TEXAS LNG FACES QUESTIONS FROM U.S. CORPS OF ENGINEERS

By Juan Montoya
Yet another Liquefied Natural Gas export terminal facility has come under the scrutiny of federal entities commenting critically on their application to operate out of the Port of Brownsville ship channel.
The latest one is the application from Texas LNG, which is one of five companies applying for permits to the Federal Energy Regulatory Commission to construct an LNG export terminal facility. According to its website, the Brownsville Texas LNG is described as: "Texas LNG will be located on the north side of the deepwater Brownsville ship channel, on an approximately 625-acre parcel of land inside the Port of Brownsville, exclusively available through a lease option agreement between Texas LNG and the Port of Brownsville authorities.
 The location has an extensive waterfront to the Brownsville ship channel capable of accommodating conventional Liquefied Natural Gas (LNG) carriers, and is approximately 5 miles along the deepwater channel to the Gulf of Mexico. The Brownsville - Port Isabel highway (Texas state highway 48, a 4-lane divided road) runs along the northwest boundary of the site."
The site is also, critics point out, about two miles from Port Isabel, Texas.
Many fear that the establishment of an LNG facility so close to the city will place the residents and sensitive environment there at risk in the case of an industrial accident.
However, the U.S. Army Corps of Engineers has other concerns. In a three-page letter dated Sept. 1 and filed with the FERC Sept. 8,
the Corps Denise Sloan, Regulatory Project Manager, states that:
"Project Purpose and Need Statement in Section 1.2 does not contain information sufficient to address DA Permitting requirements for determining project compliance with Section 404(b)(1) Guidelines. To meet these requirements, this section should include a discussion of Basic Project Purpose and Overall Project Purpose. The Basic Project Purpose allows CESWG to determine if the project is water dependent (see 40 CFR 230.10(a)(3)). The Overall Project Purpose is used to identify and evaluate practicable alternatives (see 40 CFR 230.10(a)(2)).
(To see all the letter, click on link: https://drive.google.com/file/d/0B6lw4gOEnGiEc0hkb05HcnlNeUU3M1pzTmlfRUxUSll3Y2hF/view?usp=sharing
CESWG does not concur with the Project Purpose and Need Statement, as currently written. CESWG will coordinate with the applicant and FERC to formulate appropriate Basic and Overall Project Purpose statements for the proposed project, to be incorporated into project documents."
Aside from other concerns with impact on wetlands and navigable waters and method of dredging the channel, Sloan also questions Texas LNG's failure to address alternative sites. She writes that:
3. Section 10.5 should discuss and illustrate, and reference, both "Offsite Alternatives" and "Onsite Alternatives".
In Onsite Alternatives, other configurations of project elements on Texas LNG's Preferred Alternative site should be discussed and illustrated. Texas LNG's preferred alternative site
should be identified as such in the heading, for example "Port of Brownsville Site 3 (Texas LNG's Preferred Alternative) . Each alternative description should include a discussion of its environmental and jurisdictional impact in comparison with the preferred alternative. The LEDPA should be identified. If the alternative is not the LEDPA, that fact should be noted along with the reason(s) why it is not the LEDPA. The same should be done for the Onsite Alternatives."