In a Feb. 12, 2008, letter to Oregon Gov. Ted Kulongoski, Bradwood Landing
provided responses to comments submitted by the state regarding the Federal Energy
Regulatory Commission's draft Environmental Impact Report (dEIS) on its proposed liquefied
natural gas (LNG) terminal. While the company's formal response to Oregon agencies'
comments will be submitted to FERC so that it is part of the official record, Bradwood provided
the state with a detailed progress report for the issues identified in the Governor's Dec. 13, 2007
memo to FERC.
"I appreciate the State of Oregon's analysis of the draft Environmental Impact Statement for the
proposed Bradwood Landing LNG import terminal," said NorthernStar Natural Gas CEO William
"Si" Garrett. "Such a complex proposal requires a thorough examination of the record to ensure
that the public's interest has been served."
In its letter, Bradwood noted that FERC's dEIS was based on information dated several months
prior to its publication. Although new information was provided by Bradwood, the overwhelming
majority of issues identified by the state had already been addressed prior to the state's
comments. Bradwood Landing has continued to submit significant additional information to state
and federal agencies since the dEIS was drafted in the summer of 2007.
Because state agency comments to the dEIS explicitly did not consider information beyond what
was contained in the dEIS document itself, Bradwood developed a direct reference to the
underlying source data to facilitate Oregon agencies' review of supporting information.
The public record on the Bradwood terminal is extensive, encompassing thousands of pages of
testimony, expert technical reports and public comment. All of this information is produced as
part of a well-defined process that allows for input and review by all parties. The documents
continue to be updated and are a snapshot in time; however, they serve as a ready reference
for those agencies that need this information now.
"We prepared a comprehensive reply to address each comment," said Garrett. "Where
necessary we have provided new information, provided copies of previously submitted data that
wasn't considered by the state, and corrected certain assumptions in the original document."
"The facts are clear: the Northwest needs additional supplies of natural gas," said Garrett. "The
Bradwood Landing project is in a position to help meet that need while actually enhancing the
environment, providing jobs and revenue to Oregon, enhancing public safety, and setting a new
high standard for industrial development."
Highlights of the responses provided by NSNG are below.
- There is a clear need for additional supplies of natural gas in the Northwest.
Within the past two years, nine independent studies have examined North American and Pacific
Northwest natural gas markets. They have all come to the same conclusions: the Northwest's
traditional supplies of natural gas are declining.
- Detailed geotechnical evaluations of the site were conducted.
NSNG has conducted considerable geotechnical reports that have shown the Bradwood site
suitable. This information was summarized in the dEIS and the Oregon agency comments were
- NSNG's environmental plan exceeds requirements.
The dEIS did not reflect information regarding NSNG's updated mitigation plans and the state
did not evaluate those plans as part of its comments on the dEIS even though they had been
submitted to the state. NSNG's environmental plan goes above and beyond regulatory
requirements. For example, although only impacting slightly more than 13 acres of wetlands,
NSNG will either create or conserve 291 acres of higher value habitat. In addition, our Salmon
Enhancement Initiative is a voluntary effort that represents the largest private commitment to
watershed health on the Columbia River and will actually provide a net ecological benefit for the
- Dredging will have minimal environmental impact.
The area needed to dredge for the ship turning basin at Bradwood would occur in deep water
(greater than 20 feet). Deep water is generally not utilized by salmonids, particularly juvenile
salmonids that tend to stay in the upper water column.
- NSNG is paying for all safety and security upgrades and will not burden local emergency
NSNG has circulated an Emergency Response Plan to effected agencies and is in the process
of finalizing resources that will be made available to local emergency responder agencies and
will pay for all safety and security upgrades (totaling approx. $160 million) associated with its
- NSNG has submitted a decommissioning plan.
A decommissioning plan was submitted to Clatsop County and the Oregon Department of
Energy in the fall of 2007. This information is outside the scope of the dEIS.