and Social Impact Assessment/Fishery
Impact Statement. Developed in coordination with the Highly Migratory Species (HMS)
Fishery Management Plan for the Atlantic Tuna, Swordfish, and Shark Fisheries. NOAA,
National Marine Fisheries Service, Highly Migratory Species Management Division,
Silver Spring, Maryland. Public Document.
. 2003. Final Amendment 1 to the Fishery Management Plan for Atlantic Tunas,
Swordfish, and Sharks. National Oceanic and Atmospheric Administration, National
Marine Fisheries Service, Office of Sustainable Fisheries, Highly Migratory Species
Management Division, Silver Spring, Maryland. Public Document. pp. 648.
. 2009. Final Amendment 1 to the 2006 Consolidated Atlantic Highly Migratory Species
Fishery Management Plan, Essential Fish Habitat. National Oceanic and Atmospheric
Administration, National Marine Fisheries Service, Office of Sustainable Fisheries,
Highly Migratory Species Management Division, Silver Spring, Maryland. Public
Document. pp. 395.
. 2011. Fisheries of the United States 2010. National Marine Fisheries Service, Office
of Science and Technology, Silver Spring, MD. 118 pages.
. 2015a. Amendment 35 to the Fishery Management Plan for the Snapper Grouper
Fishery of the South Atlantic Region. September 2015. Website:
http://sero.nmfs.noaa.gov/sustainable_fisheries/s_atl/sg/2014/am35/documents/pdfs/sa_
sg_am35_ea_091015.pdf.
. 2015b. Atlantic Highly Migratory Species. Website:

http://www.nmfs.noaa.gov/sfa/hms.
NRC (National Research Council). 2003. Ocean Noise and Marine Mammals. NRC,
Washington, D.C.
Page, L.M., H. Espinoza-Perez, L.T. Findley, C.R. Gilbert, R.N. Lea, N.E. Mandrak, R.L.
Mayden, and J.S. Nelson. 2013. Common and scientific names of fishes from the United
States, Canada, and Mexico, 7th edition. American Fisheries Society, Special Publication
34, Bethesda, Maryland. 384 p.
EFH Assessment F-36

Patillo, M., L. P. Rozas, and R. J. Zimmerman. 1995. A Review of Salinity Requirements for
Selected Invertebrates and Fishes of U.S. Gulf of Mexico Estuaries. National Marine
Fisheries Service. Southeast Fisheries Service Center. Galveston, Texas.
Popper, A.N., M.E. Smith, P.A. Cott, B.W. Hanna, A.O. MacGillivray, M.E. Austin, and D.A.
Mann. 2005. Effects of exposure to seismic airgun use on hearing of three fish species.
Journal of the Acoustic Society of America 117:3958–3971.
Popper, A.N., and M.C. Hastings. 2009. Effects of anthropogenic sources of sound on fishes.
Journal of Fish Biology 75:455–498.
Reine, K.J., and C. Dickerson. 2014. Characterization of underwater sounds produced by a

hydraulic cutterhead dredge during maintenance dredging in the Stockton Deepwater
Shipping Channel, California. U.S. Army Corps of Engineers ERDC TN-DOER-E38,
March 2014. 24 pp.
Rhoads, D.C., P.L. McCall, and J.Y. Yingst. 1978. Disturbance and production on the estuarine
seafloor. American Scientist 66:577–586.
Rice, S.D., J.W. Short, R.A. Heintz, M.G. Carls, and A. Mole. 2000. Life-history consequences
of oil pollution in fish natal habitat. In: P. Catania, ed. Energy 2000: the beginning of a
new millennium. Lancaster, PA: Technomic Publishers. pp. 1210-1215.
Robertson, M.J., D.A. Scruton, R.S. Gregory, R.S., and K.D. Clarke. 2006. Effect of Suspended
Sediment on Freshwater Fish and Fish Habitat. Canadian Technical Report of Fisheries
and Aquatic Sciences 2644:37.
Rodriguez-Pino, Z. 1962. Estudios estadisticos y biologicos sobre la biajaiba (Lutjanus

synagris). Notas Pesqueras, Havana, Cuba. Nota 2:1–16.
Ruggerone, G.T., S. Goodman, and R. Miner. 2008. Behavioral Response and Survival of
Juvenile Coho Salmon Exposed to Pile Driving Sounds. Natural Resources Consultants,
Seattle, Washington. July 2008. 46 pp.
Stadler, J.H., and D.P. Woodbury. 2009. Assessing the effects to fishes from pile driving:
Application of new hydroacoustic criteria. Internoise 2009: Innovations in practical
noise control. August 2009, Ottawa, Canada.
TCEQ (Texas Commission on Environmental Quality). 2012. Texas Integrated Report:

Assessment Results for Basin 24 – Bays and Estuaries. Accessed May 2015
http://www.tceq.texas.gov/assets/public/waterquality/swqm/assess/12twqi/2012_basin2
4.pdf.
Turner, R.E., and D.F. Boesch. 1987. Aquatic Animal Production and Wetland Relationships:
Insights Gleaned Following Wetland Loss or Gain. In: D.D. Hook et al. (eds.), The
Ecology and Management of Wetlands. Vol. 1: Ecology of wetlands. Timber Press,
Portland, OR.
F-37 EFH Assessment

Urho, L., and R. Hudd. 1989. Sub-lethal effects of an oil spill on fish (herring) larvae in the
northern Quark, in the Baltic. In: Blaxter, J.H.S., J.C. Gamble, and H.V. Westernhagen,
eds., The Early Life History of Fish, 1988 Oct. 3-5, Bergen, Norway. Third ICES
Symposium: Rapports et Proces-Verbaux Des Reunions 191. Copenhagen: International
Council for the Exploration of the Sea. p. 494.
USDOE (United States Department of Energy). 2012. Turning down the dial: Ocean
development with less sound. Website: http://www.pnnl.gov/news/ release.aspx?id=930.
Accessed in March 2016.
Utne-Palm, A.C. 2002. Visual feeding of fish in a turbid environment: physical and behavioural
aspects. Marine and Freshwater Behaviour and Physiology 35:111–128.
Young, H. 2015. Personal communications from Heather Young, NOAA NMFS, Habitat
Conservation Division.
EFH Assessment F-38

APPENDIX G
FUGITIVE DUST CONTROL PLAN
Annova LNG
Brownsville Project
Draft
Fugitive Dust Control Plan
May 2016
Submitted by:
4 Houston Center
1221 Lamar Street, Suite 750
Houston, TX 77010
Prepared by:

Annova LNG Brownsville Project Fugitive Dust Control Plan
TABLE OF CONTENTS
Section Page
Acronyms and Abbreviations ............................................................................................ iii
1 INTRODUCTION ............................................................................1
1.1 Objective ..................................................................................................................1
1.2 Project Description...................................................................................................1
2 FUGITIVE DUST SOURCES ................................................................1
3 APPLICABLE REGULATORY REQUIREMENTS ..........................................2
4 FUGITIVE DUST CONTROL MEASURES .................................................2
5 INSPECTION, MONITORING, AND RECORDKEEPING ..................................3
ii
Annova Annova LNG Common Infrastructure, LLC, Annova LNG

Brownsville A, LLC, Annova LNG Brownsville B, LLC, and
mtpa million metric tonnes per annum
iii
1 INTRODUCTION
1.1 OBJECTIVE
The objective of this fugitive dust control plan is to identify potential dust emission sources and
provide guidance to construction and field personnel on measures to control the generation of
fugitive dust during construction activities associated with the Annova LNG Project (Project). It
will be the responsibility of Project contractors, working with designated environmental
inspectors, to identify all activities generating fugitive dust, implement feasible control measures,
and ensure compliance with applicable fugitive dust regulations.
1.2 PROJECT DESCRIPTION

Annova is proposing to develop a liquefied natural gas (LNG) facility capable of producing a
nominal capacity of approximately 6.0 million (metric) tonnes per annum (mtpa) of LNG. The
Project would receive natural gas via a lateral pipeline that would tie-in to an existing interstate
pipeline. The natural gas would be treated, liquefied, and stored on-site in two full containment
LNG storage tanks with a net pumpable capacity of approximately 160,000 cubic meters (m3) of
LNG each. At full plant capacity, the Project would consist of six LNG trains each with a
nominal capacity of 1.0 mtpa of LNG (total nominal capacity of approximately 6.0 mtpa). The
LNG would be loaded onto LNG carriers for export overseas.
2 FUGITIVE DUST SOURCES

Fugitive dust could be generated directly from the aboveground facility construction. The
following construction activities have been identified as having the potential for generating
fugitive dust:
• Vehicle and motorized equipment movement on paved and unpaved access roads;
• Vegetation removal;
• Clearing and grading;
• Topsoil removal;
• Cutting and filling;
• Trenching;
• Backfilling;
• Track-out onto roads;
• Bulk material loading, hauling and unloading;
1
• Use of material storage piles, and
• Use of parking, staging, and storage areas.
It is the responsibility of the Project contractor(s) and the designated environmental inspector(s)
to ensure all sources of dust generation are identified.
3 APPLICABLE REGULATORY REQUIREMENTS

The Texas Commission on Environmental Quality’s (TCEQ) fugitive dust regulations with
requirements potentially applicable to Project construction activities is presented in Texas
Administrative Code (TAC) Title 30, Part 1:
• Chapter 101.4, Nuisance; a general duty regulation that prohibits discharge from any
source whatsoever air contaminants that may be injurious or adversely affect human
health or welfare, animal life, vegetation, or property or to interfere with the normal use
and enjoyment of animal life, vegetation, or property.
• Chapter 111, Subchapter A Visible Emissions and Particulate Matter, addresses visible
emissions and various sources of particulate matter.
o Division I, Chapter 111.111(a) is a general statement prohibiting visible emissions

from any source;
o Division I Chapter 111.111(8) prohibits visible emissions exceeding 30% opacity for
any six-minute period from all other sources not previously specified in Chapter 111.
o Division 4, Chapter 111.141 identifies geographic applicability of specific particulate

matter control regulations; Cameron County is not included in the list of areas subject
to this rule.
The fugitive dust control measures applicable to the Project that address the general requirements
in Chapter 101.4 and Chapter 111 are detailed in Section 4 below.
4 FUGITIVE DUST CONTROL MEASURES

The generation of fugitive dust during construction activities would be reduced through the
application of appropriate control measures. Abatement measures will be utilized as needed and
appropriate to a particular situation. Based on typical practices for the natural gas industry and
the requirements of the TCEQ, the following specific control measures will be used as needed to
control fugitive dust emissions for the Project.
• Properly maintain construction equipment and vehicles to minimize particulate matter

from exhaust.
2
• Utilize existing public and private roads and existing ROW for access during construction
wherever possible.
• Apply water as needed to all affected unpaved roads, unpaved haul/access roads, and
staging areas (when in use).
• When appropriate, apply a water/magnesium chloride mixture as needed as a dust

suppressant.
• Reduce vehicle speeds on all unpaved roads, and unpaved haul and access roads. Speed
limits would be set to 20 mph for unpaved roads in all areas, or in accordance with posted
public speed limits.
• Inspect paved road access points and clean up track-out and/or carry-out areas at paved
road access points at a minimum of once every 48 hours.
• Gravel pads may be installed adjacent to paved roadways to limit track-out, and clearly
established and enforced traffic patterns may be used to route traffic over track-out
control devices.
• For bulk transfer operations, spray handling and transfer points with water at least 15
minutes before use.
• Cover all haul truck loads, or maintain at least six inches of freeboard space in each cargo
compartment. Ensure that all haul truck cargo compartments are constructed and
maintained to minimize spillage and loss of materials, and clean or wash each cargo
compartment at the delivery site after removal of the bulk materials.
• Apply water to active construction areas as needed. Areas should be pre-watered and
soils maintained in a stabilized condition where support equipment and vehicles will
operate. Water disturbed soils to form a crust.
• For temporary surfaces during periods of inactivity, restrict vehicular access by means of
either fencing or signage, and apply water to comply with the stabilized surface
requirements.
Water trucks will be the primary means of dust abatement during all phases of construction.
Water spray will be controlled so that over-spraying and pooling will be avoided to the extent
possible. Where roads are paved, no dust mitigation, other than cleanup of track out, will be
used.
5 INSPECTION, MONITORING, AND

RECORDKEEPING
The Project contractors will implement the dust control measures specified in this plan. An
environmental inspector or other person with construction oversight will be primarily responsible
3
for monitoring and enforcing the implementation of needed dust control measures. The inspector
will also be responsible for making sure that dust control is effective and proper documentation
is maintained. All construction site personnel will be educated on the measures outlined in this
plan.
Field inspection for dust control will occur daily. The Project contractor(s) and the
environmental inspector will be responsible for recording the following information on a daily
basis:
• Weather conditions (temperature, wind speed, and direction);
• Number of water trucks in use;
• Cases where visible dust was of such a concentration that abatement measures were
implemented;
• Condition of project soils (crusted, damp, or unstable);
• Condition of project access roads (crusted, damp, or unstable);
• Presence of track-out and when it was cleaned;
• Overall status of dust control compliance.
This information will be incorporated into the environmental inspector’s daily report.
4
APPENDIX H
PROJECTS CONSIDERED IN THE CUMULATIVE IMPACT ASSESSMENT
TABLE H-1
Projects Identified within the Geographic Scope for Cumulative Impacts

Associated with the Annova LNG Project
Estimated Timeframe Distance from Resources Potentially Affected
Project/Activity (Construction/ Annova LNG within Annova LNG Project
(Reference # on Map) Operation) Project (mi) Project Size Geographic Scope
Proposed Project
Annova LNG Project 2019/2022 0 543 acres All
Potential Future LNG Export Projects

Rio Grande LNG 1,150 acres (LNG
All resources less geology, soils,
Project and Rio Bravo 2019/2026 0.3 Facility)
and cultural.
Pipeline (#4) 2,500 acres (Pipeline)
Texas LNG and All resources less geology, soils,
2019/2020 2.2 miles 311 acres
Pipeline (#5) and cultural.
Non-jurisdictional Facilities Associated with the Annova LNG Project
Natural Gas
2019/2021 On site 1.4 acres All
Interconnection (#1)
Electric Transmission 15 miles
2019/2021 Adjacent All
Line (#2) (100 acres)
Potable Water Supply 6 miles
Pipeline (#3) (30 acres)
Natural Gas Supply 9 miles
Lateral Pipeline (#20) (110) b/
Non-jurisdictional Facilities Associated with the Rio Grande LNG Project
LNG Trucking 12 to 15 tanker All resources less geology, soils,
Unknown 0.5 mile
(not mapped) trucks/day and cultural.
Potable Water and
5-6 miles All resources less geology, soils,
Sewer Services Lines 2018/2018 2.7 miles
(est. 3.3 acres) and cultural.
(#34,35)
Electric Transmission
12.7 miles All resources less geology, soils,
Lines 2019/2020 2.7 miles
(est. 142 acres) and cultural.
(#32,33)
Road Widening State 3 miles All resources less geology, soils,
2018/2018 2.0 miles
Highway 48 (#4) (est. 36.4 acres) b/ and cultural.
Non-jurisdictional Facilities Associated with the Texas LNG Project
Intrastate Natural Gas
10.2 miles All resources less geology, soils,
Pipeline 2019 0.9 mile
(108.3 acres) and cultural.
(not mapped)
State Highway 48 All resources less geology, soils,
2018 0.9 mile 0.5 acre
Auxiliary Lane (#36) and cultural.
Electric Transmission
11 miles All resources less geology, soils,
Line 2018 0.9 mile
(120.6 acres) and cultural.
(#32,33)
Potable Water Line All resources less geology, soils,
2020 0.9 mile 7.4 miles a/
(#34) and cultural.
Pipeline Projects
Valley Crossing
Pipeline (aka Nueces- Operational as of 168 miles All resources less geology, soils,
5 miles
Brownville Pipeline) 2018 (est. 2,546 acres) c/ and cultural.
(#21)
Rio Bravo Pipeline

(included with Rio All resources less geology, soils,
2018/2020 0.3 mile 2,500 acres
Grande LNG Project) and cultural.
(#31)
H-1 Projects Considered in the

Cumulative Impacts Assessment
TABLE H-1

Electric Transmission and Generation Projects
Tenaska Brownsville
Generating Station Unknown 15 miles 270 acres
visuals, noise and cultural.
(#24)
San Roman Wind Farm Operational as of All resources less geology, soils,
8 miles 156 acres
(#44) 2016 visuals, noise and cultural.
Cameron Wind Farm Operational as of All resources less geology, soils,
16 miles 15,000 acres
(#43) 2015 visuals, noise and cultural.
Cross Valley Project Operational as of 96 miles All resources less geology, soils,
6 miles
(#23) 2016 (est. 1,746 acres) d/ visuals, noise and cultural.
Palmas Altas Wind
Underway/2019 21 miles 6,500 acres Land Use, Socioeconomics
Project (not mapped)
Palmas to East Rio
6 miles
Hondo Transmission 2019 22 miles Land Use, Socioeconomics
(est. 73 acres)
Line (not mapped)
Transportation Projects
East Loop (State 6.7 miles All resources less geology, soils,
2019/Unknown 7.6 miles
Highway 32) (#29) (127 acres) visuals, noise and cultural.
South Padre Island 17.6 miles All resources less geology, soils,
2019/2022 7.6 miles
Second Access (#28) (240.6 acres) visuals, noise and cultural.
State Highway 4 All resources less geology, soils,
2018/2020 8.5 miles Unknown
Upgrade Project (#39) visuals, noise and cultural.
State Highway 100 and
106 Wildlife Crossings 2016/2017 6-14 miles 7.1 miles
(#37, 38)
State Highway 550
Direct Connector Operational 9.4 miles Approximately 10 miles
Project (#27)
Cameron County West
Approximately All resources less geology, soils,
Railroad Relocation Operational (2015) 15.8 miles
6 miles visuals, noise and cultural.
Project (#30)
Airport Terminal (#22) 2019 15 miles Unknown
Port of Brownsville Projects
Brownsville Liquids Operational as of All resources less geology, soils,
7.1 miles Unknown
Terminal 2 (#15) 2016 visuals, noise and cultural.
Brownsville Liquids All resources less geology, soils,
Operational 5 miles Unknown
Terminal Facility (#14) noise and cultural.
GEOTRAC Industrial All resources less geology, soils,
Unknown 7.9 miles 1,400 acres
Hub (not mapped) visuals, noise and cultural.
Port of Brownsville
Operational as of 600-foot marine cargo All resources less geology, soils,
Marine Cargo Dock 16 6.5 miles
August 2015 dock visuals, noise and cultural.
and Storage Yard (#17)
Centurion Brownsville
Terminal Processing All resources less geology, soils,
Ongoing/2017 9 miles 240 acres
and Storage Facility visuals, noise and cultural.
(#16)
Big River Steel Mill (not All resources less geology, soils,
Unknown Unknown 800 acres
mapped) visuals, noise and cultural.
Projects Considered in the H-2

TABLE H-1

Waterway Improvement Projects
Brazos Island Harbor
October 2017/ All resources less geology, soils,
Channel Improvement 0.14 mile 250-foot wide channel
February 2020 visuals, noise and cultural.
Project (#7)
Bahia Grande Channel Anticipated All resources less geology, soils,
0.3 mile Unknown
Restoration (#6) 2017/Unknown visuals, noise and cultural.
BSC and Turning Basin
Underway/ All resources less geology, soils,
Maintenance Dredging Adjacent Unknown
Ongoing visuals, noise and cultural.
(#8)
Bend Easing BSC
Improvement Project Unknown 5.8 miles Unknown --
(#12)
Port Isabel
Maintenance Dredging 3.5 miles Unknown
Ongoing noise and cultural.
(#9)
Gulf Intracoastal
Waterway Maintenance 5 miles Unknown
Ongoing noise and cultural.
Dredging (#10)
Other Projects and Activities Considered
SpaceX Commercial All resources less geology, soils,
2014/2018 6.3 miles 70 acres
Spaceport Project (#18) visuals and cultural.
STARGATE Facility All resources less geology, soils
Underway 4.3 miles 2.3 acres
(#48) and cultural.
South Padre Island
Complete/ All resources less geology, soils,
Beach Re-nourishment 7.1 miles 0.8 mile
Periodic noise and cultural
(#13)
Palo Alto Battlefield
Cultural Landscape Ongoing 9.2 miles Unknown
visuals and cultural.
Restoration (#53)
2,129 acres (total
Bahia Grande Coastal All resources less geology, soils,
Ongoing 7.6 miles acquisition is over
Corridor Project (#X) visuals and cultural.
7,000 acres)
a/ The non-jurisdictional potable waterline would be located within the same construction corridor as the non-jurisdictional
natural gas supply pipeline and would be constructed concurrently; therefore, the affected area is captured within the
natural gas pipeline acreage.
b/ Acreage is estimated based on an assumed 100-foot-wide construction corridor.
c/ Acreage is estimated based on an assumed 125-foot-wide construction corridor.
d/ Acreage is estimated based on an assumed 150-foot-wide construction corridor.
H-3 Projects Considered in the

APPENDIX I
CUMULATIVE CONSTRUCTION NOISE IMPACT ASSESSMENT
Technical Memorandum
To: Eric Tomasi
Environmental Engineer
From: David M. Jones, P.E, INCE Bd. Cert.

Principal Acoustical Engineer
SLR International Corporation
6001 Savoy Drive, Suite 215
Houston, Texas 77036
dmjones@slrconsulting.com
Date: May 30, 2018
Subject: Texas LNG Construction Noise Normalization for Cumulative Noise Impact Assessment
1. INTRODUCTION
At the request of Perennial Environmental, SLR International Corporation (SLR) has been acting
as the Federal Energy Regulatory Commission (FERC) third-party reviewer for noise components
of the Texas LNG Project. As part of this review, SLR has been compiling the cumulative noise
impact section of the Draft Environmental Impact Statement (DEIS) for the Project. The
cumulative impact section assesses the potential cumulative effects from all reasonably
foreseeable future actions in the geographic scope of the Texas LNG project. There are two other
LNG projects proposed for the geographic area of the Texas LNG project: the Annova LNG and
the Rio Grande LNG projects.
2. CONSTRUCTION NOISE PREDICTIONS
Each of the three LNG projects calculated the construction sound level contributions at a set of
project-specific noise sensitive areas (project NSAs) using slightly different sound level metrics.
As part of the cumulative assessment, SLR has developed a set of cumulative NSAs and
calculation points (CPs). There were two CPs representing locations at which noise impacts might
be of concern but which were not NSAs: the observation platform for the Palmito Ranch Battlefield
National Historic Landmark and a location in the Laguna Atascosa National Wildlife Refuge
(LANWR). The cumulative NSAs were generated from the combination of the three sets of project
NSAs by combining NSAs in close proximity and removing duplicated NSA locations. Table 1,
below, summarizes the NSAs and metrics used for each project.
SLR International Corporation, 6001 Savoy Drive, Suite 215, Houston, TX 77036-3322
713 789 9400 slrconsulting.com
May 30, 2018

Texas LNG – Cumulative Construction Noise Methodology
Page 2
Table 1: Summary of NSAs and Sound Level Metrics

Number of NSAs
that Correspond Construction
Number with Cumulative Evaluation
Project of NSAs NSAs Metric Comment
Annova LNG 4 4 24-hour Ldn 24-hour Construction
Rio Grande LNG 4 4 Lmax / Leq Daytime only construction
Construction includes 24-
hours per day dredging, 10-
hours per day other
Texas LNG 3 2 24-hour Ldn
construction - Concurrent
with 24-hour operations of
Phase 1 equipment
The project NSAs did not necessarily coincide with the full set of cumulative NSAs. As such, it was
necessary to predict the sound levels at those cumulative NSAs for which there is not
corresponding project NSA. In order to sum the sound level contributions of the three different
projects, the sound levels were predicted for the cumulative set of NSAs and CPs and the metrics
for the different projects had to be standardized so that they could be compared.
2.1. Propagation Calculations
Each project predicted construction sound levels at a specific set of project NSAs closest to that
project. Using a standard hemispherical spreading formula, SLR used these predicted sound
levels, along with the distances from the acoustic center of each project to the project NSAs and
standardized cumulative NSAs or CPs, to predict the sound levels at the standardized cumulative
NSAs or CPs.
The hemispherical spreading formula is: Lp2 = Lp1 + 20 x log10 (Distance1 / Distance2)
Where Lp1 is the sound pressure level at Distance1 and Lp2 is the sound pressure level at
Distance2. Distances must be in the same units.
This is a conservative calculation methodology as it does not account for additional propagation
losses due to atmospheric absorption, ground effect, foliage, or terrain effects. It will thus tend to
overestimate the potential construction sound levels.
Table 2 shows a summary of the sound levels as predicted by each project at the project-specific
NSAs, the distance from the NSAs to the project acoustic center, and the distance from the
acoustic center to the cumulative NSA points. For those cumulative NSAs or CPs at which there is
no corresponding project NSA, the sound levels have been calculated by using the predicted levels
at the project NSA in parenthesis and propagating them to the cumulative NSA distance. Sound
levels that have been calculated in this manner are shown as shaded and italicized values.
SLR International Corporation slrconsulting.com

May 30, 2018

Page 3
Table 2: Summary of LNG Project Construction Sound Levels at the Cumulative NSAs / CPs
Predicted Predicted
Distance from Existing
Project-Specific Construction Construction
Cumulative NSA / CP to Sound
NSA Sound Level Sound Level
NSA / CP Project Level
Designation Contribution Contribution
miles (Ldn dBA) (Leq dBA) (Ldn dBA)
ANNOVA LNG
NSA C1 NSA 1 4.2 56.0 49.0
a
NSA C2 (NSA 2) 5.2 50.2 47.1
a
NSA C3 (NSA 2) 5.4 50.2 46.8
NSA C4 NSA 2 4.6 46.0 48.0
N/A
NSA C5 NSA 3 2.3 46.0 54.0
a
NSA C6 (NSA 2) 3.9 46.0 49.8
CP 1 NSA 4 3.3 43.0 52.0
a
CP 2 (NSA 2) 1.7 59.0 56.9
RIO GRANDE LNG
NSA C1 NSA 2 3.7 56.0 52.2 49.2
NSA C2 NSA 3 3.7 50.2 46.1 43.1
NSA C3 NSA 4 3.9 50.2 45.7 42.7
a
NSA C4 (NSA 2) 4.9 46.0 49.7 46.7
NSA C5 NSA 1 5.5 46.0 50.9 47.9
a
NSA C6 (NSA 2) 5.4 46.0 49.0 46.0
Palmito Ranch
CP 1 BF 5.4 43.0 42.9 39.9
CP 2 LANWR 0.8 59.0 51.7 48.7
TEXAS LNG
a
NSA C1 (NSA 2) 2.7 56.0 50.3
NSA C2 NSA 2 1.6 50.2 54.9
NSA C3 NSA 3 1.7 50.2 54.6
a
NSA C4 (NSA 2) 4.4 46.0 45.9
a
N/A
NSA C5 (NSA 2) 5.5 46.0 44.1
a
NSA C6 (NSA 2) 7.3 46.0 41.6
a
CP 1 (NSA 2) 6.8 43.0 42.2
a
CP 2 (NSA 2) 1.7 59.0 54.3
a
Sound levels at this cumulative NSA were not calculated by the project for construction noise. Sound levels at the
project NSA in parenthesis were propagated to the cumulative NSA or CP distance as described in this memo.
2.2. Sound Level Metric Normalization
The three different LNG projects include varying degrees of detail about the construction noise
calculations and schedules. Rio Grande LNG included only daytime sound levels (as Leq values)
for construction, as those activities would only occur during the day. Annova LNG and Texas LNG
included 24-hour Ldn values for construction based on daytime and nighttime activities. For

May 30, 2018

Page 4
Annova LNG, all construction activities are assumed for 24-hours per day. For Texas LNG,
general site preparation construction is included for 10 daytime hours per day, but dredging and
the Phase 1 operational noise sources are based on 24 hours per day.
In order to combine the sound levels from the three different projects, the sound level metrics had
to be standardized. The 24-hour Ldn was chosen as the standardized metric because it is the
standard FERC and EPA sound level metric, and it was used by two of the projects.
The equivalent sound level (Leq) is the sound level that has the same (equivalent) sound energy as
all of the sounds measured during a given period. If a noise source generates a sound level of 50
dBA over a one-hour period, it would produce a one-hour Leq of 50 dBA. If the noise source
generated a sound level of 50 dBA for half of the hour, but generated no noise during the other half
of the hour, the one-hour Leq would drop by three decibels, to 47 dBA, as a three decibel decrease
indicates a halving of the sound energy.
The Rio Grande LNG construction activities will take place for 12-hours a day, from 7:00 am until
7:00 pm during daylight hours only. As the Rio Grande LNG construction will take place during the
daytime for 12 hours (or half of the total hours in a day), the 24-hour Ldn will be three decibels
lower than the predicted sound level Leq during the 12-hour construction shift. The Rio Grande
LNG construction sound level contributions have been calculated by subtracting three decibels
from the given Leq.
3. CUMULATIVE ASSESSMENT
In order to predict the potential cumulative impact of construction noise from all three of the
projects during simultaneous construction activities, the predicted sound levels, as Ldn values, can
be logarithmically combined at each of the standardized cumulative assessment NSAs or CPs.
This prediction would be a worst-case construction noise assessment, as it would combine the
maximum construction noise contributions from all three LNG projects.
4. CONCLUSION
To allow comparison and cumulative assessment for the predicted construction sound levels from
the three LNG projects, the sound levels had to be assessed in terms of a common set of NSAs
and Calculation Points. In addition, the metric used to present the sound levels had to be
normalized. The sound levels from each project have been predicted at a set of standardized
cumulative NSAs and CPs from the provided project construction noise levels using a standard
hemispherical spreading formula. The sound level metrics have been normalized to use the FERC
standard 24-hour Ldn for all construction noise. The results of the standardization and
normalization are shown in Table 2.

APPENDIX J
LIST OF PREPARERS
APPENDIX J
LIST OF PREPARERS AND REVIEWERS
Tomasi, Eric – Project Manager, Air Quality and Noise, Cumulative Impacts
B.S., Aerospace Engineering, 1994, Boston University
Armbruster, Ellen – Cultural Resources

M.A., Anthropology, 1986, University of Pennsylvania
B.A., Anthropology, 1979, Bryn Mawr College
Dague, Brady – LNG Reliability and Safety

B.S., Civil Engineering, University of Maryland, 2010
Patel, Ghanshyam – LNG Reliability and Safety

B.S., Chemical Engineering, Pennsylvania State University, 2004
Peconom, John – Vegetation and Wildlife, Special Status Species

B.S., Biology and Management, 2000, University of California, Davis
Rana, Anthony – Geology, Soils

M.S., International Development, Tulane University, 2012
Graduate Studies, Hydrogeology and Geochemistry, Oklahoma State University, 1988
B.S., Geology, New Jersey City University, 1984
FERC LNG Consultants
Bachman, Robert – LNG Reliability and Safety

M.S., Structural Engineering, University of California at Berkeley, 1968
B.S., Civil Engineering, University of California at Berkeley, 1967
Bhushan, Kul – LNG Reliability and Safety

Ph.D., Geotechnical Engineering, Duke University, 1970
M.S., Highway Engineering, Panjab University, India, 1963
B.S., Civil Engineering, Panjab University, India, 1962
Stebbing, Roger – LNG Reliability and Safety

B.S., Chemical Engineering, University of Salford, England, 1968
FERC Third-Party Contractor – Tetra Tech, Inc.
Scott, John G. – Project Manager, Alternatives

M.S., Wildlife and Fisheries Science, 1995, Pennsylvania State University
B.S., Natural Resources Management, 1983, Cornell University
J-1 List of Preparers and Reviewers

Crookston, John – Deputy Project Manager

M.S., Ecology, 2007, San Diego State University
B.A., Biology, 2002, University of California, San Diego
Andrews, Emmy – Noise

M.S., Environmental Management, 2005, University of San Francisco
B.A., Art and Art History, 1998, Duke University
Brimacombe, Karen – Wetlands and Vegetation

M.S., Botany/Ecology/Evolution/Conservation/Biology Specialization, 2003, University
of Hawai'i
B.A., Psychology, 1992, Miami University
Cox, Dave – Cumulative Effects

B.S., Environmental & Engineering Geology, 2000, Western Washington University
Dadswell, Matt – Land Use, Socioeconomics, Environmental Justice

Post-Masters Study (ABD), Economic Geography, 1997, University of Washington
M.A., Economic Geography, 1990, University of Cincinnati
B.A., (Joint Honours) Economics and Geography, 1988, Portsmouth Polytechnic,
England
Dillon, Peter – Geology, Soils, Groundwater Resources

M.S., Geology (Geochemistry), 1994, Boston College
B.S., Geology, 1983, Boston College
Gravender, David – Technical Editing

M.A., English, 1991, University of Toronto
B.A., English, 1990, University of Washington
King, Erin – Cultural Resources

M.A., Cultural Anthropology, 2005, California State University, Northridge
B.A., Cultural Anthropology, 2001, University of California, Santa Barbara
Kraus, Jennifer – Surface Water Resources

Certificate, Wetlands Science and Management, 2001, University of Washington,
College of Continuing Education
B.S., Environmental Science and Biology, 1994, Marist College
Mire, June – Marine Resources, Threatened and Endangered Species

Ph.D., Zoology, 1993, University of California at Berkeley
M.S., Biological Sciences, 1987, University of New Orleans
B.A., Science Education, 1984, University of New Orleans
List of Preparers and Reviewers J-2

Ritchie, Annalissa – Visual Resources

M.S., Forest Resources, 2007, University of Washington,
B.S., Zoology, 2003, University of Washington
B.F.A., Photography, 2003, University of Washington
Scheinost, Nikki – Wildlife, Threatened and Endangered Species

B.S., Geography – Resource and Environmental Studies, Minor in Biology, 2002, Texas
State University
Williams, Chris – Air Quality

B.S., Chemical Engineering, 1998, Massachusetts Institute of Technology
Tetra Tech, Inc. is a third-party contractor assisting the Commission staff in reviewing the
environmental aspects of the project application and preparing the environmental documents required
by the National Environmental Policy Act. Third-party contractors are selected by Commission staff
and funded by project applicants. Per the procedures in Title 40 Code of Federal Regulations Part
1506.5(c), third-party contractors execute a disclosure statement specifying that they have no financial
or other conflicting interest in the outcome of the project. Third-party contractors are required to self-
report any changes in financial situation and to refresh their disclosure statements annually. The
Commission staff solely directs the scope, content, quality, and schedule of the contractor’s work. The
Commission staff independently evaluated the results of the third-party contractor’s work and the
Commission, through its staff, bears ultimate responsibility for full compliance with the requirements
of the National Environmental Policy Act.
J-3 List of Preparers and Reviewers

APPENDIX K
LIST OF REFERENCES
Aaron Economic Consulting. 2015. City of South Padre Island Economic Index. September 2015. Website:
http://southpadreislandedc.com/resources-studies (accessed March 16, 2016).
Abbott, R., E. Bing-Sawyer, and R. Blizard. 2002. Assessment of pile driving impacts on the Sacramento
blackfish (Othodon microlepidotus). Draft report prepared for Caltrans District 4. October 10, 2002.
Sacramento, CA.
AIChE CCPS. 1996. Guidelines for Evaluating Process Plant Buildings for External Explosions and Fires.
September 15. 189 pp.
Alsop, F.J. III. 2001. Smithsonian Birds of North America. Southern Lights Custom Publishing.
American Birding Association. 2015. Birding Trails in North America. Website:

http://aba.org/resources/birdingtrails.html (accessed February 16, 2016).
Anderson, J.D., D.J. Shaver, and W.J. Karel. 2013. Genetic diversity and natal origins of green turtles
(Chelonia mydas) in the western Gulf of Mexico. Journal of Herpetology 14(2):251–257.
Ashworth, J.B., and J. Hopkins. 1995. Aquifers of Texas. Texas Water Development Board Report 345.
Website:
http://www.twdb.texas.gov/publications/reports/numbered_reports/doc/R345/R345Complete.pdf
(accessed August 2016).
Attewell, P.B., and I.W. Farmer. 1973. Attenuation of ground vibrations from pile driving. Ground
Engineering, July 1973.
Baker, E.T., Jr. 1995. Stratigraphic Nomenclature and Geologic Sections of the Gulf Coastal Plain of
Texas. USGS Open-File Report 94-461. Website: http://pubs.usgs.gov/of/1994/0461/report.pdf
Barnes, J.D., L.N. Miller, and E.W. Wood (Barnes et al.). 1977. Power Plant Construction Noise Guide,
Report No. 3321. Bolt, Beranek, and Newman, Incorporated.
Bartol, S., and I. Bartol. 2011. Hearing Capabilities of Loggerhead Sea Turtles (Caretta caretta) throughout
Ontogeny: An Integrative Approach involving Behavioral and Electrophysiological Techniques.
Final Project Report.
Bartol, S.M., and D.R. Ketten. 2006. Turtle and tuna hearing. In Y. Swimmer and R. W. Brill (Eds.), Sea
Turtle and Pelagic Fish Sensory Biology: Developing Techniques to Reduce Sea Turtle Bycatch in
Longline Fisheries. (NOAA Technical Memorandum NMFS-PIFSC-7, pp. 98-103). U.S.
Department of Commerce, National Oceanic and Atmospheric Administration.
Bartol, S.M., J.A. Musick, and M.L. Lenhardt. 1999. Auditory evoked potentials of the loggerhead sea
turtle (Caretta caretta). Copeia 3: 836-840.
Bearden, S. 2015. Port Director, Port Isabel-San Benito Navigation District. Personal communication with
K. Welder, Ecology and Environment, Inc., on July 17, 2015.
Beier, P. 2005. Effects of artificial night lighting on terrestrial mammals. In: Ecological Consequences of
Artificial Night Lighting, C. Rich and T. Longcore (eds.), 19–42.
K-1 List of References

Black & Veatch. 2016a. Seismic Ground Motion Hazard Study, Annova LNG Brownsville Project.
Document Number 183169‐STDY‐0008. March 21, 2016.
Black & Veatch. 2016b. Geotechnical Investigation Report, Annova LNG Brownsville Project. Document
Number 183169‐STDY‐0006. March 21, 2016.
Black & Veatch. 2016c. Hydrodynamic Modeling. Document Number 183169-REFF-0027. Prepared for
Annova LNG, LLC. November 30.
Black & Veatch. 2016d. Analysis of Turbidity due to Dredging, Annova LNG Brownsville Project.
Document Number 183169‐REFF‐0027. April 28, 2016.
Black & Veatch. 2016e. Sedimentation Modeling. Document Number 183169-REFF-0050. Prepared for
Annova LNG, LLC. December 20.
Black & Veatch. 2016f. Beneficial Use Concepts for Dredged Material.
Black and Veatch. 2016g. Brownsville LNG Terminal Ambient Sound Level Survey Report. B&V
PROJECT NO. 181108. B&V FILE NO. 42.1000.
Blair, W.F. 1950. The biotic provinces of Texas. Texas Journal of Science 2:93-117.
Blanton & Associates, Inc. 2017. Draft Conceptual Mitigation Plan, Annova LNG Brownsville Project,
Cameron County, Texas. U.S. Army Corps of Engineers Project Number: SWG-2015-00110.
Prepared for Ecology and Environment, Inc. Prepared by Blanton & Associates, Inc. Lakeway,
Texas.
BLM (U.S. Department of the Interior, Bureau of Land Management). 1986. Manual 8431 – Visual Contrast
Rating. Website: http://blmwyomingvisual.anl.gov/docs/BLM_VCR_H-8431.pdf
BLM. 2008. Standard Environmental Colors Chart CC-001: June 2008. Website:
https://www.blm.gov/style/medialib/blm/mt/blm_programs/energy/oil_and_gas/operations/gold_b
ook.Par.82194.File.dat/Stand_Enviro_Color.pdf
BND (Brownsville Navigation District). 2012a. Port of Brownsville Leasing Policies. Date issued
November 20, 2012. Website: http://www.portofbrownsville.com/wp-
content/uploads/2013/01/Leasing-Policy.pdf (accessed May 13, 2015).
BND. 2012b. Port of Brownsville World Class Facts. Website: http://www.portofbrownsville.com/facts

(accessed May 2015).
BND. 2014. Brownsville Navigation District Proposed LNG lease sites figure. Last revision: December 19,
2014.
BND. 2015a. Brownsville Navigation District, Port of Brownsville. Letter to Andre Senenko at Annova
LNG, LLC dated September 4, 2015 regarding the availability of land for LNG facility
development.
BND. 2015b. Comprehensive Annual Financial Report for Year Ended December 31, 2014. Finance
Department. Website: http://www.portofbrownsville.com/wp-content/uploads/2013/06/CAFR-
SEC-1.pdf
List of References K-2

BND. 2016. Cargo and vessel statistics, 2012-2014. Provided by Deborah Duke, Director of Administrative
Services and Public Information Officer, Port of Brownsville, on June 18, 2016, to K. Welder
Mollow, Ecology and Environment, Inc.
BND. 2017. Comprehensive Annual Financial Report 2016. http://www.portofbrownsville.com/wp-

content/uploads/2017/01/BND-CAFR-2016.pdf. Accessed July 2017.
BOEM (Bureau of Ocean Energy Management). 2011. Outer Continental Shelf Oil and Gas Leasing
Program: 2012 – 2017. Draft Programmatic Environmental Impact Statement. November 2011.
Brownsville Economic Development Council. 2015. 2014-2015 Market and Community Profile. Website:
http://brownsvillechamber.com/wp-content/uploads/2015/06/Market-Community-Profile-2014-
2015-1.pdf (accessed February 26, 2016).
Brownsville Public Utilities Board. 2013. Water and Wastewater Department. Website:
http://www.brownsville-pub.com/departments/water-wastewater (accessed by Ecology and
Environment, Inc. on April 19, 2016).
Brownsville Public Utilities Board. 2016. Comprehensive Annual Financial Report for the Fiscal Years
Ended September 30, 2015 and 2014. Website: http://www.brownsville-pub.com/about-
us/financial (accessed by Ecology and Environment, Inc. on April 19, 2016).
Brownsville, Texas Code of Ordinances. n.d. Available at: Brownsville, Texas, Code of Ordinances,
Chapter 46, Article III. Accessed November 25, 2014.
Burger, J. 1981. Effect of human activity on birds at a coastal bay. Biological Conservation 21:231–241.
Burnham, W., J. P. Jenny, W. R. Heinrich, G. Hunt, A. B. Montoya, B. D. Mutch, and C. E. Sandfort. 2002.
Proposal: restoration of the northern aplomado falcon in New Mexico. The Peregrine Fund. Boise,
Idaho.
California Department of Transportation. 2001. Fisheries impact assessment, pile installation

demonstration project, San Francisco-Oakland Bay Bridge, East Span Seismic Safety Project.
Cameron County Parks and Recreation. 2016. Jaime J. Zapata Memorial Boat Ramp Fishing Pier and Kayak
Launch Area. Website: http://www.cameroncountyparks.com/jaime-zapata-hwy-48
Cameron County. 2009. ESD Fire Protection Zone Map. Prepared by the Cameron County GIS Department.
Plot Date April 6, 2009. Website: http://www.co.cameron.tx.us/dot/docs/THE_FIRE_ZONES.pdf
(accessed August 31, 2016).
Cameron County. 2016. Comprehensive Annual Financial Report for the Fiscal Year Ended September 30,
2015. Prepared by Martha Galarza, CPA, County Auditor. March 30. Website:
http://www.co.cameron.tx.us/document_center/FINAL%20CAFR%202015-NEW.pdf (accessed
August 3, 2016).
Campbell, Linda. 2003. Endangered and Threatened Animals of Texas, Their Life History and
Management. Website:
https://tpwd.texas.gov/publications/pwdpubs/media/pwd_bk_w7000_0013.pdf (accessed April
2016).

Caso, Arturo. 2013. Spatial Differences and Local Avoidance of Ocelot (Leopardus pardalis) and
Jaguarundi (Puma yagouaroundi) in Northeast Mexico. Website:
http://smallcats.org/files/Caso_2013.pdf (accessed April 2016).
Caterpillar. 2007. VM 20 C Project Guide: Generator Set. Caterpillar Motorem Gmblt & Co. KG. Kiel
Germany. April 2007.
Germany. August 2011.
Germany. August 2012.
CCRAM (Cameron County Regional Mobility Authority). 2015. East Loop. CCRMA: Our Projects.
Available online at: https://ccrma.org/project/east-loop/. Accessed September 2018.
CEDA (Central Dredging Association). 2011. Underwater sound in relation to dredging. Central Dredging
Association Position Paper, Prepared by the CEDA Working Group on Underwater Sound under
the remit of the CEDA Environment Commission. Available at:
www.dredgingtoday.org/news_details.asp.
CEQ (Council on Environmental Quality). 1997a. Environmental Justice Guidance under the National
Environmental Policy Act. Executive Office of the President. Washington, D.C. December 10.
Website: http://www.epa.gov/compliance/resources/ policies/ej/index.html
CEQ. 1997b. Considering Cumulative Effects Under the National Environmental Policy Act. Available
online at: https://www.energy.gov/nepa/downloads/considering-cumulative-effects-under-
nationalenvironmental-policy-act-ceq-1997. Accessed September 2018.
CEQ. 2005. Guidance on the Consideration of Past Actions in Cumulative Effects Analysis. Available at:
http://www.gsa.gov/portal/mediaId/137134/fileName/CEQ_Guidance_Consideration_PastAction
s_CumulativeEffectsAnalysis.action. Accessed June 26, 2016.
Chapa, S. 2015. School board votes down tax break for LNG project at Port of Brownsville. San Antonio
Business Journal. September 17. Website: http://www.bizjournals.com/sanantonio/blog/eagle-
ford-shale-insight/2015/09/school-board-votes-down-tax-break-for-lng-project.html
Cheniere Energy, Inc. 2016. Corpus Christi Liquefaction, LLC (Corpus Christi Liquefaction) Project
Information Website. Website: http://www.cheniere.com/corpus_christi/corpus_project.shtml
(accessed March 13, 2016).
Chowdhury, A.H., and R.E. Mace. 2007. Groundwater resource evaluation and availability model of the
Gulf Coast aquifer in the Lower Rio Grande Valley of Texas. LBG-Guyton Association.
Chowdhury, A.H., and M.J. Turco. 2006. Geology of the Gulf Coast Aquifer, Texas. Website:
https://www.twdb.texas.gov/publications/reports/numbered_reports/doc/R365/ch02-Geology.pdf
Chron. 2010. Brownsville Ship Channel full of surprises. Website:

http://blog.chron.com/saltwater/2010/08/brownsville-ship-channel-full-of-surprises/ (accessed
January 2016).

City of Brownsville. 2012. Search results for “Future Land Use Introduction”, Brownsville Comprehensive
Plan. Website: http://planning.cob.us/system/app/pages/search?scope=search-
site&q=future+land+use+introduction (accessed March 24, 2015).
City of Brownsville. 2015. City of Brownsville Zoning Map. Website:

https://docs.google.com/a/cob.us/viewer?a=v&pid=sites&srcid=Y29iLnVzfHBsYW5uaW5nfGd4
OjQ4OWMzY2ZmMjY3ZDE3NTQ (accessed by Ecology and Environment, Inc. on June 23,
2015).
City of Brownsville Public Works. 2016. The City of Brownsville Municipal Solid Waste Landfill. Website:
http://publicworks.cob.us/business (accessed August 31, 2016).
Clarke, D., C. Dickerson, and K. Reine. 2002. Characterization of underwater sounds produced by dredges.
Dredging 2002, ASCE, Orlando, Florida, USA, p 64-81.
Clark, Steve. 2018a. Local airport project advances. The Brownsville Herald, April 7, 2018. Available
online at: https://www.brownsvilleherald.com/premium/local-airport-projectadvances/
article_1ab128b2-3acb-11e8-b0df-3f604257b40e.html. Accessed February 2019.
Clark, Steve. 2018b. Steel company selects local site. The Brownsville Herald, April 25, 2018. Available
online at: https://www.brownsvilleherald.com/business/steel-company-selectslocal-
site/article_1b693cd6-4a34-11e8-8789-6b734a4d7fa7.html. Accessed February 2019.
Coast Guard (U.S. Coast Guard). 2008. Final Environmental Impact Statement for the Bienville Offshore
Energy Terminal Deepwater Port License Application. Docket No. USCG-2006-24644. August
2008. Federal Docket Management system is available at http://www.regulations.gov.
COE (U.S. Army Corps of Engineers). 1982. Department of the Army, Galveston District, Corp of
Engineers, letter to Brownsville Navigation District, Subject Permit 13942, October 5, 1982.
COE. 1987. Corps of Engineers Wetland Delineation Manual. Environmental Laboratory. Wetlands
Research Program Technical Report Y-87-1 (online edition). U.S. Army Corps of Engineers
Waterways Experiment Station. Website:
http://www.bwsr.state.mn.us/wetlands/publications/corpsmanual.pdf (accessed August 2016).
COE. 2003. Biological Assessment for Impacts to Endangered and Threatened Species Relative to the
Corpus Christi Ship Channel Improvement Project in Nueces and San Patricio Counties, Texas.
Volume II, Appendix C of : Corpus Christi Ship Channel, Channel Improvements Project Corpus
Christ and Nueces Bays, Nueces and San Patricio Counties, Texas, Final Environmental Impact
Statement. Galveston.
COE. 2010. Regional Supplement to the Corps of Engineers Wetland Delineation Manual: Atlantic and
Gulf Coast Plain Region (Version 2.0). Environmental Laboratory. ERDC/EL TR-10-20. Website:
http://www.usace.army.mil/Portals/2/docs/civilworks/regulatory/reg_supp/AGCP_regsupV2.pdf
COE. 2012. A Community-based Ecosystem Response Model for the Resacas (Oxbow Lakes) of the Lower
Rio Grande. Website: http://el.erdc.usace.army.mil/elpubs/pdf/trel12-31.pdf (accessed January
2016).

COE. 2013a. Brazos Island Harbor, Texas, Channel Improvement Project, Draft Integrated Feasibility
Study – Environmental Assessment. Website:
EA%202013.pdf (accessed June 2015).
COE. 2013b. Draft Biological Assessment for federally-listed threatened and endangered Species. Brazos
Island Harbor Channel Improvement Project, Tentatively Selected Plan (52 feet by 250 feet
Project), Cameron County, Texas. June 2013.
COE. 2014. Brazos Island Harbor, Texas Channel Improvement Project, Final Integrated Feasibility Report
– Environmental Assessment. Website:
EA%202013.pdf (accessed September 2016).
COE. 2015. USACE Galveston District awards $6.9 million contract to dredge Brownsville Ship Channel,
Port Isabel Channel. Available at: http://www.swg.usace.army.mil/Media/News-
Releases/Article/606508/usace-galvestondistrict-awards-69-million-contract-to-dredge-
brownsville-ship/.
Conant, R., and J.T. Collins. 1998. Reptiles and Amphibians of Eastern/Central North America, 3rd edition.
Peterson Field Guides. New York, New York: Houghton Mifflin Company.
Cornell Lab of Ornithology. 2015. The Birds of North American Online. Accessed May 2015
http://bna.birds.cornell.edu/bna Eds. M. Simmonds, S. Dolman, and L. Weilgart. Wiltshire,
England.
Cornell Lab of Ornithology. 2017. Whooping Crane. Website:

https://www.allaboutbirds.org/guide/Whooping_Crane/lifehistory
Countess Environmental. 2006. WRAP Fugitive Dust Handbook. Western Governor’s Association,
Denver, Colorado. September 7. Website:
https://www.wrapair.org/forums/dejf/fdh/content/FDHandbook_Rev_06.pdf
Cowardin, L.M., V. Carter, F. Golet, and E. LaRoe. 1979. Classification of Wetlands and Deepwater
Habitats of the United States. U.S. Fish and Wildlife Service Report No. FWS/OBS/-79/31.
Cox, P., and R. Risi. 2009. Cryogenic Pipeline – How the use of cryogenic piping can reduce the impact of
LNG transfer terminals on environment and local communities, while increasing site safety and
security. Printed in Offshore Technology Conference. Website:
https://www.onepetro.org/conference-paper/OTC-20223-MS
D.K. Shifflet & Associates, Ltd. 2015a. Year-End 2014 Texas Tourism Visitor Profile. Website:
http://travel.texas.gov/tti/media/PDFs/2014-Texas-Visitor-Profile.pdf (accessed March 16, 2016).
D.K. Shifflet & Associates, Ltd. 2015b. 2014 Texas Tourism Region and MSA Visitor Profile: Gulf Coast
Region. Website: http://travel.texas.gov/tti/media/PDFs/2014-Gulf-Coast-Region.pdf (accessed
March 16, 2016).
Dannenbaum Engineering Corporation and URS Corporation. 2004. Feasibility Study. Brownsville
Seawater Desalination Demonstration Project. Prepared for Brownsville Public Utilities Board,
Port of Brownsville. November 2004.

Dean Runyan Associates. 2015. The Economic Impact of Travel on Texas 1990-2014p. June 2015.
Prepared for Texas Tourism Office of the Governor Texas Economic Development & Tourism.
Dean Runyan Associates, Portland, Oregon. Website: http://travel.texas.gov/travel-
research/economic-impact/ (accessed March 16, 2016).
DOE (United States Department of Energy). 2014. Division of Fossil Energy, Order No. 3394 Granting
Long-Term Multi-Contract Authorization to Export Liquefied Natural Gas by Vessel from the
Proposed Annova LNG Terminal in Brownsville, Texas, to Free Trade Agreement Nations.
February 20, 2014.
DOE. 2015a. Division of Fossil Energy, Order No. 3638 Granting Long-Term Multi-Contract
Authorization to Export Liquefied Natural Gas by Vessel from the Proposed Corpus Christi
Liquefaction Project to be Located in Corpus Christi, Texas, to Free Trade Agreement Nations.
May 12, 2015.
DOE. 2015b. Division of Fossil Energy, Order No. 3716 Granting Long-Term Multi-Contract
Authorization to Export Liquefied Natural Gas by Vessel from the Proposed LNG Terminal in
Brownsville, Texas, to Free Trade Agreement Nations. September, 2015.
DOE. 2015c. Division of Fossil Energy, Docket No. 15-190-LNG Application for Long-Term Multi-
Contract Authorization to Export Liquefied Natural Gas to Free Trade Agreement and Non-Free
Trade Agreement Countries. December 23, 2015.
Dow Piniak, W. E., S. A. Eckert, C. A. Harms, and E. M. Stringer. 2012. Underwater Hearing Sensitivity
of the Leatherback Sea Turtle (Dermochelys coriacea): Assessing the Potential Effect of
Anthropogenic Noise. (BOEM 2012-01156, pp. 35). Herndon, VA: U.S. Department of the Interior,
Bureau of Ocean and Energy Management.
Duke, D. 2015. Director of Administrative Services and Public Information Officer, Port of Brownsville.
Personal communication with K. Welder, Ecology and Environment, Inc., on August 21.
eBird. 2015. Range and Point Maps. Website: http://ebird.org/ebird/map.
Enger, P.S. 1981. Frequency Discrimination in Teleosts - Central or Peripheral. p. 243-255 In: Hearing
and Sound Communication in Fishes, eds. W.N. Tavolga and A.N. Popper. New York: Springer-
Verlag.
Engle, V.D., J.K. Summers, and J.M. Macauley. 1999. Dissolved oxygen conditions in northern Gulf of
Mexico estuaries. Environmental Monitoring and Assessment 57:1-20.
EPA (U.S. Environmental Protection Agency). 1971. Noise from Construction Equipment and Operations,
Building Equipment, and Home Appliances, USEPA Publication NTID300.1, December 1971.
EPA. 1974. Information on Levels of Environmental Noise Requisite to Protect Public Health and Welfare
with an Adequate Margin of Safety. Office of Noise Abatement and Control. March 1974.
EPA. 1998. Final Guidance for Incorporating Environmental Justice Concerns in EPA's NEPA Compliance
Analyses. April. Website: http://www.epa.gov/compliance/resources/policies/ej/index.html.

EPA. 1999a. The Ecological Condition of Estuaries in the Gulf of Mexico. EPA 620-R-98- 004, July 1999.
EPA Office of Research and Development, National Health and Environmental Effects Research
Laboratory, Gulf Ecology Division, Gulf Breeze, Florida. http://www.epa.gov/ged/gulf.htm.
EPA. 1999b. Consideration of Cumulative Impacts in EPA Review of NEPA Documents. EPA 315-R-99-
002, May 1999. Available online at: https://www.epa.gov/sites/production/files/2014-
08/documents/cumulative.pdf Accessed September 2018.
EPA. 2008. Sole Source Aquifer Recharge Area. Website:

http://www.rd.usda.gov/files/TX_21SoleSourceAquiferRechargeArea.pdf (accessed August
2016).
EPA. 2011. Ballast Water Self Monitoring EPA 800-R-11-003. Website: http://www3.epa.gov/npdes/
pubs/vgp_ballast_water.pdf (accessed January 2016).
EPA. 2016. Surf Your Watershed. South Laguna Madre Watershed – 12110208. Website:
https://cfpub.epa.gov/surf/huc.cfm?huc_code=12110208 (accessed August 2016).
EPA. 2017. Sole Source Aquifers for Drinking Water. Intractive map of SSAs. Website:
https://www.epa.gov/dwssa (accessed April 2017).
EPA. 2018. Emissions & Generation Resource Integrated Database (eGRID). eGrid2016, released 2/15/18.
https://www.epa.gov/energy/emissions-generation-resource-integrated-database-egrid
EPA and COE. 1998. Evaluation of Dredged Material Proposed for Discharge in Waters of the U.S. –
Testing Manual, Inland Testing Manual. EPA-823-B-98-004. February 1998. Available at
https://clu-in.org/download/contaminantfocus/sediments/Evaluation-Analytical-methods-USACE-
EPA.pdf
ERCOT. 2017. Quick Facts (2/2017). Website: http://www.ercot.com/content/wcm/lists/114739/

ERCOT_Quick_Facts_22317.pdf
Ernst & Young. 2015. Project Annova. The Potential Economic Impacts in Texas. Prepared for Exelon.
February.
FAA (Federal Aviation Administration). 2014. Final Environmental Impact Statement, SpaceX Texas
Launch Site, Volume 1. Website: https://www.faa.gov/about/office_org/headquarters_offices/ast/
environmental/nepa_docs/review/launch/spacex_texas_launch_site_environmental_impact_state
ment/.
FAA. 2016. Obstruction Marking and Lighting. Advisory Circular AC 70/7460-1L, Change 1. October 8,
2016. Website: https://www.faa.gov/documentLibrary/media/Advisory_Circular/AC_70_7460-
1L_with_chg_1.pdf
Feist, B.E., J.J. Anderson, and R. Miyamoto. 1992. Potential Impacts of Pile Driving on Juvenile Pink
(Oncorhynchus gorbuscha) and Chum (O. keta) Salmon Behavior and Distribution. Seattle,
Washington: Fisheries Research Institute, School of Fisheries, and Applied Physics Laboratory,
University of Washington.
FEMA (Federal Emergency Management Agency). 2018a. Cameron County FIRM/FEMA Map. FEMA,
2014. Available online at: www.co.cameron.tx.us/dot/docs/Cameron_County_Flood_Map.pdf.

FEMA. 2018b. Flood Insurance Study, Cameron County, Texas. Effective Date February 16, 2018. Flood
Insurance Study Number 48061CV001A. Available online at: https://map1.msc.fema.gov/
data/48/S/PDF/48061CV001A.pdf?LOC=03264e2c4475a1c64ce1ae71b40d3345.
FERC (Federal Energy Regulatory Commission). 2005. Final Environmental Impact Statement, Golden
Pass LNG Terminal and Pipeline Project. OEP/DG2E/Gas Branch 2, Golden Pass LNG Terminal
LP, Docket No. CP04-386-000.
FERC. 2007. Draft Seismic Design Guidelines and Data Submittal Requirements for LNG Facilities. Office
of Energy Projects, January 23, 2007. Website: https://www.ferc.gov/industries/gas/indus-
act/lng/lng-seis-guide.pdf
FERC. 2013a. Upland Erosion Control, Revegetation, and Maintenance Plan. Office of Energy Projects,
May 2013. Website: http://www.ferc.gov/industries/gas/enviro/plan.pdf (accessed April 1, 2015).
FERC. 2013b. Wetland and Waterbody Construction and Mitigation Procedures. Office of Energy Projects,
May 2013. Website: http://www.ferc.gov/industries/gas/enviro/procedures.pdf (accessed April 1,
2015).
Ferguson, Henry N. 1976. The Port of Brownsville: A Maritime History of the Rio Grande Valley.
Brownsville: Springman-King, 1976.
Ferguson, Jason. 2015. Texas Parks and Wildlife Department, Coastal Fisheries Division, Lower Laguna
Madre Field Office. Personal communication with K. Welder, Ecology and Environment, Inc., on
June 18, 2015.
FireDepartment.net. 2015a. Cameron County, TX Fire Departments. Website:

http://www.firedepartment.net/directory/texas/cameron-county (accessed by Ecology and
Environment, Inc. on May 30, 2015).
FireDepartment.net. 2015b. Willacy County, TX Fire Departments. Website:

http://www.firedepartment.net/directory/texas/willacy-county (accessed by Ecology and
Fisher, M. 2015. Texas Parks and Wildlife Department. Personal communication with K. Welder, Ecology
and Environment, Inc., on June 17, 2015.
Fisher, M. 2017. Texas Parks and Wildlife Department. Personal communication with M. Dadswell, Tetra
Tech. April 24.
Fisheries Hydroacoustic Working Group. 2008. Principle for Interim Criteria for Injury to Fish from Pile
Driving. Memorandum from Federal Highway Administration. June 12, 2008.
Freeport LNG. 2018. Freeport LNG Newsroom, Latest News Releases. http://www.newsrouter.com/
Newsrouter_uploads/77_New/newsroom.asp (Accessed September 12, 2018).
FWHA. 2006. FHWA Highway Construction Noise Handbook. Federal Highway Administration
publication FHWA-HEP-06-015. August 2006.

FWS (United States Fish and Wildlife Service). 1990a. Ocelot Recovery Plan (Leopardus pardalis) Draft
First Revision. Website: http://www.fws.gov/southwest/es/Documents/R2ES/
Draft_Ocelot_Recovery_Plan-First_Revision.pdf (accessed April 2016).
FWS. 1990b. Gulf Coast Jaguarundi Recovery Plan. https://www.fws.gov/southwest/es/Documents

/R2ES/GulfCoastJaguarundi_FinalRecoveryPlan_Dec2013.pdf
FWS. 1990b. Northern Aplomado Falcon Recovery Plan. Albuquerque, New Mexico.
FWS. 1999. Lower Rio Grande Valley and Santa Ana National Wildlife Refuges Comprehensive
Conservation Plan. Website: http://www.fws.gov/uploadedFiles/LRGV%20CCP_2008.pdf
(accessed April 20, 2016).
FWS. 2000. News and Activities – Free-for-all with Furfural Kills 9 Million Fish. Website:
http://www.fws.gov/contaminants/DisplayNews.cfm?NewsID=E2D4E08E-7448-11D4-
A169009027B6B5D3 (accessed May 2015).
FWS. 2000. Endangered and threatened wildlife and plants: proposed determination of critical habitat for
wintering piping plovers. Federal Register 65:41782-41812.
FWS. 2002. Colonial-Nesting Waterbirds, A Glorious and Gregarious Group. Arlington, Virginia. Website:
http://www.fws.gov/birds/waterbird-fact-sheet.pdf (accessed May 2014).
FWS. 2003. Laguna Atascosa National Wildlife Refuge, South Texas Refuge Complex, Proposed Re-
Flooding and Restoration of Bahia Grande, Final Draft Environmental Assessment. Website:
https://www.doi.gov/sites/doi.opengov.ibmcloud.com/files/uploads/BahiaEA-Final-Draft-with-
Public-Notice-2.pdf\ (accessed November 1, 2016).
FWS. 2004. Field Notes Energy. South Bay Coastal Preserve. Website: https://www.fws.gov/
fieldnotes/regmap.cfm?arskey=13933 (accessed September 2016).
FWS. 2007. West Indian Manatee (Trichechus manatus) 5-Year Review: Summary and Evaluation. (pp.
86). Southeast Region, Jacksonville Ecological Services Office and Caribbean Field Office.
FWS. 2010a. Texas ayenia (Tamaulipan kidneypetal) Ayenia limitaris Cristóbal. 5-year review: summary
and evaluation. U.S. Fish and Wildlife Service. Corpus Christi Ecological Services Field Office.
Corpus Christi, Texas
FWS. 2010b. Laguna Atascosa National Wildlife Refuge Comprehensive Conservation Plan. September.
FWS. 2010c. Draft Ocelot Recovery Plan. https://www.fws.gov/southwest/es/Documents/R2ES/

Draft_Ocelot_Recovery_Plan-First_Revision.pdf.
FWS. 2012a. National Wetlands Inventory - Wetlands. Website: http://www.fws.gov/wetlands (accessed

March 24, 2015).
FWS. 2012b. Lower Rio Grande Valley, National Wildlife Refuge, Texas. Wildlife and Habitat. Website:
http://www.fws.gov/refuge/Lower_Rio_Grande_Valley/wildlife_habitat.html (accessed August
12, 2016).

FWS. 2012c. Migratory Bird Flyways. Migratory Bird Program. Website:

http://www.fws.gov/migratorybirds/flyways.html (accessed May 2015).
FWS. 2012d. Lower Rio Grande Valley NWR - Boca Chica Beach. Available at:
http://www.fws.gov/refuge/Lower_Rio_Grande_Valley/visit/boca_chica_beach.html. Accessed
on February 3, 2016.
FWS. 2012e. Leatherback Sea Turtle (Dermochelys coriacea). (pp. 2). North Florida Ecological Services
Office. December 2012.
FWS. 2013a. Lower Rio Grande Valley National Wildlife Refuge, About the Refuge. Available at:
http://www.fws.gov/refuge/Lower_Rio_Grande_Valley/about.html (accessed May 22, 2015).
FWS. 2013b. Florida Manatee Recovery Facts. Website: http://www.fws.gov/northflorida/

Manatee/manatee-gen-facts.htm (Accessed January 12, 2014).
FWS. 2013c. Gulf Coast Jaguarundi Recovery Plan (Puma yagouaroundi cacomitli). Website:
http://www.fws.gov/southwest/es/Documents/R2ES/GulfCoastJaguarundi_FinalRecoveryPlan_D
ec2013.pdf (accessed April 2016).
FWS. 2013d. SpaceX Texas launch site. Biological and conference opinion. URL =
https://www.faa.gov/about/office_org/headquarters_offices/ast/environmental/nepa_docs/review/
documents_progress/spacex_texas_launch_site_environmental_impact_statement/media/Final_B
O_FAA_SpaceX_sm.pdf.
FWS. 2014a. West Indian Manatee (Trichechus manatus): FLORIDA STOCK (Florida subspecies,
Trichechus manatus latirostris). Website: https://www.fws.gov/northflorida/manatee/
SARS/FR00001606_Final_SAR_WIM_FL_Stock.pdf
FWS. 2014b. Northern aplomado falcon (Falco femoralis septentrionalis) 5-year review: summary and
evaluation. USFWS New Mexico Ecological Services Field Office, Albuquerque, NM. August 26,
2014. Website: http://ecos.fws.gov/docs/five_year_review/doc4436.pdf (accessed May 2015).
FWS. 2014c. Endangered and threatened wildlife and plants; threatened species status for the rufa red knot.
Final Rule. Federal Register 79(238):73706-73748.
FWS. 2014d. Rufa red knot background information and threats assessment. Supplement to Endangered
and threatened wildlife and plants; final threatened status for the rufa red knot (Calidris canutus
rufa). New Jersey Field Office, Pleasantville.
FWS. 2015a. Critical Habitat Portal. Website: http://ecos.fws.gov/crithab (accessed March 24, 2015).
FWS. 2015b. Laguna Atascosa Bahia Grande Unit. Website:

http://www.fws.gov/refuge/laguna/about/bahia_grande_unit.html (accessed January 2016).
FWS. 2015c. National Wildlife Refuge System: Cooperative Recovery Initiative. Website:
http://www.fws.gov/refuges/whm/cooperativeRecoveryInitiative.html.
FWS. 2015d. Information, Planning, and Conservation System (IPaC). Website:

http://ecos.fws.gov/ipac/wizard/trustResourceList!prepare.action (accessed April 9, 2015).

FWS. 2015e. International Affairs, Monarch Butterfly. Website: https://tpwd.texas.gov/

huntwild/wild/wildlife_diversity/texas_nature_trackers/monarch/ (accessed July 2015).
FWS. 2015f. Foreign Species, Parrots. Website: http://www.fws.gov/endangered/what-we-

do/parrots2.html (accessed March 16, 2016).
FWS. 2015g. Rufa Red Knot (Calidris canutus rufa). Website: http://www.fws.gov/northeast/redknot/
(accessed April 2016).
FWS. 2015h. Letter from FWS Corpus Christi Office of the Texas Coastal Ecological Service Field Office
to Edward Miller, P.E., Annova LNG, LLC regarding Consultation No. 02ETCC00-2015-TA-0317.
May 20.
FWS. 2016a. Pollinators of Texas. Website: https://www.fws.gov/southwest/es/Documents/

R2ES/Monarch_Texas_Pollinator_Fact_Sheet_FINAL.pdf
FWS. 2016b. Personal Communication, inter-agency meeting with FWS, TPWD, and the RG Developers.
Corpus Christi, Texas. March 3, 2016.
FWS. 2016c. Laguna Atascosa National Wildlife Refuge, Texas. Website:

http://www.fws.gov/refuge/Laguna_Atascosa (accessed March 16, 2016).
FWS. 2017. Threats to Birds. Collisions. Website: https://www.fws.gov/birds/bird-enthusiasts/threats-to-

birds/collisions.php. Accessed December 2017.
FWS. 2018a. Whooping Crane (Grus Americana). Website: http://ecos.fws.gov/ecp0/profile/

speciesProfile?spcode=B003.
FWS. 2018b. Eastern black rail. https://www.fws.gov/southeast/wildlife/birds/eastern-black-rail. Updated

October 5, 2018.
FWS North Florida Ecological Services Office. 2016. Florida Manatee - Issues and Information. Website:
https://www.fws.gov/northflorida/manatee/manatees.htm.
FWS and Federal Highway Administration. 2017. Bayside Wildlife Drive Project. Draft Environmental
Assessment. September. Available online at: https://www.fws.gov/uploadedFiles/
Final%20Draft%20Bayside%20Wildlife%20Drive%20EA_ver2%20(1).pdf.
Gardner, M.B. 1981. Effects of Turbidity on Feeding Rates and Selectivity of Bluegills. Transactions of
the American Fisheries Society 110: 446–450.
George, P.G., R.E. Mace, and R. Petrossian. 2011. Aquifers of Texas. Report 380, Texas Water
Development Board.
Germano, J., J. Parker, and J. Charles. 1994. Monitoring Cruise at the Massachusetts Bay Disposal Site,
August 1990. DAMOS Contribution No. 92. U.S. Army Corps of Engineers, New England
Division, Waltham, MA.
GMFMC (Gulf of Mexico Fishery Management Council). 1998. Generic amendment for addressing
essential fish habitat requirements in the Fishery Management plans of the Gulf of Mexico. Tampa,
Florida: Gulf of Mexico Fishery Management Council.

GMFMC. 2004. Final Environmental Impact Statement for the Generic Amendment to the fishery
management plans of the Gulf of Mexico. Tampa, Florida: Gulf of Mexico Fishery Management
Council.
GMFMC. 2005. Generic amendment for addressing essential fish habitat requirements in the Fishery
Management plans of the Gulf of Mexico. Gulf of Mexico Fishery Management Council, Tampa,
Florida.
GMFMC. 2007. Amendment 14 to the Shrimp Fishery Management Plan. Website:

http://www.gulfcouncil.org/Beta/GMFMCWeb/downloads/Final%20RF%20Amend%2027-
%20Shrimp%20Amend%2014.pdf (accessed May 2015).
GMFMC. 2010. Final Report: Gulf of Mexico Fishery Management Council 5-Year Review of the Final
Generic Amendment Number 3 Addressing Essential Fish Habitat Requirements, Habitat Areas of
Particular Concern, and Adverse Effects of Fishing in the Fishery Management Plans of the Gulf
of Mexico. (pp. 105). Tampa, FL: Gulf of Mexico FMC.
Grassman, L.I. 2006. Wild cats of Texas. Wildlife. Houston Zoo, Fall, p. 6.
Gulf Coast Ecosystem Restoration Council. 2015. Resources and Ecosystems Sustainability, Tourist
Opportunities, and Revived Economies of the Gulf Coast States Act (RESTORE Act) Initial
Funded Priorities List. Website:
https://www.restorethegulf.gov/sites/default/files/FPL_FINAL_Dec9Vote_EC_Library_Links.pdf
(accessed by Ecology and Environment, Inc. on February 3, 2016).
Guthrie, D.M., and W.R.A. Muntz. 1993. Role of vision in fish behavior. In: Behaviour of Teleost Fishes,
89–121, T.P. Pitcher (ed.). 2nd Edition. Chapman and Hall, London, U.K.
Gutierrez, O. 2015. Fire Chief, City of Raymondville, TX. Personal communication with K. Welder,
Ecology and Environment, Inc., on June 1, 2015
Haines, A. M., Tewes, M. E., and L. L. Laack. 2005. Survival and sources of mortality in ocelots. Journal
of Wildlife Management 69(1):255-263.
Handley, L., Altsman, D., and DeMay, R., eds. 2007. Seagrass Status and Trends in the Northern Gulf of
Mexico: 1940-2002: U.S. Geological Survey Scientific Investigations Report 2006-5287 and U.S.
Environmental Protection Agency 855-R-04-003, 267 p.
Hanson, J., M. Helvey, and R. Strach (Eds.). 2004. Non-fishing impacts to essential fish habitat and
recommended conservation measures, Version 1. Long Beach, CA: National Marine Fisheries
Service, Southwest Region.
Hastings, M.C., and A.N. Popper. 2005. Effects of Sound on Fish. Prepared for California Department of
Transportation, Sacramento, California.
Hastings, M.C., A.N. Popper, J.J. Finneran, and P.J. Lanford. 1996. Effects of Low-Frequency Underwater
Sound on Hair Cells of the Inner Ear and Lateral Line of the Teleost Fish Astronutus ocellatus.
Journal of the Acoustical Society of America 99(3):1759-1766.
Hayhoe, K., D.J. Wuebbles, D.R. Easterling, D.W. Fahey, S. Doherty, J. Kossin, W. Sweet, R. Vose, and
M. Wehner. 2018. Our Changing Climate. In Impacts, Risks, and Adaptation in the United States:

Fourth National Climate Assessment, Volume II [Reidmiller, D.R., C.W. Avery, D.R. Easterling,
K.E. Kunkel, K.L.M. Lewis, T.K. Maycock, and B.C. Stewart (eds.)]. U.S. Global Change Research
Program, Washington, DC, USA, pp. 72–144. doi: 10.7930/NCA4.2018.CH2
Hazel, J., I. R. Lawler, H. Marsh, and S. Robson. 2007. Vessel Speed Increases Collision Risk for the Green
Turtle Chelonia Mydas. Endangered Species Research 3(2):105-113.
Hector, D.P. 1990. Northern Aplomado Falcon recovery plan. Albuquerque, NM: United States Fish and
Wildlife Service.
Hendrickson, D.A., and A.E. Cohen. 2015. Fishes of Texas Project Database (Version 2.0).
doi:10.17603/C3WC70. Website: http://www.fishesoftexas.org/data/
?submit=Submit&genus=357&species=772 (accessed August 12, 2016).
Hosman, R.L. 1996. Regional Stratigraphy and Subsurface Geology of Cenozoic Deposits, Gulf Coastal
Plain, South-Central United States. USGS Professional Paper 1416-G. 1996.
Howard Midstream Energy Partners. 2015. Howard Energy Partners Expands Its Presence in the Port of
Brownsville With a New Bulk Liquid Terminal Facility. Available at:
http://www.howardenergypartners.com/news/howard-energy-partners-expands-itspresence-in-the-
port-of-brownsville-with-a-new-bulk-liquid.
Huijbers, C.M., I. Nagelkerken, P.A.C. Lossbroek, I.E. Schulten, A. Siegenthaler, M.W. Holderied, and
S.D. Simpson. 2012. A Test of the Senses: Fish Select Novel Habitats by Responding to Multiple
Cues. Ecology 93(1):46-55.
Hunt, E.C., G. Bourneuf. 2003. Modern Engineer’s Manual, Volume 1, 3rd Edition. Eds. D. Augustine and
J. Tiratto. Cornell Maritime Press, Inc. Centreville, Maryland.
ICC (International Code Council Inc.). 2009. International Building Code. February 2009.
ICF Jones & Stokes, and Illingworth and Rodkin, Inc. 2009. Final Technical Guidance for Assessment and
Mitigation of Hydroacoustic Effect of Pile Driving on Fish. Prepared for California Department of
Transportation. February 2009. 298 pp.
ICUN (International Union for Conservation of Nature). 2015. Website: http://www.iucn.org (accessed
April 22, 2015).
iLinks Geosolutions. 2015. Survey Report Hydrographic, Geophysical & Archaeological Surveys,
Brownsville Ship Channel, TX, July 6th through July 10th. Conducted on behalf of Audubon,
Annova LNG Brownsville Project, Texas.
Jefferson, T.A., and A.J. Shiro. 1997. Distribution of cetaceans in the offshore Gulf of Mexico. Mammal
Society. Mammal Rev. 27:27–50.
Jones, S. L. 2010. Sprague’s Pipit (Anthus spragueii) conservation plan. U.S. Department of Interior, Fish
and Wildlife Service, Washington, D.C.
Kloesel, K., B. Bartush, J. Banner, D. Brown, J. Lemory, X. Lin, G. McManus, E. Mullens, J. Nielsen-
Gammon, M. Shafer, C. Sorenson, S. Sperry, D. Wildcat, and J. Ziolkowska. 2018. Southern Great
Plains. In Impacts, Risks, and Adaptation in the United States: Fourth National Climate

Assessment, Volume II [Reidmiller, D.R., C.W. Avery, D.R. Easterling, K.E. Kunkel, K.L.M.
Lewis, T.K. Maycock, and B.C. Stewart (eds.)]. U.S. Global Change Research Program,
Washington, DC, USA, pp. 987–1035. doi: 10.7930/NCA4.2018.CH23.
Koropchak, S., W. Daniels, A. Wick, G. Whittecar, and N. Haus. 2016. Beneficial Use of Dredge Material
for Soil Reconstruction and Development of Dredge Screening Protocols. Journal of
Environmental Quality 45(1):62-73. Available online at https://www.ncbi.nlm.nih.gov/
pubmed/26828161.
Laack L.L., M.E. Tewes, A.M. Haines, and J.H. Rappole. 2005. Reproductive life history of ocelots
Leopardus pardalis in southern Texas. Acta Theriologica 50:505–514.
Lande, R. 1988. Genetic and demography in biological conservation. Science 241(4872):1455–1460.
Landry, A. M., D. T. Costa, F. L. Kenyon and M. S. Coyne. 2005. Population Characteristics of Kemp's
Ridley Sea Turtles in Nearshore Waters of the Upper Texas and Louisiana Coasts. Chelonian
Conservation and Biology 4(4):801–807.
Lenhardt, M.L. 1982. Bone Conduction Hearing in Turtles. Journal of Auditory Research 22:153-160.
Lenhardt, M.L. 1994. Seismic and Very Low Frequency Sound Induced Behaviors in Captive Loggerhead
Marine Turtles (Caretta caretta). Presented at the Fourteenth Annual Symposium on Sea Turtle
Biology and Conservation, Hilton Head, SC.
Lenhardt, M.L. 2002. Sea Turtle Auditory Behavior (A). Journal of the Acoustical Society of America
112(5):2314.
Lenhardt, M.L., S. Bellmund, R.A. Byles, S.W. Harkins, and J.A. Musick. 1983. Marine Turtle Reception
of Bone Conducted Sound. Journal of Auditory Research 23:119-125.
Long Island Village. 2019. Long Island Village Seaside Living at Port Isabel, TX. Website:
https://www.longislandvillage.com/default.php. Accessed on March 19, 2019.
Ludeke, K., D. German, and J. Scott. 2010. Texas Vegetation Classification Project: Interpretative Booklet
for Phase 3. Texas Parks and Wildlife Department and Texas Natural Resources Information
System.
LUMC (Louisiana Universities Marine Consortium). 2016. Hypoxia in the Northern Gulf of Mexico.
Website: http://www.gulfhypoxia.net/overview/ (accessed January 2016).
LUMCON (Louisiana Universities Marine Consortium). 2016. Hypoxia in the Northern Gulf of Mexico.
Website: http://www.gulfhypoxia.net/overview/ (accessed January 2016).
Mace, R.E., S.C. Davidson, E.S. Angle, and W.F. Mullican III. 2006. Aquifers of the Gulf Coast. Texas
Water Development Board Report 365. Website: http://www.twdb.texas.gov/publications/reports/
numbered_reports/doc/R365/R365_Composite.pdf (accessed August 2016).
MARAD (U.S. Department of Transportation Maritime Administration). 2015. MARAD Open Data Portal,
Maritime Data &Statistics. Website: https://www.marad.dot.gov/resources/data-statistics/
(Accessed November 11, 2016).

Marchex, Inc. 2015. Yellow.com: Yellow pages made simple. Website: http://www.yellow.com (accessed
by Ecology and Environment, Inc. on May 31, 2015).
Martin Associates/John C. Martin Associates, LLC. 2012. The Local and Regional Economic Impacts of
the Port of Brownsville. Prepared for the Port of Brownsville/Brownsville Navigation District.
September 25, 2012.
Martin, K.J., S.C. Alessi, J. C. Gaspard, A.D. Tucker, G.B. Bauer, and D.A. Mann. 2012. Underwater
hearing in the loggerhead turtle (Caretta caretta): a comparison of behavioral and auditory evoked
potential audiograms. Journal of Experimental Biology 215(17): 3001–3009.
Mathis, M., and D. Matisoff. 2004. A Characterization of Ecotourism in the Texas Lower Rio Grande
Valley. Discussion Paper VNT-04-01. March.
McKenna, K.K., P.G. 2014. Texas Coastwide Erosion Response Plan. Texas General Land office. Available
online at: http://www.glo.texas.gov/coast/coastalmanagement/forms/files/coastwide-erosion-
response-plan.pdf. Accessed September 2018.
Mennitt, D., K. Sherrill, and K. Fristrip. 2014. A geospatial model of ambient sound pressure levels in the
contiguous United States. Journal of the Acoustical Society of America 135(5):2746–64.
Metz, T.L. and A.M. Landrey, Jr. 2013. An assessment of green turtle (Chelonia mydas) stacks along the
Texas coast, with emphasis on the lower Laguna Madre. Chelonian Conservation and Biology
12(2):293–302.
Mikkelsen, O.A., and M. Pejrup. 2000. In situ particle size spectra and density of particle aggregates in a
dredging plume. Marine Geology 170:443–459.
Murray, P.M., and H.L. Saffert. 1999. Monitoring Cruises at the Western Long Island Sound Disposal Site,
September 1997 and March 1998. DAMOS Contribution No. 125. U.S. Army Corps of Engineers,
New England District, Concord, MA.
National Ocean Economics Program. 2016a. Top Commercial Fishing Ports for the Gulf of Mexico in 2014.
Website: http://www.oceaneconomics.org/default.aspx (accessed March 21, 2016).
National Ocean Economics Program. 2016b. “Landing History for Brownsville-Port Isabel, Texas:
Commercial Fish Landings.” Website: http://www.oceaneconomics.org/default.aspx (accessed
March 21, 2016).
Nelsen, Aaron. 2008. “Vanishing Fleet.” The Brownsville Herald. Posted August 4, 2008. Website:
http://www.brownsvilleherald.com/business/article_3e6a0694-3bea-580c-b509-
018c0174d2e7.html (accessed December 28, 2016).
Newcombe, C.P., and J.O.T. Jensen. 1996. Channel suspended sediment and fisheries: a synthesis for
quantitative assessment of risk and impact. North American Journal of Fisheries Management
16:693–727.
NFWF (National Fish and Wildlife Foundation). 2015. Gulf Environmental Benefit Fund. Texas: Bahia
Grande Conservation Corridor – Boswell-Jenkins Tract Acquisition. Website:
http://www.nfwf.org/gulf/Documents/tx-boswell%20jenkins-15.pdf

Nightingale, B., and C.A. Simenstad. 2001. Dredging Activities: Marine Issues. Website:
http://depts.washington.edu/trac/bulkdisk/pdf/507.1a.pdf (accessed January 2016).
NLCD (National Land Cover Database). 2011. United States Geologic Survey. A comprehensive change
detection method for updating the National Land Cover Database to circa 2011.
NOAA (National Oceanic and Atmospheric Administration). 2000. Incident News – Furfural Spill.
Website: http://incidentnews.noaa.gov/incident/7458/507735 (accessed May 2015).
NOAA. 2000. Incident News – Furfural Spill. Website: http://incidentnews.noaa.gov/incident/7458/507735

(accessed May 2015).
NOAA. 2012. Sea Lake and Overland Surge from Hurricanes (SLOSH) model display Program (1.65i).
December 14, 2012. Website: http://www.nhc.noaa.gov/surge/slosh.php#SDISPLAY (accessed
January 2014).
NOAA. 2013. Annual Climatological Summary 2009-2013. Obtained from NOAA’s Climate Data Online
Search for Annual Summaries for January 1, 2009 through December 31, 2013: Website:
http://www.ncdc.noaa.gov/cdo-web/search (accessed September 2016).
NOAA. 2015a. Annual Climatological Summary 2015. Obtained from NOAA’s Climate Data Online
Search for Annual Summaries for January 1, 2015 through November 1, 2015: Website:
http://www.ncdc.noaa.gov/cdo-web/search (accessed September 2016).
NOAA. 2016a. 1981-2010 U.S. Climate Normals. Website: ftp://ftp.ncdc.noaa.gov/pub/

data/normals/1981-2010/
NOAA. 2016b. National Hurricane Center, Tropical Cyclone Climatology. Available at:
http://www.nhc.noaa.gov/climo/
NOAA. 2017. Global and Regional Sea Level Rise Scenarios for the United States. January.
NOAA Fisheries (National Oceanic and Atmospheric Administration, National Marine Fisheries Service).
1999a. Fishery Management Plan for Atlantic Tunas, Swordfish and Sharks. NOAA, National
Marine Fisheries Service, Highly Migratory Species Management Division, Silver Spring, MD.
Public Document.
NOAA Fisheries. 1999b. Amendment 1 to the Atlantic Billfish Fishery Management Plan. NOAA, National
Marine Fisheries Service, Highly Migratory Species Management Division, Silver Spring, MD.
NOAA Fisheries. 2004. Sea Turtle Protection and Conservation. Website:

http://www.nmfs.noaa.gov/prot_res/PR3/Turtles.html#species.
NOAA Fisheries. 2008. Vessel Strike Avoidance Measures and Reporting for Mariners. Southeast Regional
Office. February. Website: http://sero.nmfs.noaa.gov/protected_resources/section_7/
guidance_docs/documents/copy_of_vessel_strike_avoidance_february_2008.pdf
NOAA Fisheries. 2009. Final Amendment 1 to the 2006 Consolidated Atlantic Highly Migratory Species
Fishery Management Plan, Essential Fish Habitat. NOAA, National Marine Fisheries Service,
Highly Migratory Species Management Division, Silver Spring, MD. Public Document.

NOAA Fisheries. 2011a. Fisheries of the United States 2010. National Marine Fisheries Service, Office of
Science and Technology, Silver Spring, MD. 118 pages.
NOAA Fisheries. 2011b. Marine Mammals. Website: http://www.nmfs.noaa.gov/pre/special/

mammals/cetaceans.htm
NOAA Fisheries. 2012. An Overview of Protected Species in the Gulf of Mexico. Southeast Regional
Office Protected Resources Division. February. Website: https://www.boem.gov/Oil-and-Gas-
Energy-Program/GOMR/NMFS-Protected-Species-In-GOM-Feb2012.aspx
NOAA Fisheries. 2013. Biological Opinion on the Programmatic Geological and Geophysical Activities in
the Mid- and South Atlantic Planning Areas from 2013 to 2020 (pp. 370). Prepared by NMFS for
The Bureau of Ocean Energy Management and The Bureau of Safety and Environmental
Enforcement.
NOAA Fisheries. 2014. Loggerhead Sea Turtle Critical Habitat in the Northwest Atlantic Ocean. Website:
http://www.nmfs.noaa.gov/pr/species/turtles/criticalhabitat_loggerhead.htm (last updated
September 18, 2014).
NOAA Fisheries. 2015a. Atlantic Spotted Dolphin. Website: http://www.fisheries.noaa.gov/pr/species/

mammals/dolphins/atlantic-spotted-dolphin.html (accessed February 2016).
NOAA Fisheries. 2015b. Bottlenose Dolphin. Website: http://www.fisheries.noaa.gov/pr/

species/mammals/dolphins/bottlenose-dolphin.html (accessed February 2016).
NOAA Fisheries. 2015c. EFH Text Descriptions and GIS Data Inventory. Website:
http://www.habitat.noaa.gov/protection/efh/newInv (accessed May 2015).
NOAA Fisheries. 2015d. Personal Communications with Heather Young, NOAA NMFS, Habitat
Conservation Division, Southeast Region.
NOAA Fisheries. 2015e. Kemp’s Ridley Turtle. National Marine Fisheries Service. Website:
http://www.nmfs.noaa.gov/pr/species/turtles/kempsridley.htm (accessed June 2015).
NOAA Fisheries. 2016a. Sperm Whale (Physeter macrocephalus): Northern Gulf of Mexico Stock. May.
Website: http://www.fisheries.noaa.gov/pr/sars/pdf/stocks/atlantic/
2015/f2015_spermgmex.pdf
NOAA Fisheries. 2016b. Green Turtle: Chelonia mydas. Website:

http://www.fisheries.noaa.gov/pr/species/turtles/green.html
NOAA Fisheries. 2016c. Loggerhead Turtle (Caretta caretta). Website:

http://www.nmfs.noaa.gov/pr/species/turtles/loggerhead.html
NOAA Fisheries. 2016d. Hawksbill Turtle (Eretmochelys imbricata). Website:

http://www.fisheries.noaa.gov/pr/species/turtles/hawksbill.html
NOAA Fisheries. 2016e. Leatherback Turtle (Dermochelys coriacea). Website:

http://www.fisheries.noaa.gov/pr/species/turtles/leatherback.html

NOAA Fisheries. 2016f. Southeast Regional Office. “Rebirth of the Bahia Grande, Texas.” Website:
http://sero.nmfs.noaa.gov/habitat_conservation/hcd_headlines/bahia_grande_tx.html (accessed
November 1, 2016).
NOAA Fisheries. 2018. North Atlantic Right Whale Sighting Survey and Early Earning System. Website:
http://sero.nmfs.noaa.gov/protected_resources/right_whale/seus_sightings/index.html (Accessed
March 8, 2018).
NOAA Fisheries and FWS. 2013a. Hawksbill sea turtle (Eretmochelys imbricata). 5-year review: summary
and evaluation. June 2013.
NOAA Fisheries and FWS. 2013b. Leatherback sea turtle (Dermochelys coriacea). 5-year review: summary
and evaluation. November 2013.
NOAA Fisheries and FWS. 2015. Kemp’s Ridley Sea Turtle (Lepidochelys kempii) 5-year Review:
Summary and Evaluation (pp. 63). Silver Spring, MD. Website:
http://www.nmfs.noaa.gov/pr/listing/final_july_2015_kemp_s_5_year_review.pdf
NOAA Fisheries, FWS, and Secretary of Environment and Natural Resources, Mexico (SEMARNAT).
2011. Draft Bi-National Recovery Plan for the Kemp’s ridley Sea Turtle (Lepidochelys kempii),
Second Revision. National Marine Fisheries Service. Silver Spring, MD.
NoiseQuest. 2015. What does noise affect? Wildlife section. Website:

http://www.noisequest.psu.edu/noiseeffects-wildlife.html (accessed January 2016).
NPS (U.S. Department of the Interior, National Park Service). 2006. Management Policies 2006. United
States Department of the Interior, National Park Service, Washington, DC. Website:
http://www.nps.gov/policy/MP2006.pdf (accessed August 9, 2016).
NPS. 2010a. Update to the Civil War Sites Advisory Commission Report on the Nation’s Civil War
Battlefields, State of Texas. Website: http://www.nps.gov/abpp/cwsii/cwsacreporttexasupdate.pdf
(accessed by Ecology and Environment, Inc. on May 26, 2015).
NPS. 2010b. National Wild and Scenic River Inventory Texas Segments. U.S. Department of the Interior,
National Park Service, Washington D.C. Website:
http://www.nps.gov/ncrc/programs/rtca/nri/states/tx.html. Accessed on May 19, 2015.
NPS. 2010c. National Parks and National Trail Systems Map. U.S. Department of the Interior, National
Parks Service, Washington D.C. Website:
http://www.nps.gov/nts/maps/National%20Trails%20map.pdf. Accessed on May 19, 2015.
NPS. 2012. National Natural Landmarks Program. Texas. Website:

http://www.nature.nps.gov/nnl/state.cfm?State=TX. Accessed May 19, 2015.
NPS. 2015. National Register of Historic Places. Website: http://nrhp.focus.nps.gov/natreg docs/

Download.html (accessed March 24, 2015).
NPS. 2016a. Padre Island National Seashore. Website: https://www.nps.gov/pais/index.htm (accessed

August 9, 2016).

NPS. 2016b. State of the Park Report for Palo Alto Battlefield National Historical Park. Updated July 15,
2016. https://www.nps.gov/stateoftheparks/paal/naturalresources/vegetation.cfm. Accessed 3/15
2017.
NPS. 2017. Palo Alto Battlefield. National Historic Park – Texas. Management. Website:
https://www.nps.gov/paal/learn/management/index.htm.
NPS. 2017b. On the Laguna Madre. Website: https://www.nps.gov/pais/planyourvisit/laguna-madre.htm.

Last updated June 22, 2017. Accessed online on March 18, 2019.
NRC (U.S. Nuclear Regulatory Commission). 2007. Tornado Climatology of the Contiguous United States.
NUREG/CR-4461, Revision 2. PNNL-15112, Revision 2. Prepared by J.V. Ramsdell, Jr., and J.P.
Rishel. Pacific Northwest National Laboratory. February. Available at:
https://www.nrc.gov/reading-rm/doc-collections/nuregs/contract/cr4461/#pub-info
NRCS (Natural Resources Conservation Service). 2010. Natural Resources Conservation Service Invasive
Species Policy GM_190_414 - Part 414 - Invasive Species. Website:
http://directives.sc.egov.usda.gov/ViewRollUp.aspx?hid=17018 (accessed August 31, 2016).
NRCS. 2015a. United States Department of Agriculture. Web Soil Survey. Website:
http://websoilsurvey.nrcs.usda.gov (accessed March 24, 2015).
NRCS. 2015b. Soil Survey Geographic (SSURGO) database for Cameron County, Texas. Published by the
U.S. Department of Agriculture, NRCS. Survey Area Version Date: September 22, 2015. Website:
https://gdg.sc.egov.usda.gov
NRCS. 2016. PLANTS database. Introduced, Invasive, and Noxious Plants. U.S. Department of
Agriculture, Natural Resources Conservation Service website. Website:
http://plants.usda.gov/java/noxiousDriver (accessed September 7, 2016).
NRS Engineering. 2008. Final Pilot Study Report - Texas Seawater Desalination Demonstration Project.
Prepared for the Texas Water Development Board, Brownsville Public Utilities Board, and Port of
Brownsville. October 2008. Website: http://www.twdb.texas.gov/innovativewater/desal/projects
/brownsville/doc/BPUBPilot_Final_Report.pdf (accessed September 2016).
Oberholser, H.C. 1974. The Bird Life of Texas. University of Texas Press, Austin.
OCIMF (Oil Companies International Marine Forum). 2008. Mooring Equipment Guidelines. 3rd edition.
Onuf, C.P. 2002. Laguna Madre. United States Geological Survey, National Wetlands Research Center.
Website: http://pubs.usgs.gov/sir/2006/5287/pdf/LagunaMadre.pdf (accessed May 2015).
Orr, T., S. Herz, and D. Oakley. 2013. Evaluation of Lighting Schemes for Offshore Wind Facilities and
Impacts to Local Environments. U.S. Department of the Interior, Bureau of Ocean Energy
Management, Office of Renewable Energy Programs, Herndon, Virginia. Website:
http://www.data.boem.gov/PI/PDFImages/ESPIS/5/5298.pdf (accessed April 2014).
Page, W.R., D. VanSistine, and K. Turner. 2005. Preliminary Geologic Map of Southernmost Texas, United
States, and Parts of Tamaulipas and Nuevo Leon, Mexico: Environmental Health Investigations in
the United States-Mexico Border Region. USGS Open File Report 2005–1409.

Paine, J.G. 2000. Identifying and assessing ground water in the Lower Rio Grande Valley, Texas, using
airborne electromagnetic induction: The University of Texas at Austin, Bureau of Economic
Geology, final report prepared for Texas Water Development Board under interagency contract no.
99-483-310, 80 p. + CD-ROM. Website: http://www.beg.utexas.edu/staffinfo/paine-
pubs/paine_twdb_lrgv_2000.pdf (accessed August 2016).
Patillo, M., L.P. Rozas, and R.J. Zimmerman. 1995. A Review of Salinity Requirements for Selected
Invertebrates and Fishes of U.S. Gulf of Mexico Estuaries. National Marine Fisheries Service.
Southeast Fisheries Service Center. Galveston, TX.
Patterson, J.W., Jr. 2012. Evaluation of New Obstruction Lighting Techniques to Reduce Avian Fatalities.
DOT/FAA/TC-TN12/9. U.S. Department of Transportation, Federal Aviation Administration.
May. Website: http://www.tc.faa.gov/its/worldpac/techrpt/tctn12-9.pdf
Peregrine Fund. 2012. Aplomado falcon restoration. Website: http://www.peregrinefund.org/projects/

aplomado-falcon.
Peregrine Fund. 2015. Aplomado Falcon Restoration Conserving Birds of Prey Worldwide. Accessed June
2015. Website: http://www.peregrinefund.org/aplomado
Poot, H., B.J. Ens, H. de Vries, M.A.H. Donners, M.R. Wernand, and J.M. Marquenie. 2008. Green light
for nocturnally migrating birds. Ecology and Society 13(2):47.
Port Isabel Economic Development Corporation. 2015. Community Profile-Environmental and Natural
Resources. Website: http://portisabel-texas.com/edc/communityprofile/
environmentalnaturalresources.
Port of Brownsville. 2016. Facts. Website: http://www.portofbrownsville.com/facts/ (accessed August 30,

2016).
Port of Oakland. 1999. Oakland Harbor Navigation Improvement (-50 Foot) Project, Revisions to the Final
Environmental Impact Report. SCH No. 97072051. Prepared by Port of Oakland State Agency.
September.
Prescott, C., J. Zhang, and D. Brower. 2005. New design uses ambient pressure insulted LNG pipeline
offshore. Oil and Gas Journal. Website: http://www.ogj.com/articles/print/volume-103/issue-
28/transportation/new-design-uses-ambient-pressure-insulated-lng-pipeline-offshore.html
Rhoads, D.C., P.L. McCall, J.Y. Yingst. 1978. Disturbance and production on the estuarine seafloor.
American Scientist 66:577–586.
Reice, S.R., R.C. Wissmar, and R.J. Naiman. 1990. Disturbance Regimes, Resilience, and Recovery of
Animal Communities and Habitats in Lotic Ecosystems. Journal of Environmental Management
14(5):647–659.
Ridgway, S.H., E.G. Wever, J.G. McCormick, J. Palin, and J.H. Anderson. 1969. Hearing in the giant sea
turtle, Chelonia mydas. Proceedings of the National Academy of Sciences 64(3):884–890.
Rio Grande LNG, LLC. 2015. Rio Grande LNG, LLC and Rio Bravo Pipeline Company, LLC. Docket No.
PF15-____-000, Request to Initiate NEPA Pre-Filing Process for Rio Grande LNG and Rio Bravo
Pipeline Projects. March 20, 2015.

Robertson, M.J., D.A. Scruton, R.S. Gregory, and K.D. Clarke. 2006. Effect of Suspended Sediment on
Freshwater Fish and Fish Habitat. Canadian Technical Report of Fisheries and Aquatic Sciences
2644:37.
Rosenbaum, Beatrice. 2016. Director of Industrial Development, Port of Brownsville. Personal

communication with K. Welder Mollow, Ecology and Environment, Inc. on October 26, 2016.
RRC (Railroad Commission of Texas). 2015. RRC Public GIS Viewer Version: 2.09. Release Date: May 4,
2015. Website: http://wwwgisp.rrc.state.tx.us/GISViewer2.
Ruple, D.L. 1993. Shoreline Erosion Losses. Proceedings of the 59th Meeting of the Coastal Engineering
Research Board, 16-18 November 1993 Point Clear, Alabama. Available online at:
http://bigfoot.wes.army.mil/5914.html. Accessed September 2018.
Ryder, Paul. 1996. Oklahoma, Texas, in Groundwater Atlas of the United States, United States Geological
Survey HA 730-E. Website: http://capp.water.usgs.gov/gwa/ch_e/index.html (accessed April
2015).
Sanchez, J.M., J.J. Dowling, A.S. Burden, and T.B. Griffith. 2015. Draft Intensive Cultural Resources
Investigations of the Annova LNG Brownsville Project, Cameron County, Texas. Prepared by,
Blanton & Associates, Inc. Austin, Texas.
Sanchez-Cordero, V., D. Stockwell, S. Sarkar, H. Liu, C.R. Stephens and J. Gimenez. 2008. Competitive
interactions between felid species may limit the southern distribution of bobcats (Lynx rufus).
Ecography 31:757-764.
Schmidly, D.J. 2004. The Mammals of Texas. Revised edition, Vol. 59. University of Texas Press.
Seney, E.E., and J.A. Musick. 2005. Diet analysis of Kemp’s ridley sea turtles (Lepidochelys kempii) in
Virginia. Chelonian Conservation and Biology 4(4):864-871.
Seney, E.E., and A.M. Landry. 2011. Movement patterns of immature and adult female Kemp's ridley sea
turtles in the northwestern Gulf of Mexico. Marine Ecology-Progress Series 440: 241–254.
Sepulveda, P. 2015. Personal communication, telephone call on May 27, 2015, between Peter Sepulveda,
County Judge, Cameron County, and Z. Michalk, Ecology and Environment, Inc., regarding
proposed developments in the proposed project area.
Sharyland. 2017. Transmission Projects, Sharyland Utilities. http://www.sharyland.com/transmission/

Accessed 2/28/2017.
Sibley, D.A. 2003. The Sibley Field Guide to Birds of Eastern North America. Andrew Stewart Publishing,
Inc.
Source Strategies, Inc. 2016a. Hotel and motel statistics, Cameron and Willacy counties and respective
cities, annually and quarterly 2011-2015. Provided by Doug Sutton, Vice President, Source
Strategies, Inc., on February 2, 2016, to K. Welder Mollow, Ecology and Environment, Inc.
Source Strategies, Inc. 2016b. Texas Hotel Report: 4th Quarter YTD 2015. Tables: By County by City, by
Metro by City. February 12. Website: http://www.sourcestrategies.org/texas/

SpaceX. 2014. SpaceX Breaks Ground on Private Spaceport in Texas. Available at:
http://www.space.com/27234-spacex-texas-spaceport-groundbreaking.html. Accessed July 18,
2016.
Stadler, J.H., and D.P. Woodbury. 2009. Assessing the effects to fishes from pile driving: Application of
new hydroacoustic criteria. Inter●noise 2009: Innovations in practical noise control. August 2009,
Ottawa, Canada.
Stevenson, D.A., and R. P. McCulloh. 2001. Earthquakes in Louisiana. Louisiana Geological Survey -
Public Information Series No. 7.
STSSN (Sea Turtle Stranding and Salvage Network). https://grunt.sefsc.noaa.gov/stssnrep/

SeaTurtleReportII.do?action=reportIIqueryp.
TAHC (Texas Animal Health Commission). 2015. Texas Cattle Fever Tick. Available online at:
http://www.tahc.texas.gov/news/brochures/TAHCBrochure_FeverTick.pdf.
TAHC. 2016. Inspection, Treatment and Movement Requirements for Nilgai Antelope, White-Tailed Deer
or other Free-ranging Wildlife and Exotic Animals capable of hosting fever ticks located in the
Cameron County Temporary Preventative Quarantine Area (TPQA) or from Premises Quarantined
as Infested, Exposed, Adjacent or Check in the Cameron County Free Area. Available online at:
http://www.tahc.state.tx.us/animal_health/fevertick/WildlifeInspection-2014.pdf.
TCEQ (Texas Commission on Environmental Quality). 2012. Texas Integrated Report: Assessment Results
for Basin 24 – Bays and Estuaries. Website: http://www.tceq.texas.gov/assets/public/
waterquality/swqm/assess/12twqi/2012_basin24.pdf (accessed May 2015).
TCEQ. 2014a. Texas Administrative Code Title 30 Part 1 Chapter 307. Website:
https://www.tceq.texas.gov/waterquality/standards/2014standards.html (accessed August 2016).
TCEQ. 2014b. 2012 Texas Integrated Report – Texas 303(d) List (Category 5). Website:
https://www.tceq.texas.gov/waterquality/assessment/14twqi/14txir (accessed September 2016).
TCEQ. 2015a. Water Well Report Viewer. Website: http://www.tceq.texas.gov/gis/waterwellview.html

(accessed April 2015).
TCEQ. 2015b. Plotted Water Wells for Cameron County, TX. Website:
https://gisweb.tceq.texas.gov/waterwellpublic/search.jsp?type=LR&wellCounty=CAMERON%2
0COUNTY (accessed June 2015).
TCEQ. 2016. Brownsville Ship Channel, Segment ID 2494 dataset. Website:

http://www80.tceq.texas.gov/SwqmisPublic/public/default.htm (accessed September 2016).
Tewes, M. E., and D. D. Everett. 1986. Status and distribution of the endangered ocelot and jaguarundi in
Texas. In Cats of the World: Biology, Conservation, and Management. National Wildlife
Federation. Washington, D.C.
Tewes, M.E., and R.W. Hughes. 2001. Ocelot management and conservation along transportation corridors
in Southern Texas. Website: http://escholarship.org/uc/item/6mc7x9mx#page-1 (accessed April
2016).

Tewes, M.E. 2017. Clinging to Survival in the Borderlands. The Wildlife Professional
(September/October): 26–29. Website: http://www.eastfoundation.net/media/46869/twp-ocelot-
article.pdf
Texas A & M University. 2012. Economic Impact of Nature Tourism on the Rio Grande Valley:
Considering Peak and Off-Peak Visitation for 2011. Prepared by Woosnam, K., R. Dudensing, D.
Hanselka, and K. Aleshinloye. Website: http://southtexasnature.org/wp-
content/uploads/2014/02/STNMC-Final-report-4-16- 12.pdf (accessed March 16, 2016).
Texas Aquatic Science. 2015. Bays and Estuaries – Chapter 11. Website: http://texasaquaticscience.org/
bays-estuaries-aquatic-science-texas/ (accessed January 2016).
Texas Department of Agriculture. 2016. Noxious and Invasive Plant List. Figure: 4 TAC §19.300(a).
Website: http://texreg.sos.state.tx.us/fids/200701978-1.html (accessed January 2016).
Texas Education Agency. 2015. Snapshot 2014 District Detail Search. Website:
https://rptsvr1.tea.texas.gov/perfreport/snapshot/2014/district.srch.html [Search by “District by
County Name,” then enter Cameron and Willacy and click individual school districts]. Accessed
by Ecology and Environment, Inc. on May 31, 2015.
Texas General Land Office. 2015. Jaime J. Zapata Memorial Boat Ramp Fishing Pier and Kayak Launching
Area. Website: http://www.glo.texas.gov/what-we-do/caring-for-the-coast/grants-
funding/projects/ 13-045-jaime-zapata-memorial-pier.html (accessed by Ecology and
Texas LNG Brownsville, LLC. 2015. Texas LNG Brownsville, LLC, Docket No. PF15-___-000, Request
to Initiate NEPA Pre-Filing Process for Texas LNG Brownsville LLC Liquefied Natural Gas
Project. March 9, 2015.
Texas State Data Center. 2014. Population Projections for the State of Texas and Counties in one file.
Website: http://osd.texas.gov/Data/TPEPP/Projections/ (accessed March 8, 2016).
Texas Tech University. 1997. The Mammals of Texas – Online Edition. http://www.nsrl.ttu.edu/tmot.htm.
Texas Weekend Angler. 2016. Fishing in the Brownsville Ship Channel. Website:
http://www.texasweekendangler.com/fishing_the_brownsville_ship_channel.htm (accessed
January 2016).
THC (Texas Historical Commission). 2017. Palmito Ranch Battlefield National Historic Landmark.
[Internet] Available at http://www.thc.texas.gov/preserve/projects-and-programs/military-
sites/palmito-ranch-battlefield-national-historic-landmark
THC. 2017b. Texas Historical Marker – Palmetto Pilings. Travel South Texas Website. Accessed at:
http://www.stxmaps.com/go/texas-historical-marker-palmetto-pilings.html
The University of Texas-Pan American. 2014. “Winter Texan: 2013-2014 Survey.” College of Business
Administration, Valley Markets and Tourism Research Center. Website:
http://issuu.com/utpa/docs/winter_texan_2014 (accessed March 8, 2016).
The Winter Texan Connection. 2015. Texas RV Parks, Mobile Home Parks, 55+S Subdivisions,
Campgrounds, Retirement Communities and Country Clubs in the Rio Grande Valley of South

Texas. Website: http://wintertexaninfo.com/Mobilehomecommunities.html (accessed by Ecology

and Environment, Inc. on May 31, 2015).
TPWD (Texas Parks and Wildlife Department). 1989. Coastal Preserve System, South Bay, Cameron
County, Texas – Texas Parks and Wildlife Department. Available at:
http://tpwd.texas.gov/landwater/water/conservation/txgems/southbay/index.phtml. Accessed on
February 3, 2016.
TPWD. 2002. The Texas Shrimp Fishery Executive Summary. Website:

https://tpwd.texas.gov/publications/pwdpubs/media/pwd_rp_v3400_857.pdf (accessed January
2016).
TPWD. 2015a. The Monarch Butterfly. Website: http://www.fws.gov/international/animals/monarch-

butterfly.html (accessed July 2015).
TPWD. 2015b. Texas Natural Diversity Database (TXNDD). Received December 29, 2015.
TPWD. 2016a. Texas GEMS – South Bay Coastal Preserve. Website:

http://tpwd.texas.gov/landwater/water/conservation/txgems/southbay/index.phtml (accessed
January 2016).
TPWD. 2016b. South Bay Paddling Trail. Website: https://tpwd.texas.gov/fishboat/boat/paddlingtrails/

coastal/south_bay/ (accessed January 2016).
TPWD. 2016c. Texas Ecoregions. Texas Parks & Wildlife Website. Website:
https://tpwd.texas.gov/education/hunter-education/online-course/wildlife-conservation/texas-
ecoregions (accessed August 12, 2016).
TPWD. 2016d. Wildlife Habitat Assessment Program: Planning Tools and Best Management Practices
(BMPs). Website: http://tpwd.texas.gov/huntwild/wild/wildlife_diversity/habitat_assessment/
tools.phtml (accessed February 2016).
TPWD. 2016e. Texas Monarch and Native Pollinator Conservation Plan. Available online at:
https://tpwd.texas.gov/publications/pwdpubs/media/pwd_rp_w7000_2070.pdf.
TPWD. 2016e. Marine Fishes and Shellfishes of the Gulf. Website:

http://tpwd.texas.gov/landwater/water/aquaticspecies/marine.phtml (accessed January 2016).
TPWD. 2016f. Rare, Threatened, and Endangered Species of Texas. Website:

http://tpwd.texas.gov/gis/rtest/ (accessed June 2016).
TPWD. 2017a. Texas State Parks. Website: http://tpwd.texas.gov/state-parks/ (accessed January 19, 2017).
TPWD. 2017b. Texas Ecosystem Analytical Mapper. Available online at: http://tpwd.texas.gov/gis/team/.
Accessed March 29, 2017.
TPWD. 2017c. Rare, Threatened, and Endangered Species of Texas. Available online at:
http://tpwd.texas.gov/gis/rtest/. Accessed May 2017.
TPWD. 2018. Whooping Crane (Grus Americana). Website: http://tpwd.texas.gov/huntwild/

wild/species/whooper/

TPWD. n.d. Texas State Parks. Website: https://tpwd.texas.gov/state-parks (Accessed May 19, 2015).
Traffic Impact Group, LLC. 2015. Traffic Impact Analysis. Annova LNG Brownsville Project.
Brownsville, Cameron County, Texas. Black & Veatch. August 21.
Trevino, Reuben. 2016. Coastal Resource and Parks Administrator, City of South Padre Island. Personal
communication with K. Welder Mollow, Ecology and Environment, Inc., on January 28.
TWDB (Texas Water Development Board). 1990. Report 316: Evaluation of Ground-Water Resource in
the Lower Rio Grande Valley, Texas. Website:
https://www.twdb.texas.gov/publications/reports/numbered_reports/doc/R316/R316.pdf.
(accessed July 2015).
TWDB. 2006. Aquifers of the Gulf Coast of Texas. Report 365. February. Website:t
https://www.twdb.texas.gov/publications/reports/numbered_reports/doc/R365/R365_Composite.p
df
TWDB. 2015. Groundwater Conservation Districts of Texas [map]. Website:

http://www.twdb.texas.gov/mapping/doc/maps/GCDs_8x11.pdf (accessed August 2016).
TWDB. 2016. Water Data Interactive (WDI) Groundwater Data Viewer. Website:
http://www2.twdb.texas.gov/apps/WaterDataInteractive/GroundWaterDataViewer (accessed
August 2016).
TxDOT (Texas Department of Transportation). 2016. Project Tracker. Available at:

http://apps.dot.state.tx.us/apps-cq/project_tracker/.
Ungar, E.E., D.H. Sturz, and C.H. Amick. 1990. Vibration Control Design of High Technology Facilities.
Sound and Vibration (July):20–27.
University of Texas-Brownsville. 2015. STARGATE. Available at:

http://www.utb.edu/stargate/Pages/default.aspx. Accessed July 18, 2016.
University of Texas-Rio Grande Valley. 2018. The University of Texas Rio Grande Valley. 2018. Boca
Chica Beach: STARGATE Technology Center. Available online at: https://www.utrgv.edu/
umc/news/building-our-future/stargate/index.htm. Accessed September 29, 2018.
U.S. Bureau of Economic Analysis. 2015a. CA25N Total full-time and part-time employment by industry,
2014. Website: http: www.bea.gov
U.S. Bureau of Economic Analysis. 2015b. CA5N Personal Income by Major Component and Earnings by
NAICS Industry, 2014. Website: http: www.bea.gov
U.S. Bureau of Labor Statistics. 2015a. Labor Force Data by County, 2014 Annual Averages. Website:
http://www.bls.gov/home.htm
U.S. Bureau of Labor Statistics. 2015b. Regional and State Unemployment – 2014 Annual Averages. News
Release. March 4.

U.S. Census Bureau. 2000. DP-1: Profile of General Demographic Characteristics: 2000. Census 2000
Summary File 1 (SF 1) 100-Percent Data. Website: http://factfinder.census.gov/ (accessed March
8, 2016).
U.S. Census Bureau. 2010. QT-P11-Geography-Texas: Households and Families: 2010. Website:
http://factfinder.census.gov/
U.S. Census Bureau. 2016a. State and County QuickFacts. Website: http://quickfacts.census.gov/
qfd/index.html (accessed March 8, 2016).
U.S. Census Bureau. 2016b. DP04: Selected Housing. 2010-2014 American Community Survey 5-Year
Estimates. Website: http://factfinder.census.gov/faces/nav/jsf/ pages/index.xhtml
U.S. Census Bureau. 2016c. B25004: Vacancy Status. Universe: Vacant Housing Units. 2010-2014
American Community Survey 5-Year Estimates. Website:
http://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml
U.S. Census Bureau. 2016d. Poverty Definitions. Website: http://www.census.gov/hhes/www/poverty/

methods/definitions.html
U.S. Census Bureau. 2016e. B03002: Hispanic or Latino Origin by Race. 2010-2014 American Community
Survey 5-Year Estimates. Website: http://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml
U.S. Census Bureau. 2016f. B17017: Poverty Status in the Past 12 Months by Household Type by Age of
Householder. 2010-2014 American Community Survey 5-Year Estimates. Website:
http://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml.
U.S. Census Bureau. 2019. BO1003: 2010-2014 American Community Survey 5-Year Estimates. Website:
http://factfinder.census.gov/faces/nav/jsf/pages/index.xhtml.
USA Cops. 2015a. Cameron County. Website: http://www.usacops.com/tx/cameron.html (accessed by

Ecology and Environment, Inc. on May 31, 2015).
USA Cops. 2015b. Willacy County. Website: http://www.usacops.com/tx/willacy.html (accessed by

U.S. Department of Transportation. n.d. America’s Byways. Website: http://www.fhwa.dot.gov/byways

(accessed on May 20, 2015).
USEIA (United States Energy Information Administration). 2015. Texas State Energy Profile. Website:
www.eia.gov/state/print.cfm?sid=TX (Accessed May 2015).
USGCRP (U.S. Global Change Research Program). 2017. Climate Science Special Report: Fourth National
Climate Assessment, Volume I, Chapter 3 Detection and Attribution of Climate Change [Wuebbles,
D.J., D.W. Fahey, K.A. Hibbard, D.J. Dokken, B.C. Stewart, and T.K. Maycock (eds.)]. U.S.
Global Change Research Program, Washington, DC, USA, 470 pp., doi: 10.7930/J0J964J6.
USGCRP. 2018. Impacts, Risks, and Adaptation in the United States: Fourth National Climate Assessment,
Volume II: Report-in-Brief [Reidmiller, D.R., C.W. Avery, D.R. Easterling, K.E. Kunkel, K.L.M.
Lewis, T.K. Maycock, and B.C. Stewart (eds.)]. U.S. Global Change Research Program,
Washington, DC, USA, 186 pp.

USGS (U.S. Geological Survey). 2009. Regional Assessment of Tsunami Potential in the Gulf of Mexico.
Website: http://nws.weather.gov/nthmp/documents/GoMFinal01regionalAssessment.pdf
USGS. 2014. Mineral Resources On-Line Spatial Data (MRDS) Online Spatial Data. September 2014.
Website: http://mrdata.usgs.gov/mineral-resources/mrds-us.html (accessed May 2015).
USGS. 2016. National Hydrography Dataset viewer. Website: http://viewer.nationalmap.gov/

viewer/nhd.html?p=nhd (accessed August 2016).
USGS. 2018. Mineral Resources Online Spatial Data, Lissie Formation (TXQI: 0). Website:
https://mrdata.usgs.gov/geology/state/sgmc-unit.php?unit=TXQl%3B0 (accessed September 28,
2018).
Utne-Palm, A.C. 2001. Visual feeding of fish in a turbid environment: physical and behavioural aspects.
Marine Freshwater Behavior Physiology 35(1-2):111–128.
Valley Baptist Medical Center. 2015. Emergency Medicine: Overview. Website:

http://www.valleybaptist.net/medical-services/emergency-medicine/overview (accessed by
Valley Regional Medical Center. 2015. Trauma Center ER. Website:

http://valleyregionalmedicalcenter.com/service/trauma-center-er (accessed by Ecology and
Wallisch, R., and M. Russo. 2015. Draft Non-Archaeological Historic Resources Report [for the] Proposed
Annova LNG Brownsville Project, Cameron County, Texas. Prepared for Environment & Ecology,
Inc. Prepared by Blanton & Associates, Austin, Texas.
Waring, G.T., E. Josephson, K. Maze-Foley, and P.E. Rosel (eds.). 2010. U.S. Atlantic and Gulf of Mexico
Marine Mammal Stock Assessments. NOAA Tech Memo NMFS-NE 213, National Oceanic and
Atmospheric Administration, National Marine Fisheries Service, Northeast Fisheries Science
Center. Website: http://www.nefsc.noaa.gov/publications/tm/tm219
Waring, G.T., E. Josephson, K. Maze-Foley, and P.E. Rosel. 2015. US Atlantic and Gulf of Mexico Marine
Mammal Stock Assessments--2014. NOAA Tech Memo NMFS NE, 231, 361.
Whale and Dolphin Conservation Society. 2004. Oceans of Noise 2004 – A WDCS Science Report. Würsig,
B., G. Jefferson, and Thomas A. Schmidly. 2000. The marine mammals of the Gulf of Mexico. No.
599.5 W9.
Williams, Sandy. 2018. Big River Steel Chooses Brownsville for Next Mill. Steel Market Update, April
25, 2018. Available online at: https://bigriversteel.com/wpcontent/uploads/2018/04/Big-River-
Steel-Chooses-Brownsville-for-Next-Mill-Steel-Market-Update.pdf. Accessed February 2019.
Wilson, G. 2015. Pilot, Brazos-Santiago Pilots Associates. Personal communication with K. Welder
Mollow, Ecology and Environment, Inc., on September 3, 2015.
World Birding Center. 2010. Website: http://www.theworldbirdingcenter.com (accessed July 23, 2015).
WSDOT (Washington State Department of Transportation). 2016. Underwater Sound Level Report:
Colman Dock Test Pile Project 2016. Washington State Department of Transportation Pile Driving

Reports. Website: https://www.wsdot.wa.gov/sites/default/files/2017/12/12/ENV-FW-

AirPileDrivingNoise.pdf
Wursig, B., T.A. Jefferson, and D.J. Schmidly. 2000. The Marine Mammals of the Gulf of Mexico. College
Station, TX. Texas A&M University Press. 232 pages.
Wyoming Department of Environmental Quality. 2015. Permit Application Analysis A0000634, Cheyenne
Generating Station, September 17, 2015.
Wysocki, L.E., J. P. Dittami, and F. Ladich. 2006. Ship Noise and Cortisol Secretion in European
Freshwater Fishes. Biological Conservation 128(4):501–508.
Yellow Wood Associates, Inc. 2004. Report on Potential Economic and Fiscal Impacts on the Town of
Harpswell, Maine, of the LNG Terminal Proposed by TransCanada Pipelines and ConocoPhillips.
Prepared for Fairplay for Harpswell. February 3, 2004. Website:
http://pstrust.org/docs/harpswell_econ_impact_study.pdf
Yudhana, A., J. Din, S. Abdullah Sundari, and R.B.R. Hassan. 2010. Green Turtle Hearing Identification
Based on Frequency Spectral Analysis. Applied Physics Research 2(1):125–134.

APPENDIX M
INDEX
APPENDIX M
SUBJECT INDEX
access road, 1-21, 2-5, 2-7, 2-9, 2-13, 3-1, 3-17, 3- 4-70, 4-74, 4-81, 4-86, 4-87, 4-91, 4-94, 4-96, 4-99,
19, 4-30, 4-31, 4-35, 4-36, 4-37, 4-41, 4-43, 4-44, 4- 4-101, 4-106, 4-108, 4-118, 4-124, 4-127, 4-i, 4-128,
49, 4-66, 4-72, 4-73, 4-75, 4-78, 4-82, 4-87, 4-88, 4- 4-129, 4-130, 4-131, 4-132, 4-133, 4-136, 4-137, 4-
89, 4-90, 4-91, 4-92, 4-93, 4-97, 4-99, 4-105, 4-108, 138, 4-139, 4-140, 4-141, 4-142, 4-144, 4-146, 4-
4-127, 4-149, 4-153, 4-160, 4-161, 4-162, 4-163, 4- 148, 4-154, 4-164, 4-192, 4-206, 4-248, 4-249, 4-
167, 4-179, 4-180, 4-181, 4-253, 4-280, 4-323, 5-8, 255, 4-258, 4-278, 4-280, 4-282, 4-284, 4-286, 4-
5-15, 5-16, 5-20 287, 4-291, 4-292, 4-313, 4-314, 4-315, 4-318, 4-
ACHP (Advisory Council on Historic 321, 4-322, 4-325, 5-6, 5-11
Preservation), 1-8, 4-160, 4-166, 4-167, 5-21 climate change, 4-71, 4-172, 4-326, 4-329, 4-330,
APE (area of potential effect), 1-8, 4-160, 4-161, 4-331, 4-332, 5-14
4-162, 4-163, 4-165, 5-9, 5-10 Coast Guard, 1-5, 1-6, 1-11, 1-21, 2-8, 2-13, 2-20,
API (American Petroleum Institute), 2-15, 4-220, 2-24, 2-25, 4-24, 4-59, 4-60, 4-68, 4-108, 4-109, 4-
4-227, 4-231, 4-233, 4-236, 4-237, 4-239, 4-243, 4- 157, 4-158, 4-205, 4-209, 4-210, 4-211, 4-212, 4-
268, 4-271, 4-273, 5-27, 5-30, 5-32 213, 4-214, 4-215, 4-217, 4-218, 4-219, 4-220, 4-
230, 4-234, 4-243, 4-256, 4-260, 4-262, 4-275, 4-
ASCE (American Society of Civil Engineers), 4-
277, 4-298, 4-312, 5-1, 5-3, 5-11, 5-23, 5-33
207, 4-237, 4-242, 4-243, 4-245, 4-246, 4-247, 4-
248, 4-249 Coastal Management Program, 4-127
ASME (American Society of Mechanical COE (U.S. Army Corps of Engineers), 1-5, 1-15,
Engineers), 2-15, 4-227, 4-273, 5-32 1-21, 1-22, 2-16, 2-20, 4-6, 4-8, 4-17, 4-18, 4-19, 4-
21, 4-22, 4-23, 4-30, 4-31, 4-33, 4-34, 4-39, 4-49, 4-
BA (biological assessment), 1-21, 4-4, 4-65
56, 4-57, 4-59, 4-83, 4-84, 4-85, 4-99, 4-134, 4-249,
Bahia Grande, 1-12, 3-8, 3-14, 4-12, 4-14, 4-16, 4- 4-289, 4-294, 4-297, 4-299, 4-310, 5-1, 5-2, 5-3, 5-4
17, 4-19, 4-21, 4-23, 4-27, 4-47, 4-48, 4-50, 4-54, 4-
commercial fisheries, 4-59, 4-83, 4-321
70, 4-101, 4-103, 4-109, 4-122, 4-123, 4-126, 4-134,
4-215, 4-279, 4-289, 4-293, 4-294, 4-297, 4-299, 4- construction noise, 3-21, 4-48, 4-73, 4-103, 4-196,
301, 4-305, 4-315, 4-323, 5-7, 5-12 4-197, 4-204, 4-332, 4-334, 4-337, 4-338, 4-341, 5-
13, 5-14
BLEVE, 4-222, 4-252, 4-253, 4-255
cooling water, 2-24, 4-26, 4-60, 4-61, 4-238, 4-272,
BMP (best management practice), 2-19, 4-7, 4-
4-298, 4-304, 4-305, 5-5, 5-31
304, 4-311
critical habitat, 1-7, 1-8, 3-16, 3-24, 4-65, 4-66, 4-
BND (Brownsville Navigation District), 1-18, 2-
69, 4-74, 4-77, 4-78, 4-79, 4-80, 4-81, 4-84, 4-86, 4-
7, 2-8, 2-18, 2-23, 2-25, 3-17, 3-19, 3-24, 4-12, 4-
308
14, 4-23, 4-28, 4-33, 4-49, 4-50, 4-57, 4-69, 4-72, 4-
74, 4-76, 4-96, 4-97, 4-99, 4-104, 4-108, 4-109, 4- CWA (Clean Water Act), 1-5, 1-7, 1-21, 1-22, 4-
127, 4-132, 4-135, 4-136, 4-137, 4-141, 4-142, 4- 17, 4-22, 4-30, 4-300
143, 4-146, 4-156, 4-157, 4-158, 4-192, 4-284, 4- CZMA (Coastal Zone Management Act), 1-21,
285, 4-288, 4-289, 4-297, 4-306, 4-311, 4-313, 4- 4-126, 4-127, 5-7
314, 4-315, 5-7, 5-8 DMPA (Dredged Material Placement Area), 2-
BOG (boil-off gas), 1-15, 2-3, 2-5, 2-10, 4-182, 4- 16, 2-17, 2-20, 3-23, 3-24, 4-8, 4-18, 4-22, 4-57, 4-
224, 4-225, 4-227, 4-241, 4-264, 4-266, 4-267, 4- 76, 4-77, 4-78, 4-99, 4-297, 4-323, 5-16
282, 5-25, 5-26, 5-27 DOE (U.S. Department of Energy), 1-3, 1-5, 1-9,
Brazos Island, 1-12, 4-6, 4-14, 4-17, 4-101, 4-104, 1-10, 1-11, 1-22, 3-3, 3-4, 3-6, 3-7, 3-8, 3-9, 3-10,
4-107, 4-289, 4-293, 4-296, 4-310, 5-12 3-11, 4-206, 4-248, 4-256, 4-285, 5-1
CAA (Clean Air Act), 1-7, 1-21, 1-22, 4-170, 4- DOE/FE (U.S. Department of Energy, Office of
171, 4-173, 4-175, 4-176 Fossil Resources), 1-9
Cameron County, 1-1, 1-22, 2-1, 2-7, 3-14, 4-4, 4- DOT (U.S. Department of Transportation), 1-5,
8, 4-10, 4-11, 4-28, 4-45, 4-50, 4-i, 4-65, 4-66, 4-67, 1-6, 2-12, 2-19, 2-24, 2-25, 4-110, 4-205, 4-206, 4-
M-1 Appendix M – Index

207, 4-208, 4-209, 4-219, 4-220, 4-228, 4-229, 4- fugitive dust, 4-168, 4-178, 4-179, 4-180, 4-181, 4-
230, 4-231, 4-233, 4-240, 4-242, 4-244, 4-247, 4- 324, 4-325, 4-326, 5-10
248, 4-252, 4-253, 4-254, 4-255, 4-258, 4-259, 4- fugitive emissions, 4-168, 4-325
261, 4-277, 5-1, 5-11, 5-22 FWS (U.S. Fish and Wildlife Service), 1-5, 1-7,
dredging, 1-12, 2-9, 2-11, 2-16, 2-17, 2-18, 2-20, 3- 1-11, 1-21, 2-7, 3-17, 3-19, 4-14, 4-16, 4-17, 4-26,
12, 3-24, 4-3, 4-4, 4-8, 4-14, 4-18, 4-19, 4-21, 4-22, 4-31, 4-33, 4-35, 4-39, 4-40, 4-41, 4-44, 4-45, 4-46,
4-23, 4-29, 4-48, 4-49, 4-56, 4-57, 4-61, 4-62, 4-63, 4-47, 4-49, 4-50, 4-51, 4-52, 4-54, 4-59, 4-63, 4-65,
4-78, 4-86, 4-97, 4-108, 4-135, 4-165, 4-178, 4-179, 4-66, 4-67, 4-68, 4-69, 4-70, 4-71, 4-72, 4-73, 4-74,
4-195, 4-199, 4-204, 4-289, 4-296, 4-297, 4-304, 4- 4-75, 4-76, 4-77, 4-78, 4-80, 4-81, 4-82, 4-83, 4-85,
305, 4-309, 4-310, 4-311, 4-312, 4-313, 4-316, 4- 4-86, 4-87, 4-91, 4-92, 4-95, 4-97, 4-99, 4-101, 4-
320, 4-332, 4-333, 4-336, 4-337, 4-338, 4-339, 4- 103, 4-108, 4-115, 4-116, 4-122, 4-127, 4-299, 4-
341, 5-2, 5-3, 5-5, 5-6, 5-12, 5-14, 5-15 303, 4-306, 4-307, 4-308, 4-309, 4-313, 5-1, 5-4, 5-
earthquake, 1-13, 4-243, 4-244, 4-245, 4-246, 4- 5, 5-6, 5-8, 5-13, 5-16, 5-20
276, 5-35 Galveston Bay LNG, 3-6, 3-10
Eastern black rail, 4-66, 4-74, 4-82, 5-6 geologic hazards, 4-3, 4-294
EFH (Essential Fish Habitat), 1-8, 1-22, 4-54, 4- geotechnical, 2-14, 4-2, 4-3, 4-4, 4-240, 4-241, 4-
55, 4-64, 5-6 242, 4-245, 4-246
emergency response, 4-140, 4-141, 4-223, 4-228, GHG (greenhouse gases), 3-20, 4-168, 4-169, 4-
4-229, 4-253, 4-255, 4-259, 4-260, 4-262, 4-268, 4- 172, 4-173, 4-175, 4-180, 4-181, 4-182, 4-183, 4-
273, 4-318, 5-22, 5-23, 5-27, 5-28, 5-32 185, 4-280, 4-326, 4-330, 4-331, 4-332, 5-14
entrainment, 4-23, 4-58, 4-60, 4-304 Golden Pass LNG, 3-7, 4-23
environmental justice, 4-143, 4-144, 4-147, 4-322, Great Texas Coastal Birding Trail, 4-109, 4-111
5-9
green sea turtle, 4-82, 4-85, 5-6
EPA (U.S. Environmental Protection Agency),
Gulf Coast jaguarondi, 5-6
1-5, 1-7, 1-11, 1-14, 1-21, 2-11, 2-16, 3-19, 3-20, 3-
21, 3-22, 4-10, 4-12, 4-22, 4-27, 4-28, 4-30, 4-54, 4- Gulf of Mexico, 2-19, 2-21, 4-10, 4-11, 4-12, 4-14,
58, 4-59, 4-63, 4-143, 4-144, 4-146, 4-169, 4-170, 4- 4-24, 4-35, 4-i, 4-41, 4-45, 4-52, 4-53, 4-54, 4-55, 4-
171, 4-172, 4-175, 4-176, 4-177, 4-179, 4-187, 4- 56, 4-57, 4-58, 4-65, 4-66, 4-67, 4-68, 4-82, 4-83, 4-
191, 4-192, 4-195, 4-251, 4-252, 4-254, 4-258, 4- 84, 4-85, 4-86, 4-89, 4-96, 4-98, 4-99, 4-106, 4-108,
259, 4-279, 4-322, 4-325, 4-326, 4-331, 4-332, 5-1, 4-118, 4-134, 4-135, 4-157, 4-158, 4-159, 4-168, 4-
5-3, 5-14 169, 4-214, 4-244, 4-246, 4-247, 4-251, 4-280, 4-
285, 4-304, 4-310, 4-311, 4-312, 4-313, 4-321, 4-
ERP (Emergency Response Plan), 2-24, 4-218, 4-
331, 5-6
259, 4-260, 4-262, 4-263, 5-23
HAPs (hazardous air pollutants), 4-168, 4-173, 4-
Executive Order, 1-5, 1-9, 2-13, 4-44, 4-143, 4-212
175, 4-180, 4-182, 4-183, 4-185, 4-186, 4-190, 4-
FAA (Federal Aviation Administration), 1-5, 1- 280, 4-324, 4-326, 4-329
9, 1-11, 1-22, 4-46, 4-98, 4-99, 4-255, 4-256, 4-257,
hazardous air pollutants, 4-168, 4-190, 4-326
4-261, 4-262, 4-278, 5-1, 5-11, 5-22, 5-23
HAZOP (hazard and operability review), 4-226
Facility Lighting Plan, 4-44, 4-46, 4-47, 4-48, 4-
49, 4-52, 4-63, 5-5, 5-20 historic properties, 4-153, 4-160, 4-161, 4-162, 4-
166, 4-167, 5-21
flaring, 2-4, 3-22, 4-44, 4-45, 4-47, 4-75, 4-78, 4-
79, 4-82, 4-111, 4-113, 4-116, 4-117, 4-118, 4-119, hospitals, 4-141, 4-192, 4-215, 4-246
4-121, 4-122, 4-126, 4-183, 4-185, 4-187, 4-200, 4- housing, 4-138, 4-139, 4-144, 4-318
201, 4-202, 4-204, 4-303, 4-309, 4-341, 5-5, 5-10 hydrostatic testing, 2-8, 2-15, 2-18, 4-18, 4-28, 4-
flooding, 2-10, 4-3, 4-4, 4-27, 4-242, 4-300, 4-301, 29, 4-58, 4-273, 4-297, 4-304, 5-2, 5-3, 5-5, 5-32
4-330, 4-331 IMO (International Maritime Organization), 2-
Freeport LNG, 3-6, 3-7, 3-9 24, 4-24, 4-59, 4-211
FTA (Free Trade Agreement), 1-9, 1-10, 1-22, 3- impingement, 4-28, 4-57
3, 3-4, 3-6, 3-7, 3-8, 3-9, 3-10, 3-11, 4-285 Intergovernmental Panel on Climate Change, 4-
Appendix M – Index M-2

331 149, 4-152, 4-167, 4-177, 4-178, 4-198, 4-199, 4-

internal combustion engine, 4-174, 4-175, 4-179, 206, 4-218, 4-221, 4-222, 4-223, 4-229, 4-231, 4-
4-195 232, 4-233, 4-236, 4-238, 4-242, 4-250, 4-251, 4-
invasive species, 1-12, 4-39, 4-59, 4-81 252, 4-254, 4-256, 4-258, 4-261, 4-272, 4-278, 4-
keeled earless lizard, 4-92, 4-95 299, 4-325, 5-1, 5-2, 5-3, 5-4, 5-8, 5-10, 5-11, 5-13,
5-16, 5-17, 5-18, 5-20, 5-21, 5-31
KOP (key observation point), 4-48, 4-111, 4-113,
4-114, 4-115, 4-116, 4-117, 4-118, 4-119, 4-120, 4- mixed refrigerant, 2-2, 4-224, 4-229
121, 4-122, 4-123, 4-124, 4-125, 4-126, 4-163, 4- MOF (material offloading facility), 2-4, 2-13, 2-
164, 4-165, 4-315, 5-7 17, 2-18, 4-108, 4-195
Laguna Atascosa NWR, 4-33, 4-40, 4-47, 4-48, 4- NAAQS (National Ambient Air Quality
50, 4-70, 4-71, 4-73, 4-74, 4-78, 4-79, 4-99, 4-101, Standards), 4-169, 4-170, 4-172, 4-176, 4-187, 4-
4-103, 4-110, 4-122, 4-124, 4-133, 4-134, 4-309, 4- 188, 4-189, 4-324, 4-326, 4-327, 4-328, 4-329, 5-10,
317, 4-321, 4-336, 4-337, 4-341, 5-4, 5-5, 5-14 5-13
Laguna Madre, 4-12, 4-14, 4-16, 4-19, 4-47, 4-54, National Marine Fisheries Service, 1-5, 1-8
4-56, 4-69, 4-77, 4-83, 4-101, 4-104, 4-106, 4-107, National Oceanic and Atmospheric
4-118, 4-119, 4-122, 4-321 Administration, 1-5, 1-8, 4-252
leatherback sea turtle, 4-84, 4-85, 4-86, 5-6 NEPA (National Environmental Policy Act), 1-1,
Letter of Recommendation, 1-6, 1-21, 4-209, 4- 1-3, 1-5, 1-7, 1-8, 1-9, 1-10, 1-14, 1-15, 1-21, 3-1,
213, 4-217 4-143, 4-147, 4-205, 4-234, 4-251, 4-277, 4-279, 5-
15
LFL (lower flammable limit), 4-270, 5-29, 5-30
NESHAP (National Emission Standards for
LOD (Letter of Determination), 1-6, 4-205, 4- Hazardous Air Pollutants), 4-171, 4-175, 4-178
209, 4-243, 4-247, 4-248, 4-277, 5-11
NFPA (National Fire Protection Association), 1-
loggerhead sea turtle, 4-66, 4-83, 4-84, 4-86, 5-6 6, 2-12, 2-23, 2-24, 2-25, 2-26, 4-207, 4-208, 4-209,
lomas, 1-12, 4-1, 4-4, 4-35, 4-36, 4-37, 4-40, 4-41, 4-222, 4-225, 4-227, 4-228, 4-230, 4-231, 4-233, 4-
4-47, 4-50, 4-70, 4-71, 4-72, 4-92, 4-94, 4-99, 4- 234, 4-235, 4-236, 4-237, 4-238, 4-239, 4-240, 4-
103, 4-110, 4-116, 4-124, 5-4, 5-5 242, 4-244, 4-245, 4-252, 4-254, 4-266, 4-268, 4-
Lomas, 3-14, 4-35, 4-41, 4-309 271, 4-272, 4-274, 5-26, 5-28, 5-30, 5-31, 5-33
Long Island, 4-98, 4-110, 4-128, 4-129, 4-136, 4- NGA (Natural Gas Act), 1-1, 1-3, 1-4, 1-9, 1-10,
146, 4-215 1-15, 1-21, 1-22, 2-19, 3-3, 3-11, 4-44, 4-206, 4-
LOR (Letter of Recommendation), 1-6, 1-21, 2-8, 260, 4-277
4-68, 4-205, 4-209, 4-213, 4-214, 4-217, 4-218, 4- NHL (National Historic Landmark), 1-8, 1-12, 3-
243, 4-247, 4-248, 4-277, 5-11 15, 3-17, 4-104, 4-105, 4-114, 4-115, 4-116, 4-117,
Lower Rio Grande Valley NWR, 4-49, 4-50, 4- 4-154, 4-160, 4-162, 4-163, 4-164, 4-167, 4-192, 4-
70, 4-97, 4-99, 4-101, 4-103, 4-104, 4-110, 4-114, 4- 196, 4-316, 4-317, 4-323, 5-7, 5-9, 5-10, 5-14
115, 4-116, 4-117, 4-127, 4-133, 4-136, 4-146, 4- NHP, 4-162, 4-164, 4-323, 5-7
309 no action alternative, 3-1, 5-15
Marine Mammal Protection Act (MMPA), 1-22, NOAA Fisheries, 1-5, 1-8, 1-11, 1-22, 4-26, 4-52,
4-52, 4-53, 4-65 4-53, 4-54, 4-55, 4-58, 4-59, 4-62, 4-64, 4-65, 4-66,
MBTA (Migratory Bird Treaty Act), 1-7, 1-8, 4- 4-67, 4-68, 4-82, 4-83, 4-84, 4-85, 4-86, 4-95, 4-
44, 4-46, 5-5 122, 4-304, 4-305, 4-310, 4-311, 4-312, 5-6, 5-20
mean sea level, 3-11, 4-19, 4-246 NOI, 1-10, 4-166
migratory bird, 1-8, 1-12, 4-44, 4-45, 4-46, 4-47, 4- noise sensitive area, 3-14, 4-105, 4-192, 4-194, 4-
303, 4-304, 4-309, 5-5, 5-20 196, 4-200, 5-11, 5-14
minority, 4-143, 4-144, 4-147, 4-322, 5-9 non-jurisdictional, 1-4, 1-15, 1-18, 2-1, 2-8, 4-258,
mitigation, 1-4, 1-5, 1-13, 2-10, 2-12, 2-24, 3-24, 4- 4-281, 4-284, 4-285, 4-290, 4-294, 4-296, 4-299, 4-
1, 4-3, 4-7, 4-9, 4-11, 4-19, 4-29, 4-33, 4-34, 4-39, 300, 4-305, 4-306, 4-308, 4-313, 4-314, 4-315, 4-
4-46, 4-49, 4-61, 4-92, 4-94, 4-95, 4-99, 4-113, 4- 320, 4-321, 4-323, 4-324, 4-326, 4-332

northern aplomado falcon, 4-40, 4-74, 4-75, 4-76, ii, 4-132, 4-134, 4-135, 4-136, 4-156, 4-157, 4-158,
4-78, 4-81, 4-82, 4-92, 4-308, 4-309, 5-4, 5-6, 5-13 4-160, 4-194, 4-217, 4-i, 4-282, 4-285, 4-287, 4-288,
Northside Site, 3-14, 3-15, 3-16 4-292, 4-296, 4-297, 4-298, 4-299, 4-303, 4-306, 4-
NPDES (National Pollutant Discharge 307, 4-308, 4-309, 4-310, 4-311, 4-312, 4-313, 4-
Elimination System), 1-7, 1-21, 2-11, 2-15, 2-18, 314, 4-320, 4-326, 4-327, 5-8, 5-13
4-22, 4-27, 4-63, 4-305, 5-3 pre-filing process, 1-10, 1-11, 3-2, 3-8, 3-10, 4-
NWR (National Wildlife Refuge), 1-12, 1-21, 3- 147, 4-285
17, 4-40, 4-47, 4-48, 4-49, 4-50, 4-70, 4-74, 4-80, 4- PSD (Prevention of Significant Deterioration),
99, 4-101, 4-103, 4-104, 4-115, 4-116, 4-122, 4-133, 1-22, 3-20, 4-171, 4-172, 4-173, 4-177, 4-185, 4-
4-134, 4-163, 4-188, 4-189, 4-292, 4-302, 4-333 188, 4-326
ocelot, 1-12, 2-7, 3-19, 4-40, 4-41, 4-50, 4-51, 4-69, public scoping, 1-11, 4-106, 4-147, 4-322
4-70, 4-71, 4-72, 4-73, 4-74, 4-95, 4-103, 4-306, 4- recommendation, 4-46, 4-48, 4-49, 4-73, 4-76, 4-
307, 4-308, 5-4, 5-6, 5-12 92, 4-93, 4-153, 4-198, 4-218, 4-241, 4-257, 4-262,
OEP (Office of Energy Projects), 1-1, 4-9, 4-44, 4-274, 4-307, 4-310, 4-312, 5-2, 5-5, 5-8, 5-33
4-95, 4-167, 4-198, 4-261, 4-274, 4-275, 4-277, 5-2, recreational fishing, 1-11, 1-12, 4-108, 4-133, 4-
5-5, 5-10, 5-16, 5-17, 5-18, 5-19, 5-20, 5-21, 5-22, 157, 4-158, 5-7
5-33, 5-35 red knot, 4-74, 4-77, 4-78, 4-79, 4-308, 4-309, 5-6
off-site parking, 4-153, 4-154, 5-8, 5-20 red-crowned parrot, 4-74, 4-79, 4-80, 4-308, 5-6
operational noise, 3-21, 4-202, 4-204, 4-302, 4- residences, 3-2, 4-99, 4-110, 4-117, 4-127, 4-136,
332, 4-339, 5-14 4-146, 4-192, 4-313, 4-319, 4-332, 4-333, 5-7, 5-8
Palmito Ranch Battlefield NHL, 1-8, 4-99, 4-101, Rio Grande LNG, 3-6, 3-8, 3-14, 3-15, 4-80, 4-98,
4-104, 4-105, 4-110, 4-114, 4-115, 4-116, 4-127, 4- 4-136, 4-215, 4-258, 4-259, 4-284, 4-286, 4-287, 4-
152, 4-154, 4-160, 4-161, 4-162, 4-163, 4-167, 4- 289, 4-291, 4-294, 4-296, 4-298, 4-299, 4-301, 4-
192, 4-196, 4-197, 4-316, 4-317, 4-323, 4-340, 5-7, 303, 4-304, 4-305, 4-306, 4-307, 4-308, 4-309, 4-
5-9, 5-10 310, 4-311, 4-312, 4-313, 4-314, 4-315, 4-316, 4-
Palo Alto Battlefield NHP, 4-127, 4-163, 4-164, 317, 4-319, 4-320, 4-322, 4-323, 4-324, 4-325, 4-
4-167, 4-317, 4-319, 4-323, 5-7, 5-10 326, 4-327, 4-328, 4-332, 4-333, 4-336, 4-337, 4-
parking, 2-13, 4-7, 4-107, 4-109, 4-115, 4-124, 4- 338, 4-339, 4-340, 4-341, 5-12, 5-13, 5-14
153, 4-154, 4-319, 5-8, 5-20 RRC (Railroad Commission of Texas), 1-22, 2-
PHMSA (Pipeline and Hazardous Materials 15, 4-2, 4-22, 4-28, 4-58, 4-127, 5-3
Safety Administration), 2-24, 2-25, 4-209, 4-243, salinity, 4-6, 4-11, 4-17, 4-24, 4-25, 4-30, 4-36, 4-
4-252, 4-253, 4-254, 4-255, 4-258 58, 4-90, 4-298, 4-305, 5-3
pile driving, 4-48, 4-49, 4-56, 4-61, 4-62, 4-71, 4- San Martin Lake, 4-14, 4-16, 4-33, 4-80, 4-101, 4-
78, 4-81, 4-85, 4-86, 4-195, 4-196, 4-197, 4-198, 4- 103, 4-106
199, 4-204, 4-304, 4-305, 4-310, 4-311, 4-312, 4- schools, 4-110, 4-141, 4-215, 4-246, 4-318, 4-322
333, 4-336, 4-337, 4-338, 4-339, 5-6, 5-10, 5-13, 5- Seagrass, 4-i, 4-19, 4-20, 4-54
21
Secretary, 1-8, 1-9, 1-10, 4-9, 4-44, 4-46, 4-47, 4-
piping plover, 1-12, 3-16, 3-24, 4-66, 4-74, 4-76, 4-
59, 4-127, 4-167, 4-198, 4-200, 4-201, 4-261, 4-275,
77, 4-78, 4-79, 4-308, 4-309, 5-6
5-5, 5-7, 5-16, 5-17, 5-18, 5-19, 5-20, 5-21, 5-22, 5-
Port Arthur LNG, 3-6, 3-9 34
Port Isabel, 1-11, 1-12, 1-14, 3-16, 3-24, 4-19, 4- Secretary of the Commission, 4-9
45, 4-47, 4-77, 4-98, 4-104, 4-106, 4-108, 4-110, 4- Section 106, 1-22, 4-160, 4-162, 4-167, 5-10
120, 4-121, 4-128, 4-129, 4-132, 4-134, 4-135, 4-
136, 4-141, 4-146, 4-147, 4-151, 4-154, 4-156, 4-
SGCN, 4-94, 4-95
157, 4-168, 4-192, 4-215, 4-217, 4-255, 4-259, 4- SHPO (State Historic Preservation Office), 4-
289, 4-293, 4-305, 4-322, 4-327, 5-5 160, 4-161, 4-162, 4-165, 4-166, 4-167, 4-280, 5-9.
5-21
Port of Brownsville, 1-15, 2-11, 3-8, 3-14, 3-15, 3-
16, 4-16, 4-18, 4-104, 4-106, 4-107, 4-108, 4-109, 4- shrimp, 4-55, 4-56, 4-57, 4-60, 4-132, 4-134, 4-135,
Appendix M – Index M-4

4-157, 4-159, 4-321 313, 4-314, 4-315, 4-316, 4-317, 4-319, 4-320, 4-
shrimpers, 4-135, 4-157 322, 4-323, 4-324, 4-325, 4-326, 4-327, 4-328, 4-
SIP (State Implementation Plan), 4-170, 4-176, 4- 332, 4-333, 4-336, 4-337, 4-338, 4-339, 4-340, 4-
177 341, 5-12, 5-13, 5-14
SOC (species of concern), 4-44, 4-45, 4-54, 4-94, threatened and endangered species, 1-22, 3-21, 4-
4-95, 4-308, 4-309 40, 4-65, 4-153, 4-306, 5-6
South Bay, 1-12, 3-14, 3-16, 4-12, 4-14, 4-16, 4-17, TPWD (Texas Parks and Wildlife Department),
4-19, 4-27, 4-28, 4-42, 4-50, 4-54, 4-56, 4-95, 4-99, 1-11, 1-22, 2-16, 4-14, 4-16, 4-19, 4-26, 4-35, 4-43,
4-101, 4-104, 4-107, 4-108, 4-110, 4-133, 5-13, 5-15 4-50, 4-51, 4-52, 4-54, 4-55, 4-65, 4-80, 4-86, 4-87,
4-89, 4-90, 4-91, 4-92, 4-93, 4-94, 4-97, 4-104, 4-
South Bay Site, 3-14, 3-16
107, 4-108, 4-110, 4-307, 4-308, 5-5
South Padre Island, 3-16, 4-101, 4-103, 4-106, 4-
TSS (total suspended solids), 4-18,4-19, 4-21, 4-
107, 4-108, 4-109, 4-113, 4-118, 4-119, 4-128, 4-
22, 4-28, 4-58, 5-2
133, 4-134, 4-138, 4-215, 4-250, 4-255, 4-259, 4-
287, 4-288, 4-289, 4-292, 4-293, 4-300, 4-301, 4- TxDOT (Texas Department of Transportation),
315 4-72, 4-148, 4-149, 4-153, 4-154, 4-286, 4-287, 4-
292
South Texas Coastal Corridor, 4-50, 4-70, 4-71,
4-306 Valley Crossing, 1-15, 4-258, 4-282, 4-285, 4-299,
Southside Site, 3-14, 3-15, 3-16 4-300, 4-306, 4-307, 4-308, 4-309, 4-312, 4-313, 4-
314
SpaceX, 1-9, 1-12, 1-13, 4-i, 4-98, 4-99, 4-100, 4-
Valley Crossing Pipeline System, 1-15, 4-282
217, 4-256, 4-257, 4-262, 4-274, 4-278, 4-289, 4-
293, 4-299, 4-306, 4-307, 4-308, 4-313, 4-333, 5-7, vibration, 4-91, 4-199, 4-243, 4-333, 5-10
5-11, 5-23, 5-32 Visual Impact Assessment, 4-111, 4-126, 4-280,
SPCC (Spill Prevention, Control, and 5-7
Countermeasures), 2-11, 2-12, 2-13, 2-19, 4-7, 4-9, water quality, 1-7, 1-12, 4-11, 4-14, 4-16, 4-17, 4-
4-11, 4-27, 4-28, 4-63, 4-95, 4-295, 4-297, 4-305, 5- 18, 4-19, 4-21, 4-22, 4-23, 4-24, 4-25, 4-27, 4-28, 4-
1, 5-3, 5-6, 5-20 30, 4-40, 4-48, 4-49, 4-50, 4-57, 4-63, 4-86, 4-115,
species of greatest conservation need, 4-94 4-280, 4-296, 4-297, 4-298, 4-300, 4-301, 4-304, 4-
305, 4-311, 5-2, 5-3, 5-6, 5-12
spill containment, 2-25, 4-11, 4-220, 4-222, 4-228,
4-229, 4-230, 4-235, 4-237, 4-268, 5-28 West Indian manatee, 4-66, 4-68, 4-87, 4-312, 4-
313, 5-6
SSE (safe shutdown earthquake), 4-244, 4-245
wetlands, 1-4, 1-5, 1-12, 2-11, 3-2, 3-8, 3-16, 3-19,
STEC (South Texas Electric Cooperative), 1-17, 4-7, 4-30, 4-31, 4-33, 4-34, 4-35, 4-36, 4-40, 4-41,
2-8, 4-142, 4-282, 4-284, 4-294, 4-314, 4-315, 4-291
4-49, 4-52, 4-54, 4-81, 4-89, 4-93, 4-97, 4-110, 4-
tax revenue, 4-137, 4-159, 4-318, 4-322, 5-8 115, 4-125, 4-127, 4-153, 4-280, 4-298, 4-299, 4-
TCEQ (Texas Commission on Environmental 300, 4-309, 4-313, 4-331, 5-1, 5-3, 5-4
Quality), 1-22, 4-10, 4-16, 4-17, 4-22, 4-27, 4-28, whooping crane, 4-80, 5-6
4-30, 4-54, 4-169, 4-171, 4-178, 4-183, 4-185, 4-
workforce, 1-13, 2-9, 4-141, 4-148, 4-149, 4-257,
187, 4-188
4-317, 4-318, 5-8
Texas LNG, 3-6, 3-8, 3-15, 4-98, 4-136, 4-215, 4- WSA (Waterway Suitability Assessmen), 1-6, 1-
259, 4-284, 4-285, 4-286, 4-287, 4-291, 4-294, 4-
21, 2-8, 4-212, 4-213, 4-214, 4-217, 4-277, 5-11
296, 4-298, 4-299, 4-301, 4-303, 4-304, 4-305, 4-
306, 4-307, 4-308, 4-309, 4-310, 4-311, 4-312, 4-

APPENDIX L
COMMENTS ON THE DRAFT EIS AND RESPONSES
PART 1
TABLE L-1
Comments Received on the Draft EIS

Date of Letter/ FERC Docket
Letter Number Agency/Commenter Name
Comment Session Accession Number
FEDERAL AGENCIES (FA)
FA01 NOAA National Marine Fisheries Service 2/5/19 20190206-5004
FA02 United States Coast Guard, Margaret Brown 2/5/19 20190205-5000
FA03 United States Environmental Protection Agency 3/12/19 20190312-5206
FA04 United States Department of Interior 3/13/19 20190313-5200
STATE AGENCIES (SA)
SA01 Texas Commission on Environmental Quality 1/22/19 20190122-0008
SA02 Texas Parks & Wildlife Department 2/4/19 20190204-5206
SA03 Railroad Commission of Texas 3/1/19 20190308-5128
SA04 Railroad Commission of Texas 3/6/19 20190315-0010
LOCAL AGENCIES (LA)
LA01 Port of Brownsville 1/29/19 20190201-5216
COMPANIES AND ORGANIZATIONS (CO)
CO01 Suntrack Supply Services Inc 1/22/19 20190122-0007
CO02 Greater Brownsville Incentives Corporation 1/18/19 20190125-0041
CO03 South Texas Manufacturers Association 1/15/19 20190129-0035
CO04 Friends of Laguna Atascosa National Wildlife Refuge 2/4/19 20190204-5139
CO05 Annova LNG 2/4/19 20190204-5178
CO06 Friends of the Wildlife Corridor 2/4/19 20190204-5190
CO07 Institute for Policy Integrity 2/4/19 20190204-5245
CO08 Center for Liquified Natural Gas 1/24/19 20190130-5136
CO09 Annova LNG 2/4/19 20190204-5216
CO10 Sierra Club 2/4/19 20190204-5185
CO12 South Padre Chamber of Commerce 1/11/19 20190122-0006
ELECTED OFFICIALS (EO)
EO01 Texas House of Representatives, District 38 2/1/19 20190204-5194
EO02 Texas House of Representatives 2/4/19 20190226-0015
EO03 Lieutenant Governor Dan Patrick 2/4/19 20190226-0014
EO04 Senator Eddie Lucio, Jr. 3/13/19 20190314-5000
PUBLIC COMMENT SESSION (PM)
January 10, 2019 Public Comment Session – multiple
PM01 1/10/19 20190222-4000
individuals, see transcript below
INDIVIDUALS (IND)
IND01 Thomas Smith 12/28/18 20181228-5079
IND02 Kenneth G. Teague 1/4/19 20190104-5083
IND03 Gary Richards 1/9/19 20190109-5045
IND04 Jim Russell 1/14/19 20190114-5005
IND05 Sumner Herrick 1/14/19 20190114-5004
IND06 Justin Vosburg 1/14/19 20190114-5009
IND07 Mary A Branch 1/23/19 20190123-5146
IND08 Marie Norrell 1/25/19 20190125-0025
IND09 Sarah Stueber Bishop Merrill, M.S., Ph.D. 1/25/19 20190125-5022
IND10 Joyce Hamilton 1/29/19 20190129-0034
IND11 Individual 1/31/19 20190131-0011
IND12 Brian Schill 2/1/19 20190201-5120
IND13 Young 2/4/19 20190204-5089
IND14 Christine G Rakestraw 2/4/19 20190204-5062
IND15 Diane Teter 2/4/19 20190204-5105
IND16 Patrick Anderson 2/4/19 20190204-5173
IND17 Sarah Simpson 2/6/19 20190206-0014
IND18 Donald L Hockaday 2/4/19 20190204-5222
IND19 Christine G Rakestraw 2/5/19 20190205-5003
IND20 Barbara Hegarty 2/5/19 20190205-5010
IND21 Don Hockaday 2/4/19 20190205-5005
IND22 John Young 2/4/19 20190204-5256
IND23 Joyce M Hamilton 2/5/19 20190205-5026
IND24 Brooke Osborne 2/5/19 20190205-0007
IND25 Mickey Fetonte 2/5/19 20190205-0008
L-i Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND26 Liz Zepeda 2/5/19 20190205-0009
IND27 Kathleen Sjodin-Bunse 2/5/19 20190205-0010
IND28 Susan F Van Haitsma 2/5/19 20190205-0011
IND29 Austin Hyde 2/5/19 20190205-0012
IND30 Elyssa Browning 2/5/19 20190205-0013
IND31 Victoria Hendricks 2/5/19 20190205-0014
IND32 Brooke Penny 2/5/19 20190205-0015
IND33 Michael Panels 2/5/19 20190205-0016
IND34 Sean Carpenter 2/5/19 20190205-0017
IND35 Alyssa Tharp 2/5/19 20190205-0018
IND36 Kevin Gay 2/5/19 20190205-0019
IND37 Amanda Wright 2/5/19 20190205-0020
IND38 Suzzie Gagble 2/5/19 20190205-0021
IND39 Kiko Villamizar 2/5/19 20190205-0022
IND40 Barbara Hegarty 2/5/19 20190205-5010
IND41 Brianna Gaytan 2/5/19 20190205-5021
IND42 Cecilia Garrett 2/5/19 20190205-5022
IND43 Daniel Velez 2/5/19 20190205-5023
IND44 Cynthia Price 2/5/19 20190205-5024
IND45 David Fisher 2/5/19 20190205-5025
IND46 Elizabeth Pearl 2/5/19 20190205-5025
IND47 Ester H. Ybarra 2/5/19 20190205-5025
IND48 Gordon Watt 2/5/19 20190205-5025
IND49 Howard Cohen 2/5/19 20190205-5025
IND50 Joan Killelea 2/5/19 20190205-5025
IND51 John Keller 2/5/19 20190205-5025
IND52 Jonathan Salinas 2/5/19 20190205-5025
IND53 Juan Perez 2/5/19 20190205-5025
IND54 Karen Holleschau 2/5/19 20190205-5025
IND55 Kent Wittenburg 2/5/19 20190205-5025
IND56 Laura Germany 2/5/19 20190205-5025
IND57 Lee Hamilton 2/5/19 20190205-5025
IND58 Leigh Holleschau 2/5/19 20190205-5025
IND59 Lessie Spindle 2/5/19 20190205-5025
IND60 Linda Cooke 2/5/19 20190205-5025
IND61 Lynne Schaffer 2/5/19 20190205-5025
IND62 Marion Mason 2/5/19 20190205-5025
IND63 Marla Hanks 2/5/19 20190205-5025
IND64 Michele Cole 2/5/19 20190205-5025
IND65 Mimi Calter 2/5/19 20190205-5025
IND66 Muhammad Rashid 2/5/19 20190205-5025
IND67 Ned Sheats 2/5/19 20190205-5025
IND68 Rachael Brown 2/5/19 20190205-5025
IND69 Roberto Chavez 2/5/19 20190205-5025
IND70 Sarah Simpson 2/5/19 20190205-5025
IND71 Scott Nicol 2/5/19 20190205-5025
IND72 Terence Garrett 2/5/19 20190205-5025
IND73 Thomas Nieland 2/5/19 20190205-5025
IND74 Victoria Scharen 2/5/19 20190205-5025
IND75 Wacy Maggs 2/5/19 20190205-5025
IND76 Phyllis Sanders 2/6/19 20190206-0012
IND77 Carol Creech 2/6/19 20190206-0012
IND78 Nanette Gordon 2/6/19 20190206-0012
IND79 Stanley Wright 2/6/19 20190206-0012
IND80 Laura Hageman 2/6/19 20190206-0012
IND81 Kathleen Kinzler 2/6/19 20190206-0012
IND82 Kimo Virtanen 2/6/19 20190206-0012
IND83 William Larowe 2/6/19 20190206-0012
IND84 David Larsen 2/6/19 20190206-0012
IND85 Olivia Brown 2/6/19 20190206-0012
IND86 Kathryn Cain 2/6/19 20190206-0012
L-ii Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND87 Stuart Crane 2/6/19 20190206-0012
IND88 Anna George 2/6/19 20190206-0012
IND89 Thomas Garcia 2/6/19 20190206-0012
IND90 Terry Burns 2/6/19 20190206-0012
IND91 Emily Garza 2/6/19 20190206-0012
IND92 Juli Kring 2/6/19 20190206-0012
IND93 Zeoma Olszewski 2/6/19 20190206-0012
IND94 Melinda Fritsch 2/6/19 20190206-0012
IND95 Ashley Jones 2/6/19 20190206-0012
IND96 Betty Mcdugald 2/6/19 20190206-0012
IND97 Linda Charlton 2/6/19 20190206-0012
IND98 Ruth Keitz 2/6/19 20190206-0012
IND99 Christian Rodriguez 2/6/19 20190206-0012
IND100 Brandy Gibbs 2/6/19 20190206-0012
IND101 Adriana Gonzalez 2/6/19 20190206-0012
IND102 Roberto Alvarado 2/6/19 20190206-0012
IND103 Greg Grubb 2/6/19 20190206-0012
IND104 Doug Simmer 2/6/19 20190206-0012
IND105 Beth Ann Sikes 2/6/19 20190206-0012
IND106 Natalie Martens 2/6/19 20190206-0012
IND107 Megan O’Connell 2/6/19 20190206-0012
IND108 Samuel Boazman 2/6/19 20190206-0012
IND109 Pam Sohan 2/6/19 20190206-0012
IND110 Patricia Stella 2/6/19 20190206-0012
IND111 Carolynn Snyder 2/6/19 20190206-0012
IND112 Teresa French 2/6/19 20190206-0012
IND113 Girard Arcand 2/6/19 20190206-0012
IND114 David Will 2/6/19 20190206-0012
IND115 Gary Hild 2/6/19 20190206-0012
IND116 FM 2/6/19 20190206-0012
IND117 Jed Mccuistion 2/6/19 20190206-0012
IND118 Walter Breymann 2/6/19 20190206-0012
IND119 Nelda Salinas 2/6/19 20190206-0012
IND120 Marta Diaz 2/6/19 20190206-0012
IND121 Anita Cannata-Nowell 2/6/19 20190206-0012
IND122 Allison Zborowski 2/6/19 20190206-0012
IND123 Mary Miller 2/6/19 20190206-0012
IND124 Deirdre Ohearn 2/6/19 20190206-0012
IND125 Marj Sears 2/6/19 20190206-0012
IND126 Derek Eckert 2/6/19 20190206-0012
IND127 Catherine Davis 2/6/19 20190206-0012
IND128 Barbara and Roby Odom 2/6/19 20190206-0012
IND129 Christine Lockhart 2/6/19 20190206-0012
IND130 Luis Zepeda 2/6/19 20190206-0012
IND131 Rick Provencio 2/6/19 20190206-0012
IND132 Veronica Perez 2/6/19 20190206-0012
IND133 Johnny Whitright 2/6/19 20190206-0012
IND134 Tracy Bonner 2/6/19 20190206-0012
IND135 Susan Cooper 2/6/19 20190206-0012
IND136 Margaret Tatum 2/6/19 20190206-0012
IND137 Carol Creech 2/6/19 20190206-0012
IND138 Jerry Mylius 2/6/19 20190206-0012
IND139 J Wells 2/6/19 20190206-0012
IND140 Eunice Garza 2/6/19 20190206-0012
IND141 Marianne and Stefan Vogt 2/6/19 20190206-0012
IND142 Austin Gray 2/6/19 20190206-0012
IND143 Chris Nicolosi 2/6/19 20190206-0012
IND144 Payten Maness 2/6/19 20190206-0012
IND145 Robert Perry 2/6/19 20190206-0012
IND146 Neal Baron 2/6/19 20190206-0012
IND147 Richard Walsh 2/6/19 20190206-0012
L-iii Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND148 Guadalupe Yanez 2/6/19 20190206-0012
IND149 Diane Adams 2/6/19 20190206-0012
IND150 Pam Sonnen 2/6/19 20190206-0012
IND151 Charles Spencer 2/6/19 20190206-0012
IND152 Ashley Nelson 2/6/19 20190206-0012
IND153 John Willis 2/6/19 20190206-0012
IND154 Sandra Lira 2/6/19 20190206-0012
IND155 Melissa Noriega 2/6/19 20190206-0012
IND156 Juan Tejeda 2/6/19 20190206-0012
IND157 Molly Neeley 2/6/19 20190206-0012
IND158 Colleen Dieter 2/6/19 20190206-0012
IND159 Wenceslao Garza 2/6/19 20190206-0012
IND160 Melanie Sinclair 2/6/19 20190206-0012
IND161 Joan Cunningham 2/6/19 20190206-0012
IND162 Amber Manske 2/6/19 20190206-0012
IND163 Mark Goodman 2/6/19 20190206-0012
IND164 Danielle Ivie 2/6/19 20190206-0012
IND165 Barbara Swearingen 2/6/19 20190206-0012
IND166 Joe De Souza 2/6/19 20190206-0012
IND167 Mary D. Cartwright 2/6/19 20190206-0012
IND168 Jack Demarais 2/6/19 20190206-0012
IND169 Kristi Collins 2/6/19 20190206-0012
IND170 Archana Purushotham 2/6/19 20190206-0012
IND171 Terrie Williams 2/6/19 20190206-0012
IND172 George Duncan 2/6/19 20190206-0012
IND173 Neala Johnson 2/6/19 20190206-0012
IND174 H. Guh 2/6/19 20190206-0012
IND175 Lucinda Wierenga 2/6/19 20190206-0012
IND176 Mel Jordan 2/6/19 20190206-0012
IND177 Mary Tietjen 2/6/19 20190206-00124
IND178 Bianca Acosta 2/12/19 20190206-0012
IND179 Gabriela Trevino 2/12/19 20190206-0012
IND180 Susan Cooper 2/6/19 20190206-0012
IND181 Debra Johnson 2/6/19 20190206-0012
IND182 Margot Moczygemba 2/6/19 20190206-0012
IND183 Amanda Kay 2/6/19 20190206-0012
IND184 Leslie Hines 2/6/19 20190206-0012
IND185 Cristela Sifuentez 2/6/19 20190206-0012
IND186 Patricia Beltran 2/6/19 20190206-0012
IND187 Kara Page 2/6/19 20190206-0012
IND188 Madalynn Carey 2/6/19 20190206-0012
IND189 Catherine Pleasants 2/6/19 20190206-0012
IND190 Phillip Shephard 2/6/19 20190206-0012
IND191 John Rath 2/6/19 20190206-0012
IND192 Charles Foreman 2/6/19 20190206-0012
IND193 Richard Powe 2/6/19 20190206-0012
IND194 Ron Unger 2/6/19 20190206-0012
IND195 Nadia Traietti 2/6/19 20190206-0012
IND196 Joyce Dixon 2/6/19 20190206-0012
IND197 Helena Hopson 2/6/19 20190206-0012
IND198 Amanda Mahfood 2/6/19 20190206-0012
IND199 David Carter 2/6/19 20190206-0012
IND200 Cheryl Tanski 2/6/19 20190206-0012
IND201 Zachary Roberts Myones 2/6/19 20190206-0012
IND202 Ray C. Telfair II 2/6/19 20190206-0012
IND203 Marta Hubbard 2/6/19 20190206-0012
IND204 William Hoenes 2/6/19 20190206-0012
IND205 David Mulcihy 2/6/19 20190206-0012
IND206 Malva McIntosh 2/6/19 20190206-0012
IND207 James OFlaherty 2/6/19 20190206-0012
IND208 Janet Nongbri 2/6/19 20190206-0012
L-iv Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND209 Catherine Milbourn 2/6/19 20190206-0012
IND210 Carolyn Nieland 2/6/19 20190206-0012
IND211 Tom Nieland 2/6/19 20190206-0012
IND212 Douglas Rives 2/6/19 20190206-0012
IND213 Andrew Lyall 2/6/19 20190206-0012
IND214 Elizabeth Rowland 2/6/19 20190206-0012
IND215 Craig Tatum 2/6/19 20190206-0012
IND216 Rebecca Sims 2/6/19 20190206-0012
IND217 Delaina Foster 2/6/19 20190206-0012
IND218 Ricardo Rojas 2/6/19 20190206-0012
IND219 Maria Reyna-Gomez 2/6/19 20190206-0012
IND220 Julie Bush 2/6/19 20190206-0012
IND221 Virginia Downing 2/6/19 20190206-0012
IND222 Rebecca Hall 2/6/19 20190206-0012
IND223 Santiago Gomez 2/6/19 20190206-0012
IND224 Maria Anna Esparza 2/6/19 20190206-0012
IND225 Michael Chavez 2/6/19 20190206-0012
IND226 Roel Cantu 2/6/19 20190206-0012
IND227 Rick Cruz 2/6/19 20190206-0012
IND228 Becky Wharton 2/6/19 20190206-0012
IND229 Kate Wasserman 2/6/19 20190206-0012
IND230 Ryan W. 2/6/19 20190206-0012
IND231 David Garcia 2/6/19 20190206-0012
IND232 Chia Guillory 2/6/19 20190206-0012
IND233 Craig Parker 2/6/19 20190206-0012
IND234 Mark Klugiewicz 2/6/19 20190206-0012
IND235 Darryl Malek-wiley 2/6/19 20190206-0012
IND236 Noe Acevedo 2/6/19 20190206-0012
IND237 Delysia Moore 2/6/19 20190206-0012
IND238 Alfonso Saldana 2/6/19 20190206-0012
IND239 Laurie Ward 2/6/19 20190206-0012
IND240 Amparo B. de Navarro 2/6/19 20190206-0012
IND241 Cheryl Smith 2/6/19 20190206-0012
IND242 Dale and Mary Erdmann 2/6/19 20190206-0012
IND243 Ken Dixon 2/6/19 20190206-0012
IND244 John Hanson 2/6/19 20190206-0012
IND245 Velia Garcia 2/6/19 20190206-0012
IND246 Leah Huddleston 2/6/19 20190206-0012
IND247 Jacob Shields 2/6/19 20190206-0012
IND248 Sara Gilath 2/6/19 20190206-0012
IND249 Kevin Rivas 2/6/19 20190206-0012
IND250 Karli Scalise 2/6/19 20190206-0012
IND251 Robin Sherwin 2/6/19 20190206-0012
IND252 Scarlett Bacon 2/6/19 20190206-0012
IND253 Courtney Sulak 2/6/19 20190206-0012
IND254 Michael Peterson 2/6/19 20190206-0012
IND255 Ingrid Hansen 2/6/19 20190206-0012
IND256 Roger Mathre 2/6/19 20190206-0012
IND257 Laura Codina 2/6/19 20190206-0012
IND258 Eleanor Raybold 2/6/19 20190206-0012
IND259 Denis Tidrick 2/6/19 20190206-0012
IND260 Karen Hill 2/6/19 20190206-0012
IND261 Shelley Dunham 2/6/19 20190206-0012
IND262 Frances Morgan 2/6/19 20190206-0012
IND263 Craig Parker 2/6/19 20190206-0014
IND264 Martha Eberle 2/6/19 20190206-0013
IND265 Isys Chamberlain 2/6/19 20190206-0013
IND266 Tresa Colston 2/6/19 20190206-0013
IND267 Andrew Hernandez 2/6/19 20190206-0013
IND268 Beverly Walker 2/6/19 20190206-0013
IND269 James Flanagan 2/6/19 20190206-0013
L-v Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND270 Thomas Nicolazzo 2/6/19 20190206-0013
IND271 Cindy Arellano 2/6/19 20190206-0013
IND272 Omar Elizondo 2/6/19 20190206-0013
IND273 Regina Stanley 2/6/19 20190206-0013
IND274 Camilla Figueroa 2/6/19 20190206-0013
IND275 Linda Hahus 2/6/19 20190206-0013
IND276 Naomi Dove 2/6/19 20190206-0013
IND277 Yvonne Hansen 2/6/19 20190206-0013
IND278 Dawn Langerock 2/6/19 20190206-0013
IND279 Jeff Tave 2/6/19 20190206-0013
IND280 Renee Reeves 2/6/19 20190206-0013
IND281 John Nelson 2/6/19 20190206-0013
IND282 Lily Beaumont 2/6/19 20190206-0013
IND283 Steve Bradley 2/6/19 20190206-0013
IND284 Steven Reilly 2/6/19 20190206-0013
IND285 Jean Finch 2/6/19 20190206-0013
IND286 Jennifer Prevost 2/6/19 20190206-0013
IND287 Spike Werda 2/6/19 20190206-0013
IND288 Jamie Owens 2/6/19 20190206-0013
IND289 Dennis Han 2/6/19 20190206-0013
IND290 Abbas Abbohamidi 2/6/19 20190206-0013
IND291 Phyllis Price 2/6/19 20190206-0013
IND292 Audrey H 2/6/19 20190206-0013
IND293 Mary Leon 2/6/19 20190206-0013
IND294 Venkata Kothapalli 2/6/19 20190206-0013
IND295 Marilyn Spivey 2/6/19 20190206-0013
IND296 Stacie Wells 2/6/19 20190206-0013
IND297 Sandy Schmidt 2/6/19 20190206-0013
IND298 Claud Bramblett 2/6/19 20190206-0013
IND299 Cindy Gabrielsen 2/6/19 20190206-0013
IND300 Ann Sever 2/6/19 20190206-0013
IND301 William Rosenthal 2/6/19 20190206-0013
IND302 Mike Harris 2/6/19 20190206-0013
IND303 David Bell 2/6/19 20190206-0013
IND304 Robert Arber 2/6/19 20190206-0013
IND305 Vincent Fonseca 2/6/19 20190206-0013
IND306 Linda Bedre Vaughn 2/6/19 20190206-0013
IND307 Diego Gavilanes 2/6/19 20190206-0013
IND308 Anne Martin 2/6/19 20190206-0013
IND309 Joel Quaintance 2/6/19 20190206-0013
IND310 Yesenia Ceja 2/6/19 20190206-0013
IND311 Aaron Faris 2/6/19 20190206-0013
IND312 Mark Hellums 2/6/19 20190206-0013
IND313 Cynthia Maguire 2/6/19 20190206-0013
IND314 Merilee Phillips 2/6/19 20190206-0013
IND315 Jim Jones 2/6/19 20190206-0013
IND316 Jim Boldin 2/6/19 20190206-0013
IND317 Ma Strange 2/6/19 20190206-0013
IND318 Bob Freeman 2/6/19 20190206-0013
IND319 Sondra York 2/6/19 20190206-0013
IND320 Monica Cortes 2/6/19 20190206-0013
IND321 Don Sawyer 2/6/19 20190206-0013
IND322 Ivy Buchanan 2/6/19 20190206-0013
IND323 Pat Smith 2/6/19 20190206-0013
IND324 Patricia Stinson-Sunbury 2/6/19 20190206-0013
IND325 Steven Smith 2/6/19 20190206-0013
IND326 Lisa Chung 2/6/19 20190206-0013
IND327 Laura Burns 2/6/19 20190206-0013
IND328 Steve Sears 2/6/19 20190206-0013
IND239 Charity Mccluskey 2/6/19 20190206-0013
IND330 Caroline Oneal 2/6/19 20190206-0013
L-vi Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND331 Kari Brooks 2/6/19 20190206-0013
IND332 Robert Sendrey 2/6/19 20190206-0013
IND333 James Klein 2/6/19 20190206-0013
IND334 Elizabeth Young 2/6/19 20190206-0013
IND335 Elizabeth Parker 2/6/19 20190206-0013
IND336 Linda Hanratty 2/6/19 20190206-0013
IND337 Dodie Sweeney 2/6/19 20190206-0013
IND338 Evelyn Sardina 2/6/19 20190206-0013
IND339 Roma Norwine 2/6/19 20190206-0013
IND340 Vernon Berger 2/6/19 20190206-0013
IND341 Mary Kennedy 2/6/19 20190206-0013
IND342 Irene Martinez 2/6/19 20190206-0013
IND343 Jaen Lawrence 2/6/19 20190206-0013
IND344 Julisia Jackson 2/6/19 20190206-0013
IND345 Coleen Vicenti 2/6/19 20190206-0013
IND346 Michael Spradlin 2/6/19 20190206-0013
IND347 Jane Chischilly 2/6/19 20190206-0013
IND348 Lorelei Lambert 2/6/19 20190206-0013
IND349 Elaine Byrne 2/6/19 20190206-0013
IND350 Jacquelyn Dingley 2/6/19 20190206-0013
IND351 Lynn Rich 2/6/19 20190206-0013
IND352 Martin Pesaresi 2/6/19 20190206-0013
IND353 Ed Perry 2/6/19 20190206-0013
IND354 Cathy Chesser 2/6/19 20190206-0013
IND355 Jan E. Vaughan 2/6/19 20190206-0013
IND356 David Ruda 2/6/19 20190206-0013
IND357 Hector Medellin 2/6/19 20190206-0013
IND358 Kelly Hobbs 2/6/19 20190206-0013
IND359 Sandy Ransom 2/6/19 20190206-0013
IND360 Bill Holt et al. 2/6/19 20190206-0013
IND361 ED Breidenbach 2/6/19 20190206-0013
IND362 Mark Russell 2/6/19 20190206-0013
IND363 Evelyn Adams 2/6/19 20190206-0013
IND364 James Smith 2/6/19 20190206-0013
IND365 Patricia Schon 2/6/19 20190206-0013
IND366 Karen Sterling 2/6/19 20190206-0013
IND367 Turney Maurer 2/6/19 20190206-0013
IND368 Martin Penkwitz 2/6/19 20190206-0013
IND369 Danna Mcvey 2/6/19 20190206-0013
IND370 Ken Odell 2/6/19 20190206-0013
IND371 Christopher Hathaway 2/6/19 20190206-0013
IND372 Terri Mckeegan 2/6/19 20190206-0013
IND373 Terri McClung 2/6/19 20190206-0013
IND374 Margaret Little 2/6/19 20190206-0013
IND375 Tracy Mcmillan 2/6/19 20190206-0013
IND376 Sandy Phillips 2/6/19 20190206-0013
IND377 Rick Boykin 2/6/19 20190206-0013
IND378 Kent Rylander 2/6/19 20190206-0013
IND379 John Langston 2/6/19 20190206-0013
IND380 Yvonne Zepeda 2/6/19 20190206-0013
IND381 Gilberto Lopez 2/6/19 20190206-0013
IND382 Crystal Frias 2/6/19 20190206-0013
IND383 Marissa Williams 2/6/19 20190206-0013
IND384 Linda Hataway 2/6/19 20190206-0013
IND385 J Talbot 2/6/19 20190206-0013
IND386 Janet Phillips 2/6/19 20190206-0013
IND387 Michelle Emmitt 2/6/19 20190206-0013
IND388 Lisa Barrett 2/6/19 20190206-0013
IND389 Nika Dunn 2/6/19 20190206-0013
IND390 Laura Berrios 2/6/19 20190206-0013
IND391 Kathryn Brown 2/6/19 20190206-0013
L-vii Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND392 Karin Ascot 2/6/19 20190206-0013
IND393 Simona Vigil 2/6/19 20190206-0013
IND394 Jane Miller Langley 2/6/19 20190206-0013
IND395 Michael Phipps 2/6/19 20190206-0013
IND396 Dr Stern 2/6/19 20190206-0013
IND397 Rhonda Boehm 2/6/19 20190206-0013
IND398 Joseph Krause 2/6/19 20190206-0013
IND399 Tanya Kasper 2/6/19 20190206-0013
IND400 Julie Mayfield 2/6/19 20190206-0013
IND401 Gary Kasper 2/6/19 20190206-0013
IND402 Sabrina Cook 2/6/19 20190206-0013
IND403 Tracy Ferlet 2/6/19 20190206-0013
IND404 Linda Cooke 2/6/19 20190206-0013
IND405 Carolyn Croom 2/6/19 20190206-0013
IND406 Linda Bedre 2/6/19 20190206-0013
IND407 Katheryn Rogers 2/6/19 20190206-0013
IND408 Alan Ogden 2/6/19 20190206-0013
IND409 Micki Casino Gerardi 2/6/19 20190206-0013
IND410 William Parham 2/6/19 20190206-0013
IND411 Suzanne Taylor 2/6/19 20190206-0013
IND412 Donna B Matthews 2/6/19 20190206-0013
IND413 Sybil Morgan 2/6/19 20190206-0013
IND414 Linda Maher 2/6/19 20190206-0013
IND415 Michelle Smith 2/6/19 20190206-0013
IND416 Dennis Deacon 2/6/19 20190206-0013
IND417 Amy Maxwell 2/6/19 20190206-0013
IND418 Herman Rhein 2/6/19 20190206-0013
IND419 Laura Brush 2/6/19 20190206-0013
IND420 Mary Hancock 2/6/19 20190206-0013
IND421 Kerry White 2/6/19 20190206-0013
IND422 Melissa Guynes 2/6/19 20190206-0013
IND423 Jo Boles 2/6/19 20190206-0013
IND424 Yanira Aguirre 2/6/19 20190206-0013
IND425 Zara Barron 2/6/19 20190206-0013
IND426 Robert Gary 2/6/19 20190206-0013
IND427 Patsy Sasek 2/6/19 20190206-0013
IND428 Cheyenne Weaver 2/6/19 20190206-0013
IND429 Laura Carbonneau 2/6/19 20190206-0013
IND430 Jacob Fakheri 2/6/19 20190206-0013
IND431 Judy Clark 2/6/19 20190206-0013
IND432 Haiden Wattley 2/6/19 20190206-0013
IND433 Shawn Troxell 2/6/19 20190206-0013
IND434 Choky Alvarez 2/6/19 20190206-0013
IND435 Jane Lundquist 2/6/19 20190206-0013
IND436 Lynda Arredon 2/6/19 20190206-0013
IND437 Sharon Daly 2/6/19 20190206-0014
IND438 Gail Williams 2/6/19 20190206-0014
IND439 Robert Bauer 2/6/19 20190206-0014
IND440 Deena Berg 2/6/19 20190206-0014
IND441 Roger Knudson 2/6/19 20190206-0014
IND442 Bonnie Clements 2/6/19 20190206-0014
IND443 Linda Fielder 2/6/19 20190206-0014
IND444 Susan Bussa 2/6/19 20190206-0014
IND445 Margaret Schulenberg 2/6/19 20190206-0014
IND446 Samuela Walker 2/6/19 20190206-0014
IND447 Rebecca Mccuistion 2/6/19 20190206-0014
IND448 Clif Jordan 2/6/19 20190206-0014
IND449 Debbie Hyde 2/6/19 20190206-0014
IND450 Sharon Haywood 2/6/19 20190206-0014
IND451 CJ Vaughn 2/6/19 20190206-0014
IND452 Kay Mcbrayer 2/6/19 20190206-0014
L-viii Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND453 Judith Stueve 2/6/19 20190206-0014
IND454 Pat Johnson 2/6/19 20190206-0014
IND455 Sara Straube 2/6/19 20190206-0014
IND456 Claud and Sharon Bramblett 2/6/19 20190206-0014
IND457 James Clark 2/6/19 20190206-0014
IND458 Crystal Bowling 2/6/19 20190206-0014
IND459 Carina Ramirez 2/6/19 20190206-0014
IND460 Pam Sohan 2/6/19 20190206-0014
IND461 Carolina Ysasaga 2/6/19 20190206-0014
IND462 Kim Sanders George 2/6/19 20190206-0014
IND463 Wanda Kirkpatrick 2/6/19 20190206-0014
IND464 Rick Gordon 2/6/19 20190206-0014
IND465 Susan Finley 2/6/19 20190206-0014
IND466 Janice Kidd 2/6/19 20190206-0014
IND467 Catherine Croom 2/6/19 20190206-0014
IND468 Harvey Collen 2/6/19 20190206-0014
IND469 Nancy Walsh 2/6/19 20190206-0014
IND470 Fatima Quraali 2/6/19 20190206-0014
IND471 Cris Nelson 2/6/19 20190206-0014
IND472 David Allison 2/6/19 20190206-0014
IND473 Roberta Beckman 2/6/19 20190206-0014
IND474 Laura Tabor 2/6/19 20190206-0014
IND475 Lilli Pell 2/6/19 20190206-0014
IND476 Lucia Carter 2/6/19 20190206-0014
IND477 Elizabeth Whitlow 2/6/19 20190206-0014
IND478 Stephen Brown 2/6/19 20190206-0014
IND479 Stacey Schodek 2/6/19 20190206-0014
IND480 Zeb Hanley 2/6/19 20190206-0014
IND481 Susan Hradsky 2/6/19 20190206-0014
IND482 Laura Sander 2/6/19 20190206-0014
IND483 Diana Wheeler 2/6/19 20190206-0014
IND484 Liz LaFour 2/6/19 20190206-0014
IND485 Diana Gamez 2/6/19 20190206-0014
IND486 Patricia Thomson 2/6/19 20190206-0014
IND487 Fran Wessel 2/6/19 20190206-0014
IND488 Jerry Bailey 2/6/19 20190206-0014
IND489 L. Fielder 2/6/19 20190206-0014
IND490 Nancy Rosenberg 2/6/19 20190206-0014
IND491 Karen Ricks 2/6/19 20190206-0014
IND492 Edward Lackey 2/6/19 20190206-0014
IND493 Darvin Oliver 2/6/19 20190206-0014
IND494 Cynthia Meyer 2/6/19 20190206-0014
IND495 Allison Vitek 2/6/19 20190206-0014
IND496 Debra McCawley 2/6/19 20190206-0014
IND497 Frederick Chase 2/6/19 20190206-0014
IND498 Stephen Stoker 2/6/19 20190206-0014
IND499 Theresa Martinez 2/6/19 20190206-0014
IND500 Bettie Winsett 2/6/19 20190206-0014
IND501 Kathleen Younghans 2/6/19 20190206-0014
IND502 Luis Perez 2/6/19 20190206-0014
IND503 Cynthia Prince 2/6/19 20190206-0014
IND504 Natasha Tuckett 2/6/19 20190206-0014
IND505 Billiejean Jones 2/6/19 20190206-0014
IND506 Severa Krausse 2/6/19 20190206-0014
IND507 Leonor Smith Zacarias 2/6/19 20190206-0014
IND508 John Browning 2/6/19 20190206-0014
IND509 Pam Turlak 2/6/19 20190206-0014
IND510 Monica Arsate 2/6/19 20190206-0014
IND511 Monica Montalvo 2/6/19 20190206-0014
IND512 Gena Sadler 2/6/19 20190206-0014
IND513 Jeff Warner 2/6/19 20190206-0014
L-ix Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND514 Alexandra Canel 2/6/19 20190206-0014
IND515 Edward Grigassy 2/6/19 20190206-0014
IND516 J Iverson 2/6/19 20190206-0014
IND517 Joshua Jacinto 2/6/19 20190206-0014
IND518 Robert Martin 2/6/19 20190206-0014
IND519 Patricia Brooks 2/6/19 20190206-0014
IND520 Annette Pieniazek 2/6/19 20190206-0014
IND521 Noemi Silva 2/6/19 20190206-0014
IND522 Will Golding 2/6/19 20190206-0014
IND523 Aguedys Whittaker 2/6/19 20190206-0014
IND524 Waldo Castro 2/6/19 20190206-0014
IND525 Vince Mendieta 2/6/19 20190206-0014
IND526 Lori Namapee 2/6/19 20190206-0014
IND527 Stephen Schwausch 2/6/19 20190206-0014
IND528 Gaye Hokden 2/6/19 20190206-0014
IND529 Steven Bailey 2/6/19 20190206-0014
IND530 Ellen Cote 2/6/19 20190206-0014
IND531 Bob Bardo 2/6/19 20190206-0014
IND532 Sarah Zepeda 2/6/19 20190206-0014
IND533 Carol Porras 2/6/19 20190206-0014
IND534 Kimberly Gilbertson 2/6/19 20190206-0014
IND535 Rebecca Sharp 2/6/19 20190206-0014
IND536 Gerard Sullivan 2/6/19 20190206-0014
IND537 Rogelio Alcoser 2/6/19 20190206-0014
IND538 Ryan Scinta 2/6/19 20190206-0014
IND539 Shannon Prescott 2/6/19 20190206-0014
IND540 Albert Downing 2/6/19 20190206-0014
IND541 Charles Paget 2/6/19 20190206-0014
IND542 Jessica Bozeman 2/6/19 20190206-0014
IND543 Leslie Brown 2/6/19 20190206-0014
IND544 S Hartman 2/6/19 20190206-0014
IND545 Charles Counterman 2/6/19 20190206-0014
IND546 Candace Halliburton 2/6/19 20190206-0014
IND547 R Write 2/6/19 20190206-0014
IND548 Joe Rogers 2/6/19 20190206-0014
IND549 Georgena Askew 2/6/19 20190206-0014
IND550 David Burnett 2/6/19 20190206-0014
IND551 Bruce Burns 2/6/19 20190206-0014
IND552 Andrea Johnson 2/6/19 20190206-0014
IND553 Nicholas Delossantos 2/6/19 20190206-0014
IND554 Linda Kroeger 2/6/19 20190206-0014
IND555 Donald Owen 2/6/19 20190206-0014
IND556 Kathy Dorman 2/6/19 20190206-0014
IND557 Barry Brossa 2/6/19 20190206-0014
IND558 Carol Pennington 2/6/19 20190206-0014
IND559 Jeffrey Crozier 2/6/19 20190206-0014
IND560 Shanna Bradford 2/6/19 20190206-0014
IND561 Cynthia Curtis 2/6/19 20190206-0014
IND562 Julia Burgen 2/6/19 20190206-0014
IND563 Dirk Rogers 2/6/19 20190206-0014
IND564 Eric Scheilhagen 2/6/19 20190206-0014
IND565 Leah Klein 2/6/19 20190206-0014
IND566 Baldamar Lopez 2/6/19 20190206-0014
IND567 Jane Gilley 2/6/19 20190206-0014
IND568 Nick and Diana Rudolph 2/6/19 20190206-0014
IND569 Alan Holt 2/6/19 20190206-0014
IND570 Sarah Lindholm 2/6/19 20190206-0014
IND571 Edwin and Patricia Sasek 2/6/19 20190206-0014
IND572 Christina Campos 2/6/19 20190206-0014
IND573 Kate Mathis 2/6/19 20190206-0014
IND574 Steve and Rachael Alvarez-Jett 2/6/19 20190206-0014
L-x Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND575 Lisa Gewax 2/6/19 20190206-0014
IND576 Soria Adibi 2/6/19 20190206-0014
IND577 Ruby Ahiquist 2/6/19 20190206-0014
IND578 Ricardo Rojas 2/6/19 20190206-0014
IND579 Lizeth Marquez 2/6/19 20190206-0014
IND580 John Reiter 2/6/19 20190206-0014
IND581 De Hy 2/6/19 20190206-0014
IND582 Mark Witte 2/6/19 20190206-0014
IND583 Bryan Taylor 2/6/19 20190206-0014
IND584 Nara Wood 2/6/19 20190206-0014
IND585 Ronald Shenberger 2/6/19 20190206-0014
IND586 Genevieve Ali 2/6/19 20190206-0014
IND587 Asad Rahbar 2/6/19 20190206-0014
IND588 M Cole 2/6/19 20190206-0014
IND589 Sandra Varvel 2/6/19 20190206-0014
IND590 Amy Ardington 2/6/19 20190206-0014
IND591 Craig Nazor 2/6/19 20190206-0014
IND592 Nancy Lehmann 2/6/19 20190206-0014
IND593 Steve Garland 2/6/19 20190206-0014
IND594 Astrid Thomsen 2/6/19 20190206-0014
IND595 Vigil Rosser 2/6/19 20190206-0014
IND596 Joanne Fell 2/6/19 20190206-0014
IND597 Russell Hollier 2/6/19 20190206-0014
IND598 David Davidson 2/6/19 20190206-0014
IND599 Alan Montemayor 2/6/19 20190206-0014
IND600 Vera Smith 2/6/19 20190206-0014
IND601 Lala Bae 2/6/19 20190206-0014
IND602 Kathrin Dodds 2/6/19 20190206-0014
IND603 William Skinner 2/6/19 20190206-0014
IND604 Joseph Reynolds 2/6/19 20190206-0014
IND605 Brian Strasters 2/6/19 20190206-0014
IND606 Mary Greenway 2/6/19 20190206-0014
IND607 Kevin Abate 2/6/19 20190206-0014
IND608 Nancy Fullerton 2/6/19 20190206-0014
IND609 Raje Wolf 2/6/19 20190206-0014
IND610 David and Susanne Arbiter 2/6/19 20190206-0014
IND611 Gareth White 2/6/19 20190206-0014
IND612 Thomas Templeton 2/6/19 20190206-0014
IND613 Yury Ragoza 2/6/19 20190206-0014
IND614 Ron Serino 2/6/19 20190206-0014
IND615 Erin White 2/6/19 20190206-0014
IND616 Sharon Baron 2/6/19 20190206-0014
IND617 Debra Walker 2/6/19 20190206-0014
IND618 Sherri Sherbo 2/6/19 20190206-0014
IND619 Theresa Flanagan 2/6/19 20190206-0014
IND620 Carolyn Rich 2/6/19 20190206-0014
IND621 Annette Mcanally 2/6/19 20190206-0016
IND622 Deborah Williams 2/6/19 20190206-0016
IND623 Robert Gilliland 2/6/19 20190206-0016
IND624 Harriet Horton 2/6/19 20190206-0016
IND625 Amy Quate 2/6/19 20190206-0016
IND626 Kat Feuerbacher 2/6/19 20190206-0016
IND627 Cindy Brittain 2/6/19 20190206-0016
IND628 Fred Lindner 2/6/19 20190206-0016
IND629 Christiana Brinton 2/6/19 20190206-0016
IND630 Eugene Molina 2/6/19 20190206-0016
IND631 Mary Jozwiak 2/6/19 20190206-0016
IND632 Yolanda Birdwell 2/6/19 20190206-0016
IND633 Sandy York 2/6/19 20190206-0016
IND634 Valerie Hernandez 2/6/19 20190206-0016
IND635 Barbara Anderson 2/6/19 20190206-0016
L-xi Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND636 James Gillum 2/6/19 20190206-0016
IND637 Michael Collard 2/6/19 20190206-0016
IND638 Karen Sprague 2/6/19 20190206-0016
IND639 Melanie Demartinis 2/6/19 20190206-0016
IND640 Gloria Skillman 2/6/19 20190206-0016
IND641 Linda Berger 2/6/19 20190206-0016
IND642 Elisa Hirt 2/6/19 20190206-0016
IND643 Julia Woodward-Parker 2/6/19 20190206-0016
IND644 Kathy Rinehart 2/6/19 20190206-0016
IND645 Jill Buchanan 2/6/19 20190206-0016
IND646 Julie Solell 2/6/19 20190206-0016
IND647 Jim Tucker 2/6/19 20190206-0016
IND648 Mary Cato 2/6/19 20190206-0016
IND649 Rochelle Brackman 2/6/19 20190206-0016
IND650 Nettie Standiford 2/6/19 20190206-0016
IND651 Jose Gomez 2/6/19 20190206-0016
IND652 Lauren Danford 2/6/19 20190206-0016
IND653 Frank Dufour 2/6/19 20190206-0016
IND654 Harold Albers 2/6/19 20190206-0016
IND655 Teran Hughes 2/6/19 20190206-0016
IND656 Cheryl Morris 2/6/19 20190206-0016
IND657 Tammy Scott 2/6/19 20190206-0016
IND658 Kathryn Samec 2/6/19 20190206-0016
IND659 Teresa Saldivar 2/6/19 20190206-0016
IND660 Elizabeth Grimsley 2/6/19 20190206-0016
IND661 Andrea MacRae 2/6/19 20190206-0016
IND662 Holly Thiel 2/6/19 20190206-0016
IND663 Donna Crittenden 2/6/19 20190206-0016
IND664 Nancy Mcgrath 2/6/19 20190206-0016
IND665 Douglas Chalmers 2/6/19 20190206-0016
IND666 Pat Roberson 2/6/19 20190206-0016
IND667 Katie Drackert 2/6/19 20190206-0016
IND668 Eva Coleman 2/6/19 20190206-0016
IND669 Tracy Briney 2/6/19 20190206-0016
IND670 Irenia Salazar-Parada 2/6/19 20190206-0016
IND671 Charmaine Berry 2/6/19 20190206-0016
IND672 Cima Malkhassian 2/6/19 20190206-0016
IND673 Diane and Michael Wonio 2/6/19 20190206-0016
IND674 Gwynne Carosella 2/6/19 20190206-0016
IND675 Monique Mcintyre 2/6/19 20190206-0016
IND676 Karen Naumann 2/6/19 20190206-0016
IND677 Christina Scattergood 2/6/19 20190206-0016
IND678 Richard Schlenk 2/6/19 20190206-0016
IND679 Brittney Collins 2/6/19 20190206-0016
IND680 Catherine Willmann 2/6/19 20190206-0016
IND681 Tracy Simmons 2/6/19 20190206-0016
IND682 Joan Allison 2/6/19 20190206-0016
IND683 Jeanne Jordan 2/6/19 20190206-0016
IND684 Sherry Andresen 2/6/19 20190206-0016
IND685 William Romfh 2/6/19 20190206-0016
IND686 Joanne segura-Delgado 2/6/19 20190206-0016
IND687 Betsy Lambert 2/6/19 20190206-0016
IND688 Bill France 2/6/19 20190206-0016
IND689 Kristina Williams 2/6/19 20190206-0016
IND690 Angela Barrera 2/6/19 20190206-0016
IND691 Lynsey Holland 2/6/19 20190206-0016
IND692 Melodie Palmer 2/6/19 20190206-0016
IND693 Kathleen Bryson 2/6/19 20190206-0016
IND694 Doyle Sebesta 2/6/19 20190206-0016
IND695 Todd Teulon 2/6/19 20190206-0016
IND696 Alexis Sosa 2/6/19 20190206-0016
L-xii Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND697 Mike Johnson 2/6/19 20190206-0016
IND698 Marla Hanks 2/6/19 20190206-0016
IND699 Sheyla Mendoza 2/6/19 20190206-0016
IND700 Derek Luft 2/6/19 20190206-0016
IND701 Alice Kuchenthal 2/6/19 20190206-0016
IND702 Deana Phillips 2/6/19 20190206-0016
IND703 Terry Burton 2/6/19 20190206-0016
IND704 Elizabeth Burton 2/6/19 20190206-0016
IND705 Jeanne Kyser 2/6/19 20190206-0016
IND706 Jose Sanchez 2/6/19 20190206-0016
IND707 Sheila Simpson 2/6/19 20190206-0016
IND708 Terri McNeal 2/6/19 20190206-0016
IND709 Gloria Silva 2/6/19 20190206-0016
IND710 Gilbert Pritchett 2/6/19 20190206-0016
IND711 Cameron Babberney 2/6/19 20190206-0016
IND712 Leslie Hopkins 2/6/19 20190206-0016
IND713 Penny Hartwell 2/6/19 20190206-0016
IND714 William Michael 2/6/19 20190206-0016
IND715 Clarisa Rostro 2/6/19 20190206-0016
IND716 Rose Morris 2/6/19 20190206-0016
IND717 Duane Patrick 2/6/19 20190206-0014
IND718 Alexander Helou 2/6/19 20190206-0016
IND719 Cliff Perkins 2/6/19 20190206-0016
IND720 Betty Alex 2/6/19 20190206-0016
IND721 Corliss Crabtree 2/6/19 20190206-0016
IND722 P Leal 2/6/19 20190206-0016
IND723 Mary Mueller 2/6/19 20190206-0016
IND724 Ann Mcgory 2/6/19 20190206-0016
IND725 Tayyab Malik 2/6/19 20190206-0016
IND726 Mittie Hinz 2/6/19 20190206-0016
IND727 Felipe-Andres Piedra 2/6/19 20190206-0016
IND728 James Lipsey 2/6/19 20190206-0016
IND729 Jessimikuh Shhboom 2/6/19 20190206-0016
IND730 Marie Norrell 2/6/19 20190206-0016
IND731 John Rooney 2/6/19 20190206-0016
IND732 John Fisher 2/6/19 20190206-0016
IND733 Mary Celaya 2/6/19 20190206-0016
IND734 Erika Shea 2/6/19 20190206-0016
IND735 Craig Liebendorfer 2/6/19 20190206-0016
IND736 Mark Monger 2/6/19 20190206-0016
IND737 Sarah Page 2/6/19 20190206-0016
IND738 William Cook 2/6/19 20190206-0016
IND739 Connie Leblanc 2/6/19 20190206-0016
IND740 Debra Francis 2/6/19 20190206-0016
IND741 Anna Kaiser 2/6/19 20190206-0016
IND742 James Rice 2/6/19 20190206-0016
IND743 Bill Rogers 2/6/19 20190206-0016
IND744 Jane Jatinen 2/6/19 20190206-0016
IND745 David Michalek 2/6/19 20190206-0016
IND746 Frank Blake 2/6/19 20190206-0016
IND747 Morgan Meyers 2/6/19 20190206-0016
IND748 Linda Brust 2/6/19 20190206-0016
IND749 Roberto Salazar 2/6/19 20190206-0016
IND750 Martha Honey 2/6/19 20190206-0016
IND751 Mackenzie Crone 2/6/19 20190206-0016
IND752 Kathy Pinckney 2/6/19 20190206-0016
IND753 Marie Palos 2/6/19 20190206-0016
IND754 David Mohan 2/6/19 20190206-0016
IND755 Bianca Marcuccino-Walsh 2/6/19 20190206-0016
IND756 Gary Aten 2/6/19 20190206-0016
IND757 Carol Denning 2/6/19 20190206-0016
L-xiii Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND758 Debra Hollinger 2/6/19 20190206-0016
IND759 Suzanne Gil 2/6/19 20190206-0016
IND760 Robert Bauhs 2/6/19 20190206-0016
IND761 Rebekah Farrell 2/6/19 20190206-0016
IND762 Gaye Holden 2/6/19 20190206-0016
IND763 Jennifer Nichols 2/6/19 20190206-0016
IND764 Brian Schill 2/6/19 20190206-0016
IND765 David Powell 2/6/19 20190206-0016
IND766 Mariel Davis 2/6/19 20190206-0016
IND767 Pam Jaso 2/6/19 20190206-0016
IND768 David Dorsey 2/6/19 20190206-0016
IND769 Sophia Melendez 2/6/19 20190206-0016
IND770 Linda Greene 2/6/19 20190206-0016
IND771 Reynolds Reynolds 2/6/19 20190206-0016
IND772 Krissie Marty 2/6/19 20190206-0016
IND773 Alma Mata 2/6/19 20190206-0016
IND774 Lonne Martinec 2/6/19 20190206-0016
IND775 Kurtis Castellanos 2/6/19 20190206-0016
IND776 Marie Hamm 2/6/19 20190206-0016
IND777 Karen Arceri 2/6/19 20190206-0016
IND778 Molly Rooke 2/6/19 20190206-0016
IND779 Sarah Burden-Mcclure 2/6/19 20190206-0016
IND780 Alice Perez 2/6/19 20190206-0016
IND781 Christina Esmahan 2/6/19 20190206-0016
IND782 Tria Shaffer 2/6/19 20190206-0016
IND783 Bianca Gallegos 2/6/19 20190206-0016
IND784 Michael and Jeanne Galvin 2/6/19 20190206-0016
IND785 Ling Zhu 2/6/19 20190206-0016
IND786 Sarah Fawcett 2/6/19 20190206-0016
IND787 Joe Lopez 2/6/19 20190206-0016
IND788 Carol Fly 2/6/19 20190206-0016
IND789 Iris Waser 2/6/19 20190206-0016
IND790 Evelyn Myler 2/6/19 20190206-0016
IND791 Cecile Burandt 2/6/19 20190206-0016
IND792 Michael Gray 2/6/19 20190206-0016
IND793 L Borgen 2/6/19 20190206-0016
IND794 Carla Harris 2/6/19 20190206-0016
IND795 Lauren Ide 2/6/19 20190206-0016
IND796 Martin Terry 2/6/19 20190206-0016
IND797 Kenneth Johnson 2/6/19 20190206-0016
IND798 Kris Manley 2/6/19 20190206-0016
IND799 Suzanne Herzing 2/6/19 20190206-0016
IND800 John-Michael Torres 2/6/19 20190206-0016
IND801 Teresa Pietersen 2/6/19 20190206-0016
IND802 Kathryn Davidson 2/6/19 20190206-0016
IND803 Michael and Susie Way 2/6/19 20190206-0016
IND804 Shirley Slampa 2/6/19 20190206-0016
IND805 Karen Phillips 2/6/19 20190206-0016
IND806 Sarah Berner 2/6/19 20190206-0016
IND807 Antoinette Freeman 2/6/19 20190206-0016
IND808 Teresa Summerlin 2/6/19 20190206-0016
IND809 Riley Walberg 2/6/19 20190206-0016
IND810 John Ader 2/6/19 20190206-0016
IND811 June Jensen 2/6/19 20190206-0016
IND812 Grace Pruitt 2/6/19 20190206-0016
IND813 Hernan Ortega 2/6/19 20190206-0016
IND814 Anthony Sanchez 2/6/19 20190206-0016
IND815 Missy Elley 2/6/19 20190206-0016
IND816 Pam Wetzels 2/6/19 20190206-0016
IND817 Colleen Theriot 2/6/19 20190206-0016
IND818 Nancy Latner 2/6/19 20190206-0016
L-xiv Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND819 Jonathan Sanders 2/6/19 20190206-0016
IND820 Michelle Esposito 2/6/19 20190206-0016
IND821 Ashley Beard 2/6/19 20190206-0016
IND822 Melanie Schuchart 2/6/19 20190206-0016
IND823 Enedelia Salinas 2/6/19 20190206-0016
IND824 Chris Soignier 2/6/19 20190206-0016
IND825 Jeremiah Stith 2/6/19 20190206-0016
IND826 Jack Elam 2/6/19 20190206-0016
IND827 Eugenia Schuler 2/6/19 20190206-0016
IND828 Elizabeth Venable 2/6/19 20190206-0016
IND829 Linda Olsoe 2/6/19 20190206-0016
IND830 Jensie Madden 2/6/19 20190206-0016
IND831 Raynae Baker 2/6/19 20190206-0016
IND832 Susan Thorn 2/6/19 20190206-0016
IND833 Judith Bentancourt 2/6/19 20190206-0016
IND834 Sandy Simmons 2/6/19 20190206-0016
IND835 Sari Albornoz 2/6/19 20190206-0016
IND836 Mari Wilson 2/6/19 20190206-0016
IND837 Lillian Nance 2/6/19 20190206-0016
IND838 Stewart Yaros 2/6/19 20190206-0016
IND839 Shelby Scarbrough 2/6/19 20190206-0016
IND840 Trinity Cobb 2/6/19 20190206-0016
IND841 Susie Thompson 2/6/19 20190206-0016
IND842 Lisa Parisi 2/6/19 20190206-0016
IND843 Patty Adams 2/6/19 20190206-0016
IND844 Celeste Rosales 2/6/19 20190206-0016
IND845 Kayla Muzquiz 2/6/19 20190206-0016
IND846 Cheryl Watson 2/6/19 20190206-0016
IND847 E Ingraham 2/6/19 20190206-0016
IND848 Mary McDonald 2/6/19 20190206-0016
IND849 Marilyn Endres 2/6/19 20190206-0016
IND850 John Lethco 2/6/19 20190206-0016
IND851 Brian Abernathy 2/6/19 20190206-0015
IND852 Jane Abrams 2/6/19 20190206-0015
IND853 Noe Acevedo 2/6/19 20190206-0015
IND854 U Sakoglu 2/6/19 20190206-0015
IND855 P.S. Allison 2/6/19 20190206-0015
IND856 Max Anderson 2/6/19 20190206-0015
IND857 Sandra Arzola 2/6/19 20190206-0015
IND858 Jill Bailey 2/6/19 20190206-0015
IND859 Scott Baker 2/6/19 20190206-0015
IND860 Justin Bautista 2/6/19 20190206-0015
IND861 Bea Bee 2/6/19 20190206-0015
IND862 Bhuvanesh Bhatt 2/6/19 20190206-0015
IND863 Denise Bickford 2/6/19 20190206-0015
IND864 Sarah Bijoy 2/6/19 20190206-0015
IND865 John Boriack 2/6/19 20190206-0015
IND866 Justin Bosler 2/6/19 20190206-0015
IND867 Tia Bostarter 2/6/19 20190206-0015
IND868 Carol Box 2/6/19 20190206-0015
IND869 Ciara Boyer 2/6/19 20190206-0015
IND870 Kate Bremer 2/6/19 20190206-0015
IND871 Becky Browning 2/6/19 20190206-0015
IND872 Klementyna Bryte 2/6/19 20190206-0015
IND873 Richard Buck 2/6/19 20190206-0015
IND874 Elizabeth Burnette 2/6/19 20190206-0015
IND875 Kathryn Burns 2/6/19 20190206-0015
IND877 Christine Smith 2/6/19 20190206-0015
IND878 Grace Cagle 2/6/19 20190206-0015
IND879 Richard Caldwell 2/6/19 20190206-0015
L-xv Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND880 Barbara Campbell 2/6/19 20190206-0015
IND881 Lisa Canorro 2/6/19 20190206-0015
IND882 Celine Capiccioni 2/6/19 20190206-0015
IND883 Paul Cardwell 2/6/19 20190206-0015
IND884 Cathy Carpentier 2/6/19 20190206-0015
IND885 Rosemary Carson 2/6/19 20190206-0015
IND886 Marisol Cervantes 2/6/19 20190206-0015
IND887 Khy Chapman 2/6/19 20190206-0015
IND888 Jose Choquehaunca 2/6/19 20190206-0015
IND889 Chris Clark 2/6/19 20190206-0015
IND890 John Clary 2/6/19 20190206-0015
IND891 Mary Cohron 2/6/19 20190206-0015
IND892 Danielle Cole 2/6/19 20190206-0015
IND893 Debra Coleman 2/6/19 20190206-0015
IND894 Audrey Colombe 2/6/19 20190206-0015
IND895 Linda Cox 2/6/19 20190206-0015
IND896 Diana Clark 2/6/19 20190206-0015
IND897 Susan Daugherty 2/6/19 20190206-0015
IND898 Alfred Davila 2/6/19 20190206-0015
IND899 Ilene Dillon-Fink 2/6/19 20190206-0015
IND900 Ken Dixon 2/6/19 20190206-0015
IND901 Carolyn Downs 2/6/19 20190206-0015
IND902 Stephanie Doyle 2/6/19 20190206-0015
IND903 Susana Dunlap 2/6/19 20190206-0015
IND904 John Edwards 2/6/19 20190206-0015
IND905 Suzy Eide 2/6/19 20190206-0015
IND906 Susan Ellis 2/6/19 20190206-0015
IND907 Stephanie Ertel 2/6/19 20190206-0015
IND908 Dan Everly 2/6/19 20190206-0015
IND909 Brad First 2/6/19 20190206-0015
IND910 Diamond Flores 2/6/19 20190206-0015
IND911 Marcha Fox 2/6/19 20190206-0015
IND912 Jose Gamobia 2/6/19 20190206-0015
IND913 Xylia Garcia 2/6/19 20190206-0015
IND914 Margaret Garza 2/6/19 20190206-0015
IND915 Carol Gerson 2/6/19 20190206-0015
IND916 Jennifer Golden 2/6/19 20190206-0015
IND917 Patricia Gonzales 2/6/19 20190206-0015
IND918 Autumn Gonzalez 2/6/19 20190206-0015
IND919 Mark Goodman 2/6/19 20190206-0015
IND920 Kathy Goodwin 2/6/19 20190206-0015
IND921 Karen Grosse-Ramirez 2/6/19 20190206-0015
IND922 Shannon Grounds 2/6/19 20190206-0015
IND923 John Guest 2/6/19 20190206-0015
IND924 Sandi Hebley 2/6/19 20190206-0015
IND925 Jacqui Hamlett 2/6/19 20190206-0015
IND926 Don Hammond 2/6/19 20190206-0015
IND927 Robin Hanson 2/6/19 20190206-0015
IND928 Pamela Hardwick 2/6/19 20190206-0015
IND929 Lucy Harmon 2/6/19 20190206-0015
IND930 Dan Harrison 2/6/19 20190206-0015
IND931 Jana Harter 2/6/19 20190206-0015
IND932 Miguel Hernandez 2/6/19 20190206-0015
IND933 Claudia Herrera 2/6/19 20190206-0015
IND934 Janice Hewitt 2/6/19 20190206-0015
IND935 Ginger Himelright 2/6/19 20190206-0015
IND936 Holly Holmes 2/6/19 20190206-0015
IND937 Jean Hopkins 2/6/19 20190206-0015
IND938 Athenea Hughes 2/6/19 20190206-0015
IND939 Lee Hutchings 2/6/19 20190206-0015
IND940 Adrienne Inglis 2/6/19 20190206-0015
L-xvi Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND941 Pete Inman 2/6/19 20190206-0015
IND942 Teresa Iovino 2/6/19 20190206-0015
IND943 Katie Irani 2/6/19 20190206-0015
IND944 John Wilson 2/6/19 20190206-0015
IND945 Henry Jackson 2/6/19 20190206-0015
IND946 Kyle Jeffries 2/6/19 20190206-0015
IND947 Ann Joseph 2/6/19 20190206-0015
IND948 Karen Browning 2/6/19 20190206-0015
IND949 Kirk and Xochitl Jackson 2/6/19 20190206-0015
IND950 Sierra King 2/6/19 20190206-0015
IND951 Alison Kirsch 2/6/19 20190206-0015
IND952 Tracey Kunkler 2/6/19 20190206-0015
IND953 Pamela Kurner 2/6/19 20190206-0015
IND954 Lori Williams 2/6/19 20190206-0015
IND955 Juanita Lambie 2/6/19 20190206-0015
IND956 Julia Landress 2/6/19 20190206-0015
IND957 Stephanie Levinson 2/6/19 20190206-0015
IND958 John Lewis 2/6/19 20190206-0015
IND959 Elizabeth Lopez 2/6/19 20190206-0015
IND960 Rev Luis Ignacio Gameros M Div 2/6/19 20190206-0015
IND961 Matt Lykken 2/6/19 20190206-0015
IND962 Laris Manescu 2/6/19 20190206-0015
IND963 Pamela Massey 2/6/19 20190206-0015
IND964 Sharon Matz 2/6/19 20190206-0015
IND965 Andrea Maxwell 2/6/19 20190206-0015
IND966 Sally McAfee 2/6/19 20190206-0015
IND967 K McGaughy 2/6/19 20190206-0015
IND968 Meredith McGuire 2/6/19 20190206-0015
IND969 Susan McKinley 2/6/19 20190206-0015
IND970 Allison Metzger 2/6/19 20190206-0015
IND971 Eric Meyer 2/6/19 20190206-0015
IND972 Kent and Karol Middleton 2/6/19 20190206-0015
IND973 Diana L Montejano 2/6/19 20190206-0015
IND974 Laura Mordecai 2/6/19 20190206-0015
IND975 Winnie Tate Morgan 2/6/19 20190206-0015
IND976 Tilsa Muldoon 2/6/19 20190206-0015
IND977 Martha Mullens 2/6/19 20190206-0015
IND978 Anthony Murray 2/6/19 20190206-0015
IND979 Tracy Musgrove 2/6/19 20190206-0015
IND980 Roger Neumann 2/6/19 20190206-0015
IND981 Susan Nichols 2/6/19 20190206-0015
IND983 Karen Norton 2/6/19 20190206-0015
IND984 William Okain 2/6/19 20190206-0015
IND985 Sidney Parsons 2/6/19 20190206-0015
IND986 Victoria Patterson 2/6/19 20190206-0015
IND987 Patricia Patteson 2/6/19 20190206-0015
IND988 Anita Pauwels 2/6/19 20190206-0015
IND989 Syliva Pena 2/6/19 20190206-0015
IND990 Cynthia Perez 2/6/19 20190206-0015
IND991 Judy Perkins 2/6/19 20190206-0015
IND992 Al Plata 2/6/19 20190206-0015
IND993 Beverly Polan 2/6/19 20190206-0015
IND994 Mary Pustejovsky 2/6/19 20190206-0015
IND995 Emilio Ramirez 2/6/19 20190206-0015
IND996 Linda Ramos 2/6/19 20190206-0015
IND997 Cathy Ramsey 2/6/19 20190206-0015
IND998 Carol Reinking 2/6/19 20190206-0015
IND999 Ana Reza 2/6/19 20190206-0015
IND1000 Christina Richer 2/6/19 20190206-0015
IND1001 Kim Riggins 2/6/19 20190206-0015
L-xvii Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND1002 Maritza Rodriguez 2/6/19 20190206-0015
IND1003 Barbara Rogers 2/6/19 20190206-0015
IND1004 Terri Rose 2/6/19 20190206-0015
IND1005 Debbie Rothermel 2/6/19 20190206-0015
IND1006 Jean Rothfusz 2/6/19 20190206-0015
IND1007 Michael Russell 2/6/19 20190206-0015
IND1008 Michelle Rutan 2/6/19 20190206-0015
IND1009 Miroslava Saenz 2/6/19 20190206-0015
IND1010 Claudio Salazar 2/6/19 20190206-0015
IND1011 Blanca Sanchez-Navarro 2/6/19 20190206-0015
IND1012 Dorothy Schleicher 2/6/19 20190206-0015
IND1013 Linda Schubert 2/6/19 20190206-0015
IND1014 Phillip Scott 2/6/19 20190206-0015
IND1015 Bonni Scudder 2/6/19 20190206-0015
IND1016 Rose Slatouski 2/6/19 20190206-0015
IND1017 Jan Smith 2/6/19 20190206-0015
IND1018 Judith Snape 2/6/19 20190206-0015
IND1019 Elisabeth Sommer 2/6/19 20190206-0015
IND1020 Sandra Sparks 2/6/19 20190206-0015
IND1021 Nathan Stanfield 2/6/19 20190206-0015
IND1022 Diana Steinhagen 2/6/19 20190206-0015
IND1023 Teresa Stoever 2/6/19 20190206-0015
IND1024 Jeff Stone 2/6/19 20190206-0015
IND1025 Dominic Stricherz 2/6/19 20190206-0015
IND1026 Shelby Strickland 2/6/19 20190206-0015
IND1027 Rachel Stroud 2/6/19 20190206-0015
IND1028 Dan Sundberg 2/6/19 20190206-0015
IND1029 Cindy Symington 2/6/19 20190206-0015
IND1030 Joanna Symmonds 2/6/19 20190206-0015
IND1031 Tina Theriaque 2/6/19 20190206-0015
IND1032 Mary Timmons 2/6/19 20190206-0015
IND1033 Joe Tompkins 2/6/19 20190206-0015
IND1034 Sid Totten 2/6/19 20190206-0015
IND1035 Diane Trudeau 2/6/19 20190206-0015
IND1036 Lannie Tucker 2/6/19 20190206-0015
IND1037 Lesa Tyson 2/6/19 20190206-0015
IND1038 Tandie Van Den Berg 2/6/19 20190206-0015
IND1039 Jane Leatherman Van Praag 2/6/19 20190206-0015
IND1040 Jason Vandever 2/6/19 20190206-0015
IND1041 Gumecindo Villanueva 2/6/19 20190206-0015
IND1042 Lois Wagenseil 2/6/19 20190206-0015
IND1043 Susan Waskey 2/6/19 20190206-0015
IND1044 Debra Watson 2/6/19 20190206-0015
IND1045 Eileen Welch 2/6/19 20190206-0015
IND1046 Beth Wernick 2/6/19 20190206-0015
IND1047 Becky Wharton 2/6/19 20190206-0015
IND1048 Mauri Williams 2/6/19 20190206-0015
IND1049 Twila Willis 2/6/19 20190206-0015
IND1050 Ellen Willmore 2/6/19 20190206-0015
IND1051 Dog Wood 2/6/19 20190206-0015
IND1052 J E Yee 2/6/19 20190206-0015
IND1053 Tracy Zadwick 2/6/19 20190206-0015
IND1054 Andrea Gonzalez 2/7/19 20190207-5031
IND1055 Ariadne Acevedo 2/7/19 20190207-5031
IND1056 Katelyn Aguirre 2/7/19 20190207-5031
IND1057 Mike Anderson 2/7/19 20190207-5031
IND1058 Robert Anzaldua 2/7/19 20190207-5031
IND1059 Dennis Bates 2/7/19 20190207-5031
IND1060 Lydia Beckham 2/7/19 20190207-5031
IND1061 Evan Bloom 2/7/19 20190207-5031
IND1062 Briana Brown 2/7/19 20190207-5031
L-xviii Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND1063 Joseph Cantu 2/7/19 20190207-5031
IND1064 Alejandro Flores 2/7/19 20190207-5031
IND1065 Karen Carbiener 2/7/19 20190207-5031
IND1066 Ivan Celedon 2/7/19 20190207-5031
IND1067 Roel Cepeda 2/7/19 20190207-5031
IND1068 Magaly Cornejo 2/7/19 20190207-5031
IND1069 Dora Garcia 2/7/19 20190207-5031
IND1070 Patrick de la Garza Und Senkel 2/7/19 20190207-5031
IND1071 Reta Durham 2/7/19 20190207-5031
IND1072 Esther Martinez 2/7/19 20190207-5031
IND1073 Elizabeth Perez 2/7/19 20190207-5031
IND1074 Joshua Ekrut 2/7/19 20190207-5031
IND1075 Nicole Ekstrom 2/7/19 20190207-5031
IND1076 Fancy Fairchild 2/7/19 20190207-5031
IND1077 Tabatha Ferguson 2/7/19 20190207-5031
IND1078 Pearl Fry 2/7/19 20190207-5031
IND1079 Jacqueline Galarza 2/7/19 20190207-5031
IND1080 Maria Galasso 2/7/19 20190207-5031
IND1081 Mariela Garcia 2/7/19 20190207-5031
IND1082 Michele Gardner 2/7/19 20190207-5031
IND1083 Harry Goette 2/7/19 20190207-5031
IND1084 Shayla Gonzalez 2/7/19 20190207-5031
IND1085 Leticia Guerra 2/7/19 20190207-5031
IND1086 Carly Hamilton 2/7/19 20190207-5031
IND1087 Edna Goette 2/7/19 20190207-5031
IND1088 Elizabeth Head 2/7/19 20190207-5031
IND1089 Selena Herrera 2/7/19 20190207-5031
IND1090 Frank Hobin 2/7/19 20190207-5031
IND1091 Larry Hollmann 2/7/19 20190207-5031
IND1092 Javier Guerra 2/7/19 20190207-5031
IND1093 Juan Martinez 2/7/19 20190207-5031
IND1094 Dianne Johnson 2/7/19 20190207-5031
IND1095 Steven Lanoux 2/7/19 20190207-5031
IND1096 Natalie Van Leekwijck 2/7/19 20190207-5031
IND1097 Mary Hollmann 2/7/19 20190207-5031
IND1098 John MacFarlane 2/7/19 20190207-5031
IND1099 Ashley Martinez 2/7/19 20190207-5031
IND1100 William McKinney 2/7/19 20190207-5031
IND1101 Doris Meinerding 2/7/19 20190207-5031
IND1102 Vince Mendieta 2/7/19 20190207-5031
IND1103 Richard Mendoza 2/7/19 20190207-5031
IND1104 Leslie Burr 2/7/19 20190207-5031
IND1105 Melissa Perez 2/7/19 20190207-5031
IND1106 Robert Garcia 2/7/19 20190207-5031
IND1107 Carol Midboe 2/7/19 20190207-5031
IND1108 Angel Ramirez 2/7/19 20190207-5031
IND1109 Louise Reavis 2/7/19 20190207-5031
IND1110 Jennifer Rodriguez 2/7/19 20190207-5031
IND1111 Tom Sagona 2/7/19 20190207-5031
IND1112 Niquita Salinas 2/7/19 20190207-5031
IND1113 Ceclia Sanchez 2/7/19 20190207-5031
IND1114 Theresa Speck 2/7/19 20190207-5031
IND1115 Laurel Steinberg 2/7/19 20190207-5031
IND1116 David Thurston 2/7/19 20190207-5031
IND1117 Sergio Trevino 2/7/19 20190207-5031
IND1118 Elizabeth Watts 2/7/19 20190207-5031
IND1120 Steve Wilder 2/7/19 20190207-5031
IND1121 Bradley Willis 2/7/19 20190207-5031
IND1122 Oscar Zertuche 2/7/19 20190207-5031
IND1123 Tom Sagona 2/25/19 20190225-5006
L-xix Appendix L – Comments on the Draft EIS

and Responses
TABLE L-1

IND1124 Isidro Leal 3/11/19 20190311-4000
IND1125 Xandra Leal 3/11/19 20190311-4001
IND1126 Ava Leal 3/11/19 20190311-4002
IND1127 Michael Baguio 3/11/19 20190311-4003
IND1128 Laura Baguio 3/11/19 20190311-4004
IND1129 Juan B Maucias 3/11/19 20190311-4005
IND1130 Lucas Mosley 3/11/19 20190311-4006
IND1131 Joe Linck 3/11/19 20190311-4007
IND1132 James Tucker 3/13/19 20190313-5081
IND1133 Jennie McBride 3/13/19 20190313-4001
IND1134 Ed McBride 3/13/19 20190313-4002
IND1135 Mary Volz 3/13/19 20190313-4003
IND1136 Glenn Boward 3/13/19 20190313-4004
IND1137 Grant Wilson 3/13/19 20190313-5166
IND1138 Isidro Leal 3/13/19 20190313-4005
IND1139 Karen Boward 3/13/19 20190313-4006
IND1140 Angel Ramirez 3/13/19 20190313-5219
IND1141 Ariadne Acevedo 3/13/19 20190313-5219
IND1142 Bill Wlilliams 3/13/19 20190313-5219
IND1144 Christy Tovar 3/13/19 20190313-5219
IND1145 Drue Ann Wise 3/13/19 20190313-5219
IND1146 Edna Goette 3/13/19 20190313-5219
IND1147 Elizabeth Freeth 3/13/19 20190313-5219
IND1148 Elizabeth J Goble 3/13/19 20190313-5219
IND1149 Ian Martinez 3/13/19 20190313-5219
IND1150 Jan Wittington 3/13/19 20190313-5219
IND1151 Jim Summers 3/13/19 20190313-5219
IND1152 Joachim Herbig 3/13/19 20190313-5219
IND1153 John Ferrell 3/13/19 20190313-5219
IND1154 Jonathan Salinas 3/13/19 20190313-5219
IND1155 Julia Jorgensen 3/13/19 20190313-5219
IND1156 Katelyn Aguirre 3/13/19 20190313-5219
IND1157 Katie Lavallee 3/13/19 20190313-5219
IND1158 Leslie Wilder 3/13/19 20190313-5219
IND1160 Magaly Cornejo 3/13/19 20190313-5219
IND1161 Maria Galasso 3/13/19 20190313-5219
IND1162 Marie Hines 3/13/19 20190313-5219
IND1163 Mario Rodriguez 3/13/19 20190313-5219
IND1164 Michelle Piette 3/13/19 20190313-5219
IND1165 Mike Anderson 3/13/19 20190313-5219
IND1166 Natalia Gonzalez 3/13/19 20190313-5219
IND1167 Ned Sheats 3/13/19 20190313-5219
IND1168 Oscar Rodriguez 3/13/19 20190313-5219
IND1169 Patrick De La Garza Und Senkel 3/13/19 20190313-5219
IND1172 Robert Radnik 3/13/19 20190313-5219
IND1173 Stephanie Lara 3/13/19 20190313-5219
IND1175 Vanessa Hernandez 3/13/19 20190313-5219
IND1176 Victor Alvarez 3/13/19 20190313-5219
IND1177 William Hoenes 3/13/19 20190313-5219
IND1178 Yvonne Martinez 3/13/19 20190313-5219
IND1179 John Young 2/25/19 20190313-5232
IND1180 Kenneth Teague 4/1/19 20190401-5043
L-xx Appendix L – Comments on the Draft EIS

and Responses
FEDERAL AGENCIES
FA01 NOAA National Marine Fisheries Service, page 1 of 1
FA01-1 Thank you for your comment.
L-1 Appendix L – Comments on the Draft EIS and Responses

FA02 U.S. Coast Guard, page 1 of 1
FA02-1 Thank you for your comment. In its comments on the draft EIS
Annova requested that we evaluate the maximum potential of 125 LNG carriers
per year. The final EIS has been revised.

FA03 U.S. Environmental Protection Agency, page 1 of 1

FA04 U.S. Department of the Interior, page 1 of 19

FA04 continued, page 2 of 19
FA04-01 Comment noted. The letter to the interested parties has been
revised to indicate that impact on some resources would remain significant.
FA04-02 Comment noted. The letter to the interested parties has been
revised to acknowledge impact on the adjacent NWR.
FA04-03 On March 15, 2019 we requested that Annova provide a response

to this FWS recommendation. In its March 25, 2019 response (FERC
accession number 20190325-5179) Annova stated that it cannot commit to a
perpetual conservation easement as a lessee to the BND because Annova does
not own or control the property. If the Project continues to operate beyond the
term of the existing lease, Annova can commit to extend the term of those
existing conservation easements. If the FWS grants the right-of-way for the use
of proposed access road, Annova would not develop the alternative access road
location (see section 3.5), in which case Annova has committed to work with
the BND to establish a new conservation easement on BND property that
would protect dense thornshrub habitat on the 189-acre area that encompasses
Loma de la Jauja. See updated section 4.7.1.2 of the final EIS.
FA04-04 Based on this and similar comments received from others we have
requested that Annova provide clarification of the apparent differences in
wetlands reported. In its response filed on March 25, 2019 (FERC accession
number 20190325-5179) Annova clarified that initial emergent wetlands on site
were classified as freshwater (palustrine) emergent, but after consultation with
the COE these wetlands were reclassified as estuarine emergent. See also
updated section 4.4.1 of the final EIS.

FA04-06 Comment noted. The referenced text has been revised in the
executive summary to indicate that 550 acres would be disturbed during
construction.
FA04-07 The referenced text in the executive summary has been revised to
acknowledge the importance of dense thornscrub and coastal salt prairie.
FA04-08 Thank you for your comment. We have maintained the dates of
the FWS-recommended clearing window because the defined dates are easier to
implement than the general season of "winter", however section 4.6.1.2 of the
final EIS has been revised to mention that no winter construction is anticipated,
in addition to the discussion of the FWS-recommended clearing window.
FA04-09 FERC staff recommendations related to SpaceX are included in

section 4.12.6 of the EIS, as well section 5.2 which lists all recommendations
made in the EIS.

FA04-10 We have revised the referenced section of the executive summary

and section 4.13.3.5 of the EIS to conclude that cumulative impacts on the
aplomado falcon are significant.
FA04-11 Our recommended Migratory Bird Plan would address the

proposed facilities, including the proposed flare design. We do not agree that it
would be appropriate to include alternative facility designs within the
Migratory Bird Plan.
FA04-12 See response to comment FA04-3.

FA04-13 Because the natural gas supply lateral pipeline would be FERC
non-jurisdictional, we are not making a recommendation in the EIS for how the
pipeline would be installed. Specific installation methods may be included
with the Section 404/10 permit authorization if issued by the COE. The non-
jurisdictional supply lateral pipeline, along with other non-jurisdictional
facilities, is addressed in the cumulative effects analysis in section 6.0 of the
BA that was transmitted to the FWS on February 15, 2019. With regard to
conservation easements, see response to comment FA04-3.
FA04-16 Annova has stated that it is working with the FWS to develop
wildlife crossings along the access road. Ocelot habitat that would be affected
by the access road is addressed in our BA that was transmitted to the FWS on
February 15, 2019. Annova has not proposed this specific measure but has
stated that it would continue to consult with the FWS regarding potential
impacts on the ocelot and jaguarondi and potential measures to mitigate for
those impacts. This measure can be included during review of the BA.

FA04-17 Comment noted. See also response to comment FA04-3.
FA04-18 Section 4.1.5 of the final EIS has been revised to state that
grading would impact the surface geology of the site.
FA04-19 In accordance with Annova's Plan, monitoring of revegetated

areas that are disturbed by construction would occur at a minimum after the
first and second growing seasons following construction, but would continue
until all disturbed areas were determined to be successfully revegetated. See
section 5.4 of Annova's Plan included in appendix B of this EIS.
FA04-20 Comment noted. Section 4.13.3.3 of the final EIS has been
revised to remove the statement that mangrove wetlands would be impacted by
the Project. Annova modified its proposed site plan to avoid direct impact on
mangrove wetlands.

FA04-23 The vegetation types described in section 4.5.1.1 are part of the
existing environment within the overall project site, including areas that would
not be disturbed by construction. The purpose of table 4.5.2-1 is to identify
vegetation that would be directly affected by Project construction and
operation. We do not agree that vegetation types that would not be affected
should be added to table 4.5.2-1.
FA04-24 The referenced text is specific to impacts from just the Annova
LNG Project. Cumulative impacts, including from the three proposed LNG
projects, are evaluated elsewhere, in section 4.13 of the EIS.
FA04-25 Annova's Plan includes standards for establishing successful

revegetation of areas of the Project site that would be disturbed during
construction, and standards to determine when disturbed areas can be
considered successfully revegetated following construction. Those standards
include consideration for minimizing presence of invasive species in order to
determine that areas are successfully revegetated. With regard to wildlife
crossings along the access road, see response to comment FA04-16.

FA04-26 Comment noted. The referenced text in section 4.6.1.2 of the

final EIS has been revised.

FA04-30 Comment noted. The referenced text in section 4.7.1.3 of the

final EIS has been revised to add that FWS encourages conservation of
northern aplomado falcon habitat.
FA04-31 The requested change has been made to section 4.7.1.3 of the final
EIS.
FA04-32 Cumulative impacts on the apomado falcon are considered and

evaluated, see section 4.13.3.5 of the EIS.

FA04-33 We have updated section 4.7.1.3 with reference to National

Wetlands Inventory mapping which shows abundant palustrine emergent marsh
in the vicinity of the proposed site. Cumulative impacts on this species are
addressed in section 4.13.3.5 of the EIS.
FA04-34 The analysis of noise from construction and operation includes

estimates of sound levels from points within the proposed wildlife corridor.
Predicted maximum construction noise within the corridor would range from
55 to 60 dBA Ldn and the wildlife corridor area could temporarily experience
sound levels between 85-100 dBA Lmax when pile-driving takes place,
depending upon the number of simultaneous piles and the location on the
construction pad. Predicted sound levels in the wildlife corridor during
operation would range from 50 to 65 dBA Ldn. Annova would construct a 25-
foot-tall concrete barrier wall on the western side of the site as part of the
proposed wildlife corridor, which would further reduce sound transmission
beyond the property boundary to the southwest, so sound levels to the
southwest within the wildlife corridor would likely be less than those predicted.
See also sections 4.7.1.2 and 4.11.2 of the EIS. We have included a
recommendation in section 4.11.2 of the EIS limiting pile driving to daytime
only.
FA04-35 As required under NEPA, we have reported available information

regarding the non-jurisdictional natural gas supply lateral pipeline. The detail
requested by the FWS is not available at this time.
FA04-36 See response so comment FA04-35.

FA04-37 See response so comment FA04-35.
FA04-38 Comment noted. We have revised section 4.7.1.2 to include

additional evaluation of the South Texas Coastal Corridor.
FA04-39 Thank you for your comment. The referenced statement is not
meant to imply that replanting temporarily disturbed habitat would replace
other habitat that is permanently lost.
FA04-40 The referenced statement has been removed from the referenced
section of the EIS.
FA04-41 The referenced text has been modified as suggested by removing

reference to the San Roman Wind Farm.

FA04-43 Comment noted. The requested change has been made.
FA04-44 The referenced text has been modified to clarify that the statement
does not refer to the three proposed LNG projects.
FA04-45 Thank you for your comment. Cumulative impacts on the

aplomado falcon, including from habitat loss, are addressed in section 4.13.3.5.

FA04-47 Comment noted. Much of the analysis is section 4.8.5 (Visual

Resources) and section 4.11.2 (Noise) in the EIS focuses on potential impacts
on the Palo Alto Battlefield NHL and the Palmito Ranch NHL including
analysis added at the request of the NPS during the Project pre-filing phase.
Similar, but cumulative impacts from construction and operation of the three
proposed LNG projects, are addressed in section 4.13 of the EIS. See
responses to specific comments below.

FA04-48 FAA aircraft warning devices are only required on structures over
200 feet in height. See sections 4.6.1.2 and 4.12.5.7 of the EIS. In response to
this comment we also requested that Annova verify that no FAA warning
devices would be required. In its response filed on March 25, 2019 (FERC
accession number 20190325-5179) Annova confirmed that no FAA warning
lights or devices would be required or are proposed for the Project.
FA04-49 On March 15, 2019, we requested that Annova provide additional

information on the potable water storage tank and the similarly sized
condensate storage tank. In its response filed on March 25, 2019 (FERC
accession number 20190325-5179) Annova stated the potable water storage
tank would be 40 feet in diameter and 30 feet in height and painted a dull green
color (“covert green”) to reduce visual impacts. The final EIS has been
updated to include this additional information.
FA04-50 Section 4.5.8.2 of the EIS describes the potential impacts of the
proposed Annova Project on the visual resources of the Palmito Ranch
Battlefield NHL. See the description and analysis for KOP1, KOP2, and
KOP3.
FA04-51 We used the visual simulations as a tool to assist with the analysis
of potential visual impacts, however other factors were considered in our
analysis such as landscape, existing vegetation, and distance. Section 4.10.1.2
of the final EIS has been revised to indicate that the NPS does not concur with
conclusions on impacts to the character and integrity of the Palmito Ranch
Battlefield NHL, and that consultations between FERC staff and the NPS will
continue.
FA04-52 On March 15, 2019, we requested that Annova provide additional

information on the proposed paint colors for the tall structures. In its response
filed on March 25, 2019 (FERC accession number 20190325-5179) Annova
stated the proposed tall structures would be painted a dull green color (“covert
green”) to reduce visual impacts. See also response to comment FA04-51.
FA04-53 Section 4.10.1.2 of the final EIS has been revised to indicate that
the NPS does not concur with conclusions on impacts to the character and
integrity of the Palo Alto Battlefield NHL, and that consultations between
FERC staff and the NPS will continue.

FA04-54 Appendix E includes one visual simulation that includes an LNG

vessel at the Project site. See figure E-8b.
FA04-55 As noted in responses to comments FA04-51 and 53, consultations
between FERC staff and NPS will continue. Further discussions of appropriate
dark skies lighting technology can be a part of those consultations.
FA04-56 Potential construction noise impacts on the Palmito Ranch Battlefield
NHL are assessed in section 4.11 of the EIS and discussed with respect to
recreation in section 4.8.4.2. Given its distance from the Project site, the Palo Alto
Battlefield NHP was not considered a noise sensitive area.
FA04-57 Potential impacts of Project-related traffic on Palo Alto Battlefield
NHP and Palmito Ranch Battlefield NHL are discussed in sections 4.8.4.2 and
4.9.10.1 of the EIS. Annova estimated there would be an average of 30 delivery
vehicles per day during construction, with peak deliveries of up to 80 delivery
vehicles per day during large concrete pour. This increase in truck traffic on area
roadways could be noticeable during construction but would be short term and not
expected deter visits to the Palo Alto Battlefield NHP or Palmito Ranch Battlefield
NHL. This information has been added to sections 4.8.4.2 and 4.9.10.1. Additional
analysis of potential cumulative construction-related traffic impacts has also been
added to section 4.13.3.7.
FA04-58 Annova’s transportation consultant identified the Alternate North
Truck Route as the recommended truck route to and from the north (see EIS figure
4.9.10-2). This route includes SH 550 and passes alongside the Palo Alto
Battlefield NHP. Traffic count data for SH 550 near the SH 550/SH 1847
intersection identified average annual daily traffic volumes of 17,061 in 2017
(Texas Department of Transportation 2019). The addition of 30 to 80 delivery
trucks during construction represents a small share of existing volumes at this
location, up to 0.5 percent (80/17,061) and, as a result, is not expected to deter visits
to the Palo Alto Battlefield NHP. Reference: Texas DOT. 2019. Transportation
Planning Maps. District Traffic and Urban Saturation Web Maps. 2017. Website:
https://www.txdot.gov/inside-txdot/division/transportation-planning/ maps.html.
FA04-59 We have added the NPS concern to section 4.9.10.1 of the final EIS.
However, we have no additional details on the referenced potential road
improvement projects beyond what is currently described in the EIS.

FA04-63 This requested change has been made to the recommendation in

section 4.11.2.4 of the final EIS.
FA04-64 Thank you for your comment. The requested measure may be
considered by Annova depending on the results of the required operational
noise survey.
FA04-65 Section 4.13.3.6 of the final EIS has been revised to clarify the
potential cumulative visual impacts on the NHLs.
FA04-66 Section 4.13.3.7 of the final EIS has been revised to include
additional discussion of potential cumulative impacts from construction traffic.

FA04-67 The temporary and permanent electric transmission lines that

would serve the Annova LNG Project are non-jurisdictional facilities, and
FERC is not aware of the details for these facilities such as type of structures or
their height.
FA04-68 Thank you for your comment. The Commission staff also looks
forward to ongoing consultation with the NPS.
FA04-69 Thank you for your comment. See response to comments FA04-
51 and FA04-53.
FA04-70 We have revised the recommendation in section 4.10.5 of the final

EIS to include the NPS as a consulting party.



STATE AGENCIES
SA01 Texas Commission on Environmental Quality, page 1 of 1
SA01-1 Thank you for your comment.

SA02 Texas Parks & Wildlife, page 1 of 24

SA02 continued, page 2 of 24
SA02-1 Comment noted. Non-jurisdictional facilities are discussed as part

of cumulative impacts in section 4.13 of the EIS.
SA02-2 Non-jurisdictional facilities are discussed as part of cumulative

impacts in section 4.13 of the EIS.

SA02-3 In response to this and other comments in this letter that

recommend measures that Annova should incorporate into its Project design or
plans, on March 15, 2019 we requested that Annova provide a response to
TPWD recommendations in this letter. On March 25, 2019, Annova filed its
response, stating that it has consulted with TPWD to discuss the TPWD
comments on the draft EIS and included a table summarizing how it would
address the TPWD recommendations. The filing is included on the FERC
docket under accession number 20190325-5179.
SA02-5 If Annova decides to abandon facilities in the future, Annova

would seek the appropriate authorizations from federal, state, and local
agencies at that time. Plans and requirements for abandonment would be
developed at that time.

SA02-6 Comment noted. The Final EIS has been revised to include the
Galveston Bay LNG Project in section 3.3.2.
SA02-7 Annova would follow restoration measures from both its Upland
Erosion Control, Revegetation, and Maintenance Plan (Annova's Plan) and its
Wetland and Waterbody Construction and Restoration Procedures (Annova's
Procedures). Annova's Procedures (section D) allow for restoration of
temporally disturbed wetlands through natural revegetation. However, if
natural rather than active revegetation is used, Annova's Procedures require that
the plant species composition is consistent with early successional wetland
plant communities in the affected ecoregion, and invasive species and noxious
weeds must be absent to be considered successfully revegetated, unless they are
abundant in adjacent areas that were not disturbed by construction.
SA02-8 The final EIS has been revised by the addition of San Martin Lake
as requested.
SA02-9 Aquatic resources other than seagrass are addressed in section

4.6.2 of the EIS.

SA02-10 Impacts on tidal flats are acknowledged in the EIS, however

mitigation for these impacts would be under the jurisdiction of the COE if
considered appropriate during the COE's review of Annova's application to the
COE.
SA02-11 Any compensatory migitation required for wetland impacts,

temporary or permanent, would be decided during the COE's review of
Annova's application to the COE.
SA02-12 See response to comment SA2-10.

SA02-13 We do not agree that it should be required to clean equipment as it

moves from area to area within the Project site. However, Annova's Plan
includes standards for establishing successful revegetation of areas of the
Project site that would be disturbed during construction and revegetated
following construction. Those standards include consideration for minimizing
presence of invasive species in order to determine that areas are successfully
revegetated.
SA02-14 In response to this and other comments in this letter that

recommend measures that Annova should incorporate into its Project design or
plans, on March 15, 2019 we requested that Annova provide a response to
TPWD recommendations in this letter. On March 25, 2019, Annova filed its
response, stating that it has consulted with TPWD to discuss the TPWD
comments on the draft EIS and included a table summarizing how it would
address the TPWD recommendations. The filing is included on the FERC
docket under accession number 20190325-5179.

SA02-14a Section 4.6.1.2 of the final EIS has been revised to include
discussion of the colonial waterbird rookery located at the confluence of the
BSC and the Port Isabel Channel.
SA02-15 Section 4.6.2.1 of the final EIS has been revised to include
additional discussion of the importance of the BSC and connected shallow
water habitat.
SA02-16 The reference to a recommendation in section 4.7.3 of the draft

EIS was an error. With regard to implementation of the TPWD
recommendations, see response to comment SA02-14.
SA02-17 In section 4.6.1.2 we recommend that Annova develop a project-

specific Migratory Bird Plan that includes measures to avoid and minimize
impacts on migratory birds, and that the plan be developed in consultation with
the FWS. The Migratory Bird Plan would be the appropriate place to address
best practices for communication tower measures to reduce impacts on birds.

SA02-18 Potential impacts from construction of the non-jurisdictional

electric transmission line are addressed in cumulative impacts in section 4.13 of
the EIS.

SA02-20 As described in table 4.13.1-1, the geographic scope used for

evaluating potential cumulative impacts on resident and migratory birds is the
HUC-10 watershed. The projects listed in this comment are outside of the
HUC-10 watershed and therefore outside the area included in our analysis.

SA02-21 Shallow waterbodies that are connected to the BSC are included
in the EIS's assessment of potential cumulative impacts on water resources.
Section 4.13.2.2 of the final EIS has been revised to make this clear.
SA02-22 The final EIS has been revised to remove the referenced sentence
that described expected commitments that would be made following
construction of the non-jurisdictional facilities.
SA02-23 We have intentionally limited the analysis in section 4.13.3.5 to

federally listed species.

SA02-24 With regard to implementation of the TPWD recommendations,

see response to comment SA2-14.
SA02-25 Comment noted.
SA02-26 The suggested correction has been made in section 4.7.2.1 of the
final EIS.
SA02-27 The suggested correction has been made in section 4.7.2.7 of the
final EIS.


SA02-28 This comment is specific to the supply pipeline which is the

subject of the COE application. Since the supply pipeline is a FERC non-
jurisdictional facility, FERC defers to the COE with regard to this comment.

SA02-29 See response to Comment SA2-28.




SA02-35 This comment addresses issues that are the subject of the COE
permit application and under the jurisdiction of the COE, and as we understand
are currently under review by the COE. Therefore, we defer to the COE with
regard to this comment.







SA03 Railroad Commission of Texas, page 1 of 1

SA04 Railroad Commission of Texas, page 1 of 1

LOCAL AGENCIES
LA01 Port of Brownsville, page 1 of 1
LA01-1 Thank you for your comment.

COMPANIES AND ORGANIZATIONS
CO01 Suntrack Supply Services, Inc, page 1 of 1
CO01-1 Thank you for your comment.

CO02 Greater Brownsville Incentives Corporation, page 1 of 1
L-52 Appendix L – Comments and Responses

CO03 South Texas Manufacturers Association, page 1 of 1

CO04 Friends of Laguna Atascosa National Wildlife Refuge, page 1 of 4
CO04-1 We disagree that areas that would experience light and sound
from the Project should be considered part of the Project footprint, however the
EIS does evaluate light and sound impacts on areas surrounding the Project, as
appropriate. It is typical that some plans, such as the Facility Lighting Plan, are
not prepared until projects advance into the final design phase. We will
evaluate the Facility Lighting Plan when it is filed, and the public will also have
the opportunity to review and comment at that time.
CO04-2 The EIS acknowledges there would be impact on the Laguna

Atascosa NWR from noise during construction. Impact to the southern portion
of the refuge along SH48, including to birders, is described in section 4.8.4.2 of
the EIS. Impact from construction noise is discussed in section 4.11.12. The
FEIS discussion of socioeconomics in section 4.9.2.2 has been revised to
include references to the EIS sections on noise and visual impacts.

CO04 continued, page 2 of 4
CO04-3 Section 4.3.2.2 of the EIS describes the potential impact on the
Bahia Grande from sedimentation from Project dredging.
CO04-4 The Final EIS has been revised to refer to the Bahia Grande
restoration project rather than mitigation project.
CO04-5 The EIS includes analysis of potential impacts on socioeconomics

beyond the study that was completed by Annova. See also response to
comment CO4-2.
CO04-6 The potential contribution of the Annova Project on climate

change is evaluated in section 4.13.3.9 of the EIS.
CO04-7 See Section 1.2.10 of the EIS. The DOE has exclusive
jurisdiction over the export of natural gas as a commodity. DOE has delegated
to the Commission authority to approve or disapprove the construction and
operation of particular facilities. The facilities are considered the site at which
such facilities would be located, and with respect to natural gas that involves
the construction of new domestic facilities, the place of entry for imports or exit
for exports. However, the DOE Secretary has not delegated to the Commission
any authority to approve or disapprove the import or export of the commodity
itself as part of the Commission’s public interest determination. With respect
to the connection to the Valley Crossing Pipeline System, in a filing with the
Commission on March 25, 2019 (accession number 20190325-5179), Annova
acknowledged that design changes to the Valley Crossing Pipeline system
would be required to accommodate the natural gas supply required for the
Annova LNG Project. Annova anticipates the design changes could include
expansion of the Valley Crossing receipt header system and addition of
approximately 150,000 hp of new compression. See updated section 1.4.1 of
the final EIS.
CO04-8 Potential Project impacts on the ocelot and jaguarundi are

addressed in section 4.7.1 of the EIS, as well as in the Biological Assessment
that FERC submitted to the U.S. Fish and Wildlife Service (FWS) on February
15, 2019 (see FERC accession number 20190215-3006). The final
determination of effect, and how that may impact authorization of the Project,
is pending completion of consultation with the FWS.

CO04-9 Annova developed the proposed Project layout in consultation

with the FWS. FERC acknowledges the current layout presents tradeoffs with
respect to habitat impacts, but addresses the impacts of the current layout in the
EIS. The cumulative impacts discussion with respect to the ocelot has been
revised in the Final EIS, see section 4.13.3.5.
CO04-10 Comment noted. The EIS addresses the potential impacts of the
Annova Project on the resources listed, and addresses the potential cumulative
impacts of the Annova Project combined with the TX LNG and Rio Grande
LNG projects. The Commission will consider these potential impacts in its
decision whether or not to authorize (permit) the Annova Project.

CO04-11 Comment noted. Potential impacts on wildlife habitat, including

from segmenting habitat within the wildlife corridor between the Laguna
Atascosa and Lower Rio Grande Valley NWRs, is evaluated in the EIS.
CO04-12 Comment noted. See responses to individual comments above.

CO05 Annova LNG, page 1 of 8

CO05-1 The purpose of our cumulative impacts analysis is to evaluate the

cumulative impacts of all projects, not to compare impacts between projects or
to rank a project's contribution to cumulative impacts relative to other projects.
Therefore, we do not agree that it is necessary to rank or further clarify the
Annova Project's contribution to cumulative impacts beyond what is presented
in the EIS. For comparison purposes, the individual sections of the EISs for the
three proposed LNG projects can be reviewed to compare impacts between the
individual projects.
CO05-2 See response to comment CO5-1. Also, based on footnote c in

Table 4.13.3-1 in this comment, we have revised the final EIS where
appropriate to assume the Project would receive up to 125 LNG carriers per
year.

CO05-3 See response to comment CO5-1.


CO05-4 See response to comment CO5-1. In addition, as stated in the

EIS, a decision on the acceptability of Annova's draft Conceptual Mitigation
Plan is pending review by the COE.
CO05-5 See response to comment CO5-1. In addition, section 4.13.3.7 of

the final EIS has been modified to clarify that construction traffic for the
Annova LNG Project would primarily use SH4 rather than SH48.




CO06 Friends of the Wildlife Corridor, page 1 of 4

CO06-2 We disagree that all plans and information must be available
during preparation of the draft EIS. Information filed by Annova during the
draft EIS comment period is available to the public for review after filing with
FERC. On February 7, 2019 FERC extended the comment period on the draft
EIS until March 13, 2019, as a result of the partial Federal government
shutdown.
CO06-3 We disagree that the draft EIS was incomplete because of its non-
availability in Spanish. Executive Order No. 12898, which informs the federal
government’s approach to issues of environmental justice, provides that “Each
Federal agency may, whenever practicable and appropriate, translate crucial
public documents, notices, and hearings relating to human health or the
environment for limited English-speaking populations.” However, Executive
Order No. 12898 applies to the agencies specified in section 1-102 of that
Order, and the Commission is not one of the specified agencies. Consequently,
even if translation were required under Executive Order No. 12898, the
provisions of the Order are not binding on the Commission. However, it is
current Commission practice to address environmental justice in its NEPA
document when raised. Therefore, we have included this discussion in the final
EIS in section 4.9.9. Further, in an effort to include Spanish language speakers
in the NEPA process, Spanish language Project materials were made available
to the public during the scoping meeting and public comment meeting held in
Port Isabel and described in section 1.3.1 of the FEIS. In addition, a translator
was available to assist Spanish language speakers. During the public scoping
meeting, very few of the Spanish language materials that were made available
were utilized by attendees. As such, we determined that translation of the draft
EIS into Spanish was not necessary.
CO06-4 As noted in the draft EIS, the EIS was prepared by FERC staff,
and statements and conclusions in the EIS represent the FERC's analysis unless
specifically attributed to Annova. Impacts on lomas, including Loma Potrero
Cercado, and the related impacts on wildlife, are described in various sections
of the EIS. The final EIS has been revised to remove the statement that no
forest vegetation would be impacted. While lomas within the Project site
contain some scattered trees, the habitat is classified as scrub (following the
Ecological Mapping System of Texas) or thornscrub. However, the National
Land Cover Database (NLCD) does classify a portion of the site as forested
land use. Section 4.5.1 of the final EIS has been revised to clarify.

CO06-5 We do not agree that Annova's vegetation survey needs to be redone to

support preparation of the EIS. However, another agency may conduct a vegetation
survey of the site, or require Annova to complete another survey, if deemed appropriate
by that agency. We are not aware of evidence that specific vegetation types exist on the
site that were not identified in Annova's vegetation survey.
CO06-6 Annova initially classified some wetlands within the site as freshwater, as
shown in initial wetland survey reports filed with FERC. However, based on
consultation with the COE and further evaluation of vegetation and soil characteristics,
Annova revised the classification to be estuarine. See further explanation in Annova’s
March 25, 2019, filing in response to our EIR (FERC accession number 20190325-5179.
CO06-7 The draft conceptual mitigation plan is under the jurisdiction of the COE.
The COE would determine the adequacy of the plan. According to Annova, the COE
has stated that the final acreages would be determined based on the final mitigation
needs and work plan, which would be completed through COE coordination and permit
review, and subsequent development of engineering plans.
CO06-8 It is not necessary that the FWS Biological Opinion precede the
Commission’s permitting decision. See also response to comment CO4-8.
CO06-9 Potential impacts on wildlife habitat, including from segmenting habitat
within the wildlife corridor between the Laguna Atascosa and Lower Rio Grande Valley
NWRs, is evaluated in the EIS. See also response to comment CO4-8. The referenced
statement regarding lands identified for acquisition matches the features shown as
"USFWS Refuge Acquisition Boundary" on the November 2014 Bahia Grande Coastal
Corridor Project map. Section 4.8.4.2 of the final EIS has been revised to clarify this
statement.
CO06-10 It is typical that consultations with the FWS and NMFS as required for
compliance with Endangered Species Act and the Migratory Bird Treaty Act may not be
completed prior to issuance of the EIS, or prior to Project authorization. However, in
such a case project authorization would be conditioned on the successful completion of
the required consultations and any related mitigation plans. We will evaluate any
outstanding plans when they are filed with the FERC, and the public will also have the
opportunity to review and comment at that time.
CO06-11 We acknowledge that Annova's proposed measure using the modifier
"attempt" does not guarantee the measure would be implemented. However, our
evaluation of potential impacts takes this into consideration. In addition, as stated in
section 4.6.1.2 of the EIS, in the event that clearing could not be accomplished during
the stated time window, Annova proposes to implement additional measures, as
recommended by the FWS, designed to avoid or minimize impacts on nesting birds,
which would be acceptable.

CO06-12 The loss of loma habitat, the Project's location relative to

remaining habitat, and the potential effectiveness of the proposed wildlife
corridor along the west side of the Project site, were all considered as part of
our evaluation of potential impact on the ocelot.
CO06-13 Our evaluation of impact on Essential Fish Habitat (EFH),
including from loss of habitat, and from increased turbidity, was included in the
EFH Assessment in appendix F of the EIS. Our general conclusion is potential
impacts resulting from Project construction and operation are expected to be
short-term and highly localized, occurring primarily during construction or
shortly thereafter. On February 5, 2019, the National Marine Fisheries Service
filed comments with the FERC agreeing with the conclusions in the EFH
Assessment (see FERC accession number 20190206-5004.
CO06-14 Section 4.3.2.2 of the EIS describes the potential impact on the
Bahia Grande from sedimentation from Project dredging. The Final EIS has
been revised to refer to the Bahia Grande restoration project rather than
mitigation project.
CO06-15 Impacts on the Lower Rio Grande Valley, South Padre Island,
Palmetto Hill Battlefield, and Laguna Atascosa NWR are discussed in section
4.8.4.2 of the EIS. Construction and operation of the Project would result in
site-specific impacts on recreation and visitor use during construction and
operation, as discussed. These site-specific impacts are not expected to affect
overall regional tourism patterns, but could result in localized impacts, with
visitors and other recreationists seeking similar opportunities nearby or
elsewhere in the region.
CO06-17 As stated in the EIS and shown in table 4.11.1-4 (in section
4.11.1.4), the stationary sources associated with the Project would have
operating emissions that are less than the PSD major source thresholds for all
(non-GHG) pollutants. Although potential emissions of GHG are above the
PSD significant emission threshold, the requirements of PSD are not triggered
if GHG is the only pollutant above this threshold. However, the Project would
be subject to the Title V program because the stationary source emissions
would exceed the major source thresholds for CO and GHGs. Therefore,
Annova would need to apply for and obtain a Title V operating permit. The
applicable air permits are the appropriate mechanism for determining
mitigation, if necessary. See also new section 3.6.2 of the final EIS.

CO06-18 We address impact on wildlife from construction noise, in

particular pile driving, in several sections of the EIS. See sections 4.6.1.1,
4.6.1.2, 4.11.2.3 and 4.11.2.4 as well as response to comment FA04-34. We
disagree the analysis is inadequate.
CO06-19 A determination that an impact would be significant is not a

determination that the impact would be "too great". The Commission will take
into account the environmental conclusions made in the EISs for the three LNG
projects when considering whether or not to authorize the projects.
CO06-21 See responses to individual comments on these topics above.
CO06-22 The Commission will take into account the potential impacts on
these resources when considering whether or not to authorize the Annova
Project.

CO07 Institute for Policy Integrity, page 1 of 15
CO07-1 Thank you for your comments. See responses to individual

comments below.
CO07-2 It is beyond the scope of the EIS to attempt to monetize the social
cost of greenhouse gas emissions. See also response to the following comment
CO7-3.
CO07-3 Regarding the Social Cost of Carbon (SCC) tool, as well as the
Social Cost of Methane and Nitrous Oxide tools, estimates the monetized
climate change damage associated with an incremental increase in carbon
dioxide (CO2) emissions in the given year. It estimates the cost today of future
climate change damage, represented by a series of annual costs per metric ton
of emissions discounted to present-day value. We recognize the availability of
the SCC tool, but conclude that it is not appropriate for use in project analyses
for the following reasons: The SCC is not meaningful in our NEPA analysis for
project decisions under the Natural Gas Act (NGA). The Commission has
determined that the SCC tool is more appropriately used in NEPA analyses by
regulators whose responsibilities are tied more directly to fossil fuel production
or consumption. The Commission’s authority under Section 7 of the NGA has
no direct connection to the production or end use of natural gas. The
Commission does not control the production or consumption of natural gas.
Producers, consumers, and their intermediaries respond freely to market signals
about location-specific supply and location-specific demand. The Commission
oversees proposals to transport natural gas between those locations. Our NEPA
analysis considers all construction emissions and annual operational GHG
emissions that are causally related to the proposed action that is before the
Commission.















CO08 Center for Liquefied Natural Gas, page 1 of 3



CO09-1 Section 4.9.10.1 of the final EIS has been updated to include some
of the non-sensitive information that is provided in this filing on the potential
off-site parking locations. We have retained a recommendation that Annova
provide additional information prior to construction.



CO10 Sierra Club, page 1 of 113
CO10-1 We do not agree that the draft EIS fails to satisfy NEPA, or that a
supplemental draft EIS is required. See responses to specific comments below.



CO10-2 We disagree. The EIS discloses the potential impacts on

environmental resources resulting from construction and operation of the
Project. The EIS was prepared in accordance with NEPA, CEQ guidelines, and
other applicable requirements. The EIS includes sufficient detail to enable the
reader to understand and consider the issues raised by the Project and addresses
a range of alternatives. The omissions cited in the comment (e.g., EFH
assessment, wetlands mitigation details, etc.) are concurrent federal reviews
being contemplated by federal resource agencies such as the NMFS, FWS, and
COE. Although not finalized at the time of the draft EIS, the impacts
associated with these reviews were disclosed for consideration.


CO10-3 The draft EIS comment period was consistent with the FERC's
typical comment period of 45 days. While some information was pending at
the issuance of the draft EIS, the public was not deprived of a meaningful
opportunity to comment on substantial adverse environmental effects of the
Project or a feasible way to mitigate or avoid such effects. The EIS includes
sufficient detail to enable the reader to understand and consider the issues
raised by the Project and addresses a reasonable range of alternatives.
CO10-4 A Spanish-speaking interpreter was provided during the public

comment session on the DEIS.
CO10-5 See response to CO04-7. Under section 3 of the Natural Gas Act,
oversight for LNG export is divided between the Commission and the U.S.
Department of Energy (DOE). FERC is responsible for the siting of LNG
facilities; however, it is the DOE, not the Commission, which retains the
exclusive authority over the export of the natural gas as a commodity, including
the responsibility to consider whether the exportation of that gas is in the public
interest. As discussed in section 1.2.1.2, the DOE issued an order granting
authorization to Annova to export LNG by vessel from the LNG terminal to
free trade agreement countries.



CO10-8 Comment noted. See response to comment CO10-5.
CO10-9 We disagree. See responses to specific alternatives comments

below.
CO10-11 Comment noted. We have updated the analysis in the final EIS to
include the grid-sources emissions using the EPA's AVERT model. See section
3.6.2.



CO10-12 It is beyond the scope of the EIS to address indirect effects from
the production of the electricity that would be used by the Project.
CO10-13 During the pre-filing process Annova modified the proposed site
layout to reduce the area of shoreline impact, including to avoid impact on
mangrove wetlands. As shown on figure 1-2 of the EIS, most of the shoreline
impact would be associated with the marine facilities that require a direct
connection to the marine waterway. We do not agree that it is necessary to
evaluate an alternative design that would move gas pre-treatment, liquefaction,
and LNG storage facilities farther from the shoreline.


CO10-14 The Commission evaluates projects as proposed, and reasonable

alternatives to those projects. It is important to note that the Commission’s role
under the NGA is to review applications filed with it, not to develop alternative
plans for energy infrastructure that would deviate from the project’s stated
purpose. Thus, alternatives such as building a facility with a smaller design
capacity and output as suggested in this comment are not evaluated in the EIS,



CO10-15 The EIS evaluates impacts on local communities. See sections

4.9 and 4.8. See also responses to further specific comments below.

CO10-16 We disagree. Environmental justice impacts are adequately

addressed in the EIS. See section 4.9.9.

CO10-17 We disagree. Potential impacts on public health and safety are

adequately addressed in sever sections of the EIS. See section 4.9.8 (Public
Services), 4.9.9.2 (Disproportionate Human Health or Environmental Effects),
4.11 (Air Quality and Noise), and 4.12 (Reliability and Safety). Cumulative
impacts on public health and safety from construction and operation of the
Annova LNG project combined with other proposed projects, including LNG
projects, is addressed in sections 4.13.3.7, 4.13.3.9, and 4.13.3.10.


CO10-18 As stated in the EIS (section 4.12.5.8) Annova submitted a draft

emergency response plan (ERP) to address emergency events and potential
release scenarios in its application with FERC. The ERP would include public
notification, protection, and evacuation. FERC staff evaluated the initial draft
of the emergency response procedures to assure that it covers the hazards
associated with the Project. In addition, we recommend in section 4.12.6 that
Annova provide additional information, for review and approval, on
development of updated emergency response plans prior to initial site
preparation. We also recommend in section 4.12.6 that Annova file three
dimensional drawings, for review and approval, that demonstrate there is a
sufficient number of access and egress locations. If this project is authorized
and constructed, Annova would coordinate with local, state, and federal
agencies on the development of an emergency response plan and cost sharing
plan. We recommend in section 4.12.6 that Annova provide periodic updates
on the development of these plans for review and approval, and ensure they are
in place prior to introduction of hazardous fluids. In addition, we recommend
in section 4.12.6 that project facilities be subject to regular inspections
throughout the life of the facility and would continue to require Annova to file
updates to the ERP, as necessary.

CO10-19 We disagree. The potential impact of the Annova Project on

public schools is acknowledged in section 4.9.8.3. The cumulative impact of
the Annova Project with other area projects, including other proposed LNG
projects, is addressed in section 4.13.3.7.

CO10-20 We disagree. Section 4.9.3 of the EIS addresses the potential

impact of the Project on property values of the nearest residences. Section
4.9.3 includes the statement "Industrial and similar developments have been
found to affect property values within an approximate 2-mile radius (Yellow
Wood Associates 2004)" and goes on to evaluate potential Project-specific
impacts.

CO10-21 The results of the traffic impact analysis prepared for the Project
(Traffic Impact Group 2015) are summarized in section 4.9.10.1. As noted in
the comment, the analysis assumes that staggered shifts would be employed
during construction to reduce potential impacts on roadway traffic.
Contrary to the summary provided in the comment, the traffic impact analysis
does not assume that workers would be transported to and from the
construction site from a centralized location via passenger buses. The traffic
impact analysis is based on workers commuting to and from the site (with an
assumed 20 percent carpool rate). Proposed mitigation for the four
intersections that would likely be impacted are summarized in table 4.9.10-3.
However, as noted in the EIS, Annova has proposed bussing, and, if that were
to occur, it would reduce the potential impacts identified in the traffic impact
analysis and described in section 4.9.10.1. Contrary to the summary provided in
the comment, the Project would not add large commuter traffic flows to SH 48,
which is located across the BSC from the Project site. Primary site access
would be via SH 4. SH 48 from Port Isabel was identified as a potential truck
route, but the traffic impact study identified two other routes as the
recommended routes (see section 4.9.10.1, Heavy Trucks subsection).
Therefore, the Project is not expected to affect the ability of Port Isabel and
Laguna Heights residents to travel along SH 48 to and from Brownsville.
Potential traffic-related impacts on tourists are discussed in section 4.9.10.1,

Tourism and Recreation subsection.


CO10-22 The economic impact analysis cited in this comment was, as noted in the
draft EIS, prepared by Ernst & Young (2015) on behalf of Annova. Separate impact
analyses were conducted for the state and Cameron County (see table 4.9.2-2 in the
EIS). Direct employment related to on-site construction was provided by Exelon
management and only those direct jobs expected to be filled by Texas and Cameron
County residents, respectively, are included in table 4.9.2-2. Indirect impacts were
estimated based on the shares of Project-related expenditures expected to occur in-state
and in Cameron County, respectively, also using information provided by Exelon. This
approach does not count positions filled by non-local workers as direct benefits to the
modeled regions (the state and Cameron County), and, while details are not provided by
Ernst & Young (2015), this type of modeling is designed to capture only those
secondary (indirect and induced) impacts that occur in the modeled region. In other
words, although specific details of the modeling approach are not provided, it is
reasonable to assume that the analysis accounted for the impacts of the non-local
workforce in an appropriate manner.
With respect to the potential for incoming workers to "significantly change the
character of the area" due to their "different cultures and lifestyles," as discussed in
section 4.9.1, an average of 253 non-local workers are expected to be employed for
the construction phase of the Project, peaking with total employment of up to 780
non-local workers. These potential temporary increases in population would be
equivalent to about 0.1 percent and 0.2 percent of the existing population in
Cameron County and unlikely to significantly alter local character or existing
patterns of economic activity. Finally, the comment expresses concern that once
Project construction is complete, the decrease in demand for Project-related goods
and services and reduction in local expenditures by non-local workers could result
in a disproportionately large shock to the local economy, resulting in business
displacement and increased unemployment. Project construction would provide
substantial investment in the local economy, as indicated by the Ernst & Young
(2015) study, and provide opportunities for local workers and businesses, some of
which could last up to four years. As construction nears completion, it is
anticipated that workers will seek new opportunities and businesses will adjust their
outputs and production forecasts accordingly. The newspaper article cited in the
comment found that while the Enid area experienced a large decline in gross
domestic product, consistent with large construction projects coming to an end, the
overall economy remained strong (Wilmoth 2018).
Reference: Wilmoth, B. 2018. Enid's economy slows as construction projects are
completed. The Oklohoman. September 20. Website: https://newsok.com/
article/5608887/enids-economy-slows-as-construction-projects-are-completed?
Accessed on March 18, 2019.

CO10-23 See response to previous comment CO10-22.


CO10-24 As noted in the comment, operation and maintenance of the

Project would require 165 personnel, with an estimated average salary per
worker of $105,000, including benefits (Ernst & Young 2015). Spending by
these relatively highly paid workers would support other economic activity in
the local economy, along with Project-related operations and maintenance
spending. The civilian labor force in Cameron County in 2014 consisted of
about 168,000 workers (table 4.9.2-1). The addition of 165 well-paid jobs is
not expected to result in substantial changes to patterns of local economic
activity. As noted in section 4.9.6, Annova anticipates that approximately 110
of these positions would be filled by non-local workers who would permanently
relocate to the area. The relocation of approximately 110 workers and their
families to the Project area is not expected to affect the supply of regional
housing resources.
CO10-25 The addition of approximately 110 workers to the Cameron

County area, is equivalent to about 0.03 percent of total county population in
2014 (table 4.9.1-1) and unlikely to have a noticeable effect on community
cohesiveness.

CO10-26 The comment requests that the economic impact analysis

presented in the EIS take into account what it terms the "market volatility of
LNG" and, more specifically, the effects of competition from other LNG
terminal facilities given uncertainty regarding the supply of natural gas likely to
be available for export. The economic impact analysis summarized in the EIS
(Ernst & Young 2015) assumes that the Annova facility would operate as
proposed, with Project-related employment and expenditures supporting
secondary (indirect and induced) economic activity elsewhere in Texas and
Cameron County. Modeling the effects of competition and price changes is
outside the scope of this analysis, but any reductions in Project-related local
employment and spending would have commensurate effects on estimated
secondary (indirect and induced) impacts.

CO10-27 The comment states that the draft EIS concluded that the Project
would not affect regional tourism patterns or the overall level of visitation to
the region "with relatively little evidentiary support." Construction and
operation of the Project would result in site-specific impacts on recreation and
visitor use during construction and operation, as discussed in section 4.9.2.2 of
the EIS. These site-specific impacts are not expected to affect overall regional
tourism patterns, but could result in localized impacts, with visitors and other
recreationists seeking similar opportunities nearby or elsewhere in the region.
Project-related impacts on recreation and tourism are discussed in more detail
in section 4.8.4 of the EIS.





CO10-29 The EIS does not assess the potential for the proposed LNG
terminal to discourage future investment in recreation and tourism-related
businesses or other activities that seek proximity to recreational opportunities
or scenic resources. Similarly, the analysis does not consider the potential for
the proposed LNG terminal to attract other more industrial uses to the area.
This type of analysis would be speculative at best, as many factors influence
business and household location decisions, and the likelihood that the LNG
terminal alone would attract new, unrelated industrial activities is believed to
be low.

CO10-30 The cited text accurately discloses the anticipated direct effects of
Project construction and operation on the recreation and tourism sector.
Cumulative effects are assessed in section 4.13 of the EIS.


CO10-31 Potential impacts on commercial fishing are discussed in section

4.9.2.3 of the EIS. Specific concerns raised by the commenter with respect to
EFH are discussed in response to comments CO10-32 to CO10-38.

CO10-32 In its comments on the Essential Fish Habitat Assessment

included in the draft EIS (see comment FA01-1), the National Marine Fisheries
Service stated that it has reviewed the information provided and concurs that
the impacts would be temporary and minor. Therefore, NMFS has no
Conservation Recommendations to provide on this project, and this concludes
the EFH consultation requirements of the Magnuson-Stevens Fishery
Conservation and Management Act and no further consultation with NMFS is
required.



CO10-34 As stated in the EIS Cumulative Impacts section (section

4.13.3.4), withdrawal of cooling water by LNG carriers at the three terminals
would have direct effects on ichthyoplankton. However, combined, engine
cooling water withdrawal by LNG carriers for all three projects would have a
minor impact on ichthyoplankton within the BSC. The EIS correctly identifies
that there is likely not higher densities of ichthyoplankton in cooling water used
by LNG vessels than in other parts of the BSC. Because a significant
percentage of the water in the BSC would not be used, then a significant
percentage of the ichthyoplankton stock would also not be affected. The
estimate of ichthyoplankton mortality was included as part of the analysis in the
EFH assessment (see section 4.0 and 4.2.1.5 of the EFH Assessment in
appendix F of the EIS). See response to comment CO10-32 for the NMFS
response to this analysis.
CO10-35 Based on review of the EFH Assessment by the NMFS no

mitigation is required to minimize impacts on fisheries. See response to
comment CO10-32.
CO10-36 The EIS assesses the potential for invasive species introductions
via ballast water in sections 4.3.2.2 and 4.6.2.2; however, the final EIS has been
updated to include additional information regarding the efficacy and timeline
for these measures.

CO10-37 See response to Comments CO10-35 and 37.

CO10-38 We maintain that the EIS adequately addresses cumulative

impacts on EFH and fisheries. See also NOAA Fisheries comment on the
Annova Project EFH Assessment in comment FA01-01.
CO10-39 The final EIS has been updated to account for the potential
maximum of up to 125 LNG carriers per year visiting the Annova Project.
Potential impact on the commercial fishing, including the BSC-based
shrimping industry is include in section 4.9.2.3 of the EIS. However, based on
this comment and similar comments received on the draft EIS, on March 15,
2019, we requested that Annova provide additional information regarding
potential impacts on the Brownsville-based shrimp industry from proposed
LNG vessels transiting the BSC, and have updated the final EIS as appropriate.
See also Annova's response to our EIR on the FERC docket in accession
number 20190325-5179.

CO10-40 As noted in section 4.9.2.2, potential impacts on fishery resources

are discussed in section 4.6 of the EIS. Specific concerns raised by the
commenter with respect to EFH are discussed in response to comments CO10-
32 to CO10-38. Potential impacts on fishery resources are not expected to
affect the commercial fishing industry.

CO10-41 The Project is not expected to cause "damage to the commercial

fishing and shrimping industries," and even if these types of effect were to
occur, it is not clear how that would in turn affect the tourism industry. It may
also be noted, as stated in section 4.9.2.2, that almost all of the shrimp landed at
the Ports of Brownsville and Port Isabel is caught offshore in the Gulf of
Mexico. The commercial fishing that does occur in the estuarine waters of
Cameron and Willacy Counties is dominated by bait fisheries, with a small
black drum (Pogonias cromis) commercial fishery also present.

CO10-42 The example provided in the comment refers to mitigation that

was required by the Massachusetts Executive Office of Environmental Affairs
(Rigzone.com 2006). As stated in the EIS (section 4.9.2.4), construction barge
traffic is not expected to affect the passage of shrimp boats or other commercial
fishing vessels through the BSC. Commercial fishermen who dock along the
BSC may experience delays when LNG carriers are making ports of call at the
Project site. Temporarily displaced shrimpers would be able to trawl elsewhere
in the BSC or nearby Gulf of Mexico.
Reference: Rigzone.com. 2006. Romney Approves Two Offshore LNG

Terminals. Website: https://www.rigzone.com/news/oil_gas/a/39328/
romney_approves_two_offshore_lng_terminals/ Accessed on March 18, 2019.

CO10-43 Comment noted. See our assessment of compliance with section

106 in section 4.10 of the EIS.
CO10-44 It is standard practice for a Commission Order to include a

condition that construction may not proceed until after the NHPA Section 106
compliance process has been completed. We summarize our compliance with
Section 106 in section 4.10 of the EIS. We recommend that Annova file all
outstanding reports and agency comments with the FERC and that FERC staff
complete the Section 106 consultation process before construction may begin.



CO10-47 We disagree that we should enlarge the direct and indirect APE
for evaluating impacts. However, we evaluate the potential impact on two
NRHP-listed properties that lie outside the direct and indirect APE, the Palo
Alto Battlefield NHL located approximately 9.1 miles west of the Project site,
and the Brazos Santiago Depot located approximately 5.5 miles east of the
Project site. See section 4.10.1.2. We also evaluate potential visual and noise
impacts on the Laguna Atascosa and the Lower Rio Grande NWRs which are
outside of the direct and indirect APEs. See sections 4.8.4, 4.8.5, and 4.11.2.


CO10-48 The EIS thoroughly evaluates the potential Project impacts on the
Palmito Ranch Battlefield NHL. See sections 4.10.1.2, 4.8.4. 4.8.5, 4.11.2, and
appendix E.


CO10-51 We disagree. We believe the analysis in sections 4.8.5 and

4.10.1.2 of the EIS support the conclusion that the Project would not affect the
essential features of the Palmito Ranch Battlefield for the period of significance
(the Civil War) and its overall integrity would remain intact.

CO10-52 We disagree. We believe the analysis in section 4.11.2 supports

the conclusion that noise from the Project would not have a significant effect on
the Palmito Ranch Battlefield.

CO10-54 We disagree that the draft EIS fails to adequately address impacts
on listed and sensitive species. See responses to individual comments below.


CO10-55 FERC staff have not deferred NEPA obligations with respect to
federally listed threatened and endangered species. Section 4.7.1 of the EIS
includes the NEPA evaluation of potential impacts on federally listed
threatened and endangered species.

CO10-56 We disagree that the analysis in the EIS fails to adequately

address effects on listed species. See response to individual comments below.

CO10-57 We disagree that the EIS largely dismisses or mischaracterizes

potential impact on the ocelot north-south movement corridor and the
significance of impacted habitats. However, based on this request, section
4.7.1.2 of the final EIS has been revised to include additional discussion of the
north-south movement corridor (South Texas Coastal Corridor) and potential
project impacts. Cumulative impacts on the north-south movement corridor,
including specifically from the three proposed LNG projects, is addressed in
section 4.13.3.5. Section 4.13.3.5 of the final EIS has also been updated to
address comments on the draft EIS, including from the FWS.

CO10-58 The EIS includes information that is currently know about

measures that would avoid, minimize, or mitigate for impacts on the ocelot
from construction and operation of the Project. Greater detail is also included
in the BA which the FWS will use in its evaluation of impacts on the species.


CO10-59 Section 3.4 of the EIS includes evaluation of alternative sites

along the BSC. Each of the alternative sites would involve different impacts on
ocelot habitat and potential impacts on the South Texas Coast Corridor for
ocelot movement. As stated in the EIS we conclude that none of the alternative
sites would result in an environmental advantage over the proposed site. See
also response to comment CO10-13.

CO10-60 As noted in section 4.7.1.3, the Project would result in the

permanent loss of one acre of potential suitable habitat for the piping plover
and red knot. Although this one acre is not designated critical habitat, available
designated critical habitat in the area can be used to place the loss of one acre
of potential habitat in context. The one acre would represent 0.01 percent of
critical habitat in the 7,217-acre Unit TX-1. We maintain that this impact on
potential habitat may affect but is not likely to adversely affect the piping
plover and red knot. With regard to additional conservation measures, we
maintain that no additional measures are necessary, but the FWS may
recommend or require additional conservation measures as part of its review of
the BA.

CO10-61 As stated in section 4.7.1.3, one acre of potential habitat would be

permanently affected by the Project. While the Project site includes 13.4 acres
of designated critical habitat, the portion of the site that contains critical habitat
would not be directly affected, and therefore no designated critical habitat
would be directly impacted by the Project. The 13.4 acres of critical habitat
within the Project site is approximately 0.2 percent of the critical habitat
included in the 7,217-acre Unit TX-1, and 0.02 percent of the total piping
plover critical habitat designated in Texas. We maintain that constructing and
operating the Project would not significantly destroy or adversely modify
piping plover critical habitat.

CO10-62 The evaluation of potential impacts on sea turtles in section

4.7.1.4 of the EIS acknowledges the potential for vessel strikes on sea turtles,
and mortality as a result. However, based on this comment we have updated
section 4.7.1.4 to include additional information on the potential for vessel
strikes to occur.



CO10-63 See response to comment CO10-62. In revised section 4.7.1.4 of

the EIS we conclude that the addition of 125 LNG carriers per week to the BSC
and Gulf of Mexico waters would not be likely to adversely affect sea turtles
through vessel strike. As a result, we are not recommending additional
mitigation measures and we maintain that constructing and operating the
Project may affect but is not likely to adversely affect any sea turtle species.

CO10-64 We disagree. Section 4.7 of the EIS includes a species-specific

assessment of habitat loss as well as other potential construction and operation
impacts. Our conclusions and determinations of effect for each species are
based on this species-specific analysis.
CO10-65 On February 15, 2019, we sent the Biological Assessment to the

FWS with a letter requesting concurrence with our determinations of effect
contained in our Biological Assessment for the Project (see FERC Docket
accession number 20190215-3006). It is standard practice for a Commission
Order to include a condition that construction may not proceed until after
section 7 consultation under the Endangered Species Act has been completed.
Here, we recommend that Annova should not begin construction until the
FERC staff completes section 7 consultation. The public will continue to have
the opportunity to review and comment on filings as they are made with the
Commission.

CO10-66 We disagree. Wetland impacts from Project construction and

operation are evaluated in section 4.4 of the EIS. Alternatives are evaluated in
section 3.0, which includes a comparison of wetland impacts by alternatives
where that information is available. Impacts from the non-jurisdictional supply
pipeline are evaluated in cumulative impacts in section 4.13 of the EIS.

CO10-67 Section 3.4 of the EIS includes an evaluation of alternative LNG

sites, including a comparison of NWI-mapped wetlands within each site. See

CO10-68 Minimization measures are included in Annova’s Procedures that

would adequately address wetlands that are only temporarily affected by
Project construction, such that impacts on temporally affected wetlands would
be less than significant. As stated in section 4.4 of the EIS, it would be the
responsibility of the COE as part of its review of the Section 404/Section 10
permit under the Clean Water Act, not the Commission, to determine the need
for wetland mitigation and the adequacy of mitigation proposed by Annova,
including consideration of the current conditions and the ownership or
management of the mitigation area. We anticipate that if the COE issues a
Section 404/Section 10 permit for the Project, it would be conditioned upon
Project-related adverse impacts on wetlands and waters of the U.S. being
effectively offset by mitigation similar to what Annova has identified in its
draft Conceptual Mitigation Plan.

CO10-69 We disagree that the supply pipeline would be FERC

jurisdictional. We address this non-jurisdictional facility in section 4.13 of the
EIS under cumulative effects. The COE is evaluating the supply pipeline as
part of its review of the Section 404/Section 10 permit application, which we
assume will also include consideration of the need for mitigation for wetland
impacts associated with the pipeline.
CO10-70 See response to Comment CO10-69.

CO10-71 See response to Comments CO10-68 and CO10-69.

CO10-72 Notwithstanding that the wetland mitigation plan is under review

and jurisdiction of the COE and not the Commission (see response to Comment
CO10-68), in an Environmental Information Request dated March 15, 2019, we
asked Annova to respond to this comment and similar comments. In its
response Annova maintains that the draft Conceptual Mitigation Plan
accurately represents the wetland site conditions. See Annova's response on the
Project docket in accession number 20190325-5179. Ultimately, the COE will
make a determination regarding the acceptability of the wetland mitigation
plan.

CO10-73 We disagree that the discussion and analysis of risk posed by the
SpaceX launch site on the Project is inadequate. Public portions of the ACTA
report were submitted to the project docket on April 25, 2017, and
supplemental data was submitted on August 22, 2017. The public information
provided in these filings shows the debris impact probability contours for
varying debri from both the Falcon 9 and Falcon Heavy rocket launch vehicles.
The draft EIS provided the FERC staff's conclusions based on this analysis.

CO10-74 The impact probabilities are dependent on fragment velocity,

mass, shape and size. The initial ACTA report provided impact probability
contours for fragments above 10,000 foot-pounds kinetic energy. In response
to FERC staff's information request, additional public contours (results of the
analysis) were provided for fragments with kinetic energy thresholds of 11,
100, 1,000, 10,000, 100,000, and 1,000,000 foot-pounds. The kinetic energies
relate to the potential for them to cause damage, including potential adverse
impacts on people and potential damage to piping, pressure vessels, and
reinforced concrete of a varying thicknesses. This information was used to
assess the potential direct impact to persons onsite (i.e., construction workers
and permanent plant personnel) and potential for cascading effects that could
lead to releases. For any releases that could be triggered, hazard modeling was
evaluated under varying conditions to determine whether there could be
impacts offsite that could impact the public. The analyses indicated there
would not be any significant risk to the offsite public. Specific information on
what potential projectiles could result in damage and releases is considered as
potential information that adversaries could use and therefore was categorized
as Critical Energy Infrastructure Information (CEII) and would not be subject
to public disclosure.

CO10-75 Section 4.12.5.7 of the final EIS has been updated to indicate that
the analysis is specific to both Falcon 9 and Falcon Heavy launch vehicles and
not for conceptual launch vehicles such as the Big Falcon Rocket. FERC staff
recommendations in section 4.12.6 have also been updated so that Annova must
file procedures to conduct risk-based assessments that would incorporate the
FAA's public guidance prior to a rocket launch. Since the risk assessments
would incorporate the FAA's public guidance, the risk assessments would be
based on the most up-to-date information about areas likely to be impacted by
falling debris and would allow Annova to take any action such as reducing or
stopping certain plant operations prior to a rocket launch.



CO10-76 As noted in the Coast Guard's Letter of Recommendation

Analysis, FERC staff and Coast Guard did discuss space rocket launch
operations and potential impacts on LNG marine vessels. These discussions
were based on FERC staff analysis of the two public ACTA submittals filed on
April 25, 2017, and August 22, 2017. As noted in the comment, the Coast
Guard would assess with LNG marine vessel transit on a case-by-case basis to
determine if any safety and security measures are necessary.

CO10-77 This comment references comments submitted under accession

number 20150114-5038 that are addressed in the final EIS issued under Docket
Number CP13-483-000 (see accession number 20150930-4002, Appendix W
Part 7). In addition, section 4.12.2 discusses the August 2018 MOU between
DOT PHMSA and FERC. Under this MOU, the DOT PHMSA would issue a
Letter of Determination after reviewing Annova's hazard analysis and modeling
results. Section 4.12.3.1 indicates that major LNG marine vessel accidents
have not resulted in injury to the public and have resulted in minimal loss of
LNG for incidents involving loading or unloading operations and no loss of
LNG after a grounding or collision event. Section 4.12.5.1 discusses why the
1944 release incident in Cleveland, Ohio resulted in public impacts and also
states that subsequent major incidents (including the 2014 incident at the
Plymouth LNG facility that is referenced in the comment) have not impacted
the public.

CO10-78 As part of DOT PHMSA's LOD process, Annova has submitted

numerous responses to DOT PHMSA's information requests on the FERC
docket. Based on its review of this information, DOT PHMSA issued its Letter
of Determination on March 20, 2019.
CO10-79 The August 2018 MOU between DOT PHMSA and FERC does
not require DOT PHMSA's LOD to be issued prior to the draft EIS. Annova
has filed in the Project docket numerous filings in response to DOT PHMSA
information requests. Certain information is filed as public information and is
available for the public to review. In addition, as indicated in section 4.12.5.2
of the EIS, FERC conducted a engineering review on the use of various layers
of protection or safeguards to reduce risks of potential hazards to offsite public.
FERC also reviewed potential impacts from natural hazards and external
impacts from the surrounding areas. This review focuses on the safe and
reliable operation of the site.

CO10-80 We disagree. The possible impact of the Project on price,

production, and use of natural gas in the United States are not part of the scope
of the EIS.
CO10-81 As discussed in section 1.3 of the FEIS, production, extraction,

and end-use of natural gas are not part of the proposed action evaluated in the
EIS. Speculation on whether the export of natural gas would result in increased
natural gas production is outside the scope of the EIS. Gas used for export can
come from several existing production areas. Although environmental and
economic models do exist to estimate market changes based upon gas flows
into and out of markets, ultimately this type of analysis is outside of the scope
for this EIS. Our analysis of cumulative impacts of the Project, including air
quality and climate change impacts, is included in section 4.13.2 of the EIS.
Similarly, the effects of LNG combustion in end-use/importing markets are

outside of the scope of this EIS. Additionally, the DC Circuit court held in
Sierra Club v. FERC (No. 14-1249) and Sierra Club and Galveston Baykeeper
v. FERC (No. 14-1275) that FERC’s NEPA environmental review do not
include indirect impacts resulting from increased natural gas exports, such as
increased natural gas production. In addition, it held that the DOE, not FERC,
has responsibility as the agency that approves export of the commodity.


CO10-82 Section 1.2 of the EIS identifies the cooperating agencies

participating in development of the EIS and each agency's permit reviews or
administrative actions applicable to the Project. Section 1.2 also identifies
agency actions that may require NEPA and which agencies may choose to
utilize this EIS to support other agency actions.

CO10-83 We disagree. The supply pipeline is a non-jurisdictional facility

and need only be addressed in the cumulative impacts section of the EIS.

CO10-84 Section 4.13.3.9 includes a discussion of the Project's contribution

towards climate change. Review of the Project is limited to the economic and
environmental impacts of the proposal before the Commission; therefore, the
effects of LNG combustion in end-use/importing markets are outside of the
scope of this EIS.

CO10-85 Whether or not the Project would result in an increase in natural

gas production is beyond the scope of the EIS.




CO10-88 Whether or not the Project would result in an increase in overseas

natural gas use is beyond the scope of the EIS.

CO10-89 The adequacy and scope of previous reviews by DOE are beyond
the scope of the EIS.

CO10-90 We disagree. Section 4.13.3.9 includes a discussion of climate

change and greenhouse gas emissions. Section 4.11.1 disclosed the Project
direct emissions of GHGs.

CO10-91 The EPA has accepted the GWP value of 25 for methane over a
100-year period. FERC appropriately selected this value because this is the
value EPA established on November 29, 2013 for reporting of GHG emissions.
EPA supported the 100-year time period over the 20-year period in its summary
of comments and responses in the final rulemaking, 2013 Revisions to the
Greenhouse Gas Reporting Rule and Final Confidentiality Determinations for
New or Substantially Revised Data Elements, establishing the methane GWP at
25 (78 FR 71904, November 29, 2013). Similarly, in this final rulemaking,
EPA supported the adoption of the published IPCC’s Fourth Assessment
Report GWP values over the Fifth Assessment Report values. EPA
acknowledged the Fifth Assessment Report could lead to more accurate
assessments of climate impacts in the future; however, when balanced with the
benefit of retaining consistency with other U.S. climate programs, including
EPA's Greenhouse Gas Reporting Program and Inventory of U.S. Greenhouse
Gas Emissions and Sinks, the potential gain in accuracy does not justify the
loss of consistency in reporting and likely would cause stakeholder confusion
among the various GWPs used in different programs. EPA identified that it
may consider adoption of the Fifth Assessment Report GWPs in the future, at
which time we will ensure that FERC staff request the use of any revised EPA
GWP values in future NEPA evaluations.


CO10-92 Gas production and gathering activities, and the pipelines and
facilities used for these activities, are not regulated by FERC and are outside
the scope of the NEPA analysis. While past, present, and reasonably
foreseeable future oil and gas infrastructure within the geographic scope of the
cumulative impacts assessment are addressed in section 4.13. Regarding end-
use of gas, see response to comment CO10-84.
CO10-93 We disagree. Section 4.13.3.9, Climate Change, of the EIS

includes a discussion of the effects of the increase in global GHG emissions.
With respect to evaluating the social cost of carbon, see response to comment
CO7-3.






CO10-94 We disagree that the EIS fails to adequately address cumulative

impacts. Section 4.13 addresses the five items listed in this comment that are
needed for a meaningful cumulative effects analysis.

CO10-95 Section 4.13.1 of the EIS provides a discussion of past actions that
have affected resources in the Project area. In addition, the remainder of
section 4 outlines the baseline conditions in the Project area. CEQ guidance
states that an adequate cumulative effects analysis may be conducted by
focusing on the current aggregate effects of past actions without delving into
the historical details of individual past actions. In the EIS, we consider the
impacts of past projects within the resource geographic scopes as part of the
affected environment (environmental baseline) which was described and
evaluated in the preceding environmental analysis. However, present effects of
past actions that are relevant and useful are also considered. The reason for the
difference in reported cumulative impacts on wetlands between the three LNG
project EISs is because each project has slightly different geographic scope
used for the analysis, based on location and project-specific features such as the
pipeline that is included with the Rio Grande LNG project.

CO10-96 Section 4.13.3.4 of the EIS discloses cumulative impacts on

specific aquatic resources. With regard to mitigation plans, mitigation plans for
the Annova Project as well as the other two proposed LNG projects would be
finalized in coordination with the COE Section 404/Section 10 permit process,
and none of the projects would be permitted to proceed with construction (if
approved) until the mitigation plans have been finalized.

CO10-97 It is not necessary to include an appendix to support the

cumulative impacts analysis for air impacts. Section 4.13.3.9 of the final EIS
has been updated to include additional cumulative impacts air analysis.


CO10-98 We disagree that a revised or supplemental draft EIS is required.

However, we have considered all comments filed on the draft EIS and have
updated or revised the final EIS where appropriate.


CO12 South Padre Island Chamber of Commerce, page 1 of 1

ELECTED OFFICIALS
EO01 Eddie Lucio III, Texas House of Representatives, page 1 of 1
EO01-1 Thank you for your comment.

EO02 Alex Dominguez, Texas House of Representatives, page 1 of 1

EO03 Lieutenant Governor Dan Patrick, page 1 of 1

PUBLIC COMMENT SESSION
PM01 Scoping Meeting, Port Isabel, TX, January 10, 2019, page 1 of 110

PM01 continued, page 2 of 110

PM01-1 Thank you for your comment.
PM01-2 Air emissions are evaluated in section 4.11.1.2 of the EIS. As

described in that section of the EIS, primary standards for NAAQS emissions
set limits the EPA determined are necessary to protect human health including
sensitive populations such as children, the elderly, and asthmatics. Review of
the Project's emissions against the NAAQS primary standards takes into
account human health.
PM01-3 Thank you for your comment. Potential impact of the Annova
LNG Project on the local economy, including industries that support
vacationing, fishing, and ecotourism, are evaluated in section 4.9 of the EIS.




PM01-9 Thank you for your comment. We do not plan to hold other
comment sessions on the Annova LNG Project.


PM01-13 Thank you for your comment. Potential Project impacts on

migratory birds, and butterflies and other pollinators is addressed in section
4.6.1.2 of the EIS. Potential Project impacts on tourism is addressed in section
4.9.2.2 of the EIS.


PM01-15 Potential Project impacts on migratory birds is addressed in

section 4.6.1.2 of the EIS, and impact on endangered species in section 4.7. In
response to comments on the draft EIS we have added additional discussion of
the Laguna Madre in the EIS.
PM01-16 With respect to human health impacts from the operating

emissions from the Project, see response to comment PM1-2.

PM01-17 On February 7, 2019, FERC extended the comment period on the

draft EIS until March 13, 2019, as a result of the partial Federal government
shutdown.
PM01-18 With respect to impacts on lomas and mitigation for that impact,
see responses to comments IND9-14a, IND15-1, and CO10-57 and 58. With
regard to mitigation for wetland impacts, see response to comment CO10-68.
PM01-19 Thank you for your comment. The draft EIS was completed in
December 2018, and this final EIS includes comments made on the draft EIS.

PM01-20 See response to comment CO10-68.
PM01-21 As stated in section 4.5.5 of the EIS, although approximately 409

acres of vegetation would be permanently lost because of the Project, the region
contains large quantities of similar vegetation communities. Therefore, we
have determined that construction and operation of the Project would not
significantly impact vegetation.
PM01-22 See responses to comments IND9-14a, IND15-1, and CO10-57

and 58.
PM01-23 Potential impacts on the ocelot from Project construction and

operation, including from facility lighting, is addressed in section 4.7.1.2.
PM01-24 Potential impacts on the Bahia Grande from Project construction

and operation, including sedimentation, is addressed in section 4.3.2.2 of the
EIS.
PM01-25 Potential impacts on the commercial fishing industry, including

shrimping, is addressed in section 4.9.2.3 of the EIS.

PM01-26 See response to comment IND14-6.
PM01-27 Impact on the Loma Ecological Preserve is included in section

4.6.1.2 of the EIS. This section has been updated with additional information
since issuance of the draft EIS. With respect to potential mitigation for loss of
loma habitat, see section 4.7.1.2.
PM01-28 Potential impacts on South Bay from the Project, including initial
dredging as well as vessel traffic, are addressed in section 4.3.2.2 and 4.6.2.2 of
the EIS.

PM01-29 As stated in section 4.6.1.2 of the EIS, in the event that clearing
could not be accomplished during the stated time window, Annova proposes to
implement additional measures, as recommended by the FWS, designed to
avoid or minimize impacts on nesting birds, which would be acceptable.
PM01-31 Thank you for your comment. Potential impact of the Annova
LNG Project on the local economy, including industries that support
vacationing, fishing, and ecotourism, are evaluated in section 4.9 of the EIS.


PM01-33 See response to comments IND9-14a and IND15-1.


PM01-36 See response to comments CO7-3, and IND15-13.
PM01-37 With respect to climate change, see the revised analysis in section
4.13.3.9 of the EIS. Visual impacts from structures and flaring are addressed in
section 4.8.5. The introduction of a new industrial facility at the proposed site,
including the visual impacts associated with that facility, are factored into our
analysis of potential Project impacts on tourism and recreation in section 4.9 of
the EIS.
PM01-38 Potential impact on bait shrimping is included in our analysis of

potential impact on commercial fishing. See section 4.9.2.3 of the EIS. In
response to this comment and similar comments on the draft EIS we have
added additional evaluation of potential impact on the bait shrimp industry to
the final EIS, including cumulative impact on commercial fisheries in section
4.13.3.7. See also response to comment CO10-39.
PM01-39 Potential emissions from Project operation are addressed in

section 4.11.1 of the EIS. With respect to carbon capture, see response to
comment CO6-17.

PM01-40 As stated in section 4.5.5 of the EIS, although approximately 409

acres of vegetation would be permanently lost because of the Project, the region
contains large quantities of similar vegetation communities. Therefore, we
have determined that construction and operation of the Project would not
significantly impact vegetation.
PM01-41 Section 7 of the Endangered Species Act does not require that a
permit be denied based on potential impact on a federally listed species.
However, Section 7 consultation is ongoing, and a final determination of
species effect has not been completed. See also response to comment CO10-
65.

PM01-42 In response to this and other similar comments on the draft EIS,
section 4.9.2.3 of the final EIS has added to include a discussion of the
potential Project impacts on the various conservation initiatives in the Rio
Grande Valley.

PM01 continued page 22 of 110
PM01-43 Reliability and Safety in general is evaluated in section 4.12 of the

EIS. Siting requirements, including consideration of populated areas, is
discussed in sect, 4.12.2.
PM01-44 See section 4.9 of the EIS for our evaluation of the potential
Project impacts on temporary and permanent employment.
PM01-45 Potential Project impacts on tourism of the region, including

birding and eco-tourism, is addressed in section 4.9.2.2 of the EIS. The
potential Project impacts on endangered species is addressed in section 4.7 of
the EIS.

PM01-46 Potential Project impacts on air quality, including emissions that

could potentially affect human health, is evaluated in section 4.11.1 of the EIS.
PM01-47 Potential impact on the visual character of the areas surrounding

the Project are addressed in section 4.8.5.
PM01-48 See our evaluation of Project alternatives included in section 3 of

the EIS.

PM01-50 On February 7, 2019 FERC extended the comment period on the

shutdown.
PM01-51 We disagree that the draft EIS was incomplete because it was not
available in Spanish. During scoping and comment meetings, we had Spanish
translators available.





PM01-67 In Section 3.4 of the EIS we evaluate several other alternative

sites along the BSC.
PM01-68 With respect to impact on the ocelot movement corridor, see

response to comment CO10-57. With respect to issuance of the draft EIS
before the facility lighting plan is complete, see response to comment IND15-6.

PM01-69 As noted in the comment, FERC is required to evaluate each

separate project as proposed. However, we have included a cumulative impacts
analysis in each EIS that evaluates the potential cumulative impacts should
other projects be constructed in the same region, including the three proposed
LNG projects. See section 4.13 of the Annova LNG final EIS.
PM01-70 With respect to the lighting plan, see response to comment

IND15-6. With respect to sea turtles, see our analysis of potential Project
impacts in section 4.7.1.4 of the EIS.


PM01-73 We disagree. The potential impact on seagrass and oyster beds is

adequately addressed in the EIS.
PM01-74 We are not aware that the border wall would be constructed in
such a way as to divert surface flow into the Project area. Annova is not
proposing to dredge the BSC deeper, but to dredge a new berth and turning
basin adjacent to the channel. See section 2.1.6 of the EIS.

PM01-75 Impacts from parking lots and the access road are included in the
total Project impact that is evaluated in the EIS, and the areas impacted by these
features would be included in any mitigation. Annova is proposing to install
crossings across the access road designed for ocelot movement. Annova is not
proposing crossing for crabs.
PM01-76 The estimate of ichthyoplankton mortality was included as part of

the analysis in the EFH assessment (see section 4.0 and 4.2.1.5 of the EFH
Assessment in appendix F of the EIS). In its comments on the EFH
Assessment the NMFS concurred with our conclusions. See response to
comment CO10-32 for the NMFS response to this analysis. With respect to
the Texas Coastal Zone Management Program, we have included a
recommendation in section 4.8.6 of the EIS that Annova shall file a
determination from the Texas Coastal Coordination Advisory Committee that
the Project is consistent with the laws and regulations of the state’s Coastal
Zone Management Program.
PM01-77 The potential impact of Project related noise on wildlife is

addressed in several sections of the EIS, including sections 4.6, 4.7, 4.8, and
4.11.2. It is beyond the scope of the EIS to address the Port of Brownsville's
actions with respect to the three proposed LNG projects.

PM01-78 See response to comment CO6-2. On February 7, 2019, FERC

extended the comment period on the draft EIS until March 13, 2019, as a result
of the partial Federal government shutdown.


PM01-82 Potential impacts from Project lights and noise are addressed in
the EIS. As noted in the EIS, the barrier wall that Annova proposes to
construct between the terminal site and the undisturbed wildlife corridor would
be expected to reduce some noise and light impacts within the corridor.

PM01-83 With respect to Project need, see response to comment CO6-20.

With respect to the Facility Lighting Plan, see response to comment IND15-6.
PM01-85 Section 4.12.5.8 of the EIS includes a description of the

requirements for an evacuation plan. Annova has not yet prepared the
evacuation plan.

PM01-86 GHGs and climate change is addressed in section 4.11.1 and

4.13.3.9 of the EIS, respectively.

PM01-88 See response to comments CO10-75 and CO10-73.



PM01-93 Potential impacts from Project lights and noise are addressed in
the EIS. As noted in the EIS, the barrier wall that Annova proposes to
construct between the terminal site and the undisturbed wildlife corridor would
be expected to reduce some noise and light impacts within the corridor.
PM01-94 The potential impact of the Project on wildlife habitat, and ocelot
habitat in particular, is addressed in the EIS. Potential alternative sites are
addressed in section 3.
PM01-95 GHGs and climate change is addressed in sections 4.11.1 and

4.13.3.9 of the EIS, respectively. The Project's visual impacts from lighting
and flaring is evaluated in section 4.8.5.
PM01-96 Comment noted. Potential impacts of the non-jurisdictional

power line are addressed in section 4.13 of the EIS.

PM01-98 With regard to consultation with the FWS, see response to

comment IND14-6. With regard to consultation with NOAA Fisheries see
response to comment CO10-32.

PM01-101 We disagree. Our analysis of potential impacts on sea turtles

from the proposed dredging is included in section 4.7.1.4 of the EIS.
PM01-102 See response to comments IND19-14a, IND15-1, and CO10-58.

PM01-104 See response to comments IND13-1 and IND13-2.

PM01-107 See response to comment IND9-14a and IND15-1.

PM01-108 See response to comment CO6-4 and CO6-5.

PM01-111 Section 4.7.1 of the EIS does, in fact, identify the 18 federally
listed species that could potentially be affected by the proposed Project, and
includes an analysis of the potential impact on each.
PM01-112 The EIS does, in fact, say that some wildlife could be affected by
noise and light from the Project. See the analysis in section 4.7 in general, and
section 4.7.1.2 for the ocelot in particular.

PM01-113 With respect to Project need, see response to comment CO6-20.

With respect to potential impact on tourism, including eco-tourism, see our
analysis in section 4.9.2.2 of the EIS.
PM01-114 Section 4.12.5.7 of the EIS includes our analysis of potential

SpaceX launch failures. See also responses to comments CO10-73 and CO10-
75.

PM01-115 Potential cumulative impacts from construction of the three

proposed LNG projects, as well as other projects that could be constructed in
the region, is addressed in section 4.13 of the EIS.





PM01-116 With respect to comments specific to the Rio Grande LNG

project, see the EIS and comment responses in FERC docket number CP16-
540-000. With respect to the Annova LNG Project, there is no designated blast
zone for the LNG terminal, which is proposed to be located about 5 miles from
Long Island Village. However, a small portion in the southeast corner of Long
Island Village is located within the Accidental Sandia Hazard Zone 3, and the
entire Long Island Village would be located within the Intentional Sandia
Hazard Zone 3, associated with outbound (loaded with cargo) LNG carriers that
would transit the BSC. See discussion in section 4.12.3.4 of the EIS.

PM01-117 Comment noted. In the EIS we acknowledge that some impacts

would be permanent. While Annova has proposed some mitigation, the
mitigation would compensate for some impacts and reduce their significance,
but not necessarily restore all environmental impacts. See also response to
comment CO10-68.

PM01-118 See our evaluation of Project impacts on wildlife and aquatic

resources in sections 4.6 and 4.7 of the EIS.
PM01-119 We use a number of terms in the EIS to describe potential

environmental impacts, some of which are estimated based on the proposed
action and best available information. If the Project is approved, any statement
or commitment that Annova has made in its application or subsequent filings,
and any FERC staff recommendation made in the EIS, would become a
condition of approval. See our recommendation Number 1 in section 5.2 of the
EIS.

PM01-120 See response to comment PM1-119.
PM01-121 See our assessment of protection from internal and external

hazards and accidents in section 4.12 of the EIS.

PM01-122 Thank you for your comment. We address the potential impact on
tourism from the Annova LNG Project in section 4.9.2.2 of the EIS, and
cumulative impacts from the three proposed LNG projects in section 4.13.3.7.
PM01-124 It is estimated that potential delay times for small vessels in the
BSC could be from 0.5 to 1.5 hours for a transit of an LNG carrier in the BSC,
depending on the direction of travel and location at the time of entrance by the
LNG carrier. See section 4.9.10.2 of the EIS.
PM01-125 Potential impact on recreational fishing and other users of the

BSC and Lower Laguna Madre is evaluated in sections 4.8.4.2 and 4.9.2.2 of
the EIS.

PM01-126 As stated in section 3.1 of the EIS, solar, wind, or other renewable
energy project cannot meet the purpose for the Project and are not considered
or evaluated as alternatives.
PM01-127 The potential impact on tourism from the Annova LNG Project is
PM01-128 The potential impact on scenery, sensitive species, and wetlands

from the Annova LNG Project are addressed in the EIS in sections 4.8.5, 4.7,
and 4.4, respectively.
PM01-129 Section 4.12.5.7 of the EIS includes an evaluation of potential

issues related to proximity of the Annova LNG Project to the SpaceX facility.
PM01-130 Section 4.9 of the EIS includes an evaluation of Project-related

jobs, including temporary jobs during construction and long-term jobs during
operation, and where the workers may originate from.


PM01-136 The potential impact on air emissions and related human health is
addressed in section 4.11.1 of the EIS.

PM01-138 Thank you for your comment. The proposed Annova LNG
Project site is just over 5 miles from the Long Island Village.
PM01-139 Potential impacts from the Annova LNG Project on other vessel
traffic in the BSC is addressed in section 4.9.10.2, and potential cumulative
impacts from the three proposed LNG projects is addressed in section 4.13.3.7.

PM01-141 The safety and regulatory requirements of LNG vessels that

would be traveling within the BSC is addressed in section 4.12.3 of the EIS.

PM01-142 With respect to the archeological survey that has been conducted
for the Annova LNG Project, see response to comment IND20-6. The
Carrizo/Comecrudo Tribe of Texas has submitted comments on the Texas LNG
project, but not the Annova LNG Project.
PM01-143 See response to comments IND14a and IND15-1.

PM01-145 Section 4.3.2.2 of the EIS describes the potential impact on the
Bahia Grande from sedimentation from Project dredging.



PM01-152 Potential impacts on the environment, including species and

humans, is evaluated in various sections of the EIS.
PM01-154 Section 4.9 of the EIS includes an evaluation of Project-related

jobs, including temporary jobs during construction and long-term jobs during
operation, and where the workers may originate from. Potential impact on the
regional economy, including tourism, commercial fishing, and recreation-based
business is addressed in section 4.9 of the EIS.

PM01-157 Potential impact on wildlife, including ocelots and birds, is

addressed in sections 4.6 and 4.7 of the EIS.
PM01-158 Potential Project impacts on air quality such as criteria pollutant

emissions that could potentially affect human health, are evaluated in section
4.11.1 of the EIS.

PM01-161 Potential impact on the environment from construction of the

Annova LNG Project is addressed in various sections of the EIS. Potential
impact on the economy is addressed in section 4.9.
PM01-162 See response to Comment PM01-158

PM01-165 Potential impact on the ocelot is addressed in section 4.7.1.2 of

the EIS, as well as in the Biological Assessment. See also response to
comment CO4-8.

PM01-166 Potential impact on migratory birds is addressed in section 4.6.1.2

of the EIS.

PM01-168 The potential impact of the LNG vessels that would result from
Project construction and operation is addressed in several sections of the EIS,
including section 4.9.10.2 and 4.12.3.
PM01-169 The potential threat of terrorism is addressed in the discussion of

LNG terminal and marine facilities security in several locations within section
4.12 of the EIS.
PM01-170 The potential impacts on real estate values and tourism, including
resorts, is addressed in sections 4.9.3 and 4.9.2.2.
PM01-171 Thank you for your comment. Potential impact on the area's
tourism industry is addressed in section 4.9.2.2 of the EIS.

PM01-172 We address potential impacts on loma habitats in several locations

in the EIS. See also response to comments IND9-14a and IND15-1.
PM01-173 Section 4.12.5.7 of the EIS includes an evaluation of potential

impacts on the Annova Project from external events, including a launch failure
at the SpaceX facility.
PM01-174 Habitat loss is addressed in several sections of the EIS, including

sections 4.6 and 4.7.
PM01-175 DOT PHMSA's LOD issued on March 20, 2019 evaluated the
overpressure or blast wave effects due to an explosion of flammable vapor.
Specifically, section 9.5 of the LOD analysis showed the overpressure hazards
would remain within the Project's property line and could extend into the
Brownsville Ship Channel. In addition, we evaluated whether layers of
protection would be in place to reduce the risk of offsite impacts on the public
from hazards, including explosions. Based on the proposed layers of
protection, FERC staff recommendations, and DOT PHMSA’s LOD, we find
that the risk of potential impacts from explosions were sufficiently evaluated.
With respect to the risk related to the Annova Project's location near the
SpaceX facility, see response to comments CO10-73 and CO10-75.

PM01-176 Impact on wildlife habitat, including from the proposed access

road, is addressed in section 4.6 of the EIS and impact on wetlands is addressed
in section 4.4.

PM01-177 Impact on wildlife, including increased risk from crossing of the

proposed access road, is addressed in sections 4.6 and 4.7 of the EIS.
PM01-179 With regard to wetland mitigation see response to comment

CO10-68. With regard to mitigation for impacts on lomas, including
acquisition or preservation of lands for a wildlife corridor, see response to
comment CO10-58.

PM01-180 Section 3 of the EIS evaluates alternatives for the Project,

including alternative locations. As stated in section 3.1, wind and solar energy
cannot meet the purpose for the Project and are not considered or evaluated
further in the EIS.

set limits the EPA determined would protect human health including sensitive
populations such as children, the elderly, and asthmatics.

PM01-184 The proposed Annova LNG Project does not include a pipeline
with compressor stations. Noise from construction and operation of the LNG
terminal facilities is addressed in section 4.11.2 of the EIS. Cumulative noise
from other proposed and potential projects in the region is addressed in section
4.13.3.9 of the EIS.

PM01-185 See response to previous comment PM1-184.
PM01-187 As stated in section 3.1, wind and solar energy cannot meet the
purpose for the Project and are not considered or evaluated further in the EIS.

PM01-188 See response to previous comment PM1-187.
PM01-189 Project cost, or risks to Project investors, is beyond the scope of

the EIS. See also response to comment CO6-20.
PM01-190 See response to following comment PM1-191.

PM01-191 The proposed site elevations and facilities are designed to protect
critical facilities from storm surges, including from hurricanes. However, we
have included a number of recommendations related to storm surge elevations
to ensure that the final design accounts for the maximum potential storm surge
elevation. See additional discussion in section 4.12.5.6, and our
recommendations in section 4.12.6. In addition, see response to comments
IND09-9 and IND09-13.


PM01-192 We disagree that the draft EIS was inadequate. See responses to
the preceding specific comments on noise, wildlife corridor, and threats to
Native American lands.
PM01-193 Project impacts on wetlands is addressed in section 4.4 of the EIS,

and impact on lomas and the value of lomas as wildlife habitat is addressed in
several sections including 4.5, 4.6, and 4.7. Potential impacts on the Bahia
Grande is addressed in sections 4.3 and 4.4.

PM01-194 Thank you for your comments. See section 3 of the EIS for our
assessment of alternatives, including potential alternative locations for the
proposed Annova LNG Project.
PM01-196 See response to comment IND9-14a.

PM01-198 The draft EIS does not say that dredging would do permanent and
significant damage to water quality of South Bay. See section 4.3.2 of the EIS.
PM01-199 Our assessment of Essential Fish Habitat at the Project site and
the potential impact on EFH was included in appendix D of the draft EIS. See
PM01-202 Thank you for your comment. See our assessment of air
emissions from the proposed Annova Project in section 4.11.1 of the EIS.

PM01-203 See our assessment of potential impacts on endangered species,

including the ocelot, in section 4.7 of the EIS. Potential impact on birding
opportunities is evaluated in several sections of the EIS, including 4.8, 4.9, and
4.11.2.
PM01-205 On February 7, 2019 FERC extended the comment period on the

shutdown.
PM01-206 See response to comment IND9-14a.

PM01-210 In response to our recommendation in the draft EIS, on March 20,

2019, Annova filed information on three potential locations for the off-site
parking, stating that because it is in the process of negotiations with the
property owners it cannot disclose the exact locations. However, in general
Annova states the areas are currently disturbed or in similar use as a parking
area. See updated section 4.9.10.1 of the final EIS.




PM01-219 With respect to the location of the Annova LNG Project relative
to the other projects, see response to comment IND15-5. With respect to
SpaceX, see response to comments CO10-73 and CO10-75.
PM01-221 The determination of cumulative impacts for ocelot and

jaguarundi is not justification for denying approval of the Project. See also


PM01-224 Potential impacts on sea turtles are evaluated in section 4.7.1.4 of

the EIS.

PM01-225 Cumulative impacts, including from construction and operation of

the 3 proposed LNG projects, are addressed in section 4.13 of the EIS. Annova
is not proposing mitigation plans specific to air quality or water quality.

PM01-226 The potential impacts from light on wildlife is addressed in

section 4.6 and 4.7 of the EIS.
PM01-227 Annova is not proposing to install any structures over 200 feet in
height that would require any aircraft warning lights. With respect to potential
impact on bird watchers and other visitors, see EIS sections 4.8.4 and 4.9.2.2.
With respect to air emissions and potential impact on Port Isabel High School
and South Padre Island, see response to comment PM1-183.

PM01-228 Security of the LNG terminal and LNG carriers while in transit is
addressed in several locations within section 4.12 of the EIS. See also response
to comments IND12-1 and IND21-5.

PM01-231 The analysis in the EIS includes assessment of potential short and
long-term impacts in the environment and people.
PM01-232 Potential impacts on the Bahia Grande from Project construction

and operation, including sedimentation, is addressed in section 4.3.2.2 of the
EIS. As stated in section 2.9 of the EIS, Annova anticipates at least a 25-year
life span for the Project, but the facilities would be designed and capable of
operating for 50 years or more with proper maintenance. An environmental
review would be required if Annova would propose to abandon the Project.



PM01-234 The potential impact on lomas is acknowledged in several

sections of the EIS, including sections 4.5, 4.6, and 4.7. See also response to
comment IND9-14a.

PM01-235 See response to comment CO10-57. The referenced statement

from the draft EIS regarding lands identified for acquisition matches the
features shown as "USFWS Refuge Acquisition Boundary" on the November
2014 Bahia Grande Coastal Corridor Project map. Section 4.8.4.2 of the final
EIS has been revised to clarify this statement.

PM01-237 Air emissions and air quality are evaluated in section 4.11.1.2 of
the EIS. Potential impact on wildlife, including migratory birds, is evaluated in
sections 4.6 and 4.7 of the EIS.
PM01-238 Potential impact on property values is addressed in section 4.9.3

of the EIS. See also response to comment CO10-20.

set limits the EPA determined would protect human health including sensitive
populations such as children, the elderly, and asthmatics.
PM01-240 Potential impact on water quality, and measures that would be

taken to minimize water pollution, is addressed in section 4.3.2 of the EIS.
Potential Project-related impact on tourism and water-based recreation is
addressed in sections 4.8.4 and 4.9.2.2.

PM01-241 As stated in section 2.9 of the EIS, Annova anticipates at least a

25-year life span for the Project, but the facilities would be designed and
capable of operating for 50 years or more with proper maintenance. An
environmental review would be required if Annova would propose to abandon
the Project.


PM01-245 GHGs and climate change are addressed in sections 4.11.1 and
4.13.3.9. Section 4.13.3.9 of the final EIS has been updated since issuance of
the draft EIS.
PM01-246 Section 4.12.5.6 of the EIS describes the design measures that are
proposed for the Annova Project to withstand hurricanes. We are also
recommending additional measures to ensure the integrity of the facility in the
event of a hurricane. See section 4.12.6.
PM01-247 Environmental impacts from the Valley Crossing Pipeline are

included in our cumulative impacts assessment in section 4.13 of the EIS.
Other matters related to the border crossing component of the Valley Crossing
Pipeline would be addressed in the separate FERC docket number CP17-19-
000.

PM01-248 Thank you for your comment. Environmental and social concerns
identified by the public, including local residents, are evaluated in the EIS.

PM01-249 Potential impacts on endangered species, including the ocelot, is

evaluated in section 4.7 of the EIS, as well as in our Biological Assessment.
See also response to comment CO6-8.

PM01-252 The Annova Project does not include a proposed LNG pipeline.
With respect to availability of the draft EIS in Spanish, see response to
comment CO6-3.
PM01-253 The Annova Project does not include a proposed LNG pipeline.
With respect to the number of shovel tests conducted for cultural resources, see
response to comment IND20-6.


INDIVIDUAL COMMENTERS
IND01 Thomas R Smith, page 1 of 1
IND01-1 Thank you for your comment.

IND02 Kenneth Teague, page 1 of 7
IND02-1 Comment noted. Potential environmental impacts from the

natural gas supply pipeline are addressed as part of our cumulative impacts
assessment in section 4.13 of the EIS.
IND02-2 With respect to FWS and TPWD comments, see comment letters
FA04 and SA02. The EIS discloses information on impacts and mitigation
measures as known. With respect to the status of ESA consultation with the
FWS, see response to comment CO10-65.

IND02 continued, page 2 of 6
IND02-3 As stated in the EIS, Annova’s stated purpose is to source natural

gas from the South Texas Gulf Coast region. Our review of alternatives,
however, expanded the area of our analysis to include the entire Texas Gulf
Coast. We believe that the existing supply and pipeline network in the Texas
Gulf Coast could meet Annova’s objective for the source of natural gas, and
this region of analysis would not significantly change the duration of LNG
carrier transits. A site located on the Calcasieu River in Louisiana would
require either an extended pipeline or a different natural gas supply network.
We determined that locations this far removed from the proposal would modify
the applicant’s stated purpose and did not consider these further.

IND02-4 We have identified no indications that there might be

contaminated sediments at the proposed Project site, therefore we do not
consider it necessary to require testing of the area to be dredged. Without some
indication that there is a concern for contaminated sediments, we maintain that
previous studies and analysis are appropriate to establish baseline conditions.
IND02-5 The potential for the Project to impact seagrasses from turbidity
caused by dredging is addressed in section 4.3.2.2 and 4.6.2 of the EIS. We
have revised section 4.3.2.2 of the final EIS to acknowledge the potential
presence of seagrasses in the Bahia Grande, however, no seagrasses are
currently mapped in the Bahia Grande, nor is the Bahia Grande identified as an
area containing seagrass in the TPWD’s 2012 update to its Seagrass
Conservation Plan.

IND02-6 Annova's Plan and Procedures include measures designed to

ensure temporarily disturbed areas are revegetated following construction,
include post construction monitoring to determine revegetation success.
However, our conclusions in the EIS related to habitat and wetland impacts is
not contingent upon temporarily disturbed areas reaching a certain level of
quality following construction. The potential need for mitigation for impacts
on wetlands, whether temporary or permanent, will be addressed by the COE
during review of Annova's Section 404/Section 10 permit application.

IND02-8 We address the non-jurisdictional natural gas supply pipeline in

section 4.13 of the EIS under cumulative effects. The COE is evaluating the
supply pipeline as part of its review of the Section 404/Section 10 permit
application.
IND02-9 See response to comment IND02-05.
IND02-10 See response to comment CO10-68. Impacts on tidal flats are

acknowledged in the EIS, however mitigation for these impacts would be under
the jurisdiction of the COE if considered appropriate during the COE's review
of Annova's application to the COE.
IND02-11 See response to comment CO10-68.


IND03 Gary Richards, page 1 of 1
IND03-1 The Annova Project is not proposed to be located on South Padre

Island. The potential visual impacts from the Project, including from LNG
storage tanks and flare stacks, are addressed in section 4.8.5 of the EIS.
IND03-2 The potential impacts from air emissions are addressed in section
4.11.1 of the EIS. The proposed Annova Project would not include trucks
transporting fracked gas, or LNG.
IND03-3 The potential impacts on local socioeconomics, including public

services and taxes, is addressed in section 4.9 of the EIS.
IND03-4 We address the potential impacts on the National Wildlife

Refuges in several locations in the EIS, including in sections 4.8.4, 4.8.5, and
4.11.2. Potential impacts from the non-jurisdictional natural gas supply
pipeline are addressed in section 4.13.
IND03-5 The potential impacts on tourism are addressed in the EIS in

sections 4.8.4 and 4.9.

IND04 Jim Russell, page 1 of 1

IND05 Sumner Herrick, page 1 of 1

IND06 Justin Vosburg, page 1 of 1

IND07 Mary Branch, page 1 of 5
IND07-1 The Commission will consider the analysis in this EIS, including
comments such as this one, as part of its determination of whether or not to
authorize the Project.
IND07-2 As a matter of practice the Commission does not hold public

hearings during its review of LNG projects.
IND07-4 See response to comment CO10-68 and IND2-08.
IND07-5 The natural gas supply pipeline is a non-jurisdictional facility and

therefore not under the jurisdiction of FERC.
IND07-7 Potential impacts on lomas are described in several locations in

the EIS. The COE is currently reviewing Annova's Section 404/Section 10
permit for the proposed wetland impacts.

IND07-8 The natural gas supply pipeline is a non-jurisdictional facility and

therefore not under the jurisdiction of FERC.
IND07-9 A cumulative impacts analysis that includes the Rio Grande LNG
and Texas LNG projects, as well as the Valley Crossing Pipeline, is included in
section 4.13 of the EIS.
IND07-10 Comment noted. The significance of Bahia Grande, and the

potential impacts of the Annova Project on this system, as well as the potential
cumulative impacts of the Annova Project combined with other projects, is
evaluated in the EIS.
IND07-11 The FWS estimated that the amount of dense shrub vegetation
available in the Laguna Atascosa NWR and the surrounding area (within a
13.7-mile buffer around the refuge, the Project site being located just outside
this buffer) is 19,200 acres. This is the habitat that is important for the ocelot.
Construction of the Project would impact less than 1 percent of the dense shrub
vegetation within a 13.7-mile radius around the Laguna Atascosa NWR. As
explained in the EIS, we have determined that past and present cumulative
impacts on ocelots and jaguarundis are significant and the future projects
considered here will only increase this impact. That is, the addition of LNG
terminals would not create a significant impact, they would merely exacerbate
an existing significant cumulative impact.

IND07-12 See response to comment IND7-10. Also, impacts on the Bahia

Grande would not itself be reason to deny authorization of the Project.
However, the Commission will consider these impacts as part of its
determination of whether or not to authorize the Project.

IND07-13 Comment noted. Estimated jobs that would be created during

construction and operation are addressed in section 4.9 of the EIS.
IND07-14 Reliability and safety is addressed in section 4.12 of the EIS. We

note that LNG is a form of methane, not propane, and the two gases behave
very differently when released.
IND07-15 The Commission will evaluate Project need during its

determination of whether or not to authorize the Project.
IND07-16 The Commission does not monitor information on an applicant's

website. We rely on information filed with the Commission under oath.

IND07-17 As a matter of practice the Commission does not hold public

hearings during its review of LNG projects.
IND07-18 The public comment period on the draft EIS was extended to
March 13, 2019.

IND08 Marie Norrell, page 1 of 1

IND09 Dr. Sarah Stueber Bishop Merrill, page 1 of 16
IND09-2 Thank you for your comment. See responses to individual

comments below.
IND09-3 With respect to the mitigation plan for wetland impacts, see
response to comment CO10-72. With respect mitigation for impacts on
wildlife habitat, including preservation of a wildlife corridor, see response to
comments CO10-57 and CP10-58.

IND09-4 We disagree.
IND09-5 We assume the commenter is referring to the Annova LNG

Project and not the TX LNG project. See responses to individual comments
below.
IND09-6 As stated in table 4.13.1-1 of the EIS, the geographic scope for
our cumulative impacts analysis for noise is any project that can cause an
impact to an NSA within 1 mile of the proposed Annova LNG Project. There
are no pipeline compressor stations located within this geographic scope.
IND09-7 DOT PHMSA's LOD issued on March 20, 2019 evaluated the
Brownsville Ship Channel. In addition, section 4.12.5.6 of the EIS discusses
Annova's design to protect against storm surges. To ensure the site would be
protected from storm surges, we recommended in section 4.12.6 of the draft
EIS that Annova provide a wave overtopping analysis for a 500-year storm that
also accounts for sea level rise. Annova provided this analysis to show how the
facility would be protected in the event of storm surge and flood inundating the
facility. We have included a recommendation in section 4.12.6 of the final EIS
that Annova demonstrates how the Project would be protected against wave
run-up from the 500-year event. In addition, the facility would be designed to
withstand a Category 4 hurricane. FERC staff also recommends in section
4.12.6 of the EIS that Annova implement a routine monitoring plan to ensure
that the site does not fall beneath an elevation of 16.5 feet NAVD 88, and the
earthen berm be maintained at an elevation of no less than 21 feet NAVD 88.

IND09-8 Section 4.12.5.8 of the EIS as well as a FERC staff

recommendation in section 4.12.6 discuss a Cost Sharing Plan. This plan
would highlight how Annova would cover the costs of state and local first
responders that are required for the security and emergency response for the
site. First responders would have an opportunity to discuss any resource or
training need during this consultation. DOT PHMSA and Coast Guard also
have training requirements of personnel involved in emergency response. We
also note that NFPA 59A (2001) was revised and issued in 2006, not 2003.

IND09-9 Section 4.12.5.6 of the EIS discusses how the Project would be
resilient against natural hazards such as geological, meteorological, and
hydrological events. Sea level rise has also been considered in the analysis. In
addition, the facility has been designed to withstand natural hazards (such as
earthquakes, hurricanes, and winds) based on mean return intervals in
accordance with federal regulations and best practices. Also see response to
comment IND09-013 for statement on recent hurricanes.
IND09-10 DOT PHMSA's LOD issued on March 20, 2019 evaluated the
Brownsville Ship Channel. In addition, we evaluated whether layers of
protection would be in place to reduce the risk of offsite impacts on the public
from hazards, including explosions. Based on the proposed layers of
protection, FERC staff recommendations, and DOT PHMSA’s LOD, we find
that the risk of potential impacts from explosions were sufficiently evaluated.

IND09-12 DOT FAA regulations cover safety of SpaceX launches and

consider wind conditions. In addition, the risk of a rocket launch failure
resulting in releases from the Project site that could impact the public is
extremely low given the low likelihood of debris that would result in large
releases and the distance between the public and the Project site. For debris to
impact the Project site, the direction of wind that would cause a failure at the
Project site would be in opposite direction from the public.

IND09-13 The proposed facility is designed to withstand a sustained wind

speed of 150 mph (183 mph 3-second sustained wind speed) which has an
approximately 30,500 year mean return interval and would be designed to
manage wave overtopping from a 500 year storm surge.
The equivalent return period for a storm event is specific to the spot or area
where the storm hit and should not be compared to the total number of 500-year
events that occur across the country. Hurricane Harvey caused 1000-year
precipitation and flooding in various areas of Texas; however, it made landfall
170 miles north of Brownsville. Other recent hurricanes such as Hurricanes
Florence, Irma, and Maria impacted the eastern coast of the United States.
Furthermore, the 65 to 70 inches of rainfall from Hurricane Harvey which

caused 1000-year floods in some places was the maximum observed rainfall in
an isolated area where the eye of the storm had hit (with the most intense
rainfall). The NOAA document in the comment also provides a figure that
shows total rainfalls drops significantly just 25 miles outside of where the eye
made landfall and the vast majority of coastal Texas affected by Harvey
experienced between 1 and 25 inches of rain.
IND09-14 See our response to comment CO10-81. Section 1.3 of the final
EIS has been updated to clarify that production, extraction, and end-use of
natural gas are not part of the proposed action evaluated in the EIS.

IND09-14a Potential impacts on lomas are described in several locations in

the EIS, and the discussion of lomas in the final EIS has also been updated in
response to comments on the draft EIS. With regard to mitigation for impacts
on lomas, see response to comments CO10-57 and CP10-58.
IND09-15 As stated in section 1 of the FERC Guidance Manual for

Environmental Report Preparation, the Guidance Manual is not a mandatory
document. Furthermore, the return period does not correspond to the number
of storms across the U.S or a region, but to a focused and refined area. For
example, the 10,000 year return periods from NUREG/CR 4461 are used to
evaluate tornado effects for an areas defined by 2 degrees in latitude and
longitude (approximately 139.4 miles by 139.4 miles or 19,044 square miles).
Also see response to comment IND09-013.

IND09-16 The ACTA studies (see response to comment CO10-073)

considered the entire Project site as well as specific areas within the Project site
to determine potential cascading effects. Also see response to comment
IND09-012 above. DOT PHMSA's LOD issued on March 20, 2019 evaluated
the overpressure or blast wave effects due to an explosion of flammable vapor.
Brownsville Ship Channel.

on lomas and their value as wildlife habitat, see response to comments CO10-
57 and CP10-58.

IND09-18 See response to comment ING09-17.

IND09-20 As described in section 4.4.1 of the EIS, the wetlands within the
Project site were identified in accordance with the COE Wetland Delineation
Manual and the Regional Supplement to the Corps of Engineers Wetland
Delineation Manual: Atlantic and Gulf Coastal Plain Region, and classified
according to the Classification of Wetlands and Deepwater Habitats in the
United States (Cowardin et al. 1979).
IND09-21 A standard condition contained in all FERC authorizations, and

recommended here, provides delegated authority to the Director of OEP, or the
Director’s designee, to take whatever steps are necessary to ensure the
protection of life, health, property, and the environment during construction and
operation of the terminal. This authority includes stop-work authority and
authority to cease operation. Annova proposes to implement the FERC's
Wetland and Waterbody Construction and Mitigation Procedures, as modified
for the Project-specific site, which we call in the EIS Annova's Procedures. See
section 2.5 and appendix B of the EIS. As indicated in the section 4.4 of the
EIS, only about one-third of the site contains wetlands.

IND09-22 See response to comments CO10-57 and CP10-58.
IND09-23 See response to comments CO10-57 and CP10-58.

IND09-24 Greenhouse gases and climate change are addressed in section

4.13.3.9 of the EIS. See also response to IND9-14.
IND09-25 Greenhouse gases and climate change are addressed in section

4.13.3.9 of the EIS. See also response to IND9-14.
IND09-26 Project cost, or risks to Project investors, is beyond the scope of

the EIS.
IND09-27 Cumulative impacts, including from construction of the 3

proposed LNG projects, is addressed in section 4.13 of the EIS.

IND09-28 The incident at the Chinese port in August 2015 did not involve
an LNG facility nor did it result in any known cascading consequence at the
nearby LNG facility. VCEs are further discussed in response the comment
IND09-010. Section 4.12.5.7 of the EIS addresses launch failures from the
SpaceX launch site.

the EIS.
IND09-31 The Commission will consider the analysis in this EIS, including
comments such as this one, as part of its determination of whether or not to
authorize the Project. With regard to construction of a wildlife corridor for
mitigation, see response to comment CO10-58.

IND09-32 As stated in section 3.1 of the EIS, wind and solar energy cannot
meet the purpose for the Project and are not considered or evaluated further in
the EIS. All comments on the project, including comments in support, are
considered in our EIS.
IND09-33 The potential impacts on air quality from the Project are
IND09-34 The potential impacts on the socioeconomics of the surrounding

communities from the Project are addressed in section 4.9 of the EIS. Section
4.9 of the final EIS has also been revised to include additional analysis of the
potential impact on the local shrimp industry. As stated in section 4.5.1.4 of
the EIS, the Annova Project would not remove any mangrove habitat.



IND10 Joyce Hamilton, page 1 of 1
IND10-1 Thank you for your comment. See our assessment of potential
Project impacts on vegetation, lomas, and wildlife in the respective sections of
the EIS.

IND11 Individual, page 1 of 1
IND11-1 Thank you for your comment

IND12 Brian Schill, page 1 of 1
IND12-1 Sections 2.8, 4.12.1, 4.12.3, and 4.12.4 of the EIS address security
of LNG vessels and the LNG facility. The security requirements for the
proposed Project are governed by 33 CFR 105, 33 CFR 127, and 49 CFR 193,
Subpart J – Security. 33 CFR 105, as authorized by the Maritime
Transportation Security Act, requires all terminal owners and operators to
submit a Facility Security Assessment and a Facility Security Plan to the Coast
Guard for review and approval before commencement of operations of the
proposed project facilities. Annova LNG would also be required to control and
restrict access, patrol and monitor the plant, detect unauthorized access, and
respond to security threats or breaches under 33 CFR 105.
IND12-2 Climate change is addressed in section 4.13.3.9 of the EIS.

the EIS.

IND13 Young, page 1 of 3
IND13-1 Because of this comment and other similar comments received on

the draft EIS, on March 15, 2019, we requested that Annova respond to these
concerns. In its response filed March 25, 2019 (see FERC docket accession
number 20190325-5179), Annova acknowledged that an expansion and design
changes to the Valley Crossing Pipeline system would be required to
accommodate the natural gas supply required for the Annova LNG Project.
Annova anticipates the design changes could include expansion of the Valley
Crossing receipt header system and addition of approximately 150,000 hp of
new compression. This information has been added to revised section 1.4.1 of
the final EIS.
IND13-3 Potential expansion of the Valley Crossing Pipeline and related

reliability and safety review is beyond the scope of this EIS.



IND14 Christin Rakestraw, page 1 of 2
IND14-2 The impact of the moving safety security zone on other vessels
would depend on variables such as the distance and direction of travel relative
to the LNG carrier. Therefore, the moving safety security zone would not shut
down the waterway to all vessels in all cases.
IND14-3 The potential impact on users of the Jaime Zapata Memorial Boat
Ramp is addressed in section 4.8.4.2 of the EIS under the heading Recreational
Fishing.
IND14-4 Because the BSC crosses the Lower Laguna Madre in an open
body of water, transit by LNG carriers, including the associated moving safety
and security zone, would primarily affect other deep draft vessels that must stay
within the navigation channel. There would be limited impact on small,
shallow draft vessels that normally operate outside of the defined navigation
channel. Section 4.8.4 of the final EIS has been revised to include additional
discussion of recreational boat traffic within the Lower Laguna Madre.

IND14-5 Comment noted. Potential impacts on recreation and tourism are

IND14-6 It is standard practice for an EIS to be completed prior to the

completion of all plans, and if a project is approved, for the Commission Order
to include a condition that construction may not proceed until after all
necessary plans and related agency consultations have been completed. This
practice is also upheld by the courts (see Grapevine v FAA). The public will
continue to have the opportunity to review and comment on filings as they are
made with the Commission.
IND14-7 As stated in section 5.2 of the EIS, recommendations in the EIS

are made by FERC staff who prepared the EIS, and if the Commission
authorizes the Project, they are measures that FERC staff recommends be
included as specific conditions in the Commission’s Order.

IND15 Diane Teter, page 1 of 2

on lomas, see response to comments CO10-57 and CP10-58.
IND15-5 We are not aware of evidence that specific vegetation types exist
on the site that were not identified in Annova's vegetation survey.
IND15-6 Annova has included proposed lighting design measures to

minimize contrast with the night sky in the landscape. These are discussed in
the EIS. It is standard practice that some plans, such as the Facility Lighting
Plan, are not prepared until projects advance into the final design phase. As
stated in section 4.6.1.1, we recommend that the Facility Lighting Plan be filed
prior to construction, and in section 4.6.1.2 we recommend that Annova consult
with the FWS during development of the plan. We will evaluate the Facility
Lighting Plan when it is filed, the public will also have the opportunity to
review and comment at that time.
IND15-7 As described in section 4.6.1.2, all land within the Project site is
under control of the Brownsville Navigation District. With regard to potential
mitigation for loss of wildlife habitat, see response to comment CO10-58.
IND15-8 See response to comments CO4-3 and CO4-4.
IND15-9 Section 4.3.2.2 of the EIS describes the potential impact on South
Bay, including seagrass beds, from sedimentation from Project dredging and
LNG carrier traffic during operation. Cumulative impacts, including from
operation of the 3 proposed LNG projects, are addressed in section 3.13.3.2,
3.13.3.3, and 3.13.3.4.

IND15-10 As stated in section 4.6.1.2 of the EIS, in the event that clearing
could not be accomplished during the stated time window, Annova proposes to
implement additional measures, as recommended by the FWS, designed to
avoid or minimize impacts on nesting birds, which would be acceptable.
IND15-11 On February 5, 2019, the National Marine Fisheries Service filed
comments with the FERC agreeing with the conclusions in the EFH
Assessment (see FERC accession number 20190206-5004.
IND15-12 The Courts have upheld the Commission practice of issuing a
conditioned Order (see Del. Riverkeeper Network v FERC). It is standard
practice for a Commission Order to include a condition that construction may
not proceed until all required consultations with federal agencies has been
completed. This practice is also upheld by the courts (see Grapevine v FAA).
The public will continue to have the opportunity to review and comment on
filings as they are made with the Commission.
IND15-13 As described in section 4.12.5.8, Annova would be required to
develop a comprehensive Emergency Response Plan (ERP), and Section 3A
(e) of the NGA (as amended by EPAct 2005) specifies that the ERP must
include a Cost-Sharing Plan that contains a description of any direct cost
reimbursements the applicant agrees to provide to any state and local agencies
with responsibility for security and safety at the LNG terminal and in proximity
to LNG marine facilities. The cost-sharing plan must include the LNG
terminal operator’s letter of commitment with agency acknowledgement for
each state and local agency designated to receive resources.
IND15-14 As described in section 4.11.1.2 of the EIS, the NAAQS, primary
standards set limits the EPA determined would protect human health including
sensitive populations such as children, the elderly, and asthmatics
IND15-15 Section 4.12.5.7 of the EIS includes an evaluation of potential
impacts on the Annova Project from external events, including incidents at the
proposed Rio Grande LNG and Texas LNG facilities.
impacts on the Annova Project from external events, including a launch failure
at the SpaceX facility.

IND16 Patrick Anderson, page 1 of 17
IND16-3 On February 7, 2019, FERC extended the comment period on the

Draft EIS until March 13, 2019, as a result of the partial Federal government
shutdown.
IND16-4 We disagree that the draft EIS was incomplete because of its non-
availability in Spanish. See also response to comment CO6-3.
IND16-5 Comment noted. The EIS addresses the potential impacts of the
Annova Project on the resources listed and addresses the potential cumulative
impacts of the Annova Project combined with the TX LNG and Rio Grande
LNG projects. The Commission will consider these potential impacts in its
decision whether or not to authorize (permit) the Annova Project.

IND16-6 See response to comments IND13-1 and IND13-2.

IND16-9 The design, construction, and operating requirements for the

Project are contained in 33 CFR 103 through 105, 33 CFR 127, and 49 CFR
193. In addition, Annova must meet the DOT PHMSA's siting regulations in
49 CFR 193. These regulations do not require the use of SIGTTO publications.
However, certain design criteria described as recommendations in SIGTTO
Information Paper No. 14, Site Selection and Design for LNG Ports and Jetties,
(i.e., strength/positions of mooring systems and breasting dolphins; interlinking
of ship and shore ESD systems; installing quick acting valves at the PERC
connections; using sensors to monitor the positions of the LNG loading arms;
limiting ignition sources on the jetty; use of tugs and pilots to safely maneuver
the LNG marine vessel to the jetty, etc.) are considered during the Coast Guard
and FERC’s evaluation of the Project. In addition, as indicated in section
4.12.5.2 of the EIS, FERC staff conducted a engineering review on the use of
various layers of protection or safeguards to reduce risks of potential hazards to
off-site public. We also reviewed potential impacts from natural hazards and
external impacts from the surrounding areas.



IND16-16 Annova's application to FERC does not include a pipeline.

Potential impacts on wetlands from the supply lateral pipeline is under the
jurisdiction of the COE.
IND16-17 See response to comments IND9-14a and IND15-1.
IND16-19 It is acknowledged that the Annova Project would permanently

impact wetlands and lomas. This is disclosed in the EIS. Cumulative impacts
on wetlands, lomas, and rare species, including from construction of the 3

IND16-20 See response to comment IND16-19. With regard to mitigation

for impacts on lomas, see response to comments IND14-a and IND15-1.




IND16-25 Cumulative impacts, including from construction of the 3

IND16-26 Comments on the referenced COE public notice and permit

application will be addressed by the COE. Potential impacts from the Annova
Project on historic resources are addressed in section 4.10 of the EIS, and
cumulative effects on cultural and historic resources are addressed in section
4.13.3.8.

IND16-27 see response to comment CO10-57.
IND16-28 See response to comments CO10-57 and CO10-58. The

Commission will take into account the potential impacts on these resources
when considering whether or not to authorize the Annova Project.

IND16-30 As stated in section 4.7.3 of the EIS, consultation under the

Endangered Species Act is ongoing. See also response to comment CO10-65.
IND16-31 The Commission will take into account the potential impacts on
these resources when considering whether or not to authorize the Annova
Project.
IND16-32 The Commission will take into account project need when
considering whether or not to authorize the Annova Project.
IND16-33 We disagree the socioeconomic analysis in section 4.9 of the draft

EIS is narrow in view and incomplete. With regard to cost of public safety and
security, see response to comment IND15-13.


IND16-35 In response to this and other similar comments on the draft EIS,
section 4.9.2.3 of the final EIS has added to include a discussion of the
potential Project impacts on the various conservation initiatives in the Rio
Grande Valley.
IND16-36 See response to previous comment IND16-35.

IND16-38 Cumulative impacts on air quality, including from the 3 proposed

LNG projects, is addressed in section 4.13.3.9 of the EIS.
IND16-39 The contribution of the Annova Project to impacts on the

resources listed are addressed in the respective sections of the EIS. The
Commission will take into account the potential impacts on these resources
when considering whether or not to authorize the Annova Project.

IND16-40 Comment noted.
IND16-42 A finding of significant impact is not in itself reason for denial of

a project.

IND17 Sarah Simpson, page 1 of 1
This form letter or a nearly identical letter was also received from the
following, which are not repeated here in this appendix:
Sanders (IND76), French (IND112), Arcand (IND113), FM (IND116), Nelson

(IND152), Noriega (IND155), Neeley (IND157), Dieter (IND158), Garza (INC159),
Sinclair (IND160), Manske (IND162), Goodman (IND163), Swearingen (IND165),
Demarais (IND168), Collins (IND169), Williams (IND171), Guh (IND174), Wierenga
(IND175), Jordan (IND176), Moczygemba (IND182), Hines (IND184), Beltran
(IND186), Page (IND187), Carey (IND188), Shephard (IND190), Foreman (IND192),
Powe (IND193), Unger (IND194), Traietti (IND195), Dixon (IND196), Hopson
(IND197), Tanski (IND200), Myones (IND201), Telfair (IND202), Mulcihy (IND205),
McIntosh (IND206), Oflaherty (IND207), Nongbri (IND208), Rives (IND212), Lyall
(IND213), Rowland (IND214), Tatum (IND215), Rojas (IND218), Bush (IND220), Hall
(IND222), Cantu (IND226), Wasserman (IND229), Wash (IND230), Garcia (IND231),
Parker (IND233), Klugiewicz (IND234), Wiley (IND235), Navarro (IND240), Erdmann
(IND242), Garcia (IND245), Huddleston (IND246), Shields (IND247) Gilath (IND248),
Rivas (IND249), Bacon (IND252), Sulak (IND253), Mathre (IND256), Martin
(IND308), Dingley (IND250), Holt et al (IND360), Russell (IND362), Adams
(IND363), Mcvey (IND369), Smith (IND415), Dunlap (IND903)
IND17-1 Thank you for your comment. See the EIS for our assessment of
potential impacts on communities and the local environment.
IND17-2 Thank you for your comment. Based on surveys completed and
consultation with the Texas Historical Commission, the Annova Project would
not destroy any known indigenous cultural sites. See section 4.10 of the EIS.
Potential impact on local industries is evaluated in section 4.9 of the EIS.
IND17-4 Production, extraction, and end-use of natural gas, including from

fracking, are not part of the scope of the EIS. NEPA review of the Project is
limited to the socioeconomic and environmental impacts of the proposal before
the Commission; therefore, the effects of production and end-use are outside of
the scope of this EIS. Section 1.3 of the final EIS has been updated to clarify.
See also response to comment IND9-14.

IND18 Donald Hockaday, page 1 of 1

IND19 Christine Rakestraw, page 1 of 2
IND19-1 Further discussion or reference to the Laguna Madre has been

added to sections 4.3.2, 4.8.4, 4.8.5, and 4.9 of the final EIS.
IND19-2 Section 4.8.4 of the final EIS has been revised to include
additional discussion of water-based recreation within the Laguna Madre.

IND19-4 Project-related impacts on the Lower Laguna Madre would

generally be limited to LNG vessel traffic within the existing navigation
channel/BSC, where the channel passes along the very bottom of the Laguna
Madre after passing through the Brazos Santiago Pass. However, based on this
and similar comments additional discussion has been added to the final EIS.
IND19-5 Thank you for your comment. Section 4.8.4.2 of the final EIS has
been revised to note that the boat ramp in Arroyo is in Cameron County.
IND19-6 Comment noted. On February 7, 2019 FERC extended the

comment period on the draft EIS until March 13, 2019.

IND20 Barbara Hegarty, page 1 of 3
This form letter or a nearly identical letter was also received from the following
individuals, which are not reproduced in this appendix:
Osborne (IND24), Fetonte (IND25), Sjodin-Bunse (IND27), Hyde (IND29), Penny (IND32), Carpenter (IND34),
Tharp (IND35), Gay (IND36), Wright (IND37), Gagble (IND38), Villamizar (IND39), Garrett (IND42), Velez
(IND43), Cohen (IND49), Killelea (IND50), Salinas (IND52), Perez (IND53), Hamilton (IND57). Holleschau
(IND58), Schaffer (IND61), Mason (IND62), Hanks (IND63), Chavez (IND69), Maggs (IND75), A Gonzalez
(IND1054), Acevedo (IND1055), Anderson (IND1057), Anzaldua (IND1058), Bloom (IND1061), Brown
(IND1062), Celedon (IND1066), Cornejo (IND1068), DeLaGarza Und Senkel (IND1070), Galarza (IND1079),
Garcia (IND1081), Gardner (IND1082), Goette (IND1083), Guerra (IND1085), Goette (IND1087), Herrera
(IND1089), J Martinez (IND1093), Leekwijck (IND1096), M Hollmann (IND1097), Martinez (IND1099),
Meinerding (IND1101), Mendieta (IND1102), Salinas (IND1112), Thurston (IND1116), Watts (IND1118),
Williams (IND1142), Nieland (IND1143), Goette (IND1146), Goble (IND1148), Wittington (IND1150),
Summers (IND1151), Herbig (IND1152), Salinas (IND1154), Cornejo (IND1160), Anderson (IND1165),
Gonzalez (IND1166), Sheats (IND1167), Senkel (IND1169), Garcia (IND1171), Lara (IND1173), Hoenes
(IND1177)
IND20-1 See responses to individual comments below.

IND20-2 We disagree that all plans and information must be available during
preparation of the draft EIS. Information filed by Annova during the draft EIS
comment period is available to the public for review after filing with FERC. On
February 7, 2019, FERC extended the comment period on the draft EIS until March
13, 2019, as a result of the partial Federal government shutdown.
IND20-3 We disagree that the draft EIS is incomplete because of its non-
availability in Spanish. See also response to comment CO6-3.
IND20-4 The need for the project will be evaluated by the Commission when
determining whether to authorize the Project.
IND20-5 As described in section 4.12.5.8 of the EIS, Annova would be
required to develop a comprehensive Emergency Response Plan (ERP), and Section
3A (e) of the NGA (as amended by EPAct 2005) specifies that the ERP must
include a Cost-Sharing Plan that contains a description of any direct cost
reimbursements the applicant agrees to provide to any state and local agencies with
responsibility for security and safety at the LNG terminal and in proximity to LNG
marine facilities. The cost-sharing plan must include the LNG terminal operator’s
letter of commitment with agency acknowledgement for each state and local agency
designated to receive resources. The potential contribution of the Annova Project
on climate change is evaluated in section 4.13.3.9 of the EIS. It is beyond the scope
of this EIS to evaluate the micro and macro costs of climate change in general.
IND20-6 We disagree that the cultural resource surveys were inadequate. The
survey protocol and results have been reviewed by the Texas Historical
Commission. The reference to the number of shovel tests in the EIS is specific to
just a small portion of the site that was surveyed and was not the total number of
shovel tests conducted for the Project.


impacts on the Annova Project from external events, including incidents at the
proposed Rio Grande LNG and Texas LNG facilities.
IND20-8 See response to comment CO10-75 and CO10-73.
IND20-9 See response to comment IND13-1 and IND13-2.


IND21 Don Hockaday, page 1 of 9
IND21-1 The Commission must evaluate each individual application as

proposed and prepare the appropriate NEPA document. Within the cumulative
impacts analysis in the EIS, the effects of all relevant projects on each resource
is considered and disclosed. Reformatting the discussion would not impact the
conclusion. The Commission will take into account the analysis in each EIS,
including the cumulative impact assessment, when it considers whether or not
to authorize each project.

IND21-3 CEQ directs agencies to reduce paperwork and the accumulation

of extraneous background data. Conclusions contained in the EIS are based
upon much additional information that is on the public record and the FERC
project docket, as referenced in the EIS. Conclusions are also based upon the
extensive experience of staff who have prepared numerous impact statements
describing gas infrastructure projects and, importantly, have conducted
compliance reviews of gas infrastructure projects that were constructed. With
regard to plans that are not yet finalized, see response to comment IND14-6.
IND21-4 See response to comment IND02-3. Port Mansfield was

eliminated from further analysis due to the extensive amount of dredging that
would be required and the environmental impacts within the Laguna Madre that
would be associated with that dredging. Section 3.4 of the final EIS has been
revised to clarify.
IND21-5 See response to comments IND21-6 through IND21-10.

IND21-6 The potential impact on bait shrimping is addressed in section 4.9,

however additional analysis has been added to the final EIS.
IND21-7 The potential threat of terrorism is addressed in the discussion of

LNG terminal and marine facilities security in several locations within section
4.12 of the EIS. See also response to comments IND12-1, and IND21-5.
IND21-8 The potential impact on the existing economy of the region,

including fishing and tourism, is addressed in section 4.8 and 4.9 of the EIS.
Additional description of the recreation-based industry of the Laguna Madre
has also been added to the final EIS.
IND21-9 Construction of the Annova Project, as well as the Rio Grande

LNG and TX LNG projects, would result in eliminating public access to the
BSC shorelines within each facility. With the exception of the shoreline within
the LNG terminal facilities themselves, no restrictions are anticipated on
recreational fishing or other shoreline activities along the BSC or along beaches
or jetties that would be passed by LNG carriers.
IND21-10 See response to comments IND12-1, and IND21-5.

IND21-11 Potential impacts on the bait shrimping industry that uses the BSC
are discussed in section 4.9.2.4 of the EIS. As noted in the section, TPWD
provided information about bait shrimping in the area (i.e., Fisher, 2015, 2017).
We issued an EIR to Annova on March 15, 2019, requesting additional
information regarding potential impacts on the Brownsville-based shrimp
industry from proposed LNG vessels transiting the BSC. The information
request asked that Annova provide a discussion of mitigation measures to
reduce the potential direct impacts of Project-related LNG vessel traffic on the
Brownsville-based shrimp industry. The request also asked if Annova would
commit to funding a study of the cumulative impact of LNG vessels from all
three proposed LNG terminals on the Brownsville-based shrimp industry. See
information filed by Annova in response to our EIR, on the FERC docket under
accession number 20190325-5179.


impact on water quality from LNG vessel transit within the BSC, including
from shoreline erosion from vessel wakes and propeller wash, and from
resuspension of bottom sediments from propeller wash during transit of fully
loaded, outbound LNG carriers. Section 4.3.2.2 in the final EIS has also been
updated to note that the BSC was specifically created to provide deep water
access for maritime commerce, and as such, use of the waterway by LNG
carriers would be consistent with the planned purpose and use of the BSC.
In section 4.13.3.2 we address potential cumulative impacts on surface water,

and as stated in that section, given the substantial increase in large vessel traffic
within the BSC related to the three Brownsville LNG projects, and other
projects, it is expected that cumulative impacts on surface water resources
associated with shoreline erosion and turbidity from increased vessel traffic
would be persistent and moderate to significant throughout the life of the
projects, particularly along unarmored portions of the BSC.

IND21-13 In response to this comment, population information for the city

of Port Isabel, the town of Laguna Vista, and Long Island Village has been
added to section 4.9.1 of the final EIS.
IND21-14 The contribution of recreation and tourism to the regional

economy is discussed in section 4.9.2.2. As noted in section 4.9.1, the Rio
Grande Valley is home to a large seasonal winter population of retirees
temporarily relocating to the area. Impacts on existing recreational resources
are assessed in section 4.8.4.2. Construction and operation of the Project would
result in site-specific impacts on recreation and visitor use during construction
and operation. As discussed in section 4.9.2.2, these site-specific impacts are
not expected to affect overall regional tourism patterns, but could result in
localized impacts, with visitors and other recreationists seeking similar
opportunities nearby or elsewhere in the region.


IND21-15 As discussed in section 4.8.4.2, construction and operation of the

Project would not permanently affect access to the majority of regional fishing
locations in the waters in the vicinity of the Project site, including the estuarine
waters of Cameron and Willacy counties and the offshore Gulf of Mexico.
Project construction and operation may, however, as discussed, temporarily
affect access to recreational fishing and boating activities along the BSC,
including the Jaime J. Zapata Memorial Boat Ramp Fishing Pier and Kayak
Launch Area. As described in the EIS, the Project site has been used in the past
as an informal fishing location, boat launch, and BSC access point for anglers.
Public access to the site is presently blocked, following a request from the U.S.
Border Patrol, and would continue to be blocked during Project construction
and operation.
IND21-16 We do not agree that a separate study by the Department of

Homeland Security is required. See also response to comment IND12-1.
IND21-17 We are not aware of any consultation with TXPWD with regard to
changes in regulations related to bait shrimping should the Annova Project, or
the other two LNG projects, be approved, or of a funded study of potential
impact on the bait shrimp industry. However, in response to this and similar
comments on the draft EIS, we issued an EIR to Annova on March 15, 2019,
asking if Annova would commit to funding a study of the cumulative impact of
LNG vessels from all three proposed LNG terminals on the Brownsville-based
shrimp industry. See information filed by Annova in response to our EIR, on
the FERC docket under accession number 20190325-5179.

IND21-18 The FERC has not required such a study, nor are we aware that
such a study has been completed.
IND21-20 Environmental justice is adequately addressed in section 4.9.9 of

the EIS. See also response to comment IND21-9.
IND21-21 Thank you for your comment. See responses to the individual
comments above.

IND22 John Young, page 1 of 4
IND22-1 As stated in section 1.4.1 of the EIS, the natural gas supply
pipeline is a FERC non-jurisdictional facility. The application to the COE did
not change that status.
IND22-2 Thank you for your comment. As noted, this comment is directed
to the COE.
to the COE.
to the COE.
to the COE.
to the COE.

IND22-7 As noted in the draft EIS, the EIS was prepared by FERC staff,
and statements and conclusions in the EIS represent the FERC's analysis unless
specifically attributed to Annova.
IND22-9 This comment does not reference a specific plan, measure, or

mitigation so it is not possible to provide a direct response.

IND22-10 The EIS represents FERC staff’s independent review of the

proposed Project. The review was conducted by an experienced
interdisciplinary team that, as demonstrated by the issuance of hundreds of
requests for additional data, performed its due diligence in vetting all
information provided by the applicant. If the Commission authorizes the
Project, Annova would be required to comply with all conditions of that
authorization.


IND23 Joyce Hamilton, page 1 of 2
IND23-1 Thank you for your comment. We assess the impact on lomas and
related impact on ocelots in several sections of the EIS, including sections 4.5,
4.6, and 4.7. See also responses to comments IND9-14a and IND15-1.


IND30 Elyas Browning, page 1 of 2
IND30-2 Thank you for your comment. Short and long-term environmental
impacts are addressed in the EIS. There is no FERC-jurisdictional pipeline
associated with the Annova Project and addressed in the EIS.


IND31 Victoria Hendricks, page 1 of 2


IND45 David Fisher, page 1 of 3



IND46 Elizabeth Pearl, page 1 of 3



IND47 Ester Ybarra, page 1 of 3



IND48 Gordon Watt, page 1 of 3
IND48-2 Thank you for your comment. The EIS is FERC staff's evaluation
of the potential environmental and socioeconomic impacts of the Annova
Project.



IND51 John Keller, page 1 of 3
IND51-1 Section 4.10.1.1 of the EIS summarizes the results of the

archaeological survey, including review and comment by the SHPO (Texas
Historical Commission). FERC staff have also reviewed the methodology and
results of archaeological surveys and find them to be in accordance with
standard protocols. The reference to the number of shovel tests in the EIS is
specific to just a small portion of the site that was surveyed and was not the
total number of shovel tests conducted for the Project.
IND51-2 Thank you for your comment. Annova's permit application is

under review by FERC, and this EIS represents the NEPA analysis of potential
impacts.



IND55 Kent Wittenburg, page 1 of 3



IND56 Laura Germany, page 1 of 3



IND59 Lessie Spindle, page 1 of 3



IND60 Linda Cooke, page 1 of 3
IND60-1 The potential impact on ocelots is evaluated in section 4.7.1.2 of

the EIS. FERC staff is not aware of any environmental studies that have been
waived. The status of environmental permits and agency consultations is
summarized in section 1.5 of the EIS in table 1.5-1.



IND64 Michele Cole, page 1 of 3



IND65 Mimi Calter, page 1 of 3



IND66 Muhammad Rashid, page 1 of 3
IND66-1 The potential impact on wildlife is evaluated in section 4.6 and

ocelots in section 4.7.1.2 of the EIS. As stated in section 3.1 of the EIS, solar,
wind, or other renewable energy project cannot meet the purpose for the Project
and are not considered or evaluated as alternatives.



IND67 Ned Sheats, page 1 of 3
IND67-1 Thank you for your comment. With respect to Project need, see
IND67-2 The potential impact from pipelines or other transport facilities

that are not part of the proposed Annova LNG Project are evaluated in the
cumulative impacts assessment in section 4.13 of the EIS.



IND68 Rachael Brown, page 1 of 3
IND68-1 With respect to the analysis of potential risk associated with the
SpaceX facility, see response to comment CO10-73. The intrinsic value of the
environment that would be affected by the proposed Project is considered
throughout the EIS. With respect to need, see response to comment CO6-20.



IND70 Sarah Simpson, page 1 of 3
IND70-1 As stated in section 3.1 of the EIS, solar, wind, or other renewable



IND71 Scott Nicol, page 1 of 3
IND71-1 The estimated air emissions and ambient air quality modeling
analysis from the Annova Project are addressed in section 4.11.1 of the EIS.



IND72 Terence Garrett, page 1 of 3



IND73 Thomas Nieland, page 1 of 3



IND74 Victoria Scharen, page 1 of 3



IND77 Carol Creech, page 1 of 1
IND77-1 With regard to fracking, see response to comment IND9-14.

IND78 Nanette Gordon, page 1 of 1

IND79 Stanley Wright, page 1 of 1


IND81 Kathleen Kinzler, page 1 of 1
IND81-1 With regard to fracking, see response to comment IND9-14. As

stated in section 3.1 of the EIS, solar, wind, or other renewable energy project
cannot meet the purpose for the Project and are not considered or evaluated as
alternatives.

IND83 William Larowe, page 1 of 1

IND84 David Larsen, page 1 of 1

IND85 Olivia Brown, page 1 of 1

IND86 Kathryn Cain, page 1 of 1

IND87 Stuart Crane, page 1 of 1
IND87-1 Comment noted. Estimated air quality impacts from the Annova
Project is addressed in section 4.11.1 and cumulative air quality impact is
addressed in section 4.13.3.9.

IND88 Anna George, page 1 of 1

IND89 Thomas Garcia, page 1 of 1
IND89-1 Comment noted. Estimated air quality impacts from the Annova
Project is addressed in section 4.11.1 and cumulative air quality impact is
addressed in section 4.13.3.9.

IND90 Terry Burns, page 1 of 1
IND90-1 Thank you for your comment. Discussion of GHG and climate
change can be found in section 4.13.3.9.

IND91 Emily Garza, page 1 of 1

IND92 Juli Kring, page 1 of 1

IND93 Zeoma Olszewski, page 1 of 1
IND93-1 With regard to fracking, see response to comment IND9-14.

Discussion of GHG and climate change can be found in section 4.13.3.9.

IND94 Melinda Fritsch, page 1 of 1

IND95 Ashley Jones, page 1 of 1

IND96 Betty Mcdugald, page 1 of 1

IND97 Linda Charlton, page 1 of 1

IND98 Ruth Keitz, page 1 of 1
IND98-1 Thank you for your comment. See assessment of potential

impacts from the Annova Project on ecology in sections 4.4 through 4.7, and
tourism and fishing in sections 4.8 and 4.9 of the EIS.

IND99 Christian Rodriguez, page 1 of 1

alternatives.

IND100 Brandy Gibbs, page 1 of 1

IND101 Adriana Gonzaelz, page 1 of 1

IND102 Roberto Alvarado, page 1 of 1

IND103 Greg Grubb, page 1 of 1

IND104 Doug Simmer, page 1 of 1

IND105 Beth Ann Sikes, page 1 of 1

IND106 Natalie Martens, page 1 of 1
IND106-1 Thank you for your comment. Note that the Annova Project does
not include a FERC-jurisdictional pipeline.

IND107 Megan O’Connell, page 1 of 1
IND107-1 The Annova LNG Project does not include extraction activities.

IND108 Samuel Bozeman, page 1 of 1

IND109 Pam Sohan, page 1 of 1
IND109-1 Thank you for your comment. Note that the Annova Project does
not include a FERC-jurisdictional pipeline.

IND110 Patricia Stella, page 1 of 1
IND110-1 The Annova LNG Project does not include fracking. See also

IND111 Carolynn Snyder, page 1 of 1
IND111-1 Thank you for your comment. See the respective sections of the
EIS for our assessment of potential impacts of the Annova Project, as well as
cumulative impacts from the three proposed LNG projects, on local
communities, cultural resources, and local industries.
IND111-3 Comment noted. We have addressed potential impacts on the

local communities in the EIS. With regard to fracking, see response to
comment IND9-14.
IND111-4 The proposed Annova LNG Project does not include a FERC-
jurisdictional pipeline. See section 1.4.1 and 4.13 for our assessment of
potential impact from the non-jurisdictional natural gas supply pipeline.
IND111-5 Thank you for your comment. The Annova LNG Project does not
include fracking. See also response to comment IND9-14.

IND114 David Will, page 1 of 1

IND115 Gary Hild, page 1 of 1
include fracking. See also response to comment IND9-14. With regard to
renewable energy, as stated in section 3.1 of the EIS, solar, wind, or other
renewable energy project cannot meet the purpose for the Project and are not
considered or evaluated as alternatives.

IND117 Jed Mccuistion, page 1 of 1

IND118 Walter Breymann, page 1 of 1
include fracking. See also response to comment IND9-14. With regard to
renewable energy, as stated in section 3.1 of the EIS, solar, wind, or other

IND119 Nelda Salinas, page 1 of 1

IND120 Marta Diaz, page 1 of 1

IND121 Anita Cannata-Nowell, page 1 of 1

IND122 Allison Zborowski, page 1 of 1

IND123 Mary Miller, page 1 of 1

IND124 Deirdre Ohearn, page 1 of 1

IND125 Marj Sears, page 1 of 1

IND126 Derek Eckert, page 1 of 1

IND128 Barbara & Roby Odom, page 1 of 1

IND130 Luiz Zepeda, page 1 of 1

IND131 Rick Provencio, page 1 of 1

IND132 Veronica Perez, page 1 of 1

IND133 Johnny Whitright, page 1 of 1

IND134 Tracey Bonner, page 1 of 1

IND135 Susan Cooper, page 1 of 1

IND136 Margaret Tatum, page 1 of 1

IND137 Carol Creech, page 1 of 1

IND138 Jerry Mylius, page 1 of 1

IND139 J. Wells, page 1 of 1

IND140 Eunice Garza, page 1 of 1

IND141 Marianne & Stefan Vogt, page 1 of 1

IND142 Austin Gray, page 1 of 1
IND142-1 Thank you for your comment. The proposed Annova LNG Project
does not include fracking.

IND143 Chris Nicolosi, page 1 of 1
IND143-1 Thank you for your comment. We disagree that the draft EIS for the
Annova LNG project was inadequate. However, we have made a number of
updates and added additional information in the final EIS in direct response to
comments received on the draft EIS.

IND144 Payten Maness, page 1 of 1
IND144-1 The Annova LNG Project does not include fracking. With respect
to use of wind power, as stated in section 3.1 of the EIS, wind or other

IND145 Robert Perry, page 1 of 1
IND145-1 As stated in section 3.1 of the EIS, wind or other renewable energy
project cannot meet the purpose for the Project and are not considered or
evaluated as alternatives. The potential environmental impacts, human health,
and habitat loss from construction and operation of the Annova LNG Project
are addressed in the EIS.

IND146 Neal Baron, page 1 of 1
IND146-1 The proposed Annova LNG Project does not include fracking.

IND147 Richard Walsh, page 1 of 1
IND147-1 We disagree that impacts are not well enough revealed in the EIS,
and without providing specifics it’s not possible to respond further. However,
we have made a number of updates and added additional information in the
final EIS in direct response to comments received on the draft EIS.

IND148 Guadalupe Yanez, page 1 of 1

IND149 Diane Adams, page 1 of 1

IND150 Pam Sonnen, page 1 of 1

IND151 Charles Spencer, page 1 of 1

IND153 John Willis, page 1 of 1
IND153-1 Discussion of GHG and climate change can be found in section

4.13.3.9..

IND154 Sandra Lira, page 1 of 1
IND154-1 Thank you for your comment. The potential impact of the proposed
Annova LNG Project on the local environment and communities is assessed in
the EIS.

IND156 Juan Tejada, page 1 of 1
IND156-1 Thank you for your comment. See the EIS for our evaluation of the
potential impact of the Annova LNG Project on humans and the environment.

IND161 Joan Cunningham, page 1 of 1
IND161-1 As stated in section 3.1 of the EIS, solar, wind or other renewable
or evaluated as alternatives. Discussion of GHG and climate change can be
found in section 4.13.3.9.

IND164 Danielle Ivie, page 1 of 1

IND166 Joy De Souza, page 1 of 1
IND166-1 An evaluation of using existing LNG terminals as an alternative to

the proposed Project is included in section 3.3 of the EIS.

IND167 Mary Cartwright, page 1 of 1
IND167-1 The potential impact of the Project on sea turtles and other
endangered species is included in section 4.7 of the EIS.

IND170 Archana Purushotham, page 1 of 1

IND172 George Duncan, page 1 of 1

IND173 Neala Johnson, page 1 of 1

IND177 Mary Tietjen, page 1 of 1
IND177-1 The proposed Annova LNG Project does not include fracking. As
stated in section 3.1 of the EIS, solar, wind or other renewable energy project
alternatives. Discussion of GHG and climate change can be found in section
4.13.3.9.

IND178 Bianca Acosta, page 1 of 1
IND178-1 The potential impacts on scenery and visual resources is evaluated

in section 4.8.5 of the EIS.
IND178-2 The potential impact on recreational fishing is evaluated in section

4.8.3 of the EIS.

IND179 Gabriela Trevino, page 1 of 1
IND179-1 The EIS evaluates potential environmental hazards that would result
from construction and operation of the Project.

IND180 Susan Cooper, page 1 of 1

IND181 Debra Johnson, page 1 of 1

IND183 Amanda Kay, page 1 of 1

IND185 Cristela Sifuentez, page 1 of 1

IND189 Catherine Pleasants, page 1 of 1

IND191 John Rath, page 1 of 1
or evaluated as alternatives. Discussion of GHG and climate change can be
found in section 4.13.3.9.

IND198 Amanda Mahfood, page 1 of 1

IND199 David Carter, page 1 of 1

IND203 Marta Hubbard, page 1 of 1

IND204 William Hoenes, page 1 of 1

IND209 Catherine Milbourn, page 1 of 1

IND210 Carolyn Nieland, page 1 of 1
IND210-1 The potential impact of the Project on tourism, including South

Padre Island, Port Isabel, and Laguna Vista, is evaluated in sections 4.8 and 4.9
of the EIS.

IND211 Tom Nieland, page 1 of 1
IND211-1 The potential impact of the Project on tourism is evaluated in


IND216 Rebecca Sims, page 1 of 1

IND217 Delaina Foster, page 1 of 1
IND217-1 The potential impact on the regional shrimping industry is addressed

in section 4.9.2.3 of the EIS. We have also updated the final EIS to include
additional information on this topic since issuance of the draft EIS.

IND219 Maria Reya-Gomez, page 1 of 1
IND219-1 The potential impacts of the Annova LNG Project on the local
communities and on the environment and wildlife habitats is evaluated in
several sections of the EIS.

IND221 Virginia Downing, page 1 of 1

IND223 Santiago Gomez, page 1 of 1
impact on air quality in section 4.11.1 of the EIS.

IND224 Maria Anna Esparza, page 1 of 1

IND225 Michael Chavez, page 1 of 1

IND227 Rick Cruz, page 1 of 1

IND228 Becky Wharton, page 1 of 1

IND232 Chia Guillory, page 1 of 1
IND232-1 Thank you for your comment. See section 4.6 for our evaluation of
potential impact on wildlife from the proposed Annova LNG Project.

IND236 Noe Acevedo, page 1 of 1

IND237 Delysia Moore, page 1 of 1
IND237-1 Thank you for your comment. Discussion of GHG and climate

IND238 Alfonso Saldana, page 1 of 1

IND239 Laurie Ward, page 1 of 1

IND241 Cheryl Smith, page 1 of 1
does not include a pipeline.

IND243 Ken Dixon, page 1 of 1
IND243-1 Thank you for your comment. See our assessment of impact on
wildlife and wildlife habitat in sections 4.6 and 4.7 of the EIS.

IND244 John Hanson, page 1 of 1

IND250 Karli Scalise, page 1 of 1
IND250-1 Thank you for your comment. Section 4.12 of the EIS evaluates the
safety and reliability of the proposed Project.

IND251 Robin Sherwin, page 1 of 1

IND254 Michael Peterson, page 1 of 1

IND255 Ingrid Hansen, page 1 of 1

IND257 Laura Codina, page 1 of 1

IND258 Eleanor Raybold, page 1 of 1

IND259 Denis Tidrick, page 1 of 1
IND259-1 Because of the reference to an increase in seismic activity we

assume this comment is referring to the practice of fracking. The proposed
Annova LNG Project does not include fracking.

IND260 Karen Hill, page 1 of 1
IND260-1 Thank you for your comment. Potential impact on migratory birds
is addressed in section 4.6.1.2 of the EIS.

IND261 Shelley Dunham, page 1 of 1

IND262 Frances Morgan, page 1 of 1

IND263 Craig Parker, page 1 of 1

IND264 Martha Eberle, page 1 of 1

IND265 Isys Chamberlain, page 1 of 1

IND266 Tresa Colston, page 1 of 1

IND267 Andrew Hernandez, page 1 of 1

IND268 Beverly Walker, page 1 of 1

IND269 James Flanagan, page 1 of 1
IND269-1 Thank you for your comment. The potential impacts from the
Annova LNG Project on air, water, and land are addressed in the EIS.

IND270 Thomas Nicolazzo, page 1 of 1
IND270-1 Thank you for your comment. As stated in section 3.1 of the EIS,
solar, wind or other renewable energy project cannot meet the purpose for the
Project and are not considered or evaluated as alternatives.

IND271 Cindy Arellano, page 1 of 1

IND272 Omar Elizondo, page 1 of 1
IND272-1 The potential impacts on commercial and recreational fishing, and

the Laguna Madre, are addressed in the EIS.

IND273 Camilla Figueroa, page 1 of 1

IND274 Regina Stanley, page 1 of 1

IND275 Linda Hahus, page 1 of 1

IND276 Naomi Dove, page 1 of 1

IND277 Yvonne Hansen, page 1 of 1
IND277-1 The proposed Annova LNG Project does not include fracking, oil
drilling, or a pipeline.

IND278 Dawn Langerock, page 1 of 1
IND278-1 Based on surveys and information known to date, including

consultation with the Texas Historical Commission, the Annova LNG Project
would not impact any known indigenous cultural sites. See further detail in
section 4.10 of the EIS. The proposed Annova LNG Project does not include
fracking or pipelines. With respect to fracking and pipelines in the Eagle Ford
and Permian Basin regions, see response to comment IND9-14.

IND279 Jeff Tave, page 1 of 1

IND280 Renee Reeves, page 1 of 1

IND281 John Nelson, page 1 of 1
IND281-1 Thank you for your comment. See the EIS for an assessment of the
potential impacts of the Annova LNG Project on the environment and the
region.

IND282 Lily Beaumont, page 1 of 1

IND283 Steve Bradley, page 1 of 1
IND283-1 The Annova LNG Project does not include fracking. As stated in
section 3.1 of the EIS, solar, wind or other renewable energy project cannot
meet the purpose for the Project and are not considered or evaluated as
alternatives.

IND284 Steven Reilly, page 1 of 1
is not proposed in South Padre Island.

IND285 Jean Finch, page 1 of 1
IND285-1 The proposed Annova LNG project does not include planned
fracking.

IND286 Jennifer Prevost, page 1 of 1

IND287 Spike Werda, page 1 of 1

IND290 Abbas Aboohamidi, page 1 of 1

IND291 Phyllis Price, page 1 of 1

IND292 Audrey H, page 1 of 1
IND292-1 The potential impacts on wildlife, including the ocelot, are


IND293 Mary Leon, page 1 of 1

IND294 Venkata Kothapalli, page 1 of 1

IND295 Marilyn Spivey, page 1 of 1

IND296 Stacie Wells, page 1 of 1

IND297 Sandy Schmidt, page 1 of 1
IND297-1 With respect to impact on communities, the local environment, and

local industries, these potential impacts on addressed in the EIS. Based on
surveys and information known to date, including consultation with the Texas
Historical Commission, the Annova LNG Project would not impact any known
indigenous cultural sites. See further detail in section 4.10 of the EIS.

IND300 Ann Sever, page 1 of 1

IND302 Mike Harris, page 1 of 1

IND304 Robert Arber, page 1 of 1

IND305-1 Cultural resource impacts and mitigation are addressed in section

4.10.4 of the EIS.
IND305-2 Effects to economy and employment are addressed in section

4.9.2 of the EIS.
IND305-3 Permits, approvals, and regulatory reviews are addressed in

IND305-4 Reliability and safety issues and associated requirements to ensure

public safety are addressed in section 4.12 of the EIS.
IND305-5 Production, extraction, and end-use of natural gas, including from

fracking, are not part of the scope of the EIS. NEPA review of the Project is
limited to the socioeconomic and environmental impacts of the proposal before
the Commission; therefore, the effects of production and end-use are outside of
the scope of this EIS. Section 1.3 of the FEIS has been updated to clarify.

IND306 Linda Bedre Vaughn, page 1 of 1

IND307 Diego Gavilanes, page 1 of 1
IND307-1 Wildlife impacts and mitigation measures are addressed in section

4.6 of the EIS.

IND309 Joel Quaintance, page 1 of 1

IND310 Yesenia Ceja, page 1 of 1

IND312 Mark Hellums, page 1 of 1
IND312-1 Visual resources and impacts are addressed in section 4.8.5 of the
EIS.

IND313 Cynthia Maguire, page 1 of 1
IND313-1 Cumulative impacts, including impacts from other LNG facilities,

are addressed in section 4.13 of the EIS.

IND315 Jim Jones, page 1 of 1
IND315-1 See responses to comments CO10-005 and IND09-14.

IND316 Jim Boldin, page 1 of 1

IND317 Ma Strange, page 1 of 1

IND319 Sondra York, page 1 of 1
IND319-1 The EIS addresses impacts on the environment from the proposed
Project.

IND320 Monica Cortes, page 1 of 1

IND321 Don Sawyer, page 1 of 1
IND321-1 The EIS addresses impacts on the environment from the proposed
Project. Impacts on land use is addressed in sections 4.8.1 through 4.8.4 of the
EIS.

IND322 Ivy Buchanan, page 1 of 1

IND323 Dr. Pat Smith, page 1 of 1

IND324 Patricia Stinson-Sunbury, page 1 of 1
IND324-1 Impacts on air quality are addressed in section 4.11.1 of the EIS.

IND325 Steven Smith, page 1 of 1

IND326 Lisa Chung, page 1 of 1

IND327 Laura Burns, page 1 of 1

IND328 Steve Sears, page 1 of 1

IND329 Charity Mccluskey, page 1 of 1

IND330 Caroline Oneal, page 1 of 1

IND331 Karl Brooks, page 1 of 1

IND332 Robert Sendrey, page 1 of 1
IND332-1 Future plans and abandonment are addressed in section 2.9 of the
EIS. Socioeconomic impacts are addressed in section 4.9 of the EIS.

IND333 James Klein, page 1 of 1

IND334 Elizabeth Young, page 1 of 1

IND335 Elizabeth Parker, page 1 of 1
IND335-1 Fracking is addressed in the response to comment IND09-14.

Impacts on water quality and wildlife habitat are addressed in sections 4.3 and
4.6 of the EIS, respectively.

IND336 Linda Hanratty, page 1 of 1

IND337 Dodie Sweeney, page 1 of 1

IND338 Evelyn Sardina, page 1 of 1

IND339 Roma Norwine, page 1 of 1
IND339-1 The EIS addresses impacts on environmental resources. As stated

in section 3.1 of the EIS, solar, wind, or other renewable energy project cannot
meet the purpose for the Project and are not considered or evaluated as
alternatives.

IND340 Vernon Berger, page 1 of 1

IND341 Mary Kennedy, page 1 of 1
IND341-1 Impacts on aquatic resources and marine life are addressed in

section 4.6.2 of the EIS. Coastal zone management is addressed in section
4.8.6 of the EIS.

IND342 Irene Martinez, page 1 of 1

Permits, approvals, and regulatory reviews are addressed in section 1.5 of the
EIS.

IND343 Jaen Lawrence, page 1 of 1

IND344 Julisia Jackson, page 1 of 1

IND345 Coleen Vincenti, page 1 of 1
IND345-1 Future plans and abandonment area addressed in section 2.9 of the
EIS. The EIS addresses impacts on environmental resources in section 4; and
addresses cumulative impacts in section 4.13.

IND346 Michael Spradlin, page 1 of 1

IND347 Jane Chischilly, page 1 of 1

IND348 Lorelei Lambert, page 1 of 1
IND348-1 Fracking is not proposed as part of the Project. See also response
to comment IND09-14.

IND349 Elaine Byrne, page 1 of 1
IND349-1 See responses to IND305-1 through IND305-5.

IND351 Lynn Rich, page 1 of 1
IND351-1 The EIS addresses impacts on wildlife and human interests

including socioeconomics, recreation; as well as water and air quality.

IND352 Martin Pesaresi, page 1 of 1
IND352-1 The EIS addresses impacts on environmental resources.

IND354 Cathy Chesser, page 1 of 1

IND355 Jan Vaughan, page 1 of 1

IND356 David Ruda, page 1 of 1

IND357 Hector Medellin, page 1 of 1

IND358 Kelly Hobbs, page 1 of 1

IND359 Sandy Ransom, page 1 of 1

IND361 Ed Breidenbach, page 1 of 1

IND364 James Smith, page 1 of 1

IND365 Patricia Schon, page 1 of 1

IND366 Karen Sterling, page 1 of 1

IND367 Turney Maurer, page 1 of 1
IND367-1 Impacts on communities and recreation are addressed in sections

4.8.3 and 4.8.4 of the EIS, respectively.

IND370 Ken Odell, page 1 of 1

LNG export is addressed in the response to comment CO10-005.

IND371 Christopher Hathaway, page 1 of 1

Environmental impacts, including impacts on coastal resources, are addressed
in the EIS.

IND372 Terri Mckeegan, page 1 of 1

IND374 Margaret Little, page 1 of 1
IND374-1 Impacts on water resources and water quality are addressed in

section 4.3 of the EIS. Impacts on socioeconomic resources, including
economic resources, are addressed in section 4.9 of the EIS. The Project
purpose and agency involvement related to the NEPA process are described in
section 1 of the EIS.

IND375 Tracy Mcmillan, page 1 of 1
IND375-1 Impacts on water resources are addressed in section 4.3 of the

EIS.

IND376 Sandy Phillips, page 1 of 1

IND377 Rick Boykin, page 1 of 1

IND378 Kent Rylander, page 1 of 1

IND379 John Langston, page 1 of 1

IND380 Gilberto Lopez, page 1 of 1
IND380-1 Fracking is addressed in the response to comment IND09-14. As

alternatives.

IND381 Yvonne Zepeda, page 1 of 1

IND382 Crystal Frias, page 1 of 1
IND382-1 Impacts on wildlife and aquatic resources are addressed in section

4.6. of the EIS.

IND383 Marissa Williams, page 1 of 1
IND383-1 Impacts on air quality are addressed in section 4.11 of the EIS.

IND384 Linda Hataway, page 1 of 1

Environmental impacts, including impacts on water, wildlife, and vegetation
are addressed in the EIS.

IND385 J. Talbot, page 1 of 1

IND386 Janet Phillips, page 1 of 1

IND387 Michelle Emmitt, page 1 of 1
IND387-1 Overall conclusions and recommendations are addressed in

section 5 of the EIS.

IND388 Lisa Barrett, page 1 of 1

IND389 Nika Dunn, page 1 of 1
IND389-1 The purpose of the proposed Project is addressed in section 1.1 of

the EIS. Environmental impacts are addressed in the EIS.

IND391 Kathryn Brown, page 1 of 1

Socioeconomic impacts including environmental justice issues are addressed in

IND392 Karin Ascot, page 1 of 1
IND392-1 Impacts on visual resources are addressed in section 4.8.5 of the

EIS.

IND394 Jane Miller Langley, page 1 of 1

IND395 Michael Phipps, page 1 of 1

IND396 Dr. Stern, page 1 of 1

IND397 Rhonda Boehm, page 1 of 1
IND397-1 The alternatives evaluation is addressed in section 3.0 of the EIS.

IND398 Joseph Krause, page 1 of 1
IND398-1 Impacts on recreation are addressed in section 4.8.4 of the EIS.

IND399 Tanya Kasper, page 1 of 1

EIS.

IND400 Julie Mayfield, page 1 of 1

IND401 Gary Kasper, page 1 of 1

IND402 Sabrina Cook, page 1 of 1

IND404 Linda Cooke, page 1 of 1
IND404-1 With respect to the potential to increase fracking in the Eagle Ford
shale and Permian Basin, see response to comment CO0-14. With respect to
the Project’s contribution to climate change, see section 4.13.3.9 of the EIS.
Other cumulative effects from construction of the three proposed LNG
terminals are addressed in section 4.13 of the EIS.
IND404-2 The non-jurisdictional pipeline that would be associated with the

Annova LNG Project would be about 9 miles in length. Potential impacts from
that pipeline are included in our assessment of cumulative impacts in section
4.13 of the EIS.

IND406 Linda Bedre, page 1 of 1

IND407 Katheryn Rogers, page 1 of 1

IND408 Alan Ogden, page 1 of 1
IND408-1 The potential impact of the Annova Project on the region,

including on wildlife and residents of the area, is evaluated in the EIS.

IND409 Micki Cansino Gerardi, page 1 of 1
See also response to comment CO0-14. The potential environmental and social
impact of the Annova Project on the region, as well as the two other proposed
LNG projects, is evaluated in the EIS.

IND410 William Parham, page 1 of 1

IND411 Suzanne Taylor, page 1 of 1

IND412 Donna Matthews, page 1 of 1

IND413 Sybil Morgan, page 1 of 1

IND414 Linda Maher, page 1 of 1

IND416 Dennis Deacon, page 1 of 1

IND417 Amy Maxwell, page 1 of 1
See also response to comment CO0-14. As stated in section 3.1 of the EIS,
solar, wind, or other renewable energy project cannot meet the purpose for the

IND419 Laura Brush, page 1 of 1
See also response to comment CO0-14. Based on surveys and information
known to date, including consultation with the Texas Historical Commission,
the Annova LNG Project would not impact any known indigenous cultural
sites. See further detail in section 4.10 of the EIS.

IND420 Mary Hancock, page 1 of 1

IND422 Melissa Guynes, page 1 of 1

IND423 Jo Boies, page 1 of 1

IND424 Yanira Aguirre, page 1 of 1

IND425 Zara Barron, page 1 of 1
IND425-1 Thank you for your comment. The potential impact on businesses
and the local economy is evaluated in section 4.9 of the EIS.

IND426 Robert Gary, page 1 of 1

IND427 Patsy Sasek, page 1 of 1
to use of solar and wind power, as stated in section 3.1 of the EIS, wind or
other renewable energy project cannot meet the purpose for the Project and are
not considered or evaluated as alternatives. Potential impact of the Project on
plants, animals, and ecosystems, and potential socioeconomic impacts, are
assessed in the EIS.

IND428 Cheyenne Weaver, page 1 of 1
IND428-1 As stated in section 3.1 of the EIS, wind or other renewable


IND429 Laura Carbonneau, page 1 of 1


IND430 Jacob Fakheri, page 1 of 1

IND431 Judy Clark, page 1 of 1
IND431-1 The Annova LNG Project does not include fracking.

IND432 Haiden Wattley, page 1 of 1

IND433 Shawn Troxell, page 1 of 1

or evaluated as alternatives. The Annova LNG Project does not include
fracking. See also response to comment IND9-14.

IND434 Choky Alvarez, page 1 of 1

IND435 Jane Lundquist, page 1 of 1

IND437 Sharon Daly, page 1 of 1
IND437-1 The Annova LNG Project does not include fracking. As stated in
section 3.1 of the EIS, wind or other renewable energy project cannot meet the
purpose for the Project and are not considered or evaluated as alternatives.

IND438 Gail Williams, page 1 of 1

IND439 Robert Bauer, page 1 of 1

IND440 Deena Berg, page 1 of 1

IND441 Roger Knudson, page 1 of 1

IND442 Bonnie Clements, page 1 of 1

IND443 Linda Fielder, page 1 of 1

would not impact any known indigenous cultural sites. See further detail in
section 4.10 of the EIS. With respect to potential impact on the coastline of
South Padre Island, the Project is located about 8 miles from the island.

IND444 Susan Bussa, page 1 of 1

IND445 Margaret Schulenberg, page 1 of 1

IND446 Samuela Walker, page 1 of 1

IND447 Rebecca Mccuistion, page 1 of 1
IND447-1 The proposed Annova LNG Project does not include a pipeline.
A non-jurisdictional pipeline would provide gas to the Annova Project

IND448 Clif Jordan, page 1 of 1
IND448-1 Thank you for your comment. See our assessment of Project
alternatives in section 3 of the EIS.

IND449 Debbie Hyde, page 1 of 1
to use of solar, wind, and other renewable energy, as stated in section 3.1 of the
EIS, renewable energy project cannot meet the purpose for the Project and are
not considered or evaluated as alternatives.

IND450 Sharon Haywood, page 1 of 1

IND451 CJ Vaughn, page 1 of 1
IND451-1 As stated in section 3.1 of the EIS, wind, solar, or other renewable

IND452 Kay Mcbrayer, page 1 of 1

IND453 Judith Stueve, page 1 of 1

IND454 Pat Johnson, page 1 of 1

IND455 Sara Straube, page 1 of 1

IND456 Claud & Sharon Bramblett, page 1 of 1

IND457 James Clark, page 1 of 1

IND458 Crystal Bowling, page 1 of 1
to fracking in other parts of Texas, see response to comment IND9-14. As
stated in section 3.1 of the EIS, solar, wind or other renewable energy project
alternatives.

IND459 Carina Ramirez, page 1 of 1

IND460 Pam Sohan, page 1 of 1
See also response to comment IND9-14. Based on surveys and information
known to date, including consultation with the Texas Historical Commission,
the Annova LNG Project would not impact any known sacred cultural sites.
See further detail in section 4.10 of the EIS.

IND461 Caroline Ysasaga, page 1 of 1

IND462 Kim Sanders George, page 1 of 1

IND463 Wanda Kirkpatrick, page 1 of 1

IND464 Rick Gordon, page 1 of 1

IND465 Susan Finley, page 1 of 1

IND466 Janice Kidd, page 1 of 1

IND467 Catherine Croom, page 1 of 1

IND468 Harvey Collen, page 1 of 1

IND469 Nancy Walsh, page 1 of 1

IND470 Fatimah Quraali, page 1 of 1

IND471 Cris Nelson, page 1 of 1
IND471-1 Thank you for your comment. The proposed Annova LNG
Project is about 8 miles from South Padre Island.

IND472 David Allison, page 1 of 1

IND473 Roberta Beckman, page 1 of 1

IND474 Laura Tabor, page 1 of 1

IND475 Lilli Pell, page 1 of 1

IND476 Lucia Carter, page 1 of 1

IND477 Elizabeth Whitlow, page 1 of 1

IND478 Stephen Brown, page 1 of 1

IND479 Stacey Schodek, page 1 of 1

IND481 Susan Hradsky, page 1 of 1

IND482 Laura Sander, page 1 of 1

IND483 Diana Wheeler, page 1 of 1
Project does not include fracking. See also response to comment IND9-14.

IND484 Liz LaFour, page 1 of 1

IND485 Diana Gamez, page 1 of 1

IND486 Patricia Thomson, page 1 of 1

IND487 Fran Wessel, page 1 of 1

IND488 Jerry Bailey, page 1 of 1

IND489 L. Fielder, page 1 of 1
IND489-1 Thank you for your comment. With respect to fracked gas
infrastructure, the proposed Annova LNG Project does not include fracking,
and we do not address the potential upstream sources of natural gas. See also
response to comment IND9-14. The concerns identified in this comment are all
address in the EIS.

IND490 Nancy Rosenberg, page 1 of 1

IND491 Karen Ricks, page 1 of 1

IND492 Edward Lackey, page 1 of 1

IND493 Darvin Oliver, page 1 of 1

IND494 Cynthia Meyer, page 1 of 1

IND495 Allison Vitek, page 1 of 1
wind, solar, or other renewable energy project cannot meet the purpose for the

IND496 Debra McCawley, page 1 of 1

IND497 Frederick Chase, page 1 of 1

IND498 Stephen Stoker, page 1 of 1

IND499 Theresa Martinez, page 1 of 1
wind, solar, or other renewable energy project cannot meet the purpose for the

IND500 Bettie Winsett, page 1 of 1

IND501 Kathleen Younghans, page 1 of 1

IND502 Luis Perez, page 1 of 1

IND503 Cynthia Prince, page 1 of 1

IND504 Natasha Tuckett, page 1 of 1

IND505 Billiejean Jones, page 1 of 1

IND506 Severa Krausse, page 1 of 1

IND507 Leonor Smith Zacarfas, page 1 of 1

IND508 John Browning, page 1 of 1

IND509 Pam Turlak, page 1 of 1

IND510 Monica Arsate, page 1 of 1

IND511 Monica Montalvo, page 1 of 1

IND512 Gena Sadler, page 1 of 1

IND513 Jeff Warmer, page 1 of 1

IND514 Alexandra Canei, page 1 of 1

IND515 Edward Grigassy, page 1 of 1
IND515-1 As stated in section 3.1 of the EIS, wind, solar, or other renewable
or evaluated as alternatives. The proposed Annova LNG Project does not

IND516 J. Iverson, page 1 of 1

IND517 Joshua Jacinto, page 1 of 1

IND518 Robert Martin, page 1 of 1

IND519 Patricia Brooks, page 1 of 1

IND521 Noemi Silva, page 1 of 1

IND523 Aguedys Whittaker, page 1 of 1

IND524 Waldo Castro, page 1 of 1
IND524-1 The proposed Annova LNG Project does not include fracking,
mining, or manufacturing. See also response to comment IND9-14.

IND526 Lori Namapee, page 1 of 1

APPENDIX L
COMMENTS ON THE DRAFT EIS AND RESPONSES
PART 2
IND527 Stephen Schwausch, page 1 of 1
IND527-6 The proposed Annova LNG Project does not include fracking,
mining, or manufacturing. See also response to comment IND9-14.

IND529 Steven Bailey, page 1 of 1

IND530 Ellen Cote, page 1 of 1
IND530-1 See the response to comment IND09-14.

IND531 Bob Bardo, page 1 of 1
IND531-1 Alternatives are described and evaluated in section 3 of the EIS.

IND532 Sarah Zepeda, page 1 of 1
IND532-1 The alternatives considered, including consideration of different

locations, are described and evaluated in section 3 of the EIS.
IND532-2 Reliability and safety considerations are addressed in section 4.13

of the EIS.

IND533 Carol Porras, page 1 of 1

IND534 Kimberly Gilbertson, page 1 of 1
IND534-1 Impacts on cultural resources are addressed in section 4.10 of the

EIS.
IND534-2 Economic and employment impacts are addressed in section 4.9.2

of the EIS.

IND536 Gerard Sullivan, page 1 of 1

IND537 Rogellio Alcoser, page 1 of 1

IND538 Ryan Scinta, page 1 of 1

IND540 Albert Downing, page 1 of 1

IND541 Charles Alexander Vaughn Paget, page 1 of 1
IND541-2 See the response to comment IND09-014. Reliability and safety

IND541-3 See the response to comment CO10-57. Impacts on special status

species are addressed in section 4.7 of the EIS; and impacts on wetlands are
addressed in section 4.4 of the EIS.
IND541-4 Thank you for your comment. Impacts on special status species
IND541-5 Impacts on wildlife and aquatic resources are addressed in section

4.6 of the EIS.

IND542 Jessica Bozeman, page 1 of 1

IND543 Leslie Brown, page 1 of 1

IND544 S. Hartman, page 1 of 1
IND544-1 Impacts on recreation are addressed in section 4.8.4 of the EIS.
IND544-2 Impacts on wildlife and visual resources are addressed in sections

4.6 and 4.8.5 of the EIS, respectively. Socioeconomic impacts, including
economic and employment impacts, are addressed in section 4.9 of the EIS.

IND545 Charles Counterman, page 1 of 1

IND546 Candace Halliburton, page 1 of 1
IND546-1 Impacts on recreation and visual resources are addressed in

section 4.8.4 and 4.8.5 of the EIS, respectively.

IND548 Joe Rogers, page 1 of 1
IND548-1 The alternatives considered, including consideration of different

locations, are described and evaluated in section 3 of the EIS.

IND549 Georgena Askew, page 1 of 1

IND552 Andrea Johnson, page 1 of 1
IND552-4 See the response to comment CO10-005.

IND554 Linda Kroeger, page 1 of 1

IND555 Donald Owen, page 1 of 1

IND556 Kathy Dorman, page 1 of 1
IND556-1 Impacts on environmental resources including wildlife are

addressed in the EIS.

IND557 Barry Brossa, page 1 of 1
IND557-1 Conclusions and recommendations related to the proposed Project

are addressed in section 5 of the EIS.

IND558 Carol Pennington, page 1 of 1
IND558-1 See responses to comments IND09-014 and CO10-005.

EIS.
IND558-3 Impacts on recreation and visual resources are addressed in

sections 4.8.4 and 4.8.5 of the EIS. Coastal zone management is addressed in
section 4.8.6 of the EIS.
IND558-4 Impacts on wildlife, special status species, and vegetation are

addressed in sections 4.6, 4.7, and 4.5 of the EIS.

IND559 Jeffrey Crozier, page 1 of 1

IND560 Shanna Bradford, page 1 of 1
IND560-1 Environmental impacts are addressed in the EIS. Impacts on

cultural resources are addressed in section 4.10 of the EIS.
IND560-2 Socioeconomic and employment impacts are addressed in section

4.9.2 of the EIS.

IND561 Cynthia Curtis, page 1 of 1

IND562 Julia Burgen, page 1 of 1
IND562-1 Thank you for your comment. The EIS addressed impacts on
environmental resources.

IND563 Dirk Rogers, page 1 of 1

IND564 Eric Scheihagen, page 1 of 1

IND564-2 Economic and employment impacts are addressed in section 4.9.2

of the EIS.

IND564-4 Reliability and safety are addressed in section 4.12 of the EIS.

IND565 Leah Klein, page 1 of 1
IND565-1 Thank you for your comment. The EIS addresses impacts on
environmental and socioeconomic resources.

IND566 Baldamar Lopez Jr, page 1 of 1

IND567 Jane Gilley, page 1 of 1

IND568 Nick & Diana Rudolph, page 1 of 1

IND569 Alan Holt, page 1 of 1


4.9.2 of the EIS.

IND569-4 See response to comment IND09-014. Reliability and safety are


IND571 Edwin & Patricia Sasek, page 1 of 1
IND571-1 The EIS addresses impacts on environmental resources including

wildlife, special status species, and air quality. Reliability and safety are
addressed in section 4.12 of the EIS. Fracking is addressed in the response to
comment IND09-014.

IND572 Christina Campos, page 1 of 1

IND573 Kate Mathis, page 1 of 1

IND574 Steve & Rachael Alvarez-Jett, page 1 of 1
IND574-1 Thank you for your comment. Impacts on environmental

resources are addressed in the EIS.

IND575 Lisa Gewax, page 1 of 1

IND577 Ruby Ahlquist, page 1 of 1
IND577-1 See response to comment CO10-57. Impacts on special status

species and wetlands are addressed in section 4.7 and 4.4 of the EIS,
respectively.

IND578 Ricardo Rojas, page 1 of 1
IND578-1 See responses to comments CO10-005 and IND09-014.

Socioeconomic impacts are addressed in section 4.9 of the EIS.

EIS; and environmental justice is addressed in section 4.9.9 of the EIS.

IND579 Lizeth Marquez, page 1 of 1

IND580 John Reiter, page 1 of 1

IND581 De Hy, page 1 of 1

IND582 Mark Witte, page 1 of 1

IND583 Bryan Taylor, page 1 of 1
IND583-1 Impacts on wetlands are addressed in section 4.4 of the EIS.

IND584 Nara Wood, page 1 of 1

IND586 Genevieve Ali, page 1 of 1

IND587 Asad Rahbar, page 1 of 1
IND587-2 Impacts on socioeconomic resources including the economy are

addressed in sections 4.9 and 4.9.2 of the EIS.

IND589 Sandra Varvel, page 1 of 1

IND590 Amy Ardington, page 1 of 1
IND590-1 Thank you for your comment. Alternatives evaluated are

described in section 3 of the EIS.

IND591 Craig Nazor, page 1 of 1
IND591-3 Impacts on socioeconomic resources are addressed in section 4.9

of the EIS. Reliability and safety are addressed in section 4.12 of the EIS.

IND592 Nancy Lehmann, page 1 of 1
IND592-1 The Project description is provided in section 2 of the EIS. Also

see response to comment IND09-014.

IND593 Steve Garland, page 1 of 1
IND593-1 Alternatives are evaluated in section 3 of the EIS. Also see


IND594 Astrid Thomsen, page 1 of 1

IND595 Virgil Rosser, page 1 of 1
IND595-1 Thank you for your comment. The EIS addresses alternatives for
the proposed action and impacts on environmental and socioeconomic
resources.

IND596 Joanne Fell, page 1 of 1
resources.

IND597 Russell Hollier, page 1 of 1
resources. Also see responses to comments IND09-014 and IND76-001.

IND598 David Davidson, page 1 of 1
IND598-1 See response to comment CO10-57. Impacts on special status

species including the ocelot are addressed in section 4.7 of the EIS.

IND599 Alan Montemayor, page 1 of 1
The EIS addresses impacts on environmental resources. Also see response to
comment IND09-014.

IND600 Vera Smith, page 1 of 1

IND601 Lala Bae, page 1 of 1

IND603 William Skinner, page 1 of 1

EIS; and environmental justice is addressed in section 4.9.9 of the EIS.

IND604 Joseph Reynolds, page 1 of 1

IND605 Brian Strasters, page 1 of 1

IND607 Kevin Abate, page 1 of 1

IND608 Nancy Fullerton, page 1 of 1

IND609 Raje Wolf, page 1 of 1
IND609-1 The EIS addresses impacts on environmental and socioeconomic

resources.

IND610 David & Susanne Arbiter, page 1 of 1

IND611 Gareth White, page 1 of 1

EIS.
IND611-2 Impacts on the economy and employment are addressed in section

4.9.2 of the EIS.

IND611-5 See responses to comments IND09-014 and CO10-005.

IND612 Thomas Templeton, page 1 of 1

IND613 Yury Ragoza, page 1 of 1
IND613-1 Thank you for your comment. Conclusions and recommendations

are addressed in section 5 of the EIS.

IND614 Ron Serino, page 1 of 1

resources.

IND616 Sharon Baron, page 1 of 1

IND617 Debra Walker, page 1 of 1

IND618 Sherri Sherbo, page 1 of 1
Permits, approvals, and regulatory reviews are addressed in section 1.5 of the
EIS.
IND618-4 Wildlife, special status species, wetlands, and vegetation are

addressed in sections 4.6, 4.7, 4.4, and 4.5, of the EIS, respectively.

4.9.2 of the EIS.
IND618-7 The Project description is provided in section 2 of the EIS and the
evaluation of alternatives is provided in section 3 of the EIS.

IND619 Theresa Flanagan, page 1 of 1

IND620 Carolyn Rich, page 1 of 1
IND620-1 Thank you for your comment. The EIS describes impacts on

IND621 Annette Mcanally, page 1 of 1

EIS.

4.9.2 of the EIS.
IND621-4 Permits, approvals, and regulatory review are addressed in section

1.5 of the EIS.
Also see response to comment CO07-003.

IND622 Deborah Williams, page 1 of 1

Alternatives are evaluated in section 3 of the EIS.

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND623 Robert Gilliland, page 1 of 1

resources.

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND624 Harriet Horton, page 1 of 1
IND624-1 The EIS addresses impacts on environmental resources. Also see

responses to comments IND09-014 and CO07-003.

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND625 Amy Quate, page 1 of 1

resources. Economic impacts are addressed in section 4.9.2 of the EIS.

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND626 Kat Feuerbacher, page 1 of 1
IND626-1 Impacts on visual resources and wildlife are addressed in sections

4.8.5 and 4.6 of the EIS, respectively.

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND627 Cindy Brittain, page 1 of 1
IND627-1 Thank you for your comment. Socioeconomic impacts are


EIS.

4.9.2 of the EIS.

1.5 of the EIS.
Also see responses to comments CO07-003 and IND07-014.

IND628 J. Fred Lindner, page 1 of 1

EIS.

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND629 Christiana Brinton, page 1 of 1

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND630 Eugene Molina, page 1 of 1
IND630-1 Impacts on environmental resources are addressed in the EIS.

Environment justice is addressed in section 4.9.9 of the EIS.

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND631 Mary Jozwiak, page 1 of 1
IND631-1 See response to comment IND09-014. Impacts on air quality are


EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND632 Yolanda Birdwell, page 1 of 1

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND633 Sandy York, page 1 of 1

resources. Impacts on visual resources, wildlife, and recreation are addressed in
sections 4.8.5, 4.6, and 4.8.4, respectively.

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND634 Valerie Hernandez, page 1 of 1

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND635 Barbara Anderson, page 1 of 1

resources. Impacts on visual resources and wildlife are addressed in sections
4.8.5 and 4.6, respectively.

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND636 James Gillum, page 1 of 1

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND637 Michael Collard, page 1 of 1

resources. Also see response to comment IND76-001.

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND638 Karen Sprague, page 1 of 1
IND638-1 Impacts on wildlife and special status species are addressed in

sections 4.6 and 4.7, respectively.

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND639 Melanie Demartinis, page 1 of 1
IND639-1 See responses to IND09-014 and IND115-01.

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND640 Gloria Skillman, page 1 of 1

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND641 Linda Berger, page 1 of 1
IND641-1 The Project purpose is described in section 1.1 of the EIS; and the
agency purpose and scope is provided in section 1.2 of the EIS.

EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND642 Elisa Hirt, page 1 of 1
IND642-1 Reliability and safety of the proposed Project is addressed in


EIS.

4.9.2 of the EIS.

1.5 of the EIS.

IND643 Julia Woodward-Parker, page 1 of 1
response to comment IND9-14. With respect to use of renewables, as stated in
section 3.1 of the EIS, renewable energy cannot meet the purpose for the
Project and is not considered or evaluated as alternatives.

IND644 Kathy Rinehart, page 1 of 1

IND645 Jill Buchanan, page 1 of 1

IND646 Julie Soleil, page 1 of 1

IND647 Jim Tucker, page 1 of 1
IND647-1 The proposed Annova LNG Project would not involve the use of
eminent domain.


IND649 Rochelle Brackman, page 1 of 1

IND650 Nettie Standiford, page 1 of 1

IND652 Jose Gomez, page 1 of 1
IND652-1 Thank you for your comment. The potential Project impacts on
property values is addressed in section 4.9.3 of the EIS, and the potential
impacts on the local economy including tourism is evaluated in section 4.9.2.2.

IND652 Lauren Danford, page 1 of 1

IND653 Frank Dufour, page 1 of 1

IND654 Harold Albers, page 1 of 1

IND655 Teran Hughes, page 1 of 1
IND655-1 The potential Project impacts on the local economy including

tourism is evaluated in section 4.9.2.2 of the EIS.

IND656 Cheryl Morris, page 1 of 1

IND657 Tammy Scott, page 1 of 1

IND658 Kathryn Samec, page 1 of 1

IND659 Teresa Saldivar, page 1 of 1
IND659-1 Thank you for your comment. Our assessment of the potential
impacts of the proposed Annova LNG Project on the Port of Brownsville and
the surrounding communities is included in the EIS.

IND660 Elizabeth Grimsley, page 1 of 1
IND660-1 As stated in section 3.1 of the EIS, renewable energy cannot meet
the purpose for the Project and is not considered or evaluated as alternatives.

IND661 Andrea MacRae, page 1 of 1

IND662 Holly Thiel, page 1 of 1

IND663 Donna Crittenden, page 1 of 1

IND664 Nancy McGrath, page 1 of 1

IND665 Douglas Chalmers, page 1 of 1
IND665-1 Thank you for your comment. The Annova LNG Project’s
potential contribution to climate change is evaluated in section 4.13.3.9 of the
EIS.

IND666 Pat Roberson, page 1 of 1

IND667 Katie Drackert, page 1 of 1

IND668 Eva Coleman, page 1 of 1
IND668-1 Thank you for your comment. The potential impact on birds and
other wildlife is evaluated in sections 4.6 and 4.7 of the EIS.

IND669 Tracy Briney, page 1 of 1

IND670 Irenia Salazar-Parada, page 1 of 1
IND670-1 With respect to use of renewables, as stated in section 3.1 of the

EIS, renewable energy cannot meet the purpose for the Project and is not
considered or evaluated as alternatives. With respect to fracking, the Annova
LNG Project does not include fracking. See also response to comment IND9-
14.

IND671 Charmaine Berry, page 1 of 1

IND672 Cima Malkhassian, page 1 of 1
Project is located about 8 miles from South Padre Island.

IND673 Diane Y Michael Wonio, page 1 of 1
IND673-1 Thank you for your comment. See various sections of the EIS for
our assessment of the potential impacts from the Annova LNG Project on
recreation, wildlife, and native plants.

would not impact any known sacred grounds or indigenous cultural sites. See
further detail in section 4.10 of the EIS.

IND674 Gwynne Carosella, page 1 of 1

IND675 Monique Mcintyre, page 1 of 1

IND676 Karen Naumann, page 1 of 1

IND677 Christina Scattergood, page 1 of 1

IND678 Richard Schlenk, page 1 of 1
IND678-1 Thank you for your comment. The potential impact on birds and
other wildlife is evaluated in sections 4.6 and 4.7 of the EIS.

IND679 Brittney Collins, page 1 of 1

IND680 Catherine Willmann, page 1 of 1
IND680-1 Thank you for your comment. See sections 4.8 and 4.9 of the EIS
for our assessment of the potential impacts of the Annova LNG Project on the
local communities, people, and businesses.

IND681 Tracy Simmons, page 1 of 1

IND682 Joan Allison, page 1 of 1

IND683 Jeanne Jordan, page 1 of 1
Project is about 8 miles from South Padre Island.

IND684 Sherry Andresen, page 1 of 1
IND684-1 Thank you for your comment. The potential impacts on the area
surrounding the proposed Project, and potential risk, are addressed in the EIS.

IND685 William Romfh, page 1 of 1

IND686 Joanna Segura-Delgado, page 1 of 1

IND687 Betsy Lambert, page 1 of 1

IND688 Bill France, page 1 of 1

IND689 Kristina Williams, page 1 of 1

IND690 Angela Berrera, page 1 of 1


IND691 Lynsey Holland, page 1 of 1


IND692 Melodie Palmer, page 1 of 1

IND693 Kathleen Bryson, page 1 of 1

IND694 Doyle Sebesta, page 1 of 1

IND695 Todd Teulon, page 1 of 1

IND696 Alexis Sosa, page 1 of 1

IND697 Mike Johnson, page 1 of 1
impact on tourism in section 4.9.2.2 of the EIS.

IND698 Marla Hanks, page 1 of 1

IND699 Sheyla Mendoza, page 1 of 1

IND700 Derek Luft, page 1 of 1

IND701 Alice Kuchenthal, page 1 of 1

IND702 Deana Phillips, page 1 of 1

IND703 Terry Burton, page 1 of 1

IND704 Elizabeth Burton, page 1 of 1

IND705 Jeanne Kyser, page 1 of 1

IND706 Jose Sanchez, page 1 of 1

IND707 Sheila Simpson, page 1 of 1

IND708 Terri McNeal, page 1 of 1

IND709 Gloria Silva, page 1 of 1
IND709-1 Thank you for your comment. The potential impacts on the
ecosystem and the local economy is evaluated in several sections of the EIS.

IND710 Gilbert Pritchett, page 1 of 1

IND711 Cameron Babberney, page 1 of 1
IND711-4 See response to comment IND17-2

IND712 Leslie Hopkins, page 1 of 1

IND713 Penny Hartwell, page 1 of 1

IND714 William Michael, page 1 of 1

IND715 Clarisa Rostro, page 1 of 1

IND716 Rose Morris, page 1 of 1

IND717 Duane Patrick, page 1 of 1

IND718 Alexander Helou, page 1 of 1

IND719 Cliff Perkins, page 1 of 1

IND720 Betty Alex, page 1 of 1

IND721 Corliss Crabtree, page 1 of 1

IND722 P. Leal, page 1 of 1

IND723 Mary Mueller, page 1 of 1

IND724 Ann Mcgory, page 1 of 1

IND725 Tayyab Malik, page 1 of 1

IND726 Mittie Hinz, page 1 of 1

IND727 Felipe-Andres Piedra, page 1 of 1

IND728 James Lipsey, page 1 of 1

IND729 Jessimikuh Shhboom, page 1 of 1

IND730 Marie Norrell, page 1 of 1

IND731 John Rooney, page 1 of 1
IND731-2 The potential Project impacts on human health is addressed

through review of projected air emissions against regulatory thresholds that
have been established for the protection of human health, such as the NAAQS.

IND732 John Fisher, page 1 of 1

IND733 Mary Celaya, page 1 of 1

4.13.3.9.
IND733-2 The potential impact on endangered species is included in section

4.7 of the EIS, as well as the Biological Assessment currently under review by
the FWS.


IND734 Erika Shea, page 1 of 1

IND735 Craig Liebendorfer, page 1 of 1

IND736 Mark Monger, page 1 of 1


IND738 William Cook, page 1 of 1
IND738-1 With respect to use of solar power and other renewables, as stated
in section 3.1 of the EIS, renewable energy cannot meet the purpose for the
Project and is not considered or evaluated as alternatives.

IND739 Connie Leblanc, page 1 of 1
IND739-1 Thank you for your comment. With regard to evaluation of

impacts near the Eagle Ford Shale, see response to comment IND9-14.

IND740 Debra Francis, page 1 of 1

IND741 Ann Kaiser, page 1 of 1

IND742 James Rice, page 1 of 1

IND743 Bill Rogers, page 1 of 1


IND744 Jane Jatinen, page 1 of 1

IND745 David Michalek, page 1 of 1

IND746 Frank Blake, page 1 of 1

IND747 Morgan Mayes, page 1 of 1

IND748 Linda Brust, page 1 of 1
wind or other renewable energy projects cannot meet the purpose
for the Project and are not considered or evaluated as alternatives.

IND749 Roberto Salazar, page 1 of 1

IND750 Martha Honey, page 1 of 1
include fracking.

IND751 Mackenzie Crone, page 1 of 1

IND752 Kathy Pinckney, page 1 of 1
include fracking.

IND753 Marie Palos, page 1 of 1

IND754 David Mohan, page 1 of 1
Section 3.1 of the EIS presents alternatives to the proposed
Project.

IND755 Bianca Marcuccino-Walsh, page 1 of 1

IND756 Gary Aten, page 1 of 1

IND757 Carol Denning, page 1 of 1
include fracking.

IND758 Debra Hollinger, page 1 of 1
IND758-1 Thank you for your comment. Based on surveys and information
known to date, including consultation with the Texas Historical
Commission, the Annova LNG Project would not impact any
known indigenous cultural sites. See further detail in section 4.10
of the EIS. Potential impact of the Project on coastal ecosystems
is assessed in the EIS.

IND759 Suzanne Gil, page 1 of 1
IND759-1 Thank you for our comment.

IND760 Robert Bauhs, page 1 of 1

IND761 Rebekah Farrell, page 1 of 1
include fracking.

IND762 Gaye Holden, page 1 of 1

IND763 Jennifer Nichols, page 1 of 1

IND764 Brian Schill, page 1 of 1
IND764-1 Concerns related to LNG facility reliability and safety are

discussed in section 4.12 of the EIS.

4.13.3.9.

IND765 David Powell, page 1 of 1
IND765-1 Concerns related to LNG facility reliability and safety are

discussed in section 4.12 of the EIS.

4.13.3.9.

IND766 Mariel Davis, page 1 of 1
IND766-1 Thank you for your comment. The Annova LNG Project does
include fracking or a pipeline. As stated in section 3.1 of the EIS,

IND767 Pam Jaso, page 1 of 1

IND768 David Dorsey, page 1 of 1

IND769 Sophia Melendez, page 1 of 1

IND770 Linda Greene, page 1 of 1

IND771 Reynolds Reynolds, page 1 of 1

IND772 Krissie Marty, page 1 of 1

IND773 Alma Mata, page 1 of 1

IND774 Lonne Martinec, page 1 of 1
include fracking.

IND775 Kurtis Castellanos, page 1 of 1

IND776 Marie Hamm, page 1 of 1

IND777 Karen Arceri, page 1 of 1

IND778 Molly Rooke, page 1 of 1
IND778-1 Thank you for your comment. Potential concerns related to

climate change are discussed in section 4.13 of the EIS. Potential
impacts on businesses are addressed in section 4.9.

IND779 Sara Burden-Mcclure, page 1 of 1
include fracking.

IND780 Alice Perez, page 1 of 1
include a pipeline.

IND781 Christina Esmahan, page 1 of 1
include fracking.

IND782 Tria Shaffer, page 1 of 1
include a pipeline or fracking.

IND783 Bianca Gallegos, page 1 of 1

IND784 Michael & Jeanne Galvin, page 1 of 1
IND784-6 See response to comment IND17-.

IND785 Ling Zhu, page 1 of 1
IND785-1 Thank you for your comment. Potential impacts on recreation are

IND786 Sarah Fawcett, page 1 of 1
include fracking.

IND787 Joe Lopez, page 1 of 1
include fracking.

IND788 Carol Fly, page 1 of 1
include fracking.

IND789 Iris Waser, page 1 of 1
include fracking.

IND790 Evelyn Myler, page 1 of 1
include fracking.

IND791 Cecile Burandt, page 1 of 1
include fracking or a pipeline.

IND792 Michael Gray, page 1 of 1
include fracking.

IND793 L. Borgen, page 1 of 1

IND794 Carla Harris, page 1 of 1
IND794-1 Thank you for your comment. The Annova LNG Project is not
located on the coastline. Impacts on shorelines in the Brownsville
Ship Channel are addressed in section 4.3 of the EIS. See
response to comment IND17-2 regarding indigenous lands.
IND794-2 Thank you for your comment. See the EIS for our assessment of
the potential environmental impacts of the project.

IND795 Lauren Ide, page 1 of 1

IND796 Martin Terry, page 1 of 1

IND797 Kenneth Johnson, page 1 of 1

IND798 Kris Manley, page 1 of 1
include fracking.

IND799 Suzanne Herzing, page 1 of 1
include fracking.

IND800 John-Michael Torres, page 1 of 1

IND801 Teresa Pietersen, page 1 of 1
include fracking or a pipeline.

IND802 Kathryn Davidson, page 1 of 1

IND803 Michael & Susie Way, page 1 of 1

IND804 Shirley Slampa, page 1 of 1
include a pipeline.

IND805 Karen Phillips, page 1 of 1

IND806 Sarah Berner, page 1 of 1
include fracking.

IND807 Antoinette Freeman, page 1 of 1

IND808 Teresa Summerlin, page 1 of 1
include a pipeline.

IND809 Riley Walberg, page 1 of 1

IND810 John Ader, page 1 of 1

IND811 June Jensen, page 1 of 1

IND812 Grace Pruitt, page 1 of 1

IND813 Hernan Ortega, page 1 of 1

IND814 Anthony Sanchez, page 1 of 1

IND815 Missy Elley, page 1 of 1

IND816 Pam Wetzels, page 1 of 1
IND816-1 The potential impact on the existing economy of the region,

including tourism and fishing, is addressed in section 4.8 and 4.9
of the EIS. Potential impacts on scenery are addressed in section
4.8.

IND817 Colleen Theriot, page 1 of 1

IND818 Nancy Latner, page 1 of 1

IND819 Jonathan Sanders, page 1 of 1
IND819-1 Potential impacts on land use and recreation are addressed in


IND820 Michelle Esposito, page 1 of 1
IND820-1 Potential impacts on land use and recreation are addressed in


IND821 Ashley Beard, page 1 of 1
IND821-1 Thank you for your comment. The Annova LNG Project is not
located on the coastline. Impacts on shorelines in the Brownsville
Ship Channel are addressed in section 4.3 of the EIS.

IND822 Melanie Schuchart, page 1 of 1

IND823 Enedelia Salinas, page 1 of 1

IND824 Chris Soignier, page 1 of 1

IND825 Jeremiah Stith, page 1 of 1

IND826 Jack Elam, page 1 of 1

IND827 Eugenia Schuler, page 1 of 1

IND828 Elizabeth Venable, page 1 of 1

IND829 Linda Olsoe, page 1 of 1
include a pipeline.

IND830 Jensie Madden, page 1 of 1

IND831 Raynae Baker, page 1 of 1
IND831-1 Thank you for your comment. The Anova LNG Project does not
include fracking.

IND832 Susan Thorn, page 1 of 1

IND833 Judith Betancourt, page 1 of 1

IND834 Sandy Simmons, page 1 of 1
include fracking.

IND835 Sari Albornoz, page 1 of 1

IND836 Mari Wilson, page 1 of 1

IND837 Lillian Nance, page 1 of 1

IND838 Stewart Yaros, page 1 of 1

IND839 Shelby Scarbrough, page 1 of 1
involve drilling.

IND840 Trinity Cobb, page 1 of 1

IND841 Susie Thompson, page 1 of 1

IND842 Lisa Parisi, page 1 of 1

IND843 Patty Adams, page 1 of 1

IND844 Celeste Rosales, page 1 of 1

IND845 Kayla Muzquiz, page 1 of 1

IND846 Cheryl Watson, page 1 of 1
IND846-1 Thank you for your comment. As stated in section 3.1 of the
EIS, wind or other renewable energy project cannot meet the
purpose for the Project and are not considered or evaluated as
alternatives.

IND847 E. Ingraham, page 1 of 1

IND848 Mary McDonald, page 1 of 1

IND849 Marilyn Endres, page 1 of 1

IND850 John Lethco, page 1 of 1

IND851 Brian Abernathy, page 1 of 1
IND851-1 Thank you for your comment. The Annova NLG Project does
not include fracking.

IND852 Jane Abrams, page 1 of 1

IND853 Noe Acevedo, page 1 of 1
IND853-1 Thank you for your comment. Section 4.13 of the EIS provides
an analysis of the cumulative impacts associated with the
Project.

IND854 U. Sakoglu, page 1 of 1

IND855 P.S. Allison, page 1 of 1

IND856 Max Anderson, page 1 of 1
IND856-1 Thank you for your comment. The potential impact on

businesses and the local economy is evaluated in section 4.9 of
the EIS. Potential impact of the Project on plants, animals, and
ecosystems are assessed in the EIS.

IND857 Sandra Arzola, page 1 of 1

IND858 Jill Bailey, page 1 of 1

IND859 Scott Baker, page 1 of 1

IND860 Justin Bautista, page 1 of 1
IND860-1 Thank you for your comment. The Annova LNG project does
not include fracking or a pipeline. With respect to use of solar
and wind power, as stated in section 3.1 of the EIS, wind or
other renewable energy projects cannot meet the purpose for
the Project and are not considered or evaluated as alternatives.

IND861 Bea Bee, page 1 of 1

IND862 Bhuvanesh Bhatt, page 1 of 1
IND862-1 Thank you for your comment. With respect to use of solar and
wind power, as stated in section 3.1 of the EIS, wind or other
renewable energy projects cannot meet the purpose for the

IND863 Denise Bickford, page 1 of 1

See response to comment IND17-1. IND864 Sarah Bijoy, page 1 of 1
not include fracking. With respect to use of solar and wind
power, as stated in section 3.1 of the EIS, wind or other
renewable energy projects cannot meet the purpose for the

IND865 John Boriack, page 1 of 1

IND866 Justin Bosler, page 1 of 1
IND866-1 Thank you for your comment. See response to comment CO6-
17 regarding carbon capture.

IND867 Tia Bostater, page 1 of 1

IND868 Carol Box, page 1 of 1

IND869 Clara Boyer, page 1 of 1
IND869-1 Thank you for your comments. The Annova LNG Project does
not include fracking or a pipeline. The potential impacts
associated with the Project are analyzed in the section 4 of the
EIS.

IND870 Kate Bremer, page 1 of 1
not include a pipeline. Potential impact of the Project on plants,
animals, and ecosystems are assessed in the EIS.

IND871 Becky Browning, page 1 of 1

IND872 Klementyna Bryte, page 1 of 1

IND873 Richard Buck, page 1 of 1

IND874 Elizabeth Burnette, page 1 of 1

IND875 Kathryn Burns, page 1 of 1

IND876 Carolyn Nieland, page 1 of 1

IND877 Christine Smith, page 1 of 1

IND878 Grace Cagle, page 1 of 1

IND879 Richard Caldwell, page 1 of 1

IND880 Barbara Campbell, page 1 of 1
not include fracking or a pipeline. As stated in section 3.1 of
the EIS, wind or other renewable energy projects cannot meet
the purpose for the Project and are not considered or evaluated
as alternatives.

IND881 Lisa Canorro, page 1 of 1

IND882 Celine Capiccioni, page 1 of 1

IND883 Paul Cardwell, page 1 of 1
IND883-1 Thank you for your comment. Section 4.12 of the EIS
addresses safety and reliability of the LNG facilities.

IND884 Cathy Carpentier, page 1 of 1

IND885 Rosemary Carson, page 1 of 1

IND886 Marisol Cervantes, page 1 of 1
not include a pipeline.

IND887 Khy Chapman, page 1 of 1

IND888 Jose Choquehuanca, page 1 of 1

IND889 Chris Clark, page 1 of 1

IND890 John Clary, page 1 of 1

IND891 Mary Cohron, page 1 of 1
not include fracking or a pipeline.

IND892 Danielle Cole, page 1 of 1

IND893 Debra Coleman, page 1 of 1

IND894 Audrey Colombe, page 1 of 1

IND895 Linda Cox, page 1 of 1

IND896 Diana Clark, page 1 of 1

IND897 Susan Daugherty, page 1 of 1
IND897-1 Thank you for your comment. The potential impact on

businesses and the local economy is evaluated in section 4.9 of
the EIS.

IND898 Alfred Davila, page 1 of 1

IND899 Ilene Dillon-Fink, page 1 of 1

IND900 Ken Dixon, page 1 of 1
IND900-1 Thank you for your comment. Potential impacts of the Project
on plants, animals, and ecosystems are assessed in section 4 of
the EIS.

IND901 Carolyn Downs, page 1 of 1

IND902 Stephanie Doyle, page 1 of 1

IND904 John Edwards, page 1 of 1

IND905 Suzy Eide, page 1 of 1
EIS, wind or other renewable energy projects cannot meet the
alternatives.

IND906 Susan Ellis, page 1 of 1

IND907 Stephanie Ertel, page 1 of 1

IND908 Dan Everly, page 1 of 1
not include fracking. Based on surveys and information known
to date, including consultation with the Texas Historical
Commission, the Annova LNG Project would not impact any
known indigenous cultural sites. See further detail in section
4.10 of the EIS. With respect to potential impact on the
coastline of South Padre Island, the Project is located about 8
miles from the island.

IND909 Brad First, page 1 of 1

IND910 Diamond Flores, page 1 of 1

IND911 Marcha Fox, page 1 of 1

IND912 Jose Gamboa, page 1 of 1

IND913 Xylia Garcia, page 1 of 1

IND914 Margaret Garza, page 1 of 1

IND915 Carol Gerson, page 1 of 1

IND916 Jennifer Golden, page 1 of 1

IND917 Patricia Gonzales, page 1 of 1
IND917-1 Thank you for your comment. Potential impact of the Project
on plants, animals, and ecosystems, and potential
socioeconomic impacts, are assessed in Section 4 of the EIS.

IND918 Autumn Gonzalez, page 1 of 1

IND919 Mark Goodman, page 1 of 1

IND920 Kathy Goodwin, page 1 of 1
not include fracking or a pipeline.

IND921 Kren Grosse-Ramirez, page 1 of 1

IND922 Shannon Grounds, page 1 of 1

IND923 John Guest, page 1 of 1

IND924 Sandi Hebley, page 1 of 1
EIS, wind or other renewable energy project cannot meet the
alternatives.

IND925 Jacqui Hamlett, page 1 of 1

IND926 Don Hammond, page 1 of 1

IND927 Robin Hanson, page 1 of 1

IND928 Pamela Hardwick, page 1 of 1

IND929 Lucy Harmon, page 1 of 1
IND929-1 Thank you for your comment. Potential impact of the Project
on plants, animals, and ecosystems are assessed in section 4 of
the EIS.

IND930 Dan Harrison, page 1 of 1

IND931 Jana Harter, page 1 of 1

IND932 Miguel Hernandez, page 1 of 1

IND933 Claudia Herrera, page 1 of 1

IND934 Janice Hewitt, page 1 of 1
not include fracking or pipeline construction.

IND935 Ginger Himelright, page 1 of 1

IND936 Holly Holmes, page 1 of 1

IND937 Jean Hopkins, page 1 of 1
IND937-1 Thank you for comment. The issue of environmental justice is


IND938 Athenea Hughes, page 1 of 1

IND939 Lee Hutchings, page 1 of 1
IND939-1 Thank you for your comment. Safety and reliability of the
Annova LNG Project is addressed in section 4.12 of the EIS.

IND940 Adrienne Inglis, page 1 of 1

IND941 Pete Inman, page 1 of 1

IND942 Teresa Iovine, page 1 of 1
IND942-1 Thankyou for your comment.

IND943 Katie Irani, page 1 of 1

IND944 John Wilson, page 1 of 1

IND945 Henry Jackson, page 1 of 1

IND946 Kyle Jeffries, page 1 of 1

IND947 Ann Joseph, page 1 of 1

IND948 Karen Browning, page 1 of 1
IND948-1 With regard to renewable energy, as stated in section 3.1 of the

EIS, solar, wind, or other renewable energy project cannot meet the purpose for

IND949 Kirk & Xochiti Jackson, page 1 of 1

IND950 Sierra King, page 1 of 1
IND950-1 Socioeconomic impacts are addressed in section 4.9 of the EIS.

IND951 Alison Kirsch, page 1 of 1
IND951-1 Impacts on wildlife are addressed in section 4.6 of the EIS.

IND952 Tracey Kunkler, page 1 of 1


IND953 Pamela Kurner, page 1 of 1

Reliability and safety are addressed in section 4.12 of the EIS. Also see

IND954 Lori Williams, page 1 of 1

4.9.2 of the EIS. Also see response to comment IND09-014.

IND955 Juanita Lambie, page 1 of 1

the Project and are not considered or evaluated as alternatives. Also see

IND956 Julia Landress, page 1 of 1

IND957 Stephanie Levinson, page 1 of 1

resources.

IND958 John Lewis, page 1 of 1
IND958-1 The EIS process is described in section 1 of the EIS; and the
public review and comment process is specifically described in section 1.3.

IND959 Elizabeth Lopez, page 1 of 1

4.13.3.9.

IND960 Rev Luis Ignacio Gameros M Div, page 1 of 1
IND960-1 Thank you for your comment. Impacts on visual resources are
addressed in section 4.8.5 of the EIS. The EIS process including agency and
public involvement is addressed in section 1 of the EIS.

IND961 Matt Lykken, page 1 of 1

EIS.
IND961-2 The EIS process is described in section 1 of the EIS and the
Project purpose is specifically described in section 1.1.

IND962 Larisa Manescu, page 1 of 1
IND962-1 The EIS process including the public comment and review
process is described in section 1 of the EIS. Discussion of GHG and climate

IND963 Pamela Massey, page 1 of 1

IND964 Sharon Matz, page 1 of 1

IND965 Andrea Maxwell, page 1 of 1

IND966 Sally McAfee, page 1 of 1

4.13.3.9. Reliability and safety are addressed in section 4.12 of the EIS.
Impacts on the economy and employment are addressed in section 4.9.2 of the
EIS.

IND967 K. McGaughy, page 1 of 1

IND968 Meredith McGuire, page 1 of 1

4.13.3.9. Also see response to comment IND09-014.

IND969 Susan McKinley, page 1 of 1

4.13.3.9. Impacts on special status species are addressed in section 4.7 of the
EIS.

IND970 Allison Metzger, page 1 of 1
IND970-1 Thank you for your comment. Also see response to comment
IND09-014.

IND971 Eric Meyer, page 1 of 1

IND972 Kent & Karol Middleton, page 1 of 1
IND972-1 The purpose of the Project is described in section 1.1 of the EIS.

IND973 Diana Montejano, page 1 of 1
IND973-1 Impacts on socioeconomic resources are addressed in section 4.9

and impacts on land use are addressed in section 4.8 of the EIS.

IND974 Laura Mordecai, page 1 of 1

IND975 Winnie Tate Morgan, page 1 of 1
IND975-1 The EIS process is described in section 1 of the EIS. Conclusions

and recommendations with regard to environmental and socioeconomic impacts
are described in section 5 of the EIS.

IND976 Tilsa Muldoon, page 1 of 1
IND976-1 Thank you for your comment. The EIS process is described in
section 1 and the evaluation of alternatives is provided in section 3 of the EIS.

IND977 Martha Mullens, page 1 of 1
IND09-014.

IND978 Anthony Murray, page 1 of 1

IND979 Tracy Musgrove, page 1 of 1
Project and are not considered or evaluated as alternatives. Also see response to
comment IND09-014.

IND980 Roger Neumann, page 1 of 1
section 1 of the EIS. The EIS addresses impacts on environmental and
socioeconomic resources.

IND981 Susan Nichols, page 1 of 1


IND983 Karen Norton, page 1 of 1

IND984 William Okain, page 1 of 1

IND985 Sidney Parsons, page 1 of 1
section 1, and the evaluation of alternatives is provided in section 3 of the EIS.

IND986 Victoria Patterson, page 1 of 1
IND09-014.

IND987 Patricia Patteson, page 1 of 1

EIS. Impacts on the economy are addressed in section 4.9.2 of the EIS. Impacts
on wildlife and special status species are addressed in sections 4.6 and 4.7 of
the EIS, respectively.

IND988 Anita Pauwels, page 1 of 1
IND988-1 The evaluation of alternatives is addressed in section 3 of the EIS.

IND989 Sylvia Pena, page 1 of 1
IND989-1 The EPA has developed the NAAQS to protect human health and
the environment, including vulnerable populations such as the elderly, children
and asthmatics. Ambient air quality impacts, and whether they are below or
exceed the NAAQS are addressed in section 4.11.1, air quality, and section
4.13, cumulative impacts of the EIS.

IND990 Cynthia Perez, page 1 of 1
IND990-1 Alternatives are evaluated and described in section 3 of the EIS.

IND991 Judy Perkins, page 1 of 1

IND992 Al Plata, page 1 of 1

IND993 Beverly Polan, page 1 of 1
IND993-1 Thank you for your comment. Impacts on employment are


IND994 Mary Pustejovsky, page 1 of 1
IND994-1 Impacts on socioeconomics are addressed in section 4.9 of the

EIS; and impacts on recreation are addressed in section 4.8.4 of the EIS.
Economic impacts on recreation and tourism are addressed in section 4.9.2.2 of
the EIS.

IND995 Emilio Ramirez, page 1 of 1

IND996 Linda Ramos, page 1 of 1
IND996-1 A description and evaluation of alternatives is provided in section

3 of the EIS.

IND997 Cathy Ramsey, page 1 of 1
IND997-1 Thank you for your comment. The EIS includes an evaluation of
alternatives in section 3 and addresses impacts on environmental and
socioeconomic resources. The EIS process is described in section 1 of the EIS.

IND998 Carol Reinking, page 1 of 1

IND999 Ana Reza, page 1 of 1

IND1000 Christian Richer, page 1 of 1

section 1, and a description and evaluation of alternatives is provided in section
3 of the EIS.

IND1002 Maritza Rodriguez, page 1 of 1
IND1002-1 Impacts on socioeconomics are addressed in section 4.9 of the

EIS; and impacts on recreation are addressed in section 4.8.4 of the EIS.
Economic impacts on recreation and tourism are addressed in section 4.9.2.2 of
the EIS. Impacts on visual resources are addressed in section 4.8.5 of the EIS.

IND1003 Barbara Rogers, page 1 of 1

IND1004 Terri Rose, page 1 of 1
or evaluated as alternatives. Impacts on visual resources are addressed in
section 4.8.5 of the EIS. Also see response to comment IND09-014.

IND1005 Debbie Rothermel, page 1 of 1

IND1006 Jean Rothfusz, page 1 of 1
IND1006-1 Impacts on tourism are addressed in section 4.9.2.2 of the EIS.

IND1007 Michael Russell, page 1 of 1

IND1008 Michelle Rutan, page 1 of 1

IND1009 Miroslava Saenz, page 1 of 1

EIS.

resources. Impacts on wildlife are addressed in section 4.6 and impacts on the
economy are addressed in section 4.9.2 of the EIS.

IND1010 Claudio Salazar, page 1 of 1
IND1010-1 Thank you for your comment. See response to comment IND09-
014.

IND1011 Bianca Sanchez-Navarro, page 1 of 1
section 1 of the EIS. Also see response to comment IND09-014.

IND1012 Dorothy Schleicher, page 1 of 1

IND1013 Linda Schubert, page 1 of 1

IND1014 Philip Scott, page 1 of 1
IND1014-1 Reliability and safety is addressed in section 4.12 of the EIS.
IND1014-2 Impacts on wildlife are addressed in section 4.6 of the EIS; and
impacts on tourism are addressed in section 4.9.2.2 of the EIS.

IND1015 Bonni Scudder, page 1 of 1

IND1016 Rose Slatouski, page 1 of 1

IND1017 Jan Smith, page 1 of 1

IND1018 Judith Snape, page 1 of 1

IND1019 Elisabeth Sommer, page 1 of 1
IND1019-1 Thank you for your comment. Impacts on tourism are addressed
in section 4.9.2.2 of the EIS.

IND1020 Sandra Sparks, page 1 of 1

IND1021 Nathan Stanfield, page 1 of 1

IND1022 Diana Steinhagen, page 1 of 1
IND1022-1 Thank you for your response. Permits, approvals, and regulatory
reviews are addressed in section 1.5 of the EIS.

IND1023 Teresa Stoever, page 1 of 1

IND1024 Jeff Stone, page 1 of 1

IND1025 Dominic Stricherz, page 1 of 1

alternatives.

IND1026 Shelby Strickland, page 1 of 1
IND1026-1 Impacts on cultural resources are addressed in section 4.10 and

environmental justice is addressed in section 4.9.9 of the EIS.

resources. Impacts on tourism are addressed in section 4.9.2.2 of the EIS.
Reliability and safety is addressed in section 4.12 of the EIS. Also see response
to comment IND09-014.

IND1027 Rachel Stroud, page 1 of 1
IND1027-1 See response to comment IND09-014. Impacts from climate

change are addressed in section 4.13 of the EIS.

IND1028 Dan Sundberg, page 1 of 1

IND1029 Cindy Symington, page 1 of 1

IND1030 Joanna Symmonds, page 1 of 1

IND1031 Tina Theriaque, page 1 of 1
IND1031-1 Impacts on tourism and recreation are addressed in sections

4.9.2.2 and 4.8.4 of the EIS.

IND1032 Mary Timmons, page 1 of 1

IND1033 Joe Tompkins, page 1 of 1

IND1034 Sid Totten, page 1 of 1
IND1034-1 Thank you for your comment. Impacts on wildlife are addressed
in section 4.6 of the EIS.

IND1035 Diane Trudeau, page 1 of 1

IND1036 Lannie Tucker, page 1 of 1

IND1037 Lesa Tyson, page 1 of 1

IND1038 Tandie Van Den Berg, page 1 of 1

IND1039 Jane Leatherman Van Praag, page 1 of 1

IND1040 Jason Vandever, page 1 of 1

IND1041 Gumecindo Villanueva, page 1 of 1

IND1042 Lois Wagensell, page 1 of 1

alternatives.

IND1043 Susan Waskey, page 1 of 1
IND1043-1 See response to comment CO007-003. Discussion of GHG and

climate change can be found in section 4.13.3.9.

IND1044 Debra Watson, page 1 of 1

IND1045 Eileen Welch, page 1 of 1

IND1046 Beth Wernick, page 1 of 1

IND1047 Becky Wharton, page 1 of 1

IND1048 Mauri Williams, page 1 of 1

IND1049 Twila Willis, page 1 of 1
environmental resources including water and wildlife.

IND1050 Ellen Willmore, page 1 of 1

IND1051 Dog Wood, page 1 of 1
environmental and socioeconomic resources. Also see response to comment
IND09-014.

IND1052 J.E. Yee, page 1 of 1

IND1053 Tracy Zadwick, page 1 of 1

IND1056 Katelyn Aguirre, page 1 of 3

IND1056-9 See response to comment CO10-73 and CO10-75.


IND1059 Dennis Bates, page 1 of 3
IND1059-1 Thank you for your comment. The Project description is provided
in section 2 of the EIS.
IND1059-2 Impacts on marine resources are addressed in section 4.6.2 of the

EIS.
IND1059-3 The Project purpose is provided in section 1.1 and the description
and evaluation of alternatives is provided in section 3 of the EIS.
IND1059-4 Conclusions and recommendations associated with the proposed

Project are provided in section 5 of the EIS.

IND1059-8 Impacts on public services are addressed in section 4.9.8 of the

EIS. Reliability and safety is addressed in section 4.12 of the EIS. See also
IND1059-9 See response to comment IND20-6; and responses to comments

IND14-6 and PM1-142.
IND1059-11 See responses to comments CO10-73 and CO10-75.
IND1059-12 See responses to comments IND13-1 and IND13-2

IND1059-13 See responses to comments IND9-14a and IND15-1.
IND1059-14 See responses to comments CO6-8 and CO4-8.

IND1060 Lydia Beckham, page 1 of 3
IND1060-6 Potential impacts on public services are addressed in section 4.9.8

of the EIS. Discussion of GHG and climate change can be found in section
4.13.3.9.

IND1060-7 See response to comments IND20-6 and PM1-142.


IND1063 Joseph Cantu, page 1 of 3



IND1064 Alejandro Flores, page 1 of 3



IND1065 Karen Carbiener, page 1 of 3



IND1067 Roel Cepeda, page 1 of 1

IND1069 Dora Garcia, page 1 of 3



IND1071 Reta Durham, page 1 of 5
IND1071-2 Potential impacts on recreation and tourism and related businesses

are addressed in sections 4.8 and 4.9 of the EIS.
IND1071-5 Potential impacts on the commercial fishing industry are


IND1071-8 Evaluating potential impacts on the price of electricity is outside

the scope of this EIS.




IND1072 Esther Martinez, page 1 of 3



IND1073 Elizabeth Perez, page 1 of 3



IND1074 Joshua Ekrut, page 1 of 3



IND1075 Nicole Ekstrom, page 1 of 3



IND1076 Fancy Fairchild, page 1 of 3
IND1076-1 Concerns related to facility safety are addressed in section 4.12 of

the EIS. The Annova LNG Project does not include a pipeline. See response to
comment IND1060-6, which addresses the socioeconomic concerns identified
here.



IND1077 Tabatha Ferguson, page 1 of 3



IND1078 Pearl Fry, page 1 of 3



IND1080 Maria Galasso, page 1 of 3



IND1084 Shayla Gonzalez, page 1 of 3



IND1086 Carly Hamilton, page 1 of 3
IND1086-1 Potential impacts on wildlife are addressed in section 4.6 of the

EIS.



IND1088 Elizabeth Head, page 1 of 3



IND1090 Frank Hobin, page 1 of 3



IND1091 Larry Hollmann, page 1 of 4
IND1091-1 Estimated impacts on air quality are addressed in section 4.11 of

the EIS.
IND1091-2 Potential impacts on turtles are addressed in sections 4.6 and 4.7
of the EIS.
IND1091-3 Potential impacts on jaguarundi and ocelot are addressed in

IND1091-4 Potential impacts on wildlife are addressed in section 4.7 of the

EIS.




IND1092 Javier Guerra, page 1 of 3



IND1094 Dianne Johnson, page 1 of 3
IND1094-1 Thank you for your comment. Please see the below responses.



IND1095 Steven Lanoux, page 1 of 2
IND1095-2 Potential impacts on wildlife are addressed in sections 4.6 and 4.7
of the EIS.
IND1095-3 The effects of dredging on aquatic wildlife is addressed in section

4.7 of the EIS.
IND1095-4 The Project description including a description of the operations

requirements for the proposed facility is provided in section 2 of the EIS.
IND1095-5 The dredging plan is described in section 2.6.2.1 of the EIS. It is

not clear what the commenter means by understated. Impacts on transportation
and traffic are provide in section 4.9.10 of the EIS. Section 4.13.3.7 of the final
EIS has been modified to clarify that construction traffic for the Annova LNG
Project would primarily use SH4 rather than SH48.
IND1095-6 Reliability and safety including a discussion of design of the

Project for hurricane force winds is provided in sections 4.12, 4.12.5.6, and
4.12.5.8 of the EIS.

IND1095-8 Security procedures and requirements are addressed in section

4.12 of the EIS.

IND1098 John MacFarlane, page 1 of 5
IND1098-5 Potential impacts and avoidance steps to nesting birds are

addressed in sections 4.6.1.2 and 5.1.6. See also response to comment CO6-11.

IND1098-7 Ambient air quality impacts quantified and discussed in section

4.11 of the EIS. These are compared to the NAAQS. See also response to
comment PM1-2.


of the EIS. Climate change is addressed in section 4.13.3.9.



IND1100 William McKinney, page 1 of 3



IND1103 Richard Mendoza, page 1 of 3



IND1104 Leslie Burr, page 1 of 3



IND1105 Melissa Perez, page 1 of 3



IND1106 Robert Garcia, page 1 of 3

IND1106-11 See response to comments CO06-004, IND9-14a and IND15-1.

IND1106-12 See response to comments CO4-8, CO6-8 and CO4-8.

Impacts on special status species are addressed in section 4.7 of the EIS.

IND1107 Carol Midboe, page 1 of 3



IND1108 Angel Ramirez, page 1 of 3



IND1109 Louise Reavis, page 1 of 3



IND1110 Jennifer Rodriguez, page 1 of 3



IND1111 Tom Sagona, page 1 of 3



IND1113 Ceclia Sanchez, page 1 of 3



IND1114 Theresa Speck, page 1 of 3



IND1115 Laurel Steinberg, page 1 of 3



IND1117 Sergio Trevino, page 1 of 3



IND1119 Lucinda Wierenga, page 1 of 3

of the EIS. Discussion of GHG and climate change can be found in
section 4.13.3.9.



IND1120 Steve Wilder, page 1 of 3
IND1120-2 Thank you for your comment. Section 4.12 of the EIS addresses
reliability and safety aspects of the Project.


section 4.13.3.9.

IND1120-12 See response to comments IND9-14a and IND15-1. See also

response to comments CO6-8 and CO4-8.

IND1121 Bradley Willis, page 1 of 3

section 4.13.3.9.



IND1122 Oscar Zertuche, page 1 of 3

of the EIS. Discussion of GHG and climate change can be found
in section 4.13.3.9.



IND1123 Tom Sagona, page 1 of 1
IND1123-2 The air quality analysis for the Project, including emissions of
greenhouse gas emissions, can be found in section 4.10 of the EIS.

IND1124 Isidro Leal, page 1 of 2
wind or other renewable energy project cannot meet the purpose
IND1124-3 The Annova LNG Project does not include construction of a

pipeline.

IND1124-4 The Annova LNG project does not include construction of a

pipeline. Based on surveys and information known to date,
including consultation with the Texas Historical Commission, the
Annova LNG Project would not impact any known indigenous
cultural sites. See further detail in section 4.10 of the EIS.

IND1125 Xandra Leal, page 1 of 2
IND1125-2 The Annova LNG Project does not include the construction of a
pipeline.
IND1125-4 The Annova LNG Project does not include the construction of a
pipeline.


consultation with the Texas Historical Commission, the Annova
LNG Project would not impact any known indigenous cultural
sites. See further detail in section 4.10 of the EIS. See also

IND1126 Ava Leal, page 1 of 2

sites. See further detail in section 4.10 of the EIS. See also response
to comment IND20-6.

IND1126-3 Potential impacts of the Project on plants, animals, and ecosystems,

are assessed in section 4.6 and 4.7 the EIS.
IND1126-5 See response to comment PM1-142.
IND1126-6 As stated in section 3.1 of the EIS, wind or other renewable energy
project cannot meet the purpose for the Project and are not considered or
evaluated as alternatives. See also response to comment IND9-14.

IND1127 Michael Baguio, page 1 of 1

IND1128 Laura Baguio, page 1 of 2
IND1128-1 Thank you for your comment. See response to comment CO10-57
pertaining to ocelot.
IND1128-2 See response to comments CO4-3, CO10-39, and PM1-38.


IND1129 Juan Mancias, page 1 of 2


sites. Additionally, section 4.10.2 indicates that the Unanticipated
Discovery Plan has been completed and approved by SHPO and
FERC and will be implemented for the Project. Section 4.10.3
describes Tribal consultation carried out for this Project.
IND1129-5 See comment response CO4-8.



IND1132 James Tucker, page 1 of 1

IND1133 Jennie McBride, page 1 of 1
and the local economy is evaluated in section 4.9 of the EIS. Also
see comment responses CO10-39 and PM1-38.
IND1133-2 Thank you for your comment. Section 4.12 of the EIS addresses
reliability and safety aspects of the Project.

IND1134 Ed McBride, page 1 of 1

IND1135 Mary Volz, page 1 of 2

IND1135-3 Potential impacts on socioeconomics and public services are

IND1135-4 Section 4.12 of the EIS addresses reliability and safety aspects of
the Project.
IND1135-5 Potential impacts of the Project on plants, animals, and ecosystems

are assessed in the EIS.
IND1135-6 The Annova LNG Project does not include construction of a

pipeline.

IND1137 Grant Wilson, page 1 of 1

IND1140 Angel Ramirez, page 1 of 3

of the EIS. Discussion of GHG and climate change can be found in section
4.13.3.9.



IND1144 Christy Tovar, page 1 of 3

IND1144-4 See comment response CO4-8.
and the local economy is evaluated in section 4.9 of the EIS. See
response to comment CO4-3 regarding sediment into Bahia
Grande. See section 4.12 for analysis of Brownsville Ship Channel
traffic impacts. See response to comments CO10-9 and PM1-38
regarding the shrimping industry.
IND1144-6 See response to comments IND14-6, IND15-6, CO4-8, CO10-65,

and CO10-32.


IND1145 Drue Ann Wise, page 1 of 3

section 4.13.3.9.



IND1147 Elizabeth Freeth, page 1 of 3
IND1147-2 Thank you for your comment. The socioeconomic analysis is found
in section 4.9 of the EIS.

of the EIS.


section 4.13.3.9.


IND1149 Ian Martinez, page 1 of 3

section 4.13.3.9.



IND1153 John Ferrell, page 1 of 3

section 4.13.3.9..



IND1155 Julia Jorgensen, page 1 of 3

section 4.13.3.9.



IND1157 Katie Lavallee, page 1 of 3




IND1158 Leslie Wilder, page 1 of 3

section 4.13.3.9.



IND1159 Lucinda Wierenga, page 1 of 3




IND1162 Marie Hines, page 1 of 3




IND1163 Mario Rodriguez, page 1 of 3

section 4.13.3.9.



IND1164 Michelle Piette, page 1 of 3

section 4.13.3.9.



IND1168 Oscar Rodriguez, page 1 of 3

section 4.13.3.9.



IND1170 Robert Garcia, page 1 of 3




IND1172 Robert Radnik, page 1 of 3


IND1172-7 IND1170-7 See response to comments IND20-6 and PM1-142.






IND1175 Vanessa Hernandez, page 1 of 3

section 4.13.3.9.



IND1176 Victor Alvarez, page 1 of 3

section 4.13.3.9.



IND1178 Yvonne Martinez, page 1 of 3

section 4.13.3.9.



IND1179 John Young, page 1 of 8

IND1179-2 This comment is specific to the TCEQ permit review process.
IND1179-3 If the Project is approved, Annova would be required to adhere to

any statement or commitment made as part of in its application or subsequent
filings. In addition, any FERC staff recommendation made in the EIS, if adopted
by the Commission would become a condition of approval. See our
recommendation Number 1 in section 5.2 of the EIS.


Responding to comments on the TCEQ rules and procedures for permit review
is beyond the scope of the EIS.

IND1179-8 Thank you for your comment. This comment is specific to the Rio
Grande project.
IND1179-9 This comment is specific to the TCEQ rules and procedures for
permit review of the Rio Grande project which is beyond the scope of this EIS.

IND1179-10 This comment is specific to the TCEQ rules and procedures for
permit review of the Rio Grande project which is beyond the scope of this EIS.
IND1179-11 Cumulative impacts including greenhouse gas emissions are

addressed in section 4.13 of the EIS. Responding to comments on the TCEQ
rules and procedures for permit review is beyond the scope of the EIS.

IND1179-12 Responding to comments on the TCEQ rules and procedures for

permit review is beyond the scope of the EIS.

IND1179-13 Responding to comments on the TCEQ rules and procedures for

permit review is beyond the scope of the EIS.

IND1180 Kenneth Teague, page 1 of 2

IND1180-1 The potential for the Project to impact seagrasses from

turbidity caused by dredging is addressed in section 4.3.2.2 and 4.6.2 of the EIS.
The final EIS has been updated in response to this and similar comments on the
EIS to acknowledge the potential for seagrass to occur within the Bahia Grande.
IND1180-3 See response to IND1180-1. Also, as stated in section 4.3.2.2

of the EIS, Annova has committed to prepare and implement a Dredging Water
Quality Monitoring Plan that would include use of BMPs during dredging and
would require monitoring of turbidity, flow rate, pH, and TSS at locations near
dredging operations. If monitoring indicates that TSS or turbidity levels exceed
the limits established by the plan or the COE or EPA permit requirements,
Annova would implement additional measures as appropriate.

Document Content(s)
Annova LNG FEIS Volume I_CP16-480.PDF.................................1-484
Annova LNG FEIS Volume II_CP16-480_App A-K and M.PDF..................485-733
Annova LNG FEIS_App L_Comment Resp-part 1.PDF.........................734-1570
Annova LNG FEIS_App L_Comment Resp-part

2.PDF.........................1571-2306

Annova Final EIS

Hochgeladen von

Dokumentinformationen

Copyright

Verfügbare Formate

Dieses Dokument teilen

Dokument teilen oder einbetten

Freigabeoptionen

Stufen Sie dieses Dokument als nützlich ein?

Sind diese Inhalte unangemessen?

Copyright:

Verfügbare Formate

Annova Final EIS

Hochgeladen von

Copyright:

Verfügbare Formate

20190419-3027 FERC PDF (Unofficial) 04/19/2019

Federal Energy Regulatory Commission

ANNOVA LNG BROWNSVILLE PROJECT

Annova LNG Common Infrastructure, LLC Docket No. CP16-480-000

U.S. Army Corps

U.S. Department U.S. Department of National Oceanic and Federal Aviation

FEDERAL ENERGY REGULATORY COMMISSION

OFFICE OF ENERGY PROJECTS

TO THE INTERESTED PARTY:

 pipeline meter station;

Annova LNG Brownsville Project

Utilities ............................................................................................................ 2-8

3.7.2 DMPA 4A and DMPA 4B ............................................................................. 3-24

iii Table of Contents

4.9.2 Economy and Employment ......................................................................... 4-129

5.1.13 Cumulative Impacts ....................................................................................... 5-12

Number Title Page

Table 4.9.2-3 Estimated Annual Economic Impacts of Project Operation............................... 4-131

vii Table of Contents

Table of Contents viii

Number Title Page

Appendix A Distribution List for the Notice of Availability

TECHNICAL ACRONYMS AND ABBREVIATIONS

AADT average annual daily traffic

xi Acronyms and Abbreviations

Acronyms and Abbreviations xii

FIS Flood Insurance Study

xiii Acronyms and Abbreviations

Acronyms and Abbreviations xiv

NOAA Fisheries National Oceanic and Atmospheric Administration National Marine

xv Acronyms and Abbreviations

SGCN species of greatest conservation need

Acronyms and Abbreviations xvi

ES-1 Executive Summary

• gas pretreatment facilities;

Executive Summary ES-2

ES-3 Executive Summary

Executive Summary ES-4

Adherence to measures contained in Annova’s Procedures would adequately address

Wildlife and Aquatic Resources

ES-5 Executive Summary

would minimize impacts on wildlife through implementation of TPWD recommendations during

Threatened, Endangered, and Other Sensitive Species

Measures proposed by Annova to minimize impacts on federally and state-listed species

Executive Summary ES-6

Land Use, Recreation, and Visual Resources

ES-7 Executive Summary

Air Quality and Noise

Executive Summary ES-8

Reliability and Safety

ES-9 Executive Summary

We conducted a preliminary engineering and technical review of the Annova design,

Executive Summary ES-10

ES-11 Executive Summary

Executive Summary ES-12

ES-13 Executive Summary

Executive Summary ES-14

• the LNG Terminal design would include acceptable layers of protection or

In addition, we developed site-specific mitigation measures that Annova should implement

ES-15 Executive Summary

As part of the Commission’s consideration of the application, we 1 prepared this EIS to

Figure 1-1 Annova LNG Brownsville Project General Location

Figure 1-2 General Site Plan for Proposed Facilities

AGENCY PURPOSE AND SCOPE OF THE EIS