USCG - Analysis of Tanker Traffic Through Canadian Waters - Calais LNG

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ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

COTP SECTOR NORTHERN NEW ENGLAND ON SEPTEMBER 21, 2010
1. INTRODUCTION: This is to supplement my Letter of Recommendation (LOR) dated

September 21, 2010 which conveys my recommendation on the suitability of Head
Harbor Passage, Western Passage, Passamaquoddy Bay, and the St. Croix River
(hereafter collectively termed the Passamaquoddy Bay Waterway) for liquefied natural
gas (LNG) marine traffic associated with the Calais LNG Project Company LLC (Calais
LNG). It documents the processes followed in analyzing Calais LNG’s Waterway
Suitability Assessment (WSA) completed on August 28, 2009, and the suitability of the
waterway.
For the purposes of this analysis, the following assumptions were made:
a. The applicant is fully capable of, and would fully implement, any and all risk
mitigation measures they identified in their WSA and referenced in this LOR
Analysis.
b. The conditions of the port area identified in the WSA fully and accurately describe
the actual conditions of the port area at the time of the WSA submission.
c. The conditions of the port area have not changed substantially during the analysis
process.
d. The applicant will fully meet all regulatory requirements including the development
and submission of a Facility Security Plan, Emergency Manual and Operations
Manual.
2. BACKGROUND: The data and information regarding the proposed LNG import
terminal and storage facility detailed in this Letter of Recommendation Analysis (LORA)
were derived from Calais LNG’s Application and supporting Resource Reports filed with
FERC, as well as information provided directly to the Captain of the Port (COTP) Sector
Northern New England (SNNE) in the Calais LNG’s Letter of Intent (LOI) and WSA.
The WSA is an applicant-prepared, risk-based assessment designed to document and
address all safety and security concerns related to the marine transportation of LNG for a
U.S. port or waterway. The scope of the Calais LNG WSA was based on U.S. Coast
Guard (Coast Guard) policy guidance contained in Navigation and Vessel Inspection
Circular (NVIC or Circular) 05-08, Guidance Related to Waterfront Liquefied Natural
Gas (LNG) Facilities, dated December 22, 2008, including Change 1 to that Circular
dated March 18, 2009. The intent of the NVIC is to provide guidance to (1) an owner or
operator seeking approval from the Federal Energy Regulatory Commission (FERC) to
build and operate a LNG facility onshore or within State waters, and (2) the Coast Guard
as it assesses LNG marine operations under its regulations contained in 33 CFR Part 127.
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Calais LNG is proposing to construct and operate an LNG import terminal and storage
facility within a 337-acre tract of land just north of Ford Point, within the city limits of
Calais, on the St. Croix River in Washington County, Maine. The project is intended to
have the capability to receive, store, and vaporize LNG at a baseload sendout rate of 1.0
billion standard cubic feet per day (bcfd). The proposed facility includes an
approximately 1000-ft marine trestle connected to an unloading platform capable of
accommodating ships’ port and starboard sides, vessel mooring system, liquid and vapor
piping, two 160,000 m3 full-containment onshore storage tanks with potential expansion
for a third, regassification equipment, and ancillary, supporting infrastructure. An
approximate 20-mile sendout pipeline will connect the facility to the interstate Maritimes
and Northeast Pipeline. It is anticipated that one to two LNG carriers a week, ranging in
cargo capacity from 120,000 to 170,000 m3 each, would be arriving from a foreign port
and offloading to the terminal.
The location where Calais LNG has proposed to construct and operate their onshore LNG
import terminal and storage facility is contained within state waters. Therefore, under the
Energy Policy Act of 2005, the lead federal agency for this project is the Federal Energy
Regulatory Commission (FERC). As the lead federal agency, FERC is responsible for
making the final decision as to whether or not license the project. As per the
requirements contained in 33 Code of Federal Regulations (CFR) Part 127, Calais LNG is
required to submit a Letter of Intent (LOI) to the Coast Guard. Information contained in
that LOI enables the COTP to provide specific input, via a Letter of Recommendation
(LOR), to FERC as to the suitability of the waterway to support LNG marine traffic
associated with the Calais LNG project. My LOR and this accompanying analysis are
not to be construed as a permit or other “major federal action”. They are instead, my
recommendation based upon the Coast Guard’s expertise in navigation safety and
maritime security.
The intended transit route, from sea to project site, includes the Grand Manan Channel
from the Gulf of Maine or the approach to the Bay of Fundy from the Atlantic Ocean
(optional segments), Head Harbor Passage, Western Passage, Passamaquoddy Bay, and
the St. Croix River (hereinafter collectively termed the Passamaquoddy Bay Waterway).
All aspects of the transit route to and from the proposed import terminal and storage
facility were evaluated, including tides and currents, prevailing weather, density and
character of marine traffic, deep draft vessel management, recreational boating and
commercial fishing, navigational aids (buoys, markers etc.), regional waterway events,
surrounding community/port impacts, and relevant environmental/iconic considerations.
Applicable navigation charts are National Oceanic and Atmospheric Administration
(NOAA) 13394 (approach), NOAA 13396 (inward passage), and NOAA 13398
(Passamaquoddy Bay and St. Croix River). The proposed LNG vessel transit route
passes through both United States and Canadian waters; as well, portions of the vessel’s
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intended track line follow and straddle the maritime international boundary between the
countries. This required that Calais LNG adequately address and resolve several trans-
boundary considerations concerning safety and security risks, regulatory requirements,
and potential environmental/populace impacts. According to their WSA, Calais LNG
expended a significant amount of effort to gain input from Canadian government
organizations relative to the safe and secure transportation of LNG. However, they assert
that in many cases productive dialogue was encumbered by the overall objection by some
Canadian politicians to U.S. LNG projects that will require a transit of Head Harbor
Passage and Passamaquoddy Bay. As further stated in their WSA, Calais LNG is intent
on continuing their efforts to gain Canadian communication and cooperation and meet all
reasonable Canadian requirements.
3. RESOLUTION PRECIS: The following paragraphs summarize the myriad of specifics

considered and reasoning behind my recommendation. This synopsis is not all inclusive;
supplementary information and amplifying data are contained in the applicant’s WSA, to
include ship simulation studies, vessel traffic analyses, port characterization appraisals,
and risk-based safety/security assessments, among others.
The hydrographic characteristics of the waterway currently sustain deep draft vessel
movement and the simulation tests confirm that the transit and maneuvers are
comparatively feasible for the design range of LNG carriers anticipated; however, there
exist certain risk management measures and response capabilities essential to a safe and
secure port-area climate that would need to be incorporated into FERC’s authorization
order in order for the waterway to be considered suitable for LNG marine traffic. These
safety/security recommendations, resource shortfalls, and/or implementation strategies
are identified in the following paragraphs, where applicable. Specific recommendations
proposed by Calais LNG (as per their WSA) are denoted as “WSA Recommendation #1,
2, 3 …etc.” For ease of reference, the numbering scheme used in the WSA was
maintained throughout this Analysis, and therefore is not sequential. Comments pertinent
to a particular WSA Recommendation, and/or the identification of additional risk
management measures deemed essential by the COTP, are also provided where relevant.
An abridged summary of the WSA Recommendations is provided on pages 73 and 74.
4. WATERWAY TRANSIT CONSIDERATIONS
Maritime Commerce
The Passamaquoddy Bay Waterway is a mixed use thoroughfare of international
significance. Specific segments of the transit route are within the COTP SNNE’s Area of
Responsibility, while other portions are contained in part, or wholly, within Canadian
waters. Year-round recreational, commercial, and fishing boats share this waterway
going to, and from, port communities along both sides of the maritime boundary. The
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waterway has historically been, and continues to be, a relatively vibrant shipping channel
for commercial vessels plying the port of Eastport on the U.S. side, and the port of
Bayside on the Canadian side. Together, the ports received approximately103 deep draft
vessels in 2009. Of those, about 48 exported aggregate on the larger bulkers, and 25
transferred cargo on smaller sized vessels to include potatoes, timber products, gypsum,
frozen meat/fish, phosphates, and ammonium nitrate fertilizers to/from Bayside. Vessels
serving Estes Head in Eastport numbered around 30, primarily picking up bailed paper
pulp and other wood products processed by an area pulp mill. The amount of ship traffic
for Eastport has declined over the past few years for two reasons: (1) the Domtar Co.
pulp mill shut down for a significant period of time in early 2009 and didn’t resume
limited operations until 2010; and (2) vessels with appreciably larger capacities (gross
tonnages) are now being employed, which translates to fewer ships for the same gross
tonnage per annum.
Deep-Draft Traffic
As previously mentioned, Calais LNG anticipates that one to two LNG carriers per week
(average of 70-78 per year), ranging in cargo capacity from 120,000 to 170,000 m3 each,
would be transiting the waterway if their project is permitted by FERC. A competing
developer, Downeast LNG, has also filed an Application with FERC to construct and
operate an LNG import facility near Mill Cove, at the confluence of Passamaquoddy Bay
and the St. Croix River. Should that project be approved, an additional 53 (on average)
LNG carriers could conceptually transit the waterway annually bringing the combined
total for all deep-draft facilities to roughly 234 per year, which equates to a 127%
increase in vessel traffic over current numbers. In reality, the numbers of LNG ship
transits would be determined by market demand and supply, not simply terminal
operating or storage capacities. Nonetheless, there would definitely be a significant
impact on vessel traffic management and the need for cautious transit planning – both of
which will be addressed in more detail in subsequent sections.
Transit Route Description

An LNG carrier’s transit from sea to the Calais LNG terminal would follow a circuitous
route through both Canadian and U.S. waters, and is virtually the same approach route as
that currently used by all deep-draft vessels servicing the Port of Bayside, New
Brunswick, CA. Accordingly, LNG carriers will be traversing waters under the
jurisdiction of the state of Maine, and at times waters under the jurisdiction of Canada.
From sea, the vessels will either transit the Bay of Fundy and transit along the eastern
side of Grand Manan Island (St. John, NB traffic scheme) or if transiting the Gulf of
Maine, travel northerly along the Grand Manan Channel, which is on the westerly side of
Grand Manan Island (see Figure 1) 1 . Vessels then pass East Quoddy Head and enter
1
Reprinted, courtesy of ABS Consulting Inc. with permission by Calais LNG.
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Head Harbor Passage, passing between Campobello Island and Deer Island (all Canadian
waters). At the exit of Head Harbor Passage and in the vicinity of Friar Roads vessels
follow, and predominately straddle, the international maritime boundary line along their
intended route through Western Passage, Passamaquoddy Bay, and the St. Croix River
whereupon, after rounding St. Croix Island, they then turn back into Maine waters to the
proposed Calais site. The total transit time (including the approaches) would be
approximately 8 hours in duration. The transit time for the “inland” portion of the route
would be about three hours, assuming a vessel speed of 10 knots and favorable tide
conditions.
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Figure 1
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Hydrographic Characteristics
The channel is naturally deep and currents in the area run up to 5-6 knots due to the
extreme tides, with the mean range being 18 feet, and reaching 28 feet under
extraordinary circumstances. Maintenance dredging is not required. The shoreline
quickly disappears into deep water very close to the shore at high tide. At low tide there
is a considerable expanse of exposed sand and mud intermixed with a substantially rocky
shoreline containing shoals and land points that abruptly jut out into the waterway. The
waterway is dotted with large and small islands. The largest islands are contained in
Canadian waters and inhabited year-round. The intended route skirts the shoreline of the
three Fundy Isles – Deer Island, Campobello Island, and Grand Manan Island.
There are no known physical hazards, such as shipwrecks, large reefs, or shoals along the
deep-draft vessel route; as well, there are no man-made obstructions such as bridges,
dams or locks. The only major chokepoint measures approximately 1,000 yards wide
and is located between Dog Island and Deer Island Point. This area is subject to
whirlpools on the ebb and flood tides where currents from Western Passage and
Passamaquoddy Bay converge. The so-named “Old Sow” whirlpool, for example, has
garnered significant interest as a tourist attraction and has been blamed for small
recreational vessels losing control when unknowingly caught in its vortex. Due to the
extreme and divergent currents in this area, pilots need to favor the Maine coast off Dog
Island when making this bend and primarily move ships through this area as close to
slack water as possible. This window of time varies according to the particular tidal
range for the day, but lasts about one hour in duration. For this reason, voyage planning
and traffic management are critically important; all inbound and outbound transit times
are predicated upon the vessel passing through this choke point during the slack water
window. The second narrowest point between land masses occurs in Canadian waters,
within Head Harbor Passage between Casco Bay Island and Head Harbor, measuring
approximately 1,200 yards in width at the narrowest. The shallowest water depths along
the route are found in the St. Croix River and alongside the proposed dock. Bathymetry
surveys have accurately profiled the bottom character of the river with the minimum
charted depth being 44 feet at mean low-low water, just outside of the channel near buoy
11, one of two aids marking scattered shoaling and ledges surrounding St. Croix Island,
which is located mid-river off Red Beach on the U.S. side, and about 1.9 miles southward
of the port of Bayside, NB on the Canadian side. While the navigable width adjacent to
the island is only about 350 yards, this area does not experience the divergent and fast
currents commonly confronted off Dog Island.
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Figure 2
Figure 3
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Figure 4
Figure 5
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Figure 6
Figure 7
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Figure 8
Figure 9
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Figure 10
Figure 11
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Figure 12
Figures 2 through 12, courtesy of Quoddy Pilots, USA, provide a graphic overview of the
transit route, sub-divided into segments, containing reference data and points of interest
from a pilot’s perspective.
Alternative Approaches
Calais LNG has proposed that all prospective LNG carriers serving its facility enter the
system via the Grand Manan Channel, which would be the most direct passage for those
bound for the Bay of Fundy from the Gulf of Maine. The company opines that this
would serve to avoid a known right whale conservation area altogether, and as well,
better situate the vessel for Coast Guard safety and security boardings while still in U.S.
waters.
While routing of the vessels as recommended would, in fact, serve the purposes stated,
the COTP has determined that there are other factors that necessitate additional
consideration. These factors include: (1) a significant amount of commercial fishing and
lobstering takes place along the Grand Manan Channel, and increased deep draft traffic
could potentially interfere with fishing gear and hamper operations; (2) a boarding area
off West Quoddy Head could be severely impacted by offshore weather fronts, persistent
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fog, and heavy sea conditions; and (3) while Calais LNG may recommend vessels take
this route, navigational course decisions ultimately rest with vessel masters and,
depending on the vessel’s location, may be affected by consultation with the prospective
pilot and Fundy Traffic.
Vessel Traffic Management

All deep-draft vessels transiting the Passamaquoddy Bay Waterway fall under the
operational control of St. John, New Brunswick Traffic Control (Fundy Traffic). Using
radio communications and the Automatic Identification System (AIS), vessel arrivals and
departures are coordinated for the Estes Head and Bayside terminals by Fundy Traffic
with the intent of avoiding vessel head-to-head, close encounter, or overtaking situations.
It should be noted that the existing communications network (and associated
interoperability) is marginal for the port area. As well, regional radar coverage is very
limited. Fundy Traffic has radar coverage in the Bay of Fundy, but does not have visual
or radar coverage once inside Head Harbor Passage. Upgrades to the current navigation
systems and/or acquisition of new technology, such as Physical Oceanographic Real-
Time System (PORTS), Differential Global Positioning System (DGPS), and closed
circuit television (CCTV), that are cross-border compatible and jointly supported are
needed to ensure safe transits of the carriers and to safeguard all water way users and
abutting shore-side communities along the intended route. Without navigation safety
system expansion and/or increased coverage, additional operational parameters may need
to be considered and implemented accordingly. Currently, vessel positioning is strictly
dependent on VHF radio contact between the vessel masters, pilots and Fundy Traffic,
coordinated through local, cooperative agreements. To maintain safe maneuvering
capability and reduce the potential for collision the respective pilots or vessel masters
relay their course positioning details to Fundy Traffic at established way points along the
transit route. Current practice employs informal one-way traffic patterns for deep-draft
transits. This would be strictly enforced whenever LNG carriers are moving; i.e., no
meeting or overtaking situations.
WSA Recommendation #5: Allow limited two-way oceangoing vessel traffic during LNG
transits. Calais LNG recommends that the Coast Guard consider two-way traffic (limited
to specific, pre-approved locations within Passamaquoddy Bay where there is sufficient
open, navigable space in which to safely maneuver) to minimize the potential for delays
involving deep-draft vessels transiting to or from the Port of Bayside. The specifics
would be prescribed in a Transit Management Plan, and each occurrence would require
the concurrence of the COTP.
The COTP does not fully concur. At present, there is no radar coverage or monitoring
capability inside of Head Harbor Passage. Complicating the issue there is no
‘formalized’ traffic management system in place; there is no compulsory pilotage for
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vessels bound for Bayside; and the ability to upgrade current ATON in Canadian waters
to meet regional pilots’ recommendations (as per the simulation testing) remains
questionable. Therefore, unless resolution can be brought to the aforementioned, the
risks are considered too great to allow two-way oceangoing vessel traffic during LNG
transits. Notwithstanding, the COTP does agree with the applicant that this issue could
be revisited in the future when and if identified risk mitigation measures are addressed,
and after practical experience with LNG carriers is gained.
WSA Recommendation #4: Improved Portable Electronic Navigations System for Pilots.
Currently, both U.S. and Canadian pilots use handheld ‘Personalized Digital Assistant’
technology possessing Global Positioning System (GPS) and electronic chart interface to
provide accurate and functional position data for all transits being made to the Estes
cargo terminal, and ports of Eastport and Bayside. Calais LNG supports and encourages
the use of data systems of this type and is recommending that “next generation” utilities
be explored for possible use by the pilots that would make use of tidal currents and
bathymetry data that Calais LNG had previously collected in support of its project to
enhance vessel movement and docking operations. The COTP concurs with using all
navigational means available to aid in the safe transit of vessels.
Vessel Traffic Service (VTS)

In a closely related issue, proponents for LNG development and advocates for the
commercial fishing industry have suggested that a safety fairway for deep draft traffic be
instituted for the Grand Manan Channel in order to reduce the possibility of LNG carrier
interference with fishing and lobstering activities. While this proposal has considerable
merit and deserves further study, it should be recognized that it would necessitate the full
consent and cooperation of the Canadian government due to adjoining waters, and timing
may become a factor in that traffic management options, such as a safety fairway, would
invoke federal rulemaking in order to develop, promulgate, and implement the pertinent
regulations, and could possibly require submittal to the International Maritime
Organization for approval, depending on determined needs and anticipated boundaries.
Similarly, a number of comments and questions surfaced during the review process in
reference to the Cooperative Vessel Traffic Services (CVTS) system in place for the
Strait of Juan de Fuca (shared waterway between Washington and British Columbia)
along the western coast of U.S. and Canada. As outlined in 33 CFR Part 161, a CVTS
facilitates traffic movement and anchorages, avoids jurisdictional disputes, and renders
joint emergency assistance within adjoining waters. For the Juan de Fuca region
Canadian and U.S. Vessel Traffic Centers manage traffic within the CVTS area
irrespective of the International Boundary. In the case of the Passamaquoddy Bay port
area, however, there is no U.S. Vessel Traffic Service (VTS); only the quasi VTS in St.
John, N.B. (Fundy Traffic) exists. The establishment of a CVTS or similar traffic
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services system would entail significant cooperative planning between the two nations,
including respective resource identification and allocation, a bilateral response
mechanism, full concurrence on traffic control, expanded interoperability capabilities,
mutual recognition of safe refuge areas, and joint Aid to Navigation (ATON)
management, just to name a few. While a full-scale CVTS may or may not be plausible,
the same shortfalls as previously identified for a VTS system currently exist, and would
need to be laterally addressed by both governments in order to safely and securely
support LNG traffic along the shared waterway.
WSA Recommendation #6: Vessel Monitoring and Control by Fundy Traffic. Calais
LNG recommends follow-on collaboration with U.S. and Canadian authorities to improve
monitoring capabilities of the transit route. They posit existing and proposed radar, radio
communications, closed-circuit TV and AIS coverage of the transit route be analyzed and
follow-on procedures developed. COTP SNNE concurs; this recommendation is
incorporated into the risk mitigation measures provided in Section 8.
WSA Recommendation #3: LNG Transit Management Planning and Coordination. To

further define and document transit plans and operational expectations Calais LNG
intends to hold periodic meetings involving all transit participants (e.g., pilots, state,
federal and provincial agencies, shipping agents, tug companies, and LNG carrier
representatives). These planning meetings will focus on the topics and safeguards as
outlined in Enclosure 1 of NVIC 05-08, Change 1. It is anticipated that the Transit
Management Plan (TMP) will be similar in format and content to a “memorandum of
understanding” type document in which the role of each agency and industry component
will be clarified and the expectations of each detailed, as appropriate, using Enclosure 2
of NVIC 05-08, Change 1 as a guide. The COTP concurs with this recommendation.
Anchorages
At present, there are no designated “anchorage grounds” (anchorage areas subject to
pertinent rules and regulations) directly within the Passamaquoddy Bay port area;
however, historically vessels have anchored in the vicinity of Friar Roads when awaiting
dock availability in Eastport, within Passamaquoddy Bay to avert traffic or wait out
adverse weather and/or unfavorable tide/current conditions, and occasionally in the St.
Croix River just off the Port of Bayside when waiting for a vessel to move off berth.
When coming from sea, deep-draft vessels routinely anchor in the Bay of Fundy (outside
of the transit corridor and to the north of Head Harbor Passage in the vicinity of The
Wolves, dictated by water depth).
Along Head Harbor Passage and portions of Friar Roads there are submarine pipeline and
cable crossings that would preclude vessel anchoring – these are adequately charted.
Under current practice, non-LNG vessels anchor in, or hold at, Friar Roads or
Passamaquoddy Bay while waiting for a vessel proceeding in the opposite direction to
transit Head Harbor Passage or Western Passage. COTP SNNE has concluded that LNG
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vessels will not be allowed to anchor in Friar Roads or Passamaquoddy Bay while
waiting for traffic and/or a berth – anchoring or holding under these circumstances must
occur offshore. Notwithstanding, with the exception of temporary boarding areas
established by and for Coast Guard authorized resources, the anchoring or holding of
LNG vessels within Friar Roads will be limited to emergency situations only, such as
major mechanical malfunctions and reduced visibility consequent to non-forecasted,
abrupt weather changes (fog, squalls, etc.) and/or as directed by, and in consultation with,
the COTP.
Pilotage
All deep draft ships currently entering the shared waterway via Head Harbor Passage and
thence transiting Maine waters to Estes Head in Eastport must utilize a licensed pilot in
accordance with Maine and U.S. laws. In contrast, there is currently no requirement
under Canada’s Pilotage Act or Atlantic Pilotage Regulations mandating compulsory
pilotage for vessels transiting these same waters bound for Canadian ports. In practice,
however, unlicensed Canadian pilots are voluntarily employed on 90-95% of all vessels
bound for the Bayside Port Corporation marine terminal in New Brunswick.
Significant to the Calais LNG proposal, in May, 2006 a risk-based review of the St. Croix
River and its approaches was conducted by Marine Transportation Consulting to
ascertain whether the current practice of non-compulsory pilotage should remain status
quo. The assessment was conducted under the auspices of the Atlantic Pilotage Authority
(APA), the Federal Crown Corporation charged with pilotage services, to ensure the
waters meet the standards of safety of Transport Canada and the Minister of Transport.
Six recommendations resulted from the study:
• The waters and approaches to the St. Croix River to the Port of Bayside should be
designated as a Compulsory Pilotage Area.
• The APA should adopt as much of the existing pilotage infrastructure as possible.
• A review of existing “Fundy North” (Fundy Traffic) monitoring capabilities
should be conducted with a focus on improving VHF radio coverage, radar, and
Automated Information Systems (AIS).
• The establishment of “designated” anchorages in concert with the commercial
fishing industry and in communication with the U.S.
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• Review the location and adequacy of the navigational aids currently in use and
add/upgrade aids as necessary to mark all areas posing a hazard to navigation.
Re-chart the area, to include the conjoining waters of Head Harbor Passage and
Western Passage, to reflect current stationing of all aids and location of unmarked
hazards to navigation.
• Recommend that the U.S. Coast Guard include consultation with the local U.S.
pilots when conducting the next Waterways Analysis and Management System
(WAMS) review.
Complementing the risk management study, the APA also conducted a review of its
pilotage regulations in cross-comparison to those existing, informal procedures currently
in wide practice. After close collaboration with the U.S. Coast Guard, joint consensus
was tentatively reached on jurisdictional concerns in order that APA’s proposal for
compulsory pilotage move forward. A proposed amendment to the Atlantic Pilotage
Authority regulations has been drafted and is pending regulatory review and public
comment.
WSA Recommendation #16: Local Pilots for Each Transit. Calais LNG recommends
that both a U.S. pilot and a Canadian pilot be aboard each LNG carrier during initial
transits to and from their proposed terminal site. The impetus behind this
recommendation is to take advantage of the Canadian pilots’ existing experience, derived
through their routine piloting of ships to and from the Bayside terminal in New
Brunswick. Calais LNG also contends that through the supplementation of Canadian
pilots, transit-related navigation concerns of Canadian authorities will become more
transparent and ultimately benefit the transit management planning and implementation
process.
The COTP concurs, in theory, with this recommendation. The details as to how the pilots
would actually operate in tandem, as well as the jurisdictional legality regarding
authorities, responsibilities and liabilities, would need to be determined. If and when this
occurred, all operating procedures and parameters would then need to be clearly detailed
in the Transit Management Plan. The COTP also concurs with Calais LNG’s
recommendation that, if concurrent agreement were reached between the appropriate
federal and state/provincial agencies, additional familiarization training for the size and
type of LNG carriers intended, would need to be acquired through further full-mission
bridge simulator trials and/or via practical experience.
Pilot and general boarding areas

Presently, through locally conceived, informal agreement, U.S. pilots board the majority
of deep-draft vessels bound for Eastport in Canadian waters, in the vicinity of East
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Quoddy Head. LNG vessels are designated Certain Dangerous Cargo (CDC) carriers and
as such, routine safety inspections and security precautions are normally undertaken by
the Coast Guard, in U.S. waters, prior to these type vessels entering port. Accordingly,
the only boarding options currently available in which to perform these mission-oriented
activities remain the Gulf of Maine, in the near-shore vicinity of West Quoddy Head, and
in Friars Road, off Campobello Island and the port of Eastport. In the former, exposure
to seasonal high winds and heavy seas are determinate factors, and in the latter, the close
proximity to population densities remains a significant consideration.
Simulated Maneuvering Trials

During the period October 6-10, 2008 a proof of concept evaluation was performed by
Marine Safety International (MSI) at their facility in Newport, Rhode Island at the
request of, and in coordination with, ABS Consulting (ABS) on behalf of Calais LNG.
Twenty daylight trial runs were made utilizing full mission bridge simulators to evaluate
the marine aspects of navigating LNG carriers from the pilot boarding area off East
Quoddy Head to the proposed terminal site on the St. Croix River. The evaluation was
based on inbound and outbound vessel transits, partial transits under restricted conditions,
docking and undocking maneuvers, and the interjection of challenging impromptu,
emergency-based scenarios to include:
• Various mechanical failures (i.e., loss of rudder/steering, loss of propulsion).
• Emergency departures from the dock using limited tug assistance.
• Extreme/severe climatic conditions (tides/current/winds/fog).
In attendance for the simulation trials were MSI staff, Calais LNG principals and
consultants, Canadian and U.S. pilots, and U.S. Coast Guard representatives. All
simulations were conducted ‘real time’ with a 23-nautical mile one-way trip
approximating 3 hours in duration.
The objectives of the maneuvering studies were to:

• Determine the feasibility of navigating various sized fully loaded LNG
carriers from the pilot station to the proposed terminal site on the St. Croix
River at various stages of tides and currents.
• Ascertain the adequacy of four Azimuth Stern Drive Tractor Tugs (ASD);
two rated at 60 tons and two at 80 tons bollard pull, for tethered escorting,
assisting with docking maneuvers, and their ability to control the LNG
carrier’s movement under varying conditions of emergency operations such
as engine/rudder and equipment failure.
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• Identify the risks involved during inbound and outbound transits and
determine appropriate risk-mitigation factors.
• Determine the limiting environmental factors for inbound and outbound
transits.
• Evaluate arrival, turning, and departure maneuvers in the vicinity of the
terminal berth.
• Ascertain the adequacy of existing aids to navigation and identify potential
upgrades/changes that would contribute to an increased margin of safety.
• Define tethering locations, speeds, and arrangements for the ASD’s.
Simulation runs were made using LNG carriers in the 138,000 to 210,000 cubic meter
cargo carrying capacity range, and incorporated varying rudder and propulsion
configurations. The models were based on existing carriers currently plying North
America, to include the LNG RIVERS, BERGE BOSTON, BRITISH EMERALD, and
AL SAFLIYA, and the tractor tugs were modeled after the ASD DIANE MORAN and
ASD BULLDOG. The full-mission bridge simulation provided the pilot(s) with visual
cues of the surrounding areas as well as the handling/maneuvering characteristics of each
size vessel under test. The pilots were able to anticipate changing waterway
characteristics and varying traffic conditions, commencing at the pilot pickup area to the
geographical limits of their respective licenses, based on their experience and astute
familiarity with the area. This “hands on” simulation strategy provided the pilots with
exposure to the proposed LNG carriers, and correspondingly identified potential areas of
concern without compromising real-life safety.
Due to the extreme tides and resultant strength of currents in the area, adequate tug/escort
power was determined to be critical, especially during berthing and departure maneuvers;
when transiting waters from Cherry Islet to Dog Island; and when navigating relatively
narrow areas, such as around St Croix Island. Two 60 and two 80 metric-ton bollard-pull
tractor tugs were used to assist with transit, docking, and undocking operations
throughout the majority of simulations. The tugs were modeled with fully azimuthing
propulsion units, allowing them to quickly change propulsion direction and manage the
speed and steering of the LNG carriers, even under “dead-ship” conditions. For the
vessel maneuvering analyses a variety of climatic settings were introduced to simulate
predominate, seasonal conditions common to the Passamaquoddy Bay region. The
simulator interjected varying weather and hydrodynamic conditions to include current
directions and speed, stages of ebb and flood tides, wind velocities and changing
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directions, wind gusts, and low visibility factors. The injected variables ranged from
normal/routine to extreme. Simulations were also conducted based on worst-case
scenarios in order to ascertain breakaway limitations and confirm tug capabilities. Each
pilot was advised of the prevailing environmental factors at the beginning of each
computer/simulation run, and he then made up the tugs in whichever fashion best suited
him to meet the existing and/or expected, emergent conditions.
General findings:
• LNG carriers in the projected design ranges can be safely navigated from the pilot
boarding area to proposed terminal berth and returned to sea on a repeatable basis.
• Two 80 ton and two 60 ton bollard pull tractor tugs provide adequate control of
the LNG carriers and are sufficient for assisting and escorting the design range of
LNG carriers to the terminal. Tethered escorting from the pilot boarding area to
the terminal is recommended. At a minimum, an 80 ton ASD tug should be
tethered through the LNG carrier after lead to provide ‘braking’ power and
enhance steering capability. Likewise, two 60 ton ASD tugs should be tethered
through the LNG carrier bow center lead to aid in steering throughout the St.
Croix River transit.
• Tests proved that real-time measurements of current velocities and directions are
needed and this data should be made available to the pilots on a 24-hour basis.
For maximum effectiveness, it was determined that a current meter should be
staged between Dog Island and Cherry Islet, and another placed at the north end
of the proposed terminal berth.
• Environmental limitations that preclude transits include maximum sustained
winds of 25 knots and a minimum forecasted or actual visibility of two miles.
• Nighttime operations were not simulated during these trials. Consequently, prior
to any LNG carrier nighttime transits, further simulation tests need to be
accomplished to further ascertain the suitability of the current ATON system to
support non-daylight/restricted visibility operations.
• A formalized, one-way traffic control for deep-draft vessels transiting the
waterway needs to be in place.
• Additional integrated training is needed by the area pilots and respective ASD tug
captains to ensure equal familiarity and competency prior to any actual operations
taking place. A training plan should be established to preserve and build on the
necessary skill sets.
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• Transiting the Cherry Islet to Dog Island area should be avoided on a flood tide
and during those times when ebb tide currents exceed three knots.
• LNG carriers should always be berthed bow forward (i.e., into the tidal currents)
to ensure maximum maneuverability/control during docking evolutions.
• Historically speaking, vessels currently plying the region and carrying aggregate
and other less-valued cargo per ton, by the very nature of their services, may be
older and less than optimally maintained. These vessels currently transit the
waters without tug assistance and/or escort. A mechanical malfunction, such as
sudden loss of steering and/or propulsion, could potentially result in an allision
with one of the berthed LNG tankers during cargo offload, resulting in a serious
casualty. In order to afford an additional margin of safety, it is therefore deemed
prudent to have a standby tug at the ready of all berthed LNG vessels.
• ATON placement and optimum operability were evaluated by the pilots.
Recommended ATON changes included:
1. Establishing a lighted buoy at Stovers Ledge to mark the shoal area.

2. Adding a beacon and radar reflector on Clark Ledge.
3. Increasing the light intensity of the Dog Island and Deer Island fixed aids.
4. Relocating and lighting the “UH4” buoy at Popes Island.
5. Adding a lighted range in the vicinity of Kendall Head
6. Placing a lighted beacon on the east side of Kendall Head.
7. Placing a range in the vicinity of Eastport to better define the Head Harbor
inbound track line.
8. Placing a light on the west side of the Clam Cove Peninsula.
9. Relocating the St. Croix River G “11” buoy to better mark the channel
limit.
10. Adding additional aids to better mark the St. Croix River entrance.
The above is an abridged summary of the MSI simulation results and observations made
by the pilots and observers. Within the parameters of those tests conducted, the
simulated passages were relatively uneventful, even during virtual mechanical
malfunctions, as long as escort tugs were utilized effectively and the environmental
window limits adhered to. The full report, marked Appendix A, is contained within the
Calais LNG WSA.
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WSA Recommendations #1-Tugs for Escort and Docking Assistance; #2-LNG Carrier
Familiarization/Training for Pilots and Tug Captains; #7-Operational Limits for Ship
Transits; #8-Improved Aids to Navigation (ATON); and #9-Installation of
Instrumentation at the Calais LNG Terminal Berth were all by-products of the simulation
trials, as outlined above. The COTP SNNE generally concurs with the overall findings;
the above recommendations are incorporated into the risk mitigation measures denoted in
Section 8, pages 68-74. Of note: With the exception of the Dog Island aid, Clark Ledge
beacon and Kendall Head marker, the manufacture, placement, and servicing of the
remaining navigational aids fall under the authority of the Canadian government. It is
unknown at this time whether the Canadian Coast Guard (CCG) will undertake the
recommended modifications to its waterway infrastructure in support of LNG traffic.
Transit Analysis and Traffic Coordination Study

Calais LNG conducted a traffic coordination study to determine the extent to which
increased amounts of deep-draft vessel traffic (primarily LNG carriers) could potentially
impact scheduled arrivals/departures of vessels serving Estes Head cargo terminal,
Eastport Breakwater pier, and the Port of Bayside. Additionally, the study factored in
Downeast LNG, an alternate firm proposing to build and operate an LNG import terminal
and storage facility at Mill Cove, Robbinston, ME approximately five nautical miles
downstream of the proposed Calais LNG facility.
For the purposes of this study the LNG vessel traffic pattern was determined based on the
anticipated number of carrier arrivals to the terminal(s) per year. The traffic pattern for
all other vessels was based on historical statistics. Climatic information and data was
based on weather conditions prevalent for the region and season. The existing scheme
for ensuring traffic control involved vessel movements reported to, and controlled by, the
Canadian Coast Guard (i.e., “Fundy Traffic”). As well, locally conceived cooperative
agreements and transiting practices that exist between the U.S. and Canadian pilots were
factors considered, including the existing informal, one-way vessel traffic scheme. The
proposed operating parameters, as outlined in the COTP SNNE prepared Downeast LNG
Waterway Suitability Report (WSR) were applied, as well a number of assumed risks and
operating conditions based on input from the local pilots and rules and procedures
germane to existing LNG operations located elsewhere. Commercial fishing vessels and
recreational craft were not factored into this particular study; it was relegated to deep-
draft ships only. The authors reasoned that there would be minimal impact due to the
seasonal nature of recreational craft and the relatively limited numbers of commercial
fishing vessels in operation. That is not to say that local stakeholders’ concerns and
interests were not considered; to the contrary, the applicant’s contend a number of public
exchange meetings were held whereby regional concerns were addressed and ultimately
factored into risk-based safety and security assessments as outlined in Sections 4 and 5 of
their WSA.
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The Traffic Coordination Study focused on conceivable marine traffic scenarios

involving multiple combinations of inbound and outbound LNG and non-LNG vessel
movements, to and from the port-area terminals (actual and proposed), in an effort to
determine the level of control needed to efficiently and effectively manage all
commercial traffic without sacrificing safety. Calais LNG acknowledged that if both
LNG operations were to materialize, the cumulative consequences of LNG traffic serving
the pair of facilities would have a further impact on regional marine traffic. Recognizing
that all deep-draft vessel movements within the waterway are predicated on the tidal
currents at critical locations (primarily Dog Island/Cherry Islet) the study explored such
interrogatories as: Can an inbound vessel bound for Estes Head precede an LNG carrier
on the same tide? What if it were to follow the LNG carrier? Can an LNG carrier depart
the Calais dock while a cargo vessel enters Head Harbor Passage bound for Bayside?
Can an LNG carrier enter the waterway bound for the Downeast LNG terminal while an
LNG carrier departs the Calais LNG facility? Answers to these queries and others, as
well as the author’s determinate observations, are contained in the full traffic study,
Section 2.2.3 of the WSA. While the analysis “proved” many of the scenarios plausible,
it should be noted that a number of “assumptions” were made; those being, the
integration of a formalized vessel traffic control system, improved monitoring
capabilities (radar, closed-circuit TV coverage, AIS etc.) and collaborative transit
planning - all subject to maritime safety and security organizational approvals, on behalf
of both, the U.S. and Canada.
WSA Recommendations #3, LNG Transit Management Planning and Coordination, #4,
Improved Portable Electronic Navigation System for Pilots, #6, Vessel Monitoring and
Control by Fundy Traffic, #7, Operational Limits for Ship Transits, #8, Improved Aids to
Navigation, and #10, Input from Canadian Representatives, are all risk-mitigation factors
related to the above and fully concurred with by the COTP.
Cumulative Impacts
Unique to the Passamaquoddy Bay port area, three separate and distinct LNG proposals
(albeit, one has been suspended) are in varying stages of evaluation for FERC approval.
Although each is being assessed on its own merits, there exist cumulative impacts that
will need to be taken into consideration and weighed accordingly, should each ultimately
receive authorization to build and operate. If that occurs, it is conceivable that inbound,
fully loaded LNG carriers transiting to the proposed Calais LNG facility, and/or bulk
carriers serving the port of Bayside, will pass relatively close aboard (within 1,000 yards)
to offloading LNG tankers berthed at the alternately proposed facility. This type of
scenario points out the need for additional study and evaluation to ensure all potential
risks associated with multiple terminals along the same waterway are taken into
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consideration. In view of the fact that (1) all deep-draft vessel movements are predicated
on definitive tide and current conditions at Deer Island/Dog Islet, (2) favorable weather
and visibility conditions must exist, and (3) LNG carriers may be limited one-way traffic
and daylight movement only, the number of actual transit opportunities diminishes
exponentially – a recipe for possible delays and waterway congestion. This enforces the
significance of having a “formalized” traffic management and control system in place,
and the need for coordination and collaboration by area stakeholders in the development
of operational, response, and security protocols.
WSAs are typically submitted a couple of years in advance of a facility going into
operation. During the construction phase a port’s overall security picture may change
significantly, new port activities may commence, additional infrastructure may be added,
population densities may change – or, as in the case outlined above, an additional LNG
terminal may receive FERC licensure. For reasons such as these, annual reviews and
updates of all WSAs “in play” will be required until such time that each facility(s) goes
into operation. The annual reviews are intended to capture and reflect changing
conditions, both organizationally and port-wide, and address any and all cumulative
impacts, as applicable.
5. PORT LEVEL CONSIDERATIONS
Maritime Commerce
As previously noted, the two principal ports within the Passamaquoddy Bay Waterway
are Eastport, Maine on the U.S. side and Bayside, New Brunswick on the Canadian side.
While no bulk petroleum products are transported by vessel or barge through the
“internal waterway”; a significant number of crude oil tankers and LNG carriers do
traverse the Bay of Fundy in order to reach the port of St. John, New Brunswick, with a
portion of the St. John fairway being the same approach optionally available to LNG
traffic transiting to the proposed ME-based sites. No bulk chemical carriers call on
either, Eastport or Bayside.
The Port of Eastport is operated by the Eastport Port Authority. The Eastport Breakwater
dock has berthing for a vessel up to 700 feet in length with approach depths being over
100 feet and the mean low water depth averaging 42 feet. Although the dock is seldom
used by commercial oceangoing vessels, a U.S. Naval vessel traditionally docks at the
Breakwater during 4th of July celebrations. The dock is more commonly used by the
aquaculture industry, commercial fishermen, and recreational boaters. The downtown
Fish Pier, collocated with the Breakwater, provides winter berthing for two harbor tugs
and has slips for transient boats on the south side. In that these facilities are about 5/8 of
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a nautical mile from the deep-draft transit route neither would interfere with, nor be
affected by, LNG traffic.
Also located in Eastport is the Estes Head Cargo Terminal, which can accommodate a
ship of 900 feet in length in Berth A and one of up to 550 feet in Berth B. The 43 acre
terminal contains several large warehouses and open storage areas. The primary export
commodity from this terminal is wood products. Office space for the managing operator,
Federal Marine Terminals, is located just above the Estes Head Pier. This facility should
not be affected by LNG traffic, unless such transits coincide with associated arriving or
departing cargo ships, as previously discussed in the Traffic Coordination section.
The Port of Bayside is located on the St. Croix River, on the New Brunswick, Canada
side of the shared waterway, diagonally opposite of the proposed Calais LNG site. The
facility has three deep-draft vessel berths served by an approach channel of 70 feet depth.
The terminal is affixed with a ship loader used for quarried aggregate material, and
supports stevedoring companies for the handling and storing of break bulk commodities
to include potatoes, timber products, phosphate, gypsum and sensitive cold food storage.
Ammonium nitrate, shipped in bags as low-grade agriculture fertilizer in support of
regional farming, is transported by vessel to Bayside on the average of 1-3 times in any
given year, with the non-regular commodity being offloaded and transferred directly into
awaiting trucks for immediate, over-the-road delivery. There was conjecture that
dynamite was occasionally shipped by vessel to the port of Bayside in support of regional
construction, mining, and quarry/aggregate operations; however, no documentary
evidence was sighted that sustained this speculation.
The frequency at which deep-draft vessels transit to and from the Bayside facility is
market dependent. The terminal has occasionally berthed vessels one directly after
another, with instances of vessels having to lie at anchor within the river or in
Passamaquoddy Bay while awaiting berth availability; contrastingly, there are times
when the dock is reportedly idle for days at a time. Accordingly, the introduction of
LNG carriers to the proposed Calais LNG facility, just one mile across the river, would
substantially increase the immediate deep-draft volume, necessitating well-defined vessel
traffic planning and management protocols to effectively offset impending logistical
demands. The WSA recommendations cited in the Traffic Coordination section pertain
here as well.
Recreational Boating and Commercial Fishing

Regional commerce has historically consisted of aquaculture, farming, eco-tourism, and
commercial fishing. Altogether, aquaculture, fishing, and the related industries
reportedly employ over 6,000 persons within Charlotte County, New Brunswick and
Washington County, Maine. Aquaculture has been a mainstay industry in the area with
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salmon being the principal fish grown and harvested. Commercial fishing vessels
homeport along both sides of the shared waterway and operate inside of East Quoddy
Head as well as along the adjacent offshore coastlines. Primarily, the fish catch is lobster
and herring, with limited amounts of scallops and other species. It is estimated that
about 20 fishing vessels are of U.S. registry, and 15-20 are Canadian. On any given day
there may be roughly twenty small commercial draggers or lobster boats working the
inlets and coves along the border. U.S and Canadian fishing seasons don’t always
coincide, therefore, the total numbers stay relatively constant and are reflected in the
varying degree by which segments of the transit route are populated with lobster traps,
fish weirs, and aquaculture equipment. The majority of lobster fishing occurs in the
Grand Manan Channel and along the coast south of Lubec Narrows. In comparison,
lobstering within the inland channel, along Western Passage, is relatively limited due to
the strong tidal currents encountered; nonetheless, much of this gear is typically deployed
in close proximity to the boundary line, which is midstream of the transit route. The local
pilots contend that potential damage/loss to deployed fishing gear can be minimized by
favoring one side of the demarcation line over the other, depending on which country’s
fishing season is open. The Fundy North Fisherman’s Association and Canada’s
Department of Foreign Affairs and International Trades have both expressed concerned
opposition to this plan. Closely related, U.S. fishermen voiced consternation during
working group meetings regarding the increased potential for lost/damaged fishing gear
in the Gulf of Maine and southerly portion of Grand Manan Channel. In response, WSA
Recommendation #17, Fishing Gear Observer, recommends a qualified observer be
placed on the lead escort tug to monitor the proximity of fishing gear and
report/document any incident of carrier/gear contact to affect responsible reimbursement.
There are some shellfish (soft-shell clam) nurseries along the transit route; however,
these areas are well inshore where harvesting is accomplished manually by rake. The
shoreline along Head Harbor Passage, Friar Roads and Western Passage is primarily
steep and rocky and the majority of the remaining area is affected by the “red tide”, a
bloom of damaging marine microorganisms, so only a few of the coves/mud flats are
actually open to shellfish harvesting. Scallops and sea urchins are primarily harvested by
commercial draggers in Cobscook Bay and South Bay, which are south and west of the
proposed LNG transit route and would therefore not be directly impacted.
Regional Impact
The land and islands along the transit route and in the vicinity of the proposed facility site
are relatively remote, rural, and sparsely-populated, especially during the winter months.
Generally speaking, law enforcement, public safety, and emergency response capabilities
within the immediate U.S & Canadian region are in keeping with the rural nature of the
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area – minimally staffed, minimally equipped and trained, and limited in their ability to
expand due to their relatively small tax base.
Tourism along the entire Maine coast increases significantly during the late spring,
summer, and early fall, to the betterment of the region and the “down east corridor.”
Eco-tourism is estimated to bring in $300-400 million annually, supplementing the
commercial fishing, agricultural, and wood harvesting industries, with much of the tourist
pull centered on boating, canoeing/kayaking, recreational fishing, and the pristine,
biological environment. The Cities of Eastport, Calais, and other municipalities along the
regional shoreline are exploring a number of tourist-related ventures to increase local
coffers and employment opportunities.
St. Andrews, New Brunswick, a Canadian resort community located on the western shore
at the mouth of the St. Croix River and geographically opposite a competing LNG
proposal, relies almost exclusively on eco-tourism for its economic well-being. Other
attractions and sources of eco-tourism related income include kayaking, recreational
fishing, canoeing, and sightseeing by boat.
As confirmed during an independent Ports and Waterways Safety Assessment (PAWSA)

of the Passamaquoddy Bay port area, there are a number of maritime-related local events
and festivities that could potentially be impacted by, or impede, deep draft vessel traffic
flow within the region, graphically depicted in Figure 13. 2
2
Reprinted courtesy of ABS Consulting Inc., with permission by Calais LNG.
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Figure 13
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These include:
• Annual Eastport 4th of July Festival involving recreational boating events, shore
side activities, and typically a U.S. Navy vessel port visit.
• Annual Roosevelt Cup Sailboat Race in mid-July; traditionally in the vicinity of
Treat Island, Friar Roads.
• Annual Passamaquoddy Indian Tribe Celebration in early August involving
canoes and kayaks transiting between Indian Township Bridge and the Pleasant
Point Reservation. People attending and participating in the event usually camp
at Devil’s Head, near the proposed Calais LNG site, before completing the
paddling trip.
• Annual Eastport Salmon Festival and Pirate Days in early September. Activities
and attractions surrounding this event are mainly shore-based; however, some
waterside related activities occur close to the Eastport Breakwater.
• Whale watching and boat tours. Up to 20 “head boats” provide seasonal whale
watching trips and boat tours. The majority of these vessels transit Letite Passage
and/or Head Harbor Passage in order to cruise the Bay of Fundy during the
summer months.
There are other annual events and festivals held in the immediate port area which attract a
number of visitors, but do not significantly affect boating traffic. They include Memorial
Day weekend festivities, Down East Spring Bird Watching Festival, 4th of July Old Home
Week, and the Eastport Festival of Lights held in December.
While the majority of scheduled maritime-oriented events take place near-shore and/or
have limited exposure to the deep-draft channel a major concern, nevertheless, to regional
boaters and residents alike is the heightened risk of a maritime accident consequent to the
potentially two-fold increase in deep-draft vessel traffic and ancillary craft, should
multiple LNG proposals be approved and constructed. The COTP concurs, emphasizing
the significance of robust risk-mitigation measures being implemented.
Areas of Historical Significance

The Roosevelt Campobello International Park is located on the southern end of
Campobello Island, which directly abuts Head Harbor Passage and Friar Roads. The
Park and its Commission were established in 1964 by a treaty between the U.S. and
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Canada as a symbol of friendship, and thus hold iconic value for both U.S. and Canadian
citizens alike. One of the Park’s main attractions is the historic summer home of
President Franklin D. Roosevelt, which receives approximately 150,000 visitors annually.
The Park is well known for its unspoiled natural beauty and offers spectacular, unbroken
views of rugged coastline, estuarine bays, and the open ocean. Tourism dollars have a
significant and positive ripple-effect on the economic well-being of the area.
Park Commissioners have expressed grave concern regarding the proposed development
of the Calais LNG terminal (and competing proposal), citing safety and security concerns
consequent to the closeness of the transit route to the Island (deep-draft tanker traffic
would pass within 500 yards of the northeasterly coast). They consider the potential
two-fold increase in deep-draft traffic to pose an unacceptable risk; a release of fuel oil,
lube oil, or cargo as a result of an accidental grounding, collision, or intentional act of
terrorism would result in irreparable ecological harm to the environment and present an
even greater health hazard to the surrounding population and visiting tourists. Of equal
concern is the complete absence of trained personnel and/or response equipment needed
to respond to an accidental or intentional release of LNG due to the relative remoteness
of the region; a fire of any magnitude would be catastrophic to the Park and Island.
St. Croix Island, located in the middle of the St. Croix River on the U.S. side of the
maritime boundary line, is a congressionally designated International Historic Site,
managed by the U.S. National Park Service. The island was the site of one of the earliest
attempts at French colonization; colonists tried to live year-round on the island outpost,
but tragically, the majority succumbed to scurvy during their first winter. Access to the
uninhabited island is by boat only, from either U.S. or Canadian shores. Considerable
shoaling precedes the island; floating aids mark the navigational channel and
additionally, a fixed light tower on the island provides a visual bearing for mariners. The
channel skirts the island to the east; vessels shift into Canadian waters while rounding the
island, and then return to their intended course along the international boundary before
turning back into Canadian or U.S. waters to arrive at Bayside or the proposed Calais
LNG site, respectively. Local National Park Service officials are concerned that a
potential increase in deep-draft vessel traffic, coupled with the perceived hazard of LNG
cargo, could negatively impact tourism, and that the resultant wakes of passing tankers
and ancillary tugs would further erode the island’s sensitive shoreline.
Areas of Environmental Significance

The Passamaquoddy Bay port area is characterized by its pristine environment, natural
attractions and abundant wildlife. The Bay of Fundy, Passamaquoddy Bay, and
Cobscook Bay (and all approaches) are areas of unusual biodiversity and are home to a
number of species listed as endangered, threatened, or of special concern.
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A number of marine research and biological studies have been conducted by such
institutions as Canada’s Department of Fisheries and Oceans (DFO) and the New
England Aquarium, with a focus on protecting and preserving endangered aquatic life
and integrated marine management strategies within, and for, these collective bays and
adjacent estuaries. Subjects of study included the aquaculture industry, commercial
fisheries and hatcheries, protection of seabirds, marine mammals and exploited species,
among others. Collectively, the area has been reported as being one of the most diverse
aquatic ecosystems on the eastern seaboard of North America. Notwithstanding, the port
area also has a long history of maritime commerce, shipbuilding, and fishing, and
supports many diverse uses of the waterway.
The National Environmental Policy Act (NEPA) review process is designed to evaluate
projects independent of each other as well as cumulatively, if in close proximity to one
another, to ensure any and all potential impacts to the environment have been carefully
considered. The assessment includes an analysis of potential pollutants and the ability to
reduce or eliminate such pollution. Compliance with NEPA and other environmental
planning laws rest with FERC as the permitting agency.
Part and parcel to the NEPA assessment is the individual state permitting/application
review process. Project applicants must demonstrate compliance with applicable federal
and state laws and regulations regarding environmental protection to receive the
necessary approvals needed to construct their respective project. Detailed information
and data concerning environmentally sensitive areas, endangered species, wildlife
refuges, estuaries, aquaculture, and general areas of environmental significance, which
could be impacted in one way or another by the Calais LNG project, are contained in
Resource Report 3, filed with FERC. As aforementioned, environmental impact
analysis, as it relates to the issuance of an LOR, falls under the purview of FERC, not the
Coast Guard. The Coast Guard’s only role in FERC’s siting process is to serve as a
subject matter expert on waterway safety and security. Notwithstanding, in view of the
large number of oral and written comments received that centered around the “biological
significance” of Passamaquoddy Bay and its connecting tributaries, the following
sampling of the area’s ecological and environmental concerns, followed by a “snapshot”
of regional resource centers, sensitive sites, estuaries and refuges, is provided. It should
be noted that not all identified environmentally-significant areas would be directly
impacted by the Calais LNG proposal due to their geographical location and/or distance;
however, these sites are considered “common” to the region and often referred to
collectively.
The waters of the Bay of Fundy leading up to the existing regional facilities and proposed
LNG terminals are known habitats for whales for portions of the year, including the
North Atlantic right whale, which is a federally endangered species. Along the entire
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Eastern seaboard, significant efforts are being taken to protect this marine mammal.
Canada, through its Department of Fisheries and Oceans, created two Right Whale
Conservation Zones in the area. Zone 1, where right whales have been most frequently
observed, includes Grand Manan Basin within the Bay of Fundy, and Zone 2 includes the
Roseway Basin, located between Browns and Baccaro Banks on the southern Scotia
shelf. Ships are asked to avoid this area, if possible. If they do transit the area, they are
requested to decrease speed without sacrificing maneuverability, post additional lookouts,
avoid maneuvering around marine mammal activity, and report any marine mammal
sightings or collisions with same.
Designated traffic lanes exist for large ships traveling between the southeastern entrance
to the Bay of Fundy and the port of St. John, New Brunswick to enhance traffic
management, the safety of other craft, and further afford protection to the right whale.
These lanes are frequented by petroleum tankers bound for, or departing, St. John, and of
late, LNG carriers serving the recently constructed Canaport import terminal and storage
facility.
Other whales such as minke, finback, and humpback are common to the waters of Head
Harbor Passage and Friar Roads, as well as porpoises and seals. Bald eagles, Peregrine
falcons, osprey, ducks and a variety of sea birds such as the Atlantic Puffin and Common
Tern make their home along the bay and waterway as well.
Environmentally sensitive areas along the transit route include:

• The abovementioned right whale habitat area northeast of the traffic lane turnout
and approach to Head Harbor Passage.
• The coasts of Grand Manan Island and Deer Island (Clark Gregory Preserve at
Chocolate Cove and the Robert Stewart Preserve), West Isles area, and
Campobello Island.
• The Huntsman Marine Science Center, located adjacent to the DFO Biological
Station in Brandy Cove, St. Andrews, New Brunswick, which currently houses an
aquarium and is expanding to the shorefront to further tourism and provide public
access to the waterfront.
Other areas of environmental significance include:
• The St. Croix Estuary, located along the coastal region of Charlotte County,
extending from St. Stephens to St. Andrews, New Brunswick.
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• The Cobscook Bay region, a unique ecosystem and estuary renowned for its eagle
habitat, located to the west of Friar Roads.
• The Moosehorn National Wildlife Refuge, located just south of Calais, Maine,
consisting of two parcels: (1) the Baring Division, which covers 20,016 acres
southeast of Calais; and (2) the Edmunds Division, comprised of 8,735 acres and
bordering the tidal waters of Cobscook Bay. The Refuge was established in 1937
and is first in the chain of migratory refuges extending from Maine to Florida.
Routine transits of LNG carriers serving the proposed Calais LNG terminal are not
expected to operationally impact any of the above environmentally sensitive areas;
however, a marine casualty with resultant release of cargo and/or petroleum spill could
have detrimental affects. Estimated impacts are contained in environmental impact
studies, prepared for FERC by the applicant.
International and Sovereignty Considerations

Calais LNG and an alternate project proposal (Downeast LNG) both confront unique
border challenges. In order to navigate to and from either of the proposed project sites
LNG carriers must transit through Head Harbor Passage (HHP), a waterway located
entirely in Canadian waters. Moreover, the intended transit route predominately straddles
the US/CA (ME/New Brunswick) international boundary throughout its length.
The Canadian federal and provincial governments have publicly expressed strong
opposition to any and all LNG tankers traversing their sovereign waters, citing potential
security, environmental, navigational, and safety risks. Ostensibly, of expressed concern
are public safety, the economic viability of fishing and tourism, and protection of the
regional environment. Jurisdictional issues have been at the forefront as well. Canada
views HHP as historic internal waters and, as such, contends to have absolute control of
all vessel traffic, to include the exclusion of particular vessels. The U.S. asserts HHP as
being Canadian territorial seas, and as such, an international strait in which the non-
suspendable right of innocent passage, under Article 45 of the 1982 United Nations
Convention on the Law of the Sea (UNCLOS), prevails. 3 This has been a matter of
extensive discussion and legal review. Canada became party to UNCLOS in 2003; the
U.S., although signatory, has never ratified the Convention but does recognize much of
3
United States, Message of President Clinton transmitting the United Nations Convention on the Law of
the Sea to the U.S. Senate for Ratification in 1994, “Commentary -The 1982 united Nations Convention on
the Law of the Sea and the Agreement on Implementation of Part XI,” 103rd Congress, 2nd Session, Treaty
Document 103-39, at p.19.
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UNCLOS as customary international law. 4 A consequence of the U.S. ‘non-party status’

is that the United States is not subject to, nor can the U.S. make use of, the compulsory
dispute settlement provisions of UNCLOS, since this is clearly a right/obligation that
arises from membership and is not a right/obligation that arises from customary
international law. 5
The lead agency for U.S. engagement with the Canadian government is the Department
of State. There has been considerable, on-going dialogue between the two governments
ever since the first Maine-based LNG proposal was announced in 2006, to include:
• In a February 2007 letter from Canadian Ambassador M. Wilson to the FERC, the
Canadian government formally announced its opposition to LNG carriers
transiting Head Harbor Passage (HHP). In a February 2010 letter to FERC
Chairman J. Wellinghoff, succeeding Canadian Ambassador G. Doer, reiterated
Wilson’s sentiment. FERC responded to Ambassador Doer stating that while the
Commission recognizes that the “innocent passage” issues have not been resolved
they will, regardless, continue with their application review process.
• In October 2007 Senators O. Snowe and S. Collins communicated with Secretary
C. Rice imploring that any and all diplomatic means should be utilized to
encourage Canadian government participation in the FERC process.
• At a May 2009 meeting of the Canada-U.S. Inter-Parliamentary Group, delegates
from the Parliament of Canada and the U.S. Congress adopted a resolution,
offered by Senator S. Collins, recommending that “Canada and the United States
cooperate with one another to ensure that any and all investigations and reviews
of proposals to build facilities in ports, to and from which vessels would need to
navigate through the territorial waters of the other, receive the full, good faith and
expeditious cooperation of both countries.”
• In a September 2009 letter to Secretary H. Clinton, Senator S. Collins expressed
concern for ME energy development and solicited intervention on the ‘innocent
passage’ issue. Her concern was reiterated in a September 2009 letter to President
B. Obama, requesting that he raise the issue with Prime Minister S. Harper at an
upcoming summit; and again in June 2010 along with Senator S. Snowe and
4
Majorie Ann Brown, “The U.N. Law of the Sea Convention and the United States: Development since
October 2003,“ (Congressional Research Service Report for Congress, Order Code RS21890, updated 27
January 2006).
5
Ted L. McDorman, “The International Legal Status of Head Harbor Passage,” Research Memorandum,
January 2007, p. 8.
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Representative M. Michaud, in anticipation of the G8 and G20 Summits in

Toronto.
• During the annual conference of New England Governors and Eastern Canadian
Premiers held September 14, 2009 Governor J. Baldacci publicly criticized the
decision by the Canadian federal government to prohibit LNG transits through
HHP. The governor argued that HHP is an international waterway and the U.S.
and the State of ME “cannot cede control of commerce in Maine” to Canada. In
an opposing commentary Premier S. Graham restated the Province’s unequivocal
position, “Decisions on where ships are allowed to transit fall within the
jurisdiction of the Government of Canada alone…LNG tankers will not be
permitted to navigate the Canadian waters of Head Harbour Passage.”
• Mayor John Craig of St. Andrews, New Brunswick said in a letter to Governor
Baldacci that New Brunswick safety and security personnel do not have the
resources or training to respond to an LNG incident in Canadian waters. In
January 2010 the Province of New Brunswick filed a motion with the FERC
arguing that Calais LNG’s application should be dismissed; asserting that the
company failed to consider cumulative impacts of multiple LNG terminals; failed
to acknowledge Canada’s unequivocal stance on “innocent passage;” and does not
adequately account for the risk of an accidental release of LNG.
• In July 2010, Canada’s consul general to New England, Neil LeBlanc,

corresponded with Maine Department of Environmental Protection Commissioner
David Littell reiterating Canada’s oppositional stance to LNG traffic in Head
Harbor Passage citing “navigational, environmental, and public safety risks.”
Copies of official documents and formal correspondence are maintained in the Calais
LNG public docket, which is available on the FERC Internet website using the “eLibrary
link”.
Early in the assessment process relevant departments within the Canadian government,
such as Transport Canada, Coast Guard etc., were allowed to engage in “technical”
discussions with COTP Sector Northern New England in an effort to identify mutual
issues of concern, potential risks, and jointly address possible mitigating factors
surrounding the proposed LNG ventures. After a period of time, however, the Canadian
Department of Foreign Affairs curtailed any further participation in the review process in
light of their Government’s stance on “innocent passage,” and all subsequent, joint
interrogatories stalled. This action caused a deceleration in the assessment process and
ostensibly inhibited the applicants’ ability to assimilate critical resource information and
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better determine population and infrastructure impact levels along both sides of the
shared waterway.
Calais LNG reported a great deal of effort having been expended in attempts to gain input
from Canadian citizenry and various governmental organizations regarding (1) their
potential safety and security concerns, and how these concerns were dealt with for those
LNG facilities being proposed, constructed, or currently operating in Canada; and (2)
what role the Canadian safety and security organizations will want to play in ensuring
safe and secure transportation of LNG in Canadian waters and/or along the international
maritime border. Unfortunately, according to their WSA, the discussions were very
limited, encumbered by the Government’s oppositional stance against LNG transits in
HHP.
As indicated in WSA Recommendation #10; Input from Canadian Representatives,

Calais LNG fully recognizes the significance of Canadian cooperation and collaboration
on a number of safety, security, and environmental fronts that are deserving of mutual
interest and concern, and accordingly, fully intends to continue with its “outreach” efforts
to achieve reciprocal cooperation. The COTP concurs with this recommendation,
reemphasizing that it is the responsibility of the applicant to pursue and secure the ability
to implement (1) certain risk management measures as they relate to Canada, and (2) all
other recommendations identified in their WSA and referenced in the Coast Guard’s LOR
and LOR Analysis.
In addition to examining Canadian sovereignty issues, the inherent rights and concerns of
the Passamaquoddy Tribal Nation, whose members reside at the Pleasant Point
Reservation in Perry along the banks of Western Passage, and in Indian Township, in
Princeton, on the edge of the west branch of the St. Croix River have been issues of
significant concern and consideration by COTP SNNE. Indian Township is
approximately 22 miles (straight line) west of the proposed project site, and Pleasant
Point is about 14 miles south. When the US/CA boundary line (about mid-stream of the
St. Croix River) was created, it split what had traditionally been Passamaquoddy
homeland for generations, leaving Passamaquoddy Tribal members on both sides of the
international border, with the Council in Canada known as the “St. Croix/Schoodic
Band”.
Sovereignty, a critical feature of federal Indian law, has been an exceedingly complex
and sensitive issue for the Wabanaki People (Coalition of Abenaki, Penobscot, Maliseet,
Passamaquoddy and Mi’kaq Tribes) within the State of Maine for hundreds of years. At
issue is perceived aboriginal and sustenance rights. The COTP is sensitive to the issues
surrounding Passamaquoddy Nation autonomy, and early on in the regional review
process reached out to Council members seeking clarification as to the Tribe’s perception
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of authority within the territorial waters of the Passamaquoddy Bay area. In addition to
this outreach, tribal law enforcement, fire and emergency response and environmental
management personnel were invited to participate in the LNG work group processes.
The intricacy of, and overall sensitivity to, the sovereignty issues within the region have
complicated the WSA process. At question is how much sovereign authority does the
Tribe possess along the St. Croix River in view of the fact that, purportedly, aboriginal
title to some properties has ended 6 . Additionally, what is the federal government’s
jurisdictional authority and ability to (1) invoke and enforce certain requirements, such as
safety/security/exclusion zones, and/or (2) substantiate and quantify risks and impacts to
land and water considered to be hallowed hunting and fishing grounds and ceremonial
sites if, in fact, Passamaquoddy sovereign rights prevail? Towards that end, the COTP is
recommending that the applicant collaborate with the Passamaquoddy Nation to ensure
its jurisdictional interests and public safety and security concerns associated with their
project are adequately addressed and met.
6. OPERATIONAL CONSIDERATIONS
Work Group Process

Regional stakeholders contributed to the information contained in this LOR Analysis.
The COTP convened LNG working groups under the umbrella of the Passamaquoddy
Bay/Down East Sub-Committee of the Area Maritime Security Committee (AMSC LNG
Working Group or LNG Work Group) and Maine & New Hampshire Port Safety Forum,
and participated in ad hoc meetings with the regional U.S. and Canadian response and
law enforcement communities. Due to the geographic nuance, efforts of earlier working
group procedures, consequent to the two prior alternate project proposals, were used as a
baseline for the Calais project work group. Common to all working groups and sub-
committees, a balanced group of representatives were invited to participate in attempts to
ensure concerns on both sides of the international boundary were considered. While
Canadian participation was relatively sparse, their interaction, nonetheless, was
invaluable. None of the participants were asked to “vote” or otherwise indicate whether
the Calais LNG proposal should be approved. Rather, participants were relied upon to
provide valid input based on their expertise and regional familiarity in order to conduct a
thorough assessment of potential risks to navigational safety and port security associated
with the proposed project, develop and recommend operational parameters especially
significant to the St. Croix River portion of the transit, and assist in the identification of
possible mitigation measures.
6
See 25 U.S.C. §§ 1723(b), 1725(a), 1725(h).
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Members of the work group were provided electronic copies of the WSA; they then
reviewed and commented on subject areas commensurate with their vocation or expertise.
Following this, specified issues, concerns, and/or risks relating to the proposed project
were reviewed by ad hoc subcommittees for further consideration and recommended
resolution. The subcommittees presented an inventory of perceived risks, and then
followed up with recommended corresponding mitigating measures. The efforts of the
work group(s) parlayed into recommended operational parameters and a conceptual
framework for a transit management plan. It was collectively agreed that these measures,
once implemented by the COTP, would have a moderate to significant impact on
reducing the potential for safety/security related accidents and incidents. Of note, a
substantial number of the recommended measures paralleled the findings and conclusions
of the Ports and Waterways Safety Assessment (PAWSA), that was conducted
independent of the WSA review process. The following is a synopsis of the working
groups’ determinations.
Employment of Safety and Security Zones

Early on in the assessment process, the COTP recognized that a considerable amount of
confusion and misconception existed regarding the terms safety and security zones, and
the respective enforcement action of each. In an effort to qualify the terms an overview
was developed by the COTP and disseminated to working group members to assist in the
formulation of tenable operating parameters.
Several commercial and recreational boaters expressed significant concern about Coast
Guard established safety and/or security zones. Their apprehension was based on the
erroneous assumption that the entire waterway would be completely closed to all
navigation whenever LNG vessels were transiting, in effect curtailing their ability to
freely navigate and/or fish.
Historically, safety and security zones have been control mechanisms employed by
COTP’s to ensure the safe and secure navigation of vessels transiting U.S. waters
carrying bulk products such as liquefied petroleum gas (LPG) and LNG. Safety zones
serve important dual purposes. A level of safety is provided to the transiting vessel by
minimizing waterway congestion, and a layer of protection is afforded to the surrounding
port community through the reduction in casualty risk. By definition, a safety zone 7 is a
water area, shore area, or combination of both to which, for safety and/or environmental
protection purposes, access is limited to persons, vehicles, or objects specifically
authorized by the COTP or U.S. Coast Guard District Commander. No person may enter
a safety zone, remain in a safety zone, or allow any vehicle, vessel, or object to remain in
7
Regulations applicable to safety and security zones are promulgated in 33 Code of Federal Regulations
(CFR) Part 165.
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a safety zone, unless authorized by the COTP or District Commander or his/her

designated representative. And, each person in a safety zone, who has notice of a lawful
order or direction, must obey that order or direction, under penalty of law. A safety zone
may be described by fixed limits, or it may be a specified zone around a vessel in motion.
Safety zones may be established as temporary measures, such as in response to an
emergency situation, or they may be established for indefinite periods, such as along the
waterfront and shore area of a high-risk waterfront terminal or facility.
Security zones are another control mechanism available to the COTP. Security zones 8
are designated areas of land, water, or combination of land and water, established for
such time as necessary to prevent damage or injury to any vessel or waterfront facility; to
safeguard ports, harbors, or waters of the United States; or to secure the obligations of the
United States. Security zones are primarily used for national security interests rather than
strictly for safety considerations; however, due to the heightened security posture
consequent to 9/11, combinations of safety and security zones are often employed when
the need dictates.
COTP’s receive their statutory authority to safeguard the nation’s ports, waterways and
facilities from a variety of sources, including the Ports and Waterways Safety Act
(PWSA) of 1972, i.e., 33 U.S.C.§1221 et. seq. The respective authorities provide that
further vessel traffic controls may be imposed by the COTP when deemed necessary,
such as during periods of reduced visibility or adverse weather, or when in congested
waterways or other hazardous conditions. These controls include specifying time(s) of
vessel movement(s), establishing traffic schemes, limiting vessel size, draft or speed, and
the establishment of explicit operating parameters for a specific area. While only the
Coast Guard has authority to determine who may enter a zone, and under what
conditions, the COTP may delegate that authority to lawful designated on-scene
representatives, who are usually Coast Guard personnel. In Maine and New Hampshire
however, under a memorandum of understanding (MOU) with each respective state, the
Maine and New Hampshire Marine Patrols may also augment and enforce U.S. Coast
Guard safety/security zones.
Notwithstanding internal Coast Guard policy, there is no federal mandate that specifies
that a safety and/or security zone must be established; rather, it is risk and circumstance
specific. Risk-based decision making is used to determine to what extent operational
restrictions and/or safety management parameters need to be employed, taking into
consideration the current or anticipated event, Maritime Security (MARSEC) level, and
response capability needed to mitigate a safety incident or security threat. Across the
8
Security zones are also established under the authority of 50 U.S.C.§191 and 33 CFR 6.04-6.
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country Captains of the Ports monitor the marine transportation of LNG on a regular
basis. Some transit routes and terminal sites are located near large metropolitan cities
while others are in far more remote locales. Obviously, then, the type and quantity of
risk management measures needed to protect critical infrastructures and population
densities varies greatly between both ends of the scale; in other words, one size does not
fit all. The establishment of limited access areas, such as safety and security zones, is
just one tool among many available to the COTP. Accordingly, if and when COTP
SNNE decides to employ and enforce moving safety/security zones around LNG carriers
as they transit to/from the proposed terminal(s) (while in U.S. waters) specific boundary
limits will be applied. In the event that zones are established, there should be ample
room for boaters to still freely navigate the waterway along the outer periphery of the
channel, and ahead and astern of the carriers. The zone(s) will move with the vessel(s),
with the average time for the zone to pass any given point corresponding to
approximately eighteen minutes, assuming a carrier speed of 10 knots. While the zones
could cause slight delays and/or interferences, proper voyage planning and attention to
advance “Broadcast Notices to Mariners” should help alleviate potential impositions.
The establishment and enforcement of controlled access areas, e.g., safety and security
zones, are not arbitrary measures. They are established through the Federal rulemaking
process and must be published in the Federal Register. Rulemaking of a non-emergency
nature, as in the case of long term LNG siting proposals, requires the opportunity for
public comment. This process provides “constructive legal notice” to the general public
and the maritime community as to the rulemaking’s existence and legal enforceability,
and provides an opportunity to shape the rule appropriate to local, extenuating
circumstances and geographic area.
As previously indicated, LNG carriers bound for the proposed LNG site must travel
through Canadian territorial waters, specifically Head Harbor Passage, before entering
U.S. waters at the confluence of Friar Road. Following the present deep-draft track line,
the vessels would then straddle the international maritime boundary through Western
Passage, Passamaquoddy Bay, and the St. Croix River, before turning into exclusive U.S.
waters to reach the proposed site in Maine. The Coast Guard’s jurisdictional authority to
set and enforce safety and security zones is limited to U.S. navigable waters and its
territorial seas. The ability to implement complementary risk-management measures on
the Canadian side of the boundary, if deemed necessary, is dependent upon Canadian
federal and provincial collaboration.
As per WSA Recommendation #13, Safety/Security Zones, Calais LNG recommends that
the Coast Guard establish safety/security zones having the following size limits: (1)
When LNG carriers are in transit, zones would extend 2 miles ahead, 1 mile astern, and
500 yards on each side of the moving vessel (assuming a maximum LNG carrier transit
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speed of 10 knots); and (2) When LNG carriers are moored at the terminal, the fixed zone
would extend outward from the vessel 300 yards.
Although the COTP concurs with the intent behind this recommendation, in consideration
of those factors outlined above, no final determination as to the specifics of moving or
fixed safety and/or security zones has been made; however, in all probability the stand-
off parameters for moving zones will coincide with the dimensions as stated above (albeit
in nautical miles vice statute miles) and previously expressed in the Downeast LNG
Waterway Suitability Report (WSR). The size of a fixed security zone around a carrier
during cargo offloading operations, if one is determined necessary by the COTP, will
ultimately consider such factors as the “as built” trestle length and resulting distances
from shore and the international boundary.
For efficiency, a small percentage of cargo is normally maintained in an LNG carrier’s

cargo tanks, termed heel, in order to keep the tanks and associated piping in a
refrigerated/liquefied state and ready for the next loading. (No cargo refrigeration system
is employed on LNG vessels). Even though, after unloading, the vessels are not,
technically, in an inert or gas-free condition the overall risk factor has diminished;
accordingly, potential risk mitigation measures to include escorts and safety/security zone
applications for outbound transits are subject to modification, as determined by the
COTP.
Assist/Escort Tugs
Preliminary transit runs and docking maneuvers were simulated at Marine Safety
International. The simulation tests validated specific tug operating characteristics needed
to ensure maximum maneuverability during transits under varying hydrodynamic
conditions, adverse weather, and emergency/casualty situations (such as steering/rudder
failure and/or loss of propulsion aboard the carrier). Based on these simulation trials and
the expert opinion of the attending pilots, specific escort tug criteria was determined, as
earlier outlined in the Simulated Maneuvering Trials section.
Marine Firefighting Capability

In addition to the onboard firefighting capabilities of the LNG carriers, which must
comply with the requirements established by the International Gas Carrier Code, the
assist tugs are to be equipped with firefighting equipment that meets the International
Association of Classification Societies (IACS) “FiFi 1” notation; i.e., vessels must be
equipped with at least two monitors that, in total, have a discharge rate of 2400 m³/hr, and
are able to spray water to a height of 45 meters and to a minimum distance of 120 meters.
The National Fire Protection Academy also requires similar criteria for towing vessels in
order that they are Class 1 certified. This requirement is outlined in its publication NFPA
1915 – Standard on Marine Fire-Fighting Vessels, which addresses the construction of
marine fire-fighting vessels and contains criteria on a wide-range of specific standards
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including outfitting, stability, propulsion, auxiliary machinery, electrical systems, fire

pumps and fire-fighting equipment.
Shore side Emergency Response

It’s logical to expect that, in general, shore-based fire departments, emergency response
units, and emergency management organizations located in close proximity to an LNG
facility, would also have the appropriate training and equipment necessary to launch an
initial response capability to an LNG fire and/or related medical emergency. In keeping
with the rural nature of the area that capability does not currently exist in the
Passamaquoddy Bay region. If FERC authorizes the siting of the Calais LNG terminal,
the Commission Order will dictate that emergency response needs and related planning
strategies must be addressed as per Section 311(d) of the Energy Policy Act of 2005, and
the Natural Gas Act, 15 U.S.C§ 717b-1. WSA Recommendations #11 and 12, Issues for
Emergency Response Plan (ERP) and Public Education Program for Emergency
Response, respectively, reinforce Calais LNG’s intentions in that regard, and are
concurred with by the COTP.
Operating parameters
A minimum of two nautical miles of visibility will be required for the movement of LNG
vessels within the Passamaquoddy Bay Waterway while in U.S. waters. In marginal
weather conditions visibility can vary significantly along the route. The decision as to
whether sufficient visibility exists, and is likely to continue for the duration of the transit,
is a judgment call to be made jointly by the attending pilot(s) and Fundy Traffic in
consultation with, and concurrence by, the COTP.
Initially, and specific to the inside passage, loaded or partially loaded LNG carriers
should only be allowed to transit U.S. waters during daylight hours. Nighttime LNG
transits should not be conducted until additional simulation testing/training is
accomplished to benefit the attending pilots and ascertain the adequacy of existing
navigational aids for nighttime operations. Daylight is interpreted as “Civil Twilight” in
which the sun may be below the horizon but the “Horizon is clear and larger stars visible”
(Dutton’s Navigation and Plotting). In practical terms, the horizon, shoreline and
receiving berths must be clearly seen with natural light.
Once simulation trials have been completed and a history of transits established,
outbound (empty with heel allowance) LNG carriers may (in the future) be allowed to
transit after sunset during periods of fair weather and clear periods of unrestricted
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visibility (actual and forecasted) upon concurrent agreement between the attending
pilot(s) and the COTP.
Inbound fully or partially laden LNG transits should only begin if there is sufficient time
to arrive in the Cherry Islet to Dog Island area near slack water due to the unpredictability
of tidal currents in that vicinity. As a general policy, and as per the pilots’
recommendations and prevailing practice, all transits should be conducted at high slack
water or on an early ebbing tide. Transits through the Cherry Islet/Dog Island area
should always be avoided on a flood tide and as well, on an ebbing tide when currents are
in excess of three knots.
Outbound “empty” LNG transits should only begin if cast-off is within a period of time
that permits the carrier to be in the vicinity of the Cherry Islet to Dog Island area during
slack tide and there is no vessel departing the port of Bayside, Downeast LNG facility
(proposed), and/or deep draft vessels inbound Head Harbor Passage or transiting Western
Passage that could possibly result in a meeting or overtaking situation.
As determined by the simulation trials, 25 knots, as measured on the vessel, is the

maximum sustained wind speed during which an inbound or outbound transit of an LNG
carrier can commence. As with visibility, significant variation in wind conditions can
exist along the route; the decision as to whether existing wind conditions allow a
continued, safe transit will be made by the pilots in consultation with, and concurrence
by, the COTP.
7. SAFETY AND SECURITY ASSESSMENTS
General Assessment Methodology

The safety assessment evaluated the risks of an accidental release of LNG consequent to
incidents such as collisions, allisions, and groundings. Potential problems that could lead
to an accidental release were considered and the likelihood and consequences of those
events evaluated. ABS Consulting, Inc. performed and documented the risk assessment
for Calais LNG consistent with the U.S. Coast Guard’s Risk-based Decision (RBDM)
Guidelines (USCG, 2004). These guidelines defined a process in which (1) risk
questions were proposed, (2) an analysis was structured to answer those questions, and
(3) the appropriate risk techniques (including data analysis when available) were
employed. The specific transit-related questions that the assessments were structured to
answer included:
• What incidents could occur that would threaten the public or environment?
• What safeguards exist to mitigate or prevent those kinds of events?
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• Given those safeguards, what are the likelihood and consequence (i.e., the risk) of
such events?
• What additional measures could be considered to reduce the identified risks?
The additional identified measures were then factored into the WSA safety management
strategies, which provided the recommended safety measures that, when implemented,
will reduce the safety risks associated with LNG carriers transiting to the proposed
terminal site.
The security assessment evaluated the risks of intentional releases of LNG and explored
threat, vulnerability, and consequence. The probability of an incident was evaluated in
terms of threat and vulnerability, where threat was considered as the likelihood of an
attack and vulnerability being the likelihood that such an attack could succeed.
Security risks were analyzed using the security vulnerability assessment (SVA)
methodology as recommended by the American Petroleum Institute (API) and the
National Petrochemical & Refiners Association (NHPR) in their document, Security
Vulnerability Assessment Methodology for the Petroleum and Petrochemical Industries
(API/NPRA, 2003). Analysis of security risks associated with the LNG carrier transit
followed that report’s 5-step process:
• Asset Identification – Identify important assets along the waterway needing
protection.
• Threat Assessment – Identify motivated adversaries and why the asset may be
attacked.
• Vulnerability Analysis – Identify how hard or easy the asset would be to
successfully attack.
• Risk Assessment – Identify the level of risk associated with the assets.
• Countermeasure Analysis – Develop appropriate countermeasures to protect the
asset.
Both assessments applied the hazard zone criteria contained in the Sandia National
Laboratories Report SAND2004-6258 (Sandia Report), a study commissioned by the
Department of Energy (DoE), entitled Guidance on Risk Analysis and Safety Implications
of a Large Liquefied Natural Gas (LNG) Spill Over Water, dated December 2004,
coupled with the Sandia study conducted in 2008 for larger cubic capacity carriers.
Additionally, following the guidance of NVIC 05-08, the parameters commensurate with
an “intentional” release were used to define the potential areas of impact, termed “Zones
of Concern”, for both assessments.
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Also common to both assessments, a number of assumptions were made and applied.
These included:
• Consistent with the scope of the WSA, the analyses pertained to marine transits
and docking maneuvers; they did not consider shore side-related activities, such
as releases from storage tanks, pipelines and other vaporization equipment, as
those issues are addressed by other agencies such as FERC and DOT.
• Both the Calais LNG and competing, DowneastLNG facilities may be approved,
constructed, and operated, resulting in increased vessel traffic along the
waterway.
• The Calais LNG marine terminal and associated LNG carriers will comply with
all applicable international treaty requirements and federal laws and regulations
regarding the implementation of safety measure, security plans, and other
specifically mandated requirements. However, for the purposes of the
assessments, events caused by equipment failure and human error were factors
considered.
• There will be no bunkering of LNG carriers at the terminal.
• Hazard zone parameters contained in the 2004 Sandia Report were applied, and
considered applicable to LNG carriers up to 265,000 cubic meters capacity,
following the Sandia 2008 study and NVIC 05-08 guidance.
Thermal radiation Analysis

An important consideration in assessing the suitability of the proposed transit route and
its approaches to support LNG marine traffic along the intended route, is establishing the
size of the hazard zones, or Zones of Concern, associated with a large release of LNG.
The criterion used to define the outer limits of Zone 1 and 2 is incident flux, i.e., thermal
radiation that would be expected from an intense LNG vapor fire over a specified time
period.
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Figure 14 - Hazard Zone Criterion
Criteria (10
Zone minute exposure Consequence
time)
High potential for major injuries and/or significant
2*
Zone 1 37.5 kW/m structural damage consequent to a pool fire and
vapor cloud hazard
Potential for injuries and limited property damage
Zone 2 5 kW/m2
consequent to a pool fire and vapor cloud hazard
Reduced potential for injury or damage if
Lower flammability
Zone 3 appropriately clothed or protected consequent to
limit (5%)
vapor cloud hazard only; no pool fire
Source: Extrapolated from Sandia Report data
Note: *Kilowatts per square meter
As shown in Figure 14, thermal radiation consequent to a pool fire and vapor cloud
within Zone 1 can cause serious injury and/or significant damage to structures. By
definition, these are areas in which LNG shipments occur in relatively narrow harbors or
channels, or ships pass under major bridges or over tunnels, or come to within 500 meters
of major infrastructure such as military installations, commercial/business centers, or
national icons. Within Zone 2, thermal radiation, again consequent to a pool fire and
vapor cloud can cause limited injury and/or some property damage. These are areas of
broader channel widths, larger open harbors, or areas over 500 meters from major critical
infrastructure elements. Commencing with Zone 3, there is a reduced potential for
personal injury or property damage consequent to a vapor cloud only. These are areas
where LNG traffic and deliveries occur approximately 1.6 kilometers or more from major
infrastructure or in large bays or open water. The radiation risks to public safety and
property are significantly reduced. The outer limit of Zone 3 is defined based on the
lower flammability limit of the LNG vapor, i.e., the lowest concentration of fuel by
volume mixed with air that is flammable. Within all three zones, the level of risk of
injury or property damage is reduced as the distance from the source increases and the
thermal radiation decreases, as shown in Figure 14. As indicated, the most significant
impacts to public safety and property exists within approximately 500 meters of an LNG
spill/release, due to the thermal radiation hazards from fire, with much lower public
health and safety impacts at distances approaching 1600 meters and beyond.
The intensity and linear size of hazard zones calculated in the Sandia Report for
accidental and intentional spills/releases of LNG were determined only after extensive
modeling and testing. However, the potential for an LNG cargo tank breach, the
dynamics and dispersion rates, and the resultant hazards of such a spill are only generally
understood and, as such, are only postulated estimates at best. The combination of LNG
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vessel double hull design and current safety management practices throughout the marine
transportation industry have reduced LNG accidents to a point where there is little
historical or empirical information from which to arrive at finite conclusions. This lack
of information forces assumptions to be made when the size, dispersion rate, and thermal
hazards of a spill are calculated. Therefore, it should be understood that a level of
variability exists with the many current models and techniques being used to provide
adequate guidance on the hazards of an LNG spill. Some of the variables that affect the
modeling techniques, assumptions, and simplifications include: the size, mass, speed, and
loaded condition of the carrier; size, mass, collision velocities, and angle of impact if
collided with another vessel; amount of penetration and whether or not the inner hull and
primary tank boundary was compromised; size and number of breaches; whether or not
there were multiple, cascading tank failures; climatic conditions (wind velocity and sea
state); and reference of the breach to the waterline.
The Sandia Report, published in December 2004, based its findings on the capacities of
LNG carriers in operation at the time. The vessels studied had an average upper cargo
carrying capacity of 148,000 m3 with individual tank capacities of approximately 25,000
m3 of LNG, depending on number and type of design. The emerging generation of LNG
carriers has cargo carrying capacities of as much as 265,000 m3. In May of 2008, Sandia
National Labs published an additional report “Breach and Safety Analysis of Spills Over
Water from Large Liquefied Natural Gas Carriers” (SAND2008-3153) which analyzed
impacts of LNG spills associated with breaches from the emerging larger class of LNG
carriers. Overall, the results obtained from the more detailed analyses conducted and
presented by Sandia were found to be similar to the previous conclusions,
recommendations, and guidance presented in their 2004 report. For the purposes of this
LOR Analysis, and as indicated in the aforementioned WSA “assumptions”, the hazard
zones applied in association with the Calais LNG project are considered applicable to
vessels up to a maximum of 265,000m3 cargo capacity.
Figure 15 - Hazard Zone Size
Zone 3
Zone 1 Zone 2
(Lower Flammability
(37.5 kW/m2) (5 kW/m2)
Limit)
Intentional Breaches 500 m 546 yds 1600 m 1750 yds 3500 m 2.2 miles
Accidental Breaches 250 m 273 yds 700 m 765 yds 1700 m 1.06 miles
Ref: Sandia Report
As previously indicated and shown in Figure 15, calculated hazard zone sizes vary,
depending on whether the event was accidental, or intentionally caused. According to
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the Sandia Report, accidental LNG cargo tank damage scenarios exist (e.g., groundings,
collisions or allisions) that could potentially cause an effective breach area of 0.5 to 1.5 m²;
but due to existing LNG carrier design and equipment requirements, together with the
implementation of navigational safety measures such as traffic management schemes and
safety zones, the risk from accidents is generally low. In contrast, several credible intentional
LNG cargo tank damage scenarios exist that would initiate a breach of between 2 m² to
approximately 12 m², with a probable nominal size of 5 – 7 m². In most of the intentional
damage scenarios identified, an ignition source is probable and a LNG fire at, or near, the
source is very likely to occur. Additionally, some intentional damage scenarios could result
in vapor cloud dispersion with delayed ignition accompanied by a fire occurring considerable
distance from the source. In consideration of these specifics, together with the guidance
contained in NVIC 05-08, Calais LNG applied the zones sizes for intentional breaches for
all of their risk assessment work.
Hazard Zone Impacts

Figure 16 provides a graphic overlay of the hazard zones associated with an intentional
release along the intended transit route, including the two approaches from sea. Calais
LNG used the zone sizes associated with an intentional release to describe the expected
consequences of a large release of LNG from a carrier onto the water and into the
surrounding atmosphere. The superimposed zones identify where Zones of Concern
may intersect with populated areas, critical infrastructure, and areas with heavy
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Figure 16
Reprinted, courtesy of ABS Consulting Inc. with permission by Calais LNG
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concentrations of marine traffic, highlighting areas whereby risk-management strategies

should be considered. It should be noted that the centerline from which the Zones of
Concern are calculated follow the LNG carrier’s anticipated course or track line. An
LNG carrier “drifting” from the plotted route within the channel would, therefore, shift
the Zones of Concern proportionately, where greater public safety and environmental
effects could be experienced, if a worst case accidental or intentional release scenario
were realized.
LNG burns at extremely high temperatures. Once started, a natural gas fire is difficult to
extinguish. As indicated in the Sandia Report, scientists determined that should a large
LNG spill on water be ignited, it could burn at 3,000 degrees F for 30 minutes to an hour,
throwing off extreme, potentially damaging heat for the first four-tenths of a mile from
the vessel. Beyond that range, the degree of heat flux decreases appreciably depending
on surrounding climatic conditions (wave height, wind speed, etc.) and geographical
impediments such as man-made buildings or structures, and natural obstructions such as
tree lines and hills.
One of the criteria used to judge the potential impact of an LNG release is the
concentration of populace threatened. The three levels of population density, as defined
in NVIC 05-08 are:
• High population areas - residential areas with a population density of 9,000
persons or more per square mile;
• Medium population areas - residential areas with 1,000 to 9,000 persons per
square mile; and
• Low population areas - residential areas with less than 1,000 persons per square
mile.
As shown in Figure 16, the hazard zones for an intentional (terrorist-related) incident
reach at least a portion of the populated areas. Using the above criteria, the transit route
passes through relatively low population areas, i.e., predominantly less than 1,000
persons per square mile. By definition, the Pleasant Point Passamaquoddy Tribal
Reservation, having a population density of 1,376 persons per square mile and located
about 12 nautical miles downstream of the proposed terminal site and approximately ¾
nautical miles from the centerline of the transit route, is considered a borderline medium
population area; the remaining cities, towns and parishes are considered low population
areas. By contrast, the City of Calais, location of the proposed LNG terminal, has a
population of 3,447 and corresponding population density of 101 persons per square mile,
and the popular tourist area of St. Andrews, New Brunswick is home to approximately
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2,500 residents and has a population density of 620 persons per square mile. The next
highest population area affected by a transiting LNG carrier is the City of Eastport,
Maine at 448 persons per square mile. Comparatively, Campobello Island, New
Brunswick, Deer Island, and Robbinston, Maine only have population densities of 69, 58,
and 19 persons per square mile, respectively. Clearly, as shown in Figure 17, the
demographics of the Passamaquoddy Bay port area do not meet the NVIC-based criterion
specific to high population densities along the vessel’s transit route or at the proposed
facility site. This statement is not intended to demean the significance and/or importance
of the surrounding communities, environment, or very populace living, working or using
the waterway; rather, it simply concludes that the risk of LNG movement through the
waterway has been evaluated against pre-determined criteria in order to establish and
prioritize levels of impact, and as a means of determining risk mitigation strategies.
Figure 17- Population Densities for Communities Along the LNG Transit Route
Population Density Population Density
Area Along Transit Route
Classification (people/sq mi)
U.S. Municipalities/Areas
Eastport Low 448
Passamaquoddy Pleasant Point Medium 1,376
Reservation
Perry Low 29
Robbinston Low 19
Calais Low 101
Canadian Municipalities/Areas
Grand Manan Island Low 79
Campobello Island Low 69
Deer Island (Reported as part of West Low 58
Isles Parish)
St. Andrews (Town) Low 557
St. Andrews (Parish) Low 63
St. Croix (Parish located along the Low 22
east side of the St. Croix River, north
of St. Andrews)
Dufferin (Parish located north of St. Low 112
Croix River once it turns west to
Calais)
In view of the relative remoteness of the shared waterway and comparatively low
concentration of key assets, critical infrastructure, and population densities as defined by
NVIC 05-08, the following generalities, denoted by zone consequence, are provided to
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illustrate the potential impacts of an intentional release of LNG, vice graphically

depicting them by route segments:
Zone 1
• Zone 1, the measure with the most severe impact, does not affect any high
population areas or public or government centers such as schools, hospitals or
transportation infrastructure along the intended track line. However, commercial
vessels intended for the port of Bayside may well fall into Zone 1 should they
transit past docked LNG carriers (cumulative consideration if other proposed
LNG facilities are also built), and similarly, recreational and fishing vessels may
fall within the zone, depending on their course. As well, the seasonal ferry
crossings connecting Deer Island, New Brunswick and Eastport, Maine and
Campobello Island, New Brunswick could possibly be within Zone 1 as an LNG
carrier passes. Transit of such vessels through a Zone 1 area of concern can be
avoided by timing and course changes, if operational conditions permit.
• During the LNG carrier’s transit, a Zone 1 impact may very well occur at Dog
Island Light, affecting portions of Moose Island on the Maine side and Deer
Island on the New Brunswick side. This area presents the narrowest point in the
entire transit route and the pilots tend to hug the U.S. side of the dogleg, rather
than stay in the middle of the channel, in order to avoid the divergent currents
common to this portion of the waterway.
• Although no major military post or camp is situated along the waterway, Coast
Guard Station Eastport, a Search and Rescue (SAR) and Law Enforcement (LE)
installation, is located on the shore of Eastport and would fall within either Zone 1
or 2, depending on the actual course taken by the pilots when navigating the bend
off Dog Island.
• When the carriers transit Head Harbor Passage, the northern most edge of Head
Harbor and shore side neighboring areas on Campobello Island would fall within
Zone 1. When the carriers transit Friar Roads and Western Passage, the western
edge of Deer Island Point, New Brunswick, would also fall into this zone.
• The westerly edge of Seal Island, and the shoreline of Charlotte County, New
Brunswick commencing at Joes Point and continuing on to Sand Point, may fall
within Zone 1 depending on the track line of the LNG carriers transiting the St.
Croix River enroute to the proposed terminal site.
Zone 2
• Elements within the U.S. which would fall within Zone 2 while vessels transited
Friar Roads and Western Passage include most of Eastport, Kendall Head, and
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• Pleasant Point, Maine and predominately the entire easterly shoreline of

Passamaquoddy Bay and the St. Croix River. While not necessarily classified as
“critical infrastructure”, i.e. bridges, tunnels, etc., Route 190, nonetheless,
provides the only vehicle access to and from the City of Eastport. A portion of
Route 190 is within this zone of concern.
• During LNG vessel transits of Head Harbor Passage all Canadian areas and
communities along the northern and westerly edges of Campobello Island such as
Brown Head, Wilson’s Beach, Windmill Point, and Bald Head fall within Zone 2.
Also within this zone would be the islands off the coast of New Brunswick to
include Spruce Island, Sandy Island, Casco Bay Island, Green Island, Pope Island
and Indian Island. Zone 2 would also impact land masses along Friar Roads and
Western Passage such as West Deer Isle, New Brunswick communities west of
Highway 772, Doctors Cove, Cummings Cove, and Mink Point.
Zone 3
• In addition to the localities identified in the above zones, areas impacted by Zone
3 in the U.S. include all of Moose Island, Pleasant Point, Perry, Robbinston, and
land masses along the St. Croix River, including a small segment of the western
branch of the river.
• On the Canadian side, in addition to all locales previously identified along Head
Harbor Passage impacted by Zones 1 and 2, Welshpool and all of Northern
Campobello Island would fall into Zone 3, as would the communities on the
alternate side of Head Harbor Passage which would encompass areas such as
Leonardville, Bar Island, and a portion of Southern Deer Island. When carriers
navigate Friar Roads and Western Passage, the southerly portion of Deer Island
falls within this zone, and after crossing Passamaquoddy Bay the communities
and land area of Navy Island, St. Andrews, Champcook, Simpson Hill and
Bayside fall within the zone.
Within the context of the defined criteria contained in the Sandia Report, Calais LNG
identified the following as not being contained within the Zones of Concern, as plotted
from the centerline of their intended transit route:
• any wild and scenic rivers;
• any shellfish nurseries;
• any coral reefs; or
• marine protected areas (assuming vessels used the Grand Manan Channel, which
may be their preferred transit route as the North Atlantic right whale and Bay of
Fundy conservation areas are located to the northeast of Grand Manan Island).
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Sidenote: Throughout work group efforts, adamant concern was raised concerning the
NVIC methodology used to determine population densities, and therefore the accuracy
and validity of the index used to establish resource capabilities and risk management
strategies. It was suggested that the actual population density of those falling within
respective hazard zones would be a better qualifier than the “diluted” metric now being
used (average population density of an entire municipality, some of which may be within
zones and others outside zones). This recommendation was forwarded to the appropriate
Program Manager at Coast Guard Headquarters for future consideration.
Along the same lines, a number of comments were received asserting that the LNG site
selection process was in direct contrast to the guidelines and recommended best practices
for the industry outlined in The Society of International Gas Tanker and Terminal
Operators Ltd. (SIGTTO) publications. In response and to paraphrase SIGTTO, each
port environment presents a unique set of risk exposures for LNG operations and, as
such, each requires a specific, detailed study of the operating environment in every case.
The waterway suitability assessment process (WSA), as outlined in NVIC 05-08 and now
required by federal regulation 9 effective June 25, 2010, closely parallels SIGTTO’s
Quantitative Risk Assessment (QRA) methodology and, in fact, utilized many similar
decision-making tools. At specific issue was SIGTTO’s pronouncement that an LNG site
location should be suitably distanced from centers of population and the associated
mooring piers should not be situated in heavily trafficked areas or within constricting
channels where other ships pose collision risks. Some regional stakeholders thus contend
that the proposed site for the Calais LNG terminal does not, therefore, meet SIGTTO’s
site selection criteria. In response, it should be understood that SIGTTO publications and
other similar source papers are intended as general guidance documents only. Although
the recommended procedures and precautionary measures, such as those contained in
their Information Papers, are based on “best practices”, they are not regulatory standards;
rather, they are site-specific measures intended to reduce risk and be applied where
practical and within realistic limits. The Coast Guard recognizes the significance of
SIGTTO and used their publications as reference documents throughout the WSA
process. The actual site determination, while associated with the WSA, predominately
falls under the federal and state authority and purview of FERC and Maine, respectively.
Risk Assessment and Management Strategies

In consideration of the risk factors acknowledged in the Calais LNG WSA, substantiated
in part with the findings of the independently conducted PAWSA Report, it’s clearly
apparent that it will be necessary to implement mitigation measures to effectively manage
the identified navigation, safety, security and environmental risks associated with the
9
33 CFR 127.007
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project if FERC ultimately approves the Calais LNG proposal and it is subsequently
constructed and operated. Successful mitigation measures generally fall into one of two
categories: prevention and consequence management. Whereas prevention seeks to avoid
an accident, consequence management seeks to reduce the negative impacts should an
accident or incident occur.
The safety and security analyses were based, in part, on data collected during site and
location visits, interviews conducted with area stakeholders, and information gleaned
from, and in support of, the FERC Resource Reports. Safety and security measures that
are currently in place that help mitigate the associated risks were identified and
quantified. Where the identified risk appeared to not have sufficient resource capability
to adequately offset or diminish the consequences, a gap was identified and alternate
mitigation strategies explored.
The identification of plausible strategies to mitigate the risks associated with either a
marine casualty or terrorist-related incident was the focus of the analyses performed. As
previously mentioned, Calais LNG conducted its safety risk assessment following U.S
Coast Guard Risk-Based Decision-Making (RBDM) Guidelines, and analyzed its security
risks utilizing American Petroleum Institute (API) procedures. These assessments used
the thermal hazards associated with the intentional Zone of Concern contained in the
Sandia Laboratories Report to describe the expected consequences of large releases of
LNG from a carrier onto the water.
In addition to the plotting of Zones of Concern, NVIC 05-08, Change 1 also requires the
development of risk assessment scenarios and management strategies to correspond with
the calculated zones. The Calais LNG WSA contained a comprehensive inventory of
strategic scenarios and corresponding, well-conceived risk reduction measures. These
scenarios took into consideration a number of assumptions on which the overall
mitigation strategies were based. Included in the study were parameters and assumptions
such as waterway boundaries, carrier size and capacity for the defined hazard zones,
potential for vessel groundings, collisions and allsions, hazards consequential to
spill/release scenarios, potential vulnerabilities, security risks, existing safeguards, and
terrorist-related attacks and activities, among others.
For the purpose of the safety and security assessments, Calais LNG made the favorable
assumption that Canada and the United States would reach joint agreement and bi-
national consensus regarding the employment of safety, security, and response
capabilities for the protection of the vessel, its crew, and communities and other interests
along both sides of the transit route. However, Calais LNG has not been able to
demonstrate that it will, in fact, be feasible to achieve this level of cooperation.
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Nevertheless, as indicated in WSA Recommendation #10, they intend to vigorously

pursue this initiative.
Calais LNG’s risk-based assessment methodology suggests that the likelihood of

accidental releases and/or threats of intentional interference is relatively low. Its
assessment was based on the relative remoteness of the area, substantial width and depth
of the majority of the transit route, comparative absence of national iconic and/or critical
infrastructure, and reduced population densities more common to heavier industrialized
and strategically located urban port areas. Nonetheless, potential consequences, albeit
proportionately less for the Passamaquoddy Bay port area, do exist. Consequently, the
COTP, under his inherent authority under the Ports and Waterways Safety Act, in
coordination with FERC, will likely require specific risk reduction measures as outlined
throughout this LOR Analysis and summarized in Section 8.
Safety Risk Assessment (SRA) and Associated Scenarios

Consistent with the guidelines contained in NVIC 05-08, Change 1, Calais LNG applied
the Risk Management Quick-Reference Tool in conjunction with the Sandia Report to
develop a comprehensive assessment strategy that adequately analyzes the safety risks
that arise with the potential introduction of LNG operations into the port area. Their
strategy was two-fold, consisting of (1) a ‘virtual’ overview of the transit route from a
pilot or master’s perspective, and (2) analyzing an inventory of SRA, or ‘what if’,
scenarios.
In order to fully analyze the safety components of the transit route the track line was
divided into six logical sections, commencing in the Gulf of Maine, and concluding at the
terminal site. Operational details, course and distance calculations, applicable cautionary
measures, and advisory notes specific to each segment of the route were provided, from a
pilot or master’s perspective, to ascertain the adequacy of existing safeguards and/or
determine the need for additional mitigation measures. The value of this type of data is
noteworthy; Table 4.3 of the WSA contains the entire overview, segment by segment.
Employing the information contained in, and derived from, Table 4.3 of their WSA
Calais LNG developed an inventory of safety-related scenarios that were then analyzed to
determine the likelihood and severity of the identified risks. Based on the potential
impact, resource needs were then considered to identify and recommend scalable
prevention, mitigation, and response strategies necessary to counter the risks and support
the proposed operation. The safety-related risk-based scenarios focused on likelihood
while the security scenarios focused on vulnerability. A summary of identified concerns,
needed resources, and recommended actions was then provided in the WSA, Table 4.5.
Scenarios were categorized under the headings:
¾ Event (e.g., collision, allision, propulsion or steering failure, etc.)
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¾ Causes (severe weather, mechanical failure, human error, poor communications, etc.)
¾ Consequences (collision with other vessel, fire, injury, LNG release, oil pollution,
delays, allision with dock, etc.)
¾ Existing Safeguards (carrier construction/design, federal regulations and inspections,
system tests, navigation rules, pilot experience, communications, vessel radar, AIS,
traffic control (albeit informal), etc.)
¾ Prevention Recommendations (tug escort, transit management plan, improved ATON,
etc.)
¾ Response Recommendations (Canadian input, emergency response plan, education,
safety/security zones).
A brief discussion of each risk-reduction measure/strategy (existing and/or proposed) was
provided, along with corresponding recommendations for each. A summary of the
findings and/or recommendations drawn from the SRA includes:
1. The safety scenario inventory revealed that there are risk-reduction measures
currently in place that promote the safe transit of LNG carriers along the proposed
route.
2. The development and implementation of many of the Calais LNG proposed
mitigation measures, along with the COTP recommendations (based on the DELNG
WSR), would further reduce the risks associated with the marine transportation of
LNG.
3. Due to the relative remoteness of the project site and associated waterway current law
enforcement, fire fighting, medical, and emergency response capabilities are
inadequate to capably respond to a shipboard casualty involving a cargo of LNG.
4. A form of collaborative effort or bi-lateral agreement with Canada is necessary in
order to promote and/or implement:
• A mechanism for the setting and enforcing of safety and security zones (or
equivalent) in Canadian waters.
• The development of Safety and Security Communications Plans.
• Formalized vessel traffic management throughout the transit route and the
ability to affect enhanced ATON.
• Community programs for safety/security awareness.
• Joint training and exercising programs to enhance safety, security, and
response capabilities.
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• The establishment of general marine and LNG-specific firefighting and

incident management training for shore side firefighters, and revision of local
contingency plans to address joint response strategies.
• The establishment of vessel ‘positive control’ procedures that are favorable to
the laws and regulations of both countries.
• The implementation or acknowledgement of established Maritime Security
(MARSEC) Levels and Department of Homeland Security (DHS) Advisories.
• The recognition of Coast Guard established Regulated Navigation Areas.
• The possible utilization of private security force assets.
• Emergency communications compatibility with Canadian response agencies.
• The implementation of natural gas cloud ignition systems and procedures for
New Brunswick communities.
• The implementation of rapid civil emergency advisory systems to cover the
New Brunswick populace.
• The development of a Transit Management Plan, further clarifying agency
roles and addressing key safety and security concerns with corresponding
measures.
The SRA considered 12 accident-based scenarios involving the LNG. The events
included (1) a collision with another deep draft ship, a ferry, or commercial fishing boat,
(2) vessel grounding, propulsion/steering failures, and an allision with a stationary
structure, (3) on board emergencies to include fire, LNG release etc., and (4) LNG
releases during unloading operations at the terminal berth. Of the 12 safety scenarios
considered, the highest consequences to public safety, the environment, and financial
impact would be as a result of an underway collision between an LNG carrier and deep-
draft vessel in Head Harbor Passage, between Friar Roads and Dog Islet, or within the St.
Croix River. The next highest consequences would be the result of the LNG carrier
vessel alliding with the Calais marine terminal pier, an aid to navigation, or private
structure along the transit route.
To counter or reduce risks and consequences identified, the SRA identified a number of
existing navigational system safeguards, specialized/enhanced crew
training/competencies, application of quality control systems, and development of
enhanced measures specific to the area and/or characteristic to LNG carrier and crews.
Additionally, the assessment took into consideration expected preventative and mitigating
strategies commonly employed and proven at operating LNG facilities located elsewhere.
These included:
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• Enhanced crew competency linked to the internationally required “Standards

of Training, Certification and Watchkeeping” (STCW).
• Potential application and enforcement of Coast Guard safety and security
zones (U.S. waters only).
• Employment of Automatic Identification System (AIS).
• Escort tugs of specific number and operating capability.
• Specific carrier design, construction, Flag State Control and higher
classification society standards.
• Assumed formalization of one-way and traffic management plans.
• Anticipated upgrading of ATON, shore monitored radar coverage and
communication interoperability.
• USCG Port State Control safety-related boardings and testing of operational
and cargo systems.
• Dual (bi-national) piloting with integrated Bridge Management Teams
Security Vulnerability Assessments (SVA) and Associated Scenarios

A SVA of the 27 mile transit route was conducted by Calais LNG beginning at Head
Harbor Passage and ending at the proposed terminal site utilizing the API/NPRA
methodology coupled with guidance contained in NVIC 05-08. The objective of the
SVA was to evaluate hazards, threats, and vulnerabilities along the transit route as they
relate to (1) specific attacks against an LNG carrier, and (2) attacks using the ship as a
weapon. As part of the SVA process security-based scenarios were developed using site-
specific data and then analyzed to evaluate the capability of existing and proposed
countermeasures to eliminate, reduce, or manage security risks associated with the vessel
transit. An abstract of the security-related findings is contained in Section 9, the Security
Supplement, of this LOR Analysis.
Environmental Protection and Response

An accidental spill or release of LNG consequent to a marine casualty could pose
potential hazards to the public, waterway, and surrounding environment. The nature and
severity of the spill, climatic and sea conditions, and whether or not oil pollutants were
also spilled are all factors that must be taken into consideration in order to mount a rapid
and effective response.
An environmental response protocol is in place between the U.S. and Canada for spills of
oil and other noxious substances. The original Canada-United States Joint Marine
Pollution Contingency Plan (JCP) was developed to cover the Great Lakes; subsequent
geographic annexes have since been added to cover all waters of U.S/Canadian mutual
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interest where the use of combined resources would improve the response posture and
capability of each nation. The Atlantic Geographic Annex to the JCP applicable to the
Passamaquoddy Bay region is known as CANUSLANT. CANUSLANT is tested
regularly and improved by way of biennial exercises, under coordination of the U.S.
Coast Guard, District 1, and Canadian Coast Guard, Atlantic Maritimes Region.
CANUSLANT also recognizes the rights of U.S. Tribes and Canadian Aboriginal people
and even applies when only one country is affected, if the incident is of significant
magnitude to require assistance from the other country.
The primary objectives of CANUSLANT are to:

• provide a joint cross-border mechanism for a coordinated and integrated response
by both nations;
• establish a Canada-United States Joint Response Team (JRT) for the Atlantic
region under co-leadership of the Canadian Coast Guard and the U.S. Coast
Guard;
• if needed, establish and set up a Joint Command Post (JCP);
• ensure timely notification of cross-border incidents and the accurate transmission
of information between responders, and the general public and media;
• facilitate the safe and timely flow of personnel, equipment, and supplies across
the international border; and
• complement the Canada-U.S. Joint Inland Pollution Contingency Plan, and its
CANUSEAST operational supplement, if needed.
It should be noted that the JCP provides for a coordinated response to “Harmful
Substance Incidents,” a broadly defined term that encompasses much of the domestic
pollution response authority held by the two Coast Guards. CANUSLANT may be
invoked when a harmful substance incident presents an imminent and substantial risk to
public health and welfare, and/or poses potential danger to the environment on either side
of the maritime international boundary. The definition of “harmful substance” is
relatively wide-ranging and subject to both Canadian and U.S. laws and regulations.
Harmful substance includes, but is not limited to, substances subject to control by a
number of both national and international conventions and protocols such as the
International Convention for the Prevention of Pollution from Ships (more commonly
known as MARPOL 78), Federal Water Pollution Control Act, as amended, and the Oil
Pollution Act (OPA) of 1990, just to name a few. Conceptually, CANUSLANT provides
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for a strong and coordinated response regime to combat a noxious substance and/or
petroleum-based spill.
Calais LNG examined both U.S. and Canadian shipping records to analyze casualty
trends; there have been about nine deep-draft vessel-related accidents or allisons reported
for the St. Croix River, Passamaquoddy Bay, and its approaches during the period 1980
to 2006, or an average of one every three years. According to the Atlantic Pilotage
Authority (APA) and Canadian Transportation Safety Board statistics the majority of
these were relatively minor with little to no structural damage to either involved vessel(s)
or piers. On the U.S. side, a review of the U.S. Coast Guard’s Marine Safety Information
System (MSIS) and Marine Information for Safety and Law Enforcement (MISLE)
showed about 24 commercial vessel incidents had occurred during the past 20 years;
however, the majority of these dealt with towing vessels and/or construction barges. Two
cases were more relevant to the deep-draft vessel query: One incident involved a tug’s
tow-line being improperly fastened to a vessel at Estes Cargo terminal, resulting in
bulwark damage; the other happened more recently when on January 12, 2008 the empty
bulk carrier ALEXANDERGRACHT suffered a temporary loss of propulsion in Head
Harbor Passage (Canadian waters). The ship was subsequently safely anchored in Head
Harbor Passage where the engine failure was quickly diagnosed and temporarily repaired.
The vessel was able to continue to its berth at Estes Head, where final repairs and
regulatory verification were conducted. The case did not impact navigation or result in
any pollution. According to the local pilots, over 2,400 deep draft vessels have safely
transited the waterway during the past 25 year period without major incident or pollution.
As is typical for an area lacking a large industrial base and metropolitan setting, the
region is currently not prepared to accept LNG carriers. The extent and nature of the
resources, training, and equipment necessary to address emergency response and related
issues have yet to be fully determined, but will be considered in specific detail during the
FERC required emergency response planning process.
Calais LNG also presented casualty data for LNG carriers operating world-wide over the
last 40 years, during which time more than 41,000 loaded trips were made by LNG
carriers with relatively few numbers of safety incidents being reported. Of the 22 cases
provided in the WSA, ten incidents involved a carrier in collision with another ship, a
carrier running aground or major ship damage due to rough seas; however, none of the
reported incidents resulted in a release of LNG. Case histories for three LNG carriers
that ran aground and resulting in significant hull damage were also provided. Although
there was major structural damage and in some cases extensive holing of the outer hull,
no cargo leak occurred - testament to current design practices, technology, and regulatory
oversight.
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Consequence Management
Concerns related to emergency response and marine firefighting have been consistently
raised by the general public, representatives of emergency response organizations, and
elected officials on both sides of the international border throughout the process of
identifying and assessing potential risks associated with the Calais LNG proposal. As
identified during the PAWSA study, there are very limited resources immediately
available to respond to a large marine casualty and/or vessel fire along the current transit
route. The consensus of the LNG work groups and AMSC subcommittee was that,
should the Calais LNG proposal be approved by FERC, it is imperative that issues
relating to emergency response and marine firefighting be sufficiently addressed during
the development of the emergency response plan, as required by Section 311 of the
Energy Policy Act of 2005. Additionally, bilateral arrangements to ensure appropriate
cross-boundary emergency response capabilities under the existing CANUSLANT
agreement should be considered.
Resource Identification and Needs

The area along the proposed transit route presents a number of significant challenges due
to the relative remoteness of the area (i.e., equating to limited response resources),
jurisdictional implications surrounding the U.S. and Canadian border, and potential for
high consequence impacts in the event of a major LNG spill/release. As indicated in
NVIC 05-08, the Calais LNG WSA should identify credible security threats and
navigational hazards for the intended LNG marine traffic, along with appropriate risk
management measures and the resources (Federal, state/provincial, local and private
sector) needed to carry out those measures. As aforementioned, the Canadian
government has expressed unequivocal opposition to LNG carriers transiting Head
Harbor Passage; consequently, they have refused to engage in meaningful dialogue with
the U.S. (Coast Guard or applicant) on any of the issues of mutual concern.
As indicated in Calais LNG’s WSA Recommendation(s) #10: Input from Canadian
Representatives, #11: Issues for Emergency response Plan (ERP), and #12: Public
Education Program for Emergency Response the company intends to pursue credible
dialogue with Canadian government officials to secure their interests. Related, the COTP
is recommending similar actions as denoted in Section 8, Risk Mitigation Measures.
The following is an abstract of major public and private assets that are known to exist
within the port area. This list was compiled from LNG work group efforts, the Calais
LNG WSA, and/or relevant research material. The listings are not all-inclusive; they are
intended solely to provide a comparative overview.
U.S. Federal Resources

Local Coast Guard activities, to include pollution prevention and response, vessel
inspection, port state control, International Ship and Port Facility Security (ISPS) and
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Maritime Transportation Security Act (MTSA) compliance exams and vessel boardings
are the responsibility of COTP, SNNE. These are routinely handled on a day-to- day
basis by Marine Safety Detachment (MSD) Belfast, ME due to their geographic
proximity (under the auspices of Commander, Sector Northern New England).
Federal units/resources located in the immediate vicinity of the Calais LNG proposal
include:
• USCG Station Eastport: equipped with a 41’ Utility Boat (UTB) and 25’
Response Boat Small (RBS).
• USCG Station Jonesport: equipped with a 47’ Utility Motor Life Boat
(MLB), 25’ RBS, and 27’ Response Boat Homeland Security (RBHS).
• USCGC Moray (WPB 87331): an 87' Coastal Patrol Boat home ported in
Jonesport, ME.
• U.S. Customs and Border Protection (CBP) for the Eastport area is equipped
with 25' RBS and 22' Sea-Ark watercrafts.
State, County, and Local Resources

Along with federal assets, there are a number of trained emergency management, fire,
law enforcement, and environmental response agencies available to provide assistance
throughout the region. These resources include:
• Maine State Police
• State Fire Marshall’s Office
• Maine Emergency Management Agency
• Washington County Regional Communications Office
• Washington County Sheriff’s Office
• Washington County Emergency Management Agency
• Calais Fire & Emergency Management Service Dispatch
• Local city and town fire and rescue departments
• Oil Spill Response Organizations (OSRO) for Down East Region 4
The majority of local, on-site public and private emergency response services within the
immediate area are predicated on ‘everyday’ emergent situations based on a largely rural
population and risk model. In the event of a large-scale crisis or catastrophe, the
acquisition of enhanced response capabilities, such as bomb squads, hazardous materials
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response, marine firefighting/salvage operations, and major medical assistance, etc.,

would require significant coordination through the major Federal, State, and County
agencies. Due to the relative geographic remoteness of the area, this could be a time-
sensitive and complex evolution.
Canadian Resources 10
Canada has developed national prevention, preparedness, and response mechanisms to
manage environmental emergencies. Federal policy exists to effectively manage all types
of emergencies, including natural ones such as hurricanes and tornadoes, and human-
caused events, such as fire and hazardous materials spills. It should be emphasized,
however, that the physical response to emergencies is almost exclusively carried out by
the private sector, with monitoring conducted by the government. Within the federal
government, emergency preparedness and response falls under Public Safety and
Emergency Preparedness Canada (PSEPC). The mandate of the PSEPC is to lead the
national effort to protect the Canadian citizenry from natural disasters, crime, and
terrorism.
In addition to the federal PSEPC, each province has an Emergency Management Office
or Emergency Measures Organization (EMO). The EMO works at both provincial and
municipal levels, and administers disaster financial assistance programs.
The Canadian emergency response system is premised upon the following:
• Initial response action lies with the responsible party (RP).
• If the incident is beyond the scope and capacity of the RP, the municipal services,
as directed by the respective mayor, respond.
• If the municipality cannot effectively manage the emergency, provincial services
are expected to come to the aid of the local authorities.
• If the response capacity of the province or territory is exceeded, then the federal
government intervenes and provides emergency assistance
The federal government normally only intervenes upon request, or when the emergency
clearly lies within federal jurisdiction. In the event of intervention, a lead Minister heads
the Department whose normal responsibilities closely relate to the circumstances of the
incident (e.g., Environment Canada in the case of an environmental emergency on federal
land; or the Canadian Coast Guard for spills originating from a vessel).
In Atlantic Canada, the key groups which would respond to an LNG spill/release at sea or
during docking evolutions are the Canadian Coast Guard, the Habitat Management
Division of the Department of Fisheries and Oceans, Environment Canada, the Regional
10
Based on relevant web-site(s) content
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Environmental Emergency Team (REET), and Regional Response Organizations

(ROs). 11
Potential Canadian resources identified in the Calais LNG WSA depend on risk
management measures being implemented in agreement with the federal and provincial
governments. Identified resources include:
• Transport Canada – Provides experience and expertise in vessel design,
construction, stability, and salvage.
• Canadian Coast Guard – Lead federal agency for all spills originating from a ship
in Canadian waters. Responds with spill response equipment to all ship source
spills either as the primary responder or as a monitor.
• The Royal Canadian Mounted Police (RCMP), an agency of the Ministry of
Public Safety and Emergency Preparedness Directorate, provides policing and
constable service for national, federal, provincial, and local municipalities.
• Regional volunteer fire/rescue departments.
Owing to the geographic remoteness of the communities along the Canadian
shoreline, low population densities, and minimal infrastructure, emergency response
inventories and associated, trained manpower are severely limited for the port area.
Emergency Response Planning Process

In accordance with Section 311 of the Federal Energy Policy Act of 2005, Calais LNG is
required to develop an Emergency Response Plan (ERP), in consultation with the U.S.
Coast Guard and state, regional and local response affiliated agencies. The ERP must be
approved by FERC before any construction may begin and is comprised of sections
containing:
1. Organizational charts displaying the incident management structure, team
responsibilities and functions, and the identification of all primary contacts and
their respective emergency contact information.
2. Planned responses to emergency incidents such as fire, vapor releases, hurricanes,
emergency vessel dock departures, bomb threats, etc. These sections are
furthered subdivided to include:
Procedures for communications
Procedures for responses, shelter and evacuation
Description of detection and shutdown systems
11
“A Study of the Anticipated Impacts on Canada from the Development of Liquefied Natural Gas
terminals on Passamaquoddy Bay” by SENES Consultants Ltd
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Hazard control equipment and local agency response

3. Detailed record of all training and exercises
4. Documentation requirements
5. Cost sharing procedures: The Energy Policy Act and ultimately, FERC
Commission orders, will require a cost sharing plan within the ERP that identifies
the funding mechanism for all project-specific security and safety/emergency
management costs that would be imposed on state and local agencies to include:
Direct reimbursement (overtime for police and fire etc.)
Capital costs associated with emergency management equipment (patrol
boats, fire fighting equipment etc.)
Annual costs associated with specialized training for fire departments, mutual
aid, etc.
If the Calais LNG proposal is approved, all federal, state, and local agencies with
responsibilities related to the proposed project, or whose jurisdiction may reasonably be
expected to be impacted by a potential navigation safety accident or terrorist attack,
should engage in the development of the ERP. The Coast Guard will facilitate this
process by continuing to involve the Down East Area Maritime Security Subcommittee in
the development and review of the facility security plan for the Calais-based terminal,
and the services of local officials, stakeholders, and respective members of the Maine &
New Hampshire Port Safety Forum in the development of the Emergency Response Plan.
The Coast Guard will also press to engage Canadian officials and waterway users in the
development and implementation of mutually beneficial risk management strategies and
emergency response measures.
After an LNG terminal is commissioned, LNG inspectors from the Department of
Transportation (DOT) Pipeline and Hazardous Materials Safety Administration
(PHMSA) regional office examine the emergency response and preparedness plan to
ensure continued compliance with applicable regulations as part of their standard facility
inspections.
LNG terminal owners and operators are also required to submit an Operations Manual
and Emergency Manual to the Coast Guard COTP for review and approval, as per the
requirements of 33 CFR 127.019. The Operations Manual must contain:
• A description of the cargo transfer area, to include the mooring area, all transfer
connections, and schematics of all piping and electrical systems.
• The duties of personnel assigned to transfer operations.
• The maximum allowable working pressure of the cargo transfer system.
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• Operating procedures covering cargo transfer, from startup to shutdown.

• 24/7 contact info for supervisors, watch standers, and security personnel, etc.
• A description of the security system being employed and procedures for security
violations.
• Training and communications systems procedures.
The Emergency Manual must contain:

• LNG release response procedures.
• Emergency shut down procedures.
• Operating description of the firefighting system.
• Description of the emergency lighting and power systems.
• Contact info of all regional federal, state, and local law enforcement, medical
facilities, fire departments and other emergency response organizations.
• Location info of personnel shelters, if so equipped.
• First aid procedures and locations.
• Emergency procedures for mooring and unmooring LNG carriers.
The ERP may serve as the Emergency Manual required by 33 CFR 127.019, provided it
contains the above information specified by 33 CFR 127.307.
The ERP is developed through a transparent, public process involving multiple

government agencies and key state and local officials. How this process will apply to
Canada and whether or not Canadian officials will collaborate is yet to be determined.
Calais LNG WSA Recommendation #10 – Input from Canadian Representatives states:
“…Calais LNG has taken the position that coordination with the appropriate safety and
security agencies is the right approach and the U.S. Coast Guard has indicated its
expectation that Calais LNG meet reasonable Canadian requirements…” to ensure safe
and secure LNG transportation through Canadian waters and along the entire transit
route. Section 8 of this Analysis contains specific risk mitigation measures further
addressing this issue.
8. RISK MITIGATION MEASURES
Based on the applicant’s WSA and comprehensive assessment conducted of the

Passamaquoddy Bay Waterway, COTP SNNE recommends that the following risk
mitigation measures and recommendations (Figure 18/Table 5.1 provides an excerpt of
the Recommendations from the Calais LNG WSA ) be fully implemented prior to FERC
allowing Calais LNG to begin operations:
The development, by the applicant, of standard operating parameters approved by the
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U.S. Coast Guard and coordinated with the Government of Canada to enable the safe and
secure movement of LNG tankers through Canadian and U.S. waters, taking into account
the need for:
• Number and performance capabilities of assist tugs and escort vessels as well as
determining appropriate staging areas. The minimum specified number of
escort/assist tugs must be employed at all times to escort LNG carriers throughout
their transit and during berthing and unberthing. It should be noted that additional
requirements for escort tugs may be identified during the emergency response and
transit management planning processes.
• Safe operating parameters and environmental constraints, to include but not
limited to: visibility, wind, sea state, currents, and tides. At a minimum, these
parameters must include the following:
a) Inbound, loaded or partially loaded LNG carriers may only transit the
waterway during daylight hours, with daylight being interpreted, in practical
terms, as being able to clearly see the horizon, shoreline and receiving berths
clearly under conditions of natural light.
b) A minimum of two miles of visibility is required for the movement of LNG
vessels in U.S. waters. Since in marginal weather conditions visibility can
vary significantly along the route, the decision as to whether sufficient
visibility exists, and is likely to continue to exist for the transit, is a judgment
call that will be made jointly between the attending pilot(s), Fundy Traffic or
the appropriate vessel traffic management entity in consultation with, and the
concurrence of, the COTP.
c) Twenty-five knots is the maximum sustained true wind speed, as measured on
the LNG carrier, at which an inbound or outbound transit will be allowed to
commence. As with visibility, significant variation in wind conditions can
exist along the route, and the decision as to whether wind conditions permit a
safe transit will be made by the attending pilot(s) in consultation with, and
concurrence by, the COTP.
d) One-way traffic patterns for deep-draft transits will be required and strictly
enforced whenever LNG carriers are moving to avoid meeting or overtaking
situations. At the discretion of the attending pilots and in consultation with
vessel masters and Fundy Traffic, all vessel transits will be on a first-come,
first-served basis, with inbound vessels having priority over outbound.
e) There are presently no “designated anchorages” (i.e., anchorages specified in
regulation) for the inland portion of the waterway. However, three locations
are routinely used by deep-draft vessels: one located in the Bay of Fundy
(controlled by Fundy Traffic) just outside of the transit corridor and to the
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north of Head Harbor Passage; one in the vicinity of Friars Bay southeast of
Eastport; and one inside of Passamaquoddy Bay. LNG vessels will not be
allowed to anchor, or hold, in these locations while waiting for a berth –
anchoring or holding under this circumstance must occur offshore. Non-LNG
vessels may anchor or hold in these locations at the attending pilot’s
discretion.
f) With the exception of temporary boarding areas established by, and for,
USCG authorized assets, the anchoring or holding of LNG vessels within
Friar Roads will be limited to confirmed emergency situations only, such as
major mechanical malfunctions and/or reduced visibility situations following
non-forecasted, abrupt weather changes (fog, squalls, etc.) and/or as directed
by, and in consultation with, the COTP.
g) Loaded, inbound LNG carriers transiting the inland portion of the transit
route, commencing with Head Harbor Passage, must maintain at least a two-
mile separation distance to preclude the possibility of incurring overtaking
situations.
2. The development and implementation of navigation safety upgrades and

enhancements, as identified in the applicant’s WSA, to include but not limited to:
radar coverage, communications interoperability, data buoys, and aids to navigation
(ATON).
3. The development, by the applicant, of an Emergency Response Plan required by

Section 311 of the Energy Policy Act of 2005, 15 U.S.C § 717b-1(e), that is approved
by the Federal Energy Regulatory Commission and accepted by the U.S. Coast Guard
to enable a comprehensive and coordinated response to an LNG emergency, taking
into account the need for:
a) In-transit and dockside emergency procedures in the event of fire, mechanical
malfunction, allision, grounding, and/or need of safe anchorage or refuge.
b) The potential environmental impact of an LNG release and the identification and
acquisition of joint resource needs to respond to the potential release.
c) A contingency response plan specific to LNG and focusing on a layered response
approach.
d) Coordinated marine firefighting training and emergency response, with an
emphasis on containing and extinguishing LNG fires.
e) An incident management training and collaborative exercise program.
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4. Collaboration with all appropriate jurisdictions on joint, complementary rulemaking

to formalize deep-draft vessel traffic management practices for the protection of the
LNG carrier, alternate waterway users, and area residents taking into account the need
for:
a) A one-way vessel traffic scheme.
b) Deep-draft vessel escort tugs and assistance services.
c) Mandatory pilotage throughout the transit route and during docking and
undocking evolutions at all ports along the waterway, subject to Canadian
endorsement.
d) Implementation of an Automatic Identification System for all vessels involved in
the transport of LNG on this waterway.
e) Implementation of appropriate vessel speed restrictions.
f) Implementation of appropriate environmental operating parameters (e.g. currents,
tides, visibility, wind velocity, etc.).
5. The applicant must develop and successfully conduct full mission bridge simulator
training for all pilots providing services to LNG carriers. The training must take into
account the full spectrum of vessel design and length, cargo carrying capacity,
method of propulsion, steering and rudder configuration, thruster arrangements, and
maneuvering characteristics for those carriers being considered for charter. In
addition, expanded simulator training incorporating the number and design of tug
boats having the minimum performance and operating criteria previously outlined,
will be required.
6. The applicant should, as recommended in NVIC 05-08, Change 1, develop a Transit

Management Plan or similar documented procedures, in consultation with the USCG
and other cognizant agencies, that clearly outlines the roles, responsibilities, and
specific procedures for the LNG carrier, the LNG terminal, and all federal,
state/provincial, and local stakeholders with responsibilities related to the proposed
project and/or whose jurisdiction may reasonably be expected to be impacted by a
potential navigation safety accident or terrorist attack.
7. The applicant must prepare and submit an Operations Manual, as required by 33

C.F.R. § 127.305, an Emergency Manual, as required by 33 C.F.R. § 127.307, and a
Facility Security Plan as required by 33 C.F.R. § 105.120 to the COTP Sector
Northern New England for review and approval at least 6 months but no more than 12
71
REDACTED VERSION

months before the facility would begin operations.
8. The applicant must provide written verification of collaboration with, and acceptance
from, the Passamaquoddy Nation ensuring its jurisdictional interests and public safety
and security needs associated with this project are adequately met.
9. Currently there are no known credible threats specific to the proposed Calais LNG
facility; nonetheless, the threat environment is subject to change over time, especially
in view of the protracted time table necessary to facilitate construction. If the project
receives FERC approval periodic threat assessments must be conducted by Calais
LNG, at the discretion of the COTP, in order to ensure that in-place security measures
are adequate and appropriate to meet circumstances existing at the time.
10. Prior to terminal operations Calais LNG must provide the COTP with the following
information: 1) Intended LNG carrier(s)’ nation of registry; 2) The nationality or
citizenship of the officers serving on board the intended LNG carriers; and 3) The
nationality or citizenship of the crew members serving on board the intended LNG
carriers.
11. Until the facility goes into operation, Calais LNG must conduct an annual review of
their WSA and provide the COTP with an update that accurately reflects all changes
(actual and planned) made to include circumstances such as LNG carrier size or load
frequency, port characterization modifications, facility-related design alternations,
and conditions potentially affecting cumulative considerations. The annual review
cycle should coincide with the anniversary date of the LOR.
Calais LNG must determine and comply with all applicable Canadian laws and
regulations applicable to safe and secure navigation and the regulation of maritime traffic
that comply with customary international law. Such laws and regulations shall not
discriminate among foreign ships, or in their application have the practical effect of
denying, hampering, or impairing the right of non-suspendable innocent passage through
an international strait. Moreover, consistent with international law, the Coast Guard will
not require compliance with such laws and regulations that apply to the design,
construction, manning, or equipment of foreign ships unless they are giving effect to
generally accepted international rules or standards.
72
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Figure 18
Figure 18 cont’d
73
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74
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9. SENSITIVE SECURITY SUPPLEMENT
This section (pages 75-84) contains Sensitive Security Information controlled under 49
CFR Part 1520 and has been redacted. This information may not be disclosed to persons
without a “need to know” as defined in 49 CFR 1520.5, except with written permission of
the Secretary of Homeland Security.
75
REDACTED VERSION

10. CONCLUSIONS
Based on the COTP’s analysis of the potential risks to navigation safety and maritime
security, and assuming the applicant fully implements all of the risk mitigation measures
identified in the Calais LNG WSA, the U.S. Coast Guard recommends that the waterway
along the intended transit route, which takes in waters of the Gulf of Maine, Bay of
Fundy, Grand Manan Channel, Head Harbor Passage, Friar Roads, Western Passage,
Passamaquoddy Bay, and St. Croix River be considered suitable for the type and
frequency of marine traffic associated with this proposed project.
The hydrographic characteristics of the waterway are suitable to sustain deep draft vessel
movement and the simulation tests and traffic studies conducted confirm that the transit
and maneuvers are feasible for the design range of LNG carriers anticipated. If the
conditions of the waterway change the COTP may reconsider this recommendation.
Whether or not the Calais LNG proposal is approved by FERC, the USCG will continue
to systematically analyze the waters of Passamaquoddy Bay and its approaches to
effectively manage the potential risks to navigation safety and maritime security
associated with the project.
If FERC approves the project and the facility begins operations, additional resources
would be needed to mitigate safety and security risks identified during the suitability
assessment process. The required security resources, in particular law enforcement
personnel and associated security craft, and associated operational procedures are based
on existing USCG authorities and policies. These policies take into account a changing
threat environment and the potential for unknown threats. The most probable security
regime should consist of a mix of U.S. and Canadian federal, state/provincial, and local
law enforcement, which may require cost-sharing arrangements, as outlined in the Energy
Policy Act of 2005. As mentioned previously, a major portion of the vessels’ route is
initially through Canadian waters. Calais LNG must be able to adequately demonstrate
that an effective security regime has been established during the Canadian portion of the
vessels’ planned route prior to a loaded LNG vessel being allowed to transit to the
facility. By this it is meant that Calais LNG must show that the vessel is provided with,
and has the ability to implement, security measures as established and set forth in the
International Maritime Organization’s (IMO) International Ship & Port Facility Security
Code (ISPS) and Safety of Life and Sea Amendments of 2002 (SOLAS) that are at least
equivalent to the level of security required for vessels transiting waters of the United
States with similar characteristics (e.g., population densities, key port areas, critical
infrastructure, etc.).
11. LIST OF ACRONYMS
85
This record contains Sensitive Security Information (SSI) that is controlled under 49 CFR Part 1520. No
part of this record may be disclosed to persons without a “need to know”, as defined in 49 CFR 1520.5,
except with the written permission of the Secretary of Homeland Security. Unauthorized release may result
in civil penalty or other action. For U.S. Government agencies, public disclosure is governed by 5 U.S.C.
532 and 49 CFR Part 1520.
REDACTED VERSION

ABS American Bureau of Shipping

AIS Automatic Identification System
AMSC Area Maritime Security Committee
APA Atlantic Pilotage Association
API American Petroleum Institute
ASD Azimuth Stern Drive (Propulsion)
ATON Aid to Navigation
Bcfd Billion Standard Cubic Feet Per Day
BMP Bureau of Marine Patrol
CANUSLANT Canada, United States, Atlantic
CATS Community Assistance & Technical Services
CCG Canadian Coast Guard
CCTV Closed Circuit Television
CDC Certain Dangerous Cargoes
CFR Code of Federal Regulations
COLREGS International Regulations for Preventing Collisions at Sea
COTP Captain of the Port
CSP Cost Sharing plan
CVTS Cooperative Vessel Traffic Services
DFO Department of Fisheries and Oceans
DGPS Differential Global Positioning System
DHS Department of Homeland Security
DOT Department of Transportation
EIS Environmental Impact Statement
ERP Emergency Response Plan
EMO Emergency Measures Organization
FERC Federal Energy Regulatory Commission
FiFi Fire Fighting
GPS Global Positioning System
HHP Head Harbor Passage
IACS International Association of Classification Societies
IMO International Maritime Organization
ISM International Safety Management
ISPS International Ship & Port Facility Security Code
LE Law Enforcement
LNG Liquefied Natural Gas
LOI Letter of Intent
LOR Letter of Recommendation
LORA Letter of Recommendation Analysis
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LPG Liquefied Petroleum Gas

MARPOL International Convention for the Prevention of Pollution from
Ships, 1973, as modified by the Protocol of 1978
MARSEC Maritime Security
M & NP Maritimes and Northeast Pipeline, L.L.C.
MEMA Maine Emergency Management Agency
MMP Maine Marine Patrol
MSI Marine Safety International
MTSA Maritime Transportation Security Act
NEPA National Environmental Policy Act
NOAA National Oceanographic and Atmospheric Administration
NPRA National Petrochemical & Refiners Association
NVIC Navigation and Vessel Inspection Circular
OPA Oil Pollution Act of 1990
PAWSA Ports and Waterway Safety Assessment
PHMSA Pipeline and Hazardous Materials Safety Administration
PORTS Physical Oceanographic Real-Time System
PSEPC Public Safety and Emergency Preparedness Canada
PWSA Ports and Waterways Safety Act
RBDM Risk-Based Decision-Making
RCMP Royal Canadian Mounted Police
REET Regional Environmental Emergency Team
RP Responsible Party
RO Response Organization
SAR Search and Rescue
SRA Safety Risk Assessment
SVA Security Vulnerability Assessment
SIGTTO Society of International Gas Tanker and Terminal Operators
SSI Sensitive Security Information
SNNE Sector Northern New England
VHF-FM Very High Frequency-Frequency Modulated
VTS Vessel Traffic Service
UNCLOS United Nations Convention on the Laws of the Sea
USC United States Code
USCG United States Coast Guard
WAMS Waterways Analysis and Management System
WSA Waterway Suitability Assessment
WSR Waterway Suitability Report
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ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

1. INTRODUCTION: This is to supplement my Letter of Recommendation (LOR) dated

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

3. RESOLUTION PRECIS: The following paragraphs summarize the myriad of specifics

4. WATERWAY TRANSIT CONSIDERATIONS

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

Transit Route Description

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

Vessel Traffic Management

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

Vessel Traffic Service (VTS)

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

WSA Recommendation #3: LNG Transit Management Planning and Coordination. To

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

Pilot and general boarding areas

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

Simulated Maneuvering Trials

The objectives of the maneuvering studies were to:

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

1. Establishing a lighted buoy at Stovers Ledge to mark the shoal area.

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

Transit Analysis and Traffic Coordination Study

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

The Traffic Coordination Study focused on conceivable marine traffic scenarios

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

5. PORT LEVEL CONSIDERATIONS

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

Recreational Boating and Commercial Fishing

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

As confirmed during an independent Ports and Waterways Safety Assessment (PAWSA)

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

Areas of Historical Significance

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

Areas of Environmental Significance

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

Environmentally sensitive areas along the transit route include:

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

International and Sovereignty Considerations

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

UNCLOS as customary international law. 4 A consequence of the U.S. ‘non-party status’

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

Representative M. Michaud, in anticipation of the G8 and G20 Summits in

• In July 2010, Canada’s consul general to New England, Neil LeBlanc,

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

As indicated in WSA Recommendation #10; Input from Canadian Representatives,

ANALYSIS SUPPORTING THE LETTER OF RECOMMENDATION ISSUED BY

Hazard control equipment and local agency response