14
February 23, 2018 Ms. Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, D.C. 20426 Re: Sabine Pass LNG, L.P. Request to Initiate NEPA Pre-Filing Process for SPLNG Third Berth Expansion Project Docket No. PF18- ___- 000 Dear Ms. Bose: Pursuant to the requirements of 18 C.F.R. § 157.21, 1 Sabine Pass LNG, L.P. (“SPLNG”) hereby requests that the Federal Energy Regulatory Commission (“Commission” or “FERC”) initiate the Commission’s National Environmental Policy Act (“NEPA”) 2 pre-filing review of a new marine berth (“Third Berth”) that is proposed as part of the existing Sabine Pass LNG facility located in Cameron Parish, Louisiana on the Sabine Pass Channel. (“SPLNG Third Berth Expansion Project” or “Project”). In compliance with the Commission’s mandatory pre-filing procedures, SPLNG submits the following: 1. Project Schedule 3 SPLNG anticipates filing its formal application pursuant to Section 3 of the Natural Gas Act (“NGA”), 4 no later than September 7, 2018, and will respectfully request that the Commission issue an Order authorizing the siting, construction and operation of the Project no later than January 2020. SPLNG anticipates filing its Project Implementation Plan no later than March 2020 and requesting authorization to commence construction by April 2020. SPLNG anticipates a construction schedule of approximately 33 months to completion. 1 18 C.F.R. § 157.21 (2017). 2 42 U.S.C. § 4332 (2012). 3 18 C.F.R. § 157.21(d)(1). 4 15 U.S.C. § 717b (2012).

February 23, 2018 Ms. Kimberly D. Bose Federal Energy .... Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, D.C. 20426 ... • Tie-in

  • Upload
    vonhu

  • View
    214

  • Download
    0

Embed Size (px)

Citation preview

February 23, 2018

Ms. Kimberly D. Bose Secretary Federal Energy Regulatory Commission 888 First Street, NE Washington, D.C. 20426

Re: Sabine Pass LNG, L.P.

Request to Initiate NEPA Pre-Filing Process for SPLNG Third Berth Expansion Project Docket No. PF18- ___- 000

Dear Ms. Bose:

Pursuant to the requirements of 18 C.F.R. § 157.21,1 Sabine Pass LNG, L.P. (“SPLNG”) hereby requests that the Federal Energy Regulatory Commission (“Commission” or “FERC”) initiate the Commission’s National Environmental Policy Act (“NEPA”)2 pre-filing review of a new marine berth (“Third Berth”) that is proposed as part of the existing Sabine Pass LNG facility located in Cameron Parish, Louisiana on the Sabine Pass Channel. (“SPLNG Third Berth Expansion Project” or “Project”).

In compliance with the Commission’s mandatory pre-filing procedures, SPLNG submits the following:

1. Project Schedule3 SPLNG anticipates filing its formal application pursuant to Section 3 of the Natural Gas Act (“NGA”),4 no later than September 7, 2018, and will respectfully request that the Commission issue an Order authorizing the siting, construction and operation of the Project no later than January 2020. SPLNG anticipates filing its Project Implementation Plan no later than March 2020 and requesting authorization to commence construction by April 2020. SPLNG anticipates a construction schedule of approximately 33 months to completion.

1 18 C.F.R. § 157.21 (2017). 2 42 U.S.C. § 4332 (2012). 3 18 C.F.R. § 157.21(d)(1). 4 15 U.S.C. § 717b (2012).

Proposed Project Schedule

Key Milestone Activities Anticipated Schedule

Submit Request to Initiate Pre-filing Review Process February 23, 2018

File NGA Section 3 Application September 7, 2018

Issuance of Environmental Assessment October 2019

Issuance of Authorization January 2020

File Initial Implementation Plan March 2020

2. Zoning and Availability5 The Project is located in Cameron Parish, Louisiana, adjacent to the Sabine Pass Channel. The Third Berth will be located in a berth pocket to be dredged from SPLNG controlled land located east of the existing SPLNG marine berth. This area is undeveloped land in the coastal floodplain, Zone VE. A map of the SPLNG Third Berth Expansion Project is included as Attachment 1.

3. Project Description6 The SPLNG Third Berth Expansion Project will be sized to accommodate 125,000 m3 to 185,000 m3 capacity vessels. The Project includes tie-ins to the existing liquefied natural gas (“LNG”) facility and also includes the addition of piping, piperacks, utilities, and other additional infrastructure to transport the LNG to the new tie-ins and the Third Berth.

The Third Berth will be located in a berth pocket to be dredged from SPLNG controlled land located east of the existing SPLNG marine berths. The new marine facility consists of one jetty with LNG loading and LNG vapor return lines. The facility will be designed with the capability of loading approximately 12,000 m3/hr of LNG to the Third Berth.

Project components under consideration include:

• New marine berth (Third Berth)

• Tie-in to existing boil-off gas system

• LNG loading system

o Two 30-inch LNG tie-in lines

o New piperack

o Loading platform

o One LNG loading dock with four 20” loading arms

o Elevated fire monitor tower

• Sewage treatment facilities for jetty

• Spill containment facilities

5 18 C.F.R. § 157.21(d)(3). 6 Id. § 157.21(d)(4).

• Tie-ins to existing firewater system

• Tie-ins to existing plant air and instrument air system

• Tie-in to existing potable water system

• Tie-in to existing nitrogen distribution system

• New marine jetting building

• New customs/security building

• Telecoms, IT, CCTV and other systems

4. List of Relevant Federal and State Agencies in the Liquefaction Project Area with Relevant Permitting Requirements, and Statement Indicating Agency Awareness of SPLNG’s Intention to Use Pre-Filing Process (including contact names, phone numbers, and whether agencies agree to participate in this process)7

Attachment 2 identifies the federal and state agencies that have some form of review and/or permitting authority over the SPLNG Third Berth Expansion Project. For the most part, SPLNG intends to pursue such authorizations concurrent with the instant Commission process and expects to submit to the relevant agencies all applications for federal authorizations no later than September 7, 2018. SPLNG anticipates that the relevant agencies will issue their respective federal authorizations in accordance with the schedule set by the Commission pursuant to Section 157.9 of the Commission’s regulations.8 SPLNG has informed those agencies about this pre-filing review request, including the Project schedule, and requested the agencies feedback on whether they intend to participate in the pre-filing review process; such responses are pending. The Louisiana Department of Natural Resources (“LDNR”) has been designated as the lead state agency by the Governor of Louisiana to consult with the Commission regarding state and local safety considerations.

5. List and Description of the Interest of Other Persons/Organizations Contacted about the Project9

SPLNG initiated its public outreach program for the SPLNG Third Berth Expansion Project in February 2018. Since that time, SPLNG has had discussions with numerous agencies (federal, state and local), individuals, groups and organizations regarding the Project’s potential effects on the environment, its relationship with the community during construction and operation, and public safety issues. SPLNG will continue to meet with various groups and individuals regarding the SPLNG Third Berth Expansion Project as outlined in the Public Outreach Plan discussed below.

7 Id. § 157.21(d)(5). 8 Id. § 157.9. 9 Id. § 157.21(d)(6).

6. Project Work Already Done10

To date, SPLNG has already initiated various planning and development work for the Project, including:

• Public Officials contacts: SPLNG representatives began contacting federal, state, and local public officials in February 2018 regarding the proposed Project.

• Landowner contacts: The Project is located on property owned or controlled by SPLNG. SPLNG is communicating by letter with landowners adjacent to the proposed Project.

• Non-Governmental Organization contacts: SPLNG has identified environmental and non-environmental non-governmental organizations (“NGOs”) that might have interest in the Project. SPLNG plans to contact these organizations during the Pre-Filing process.

• Agency consultations: SPLNG has identified the applicable review agencies, including the United States Army Corps of Engineers, the United States Fish and Wildlife Service (“USFWS”), the Louisiana Department of Wildlife and Fisheries, the Louisiana Department of Environmental Quality, LDNR, the Louisiana Department of Culture, Recreation, and Tourism (“LCRT”), and various Federally Recognized Tribes who have an interest in the Project. SPLNG representatives have contacted the listed agencies introducing the Project and requested feedback on whether the agency is interested in participating in the Pre-Filing process.

• Project Engineering: SPLNG has defined the facilities required for the Project. • Contractor Engagement: SPLNG has been working with the following contractors to perform

various engineering and project studies: (i) Bechtel: to provide engineering and design for the Project; (ii) Burns and McDonnell: to conduct biological and cultural resource surveys, prepare

environmental Resource Reports, and obtain environmental permits and clearances; (iii) Lanier and Associates: to perform marine shipping studies; (iv) Lanner Group Ltd: to conduct Throughput and ADP modeling; (v) Maritime Institute of Graduate Studies (MITAGS): to perform Full Mission Ship

Simulation; (vi) Moffatt & Nichol: conducting Metocean, Dredge Plume Dispersion and Sedimentation

Study; (vii) Tolunay-Wong Engineers, Inc.: to perform Geotechnical Investigation Studies (viii) Lettis Consultants: to perform seismic, tsunami, and geological hazard assessment.

• Environmental Surveys: The Project area has a Jurisdictional Determination from the USACE that was issued January 13, 2015. SPLNG anticipates beginning the environmental field surveys in March 2018. Based on the USFWS Information for Planning and Consultation (“IPaC”) report and data from the state natural heritage programs, certain federal- and state-listed species have been identified as potentially occurring in the vicinity of the Project facilities.

• Cultural Resources: Phase I cultural resource surveys were conducted in July 2004 as part of the Sabine Pass LNG Terminal - Phase I Project. The LCRT, accepted the report in January 2005. SPLNG will coordinate with the LCRT to confirm these findings are still valid for the SPLNG Third Berth Expansion Project.

10 Id. § 157.21(d)(7).

• Open Houses: SPLNG is proposing to schedule an Open House in the month of April 2018.

Logistical details will be coordinated with the FERC project manager and selected third-party contractor within seven days of the Pre-Filing acceptance.

7. Third Party Consultant Proposals11 SPLNG widely distributed a request for proposals to potential third-party contractors on February 6, 2018, and received 6 responses. SPLNG is providing to the Commission Staff the response packages from all responding firms, for review and selection, as specified in the August 2016 revision of the Handbook for Using Third-Party Contractors to Prepare Environmental Documents for Natural Gas Facilities and Hydropower Projects (see Attachment 3). Attachment 3 is being filed under seal as Privileged and Confidential information.

8. Acknowledgement: Complete Environmental Report and Complete Application Required at the Time of Filing12

SPLNG acknowledges that a complete Environmental Report and a complete application under Section 3 of the NGA must be submitted to FERC at the time of filing.

9. Public Participation Plan Details13 As part of its public outreach plan, the SPLNG has conducted or will conduct the following activities:

1. Make formal announcements of the SPLNG Third Berth Expansion Project to the local, state, and federal elected officials, and will also notify key special interest groups;

2. Hold follow-up meetings with local, state and federal regulatory agencies previously contacted to identify other stakeholders and to initiate pre-filing activities with each agency;

3. Identify and inform other governmental organizations about the SPLNG Third Berth Expansion Project and address any issues that are raised by the parties represented by these organizations;

4. Identify and meet with key audiences and stakeholder groups, local associations, neighborhood groups and other non-government organizations to inform them about the SPLNG Third Berth Expansion Project and address any issues that may be raised;

5. Hold an open house in order to provide information about the Project to all of the interested state and federal agencies, adjacent tenants, as well as the public;

6. Provide all required support needed for FERC to a conduct public scoping meeting (if required);

7. Pertinent information regarding on the status of the SPLNG Third Berth Expansion Project will be posted on the publicly available website of Cheniere Energy. The website address is (www.cheniere.com) and will be populated with the information listed below:

• A list of public repositories where all project related information, including project maps, will be available for inspection;

11 18 C.F.R. § 157.21(d)(8). 12 Id. § 157.21(d)(10). 13 Id. § 157.21(d)(11).

• Frequently asked questions, with responses (FAQs); • A list of questions and issues raised at open houses and SPLNG’s responses to

each; • Newsletter contents; • Applications filed with the FERC; • Any data requests, and the SPLNG’s response to each; • Environmental documents issued by FERC; and • Other appropriate project related information.

A single point of contact has been established for the SPLNG Third Berth Expansion Project. The contact will be:

Karri Mahmoud Cheniere Energy, Inc. 700 Milam Street

Suite 1900 Houston, TX 77002

Office: (713) 375-5000 E-mail: [email protected]

Through the pre-filing process SPLNG will endeavor to identify and resolve all of the stakeholders’ potential issues and concerns, thereby providing the Commission with an application that can be moved expeditiously through the NEPA process. The Commission’s early assistance in facilitating the NEPA process is greatly appreciated.

10. Submittal to U.S. Coast Guard of Section 33 CFR Part 127.007 Letter of Intent and Preliminary Waterway Suitability Assessment14

SPLNG certifies that a Letter of Intent and Preliminary Waterway Suitability Assessment were submitted to the USCG on January 19, 2018. SPLNG respectfully requests that the Commission initiate the NEPA pre-filing process by March 8, 2018. Should you have any questions about this filing, please feel free to contact the undersigned at (713) 375-5000. Thank you, /s/ Karri Mahmoud Karri Mahmoud Sabine Pass LNG, L.P. Enclosures

Attachment 1 – Map of the SPLNG Third Berth Expansion Project Attachment 2 – Agency permitting table Attachment 3 – Third party consultant proposals (Privileged and Confidential)

14 Id. § 157.21(d)(12).

Attachment 1

© 2017 HERE © 2017 Microsoft Corporation

CHENIERE

CHENIERE

Attachment 2

SPLNG Third Berth Expansion Project Permit Table

Agency/Contact Information Permit Type Point of Contact

Federal Permits

Federal Energy Regulatory Commission (FERC) 888 First Street, NE

Washington, DC 20426 Natural Gas Act (NGA) Section 3 TBD

US Army Corps of Engineers Galveston District

U.S. Army Corps of Engineers 2000 Fort Point Road Galveston, TX 77550

(409) 766-3982

Clean Water Act (CWA) § 10/404 Kim McLaughlin

U.S. Fish and Wildlife Service Louisiana Ecological Services Field Office

646 Cajundome Blvd #400 Lafayette, LA 70506

(337) 291-3100

Endangered Species Act (ESA) § 7 Consultations Brigette Firmin

Migratory Bird Treaty Act NOAA Fisheries

Baton Rouge Field Office c/o Louisiana State University

Military Science Building; Room 266 Baton Rouge, LA 70803-7535

(225) 389-0508

Magnson-Stevens Fisheries Management and Conservation Act Twyla Cheatwood

NOAA - Southeast Regional Office 263 13th Ave. South

St. Petersburg, FL 33701 (727) 824-5312

Section 7 ESA, Marine Mammal Protection Act Rachel Sweeney

U.S. Coast Guard Marine Safety Unit

2901 Turtle Creek Drive; Suite 200 Port Arthur, TX (409) 723-6521

Letter of Intent (LOI) and Waterway Suitability Assessment

(WSA) Captain Jacqueline Twomey

Commanding Officer Notification to the USCG for

Issuance of Notification to Mariners for Dredging Activities

Facility Security Plan (FSP) Federal Emergency Management Agency

(FEMA) Region VI Floodplain Development Review

Office of Pipeline Safety U.S. Department of Transportation

Pipeline & Hazardous Materials Safety Administration

E22-207 1200 New Jersey Avenue, SE

Washington, DC (202) 366-5064

Safety and Security Review Joseph Sieve, General Engineer

SPLNG Third Berth Expansion Project Permit Table

Agency/Contact Information Permit Type Point of Contact U.S. Department of Agriculture Natural

Resources Conservation Service 3737 Government Street

Alexandria, Louisiana 71302 (318) 473-7751

Farmland Protection Policy Act (FPPA)

Charles Guillory, State Soil Scientist

State Permits Office of Coastal Management Department of

Natural Resources Office of Coastal Management

617 North 3rd Street, Suite 1078 Baton Rouge, LA 70802

(225) 342-7953

Coastal Use Permit Christine Charrier

Department of Wildlife and Fisheries La. Natural Heritage Program P.O. 2000 Quail

Drive Baton Rouge, LA 70808

(225) 765-2800

State Threatened and Endangered Species Consultation; Consultations for Bald Eagle and Migratory Birds

Venise Ortego

Mr. Don Dichon Louisiana Department of Environmental Quality /

Office of Environmental Services Waste Permits Division

602 N. Fifth Street Baton Rouge, LA 70802

(225) 219-3181

Permit to Discharge Wastes (Hydrostatic Test Discharge

Permits) Don Dichon

Louisiana Department of Environmental Quality (LDEQ) Office of Environmental Services

Water Quality Division 602 N. Fifth Street

Baton Rouge, LA 70802 (225) 219-3181

401 Water Quality Certification Elizabeth Hill

Louisiana Office of Cultural Development Capital Annex Building

1051 North Third St. Baton Rouge, LA 70804

(225) 342-8165

Section 106 National Historic Preservation Act Cultural Resources

Consultation Rachel Watson

Parish Permits Cameron Parish Permit Office Building Permits

Cameron Parish Floodplain Administrator Courthouse West Annex

148 Smith Circle Cameron, LA 70631

(337) 775-2800

Floodplain Development Permit

Kara Bonsall Coastal Zone Administrator

Federally Recognized Tribes Coushatta Tribe of Louisiana

P.O. Box 10 Elton, LA 70532 (337) 584-1560

Section 106/ Tribal Lands Kassie Dawsey, Section 106 Coordinator

SPLNG Third Berth Expansion Project Permit Table

Agency/Contact Information Permit Type Point of Contact Jena Band of Choctaw

1052 Chanaha Hina Street Trout, LA 71371 (318) 992-2717

Section 106/ Tribal Lands Alina Shively, THPO Officer

Caddo Nation P.O. Box 487

Binger, OK 73009 (405) 656-2345

Section 106/ Tribal Lands Tamara Francis, Chairman

Chitimacha Tribe 155 Chitimacha Loop Charenton, LA 70523

(337) 923-4973

Section 106/ Tribal Lands Melissa Darden, Chairman

Tunica-Biloxi Tribe of Louisiana 150 Melacon Road

Marksville, LA 71351 (318) 253-9767

Section 106/ Tribal Lands Joey P. Barbry, Chairman

Attachment 3

MATERIAL FILED SEPARATELY AS PRIVILEGED AND CONFIDENTIAL INFORMATION