Comments to US Army Corps on the 404 Supplement
for Jordan Cove LNG and the Pacific Connector Gas Pipeline

Overview

The US Army Corps of Engineers (USACE) has opened a supplemental comment period because of changes to the proposed dredging for Jordan Cove LNG project and the change in the pipeline route to the Blue Ridge Variation. The comment period is related to impacts from movement of soils in and around waterways. Your comments are needed to encourage USACE to deny the Clean Water Act Section 404 permit and the Rivers and Harbors Act Section 10 and 14 permits (together called “404/10/14 permit”).

The original comment period was open May 22 through July 21, 2018, but even if you submitted a comment on the 404/10/14 permit last year, you should still submit a supplemental comment by September 23. It is clear that this project would harm waterways and is not in the public interest.

Submit a Comment

Comments must be received by Sept 23th 2019, 5 PM. (Extended from Aug 24th, 2019)

Submit by email:

  1. Include NWP-2017-41 in the subject line

  2. Include your full name and address in the email

  3. Must be sent from the author’s email account

  4. Send to NWP-2017-41@usace.army.mil

Submit by post mail:

  1. Use attached template to write your letter, including your name and address

  2. Address and mail to:

  3. US Army Corps of Engineers
    North Bend Field Office
    2201 North Broadway, Suite C
    North Bend, Oregon 97459-2372

For questions regarding the Corps Regulatory authorities and evaluation, contact: Tyler Krug, (541) 756-2097, Tyler.J.Krug@usace.army.mil

What to Write

The goal of our comments is to show why the pipeline route on the Blue Ridge Variation and the dredging in Coos Bay are contrary to the public interest. Mention how your life, business, water supply, and/or property value would be impacted by the proposal.

Information about the proposed Blue Ridge Variation pipeline section:

  • Crosses 29 intermittent (seasonal) and 30 perennial (year-round) waterways.

  • Crosses 53 private land parcels.

  • Crosses 1.9 acres of wetland.

  • Results in permanent and temporary vegetation removal around waterways, increasing the water temperature, erosion, and sediment, which the state is required to protect because they are important to fish and other aquatic life.

  • Blasts or power hammers waterways with bedrock to bury the pipeline, which FERC admits will likely permanently alter the stream and the habitats it provides. It could also change groundwater resources such as wells or springs.

  • Includes regular herbicide spraying and mowing to keep the right-of-way clear.

  • Pembina has put very little effort into research about the impacts of construction on private wells and springs.

  • The route maps on the Blue Ridge Variation that were submitted in 2019 still show property ownership from 2013.

  • Pembina has not provided updated maps showing which private roads the construction trucks would use.

  • Please add details about your local area: erosion, slides, narrowness of roads, reliance on specific roads for access, etc.

Dredging impacts will influence the whole Coos Bay area and economy:

  • Pembina has not submitted a Dredging Pollution Prevention Plan.

  • The Coos Bay dredging areas, and the estuary generally, are used extensively by “recreational” boaters, including for fishing. In 2005, recreational boaters took 30,996 boat trips in Coos Bay and engaged in 36,547 use-days of boating activity. Approximately 88% of these use days were related to fishing (Oregon Department of Fish and Wildlife).

  • Fisheries are important to the Coos Bay economy: Fish and shellfish caught in Charleston is 2016 exceeded $18.8 million in value (ODFW).

You may also talk about impacts, including cumulative impacts, to the following topics. The US Army Corps must consider all of these in their permit decision:

  • Navigation

  • Shoreline erosion

  • Recreation

  • Water supply

  • Water quality

  • Energy needs

  • Safety

  • Food and fiber production

  • Mineral needs

  • The needs and welfare of the people

  • Endangered species

  • Conservation

  • Economics

  • Aesthetics

  • Environmental concerns

  • Wetlands

  • Historic properties

  • Fish and wildlife values

  • Flood hazards

  • Floodplain values

  • Land use

  • Property ownership


For comment assistance, contact:   Maya Jarrad (541) 841-2330 maya@noLNGexports.org

Sample Letter (copy and paste into an email):

Date: _______________________

Dear Mr. Tyler Krug,

Please accept these comments on the supplemental information for permit application number NWP-2017-41.

Please deny the Clean Water Act Section 404 permit and the Rivers and Harbors Act Sections 10 and 14 permits because the project does not comply with the 404(b)(1) Guidelines, is not in the public interest, will negatively impact wetlands, interferes with access to or use of navigable waters, will not obtain the required state and local authorizations or certifications, will impair floodplain function and values, will harm Oregon’s and the nation’s economy, and the application doesn’t include the information to show that it will sufficiently protect these interests.

I have property located at ___________________________________________________. I am impacted by the proposed project and thus I have a direct and personal interest in the proceeding, including rights to property, safety, and to a livable environment, which would be directly and negatively impacted if you approve the permit.

My concerns about the project are:

[Write your comments here]

Sincerely,  

Name:     __________________________________________

Address:  __________________________________________

__________________________________________________

__________________________________________________