AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Resource Report 10, dated 22 November 2006 (DR3) DR3 Item
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RR10 Section: Comment
General: Correct section numbering in Section 10.4. E.g. Section “10.3.1.2” should be numbered “10.4.1.2 LNG Terminal Expansions.” And Section “10.3.1.3” should be numbered “10.4.1.3 Proposed Terminals.” General: Table and Figure Numbering. Check consistency between numbering in the Table of Contents, text and on the table or figure headings. [E.g. The numbering of Table 10.5.1.3-1 (or -2) is inconsistent between the Table of Contents, text and table heading.] Establish consistency throughout the Resource Report for your table and figure numbering system. That is either start the numbering after the third level heading (e.g. Table 10.5.1-x) or after the fourth level heading (e.g. Table 10.5.1.3-x). 10.3: Footnote 5 on page 4 indicates that the only two proposed import projects in the Mid-Atlantic region are Cove Point and Crown Landing. By your definition on page 2 this list should include Broadwater. 10.4.1.1: On page 10, Freeport, the consortium who are providing construction services are incorrect, the companies are Technip U.S.A. Corp., Saipem Technigaz SA and Zachry Construction Corp. 10.4.1.1: On page 10, “Cheniere” is misspelled as “Chewier” several times. 10.4.1.2: Explain why an expansion of Crown Landing and/or Cove Point would not be a viable alternative to Sparrows Point. 10.5.1.1: Since Crown Landing believes that it has an economically viable project without dredging the navigation channel, explain why in order for an alternative to be economical, Sparrows Point would need to use ships that would require the dredging of the Delaware River.
How Comment Was Addressed
The section numbers have been corrected as appropriate throughout Resource Report 10
Responses Located in Section Number
Section 10.4 and applicable subsections
2
The table and figure numbered has been updated to maintain consistency. The table of contents and lists of figures and tables have been updated as required
Tables and Figures throughout document
3
Broadwater Energy has been included in the footnote.
Section 10.3, Footnote 5
4
The text has been revised to reflect the correct consortium of companies The spelling has been corrected throughout the Resource Report Additional information has been added to Section 10.4.1 to provide more complete analysis of viability of Cove Pt. and Crown Landing as alternatives to this market area. Additional information was added to this section to explain ship fleet makeup applicable to the terminals and related dredge depth
Section 10.4.1.1
5 6
Section 10.4.1.1 Sections 10.4.1.1 and 10.4.1.2
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Section 10.5.1.1
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AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Resource Report 10, dated 22 November 2006 (DR3) DR3 Item
8 1.
RR10 Section: Comment
10.5.1.2: On page 27, AES indicates that alternative sites on the Chesapeake south of Sparrows Point would require an addition “significant length” of pipeline. Please define a “significant length.” 10.5.2.3: Please provide a comparison of the amount of turbidity that could be expected from using the various dredging techniques, during: removal of the material, the deposition of the material at a holding area (or permanent placement area) and from any dewatering. 10.6.3: Although Table 10.6.2-1 provides the detailed comparison of environmental issues for the proposed pipeline route versus each alternative, a summary of the environmental analysis should be placed at the end of the text section for each alternative. Discuss the positive environmental aspects of the preferred route versus the alternative. If the environmental comparison is not biased toward the preferred route, express the most important reason that the Applicant chose the preferred route. If constructability issues or landowner issues are the defining routing factors, state that. 10.6.4: Provide an analysis and conclusion for each route variation. As previously mentioned, greenfield construction should not be the sole reason for rejecting an alternative or variation. Clearly state which, if any, of the variations are preferred over the original route and why. If the environmental comparison was a factor in choosing or rejecting a route variation, state this in the text. 10.6.3.3: AES indicates that Maryland Department of Transportation (MDOT) would have safety timing restrictions during any construction along Interstate 95. Would MDOT have similar restrictions for construction along any other highways, including Interstate 695?
How Comment Was Addressed
Evaluation of potential areas south of Sparrow’s Point that would serve as starting points for sendout pipeline was provided along with minimum length that may be applicable. Information on turbidity levels that may be generated by different dredge techniques and material handling was included in this section. The section has been revised to include a summary of the environmental analysis at the end of each section.
Responses Located in Section Number
Section 10.5.1.2, Footnote 20.
9 2.
Section 10.5.2.3
10
Section 10.6.3
11
The section has been revised to include the requested information for each conclusion
Section 10.6.4
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This section was modified to reflect potential access restrictions that may apply to 695.
Section 10.6.3.3
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AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 § 375.308(x) AES Sparrows Point LNG, LLC and Mid-Atlantic Express, L.L.C. Docket No. PF06-22-000 FERC Staff’s Comments on Draft Resource Report 10, dated 22 November 2006 (DR3) DR3 Item
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RR10 Section: Comment
10.6.3.4: Please provide results of discussions with the U.S. Department of Transportation concerning the pipeline co-location with Interstate 695 and any other federal or federally funded highway. 10.5.1.1: What distance criteria (or value) were used to determine if an LNG berth site would restrict vessel traffic while the LNG vessel is at berth? (I.e. support the statement that Delaware sites would restrict traffic during LNG vessel berthing while the Sparrow Point location will not.) Although within Section 10.5.1.1, subsection “Disruption of Maritime Traffic,” AES discusses this topic, the distance criteria is still not fully explained. For example, within Table 10.5.1.3-2, what led AES to conclude that The Greenbury Alternative and the Fishing Point Alternative might disrupt channel traffic, whereas all the other alternatives including Sparrows Point would minimize disruption to channel traffic. The explanation need not include a numerical limit of distance from a working channel. 10.5.2.2: On page 36, define HTF. NOTE: The reader could benefit from a list of Acronyms and Abbreviations.
How Comment Was Addressed
A summary of discussions regarding co-location has been added Both qualitative and quantitative (approximate distance) criteria discussion has been added relative to berthed vessel restriction distance.
Responses Located in Section Number
Section 10.6.3.4, Appendix B
14
Section 10.5.1.1, Footnote 19
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A list of acronyms and abbreviations has been inserted following the table of contents
After Table of Contents
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