# Florida Gas Transmission — Pipeline Special Permit

- **operation:** document
- **citation:** PHMSA-2021-0118
- **title:** Florida Gas Transmission — Pipeline Special Permit
- **source type:** permit
- **agency:** Pipeline and Hazardous Materials Safety Administration
- **status:** current
- **official:** true
- **published on:** 2022-04-04
- **effective on:** 2022-04-04
- **summary:** PHMSA-2021-0118, issued 2022-04-04 for Florida Gas Transmission's gas transmission system.
- **machine formats:** - **json:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2021-0118.json
- **markdown:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2021-0118.md
- **app url:** https://regulus.evalyn.ai/document/phmsa-special-permit-phmsa-2021-0118
- **source url:** https://www.regulations.gov/docket/PHMSA-2021-0118
**body:**

PHMSA pipeline special permit PHMSA-2021-0118. Operator: Florida Gas Transmission. System: Gas Transmission. Issue date: 2022-04-04.

<<<PAGE 1>>>

U.S. DEPARTMENT OF TRANSPORTATION
PIPELINE AND HAZARDOUS MATERIALS SAFETY ADMINISTRATION
ENVIRONMENTAL ASSESSMENT
and
FINDING OF NO SIGNIFICANT IMPACT
Special Permit Information:
Docket Number: PHMSA-2021-0118
Requested By: Florida Gas Transmission Company, LLC
Operator ID#: 5304
Original Date Requested: November 17, 2021
Issuance Date: April 4, 2022
Code Section(s): 49 CFR 192.611(a) and (d) and 192.619(a)
I. Background:
The National Environmental Policy Act (NEPA), 42 U.S.C. 4321 – 4375 et seq., Council on
Environmental Quality Regulations, 40 CFR 1500-1508, and U.S. Department of Transportation
(DOT) Order No. 5610.1C, requires the Pipeline and Hazardous Materials Safety
Administration (PHMSA) Office of Pipeline Safety (OPS)1 to analyze a proposed action to
determine whether the action will have a significant impact on the human environment.
PHMSA analyzes special permit requests for potential risks to public safety and the environment
that could result from our decision to grant, grant with additional conditions, or deny the
request. As part of this analysis, PHMSA evaluates whether a special permit will impact the
likelihood or consequence of a pipeline failure as compared to the operation of the pipeline in
1 Throughout this special permit the usage of “PHMSA” or “PHMSA OPS” means the U.S. Department of
Transportation’s Pipeline and Hazardous Materials Safety Administration Office of Pipeline Safety.
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 1 of 79

<<<PAGE 2>>>

full compliance with the Federal pipeline safety regulations. PHMSA’s environmental review
associated with the special permit application is limited to impacts that would result from
granting or denying the special permit. PHMSA developed this assessment to determine what
effects, if any, our decision would have on the environment.
Pursuant to 49 U.S.C. 60118(c) and 49 Code of Federal Regulations (CFR) 190.341, PHMSA
may only grant special permit requests that are not inconsistent with pipeline safety. PHMSA
will impose conditions in the special permit if we conclude they are necessary for safety,
environmental protection, or are otherwise in the public interest. If PHMSA determines that a
special permit would be inconsistent with pipeline safety or is not justified, the application will
be denied.
The purpose of this Final Environmental Assessment (FEA) is to comply with National
Environmental Policy Act (NEPA) for the Florida Gas Transmission Company, LLC (FGT)2
special permit to waive compliance from 49 CFR 192.611(a) and (d) and 192.619(a) for one (1)
special permit segment and one (1) special permit inspection area along the FGT natural gas
transmission pipeline system in Florida. This FEA assesses the pipeline special permit request,
in accordance with 49 CFR 190.341, and is intended to specifically analyze any environmental
impact associated with the waiver of certain federal pipeline safety regulations found in 49 CFR
192.611(a) and (d) and 192.619(a). This permit requires FGT to implement additional
conditions on the operations, maintenance, and integrity management (IM) of the approximately
0.978 miles (special permit segment) on the 26-inch Mainline Loop CMPR STA 18-19
(Pipeline) and approximately 73.7 miles (special permit inspection area) of the FGT natural gas
transmission pipeline system located in Brevard County, Florida.
II. Introduction:
Pursuant to 49 U.S.C. 60118(b) and 49 CFR 190.341, FGT submitted a special permit
application to PHMSA on November 17, 2021, requesting that PHMSA waive the requirements
of 49 CFR 192.611(a) and (d) and 192.619(a) to permit FGT to maintain the maximum
2 Florida Gas Transmission Company, LLC is owned by Energy Transfer and Kinder Morgan, Inc.
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 2 of 79

<<<PAGE 3>>>

allowable operating pressure (MAOP) for one (1) special permit segment where the class
location has changed from Class 1 to Class 3 located in in Brevard County, Florida.
PHMSA is granting a special permit to waive certain regulatory requirements where it is not
inconsistent with pipeline safety. A special permit is typically conditioned on the performance
of additional measures beyond minimum Federal pipeline safety regulations, in accordance with
49 CFR 190.341.
III. Regulatory Background:
PHMSA regulations at 49 CFR 192.611(a) require that an operator confirm or revise the MAOP
of a pipe segment that is in satisfactory condition when the hoop stress of the segment is no
longer commensurate with class location. Under 49 CFR 192.611(a), an operator may be
required to reduce the operating pressure of a pipe segment, or alternatively, may have to
replace the pipe in order to maintain the MAOP. Below is the relevant text of 49 CFR
192.611(a):
49 CFR 192.611 Change in class location: Confirmation or revision of maximum allowable
operating pressure
(a) If the hoop stress corresponding to the established maximum allowable operating pressure
of a segment of pipeline is not commensurate with the present class location, and the
segment is in satisfactory physical condition, the maximum allowable operating pressure of
that segment of pipeline must be confirmed or revised according to one of the following
requirements:
(1) If the segment involved has been previously tested in place for a period of not less than 8
hours:
(i) The maximum allowable operating pressure is 0.8 times the test pressure in Class 2
locations, 0.667 times the test pressure in Class 3 locations, or 0.555 times the test
pressure in Class 4 locations. The corresponding hoop stress may not exceed 72
percent of the SMYS of the pipe in Class 2 locations, 60 percent of SMYS in Class 3
locations, or 50 percent of SMYS in Class 4 locations.
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 3 of 79

<<<PAGE 4>>>

(ii) The alternative maximum allowable operating pressure is 0.8 times the test pressure in
Class 2 locations and 0.667 times the test pressure in Class 3 locations. For pipelines
operating at alternative maximum allowable pressure per §192.620, the corresponding
hoop stress may not exceed 80 percent of the SMYS of the pipe in Class 2 locations and
67 percent of SMYS in Class 3 locations.
(2) The maximum allowable operating pressure of the segment involved must be reduced so
that the corresponding hoop stress is not more than that allowed by this part for new
segments of pipelines in the existing class location.
3) The segment involved must be tested in accordance with the applicable requirements of
subpart J of this part, and its maximum allowable operating pressure must then be
established according to the following criteria:
(i) The maximum allowable operating pressure after the requalification test is 0.8 times
the test pressure for Class 2 locations, 0.667 times the test pressure for Class 3
locations, and 0.555 times the test pressure for Class 4 locations.
(ii) The corresponding hoop stress may not exceed 72 percent of the SMYS of the pipe in
Class 2 locations, 60 percent of SMYS in Class 3 locations, or 50 percent of SMYS in
Class 4 locations.
(iii) For pipeline operating at an alternative maximum allowable operating pressure per
§192.620, the alternative maximum allowable operating pressure after the
requalification test is 0.8 times the test pressure for Class 2 locations and 0.667 times
the test pressure for Class 3 locations. The corresponding hoop stress may not exceed
80 percent of the SMYS of the pipe in Class 2 locations and 67 percent of SMYS in
Class 3 locations.
49 CFR 192.619 What is the maximum allowable operating pressure for steel or plastic
pipelines?
(a)(2)(ii) For steel pipe operated at 100 p.s.i. (689 kPa) gage or more, the test pressure is divided
by a factor determined in accordance with the following table:
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 4 of 79

<<<PAGE 5>>>

Section 192.619(a) requires Class 3 location pipe to be pressure tested to 1.5 times MAOP.
IV. Purpose and Need
FGT requested a waiver from the requirements of 49 CFR 192.611(a) and (d) and 192.619(a) for
the special permit segment consisting of approximately 0.978 miles of natural gas transmission
pipeline listed below in Table 1 – Special Permit Segment. Without a special permit, the cited
regulations require that FGT complete pipe replacement, hydrotest, and pressure reduction,
based on population changes in the vicinity of the special permit segment. FGT must apply the
special permit conditions to one (1) special permit segment to provide an equivalent margin of
safety and environmental protection to meet the requirements of 49 CFR 192.611, as outlined in
the special permit conditions.
The special permit establishes enhanced IM procedures to maintain pipe integrity and protect
both the public and the environment for the class location units in which the special permit
segment is located for the length of pipeline covered by the special permit. In addition, FGT
must comply with conditions as provided in the terms of the special permit for all the impacted
special permit segments and the special permit inspection area in the special permit.
The special permit authorizes future class changes within the special permit inspection area
(special permit segment extensions) under the special permit, providing the special permit
segment extensions meet the special permit conditions applicable to the special permit segment.
In that case, FGT must also notify PHMSA and update this FEA/FONSI.
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 5 of 79

<<<PAGE 6>>>

V. Site Description
The special permit segment consists of 5,162 feet (approximately 0.978) of the 26-inch diameter
Mainline Loop CMPR STA 18-19 Pipeline located in Brevard County, Florida. The special
permit inspection area extends approximately 73.7 miles of the pipeline.
VI. Special Permit Segments and Special Permit Inspection Areas
Special Permit Segment:
This special permit applies to the special permit segment identified in Table 1 – Special Permit
Segment and are identified using the FGT survey station (SS) references.
Table 1 – Special Permit Segment
Special
Start
End
Outside
Permit
Diameter
Line Name Length
(feet)
Survey
Station
Survey
Station
County,
State
Year
Seam
MAOP
Segment
Number
Installed
Type
(psig)
(inches)
(SS)
(SS)
182069 26
26-inch Mainline
Loop STA 18 - STA
19
5,162 3241+20 3292+82 Brevard, FL 1968 DSAW 977
Special Permit Inspection Area:
The special permit inspection area is defined as the area that extends 220 yards on each side of
the centerline along approximately 79.7 miles of 26-inch diameter Mainline Loop pipeline. A
summary of special permit inspection area is included in Table 2 – Special Permit Inspection
Area.
Table 2 – Special Permit Inspection Area
Special
Special Permit
Outside
Permit
Inspection
Segment
Number(s)
Diameter
Line Name County, State Start Survey
Station (MP)
End Survey
Station (MP)
Length
(miles)
(inches)
Area Name
FLMEB-18 182069 26 Mainline Loop
STA18-STA19 Brevard, FL 668.8 742.5 73.7
Attachment B1 is a general map that includes the pipeline route map showing the special
permit segment and special permit inspection area.
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 6 of 79

<<<PAGE 7>>>

PHMSA is granting this special permit request based on this document and the "Special Permit
Analysis and Findings" document, which is incorporated by reference into this document and
can be read in its entirety in Docket No. PHMSA-2021-0118 in the Federal Docket Management
System (FDMS) located on the internet at www.regulations.gov.
VII. Alternatives
Alternative 1: “No Action” Alternative
If PHMSA were to select the “no action” alternative, PHMSA would deny FGT’s special permit
request, FGT would be required to fully comply with 49 CFR 192.611(a) and (d) and
192.619(a). In order to maintain the existing MAOP, FGT would be required to replace the
0.978 miles (5,162 feet) of pipe in the special permit segment or FGT would be required to
reduce pressure on the segment. FGT stated that it would choose to replace the special permit
segment to maintain the MAOP because a pressure reduction would prevent it from meeting its
contractual obligations to deliver natural gas to its customers.
Alternative 2: “Selected” Alternative – Issuance of the special permit
PHMSA is granting the special permit with the below conditions, and FGT is allowed to
continue to operate at the current maximum allowable operating pressure (MAOP) of 977
pounds per square inch gauge (psig) in the Class 3 location without replacing pipe while
complying with the special permit conditions, as described below.
VIII. Overview of Special Permit Conditions
The special permit conditions are designed to prevent leaks and ruptures such that the Special
Permit is not inconsistent with pipeline safety. This section provides an overview of the special
permit conditions. For FGT specific technical requirements, see Attachment C - Special
Permit Conditions.
1) Current Status of Pipe in the Ground
To ensure that key characteristics of the pipe currently installed in each special permit
segment is known, FGT must provide records that confirm pipe specifications, successful
pressure tests, and girth weld non-destructive tests are required. Should records be
unavailable or unacceptable, additional activities as detailed in the special permit must be
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 7 of 79

<<<PAGE 8>>>

completed. If FGT does not complete these additional activities are not completed or should
pipe be discovered that does not meet specific requirements of eligibility, the special permit
segment must be replaced.
2) Operating Conditions
The special permit inspection area must continue to be operated at or below the existing
MAOP until a restoration or uprating plan has been approved, if allowed by the special
permit. To ensure compliance with special permit conditions, the operator’s Operations and
Maintenance Manual (O&M), IMP, and Damage Prevention (DP) program must be modified
to implement the special permit conditions. In addition, PHMSA must approve any long-
term flow reversals that would impact the special permit segment.
3) Threat Management
Threats are factors that can lead to the failure of a pipeline. Activities are required to
identify, assess, remediate, and monitor threats to the pipeline.
a) General activities. The permit holder must perform annual data integration and
identification of threats to which the special permit inspection area is susceptible. These
activities must include integrity assessments with specific inline inspection tools, strict
anomaly repair criteria, and appropriate environmental assessment and permitting.
Additional integrity assessment methodologies may be used if allowed by the special
permit. Integrity assessments must then be conducted periodically at an interval
determined in the special permit for each threat identified.
b) External corrosion control requirements. The special permit requires additional
activities to monitor and mitigate external corrosion. These activities include installation
and annual monitoring of cathodic protection (CP) test stations, periodic close interval
surveys (CIS), and clearing or remediating shorted casings that may impede CP
effectiveness. These activities ensure the appropriate level of CP is reaching the pipeline
in areas where coating loss or damage has occurred in order to prevent or mitigate
external corrosion. In addition, FGT will be required to develop and implement a plan
that identifies and remediates interference from alternating or direct current (AC/DC)
sources (such as high-voltage powerlines) that could adversely impact the effectiveness
of CP.
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 8 of 79

<<<PAGE 9>>>

c) Internal corrosion control requirements. The special permit includes gas quality
specifications to mitigate internal corrosion because internal corrosion is highly
dependent on the quality of the gas transported within the pipeline and.
d) Stress corrosion cracking (SCC) requirements. To ensure that SCC is discovered and
remediated, any time a pipe segment is exposed during an excavation the permit holder
must examine coating to determine type and condition. If the coating is in poor
condition, FGT must conduct additional SCC analysis. If SCC is confirmed, FGT must
implement additional special permit defined remediation and mitigation.
e) Pipe seam requirements. FGT must perform an engineering integrity analysis to
determine susceptibility to seam threats. The permit holder must re-pressure test any
special permit segments with an identified seam to ensure the issue is not systemic in
nature.
f) External pipe stress requirements. Upon identification of any source of external stress
on the pipeline (such as soil movement), FGT must develop procedures to evaluate and
periodically monitor these stresses.
g) Third-party specific requirements. To assist in identifying the pipeline location and
minimizing the chance of accidental pipeline strikes, FGT must install and maintain line-
of-site markers for the pipeline. FGT must perform mitigation activities for any location
where a depth-of-cover survey shows insufficient soil cover.
4) Consequence Mitigation
To ensure quick response and decreased adverse outcome in the event of a failure, each side
(upstream and downstream) of the special permit segment must have and maintain operable
automatic shutdown valves (ASV) or remote-controlled valves (RCV). FGT must monitor
valves through a control room with a supervisory control and data acquisition (SCADA)
system. In addition to the mainline valves, should a crossover or lateral connect between the
valve locations, additional isolation valves may be required.
5) Post Leak or Failure
If the special permit inspection area experiences an in-service or pressure test leak/failure,
FGT must conduct a root cause analysis to determine the cause. If the cause is determined
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 9 of 79

<<<PAGE 10>>>

to be systemic in nature, the permit holder must implement a remediation plan or the special
permit segment must be replaced, as determined by the special permit specific conditions.
6) Class Location Study and Potential Extension of Special permit segment
FGT must conduct a class location study at an interval specified in the special permit. This
allows the permit holder to quickly identify extended locations that must comply with the
special permit segment requirements. FGT may extend the special permit segment with
proper notification, update of the Final Environmental Assessment, and implementation of
all requirements in the special permit.
7) PHMSA Oversite and Management
PHMSA maintains oversight and management of each special permit. This includes annual
meetings with executive level officers on special permit implementation status, written
certification of the special permit, special permit required notification of planned activities,
notification of root cause analysis results, and notification prior to certain excavation
activities so that PHMSA may observe.
8) Gas Leakage Surveys and Remediation
The special permit segment and special permit inspection area have requirements in the
special permit to conduct leakage surveys more frequently than is presently required in 49
CFR 192.706. Gas leakage surveys using instrumented gas leakage detection equipment
must be conducted along each special permit segment and at all valves, flanges, pipeline tie-
ins with valves and flanges, ILI launcher, and ILI receiver facilities in each special permit
inspection area at least twice each calendar year, not to exceed 7½ months. The type of
leak detection equipment used, survey findings, and remediation of all instrumented gas
leakage surveys must be documented by operator. The special permit will require a three-
step grading process with a time interval for remediation based upon the type of leak.
9) Documentation
FGT must maintain documentation that supports compliance with special permit conditions
for the life of the pipeline.
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 10 of 79

<<<PAGE 11>>>

IX. Affected Resources and Environmental Consequences
A. Affected Resources and Environmental Consequences of the Granted
Action and the No Action Alternatives
FGT is granted a special permit that waives compliance with 49 CFR 192.611(a) and (d) and
192.619(a) for a special permit segment totaling 5,162 feet (approximately 0.978 miles) located
within the special permit inspection area totaling approximately 73.7 miles. FGT must comply
with the special permit conditions within the special permit segment.
Potential risks from the regulatory waiver to pipeline integrity will be analyzed for each special
permit segment to evaluate the potential for impacts or increased risk to safety or environmental
resources.
Aesthetics: The visual character of the special permit segment and the special permit inspection
area will not be changed by the approval of this special permit request. The objective of the
special permit is to avoid construction or ground disturbances in the pipeline ROW that would
be necessitated if the special permit was not granted. Therefore, the issuance of the requested
special permit will result sporadic and temporary aesthetic impacts due to increased monitoring,
maintenance, and repair activities along the affected special permit segment or special permit
inspection area.
Denial of the special permit request would require the replacement or pressure testing of all the
pipeline segments associated with this special permit request. Pipe replacement would require
removal of the existing pipe and installation of a new pipe. This would result in the use of
heavy equipment and ground disturbance. Furthermore, pressure testing would also require
disturbances along the pipeline ROW.
Agricultural Resources: This special permit request will not impact agricultural resources in the
pipeline ROW where the special permit segment or the special permit inspection area are
located, as there are none in adjacent areas.
Air Quality: Air Quality Control Regions (AQCRs) are areas for which implementation plans
describe how ambient air quality standards would be achieved and maintained. AQCRs are
defined by the U.S. Environmental Protection Area (EPA) and state agencies in accordance with
the Clean Air Act of 1970 (CAA). The 1977 CAA Amendments in Section 107 require EPA and
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 11 of 79

<<<PAGE 12>>>

states to identify by category those AQCRs meeting and not meeting the U.S. National Ambient
Air Quality Standards (NAAQS) which are standards for harmful pollutants. Areas meeting the
NAAQS are designated “attainment areas,” and areas not meeting the NAAQS are designated
“nonattainment areas”. The designation of an area is made on a pollutant-by-pollutant basis. The
special permit segment occurs in areas that are designated attainment areas for all pollutants.
This special permit will not significantly affect the air quality of the special permit segment or
the special permit inspection area, as increased monitoring, maintenance, and repair activities
and associated vehicles and equipment will only have sporadic and temporary air impacts caused
by fuel combustion. The objective of the special permit is to avoid construction or ground
disturbances in the pipeline ROW that would be necessitated if the special permit was not granted.
If the special permit request is not granted, pipe replacement and hydrotesting would be required.
This would necessitate blowing down the pipeline which releases unburned natural gas into the
atmosphere, which is an aggressive greenhouse gas. Furthermore, pipe replacement and/or
pressure testing would be required which would require the temporary use of heavy equipment,
which result in release of air pollutants.
Biological Resources: The “Selected” Alternative will not impact vegetation (including
wetlands), wildlife (including threatened and endangered species), or fishery resources in the
pipeline ROW where the special permit segment or the special permit inspection area are located.
The low-growing herbaceous cover within the pipeline ROW may provide sources of food and
nesting sites for various birds, as well as cover for mammals, invertebrates, reptiles, and
amphibians. The area has been disturbed previously and is located between Interstate 95 (I-95)
and a man-made drainage canal. Furthermore, the pipeline ROW is maintained in an herbaceous
state by routine mowing and clearing activities using mechanical equipment. Therefore, the
wildlife found in the vicinity of the special permit segment will most likely be tolerant of human
disturbance. A discussion of water resources (wetlands and waterbodies) crossed by the special
permit segments is provided in this document. A discussion of listed species and sensitive areas
(i.e., conservation land) is provided below.
Listed Species
The U. S. Fish and Wildlife Service (USFWS) Information, Planning, and Conservation System
(IPaC) was utilized to identify the federally and state listed threatened and endangered species
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 12 of 79

<<<PAGE 13>>>

that could potentially inhabit or traverse the special permit segment (USFWS, 2021). Table 3
provides a list of the federally and state listed threatened and endangered species potentially
occurring in the special permit segment. A total of 13 listed species (5 birds, 6 reptiles, and 2
plants) were identified as potentially occurring in the special permit segment.
The objective of the special permit is to avoid construction or ground disturbance in the pipeline
ROW. Therefore, the “Selected” Alternative will not disturb wildlife habitat resulting in “No
effect” to listed species. However, if the special permit request is not granted by selection of the
“No Action” Alternative, then pipe replacement and/or pressure testing would be required, which
would disturb vegetation and wildlife habitat in the vicinity of the existing pipeline ROW, which
could potentially disturb listed species such as gopher tortoises and gopher tortoise commensal
species (i.e., Eastern indigo snake) in the special permit segment.
Any inspection activities related to the special permit segment will be conducted within the
boundaries of the previously disturbed pipeline ROW. FGT has received a categorical exclusion
blanket clearance from the USFWS for minor pipeline construction and maintenance projects
within FGT’s existing ROW. The Florida USFWS Ecological Services Field Office has
determined in its categorical exclusion blanket clearances that work within FGT’s existing ROW
is unlikely to adversely impact federally listed species and their habitats.
TABLE 3
Federally and State Listed Threatened and Endangered Species Potentially
Species Occurring within the Special Permit Segment Areas in Brevard County, Florida
Habitat Description Federal
Status
State
Status Determination of Effect /
Rationale
Birds
Audubon's Crested
Caracara
(Polyborus plancus
audubonii)
T T Eastern Black Rail
(Laterallus
jamaicensis ssp.
Jamaicensis)
T T Occurs in dry or wet prairie areas with
scattered cabbage palms (Sabal
palmetto). It may also be found in
lightly wooded areas.
Typically found in salt and brackish
marshes with dense cover.
No effect / No suitable habitat is
present in the special permit
project areas (maintained pipeline
ROW).
No effect / No suitable habitat is
present in the special permit
project areas (maintained pipeline
ROW).
Everglade Snail
Kite
(Rostrhamus
sociabilis
plumbeus)
E E Habitat includes salt and brackish
marshes with dense cover.
No effect / No suitable habitat is
present in the special permit
project areas (maintained pipeline
ROW).
Red-Cockaded
Woodpecker
(Picoides borealis)
E E Mature 80-120-year-old longleaf or
loblolly pine forest.
No effect / No mature 80 to120-
year-old longleaf or loblolly pine
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 13 of 79

<<<PAGE 14>>>

TABLE 3
Federally and State Listed Threatened and Endangered Species Potentially
Species Occurring within the Special Permit Segment Areas in Brevard County, Florida
Habitat Description Federal
Status
State
Status Determination of Effect /
Rationale
forest present in the special
permit project areas (maintained
pipeline ROW).
Wood Stork
(Mycteria
Americana)
T T Inhabits emergent wetland, mixed
hardwood swamps, sloughs,
mangroves, and cypress domes.
Nesting trees range from low shrubs to
cypress.
No effect / No preferred suitable
nesting habitat present in the
special permit project areas
(maintained pipeline ROW).
Reptiles
Eastern Indigo
Snake
(Drymarchon
couperi)
T T Gopher tortoise
(Gopherus
Polyphemus)
C T Species prefers xeric longleaf pine
sandhills with gopher tortoise burrows
and requires very large tracts of land.
Commensal species with gopher
tortoise burrows. FGT will adhere to
USFWS Standard Protection Measures
for the Eastern Indigo Snake if
excavations are required in an area
containing burrows.
Inhabits well-drained soils types with
sparse tree canopy such as pine
flatwoods, longleaf pine /xeric oak,
and xeric oak scrub. Habitat includes
disturbed soils within utility and road
ROWs.
No effect / Although suitable
habitat is present within the
pipeline ROW (i.e., gopher
tortoise burrows),
the special permit will allow FGT
to avoid construction in the
pipeline ROW avoiding impacts
to this species.
Green Sea Turtle
(Chelonia mydas)
T T Found in shallow waters (except when
No effect / Although suitable
habitat is present within the
pipeline ROW, the special permit
will allow FGT to avoid
construction in the pipeline ROW
avoiding impacts to this species.
No effect / No coastal habitat is
present in the special permit
project areas
Hawksbill Sea
Turtle
(Eretmochelys
imbricate)
E E migrating) inside reefs, bays, and
inlets with an abundance of seagrass.
Beaches are required for nesting.
Primarily found in tropical coral reefs.
Nesting occurs on undisturbed deep-
sand beaches in the tropics.
No effect / No coastal habitat is
present in the special permit
project areas
Leatherback Sea
Turtle
(Dermochelys
coriacea)
E E Found primarily in the ocean. Requires
sandy nesting beaches backed with
vegetation for nesting.
No effect / No coastal habitat is
present in the special permit
project areas.
Loggerhead Sea
Turtle
(Caretta caretta)
T T Florida’s sandy Atlantic and Gulf of
Mexico beaches are preferred habitat
for nesting.
No effect / No coastal habitat is
present in the special permit
project areas (maintained pipeline
ROW).
Flowering Plants
Carter's Mustard
(Warea carteri)
E E Sandhill, scrubby flatwoods, inland
and coastal scrub.
No effect / Preferred suitable
habitat not present in special
permit project areas (maintained
pipeline ROW).
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 14 of 79

<<<PAGE 15>>>

TABLE 3
Federally and State Listed Threatened and Endangered Species Potentially
Species Occurring within the Special Permit Segment Areas in Brevard County, Florida
Habitat Description Federal
Status
State
Status Determination of Effect /
Rationale
Lewton's
Polygala
(Polygala
lewtonii)
E E Oak scrub, sandhill, and transition
zones between high pine and turkey
oak barrens.
No effect / Preferred suitable
habitat not present in special
permit project areas (maintained
pipeline ROW).
Source: USFWS, 2021a.
Notes:
E - Endangered T - Threatened C - Candidate Species
Conservative Land: The Florida Natural Areas Inventory (FNAI) maintains an inventory of the
state's conservation land holdings (FNAI, 2021). The special permit segment does not cross
conservation land holdings.
Climate Change: The scope and duration of any activities associated with the special permit
segment, including maintenance and repair activities will have minimal impact on climate change.
A benefit of the “Selected” Alternative is that it will avoid methane venting, construction, or
ground disturbances in the pipeline ROW. The “No Action” Alternative would not grant a special
permit, requiring the pipe replacement and/or hydrotesting would be required, which would
necessitate the use of heavy equipment during construction and blowing down the pipeline
releasing natural gas, a known greenhouse gas. Pipeline operators can and should mitigate
blowdowns through pressure reductions and capture and storage of natural gas during pipeline
work. However, PHMSA does not currently have authority to mandate these mitigation measures.
The “Selected” alternative will result in emissions that result from increased maintenance,
monitoring, and repair requirements for the duration of the special permit. These emissions
would be expected to be significantly less than the replacement associated with the “No Action”
alternative.
Cultural Resources: Neither the “No Action” nor the “Selected” alternative will have an effect
on cultural resources. Any inspection activities associated with the special permit segment and
special permit inspection area will be conducted within the boundaries of FGT’s existing
aboveground facilities (i.e., compressor stations) and maintained pipeline ROW. FGT was
granted a categorical exclusion blanket clearance certificate from the Florida Division of
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 15 of 79

<<<PAGE 16>>>

Historical Resources for activities to be undertaken within its existing, previously disturbed
ROW to ensure compliance with the National Historic Preservation Act of 1966, as amended
(NHPA). The Florida State Historic Preservation Office (SHPO) concurred with its categorical
exclusion for work within existing ROW and stated that “no known historic properties will be
affected by this undertaking.”
Environmental Justice: The special permit alternative associated with this special permit will
not have an adverse impact on the population along the pipeline including local, minority, low
income, or limited English proficiency populations as shown below in Table 4 - Demographic
Information for Special Permit Segment – Using EPA EJScreen.
The special permit is intended to maintain or increase safety with the implementation of safety
conditions in the special permit segment. Many special permit conditions also apply to the
special permit inspection area and will not have a disparate impact on any minority, low
income, or limited English proficiency populations. This special permit will also reduce climate
change impacts, which are understood to disproportionately affect low-income and minority
communities. Therefore, consistent with DOT Order 5610.2C (“Department of Transportation
Actions to Address Environmental Justice in Minority Populations and Low-Income
Populations”) and Executive Orders 12898 (“Federal Actions to Address Environmental Justice
in Minority Populations and Low-Income Populations”), 13985 (“Advancing Racial Equity and
Support for Underserved Communities Through the Federal Government”), 13990 (“Protecting
Public Health and the Environment and Restoring Science To Tackle the Climate Crisis”),
14008 (“Tackling the Climate Crisis at Home and Abroad”), 12898 and DOT Order 5610.2(a),
and Department of Transportation Actions to Address Environmental Justice in Minority
Populations and Low-Income Populations, PHMSA does not anticipate that the special permit
will result in disproportionately high and adverse effects on minority or low-income
populations.
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 16 of 79

<<<PAGE 17>>>

Table 4 - Demographic Information for Special Permit Segments – Using EPA EJScreen
Special
Total Population
Permit
Low Income
State County
Segment
No.
(Along Special
Permit Segment)
Minority*/ People of
Color** Population
Population
Linguistically
Isolated
182069 FL Brevard 2,313 21% 13% 0%
Minority*: The term minority is used in the currently active DOT Environmental Justice Order 5610.2(a),
available at:
https://www.fhwa.dot.gov/environment/environmental_justice/ej_at_dot/orders/order_56102a/index.cfm
People of Color**: The term people of color is used in the EPA’s Environmental Justice Screening and
mapping tool (EJSCREEN). An overview of demographic indicators through EJSCREEN is available at:
https://www.epa.gov/ejscreen/overview-demographic-indicators-ejscreen
Geology and Soils: The general characteristics of the special permit segment consists of
relatively flat terrain. The project area is located in the Atlantic Plain physiographic region of
the U.S. Major Land Resource Areas (MLRAs) are geographically associated land resource
units, usually encompassing several thousand acres, characterized by a particular pattern of
soils, geology, climate, water resources, and land uses. The special permit segment crosses the
Southern Florida Flatwoods MLRA and the special permit inspection area crosses the Southern
Florida Flatwoods and Southern Florida Lowlands MLRAs (USDA NRCS, 2021a). The soils
within the Southern Florida Flatwoods and Southern Florida Lowlands MLRAs are deep or very
deep, poorly drained or very poorly drained, and loamy or sandy (USDA NRCS, 2021b).
The objective of the special permit is to avoid construction or ground disturbances in the
pipeline ROW that will be necessitated if the special permit was not granted. Therefore, the
“Selected” Alternative will not result in soils impacts to the affected special permit segment or
special permit inspection area. Furthermore, no changes to geologic conditions would occur.
Denial of the special permit request will require the replacement and/or pressure testing of the
pipeline segments associated with this special permit request. Pipe replacement would require
vegetation clearing, removal of the existing pipe, and installation of a new pipe. The removal of
the vegetative cover and ground disturbance exposes soils to the effects of wind and water
which increases the potential for soil erosion and the transport of sediment to sensitive resource
areas. Furthermore, pressure testing would also expose the soil to water which increases the
potential for soil erosion and transport of sediment to sensitive areas along the pipeline ROW.
PHMSA-2021-0118 – Florida Gas Transmission Company, LLC Environmental Assessment and Finding of No Significant Impact - Florida
Page 17 of 79

<<<PAGE 18>>>

Mineral Resources: Florida’s mineral commodities include limestone, sand, gravel, clay, heavy
minerals, phosphate, and peat. The special permit segment is located along FGT’s e
- **truncated:** true
- **body characters:** 177123
