ATTACHMENT AE - North Bend, Oregon · 405 Urban Street, Suite 310, Lakewood, CO 80228 (303)988-8844...

From: King, Seth J. (Perkins Coie)To: Chelsea Schnabel; Kelli BurnetteCc: Jane Stebbins; Pfeiffer, Steven L. (Perkins Coie)Subject: PCGP Early Works Application - Applicant"s Second Open Record Period SubmittalDate: Wednesday, May 8, 2019 4:50:33 PMAttachments: 20190508 Applicant"s Second Open Record Period Submittal.pdf

Attached please find the applicant’s second open record period submittal for the Pacific ConnectorGas Pipeline Early Works land use applications (City of North Bend File Nos. FP 2-18/CBE 3-18). Please place a copy of these materials in the official record for this matter and please place a copybefore the Planning Commission. Thank you for your courtesies. Seth King | Perkins Coie LLPPARTNER1120 N.W. Couch Street Tenth FloorPortland, OR 97209-4128D. +1.503.727.2024M. +1.503.944.9380E. [email protected]

NOTICE: This communication may contain privileged or other confidential information. If you have received it in error, please advise thesender by reply email and immediately delete the message and any attachments without copying or disclosing the contents. Thank you.

ATTACHMENT AE
mailto:[email protected]:[email protected]:[email protected]:[email protected]:[email protected]:%[email protected]

59892-0025/144344946.1

Seth J. King

[email protected]

D. +1.503.727.2024

F. +1.503.346.2024

May 8, 2019

VIA EMAIL TO [email protected]

Ms. Chelsea Schnabel, Director City of North Bend Planning Department PO Box B 835 California Avenue North Bend, OR 97459

Re: Concurrent Land Use Applications for Pacific Connector Gas Pipeline Early Works Alignment - 0.92 of a Mile

City of North Bend File Nos. FP 2-18 and CBE 3-18 Applicant’s Second Open Record Period Submittal

Dear Chelsea:

This office represents Pacific Connector Gas Pipeline, LP (“PCGP”), the applicant requesting approval of concurrent land use applications to construct an interstate natural gas pipeline (“Pipeline”) in City of North Bend File Nos. FP 2-18 and CBE 3-18 (“Applications”). This letter and its enclosures constitute PCGP’s second open record period submittal for the Applications.

Enclosed please find the following materials:

Exhibit 1 - Memorandum from Edge Environmental, Inc. dated May 2, 2019, with one attachment: This memorandum provides expert testimony and explanation to support the following conclusions: (1) the Pipeline will not have adverse impacts on abalone; (2) installation of the Pipeline will not adversely affect salinity levels in the estuary; and (3) installation and operation of the Pipeline will not generate noise at a level that will adversely affect oysters.

Exhibit 2 - Memorandum from PCGP dated May 3, 2019: This memorandum provides explanations in response to the following issues: (1) questions about the HDD installation and operations raised by the Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians in Section 4 of a letter to the City dated April 16,

Chelsea Schnabel, Planning Director May 8, 2019 Page 2

59892-0025/144344946.1

2019 (Attachment U); (2) maintenance of the pipeline sections installed via HDD; and (3) handling and disposal of cuttings produced during HDD construction operations.

Exhibit 3 - Pipeline Alignment Map with Installation Overlay: This map illustrates the Pipeline alignment in the non-CBEMP portions of the City and includes an overlay showing whether the Pipeline will be installed via trenching or boring.

Please place a copy of this submittal into the official record for this file and place a copy before the Planning Commission. PCGP reserves the right to submit additional argument and evidence in this matter consistent with the extended open record schedule established by the Planning Commission and ORS 197.763.

Thank you for your courtesies in this matter.

Very truly yours,

Seth J. King

cc: Steve Pfeiffer (via email) (w/encls.) Client (via email) (w/encls.)

405 Urban Street, Suite 310, Lakewood, CO 80228 (303)988-8844 Phone (303)988-8999 Fax

Edge Environmental, Inc.

MEMO

To: Jimmy Bernabe From: Archie Reeve Date: May 2, 2019 Re: PCGP Coos County Responses

In response to various public comments, the following research has been compiled: Abalone National Marine Fisheries (NMFS), West Coast Region, provides distributions of ESA-listed species on its website: https://www.westcoast.fisheries.noaa.gov/protected_species/species_list/species_lists.html. Two species of abalone, black abalone (Haliotis cracherodi) and white abalone (Haliotis sorenseni) are listed as endangered and are found under “Other ESA-Listed Species” on the website. Three additional abalone species are identified as Species of Concern including pink abalone (Haliotis corrugate), green abalone (Haliotis fulgens), and pinto abalone (Haliotis kamtschatkana). Pink abalone and green abalone are found along coastal Southern California and Baja California in northern Mexico. Pinto abalone is found from California to Sitka, Alaska. Very little is known about the species’ presence along the Oregon coast but one individual was reported on Orford Reef in 2009. Since then a few other pinto abalone have been on the reef and near Port Orford (NMFS Status Review Team 2017). Except for those few records, the Oregon coast appears to be a natural gap in the species range between California and Washington (NMFS Status Review Team 2017). Pink, green, and pinto abalone would not be affected by the Project. Likewise, the two ESA-listed species would not be affected by the Project. White abalone historically occurred from Point Conception, California, to Punta Abreojos, Baja California, in Mexico. The current range of black abalone is estimated to extend from Point Arena, California, south to Bahia Tortugas, Mexico, including offshore islands (NMFS 2018). Neither species occurs within the Project’s estuarine analysis are or marine analysis area as defined in the Applicant Prepared Draft Biological Assessment. References: National Marine Fisheries Service. 2018. Black Abalone (Haliotis cracherodii) Five-Year Status

Review: Summary and Evaluation. NMFS West Coast Region, Long Beach, CA.

Status Review Team. 2014. Status Review Report for Pinto Abalone (Haliotis kamtschatkana). NMFS West Coast Region, Long Beach, CA.

Exhibit 1 Page 1 of 9

2

Bentonite and Salinity Observations of montmorillonite (pure bentonite), Illite, kaolinite, and halloysite clays exposed to seawater reveal that magnesium ions (Mg2+) from seawater moved into the exchange positions in the clays rather than calcium (Ca2+) and sodium (Na+) ions (Carroll and Starkey 1958). Clay minerals react with the cations in seawater through the same kinds of exchange mechanisms that have been found experimentally for electrolytes such as NaOH and KOH. Exposure to seawater showed that replacement of H+ ions in the clay follows the order Ca2+ > Mg2+ > Na+ > K+. However, Mg2+ commonly makes up a larger proportion of the cations in the exchange positions than Ca2+ because there is more magnesium than calcium in seawater. In addition, calcium is tied up in the buffer mechanism of seawater (Carroll and Starkey 1958) provided by the presence of carbonate and borate in seawater. Calcium, not sodium, is the cation mostly affected by the buffering action because of the relation CaCO3 ↔ CaHCO3 ↔ H2C03. This series of reactions affects the availability of Ca2+ ions to enter into the exchange positions of clay minerals (Carroll and Starkey 1958). Bentonite could be exposed to seawater within the Coos Bay Estuary if there were inadvertent returns (frac-out) of bentonite during the HDD process as described in FERC’s Draft EIS. Since concentrations of Na+ in seawater far exceed concentrations of Ca2+, Mg2+, or K+, ion exchange affecting salinity (concentrations of Na+ and Cl-) appears negligible if a frac-out occurred while installing the Pipeline within the Estuary. Further, frac-outs, if they occurred, would be in the brackish water of the Estuary which is a mixture of seawater and fresh water with naturally occurring variation in salinity levels, fluctuating with tides. Reference: Carroll, D., and H.C. Starkey. 1958. Effect of Sea-water on Clay Minerals. Pages 80 to 101, in

A. Swineford (editor). Seventh National Conference on Clays and Clay Minerals. U.S. Geological Survey. Pergamon Press.

HDD Noise and Oysters Sensitivity of Pacific oysters (Magallana gigas) to sounds was examined experimentally by measuring valve (shell) movements when exposed to water-borne sounds in the range of 10 Hz to 20 kHz at various acoustic energy levels (Charifi et al. 2017). At high enough acoustic energy, oysters transiently closed their valves in response to frequencies in the range of 10 to

3

Both studies demonstrated sensitivity by the two mollusks to sounds, whether water-borne or substrate-borne. Horizontal directional drilling (HDD) has been proposed to install the Pipeline beneath the Coos Bay Estuary. All HDD operations would occur within the estuarine substrate and there would be no sounds generated through the water column. Further, HDD operations would not be “audible” to oysters (or mussels) through vibrations transmitted through the substrate. As stated by GeoEngineers (2019): “HDD operations involve successive passes with rotary drilling methods to create a hole through which the carrier pipe is installed. The hole is not created using percussion or impact methods, therefore, vibration levels associated with HDD methods are not typically of a magnitude that can be felt at the ground surface. Moreover, much of the proposed HDD path is situated at depths greater than 100 feet, which reduces the potential for vibrations to be detected by humans or wildlife.” That oysters would “hear” noise (or detect vibrations) produced by HDD beneath the Coos Bay Estuary appears unlikely and insignificant in that any effect to oysters could not be detected or meaningfully measured.

References: Charifi M., M. Sow, P. Ciret, S. Benomar, and J-C. Massabuau. 2017. The sense of hearing in

the Pacific oyster, Magallana gigas. PLoS ONE 12(10): e0185353.https://doi.org/10.1371/journal. pone.0185353

GeoEngineers. 2019. Memorandum: Response to Coos County Land Use Application Public Comment. Geoengineers, Springfield, MO. April 12, 2019.

Roberts L., S. Cheesman, T. Breithaupt, and M. Elliott. 2015. Sensitivity of the mussel Mytilus edulis to substrateborne vibration in relation to anthropogenically-generated noise. Marine Ecology Progress Series 538: 185– 195.



Page 1 Archie F. Reeve

Archie F. Reeve

Education 1984 Ph.D., University of Wyoming, Laramie, Wyoming (Major-Wildlife Ecology; Minor-

Statistics) 1970 M.A., Western Kentucky University, Bowling Green, Kentucky (Major-Secondary

Education; Minor-Biology) 1968 A.B., University of Rochester, Rochester, New York (Major-Biology;

Minors-Chemistry, Psychology) Summary of Professional Experience 2006 - Present Edge Environmental, Inc., Lakewood, Colorado. 2004 - 2006 Senior Environmental Scientist, Golder Associates, Inc., Laramie, Wyoming

and Denver, Colorado. 1992 - 2004 Senior Research Associate, PIC Technologies, Inc., Laramie, Wyoming and

Denver, Colorado. 1988 - 1992 Senior Scientist, Hayden-Wing Associates, Laramie, Wyoming. 1982 - 1983 Research Associate; Department of Zoology and Physiology, University of

Wyoming, Laramie. Cooperative Wildlife Program, Phase I - Literature Review. Overthrust Industrial Association, Denver, Colorado.

1979 - 1982 Principal Investigator; Wyoming Game and Fish Department, University of Wyoming, Laramie. Wildlife Studies - Medicine Bow Wind Energy Project. U.S. Bureau of Reclamation, Denver, Colorado.

1980 - 1981 Evaluation of various wildlife projects for ARCO Coal Mines for Campbell County, Wyoming. Boyce Consulting, Laramie, Wyoming.

1978 - 1979 Evaluation of wildlife sections for mining permits for major energy companies for Mine Reclamation Consultants Inc., Laramie, Wyoming.

Archie has more than 40 years of experience as a professional wildlife biologist, research scientist, educator, manager, and administrator. He obtained a Ph.D. in Wildlife Ecology from the University of Wyoming. He is experienced with a wide variety of wildlife species and habitats, including forest, range, and aquatic ecosystems and has performed wildlife work in nine western states including Alaska. He has designed, conducted, and directed numerous wildlife studies focusing on diverse species. Archie has completed wildlife impact assessments and biological assessments for a liquid natural gas terminal, LNG shipping, and pipeline infrastructure in Oregon, more conventional natural gas pipelines throughout the west coast and Rocky Mountains, coal mines, oil and gas fields, transmission lines, highways, railroads, ski areas, and other development projects. He is well versed in evaluating impacts to threatened and endangered species and other species classified as being of "high interest" to state and/or federal agencies. Archie has authored or co-authored numerous technical reports, public presentations, and scientific publications and continues to provide instruction, academic support, and guidance to students at the University of Wyoming. Selected Project Experience

• Pacific Connector Gas Pipeline Project. BA, FERC F-IV Application for Natural Gas Pipeline in Oregon. Pacific Connector Gas Pipeline, LP.




• Sheep Mountain Uranium Project. EIS, BA. Energy Fuels Resources. Wyoming. • Book Cliff Coal Lease-by-Application. EIS, BA research. Rhino Energy. Colorado. • Pinon Ridge Uranium Mill Project. Environmental Report to Colorado Department of

Public Health and Environment • Whirlwind Uranium Mine Project. EA, BA. Energy Fuels Resources. Colorado. • Parachute Lateral Project. BA, FERC F-IV Application for Natural Gas Pipeline in

Colorado. Northwest Pipeline Corporation. • Pinedale Anticline Oil and Gas Exploration and Development Project. Supplemental

EIS and Wildlife Technical Report, USDI Bureau of Land Management, Pinedale, Wyoming.

• Buckhorn Mountain Project. Habitat Mitigation - Crown Resources Corporation, Kinross Gold USA, Inc. Oroville, WA

• ASU Year-Round Drilling Demonstration Project. Sublette County, Wyoming. Environmental Assessment and Wildlife Technical Report. USDI Bureau of Land Management, Pinedale, Wyoming.

• Havre-Rainbow (Montana) Transmission Line Rebuild Project. Western Area Power Administration, Lakewood, CO.

• Questar Exploration and Production Company Year-round Drilling Proposal. EA and Wildlife Technical Report, USDI Bureau of Land Management, Pinedale, Wyoming.

• BA, EIS, FERC F-IV Applications for Natural Gas Pipeline Expansions in Washington. Northwest Pipeline Corporation.

• Trends in Big Game Populations (mule deer, pronghorn, elk) in Wyoming, Wyoming Cooperative Fish and Wildlife Research Unit.

• Dakota, Minnesota & Eastern Railroad Corporation Powder River Basin Expansion Project EIS, Surface Transportation Board, and USDA Forest Service, Thunder Basin National Grasslands

• Pinedale Anticline Oil and Gas Exploration and Development Project. EIS and Wildlife Technical Report, USDI Bureau of Land Management, Rock Springs District.

• Ponnequin Wind Energy Project. Weld County, Colorado. Environmental Assessment. U.S. Department of Energy, Golden, Colorado.

• Potential for Competitive Interactions Between Mule Deer and Elk in the Western United States and Canada, Wyoming Cooperative Fish and Wildlife Research Unit and Rocky Mountain Elk Foundation.

• Moxa Arch Antelope Study and Mitigation Project. Kemmerer BLM Resource Area Office, Wyoming Cooperative Fish and Wildlife Research Unit, and Wyoming Game and Fish Department, Green River.

• Wildlife Monitoring, Carbon County UCG, Inc. Exploration and Demonstration Project, Rawlins BLM District.

• Birch Creek Gas Field Impacts on Wintering Mule Deer, Pinedale BLM Resource Area Office and Wyoming Game and Fish Department, Jackson.

• Fontenelle Natural Gas Infill Drilling Projects. EIS and Wildlife Technical Report, USDI Bureau of Land Management, Rock Springs BLM District.

• Expansion II Project. FERC F-IV Application, Northwest Pipeline Corporation. • EA, BTA Oil Producers, Bravo Full Field Development, Rock Springs BLM District. • Carbon County UCG, Inc. Exploration and Demonstration Project. EA, Rawlins BLM

District. • Enron Burly Area EIS, Rock Springs BLM District Office. • Saddle Ridge Project. EA, Northwest Pipeline Corporation.




• Mainline Expansion Project. EIS, FERC F-IV Application, Northwest Pipeline Corporation.

• Sheridan Area Water Supply - Joint Powers Board, Twin Lakes Reservoir, Bighorn National Forest, WY.

• Snake River Canyon Project. EIS/BE, Wyoming Highway Department, Bridger-Teton National Forest, WY.

• Cody-Yellowstone Highway Project. EIS/BE, Wyoming Highway Department, Shoshone National Forest.

• Salmon River Highway Project. EA/BA, USDA-Forest Service, Salmon National Forest, ID.

• Aerial and ground surveys for potential black-footed ferret habitat and nesting raptors along pipeline corridors in Colorado, Utah, Wyoming, Idaho, Oregon and Washington, Northwest Pipeline Corporation.

• Farson-Fontenelle Fencing Project. EIS/BE, Wyoming Highway Department, Green River BLM Resource Area.

• Aerial and ground surveys for nesting raptors along seismic lines in Wyoming, Western Geophysical.

• Triton Oil and Gas Association, Big Game Response to Coal Bed Methane Field Development.

• Rocky Mountain Oil and Gas Association, Effects of Oil and Gas Development on Mule Deer, Sage Grouse, and Raptors.

Special Certifications • Certified by the U.S. Fish and Wildlife Service as a biologist qualified to conduct or

supervise field searches for black-footed ferrets. • Wyoming State Department of Education; certified to teach secondary school Biology,

Chemistry, Geology, Psychology, and Art. Professional Societies • American Association for the Advancement of Science • The Wildlife Society • Colorado - Wyoming Academy of Science • Sigma Xi, The Scientific Research Society Publications Reeve, A.F., and T.C. Vosburgh. 2006. Shooting prairie dogs. Pages 119-128 in J.E. Roelle,

B.J. Miller, J.L. Godbey, and D.E. Biggins (editors). Recovery of the Black-footed Ferret – Programs and Continuing Challenges: U.S. Geological Survey Scientific Investigations Report 2005-5293.

Reeve, A.F., and T.C. Vosburgh. 2006. Recreational shooting. Pages 139-156 in J.L. Hoogland (editor). Conservation of the Black-Tailed Prairie Dog. Island Press, Washington, D.C..

Lutz, D.W., M. Cox, B.F. Wakeling, D. McWhirter, L.H. Carpenter, S. Rosenstock, D. Stroud, L.C. Bender, and A.F. Reeve. 2003. Impacts and changes to mule deer habitat. Pages 13-62 in J.C. deVos, Jr., M.R. Conover, and N.E. Headrick (editors). Mule deer conservation: issues and management strategies. Berryman Institute Press, Utah State University, Logan.




White, G.C., A.F. Reeve, F.G. Lindzey, and K.P. Burnham. 1996. Estimation of mule deer winter mortality from age ratios. Journal of Wildlife Management 60:37-44.

Reeve, A.F., and S.H. Anderson. 1993. Ineffectiveness of Swareflex reflectors at reducing deer-vehicle collisions. Wildlife Society Bulletin 21:127-132.

Hayden-Wing, L.D., S.A. Tessmann, R. Rothwell, and A.F. Reeve. 1992. A wetland evaluation process for quantifying changes in waterfowl habitat values in Wyoming. in Proceedings 12 Annual Conference of the National Association of Abandoned Mine Land Programs, Breckenridge, CO.

Reeve, A.F. 1987. Looking for lynx. Wyoming Wildlife 51(2):28-33. Reeve, A.F. 1984. Environmental influences on male pronghorn home range and pronghorn

behavior. Ph.D. dissertation, University of Wyoming, Laramie, Wyoming. 172pp. Reeve, A.F. 1983. Summer home range characteristics of pronghorn males. Journal of the

Colorado-Wyoming Academy of Science 15:137. Reeve, A.F. 1982. Trapping pronghorn at a waterhole: a preliminary report. Biennial

Pronghorn Workshop 10:209-224. Reeve, A.F. 1981. Pronghorn social structure in relation to environmental and population

parameters. Journal of the Colorado-Wyoming Academy of Science 13:59. Reeve, A.F. 1980. Topographic variation as an indicator of potential raptor nesting habitat.

Journal of the Colorado-Wyoming Academy of Science 12:40. Technical Reports Reeve, A.F., F.G. Lindzey, and S.H. Anderson. 2003. Elk populations in Wyoming 1978-2001.

Wyoming Cooperative Fish and Wildlife Research Unit. 138pp. Reeve, A.F., F.G. Lindzey, and S.H. Anderson. 2003. Pronghorn populations in Wyoming 1978-

2001. Wyoming Cooperative Fish and Wildlife Research Unit. 105pp. Ayers, L.W., A.F. Reeve, F.G. Lindzey, and S.H. Anderson. 2000. A preliminary assessment of

mule deer population dynamics in Wyoming. Wyoming Cooperative Fish and Wildlife Research Unit.

Lindzey, F.G., W.G. Hepworth, T.A. Mattson, and A.F. Reeve. 1997. Potential for Competitive Interactions Between Mule Deer and Elk in the Western United States and Canada: A Review. The Rocky Mountain Elk Foundation, Missoula, MT. 82pp.

Reeve, A.F. 1996. Mule deer response to oil and gas well re-completions and winter habitat use on the Birch Creek Unit, Big Piney - LaBarge Winter Range complex during winter, 1990-1991. Bureau of Land Management, Rock Springs District and Wyoming Game and Fish Department, Jackson, WY. 34pp + appendices.

Reeve, A. and P. Krawczak. 1995. Integrating remote sensing and GIS with Bayesian probability models of wildlife habitat to evaluate cumulative impacts. Bureau of Land Management, Rock Springs District, Rock Springs, WY. 79pp.

Reeve, A.F. 1992. Characteristics of bedding sites used by elk during spring migration on the Medicine Bow National Forest, southeastern Wyoming. Wyoming Game and Fish Deptartment, Laramie and Cheyenne, WY. 68pp.

Reeve, A.F., and F.G. Lindzey. 1991. Evaluation of mule deer winter mortality in southcentral Wyoming. Wyoming Cooperative Wildlife Research Unit, Laramie, WY. 147pp.

Reeve, A.F., and L.D. Hayden-Wing. 1991. Review and evaluation of the effect of Triton Oil and Gas Corporation's proposed coal bed methane field development on elk and other big game species. Hayden-Wing Associates, Laramie and Triton Oil and Gas Corp., Dallas, TX. 92pp.




Reeve, A.F. 1990. Issues, information, and alternatives related to fencing Wyoming Highway 28, Farson to Fontenelle. Hayden-Wing Associates, Laramie and Wyoming Highway Department, Cheyenne, WY. 43pp.

Reeve, A.F. 1990. Vehicle-related mortality of big game in Nugget Canyon, Wyoming. Wyoming Cooperative Wildlife Research Unit, Laramie, WY. 127pp.

Reeve, A.F. 1990. Surveys for black-footed ferrets, prairie dog colonies, raptor nests, and sage grouse leks for the Mustang-Spence 230kV Transmission Line. Hayden-Wing Associates, Laramie and Pacific Power & Light Company, Casper, WY.

Reeve, A.F. (editor). 1989. Pronghorn productivity studies in the Fifteenmile Herd Unit. School for Field Studies, Beverly, MA.

Reeve, A.F. 1987. Wildlife monitoring reports, Arch of Wyoming, Inc., Hanna Basin Mines, Wyoming. Hayden-Wing Assoc., Sheridan, WY and Arch of Wyoming, Hanna, WY.

Reeve, A.F., M.D. Marcus, B.R. Parkhurst. 1987. Potential effects of calcium from lake liming on human health. Western Aquatics, Laramie, WY and Living Lakes, Washington, D.C. 43pp.

Reeve, A.F., and F.G. Lindzey. 1987. Winter mortality of mule deer fawns in south central Wyoming. Wyoming Cooperative Fish and Wildlife Research Unit, Laramie, WY. 89pp.

Reeve, A.F., et al. 1987. Volume 5, Environment. Site Proposal-Superconducting Super Collider (SCC), U.S. Department of Energy, Washington, D.C. State of Wyoming, Cheyenne, WY. 70pp.

Reeve, A.F. 1987. Final report: Big game studies on the Gay Mine Expansion Area Fort Hall Reservation, Idaho. Mariah Associates, Laramie, WY and J.R. Simplot Co., Pocatello, ID. 76pp.

Reeve, A.F. 1986. Vehicle-related big game mortality in Nugget Canyon, Wyoming: mitigation alternatives and recommendations. Wyoming Cooperative Fish and Wildlife Research Unit, Laramie, WY. 87pp.

Reeve, A.F., F.G. Lindzey, and S. Buskirk. 1986. Historical and recent distribution of the lynx in Wyoming. Wyoming Game and Fish Department, Cheyenne, WY. 76pp.

Yeo, J., A.F. Reeve, P. MacLaren, and A.L. Travsky. 1984. Final project report - wildlife studies - Medicine Bow Wind energy Project. Wyoming Game and Fish Department and USDI, Bureau of Reclamation, Denver, CO. 151pp.

Boelter, A., A. Reeve, and T. LaPoint. 1984. User's guide for Wyoming hazardous waste inventory system. Prepared for Wyoming Department of Environmental Quality, Solid Waste Management Program. Cheyenne, WY. 13pp.

Ward, J., D. Inkley, A. Reeve, and S. Anderson. 1983. An evaluation of the impact of coal development on white-tailed deer (Odocoileus virginianus) populations in southeastern Montana. Prepared for USDI, Fish and Wildlife Service, Wildlife Research Center, Sheridan, WY. 5pp.

Reeve, A.F., R. Schonholtz, and B. Ackerman. 1983. Cooperative wildlife program -Task 3: local knowledge. Prepared for the Overthrust Industrial Association, Denver, CO. 63pp.

Ward, J.P., D. Inkley, A.F. Reeve, and S. Anderson. 1983. An evaluation of the impact of coal development on mule deer (Odocoileus hemionus) populations in southeastern Montana. Prepared for USDI, Fish and Wildlife Service, Wildlife Research Center, Sheridan, WY. 20pp.

Meyer, J.S., A.F. Reeve, L. Cuthbert-Millett, J.G. Cook, A.L. Brummond, J.P. Ward, and M. Parker. 1983. Bibliography on the effects of human activities on wildlife: emphasizing oil and gas development, forest management, range management, and recreation in the Overthrust Belt of Wyoming, Utah, and Idaho. Prepared for the Overthrust Industrial Association, Denver, CO.




Reeve, A.F., R. Schonholtz, and B. Ackerman. 1983. Cooperative wildlife program - Appendix D, raw data: State literature searches. Prepared for the Overthrust Industrial Association, Denver, CO.

Reeve, A.F. and L. Irwin. 1983. Cooperative wildlife program - Task 5: mitigation of wildlife impacts. Prepared for the Overthrust Industrial Association, Denver, CO. 60pp.

Reeve, A.F. 1983. Cooperative wildlife program - Appendix E: survey of reclamation practices. Prepared for the Overthrust Industrial Association, Denver, CO. 26pp.

Reeve, A.F. and J. Yeo. 1982. The Pan Aero Corporation plan for wind energy development near Medicine Bow, Wyoming: concerns for wildlife. Wyoming Game and Fish Department, Cheyenne, WY. 6pp.

Reeve, A.F. 1982. Annual project report - wildlife studies - Medicine Bow Wind Energy Project. Wyoming Game and Fish Department and USDI, Bureau of Reclamation, Denver, CO. 152pp.

Reeve, A.F. 1981. Observer bias in aerial survey. Boyce Consulting, Laramie, WY. 13pp. Reeve, A.F. 1981. Design and analyses of ARCO's pronghorn surveys, September 3, 1981.

ARCO Coal Company, Denver, CO. 18pp. Reeve, A.F. 1981. Analyses of ARCO's pronghorn censusing program, 1976 to 1981. ARCO

Coal Company, Denver, CO. 18pp. Reeve, A.F. 1981. Annual project report - wildlife studies - Medicine Bow Wind Energy Project.

Wyoming Game and Fish Department and USDI, Bureau of Reclamation, Denver, CO. 86pp.

Reeve, A.F. 1980. Pronghorn censusing: an evaluation of the ARCO big game censusing program. ARCO Coal Company, Denver, CO. 10pp.


Howell, J.A., A.F. Reeve, and C. Ebin. 1979. Passerine survey, Wind Energy Project, Wyoming. USDI, Bureau of Reclamation, Casper, WY. 7pp.


59892-0025/144302161.1

Jordan Cove LNG LLC Suite 1100, 111 5 Ave SW

Portland, OR 97204

T (971) 940-7800

www.jordancovelng.com

May 3rd, 2019

Attention: Jill Rolfe Subject: Concurrent Land Use Applications for Pacific Connector Gas Pipeline Early Works Alignment – 3.67 miles Coos County File Nos. AM-18-010/HBCU-18-002

This memo is being provided to address the additional information requests received during the Coos County Land Use Application First Open Record period. 1. Responses to questions raised by Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians in Section 5 of April 12, 2019 letter (County Exhibit 13). a. How large and deep are the starting pits?

In Appendix G.2 HDD Feasibility Analyses of Resource Report 2 Water Use and Quality submitted as part of the September 2017 FERC filing, drilling fluid containment pits will be excavated, based on site-specific requirements, adjacent to the entry and exit points typically measuring up to approximately 10-ft x 20-ft x 6-ft in depth.

b. Will placement occur only in the upland areas?

Yes, the entry/exit pads are located on upland areas (i.e. not within the Coos Bay

Estuary).

c. How large are pilot bores?

The proposed pilot hole bit diameter for both HDDs is currently 12.5-in with a 6.6-in drill

pipe diameter.

d. Is it possible for the boring drill or reamers or the pipe during installation to get stuck and if so

how is this handled? Abandonment?

In Appendix I.2 HDD Failure Modes of Resource Report 2 Water Use and Quality

submitted as part of the September 2017 FERC filing, Section 2.0 Failure Modes

identifies various causes of drill bit/pipe becoming obstructed during construction

operations. Mitigative options to bypass any of these obstructions can range from

mechanical equipment replacements, modification of drilling fluid parameters, to drill path

alignment adjustments. Section 3.6 describes the proposed hole abandonment process.

e. The application states the drill would be directionally guided by two insulated wires laid on the

ground but how does that work over the estuary crossing?

For the Coos Bay crossings, the few hundred feet on either end of each crossing that are

not below water will have a "wireline" coil setup on the ground surface (ParaTrack or

similar), typically surveyed in along centerline and looped back at a predetermined offset

from the centerline to complete the circuit (offset distance will typically be the maximum


59892-0025/144302161.1


Portland, OR 97204

T (971) 940-7800


depth of the drill within that section of coil). Survey of the coil on each site should take a

day and will usually be completed prior to the HDD rig arriving or during set up. The

Bottom Hole Assembly will have both a standard wireline downhole steering tool that

tracks its position in relation to the surveyed ParaTrack coil, as well as a gyroscopic

steering tool, which does not utilize any surface coil but operates on calculating positions

based on the earth's rotation. For the first "on-land" portion on each side of each drill, the

ParaTrack and gyroscopic steering readings will be recorded and used to ensure the data

is in alignment between both tools before proceeding into the underwater section which

will be steered entirely with the gyroscopic tools.

f. What is the depth of the pullback? What are the potential impacts to fish weirs in the intertidal

zone?

The total minimum depths of the installed HDD pipeline sections for the West and East

Coos Bay crossings from the ground surface entry points will be approximately 110-ft and

200-ft, respectively. As a result, the pipeline distances within intertidal areas will range

from approximately 110-ft to 200-ft in depth below the bottom of the bay.

PCGP and CTCLUSI have both stated on the record that the Memorandum of Agreement

(MOA), including the Cultural Resources Protection Agreement (CRPA) and

Unanticipated Discoveries Plan (UDP), they have entered are appropriate measures to

protect cultural and archaeological resources. PCGP and CTCLUSI have proposed a

condition of approval requiring compliance with the MOA, including the CRPA and UDP,

which will address protection of such resources in the intertidal zone.

g. Is the in-water work window applicable to this work?

As no HDD construction activities are proposed within the Coos Bay Estuary, the in-water

work window will not apply.

h. Is there any restriction on water use (such as fishing or canoeing) during the construction

period in the area of the bay along the pipeline route if it is going “under” the bay?

There are no restrictions on water use during or, as a result of, the HDD construction

activities associated with both Coos Bay crossings.

2. Maintenance of the pipeline sections installed via HDD. There are no proposed or expected ground disturbing construction or maintenance activities within the easement above the segment of the pipeline that will be installed via HDD (e.g., under Coos Bay). Pipeline integrity inspections will include the use of inline caliper tools in compliance with the regulations adopted by PHMSA. As the pipeline will be designed, constructed, operated, and maintained as per 49 CFR 192, all integrity management requirements will be adhered to. 3. Handling and disposal of cuttings produced during HDD construction operations for the West and East Coos Bay crossings. In accordance with applicable federal and state law, PCGP will characterize and properly manage all soil, cuttings and other materials generated from the HDD installation activities. The soil, cuttings, and other materials will not be disposed of at the APCO site, where unrelated dredge material disposal is proposed to occur or at the wetland mitigation/restoration sites (e.g., Kentuck, eelgrass mitigation site) proposed by Jordan Cove Energy Project L.P.


59892-0025/144302161.1


Portland, OR 97204

T (971) 940-7800


Sincerely,

Jimmy Bernabe Project Manager, Early Works Jordan Cove LNG


LegendPCGP Proposed RouteMilepostTrenchless / Bore Pipe SegmentsBore PitConstruction Right-of-WayTemporary Extra Work SpaceCoos County ParcelFEMA Floodplain Zone AE

Exhibit 3, Page 1 of 1

Letter

Exhibit 1

Appendix A - Hydrostatic Test Plan

1.0 Introduction

2.0 General Hydrostatic Testing Process

2.1 Contractor Responsibility

2.2 Cleaning

2.3 Filling

2.4 Pressurizing

2.5 8-Hour Test

2.6 Dewatering

2.7 Drying

2.8 Tie-Ins

3.0 Source Water

4.0 Dewatering

5.0 Horizontal Directional Drill (HDD)/Direct Pipe Hydrostatic Testing

6.0 Test Failure

7.0 Potential Effects and Best Management Practices

7.1 Schedule

7.2 Water Withdrawal

7.2.1 Waterbody Source Testing

7.2.2 Invasive Species and Pathogens

7.2.3 Bio-Invasive Research

7.2.4 Waterbody Source Best Management Practices

7.2.5 Temperature and Flow Effects

7.3 Dewatering – Land Application

8.0 Monitoring

9.0 References

Attachment A - Typicals

Attachment B - Potential Treatment Matrix

Attachment C - Equipment Cleaning Procedures

Attachment D - Maps

Attachment E - Impacts Assessment

Attachment F - Hydrologic Assessment

Exhibit 2

Exhibit 3

59892-0025/144344946.1

Seth J. King

[email protected]

D. +1.503.727.2024

F. +1.503.346.2024

May 8, 2019

VIA EMAIL TO [email protected]

Ms. Chelsea Schnabel, Director City of North Bend Planning Department PO Box B 835 California Avenue North Bend, OR 97459

Re: Concurrent Land Use Applications for Pacific Connector Gas Pipeline Early Works Alignment - 0.92 of a Mile

City of North Bend File Nos. FP 2-18 and CBE 3-18 Applicant’s Second Open Record Period Submittal

Dear Chelsea:

This office represents Pacific Connector Gas Pipeline, LP (“PCGP”), the applicant requesting approval of concurrent land use applications to construct an interstate natural gas pipeline (“Pipeline”) in City of North Bend File Nos. FP 2-18 and CBE 3-18 (“Applications”). This letter and its enclosures constitute PCGP’s second open record period submittal for the Applications.

Enclosed please find the following materials:

Exhibit 1 - Memorandum from Edge Environmental, Inc. dated May 2, 2019, with one attachment: This memorandum provides expert testimony and explanation to support the following conclusions: (1) the Pipeline will not have adverse impacts on abalone; (2) installation of the Pipeline will not adversely affect salinity levels in the estuary; and (3) installation and operation of the Pipeline will not generate noise at a level that will adversely affect oysters.

Exhibit 2 - Memorandum from PCGP dated May 3, 2019: This memorandum provides explanations in response to the following issues: (1) questions about the HDD installation and operations raised by the Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians in Section 4 of a letter to the City dated April 16,

ATTACHMENT AE

Chelsea Schnabel, Planning Director May 8, 2019 Page 2

59892-0025/144344946.1

2019 (Attachment U); (2) maintenance of the pipeline sections installed via HDD; and (3) handling and disposal of cuttings produced during HDD construction operations.

Exhibit 3 - Pipeline Alignment Map with Installation Overlay: This map illustrates the Pipeline alignment in the non-CBEMP portions of the City and includes an overlay showing whether the Pipeline will be installed via trenching or boring.

Please place a copy of this submittal into the official record for this file and place a copy before the Planning Commission. PCGP reserves the right to submit additional argument and evidence in this matter consistent with the extended open record schedule established by the Planning Commission and ORS 197.763.

Thank you for your courtesies in this matter.

Very truly yours,

Seth J. King

cc: Steve Pfeiffer (via email) (w/encls.) Client (via email) (w/encls.)

ATTACHMENT AE

405 Urban Street, Suite 310, Lakewood, CO 80228 (303)988-8844 Phone (303)988-8999 Fax


MEMO

To: Jimmy Bernabe From: Archie Reeve Date: May 2, 2019 Re: PCGP Coos County Responses

In response to various public comments, the following research has been compiled: Abalone National Marine Fisheries (NMFS), West Coast Region, provides distributions of ESA-listed species on its website: https://www.westcoast.fisheries.noaa.gov/protected_species/species_list/species_lists.html. Two species of abalone, black abalone (Haliotis cracherodi) and white abalone (Haliotis sorenseni) are listed as endangered and are found under “Other ESA-Listed Species” on the website. Three additional abalone species are identified as Species of Concern including pink abalone (Haliotis corrugate), green abalone (Haliotis fulgens), and pinto abalone (Haliotis kamtschatkana). Pink abalone and green abalone are found along coastal Southern California and Baja California in northern Mexico. Pinto abalone is found from California to Sitka, Alaska. Very little is known about the species’ presence along the Oregon coast but one individual was reported on Orford Reef in 2009. Since then a few other pinto abalone have been on the reef and near Port Orford (NMFS Status Review Team 2017). Except for those few records, the Oregon coast appears to be a natural gap in the species range between California and Washington (NMFS Status Review Team 2017). Pink, green, and pinto abalone would not be affected by the Project. Likewise, the two ESA-listed species would not be affected by the Project. White abalone historically occurred from Point Conception, California, to Punta Abreojos, Baja California, in Mexico. The current range of black abalone is estimated to extend from Point Arena, California, south to Bahia Tortugas, Mexico, including offshore islands (NMFS 2018). Neither species occurs within the Project’s estuarine analysis are or marine analysis area as defined in the Applicant Prepared Draft Biological Assessment. References: National Marine Fisheries Service. 2018. Black Abalone (Haliotis cracherodii) Five-Year Status

Review: Summary and Evaluation. NMFS West Coast Region, Long Beach, CA.

Status Review Team. 2014. Status Review Report for Pinto Abalone (Haliotis kamtschatkana). NMFS West Coast Region, Long Beach, CA.


ATTACHMENT AE

2

Bentonite and Salinity Observations of montmorillonite (pure bentonite), Illite, kaolinite, and halloysite clays exposed to seawater reveal that magnesium ions (Mg2+) from seawater moved into the exchange positions in the clays rather than calcium (Ca2+) and sodium (Na+) ions (Carroll and Starkey 1958). Clay minerals react with the cations in seawater through the same kinds of exchange mechanisms that have been found experimentally for electrolytes such as NaOH and KOH. Exposure to seawater showed that replacement of H+ ions in the clay follows the order Ca2+ > Mg2+ > Na+ > K+. However, Mg2+ commonly makes up a larger proportion of the cations in the exchange positions than Ca2+ because there is more magnesium than calcium in seawater. In addition, calcium is tied up in the buffer mechanism of seawater (Carroll and Starkey 1958) provided by the presence of carbonate and borate in seawater. Calcium, not sodium, is the cation mostly affected by the buffering action because of the relation CaCO3 ↔ CaHCO3 ↔ H2C03. This series of reactions affects the availability of Ca2+ ions to enter into the exchange positions of clay minerals (Carroll and Starkey 1958). Bentonite could be exposed to seawater within the Coos Bay Estuary if there were inadvertent returns (frac-out) of bentonite during the HDD process as described in FERC’s Draft EIS. Since concentrations of Na+ in seawater far exceed concentrations of Ca2+, Mg2+, or K+, ion exchange affecting salinity (concentrations of Na+ and Cl-) appears negligible if a frac-out occurred while installing the Pipeline within the Estuary. Further, frac-outs, if they occurred, would be in the brackish water of the Estuary which is a mixture of seawater and fresh water with naturally occurring variation in salinity levels, fluctuating with tides. Reference: Carroll, D., and H.C. Starkey. 1958. Effect of Sea-water on Clay Minerals. Pages 80 to 101, in

A. Swineford (editor). Seventh National Conference on Clays and Clay Minerals. U.S. Geological Survey. Pergamon Press.

HDD Noise and Oysters Sensitivity of Pacific oysters (Magallana gigas) to sounds was examined experimentally by measuring valve (shell) movements when exposed to water-borne sounds in the range of 10 Hz to 20 kHz at various acoustic energy levels (Charifi et al. 2017). At high enough acoustic energy, oysters transiently closed their valves in response to frequencies in the range of 10 to

3

Both studies demonstrated sensitivity by the two mollusks to sounds, whether water-borne or substrate-borne. Horizontal directional drilling (HDD) has been proposed to install the Pipeline beneath the Coos Bay Estuary. All HDD operations would occur within the estuarine substrate and there would be no sounds generated through the water column. Further, HDD operations would not be “audible” to oysters (or mussels) through vibrations transmitted through the substrate. As stated by GeoEngineers (2019): “HDD operations involve successive passes with rotary drilling methods to create a hole through which the carrier pipe is installed. The hole is not created using percussion or impact methods, therefore, vibration levels associated with HDD methods are not typically of a magnitude that can be felt at the ground surface. Moreover, much of the proposed HDD path is situated at depths greater than 100 feet, which reduces the potential for vibrations to be detected by humans or wildlife.” That oysters would “hear” noise (or detect vibrations) produced by HDD beneath the Coos Bay Estuary appears unlikely and insignificant in that any effect to oysters could not be detected or meaningfully measured.

References: Charifi M., M. Sow, P. Ciret, S. Benomar, and J-C. Massabuau. 2017. The sense of hearing in

the Pacific oyster, Magallana gigas. PLoS ONE 12(10): e0185353.https://doi.org/10.1371/journal. pone.0185353

GeoEngineers. 2019. Memorandum: Response to Coos County Land Use Application Public Comment. Geoengineers, Springfield, MO. April 12, 2019.

Roberts L., S. Cheesman, T. Breithaupt, and M. Elliott. 2015. Sensitivity of the mussel Mytilus edulis to substrateborne vibration in relation to anthropogenically-generated noise. Marine Ecology Progress Series 538: 185– 195.


ATTACHMENT AE



Archie F. Reeve

Education 1984 Ph.D., University of Wyoming, Laramie, Wyoming (Major-Wildlife Ecology; Minor-

Statistics) 1970 M.A., Western Kentucky University, Bowling Green, Kentucky (Major-Secondary

Education; Minor-Biology) 1968 A.B., University of Rochester, Rochester, New York (Major-Biology;

Minors-Chemistry, Psychology) Summary of Professional Experience 2006 - Present Edge Environmental, Inc., Lakewood, Colorado. 2004 - 2006 Senior Environmental Scientist, Golder Associates, Inc., Laramie, Wyoming

and Denver, Colorado. 1992 - 2004 Senior Research Associate, PIC Technologies, Inc., Laramie, Wyoming and

Denver, Colorado. 1988 - 1992 Senior Scientist, Hayden-Wing Associates, Laramie, Wyoming. 1982 - 1983 Research Associate; Department of Zoology and Physiology, University of

Wyoming, Laramie. Cooperative Wildlife Program, Phase I - Literature Review. Overthrust Industrial Association, Denver, Colorado.

1979 - 1982 Principal Investigator; Wyoming Game and Fish Department, University of Wyoming, Laramie. Wildlife Studies - Medicine Bow Wind Energy Project. U.S. Bureau of Reclamation, Denver, Colorado.

1980 - 1981 Evaluation of various wildlife projects for ARCO Coal Mines for Campbell County, Wyoming. Boyce Consulting, Laramie, Wyoming.

1978 - 1979 Evaluation of wildlife sections for mining permits for major energy companies for Mine Reclamation Consultants Inc., Laramie, Wyoming.

Archie has more than 40 years of experience as a professional wildlife biologist, research scientist, educator, manager, and administrator. He obtained a Ph.D. in Wildlife Ecology from the University of Wyoming. He is experienced with a wide variety of wildlife species and habitats, including forest, range, and aquatic ecosystems and has performed wildlife work in nine western states including Alaska. He has designed, conducted, and directed numerous wildlife studies focusing on diverse species. Archie has completed wildlife impact assessments and biological assessments for a liquid natural gas terminal, LNG shipping, and pipeline infrastructure in Oregon, more conventional natural gas pipelines throughout the west coast and Rocky Mountains, coal mines, oil and gas fields, transmission lines, highways, railroads, ski areas, and other development projects. He is well versed in evaluating impacts to threatened and endangered species and other species classified as being of "high interest" to state and/or federal agencies. Archie has authored or co-authored numerous technical reports, public presentations, and scientific publications and continues to provide instruction, academic support, and guidance to students at the University of Wyoming. Selected Project Experience

• Pacific Connector Gas Pipeline Project. BA, FERC F-IV Application for Natural Gas Pipeline in Oregon. Pacific Connector Gas Pipeline, LP.


ATTACHMENT AE



• Sheep Mountain Uranium Project. EIS, BA. Energy Fuels Resources. Wyoming. • Book Cliff Coal Lease-by-Application. EIS, BA research. Rhino Energy. Colorado. • Pinon Ridge Uranium Mill Project. Environmental Report to Colorado Department of

Public Health and Environment • Whirlwind Uranium Mine Project. EA, BA. Energy Fuels Resources. Colorado. • Parachute Lateral Project. BA, FERC F-IV Application for Natural Gas Pipeline in

Colorado. Northwest Pipeline Corporation. • Pinedale Anticline Oil and Gas Exploration and Development Project. Supplemental

EIS and Wildlife Technical Report, USDI Bureau of Land Management, Pinedale, Wyoming.

• Buckhorn Mountain Project. Habitat Mitigation - Crown Resources Corporation, Kinross Gold USA, Inc. Oroville, WA

• ASU Year-Round Drilling Demonstration Project. Sublette County, Wyoming. Environmental Assessment and Wildlife Technical Report. USDI Bureau of Land Management, Pinedale, Wyoming.

• Havre-Rainbow (Montana) Transmission Line Rebuild Project. Western Area Power Administration, Lakewood, CO.

• Questar Exploration and Production Company Year-round Drilling Proposal. EA and Wildlife Technical Report, USDI Bureau of Land Management, Pinedale, Wyoming.

• BA, EIS, FERC F-IV Applications for Natural Gas Pipeline Expansions in Washington. Northwest Pipeline Corporation.

• Trends in Big Game Populations (mule deer, pronghorn, elk) in Wyoming, Wyoming Cooperative Fish and Wildlife Research Unit.

• Dakota, Minnesota & Eastern Railroad Corporation Powder River Basin Expansion Project EIS, Surface Transportation Board, and USDA Forest Service, Thunder Basin National Grasslands

• Pinedale Anticline Oil and Gas Exploration and Development Project. EIS and Wildlife Technical Report, USDI Bureau of Land Management, Rock Springs District.

• Ponnequin Wind Energy Project. Weld County, Colorado. Environmental Assessment. U.S. Department of Energy, Golden, Colorado.

• Potential for Competitive Interactions Between Mule Deer and Elk in the Western United States and Canada, Wyoming Cooperative Fish and Wildlife Research Unit and Rocky Mountain Elk Foundation.

• Moxa Arch Antelope Study and Mitigation Project. Kemmerer BLM Resource Area Office, Wyoming Cooperative Fish and Wildlife Research Unit, and Wyoming Game and Fish Department, Green River.

• Wildlife Monitoring, Carbon County UCG, Inc. Exploration and Demonstration Project, Rawlins BLM District.

• Birch Creek Gas Field Impacts on Wintering Mule Deer, Pinedale BLM Resource Area Office and Wyoming Game and Fish Department, Jackson.

• Fontenelle Natural Gas Infill Drilling Projects. EIS and Wildlife Technical Report, USDI Bureau of Land Management, Rock Springs BLM District.

• Expansion II Project. FERC F-IV Application, Northwest Pipeline Corporation. • EA, BTA Oil Producers, Bravo Full Field Development, Rock Springs BLM District. • Carbon County UCG, Inc. Exploration and Demonstration Project. EA, Rawlins BLM

District. • Enron Burly Area EIS, Rock Springs BLM District Office. • Saddle Ridge Project. EA, Northwest Pipeline Corporation.


ATTACHMENT AE



• Mainline Expansion Project. EIS, FERC F-IV Application, Northwest Pipeline Corporation.

• Sheridan Area Water Supply - Joint Powers Board, Twin Lakes Reservoir, Bighorn National Forest, WY.

• Snake River Canyon Project. EIS/BE, Wyoming Highway Department, Bridger-Teton National Forest, WY.

• Cody-Yellowstone Highway Project. EIS/BE, Wyoming Highway Department, Shoshone National Forest.

• Salmon River Highway Project. EA/BA, USDA-Forest Service, Salmon National Forest, ID.

• Aerial and ground surveys for potential black-footed ferret habitat and nesting raptors along pipeline corridors in Colorado, Utah, Wyoming, Idaho, Oregon and Washington, Northwest Pipeline Corporation.

• Farson-Fontenelle Fencing Project. EIS/BE, Wyoming Highway Department, Green River BLM Resource Area.

• Aerial and ground surveys for nesting raptors along seismic lines in Wyoming, Western Geophysical.

• Triton Oil and Gas Association, Big Game Response to Coal Bed Methane Field Development.

• Rocky Mountain Oil and Gas Association, Effects of Oil and Gas Development on Mule Deer, Sage Grouse, and Raptors.

Special Certifications • Certified by the U.S. Fish and Wildlife Service as a biologist qualified to conduct or

supervise field searches for black-footed ferrets. • Wyoming State Department of Education; certified to teach secondary school Biology,

Chemistry, Geology, Psychology, and Art. Professional Societies • American Association for the Advancement of Science • The Wildlife Society • Colorado - Wyoming Academy of Science • Sigma Xi, The Scientific Research Society Publications Reeve, A.F., and T.C. Vosburgh. 2006. Shooting prairie dogs. Pages 119-128 in J.E. Roelle,

B.J. Miller, J.L. Godbey, and D.E. Biggins (editors). Recovery of the Black-footed Ferret – Programs and Continuing Challenges: U.S. Geological Survey Scientific Investigations Report 2005-5293.

Reeve, A.F., and T.C. Vosburgh. 2006. Recreational shooting. Pages 139-156 in J.L. Hoogland (editor). Conservation of the Black-Tailed Prairie Dog. Island Press, Washington, D.C..

Lutz, D.W., M. Cox, B.F. Wakeling, D. McWhirter, L.H. Carpenter, S. Rosenstock, D. Stroud, L.C. Bender, and A.F. Reeve. 2003. Impacts and changes to mule deer habitat. Pages 13-62 in J.C. deVos, Jr., M.R. Conover, and N.E. Headrick (editors). Mule deer conservation: issues and management strategies. Berryman Institute Press, Utah State University, Logan.


ATTACHMENT AE



White, G.C., A.F. Reeve, F.G. Lindzey, and K.P. Burnham. 1996. Estimation of mule deer winter mortality from age ratios. Journal of Wildlife Management 60:37-44.

Reeve, A.F., and S.H. Anderson. 1993. Ineffectiveness of Swareflex reflectors at reducing deer-vehicle collisions. Wildlife Society Bulletin 21:127-132.

Hayden-Wing, L.D., S.A. Tessmann, R. Rothwell, and A.F. Reeve. 1992. A wetland evaluation process for quantifying changes in waterfowl habitat values in Wyoming. in Proceedings 12 Annual Conference of the National Association of Abandoned Mine Land Programs, Breckenridge, CO.

Reeve, A.F. 1987. Looking for lynx. Wyoming Wildlife 51(2):28-33. Reeve, A.F. 1984. Environmental influences on male pronghorn home range and pronghorn

behavior. Ph.D. dissertation, University of Wyoming, Laramie, Wyoming. 172pp. Reeve, A.F. 1983. Summer home range characteristics of pronghorn males. Journal of the

Colorado-Wyoming Academy of Science 15:137. Reeve, A.F. 1982. Trapping pronghorn at a waterhole: a preliminary report. Biennial

Pronghorn Workshop 10:209-224. Reeve, A.F. 1981. Pronghorn social structure in relation to environmental and population

parameters. Journal of the Colorado-Wyoming Academy of Science 13:59. Reeve, A.F. 1980. Topographic variation as an indicator of potential raptor nesting habitat.

Journal of the Colorado-Wyoming Academy of Science 12:40. Technical Reports Reeve, A.F., F.G. Lindzey, and S.H. Anderson. 2003. Elk populations in Wyoming 1978-2001.

Wyoming Cooperative Fish and Wildlife Research Unit. 138pp. Reeve, A.F., F.G. Lindzey, and S.H. Anderson. 2003. Pronghorn populations in Wyoming 1978-

2001. Wyoming Cooperative Fish and Wildlife Research Unit. 105pp. Ayers, L.W., A.F. Reeve, F.G. Lindzey, and S.H. Anderson. 2000. A preliminary assessment of

mule deer population dynamics in Wyoming. Wyoming Cooperative Fish and Wildlife Research Unit.

Lindzey, F.G., W.G. Hepworth, T.A. Mattson, and A.F. Reeve. 1997. Potential for Competitive Interactions Between Mule Deer and Elk in the Western United States and Canada: A Review. The Rocky Mountain Elk Foundation, Missoula, MT. 82pp.

Reeve, A.F. 1996. Mule deer response to oil and gas well re-completions and winter habitat use on the Birch Creek Unit, Big Piney - LaBarge Winter Range complex during winter, 1990-1991. Bureau of Land Management, Rock Springs District and Wyoming Game and Fish Department, Jackson, WY. 34pp + appendices.

Reeve, A. and P. Krawczak. 1995. Integrating remote sensing and GIS with Bayesian probability models of wildlife habitat to evaluate cumulative impacts. Bureau of Land Management, Rock Springs District, Rock Springs, WY. 79pp.

Reeve, A.F. 1992. Characteristics of bedding sites used by elk during spring migration on the Medicine Bow National Forest, southeastern Wyoming. Wyoming Game and Fish Deptartment, Laramie and Cheyenne, WY. 68pp.

Reeve, A.F., and F.G. Lindzey. 1991. Evaluation of mule deer winter mortality in southcentral Wyoming. Wyoming Cooperative Wildlife Research Unit, Laramie, WY. 147pp.

Reeve, A.F., and L.D. Hayden-Wing. 1991. Review and evaluation of the effect of Triton Oil and Gas Corporation's proposed coal bed methane field development on elk and other big game species. Hayden-Wing Associates, Laramie and Triton Oil and Gas Corp., Dallas, TX. 92pp.


ATTACHMENT AE



Reeve, A.F. 1990. Issues, information, and alternatives related to fencing Wyoming Highway 28, Farson to Fontenelle. Hayden-Wing Associates, Laramie and Wyoming Highway Department, Cheyenne, WY. 43pp.

Reeve, A.F. 1990. Vehicle-related mortality of big game in Nugget Canyon, Wyoming. Wyoming Cooperative Wildlife Research Unit, Laramie, WY. 127pp.

Reeve, A.F. 1990. Surveys for black-footed ferrets, prairie dog colonies, raptor nests, and sage grouse leks for the Mustang-Spence 230kV Transmission Line. Hayden-Wing Associates, Laramie and Pacific Power & Light Company, Casper, WY.

Reeve, A.F. (editor). 1989. Pronghorn productivity studies in the Fifteenmile Herd Unit. School for Field Studies, Beverly, MA.

Reeve, A.F. 1987. Wildlife monitoring reports, Arch of Wyoming, Inc., Hanna Basin Mines, Wyoming. Hayden-Wing Assoc., Sheridan, WY and Arch of Wyoming, Hanna, WY.

Reeve, A.F., M.D. Marcus, B.R. Parkhurst. 1987. Potential effects of calcium from lake liming on human health. Western Aquatics, Laramie, WY and Living Lakes, Washington, D.C. 43pp.

Reeve, A.F., and F.G. Lindzey. 1987. Winter mortality of mule deer fawns in south central Wyoming. Wyoming Cooperative Fish and Wildlife Research Unit, Laramie, WY. 89pp.

Reeve, A.F., et al. 1987. Volume 5, Environment. Site Proposal-Superconducting Super Collider (SCC), U.S. Department of Energy, Washington, D.C. State of Wyoming, Cheyenne, WY. 70pp.

Reeve, A.F. 1987. Final report: Big game studies on the Gay Mine Expansion Area Fort Hall Reservation, Idaho. Mariah Associates, Laramie, WY and J.R. Simplot Co., Pocatello, ID. 76pp.

Reeve, A.F. 1986. Vehicle-related big game mortality in Nugget Canyon, Wyoming: mitigation alternatives and recommendations. Wyoming Cooperative Fish and Wildlife Research Unit, Laramie, WY. 87pp.

Reeve, A.F., F.G. Lindzey, and S. Buskirk. 1986. Historical and recent distribution of the lynx in Wyoming. Wyoming Game and Fish Department, Cheyenne, WY. 76pp.

Yeo, J., A.F. Reeve, P. MacLaren, and A.L. Travsky. 1984. Final project report - wildlife studies - Medicine Bow Wind energy Project. Wyoming Game and Fish Department and USDI, Bureau of Reclamation, Denver, CO. 151pp.

Boelter, A., A. Reeve, and T. LaPoint. 1984. User's guide for Wyoming hazardous waste inventory system. Prepared for Wyoming Department of Environmental Quality, Solid Waste Management Program. Cheyenne, WY. 13pp.

Ward, J., D. Inkley, A. Reeve, and S. Anderson. 1983. An evaluation of the impact of coal development on white-tailed deer (Odocoileus virginianus) populations in southeastern Montana. Prepared for USDI, Fish and Wildlife Service, Wildlife Research Center, Sheridan, WY. 5pp.

Reeve, A.F., R. Schonholtz, and B. Ackerman. 1983. Cooperative wildlife program -Task 3: local knowledge. Prepared for the Overthrust Industrial Association, Denver, CO. 63pp.

Ward, J.P., D. Inkley, A.F. Reeve, and S. Anderson. 1983. An evaluation of the impact of coal development on mule deer (Odocoileus hemionus) populations in southeastern Montana. Prepared for USDI, Fish and Wildlife Service, Wildlife Research Center, Sheridan, WY. 20pp.

Meyer, J.S., A.F. Reeve, L. Cuthbert-Millett, J.G. Cook, A.L. Brummond, J.P. Ward, and M. Parker. 1983. Bibliography on the effects of human activities on wildlife: emphasizing oil and gas development, forest management, range management, and recreation in the Overthrust Belt of Wyoming, Utah, and Idaho. Prepared for the Overthrust Industrial Association, Denver, CO.


ATTACHMENT AE



Reeve, A.F., R. Schonholtz, and B. Ackerman. 1983. Cooperative wildlife program - Appendix D, raw data: State literature searches. Prepared for the Overthrust Industrial Association, Denver, CO.

Reeve, A.F. and L. Irwin. 1983. Cooperative wildlife program - Task 5: mitigation of wildlife impacts. Prepared for the Overthrust Industrial Association, Denver, CO. 60pp.

Reeve, A.F. 1983. Cooperative wildlife program - Appendix E: survey of reclamation practices. Prepared for the Overthrust Industrial Association, Denver, CO. 26pp.

Reeve, A.F. and J. Yeo. 1982. The Pan Aero Corporation plan for wind energy development near Medicine Bow, Wyoming: concerns for wildlife. Wyoming Game and Fish Department, Cheyenne, WY. 6pp.


Reeve, A.F. 1981. Observer bias in aerial survey. Boyce Consulting, Laramie, WY. 13pp. Reeve, A.F. 1981. Design and analyses of ARCO's pronghorn surveys, September 3, 1981.

ARCO Coal Company, Denver, CO. 18pp. Reeve, A.F. 1981. Analyses of ARCO's pronghorn censusing program, 1976 to 1981. ARCO

Coal Company, Denver, CO. 18pp. Reeve, A.F. 1981. Annual project report - wildlife studies - Medicine Bow Wind Energy Project.

Wyoming Game and Fish Department and USDI, Bureau of Reclamation, Denver, CO. 86pp.

Reeve, A.F. 1980. Pronghorn censusing: an evaluation of the ARCO big game censusing program. ARCO Coal Company, Denver, CO. 10pp.


Howell, J.A., A.F. Reeve, and C. Ebin. 1979. Passerine survey, Wind Energy Project, Wyoming. USDI, Bureau of Reclamation, Casper, WY. 7pp.


ATTACHMENT AE

59892-0025/144302161.1


Portland, OR 97204

T (971) 940-7800


May 3rd, 2019

Attention: Jill Rolfe Subject: Concurrent Land Use Applications for Pacific Connector Gas Pipeline Early Works Alignment – 3.67 miles Coos County File Nos. AM-18-010/HBCU-18-002

This memo is being provided to address the additional information requests received during the Coos County Land Use Application First Open Record period. 1. Responses to questions raised by Confederated Tribes of Coos, Lower Umpqua, and Siuslaw Indians in Section 5 of April 12, 2019 letter (County Exhibit 13). a. How large and deep are the starting pits?

In Appendix G.2 HDD Feasibility Analyses of Resource Report 2 Water Use and Quality submitted as part of the September 2017 FERC filing, drilling fluid containment pits will be excavated, based on site-specific requirements, adjacent to the entry and exit points typically measuring up to approximately 10-ft x 20-ft x 6-ft in depth.

b. Will placement occur only in the upland areas?

Yes, the entry/exit pads are located on upland areas (i.e. not within the Coos Bay

Estuary).

c. How large are pilot bores?

The proposed pilot hole bit diameter for both HDDs is currently 12.5-in with a 6.6-in drill

pipe diameter.

d. Is it possible for the boring drill or reamers or the pipe during installation to get stuck and if so

how is this handled? Abandonment?

In Appendix I.2 HDD Failure Modes of Resource Report 2 Water Use and Quality

submitted as part of the September 2017 FERC filing, Section 2.0 Failure Modes

identifies various causes of drill bit/pipe becoming obstructed during construction

operations. Mitigative options to bypass any of these obstructions can range from

mechanical equipment replacements, modification of drilling fluid parameters, to drill path

alignment adjustments. Section 3.6 describes the proposed hole abandonment process.

e. The application states the drill would be directionally guided by two insulated wires laid on the

ground but how does that work over the estuary crossing?

For the Coos Bay crossings, the few hundred feet on either end of each crossing that are

not below water will have a "wireline" coil setup on the ground surface (ParaTrack or

similar), typically surveyed in along centerline and looped back at a predetermined offset

from the centerline to complete the circuit (offset distance will typically be the maximum


ATTACHMENT AE

59892-0025/144302161.1


Portland, OR 97204

T (971) 940-7800


depth of the drill within that section of coil). Survey of the coil on each site should take a

day and will usually be completed prior to the HDD rig arriving or during set up. The

Bottom Hole Assembly will have both a standard wireline downhole steering tool that

tracks its position in relation to the surveyed ParaTrack coil, as well as a gyroscopic

steering tool, which does not utilize any surface coil but operates on calculating positions

based on the earth's rotation. For the first "on-land" portion on each side of each drill, the

ParaTrack and gyroscopic steering readings will be recorded and used to ensure the data

is in alignment between both tools before proceeding into the underwater section which

will be steered entirely with the gyroscopic tools.

f. What is the depth of the pullback? What are the potential impacts to fish weirs in the intertidal

zone?

The total minimum depths of the installed HDD pipeline sections for the West and East

Coos Bay crossings from the ground surface entry points will be approximately 110-ft and

200-ft, respectively. As a result, the pipeline distances within intertidal areas will range

from approximately 110-ft to 200-ft in depth below the bottom of the bay.

PCGP and CTCLUSI have both stated on the record that the Memorandum of Agreement

(MOA), including the Cultural Resources Protection Agreement (CRPA) and

Unanticipated Discoveries Plan (UDP), they have entered are appropriate measures to

protect cultural and archaeological resources. PCGP and CTCLUSI have proposed a

condition of approval requiring compliance with the MOA, including the CRPA and UDP,

which will address protection of such resources in the intertidal zone.

g. Is the in-water work window applicable to this work?

As no HDD construction activities are proposed within the Coos Bay Estuary, the in-water

work window will not apply.

h. Is there any restriction on water use (such as fishing or canoeing) during the construction

period in the area of the bay along the pipeline route if it is going “under” the bay?

There are no restrictions on water use during or, as a result of, the HDD construction

activities associated with both Coos Bay crossings.

2. Maintenance of the pipeline sections installed via HDD. There are no proposed or expected ground disturbing construction or maintenance activities within the easement above the segment of the pipeline that will be installed via HDD (e.g., under Coos Bay). Pipeline integrity inspections will include the use of inline caliper tools in compliance with the regulations adopted by PHMSA. As the pipeline will be designed, constructed, operated, and maintained as per 49 CFR 192, all integrity management requirements will be adhered to. 3. Handling and disposal of cuttings produced during HDD construction operations for the West and East Coos Bay crossings. In accordance with applicable federal and state law, PCGP will characterize and properly manage all soil, cuttings and other materials generated from the HDD installation activities. The soil, cuttings, and other materials will not be disposed of at the APCO site, where unrelated dredge material disposal is proposed to occur or at the wetland mitigation/restoration sites (e.g., Kentuck, eelgrass mitigation site) proposed by Jordan Cove Energy Project L.P.


ATTACHMENT AE

59892-0025/144302161.1


Portland, OR 97204

T (971) 940-7800


Sincerely,

Jimmy Bernabe Project Manager, Early Works Jordan Cove LNG


ATTACHMENT AE

LegendPCGP Proposed RouteMilepostTrenchless / Bore Pipe SegmentsBore PitConstruction Right-of-WayTemporary Extra Work SpaceCoos County ParcelFEMA Floodplain Zone AE

Exhibit 3, Page 1 of 1

ATTACHMENT AE

Att. AE_20190508 Applicant's Second Open Record Period Submittal.pdfLetterExhibit 1Appendix A - Hydrostatic Test Plan1.0 Introduction2.0 General Hydrostatic Testing Process2.1 Contractor Responsibility2.2 Cleaning2.3 Filling2.4 Pressurizing2.5 8-Hour Test2.6 Dewatering2.7 Drying2.8 Tie-Ins

3.0 Source Water4.0 Dewatering5.0 Horizontal Directional Drill (HDD)/Direct Pipe Hydrostatic Testing6.0 Test Failure7.0 Potential Effects and Best Management Practices7.1 Schedule7.2 Water Withdrawal7.2.1 Waterbody Source Testing7.2.2 Invasive Species and Pathogens7.2.3 Bio-Invasive Research7.2.4 Waterbody Source Best Management Practices7.2.5 Temperature and Flow Effects

7.3 Dewatering – Land Application

8.0 Monitoring9.0 ReferencesAttachment A - TypicalsAttachment B - Potential Treatment MatrixAttachment C - Equipment Cleaning ProceduresAttachment D - MapsAttachment E - Impacts AssessmentAttachment F - Hydrologic Assessment

Exhibit 2Exhibit 3

ATTACHMENT AE - North Bend, Oregon · 405 Urban Street, Suite 310, Lakewood, CO 80228 (303)988-8844...

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Transcript of ATTACHMENT AE - North Bend, Oregon · 405 Urban Street, Suite 310, Lakewood, CO 80228 (303)988-8844...