Response to Scoping Comments
On April 10-13, 2006, the Federal Energy Regulatory Commission
(FERC) held scoping meetings in Pooler, Sylvania, Thompson, and
Washington, GA. On May 8th, Southern LNG and Elba Express Company
responded to issues raised during the environmental scoping period.
Click on the appropriate heading to view the questions and responses.
Elba III Project General Comments
Elba Terminal Expansion Project Comments
References top
Elba III Project General Comments
Purpose and Needs
Alternatives
Agency Decision Making
Cumulative Impacts
Environmental Impacts
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Elba Terminal Expansion Project Comments
Terminal Site
River Traffic
Safety and Security
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Elba III Project General Comments
Purpose and Needs
Will the need for the planned project be studied? ( Ga. Conservancy Comment #20060424-05053)
Yes, although the Commission usually evaluates economic need in a preliminary determination on nonenvironmental issues (“ PD ”). Resource reports 1 and 10 of the Environmental Report, drafts of which are now available, identify the purposes of and need for the Elba III Project for the Commission's environmental record. Identifying the purpose and need at this stage of the environmental records helps to evaluate alternatives and their reasonableness. 40 C.F.R. § 1502.13. The primary objectives of the Elba III Project are to:
- Provide a competitively priced natural gas transportation infrastructure which will attract incremental global LNG supplies into the southeastern and eastern U.S. natural gas market to help meet the growing demand for clean energy;
- Provide firm interstate natural gas pipeline capacity which can move gas from Elba Island to major pipeline interconnects with 1) the existing Southern Natural Gas Company (Southern) System in its Zone 3 near the end of its South Main Line, 2) the existing Transcontinental pipeline at the end of its zone 4, and 3) the existing Transcontinental pipeline at the beginning of its zone 5;
- Provide new pipeline transportation services under agreements with BG LNG Services LLC and Shell NA LNG LLC;
- Provide direct access to a very reliable source of LNG supply for the southeastern and eastern U.S. markets to supplement traditional domestic supplies; and
- Provide interstate natural gas pipeline capacity to enhance liquidity in the southeastern and eastern U.S. markets.
The project sponsors have not yet filed applications for Commission authorization. Applications for Commission authorization must include, separate from an environmental report, evidence of need in the form of either precedent agreements, demand forecasts, or both included in Exhibit I. On September 15, 1999, the Commission issued a Policy Statement on New Facilities to provide guidance as to how we will evaluate proposals for certificating new construction. 88 FERC ¶ 61,227 (1999), orders clarifying statement of policy , 90 FERC ¶ 61,128 and 92 FERC ¶ 61,094 (2000), order further clarifying statement of policy , 92 FERC ¶ 61,094 (2000). The Policy Statement on New Facilities establishes criteria for determining whether there is a need for a planned project and whether the planned project will be consistent with the public interest. This determination complements, but is independent of, the environmental review and usually forms the basis for a PD prior to the final environmental impact statement.
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Is evidence of need publicly available now? (Wilkes-Washington Trans., p. 19)
Yes. The Elba III Project will serve the need for natural gas in the Southeast, particularly Georgia and South Carolina, and other growing markets throughout the interstate pipeline grid. Attachment 1 contains press releases issued on December 21, 2005 by the customers who have entered into precedent agreements for Elba III.
Broader evidence of that need appears in a wide variety of government- and industry-sponsored forecasts of supply and demand, and also in studies showing the benefits of consuming natural gas over other forms of fuel. Sources for these forecasts and studies include the following:
- The U.S. Energy Information Administration's Annual Energy Outlook 2006
- The U.S. Office of Fossil Energy's LNG: Understanding the Basic Facts (2005); and
- The National Petroleum Council's Balancing Natural Gas Policy –
Fueling the Demands of a Growing Economy (2003).
Also, the record for other recent projects reviewed by the Commission contains general evidence of need for additional supplies, particularly of LNG from new sources. In February 2006, the Commission published a brochure, “High Natural Gas Prices: The Basics,” projecting that LNG is likely to be an increasing part of natural gas supplies in the United States.
Where will the gas delivered by the Elba III Project go and who will benefit? (Sylvania Trans., pp. 16; Thomson Trans., p. 76-77; Wilkes-Washington Trans., p. 59)
The natural gas transported by the pipeline will be delivered to points selected by the customers of the terminal expansion and the new pipeline. All the delivery points along the planned Elba Express Pipeline are in the States of Georgia and South Carolina. Five of the seven delivery points are located in Georgia. The other two are located in South Carolina. These delivery points include three interconnects with other interstate natural gas pipelines.
A community's proximity to competitive supplies of energy is one of many factors industry considers in locating new business. The Georgia Department of Economic Development showcases Elba Island as a positive for the state's industries:
In 2002, the dormant Elba Island facility off the coast of Savannah was opened for use as an LNG terminal. LNG is a liquid fuel source that can be transported at a rate 600 times greater than when it's in a gaseous state. The terminal is one of only four LNG facilities in the nation, and showcases Georgia's pioneering spirit and innovative thinking towards power needs. http://www.georgia.org/Business/Industries/EnergyAndEnvironment.htm Although identifying possible new business is speculative, the Elba Express Pipeline will provide an opportunity for economic growth and development in communities along the route supplied from Elba Island. New delivery points could be added along the route as markets in Georgia and South Carolina develop. New supplies made available by the Elba III Project will likely increase competition for sales of natural gas, and the diversity of the supply will supplement traditional supplies whose sources may experience interruption or outage due to weather or other force majeure.
Local authorities that tax the value of real and personal property in their jurisdiction may receive additional revenues associated with the new facilities. Also, the jobs and purchases linked to the project may inject additional money into the community. Resource report 5 discusses these socioeconomic impacts.
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How will the benefits to the State of Georgia and its citizens outweigh the impact on natural resources and landowners in the project area? (Tanner Comment #20060426-00091; Lewis Comment #20060424-05133)
SLNG and EEC plan to minimize the impact on Georgia landowners and resources. Each federal, state and local agency that issues permits for the Elba III Project has a process for gathering information and a standard for reviewing the information to make a decision. The Commission must decide whether the project is in the public interest or “public convenience and necessity.” As a federal agency, the Commission has a national perspective on the need for and impact of a project. The Commission has taken note that citizens across the U.S. have concerns about higher gas prices caused by domestic demand increasing faster than domestic supply. In an effort to address higher prices, the Commission has approved applications for LNG terminal expansions and for new pipelines (http://www.ferc.gov/legal/staff-reports/high-gas-prices.pdf, Feb. 1, 2006, p.3). The Elba III Project facilitates the Commission's effort.
SLNG and EEC believe that the Elba III Project is in the public interest at a local, regional and national level. The project will benefit the State of Georgia and its citizens by making new and diverse supplies of natural gas available for delivery in the state and by supplementing supplies that come from sources within the U.S. The LNG imported through Elba Island and delivered as natural gas supports jobs in the project area—including as many as 23 full-time positions with the project sponsors—fuels power plants providing electricity to local consumers, generates tax revenues collected by local authorities, and has introduced new, state-of-the-art towing capability in the Port of Savannah.
Today, Georgia imports all of the natural gas that it consumes. Georgia receives its natural gas primarily from two sources: (1) production from the Gulf of Mexico (“ GOM ”), and (2) imported LNG received at Elba Island. In 2004 and 2005, Georgia consumers experienced a decline in supplies from the GOM caused by damage to production and pipeline infrastructure from hurricanes. The ability to receive LNG at Elba Island enhances the reliability of supply for Georgia consumers.
Can the new facilities be located closer to the markets that will actually use the gas? (Ga. Conservancy Comment # 20060424-05115; Ga. Ports Comments #20060424-05102)
No. The Elba Express Pipeline will transport natural gas primarily from the Elba Island terminal to delivery points in Georgia and South Carolina. The location of Elba Island close to these markets offers an advantage over alternative, more distant sources, including other terminals, that would require longer transportation routes by pipeline. The Elba Island terminal offers the advantage of access to imports of natural gas to supplement and diversify traditional sources serving these markets.
Resource report 10 discusses reasonable alternatives to the planned site. While other LNG terminals could potentially be sited elsewhere (onshore or offshore), building a terminal on a new site likely would have more adverse environmental impacts than expanding the existing Elba Island terminal. The existing Elba Island site has existing interconnects with pipeline, provides access to the breadth of markets and proximity to interstate pipelines necessary to secure the commitment for the large LNG supplies that are committed to the Elba III Project. Therefore, there are no sites that would be as suitable for a terminal to provide the service needed from the planned Elba III Terminal Expansion, and the evidence does not indicate that developing alternative sites would offer significant environmental advantages to expanding operations at the Elba terminal on land already owned and maintained for LNG operations.
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Will the Elba III Project increase dependence on foreign sources of petroleum products? (Sylvania Trans., pp. 21; Wilkes-Washington Trans., p. 28; Bennett Comment #20060424-05051)
No. The Elba III Project will not increase dependence on foreign energy over what would otherwise occur. Imports of energy balance domestic supplies and domestic consumption. The forecasts and studies cited above indicate that domestic consumption does and will continue to exceed domestic supplies of natural gas. The Elba III Project will expand on existing terminal and pipeline facilities to help create supply and a more flexible delivery system for natural gas users in the United States.
Would FERC's authorizing the Elba III Project be consistent with other executive branch policies? (Wilkes-Washington Trans., p. 28-30)
Yes. In fact, the project promotes important policy goals announced by the President and his administration. In Chapter Three of its 2001 report, the National Energy Policy Development Group recommended that federal agencies expedite permits for energy projects, a recommendation the President made law by Executive Order on May 18, 2001. On August 8, 2005, the President signed the Energy Policy Act of 2005, which amended the Natural Gas Act in several ways to confirm the Commission's exclusive jurisdiction while limiting its ability to deny or condition LNG import projects. The U.S. Energy Information Administration estimates the United States will have to increase imports of LNG by more than 600 percent in the next 25 years to fulfill America's increasing demand for natural gas. Stakeholders concerned about federal policies regarding LNG are encouraged to participate in the series of LNG Forums sponsored by the U.S. Department of Energy (http://fossil.energy.gov/programs/oilgas/storage/lng/lng_forums.html).
Will the Elba III Project be vulnerable to fluctuations in the price of natural gas? (Ga. Conservancy #20060424-05115)
No. The project has demonstrable market support in the form of precedent agreements for long-term firm service for both the terminal expansion and new pipeline. Those agreements are not conditioned on the price of natural gas.
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Alternatives
Will alternatives to burning natural gas be considered? (Pooler Trans., pp. 95-96; Lewis Comment #20060424-05133)
Yes. Resource report 10 will discuss alternatives to the Elba III Project. Although not specifically required by the Commission's regulations, the potential of other forms of energy or of energy conservation to meet the project goals is usually discussed. The Council on Environmental Quality requires that the EIS rigorously explore and objectively evaluate all reasonable alternatives to achieving the purpose of the project. 40 C.F.R. § § 1502.13, 1502.14(a).
Will alternative LNG import technologies be considered, such as offshore buoys? (Lewis Comment #20060424-05133; Ga. Conservancy Comment # 20060424-05115; Ga. Ports Comments #20060424-05102)
Yes. The primary goal of the Elba III Project is to provide an additional supply source and a more flexible delivery system to natural gas consumers in Georgia, South Carolina, and the southeast United States by fulfilling long-term transportation contracts with firm customers. The contracts specify an expansion of the Elba Island terminal to provide the needed capacity. Building the same capacity in another location, onshore or offshore, would likely involve a much larger footprint on land already dedicated to other uses. An offshore project, which will require more pipeline and more coastal impact to reach the same interconnects, could impact sensitive marine life and is not likely to offer a significant environmental benefit over an expansion at Elba Island while meeting the scheduling, cost, and market needs of SLNG's firm customers.
Agency Decision Making
Will the environmental impact statement include a “cost/benefit analysis” of the project? (Pooler Trans., pp. 33-34, 84; Lewis Comment #20060424-05133)
Not exactly. The Natural Gas Act defines the Commission's statutory mission of determining whether the planned Elba Island expansion is consistent with the public interest under Section 3 of the Natural Gas Act and whether the associated Elba Express Pipeline is in the public convenience and necessity under Section 7 of the Natural Gas Act. The environmental impact statement constitutes only one of several factors in the record of decision that the Commission considers in fulfilling its statutory mission. The environmental and non-environmental factors that the Commission considers and how those factors balance against each other has been established through policy statements, precedent, and judicial decisions under the Natural Gas Act. The environmental record on which the Commission reaches a decision may discuss preferences among alternatives based on relevant factors including economic and technical considerations and agency statutory missions. 40 C.F.R. § 1505.2(b). Resource report 10 must demonstrate how environmental benefits and costs were weighed against economic benefits and costs. 18 C.F.R. § 380.12(l). The environmental impact statement need not include a formal cost-benefit analysis. 40 C.F.R. § 1507.23. If a cost-benefit analysis is done, it must appear in the record, but only those effects within the scope of NEPA should be included among the “costs” (e.g., loss of land use) and “benefits” (e.g., green-house gas reductions) in an environmental review.
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Cumulative Impacts
Will the scoping process include an examination of cumulative impacts? (Pooler Trans., pp. 105; Lewis Comment #20060424-05133; EPA-4 Comments #20060428-00290)
Yes. The EIS will discuss the effects of the Commission's authorizing the Elba III Project. 40 C.F.R. § 1502.16(b). The notice published by the Commission on March 24, 2006 identified as a preliminary issue the cumulative effects of the project when combined with other past, present, or reasonably foreseeable future actions in the project area.
Environmental ImpactsWill impacts on air quality be considered? ( Ga. Sierra Comments # 20060424-05053; EPA-4 Comments #20040428-00290)
Yes.
The pipeline compressor station and LNG vaporizers combust natural gas as fuel. Burning natural gas for these and other uses promotes clean air objectives in the markets served by the Elba III Project. A nonprofit report in 2002 highlighted clean air as the most important of three forces driving demand for natural gas:
There remains a powerful movement to address clean air and climate change issues. Regulatory actions to address these environmental challenges are forcing companies to accelerate efforts to reduce emissions of sulfur, nitrogen, mercury, and other pollutants. Also, the regulation of greenhouse has emissions may be on the horizon, and natural gas is a relatively low-carbon-content fuel. These environmental factors are driving many firms to use natural gas in new facilities. In fact, natural gas has increasingly become the fuel of choice in the environmental community and industry, who see it as an acceptable alternative in the transition away from coal, nuclear, and hydroelectric power. This is due, in part, to the common view of natural gas as an abundant, economical and cleaner fuel source.
The Keystone Center, Expanding Natural Gas Pipeline Infrastructure to Meet the Growing Demand for Cleaner Power (March 2002), at 6. Participants in the report included consumer representatives, environmental advocates, industry and government agencies.
The State of Georgia's Environmental Protection Division (“ EPD ”) administers a comprehensive air quality programs that includes permitting of new sources, such as the Elba III Project. SLNG has submitted to EPD an application for the terminal expansion, and EEC will submit an application for the new compressor station on the Elba Express Pipeline. The compressor station will be permitted as a minor source, and the permit for the terminal expansion prevents significant deterioration of air quality.
In addition, resource report 9 discusses impacts on air quality for purposes of the Commission's environmental record under NEPA. The discussion will include effects on air quality attributable to the action of the Commission were it to authorize the Elba III Project. While this may include temporary construction impacts from construction equipment and fugitive dust as well as incremental impacts from operation of combustion facilities at the LNG terminal, more far-ranging impacts are too distant and speculative for meaningful analysis in the environmental record before the Commission.
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Will impacts on water quality and watersheds from dredging operations and pipeline ROW be considered? (Ga. Sierra Comments # 20060424-05053; Linscott Comment #20060424-05027; Temple-Inland Comment #20060424-00018; Bennett Comment #20060424-05051)
Yes. The States of Georgia and South Carolina administer water quality programs for purposes of issuing permits for impacts and for consulting with federal and other state agencies conducting their own review.
In addition, the project sponsors have initiated consultation with the U.S. Army Corps of Engineers. That consultation will include discussion of and mitigation for any impacts to waterbodies and wetlands and new structures in the Savannah River. To identify species that rely on waterbodies and wetlands within the project area, the sponsors consult with various agencies having responsibility to administer the Endangered Species Act, other federal, and state programs.
Finally, resource report 2 discusses impacts to water use and quality for purposes of the Commission's environmental record. Among the data included in resource report 2 is location of watershed areas.
Will impacts to cultural resources be considered? (Wilkes-Washington Trans., p. 135; Ga. Sierra Comments #20060424-05053; Standard Comment #20060427-00058)
Yes. The project sponsors will consult with applicable state and tribal historic preservation officers for the area of potential effect. All identified impacts will be confidentially reported in resource report 4 for the Commission's environmental record.
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Elba Terminal Expansion Project Comments
Terminal Site
Why not expand other LNG terminals instead of Elba Island? (Ga. Ports Comment #20060424-5102)
Other LNG terminals are expanding, and proposed new terminals have already proposed expansions. Elba Island is located close to the primary markets that the Elba III Project will serve, so expanding another existing or proposed terminal will not likely offer environmental advantages. River Traffic
Do LNG shipments to Elba Island shut down the port or get preferential treatment? ( Ga. Conservancy Comment #20060424-05115; Ga. Ports Comment #20060424-05102)
No. Although the U.S. Coast Guard has codified a regulated navigation area (“ RNA ”) for LNG operations on the Savannah River, 33 C.F.R. § 165.756, those regulations are inherently flexible and can accommodate numerous conditions and traffic situations.
Because several comments in this docket misrepresented the RNA, Attachment 3 contains a copy of the a recent safety bulletin from the Coast Guard waiving certain requirements in the RNA and restating interim guidelines, as well as a notice of proposed rulemaking (“ NOPR ”) requesting comments on the RNA. Commenters that presume the RNA remains unchanged and inflexible throughout operation of the Elba III Project ignore the Coast Guard's history of effecting change when appropriate.
The Coast Guard periodically reviews the RNA and has demonstrated a willingness to make changes addressing specific issues, as officially documented not only by the marine safety bulletins waiving requirements in the RNA but also by the several final rules making changes to the RNA in the short time since originally proposed in 2001. 69 Fed. Reg. 21,067 (Apr. 20, 2004); 67 Fed. Reg. 46,865 (July 17, 2002); 66 Fed. Reg. 51,562 (Oct. 10, 2001). In fact, SLNG submitted comments on the NOPR suggesting further changes to the RNA that may address some concerns about port congestion and shipping delays.
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Will the economic impact of increased LNG shipping on commercial traffic on the Savannah River be studied? (Pooler Trans. pp. 28-33, 39-42, 104-105; Lewis Comment #20060424-05133; Colonial Comment #20060424-05128; Ga. Ports Comments #20060424-05102)
SLNG's resource reports will discuss impacts that shipping associated with the Elba III Terminal Expansion would have on the environment, including public safety (Resource Report 11) and socioeconomic conditions (Resource Report 5). SLNG does not object to the growth of other businesses that rely on the Savannah River channel to conduct trade. Nor does SLNG's use of the Savannah River channel have a significant adverse impact on local resources. In fact, the Georgia Ports Authority has announced continuing growth in the Port of Savannah throughout LNG operations at Elba Island.
NEPA does not task federal agencies with favoring one type of commerce over another or distributing commercial revenues and expenses among users of the same resource. NEPA's purpose is “to protect the environment, not the economic interests of those adversely affected by agency decisions.” See, e.g., Western Radio Services Co. v. Espy , 79 F.3d 896, 902-903 (9th Cir. 1996); see also Metropolitan Edison Co. v. People Against Nuclear Energy , 460 U.S. 766, 776 (1983).
Although the NEPA process does not specifically involve commercial impacts, the Commission in its environmental review of past project on Elba Island has discussed impacts on other river users. For example, in its order authorizing the Elba II expansion project in Docket No. CP02-379-001, the Commission concluded that the increase in LNG shipping would not have a significant impact. The April 10, 2003 order concludes at paragraph 74:
We do not believe that there is any need for further study to evaluate the dynamics of vessel operations to derive hypothetical economic effects. The application of models to simulate a series of random events ( i.e. , arrival/departure times for LNG vessels, arrival/departure times for non-LNG vessels, and channel variables of tide, current, and visibility) yield artificial outcomes that fail to consider the decision making of the U.S. Coast Guard and Savannah Pilots. Both have authority to resolve potential scheduling conflicts, and both are committed to minimizing disruption by the movement of vessels in the channel. As reflected in the comments and this order, each class of vessel has unique constraints when operating in the channel. Scheduling that acknowledges the limitations of individual vessels can minimize the disruption to all users. The requirements of the Regulated Navigation Area specifically provide that the Captain of the Port may delay an LNG vessel's entry to the RNA to accommodate other commercial traffic. We believe the operation and scheduling of vessel traffic on the Savannah River is properly an issue for the regional authorities, rather than the Commission.
At this stage of the NEPA prefiling process, SLNG has not identified any evidence leading to a different conclusion for the Elba III Project now being considered. SLNG is nonetheless mindful of the inconvenience caused by shipping delays and will cooperate with the U.S. Coast Guard's and Pilots' efforts to minimize delays.
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Will the impact of a proposed new port in Jasper County be considered? (Pooler Trans., pp. 82-83, 91)
No. The possibility of a new port across the Savannah River from Elba Island depends on the outcome of ongoing legal proceedings and development efforts that are independent of the Elba III Project. SLNG does not believe that the Elba III Project makes the possibility of a Jasper County port more or less likely. While SLNG will continue to monitor events in Jasper County, the possible development of a new port is not an effect of the Elba III Project nor a reasonably foreseeable future action.
Will the EIS include a general study of development in the Port of Savannah? (Pooler Trans., pp. 91)
No. NEPA requires that the Commission and other federal agencies take a hard look at the effect on the environment of issuing permits for the Elba III Project. That is the major federal action being reviewed in this docket. 40 C.F.R. § 1508.18(b)(4).
Safety and Security Is there a safety factor engineered into the design of the mooring and unloading facilities for surge effect from passing traffic? (Lewis Comment #20060424-05133; Ga. Conservancy Comment #20060424-05115)
Yes. Resource report 11 discusses the impact of the Elba III Project on public safety, and resource report 13 discusses the engineering design of the new facilities. The U.S. Coast Guard imposes speed limits on passing traffic while an LNG ship occupies the slip on Elba Island, and the mooring arrangement and dock emergency systems protect the ship and terminal from surge effect. The emergency shutdown on March 14, 2006 as reported in local newspapers demonstrated that these systems worked as designed and prevented any public hazard. The U.S. Coast Guard investigates violations of the speed limit.
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What would happen if a terrorist hit one of the LNG tankships? (Pooler Trans., pp. 97-98; Ga. Conservancy Comment #20060424-05053)
The Captain of the Port for the U.S. Coast Guard in Savannah is conducting a formal risk assessment and evaluation of various safety and security aspects associated with the Elba III Terminal Expansion Project. This assessment will be accomplished through workshops focusing on waterways safety, port security, and consequence management, with involvement from a broad cross-section of government and port stakeholders with expertise in each of the respective areas.
How can the U.S. Coast Guard guarantee the security of the LNG terminal against terrorist attack? (Thomson Trans., p. 37; Tanner Comment #20060426-00086; Lewis Comment #20060424-05133)
LNG operations at Elba Island do not present a higher risk than presented by other, more hazardous products the U.S. Coast Guard has successfully secured in the Port of Savannah. Other products routinely transported by ship in Savannah include gasoline, distillate and residual fuels, ammonia and other chemicals.
The Elba Island terminal has operated safely and securely since first opening in 1978, and particularly since reopening in 2001. Since September 11, 2001, the U.S. Coast Guard and other offices of the U.S. Department of Homeland Security have initiated a number of new programs to heighten security, and SLNG has continued to participate in those programs and cooperate in countermeasures. SLNG adheres to a facility security plan reviewed by the U.S. Coast Guard and will propose any necessary amendments to accommodate changes with the Elba III Project.
Is the Elba Island terminal located in a major metropolitan area? (Tanner Comment #20060426-00086)
No. Elba Island lies within Chatham County outside the City of Savannah and several miles from any densely populated area. Attachment 4 contains a public, photo-based diagram depicting the municipal boundaries (http://www.sagis.org/ ). The planned expansion will occur within the area of Elba Island already dedicated to LNG operations.
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Will the Elba III Project create unacceptable risks to public safety in the Port of Savannah? (Colonial Comment #20060424-05128)
No. LNG and its transportation do not pose unacceptable risks. The Port of Savannah and the Savannah River channel accommodate a variety of products being shipped into and out of the U.S. and between U.S. ports every day. Each of these products, including LNG, has unique characteristics. LNG's characteristics are from a public risk and environmental hazard perspective no more and possibly less threatening than gasoline, distillate, residual fuels, chemicals, slurries and other products already safely handled in the Savannah River channel. The purpose of NEPA and the Commission's environmental review is not to favor these other products over LNG, but to assess the impact of authorizing the Elba III Project on the quality of the human environment. Resource report 11 discusses the impact of the project on public safety.
Has the Federal Aviation Administration (“ FAA ”) established a “no fly” zone over Elba Island? (Thomson Trans., p. 97)
The FAA has not identified Elba Island in any published temporary flight restrictions.
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References
Official Stenographers Report, Elba III Project, Docket No. PF06-14-000, Pooler, Georgia, April 10, 2006 (“ Pooler Trans. ”)
Official Stenographers Report, Elba III Project, Docket No. PF06-14-000, Sylvania, Georgia, April 11, 2006 (“ Sylvania Trans. ”)
Official Stenographers Report, Elba III Project, Docket No. PF06-14-000, Thomson, Georgia, April 12, 2006 (“ Thomson Trans. ”)
Official Stenographers Report, Elba III Project, Docket No. PF06-14-000, Washington, Georgia, April 13, 2006 (“ Wilkes-Washington Trans. ”)
Written comments filed in Docket No. PF06-14-000 (by eLibrary Accession# )
Upland Erosion Control, Revegetation, and Maintenance Plan (Jan. 17, 2003) (“ Plan ”)
Wetland and Waterbody Construction and Mitigation Procedures (Jan. 17, 2003) (“ Procedures ”)
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