20150908-0216 FERC PDF (Unofficial) 09/08/2015

DEPARTMENT OF THE ARMY QALVESTON DISTRICT, CORPS OF ENQINEERS

P. O. SOX 1225 QALVESTON, TEXAS 77552-1225

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ORIGINAL Policy Analysis Branch

SUBJECT: Pre-Application Consultation for SWG-2015-00110, FERC Docket No. PF15-15-000, Annova LNG Brownsville Project, USAGE Comments Regarding Preliminary Draft Resource Reports 1 and 10 Kimberly D.

Bose

Federal Energy Regulatory Commission (FERC) 888 First Street NE, Room 1A Washington,

DC 20426

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Dear Ms. Bose: O This is in reference to the Annova proposed Annova LNG Brownsvie Project (FERC Docket No. PF15-15-000). Annova is requesting permission to construct a liquefied natural gas production, storage, and export facility on the southern bank of the Brownsville Ship Channel, in Cameron County, Texas. Pursuant to our ongoing pre-application consultations, the Galveston District, U.S. Army Corps of Engineers (CESWG) submits the following comments regarding Preliminary Draft Resource Reports 1 and 10, dated April 24, 2015.

Resource Report No. 1: General Project Description:

1. The General Project

Description, page 1-1, should include a list of impacts to waters of the United States, including wetlands, which are subject to Department of the Army (DA) permitting. This list should also include permanent, and temporary, construction impacbI from permanent and temporary access roads, as well as impacts associated with temporary staging areas, and worksites.

2. Project Purpose

and Objectives Statement in Section 1.2 does not contain sufficient to address DA Permitting requirements for determining project compliance with Section 404(b)(1) Guidelines. To meet these requiremenbI, this section should include a discussion of Basic Project Purpose and Overall Project Purpose. The Basic Project Purpose allows CESWG to determine if the project is water dependent (see 40 CFR 230.10(a)(3)). The Overall Project Purpose is used to identify and evaluate practicable alternatives information

(see 40 CFR 230.10 (a)(2)). CESWG does not concur with the Project Purpose and Need Statement, as currently written. CESWG will coordinate with the applicant and FERC to formulate appropriate Basic and Overall Project Purpose statements for the proposed project, to be incorporated into project documents.

20150908-0216 FERC PDF (Unofficial) 09/08/2015

In Section 1.5.3.2,Marine Facility Construction, describe the method of dredging (hydraulic pipeline dredging and/or mechanical dredging) proposed to be used to perform new work (construction) dredging.

Section 1.5.3.2,Marine Facility Construction, state the proposed bottom depth of the LNG facility basin in feet, Mean Lower Low Water, and state the proposed allowable overdepth in feet, and the proposed advanced maintenance in feet. In

In Section 1.5.3.2,Marine Facility Construction, state specifically which "approved dredged material disposal areas" would be used for new work dredged material placement and/or disposal.

Section 1.6, Operations and Maintenance, state which dredging method(s) would be used to perform maintenance dredging of the marine facility, how much maintenance dredged material would be dredged and what type (sand, silt, clay), at what dredging cycle, and where specifically the maintenance dredged material would be placed. At what slope would the marine facility side slopes be maintained?

Table 1C-1, USAGE Primary Contact column, please remove Nicholas Laskowski's name and contact information, and Robert Jones'ame, and replace them with: Denise Sloan, Regulatory Project Manager, U.S. Army Corps of Engineers, Galveston District Regulatory Division, 2000 Fort Point Road, Galveston, Texas 77550, (409) 766-3962, denise.l.sloani6iusace.armv.mil In Appendix A,

Resource Report No. 10: Summary of Alternatives Section 10.4 Terminal Site Alternatives, should discuss and illustrate, and reference, both "Offsite Alternatives" and "Onsite Alternatives". In Onsite Alternatives, other configurations of project elements on Annova's Preferred Alternative site (the Port of Brownsville Southside tract) are discussed and illustrated.

Section 10.4.1,TIER 1 SITING PROCESS, under the Available land siting criteria, state the minimum number of acres necessary to meet this criteria. In

Figure 10.4-1, Gulf of Mexico LNG Export System Alternatives, the scope of this figure is confusing, since Annova is limiting their alternatives to the south Texas Gulf Coast, yet this figure shows alternative locations, "Potential LNG Liquifaction Projects", as far away as offshore Mississippi. Additionally, the Tier 1 alternative sites shown on Table 10.4-1 are not shown on the figure.

20150908-0216 FERC PDF (Unofficial) 09/08/2015

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4.

In Section 10.4.3,Tier 3 Siting Process, there should be a discussion of each alternative site and why each was chosen, or rejected, as the preferred alternative. Annova's preferred alternative site should be identified as such in the heading, for example "Port of Brownsville Southside Tract (Annova's Preferred Alternative)". Each alternative description should include a discussion of its environmental and jurisdictional impacts, in comparison with the preferred alternative. A statement should be made explaining why the preferred alternative is considered to be the least environmentally damaging practicable alternative. The same should be done for the Onsite Alternatives.

Please reference our file number SWG-2015-00110, in any future correspondence to this project. If you have any questions or concerns, please contact me at 409-766-3962. We can arrange a meeting to discuss the requested information if that is your desire. You may also email me at denise.l.sloanusace.armv.mil. pertaining

Sincerely,

Denise Sloan Regulatory Project Manager

Copies Furnished: Rafael Montag, Federal Energy Regulatory Commission, 888 First Street NE, Room 1A, Washington, DC 20426 Edward Miller, Annova LNG, LLC, Houston, Texas 77010

4 Houston Center, 1221 Lamar Street, Suite 750,

20150908-0216 FERC PDF (Unofficial) 09/08/2015

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