UNITED STATES DEPARTMENT OF COMMERCE

National Oceanic and Atmospheric Administration

NATIONAL MARINE FISHERIES SERVICE
NORTHEAST REGION
55 Great Republic Drive
Gloucester, MA 01930-2276

JUN 25 2009
Kimberly D. Bose, Secretary
Federal Energy Regulatory Commission
888 First Street, NE, Room 1A
Washington, DC 20426

RE: Downeast LNG Project; Docket Numbers CP07-52-000, CP07-53-000, and

CP07-53-001; Comments on Draft Environmental Impact Statement; and Essential
Fish Habitat consultation

Dear Secretary Bose:

The National Oceanic and Atmospheric Administration's National Marine Fisheries

Service (NMFS) has reviewed the Draft Environmental Impact Statement (DEIS) and
essential fish habitat (EFH) assessment for the Downeast Liquefied Natural Gas (LNG)
Project in Robbinston, ME. The purpose of these comments is to outline information
needed within the Final Environmental Impact Statement (FEIS), highlight potential
concerns relative to threatened and endangered species, and to provide conservation
recommendations relative to the EFH consultation process.

Downeast LNG proposes to construct a 3,862-foot long, 37-foot wide pier with a single
berth on the south side of Mill Cove in the Town of Robbinston near the confluence of
Passamaquoddy Bay and the S1. Croix River. The pier would accommodate LNG vessels
with cargo capacities ranging from 70,000 to 165,000 cubic meters (m\ In addition, the
project includes onshore storage and vaporization facilities for up to 320,000 m 3 of LNG,
and a 29.8-mile long send-out pipeline that would transport natural gas to a connection
into the existing Maritimes and Northeast pipeline. As proposed, the send-out pipeline
would cross 22 surface waterbodies. Construction of the LNG terminal and pipeline is
scheduled to occur over a 35-month period. On April 27, 2006, NMFS provided scoping
comments on the Federal Energy Regulatory Commission (FERC) Notice of Intent for
the Downeast LNG project, and on April 12,2007, NMFS provided comments to FERC
staff on the Administrative DEIS.

The EFH provisions of the Magnuson-Stevens Fishery Conservation and Management

Act (MSA) require federal agencies to consult with NMFS on projects such as this that
may adversely affect EFH. This process is guided by the requirements of our EFH
regulation at 50 CFR 600.905, which mandates the preparation ofEFH assessments and
generally outlines each agency's obligations in this consultation procedure. At this time,
PERC is requesting that NMFS concur with FERC's determination of effect, or, if
appropriate, provide EFH conservation recommendations. While additional information
has been requested for the FEIS, NMFS believes that sufficient information has been
received in order to continue the required EFH consultation.
National Environmental Policy Act (NEPA) comments

Threatened and Endangered Species

Section 7 of the Endangered Species Act of 1973 (ESA), as amended, requires federal
agencies to consult with NMFS to ensure that "any action authorized, funded, or carried
out by such agency ... is not likely to jeopardize the continued existence of any
endangered species or threatened species or adversely modify or destroy [designated]
critical habitat ...." (See also 50 C.F.R. part 402). FERC has correctly identified the
following ESA-listed species under NMFS jurisdiction that are known to occur in the
vicinity of the proposed Downeast LNG terminal, send-out pipeline, or LNG carrier
transit route: leatherback (Dermochelys coriacea) sea turtles, North Atlantic right
(Eubalaena glacialis), humpback (Megaptera novaeangliae), fin (Balaenoptera
physalus), sei (Balaenoptera borealis), sperm (Physeter macrocephalus) and blue
(Balaenoptera musculus) whales, Atlantic salmon (Salmo salar), and shortnose sturgeon
(Acipenser brevirostrum). Due to the presence of listed species in the action area and the
potential for the proposed activities to affect these species, FERC has initiated section 7
consultation with NMFS for the proposed project. However, the section 7 consultation
process is separate from NEPA, and as such, NMFS will provide complete endangered
and threatened species comments under separate cover as part of the ESA consultation
process.

The DEIS correctly characterizes the various types of effects that may occur due to the
construction of the terminal, construction of the send-out pipeline, potential expansion of
the Maritimes and Northeast pipeline, and vessel traffic due to long-term operation of the
terminal. None of the above-listed endangered species is likely to occur at the LNG
terminal site, so there will be limited impacts from the construction of the terminal itself.
Similarly, operational impacts such as water withdrawal/discharge and accidental spills
and releases that occur at the terminal site will not have impacts on ESA-listed species.
Construction of the send-out pipeline and expansion of the Maritimes and Northeast
Pipeline will occur in areas where Atlantic salmon are known to occur; however, any
impacts on Atlantic salmon due to construction of these facilities will be addressed
through consultation with FWS, as they have ESA lead for these activities within
freshwater habitat in Maine. Shortnose sturgeon are known to occur in areas where they
may be affected by potential expansion of the Maritimes and Northeast pipeline if such
an expansion were to occur. Although an application for such an expansion is not yet
before FERC for consideration, complete section 7 consultation for these activities will
be required with NMFS if an application is submitted.

ESA-listed whales and sea turtles may be encountered along the LNG carrier route to and
from the proposed Downeast terminal. Therefore, the greatest potential for the proposed
terminal to impact listed species is due to LNG carrier transits. FERC has identified the
following potential effects to listed sea turtles and whales due to LNG carrier transits to
and from the proposed Downeast LNG terminal:

• Vessel collisions
• Acoustic disturbance and harassment
• LN G/Fuel spills

Of these potential impacts, FERC has identified vessel collision as the primary risk to
ESA-listed species. NMFS agrees with this assessment. The applicant has proposed a
number of mitigation measures to reduce the risk of an LNG tanker en route to the
Downeast LNG terminal interacting with listed whales or sea turtles. Of the measures
proposed on p. 4-187 of the DEIS, NMFS believes that avoiding the Canadian designated
Grand Manan Basin Whale Sanctuary and reducing speeds to 10 knots or less while
transiting right whale habitat are the most effective at reducing ship strike risk to right
whales and other ESA-listed whales. FERC states on p. 4-186 that all LNG vessels
transiting to the terminal would be required to comply with NMFS-regulated practices to
protect right whales; however, regulations are not currently in place in the vicinity of the
LNG carrier route in the Bay of Fundy and near Grand Manan Island and Head Harbour
Passage. NMFS suggests that Downeast LNG further develop the vessel strike avoidance
plan in consultation with NMFS to outline when and where vessel speed restrictions will
be implemented. In addition, further information about the LNG carrier routes prior to
the approach to Grand Manan Island would help identify additional areas where
mitigation measures may be necessary. For example, there are two Areas To Be Avoided
(ATBA) that have been designated by the International Maritime Organization (IMO) in
order to protect right whales - one in Roseway Basin and one in the Great South Channel
- as well as a voluntary Dynamic Management Area (DMA) program in place throughout
the northeast US. If tankers will transit these areas en route to the terminal, compliance
with these voluntary measures would further reduce the risk of a Downeast LNG project
vessel striking a right whale.

NMFS looks forward to working with FERC and Downeast to continue evaluating the
effects of the proposed project on listed species through the section 7 consultation
process.

Marine Mammal Protection Act Comments

FERC has indicated that several species of marine mammals not listed under the ESA are
also known to be present in the vicinity of the proposed Downeast LNG terminal and
LNG carrier route. These include several species of whales, porpoises, dolphins, and
pinnipeds, with the harbor seal (Phoca vitulina), gray seal (Halichoerus grypus), harbor
porpoise (Phocoena phocoena), Atlantic white-sided dolphin (Lagenorhynchus acutus),
and minke whale (Balaenoptera acutorostrata) being the most abundant. All marine
mammals are protected under the Marine Mammal Protection Act of 1972 (MMPA). The
DEIS indicates that underwater noise generated during construction activities, especially
pile-driving, may generate noise levels that could result in harassment of marine
mammals present in the area. Other impacts related to construction and operation of the
terminal such as increased turbidity, water withdrawal and discharge, and accidental fuel
releases and spills may impact marine mammals or their prey. If it is determined that this
project has the potential to take marine mammals through injury, harassment, or

mortality, then the applicants are responsible for obtaining an incidental take permit from
the NMFS Office of Protected Resources.

Fishery Resources and Habitats

As described in the DEIS, the proposed project location serves as habitat for a broad
range of federally-managed species. While NMFS initially indicated in our scoping
comments that particular attention should be focused on winter flounder
(Pseudopleuronectes americanus) and Atlantic salmon (Salrno salar), the 12-month
ichthyoplankton monitoring program performed by Downeast LNG highlights the variety
offish species utilizing the area. Federally-managed finfish species that have been
identified as occurring in the area include winter flounder, witch flounder
(Glyptocephalus cynoglossus), windowpane flounder (Scophthalmus aquosus), Atlantic
cod (Gadus morhua), Atlantic herring (Clupea harengus), and pollock (Pollachius
virens).

Atlantic salmon utilize Passamaquoddy Bay, as well as the St Croix, Dennys, and
Pennamaquan Rivers as a migratory corridor, all of which have been designated as EFH
for Atlantic salmon. In addition, the St Croix and Dennys River are also designated a
Habitat Area of Particular Concern (HAPC) for Atlantic salmon. The DEIS states that
there are no suitable habitat conditions for any lifestage of Atlantic salmon in the stream
reaches crossed by the proposed send-out pipeline. Section 5.2.2.2 of Appendix C
describes the stream habitat evaluations performed at each stream crossing by the
applicant between July and September of 2006. Although the DEIS indicates that the
sampling protocols for these surveys were developed in coordination with the Maine
Atlantic Salmon Commission (ASC) and Maine Department of Inland Fisheries and
Wildlife (DIFW), there is no explanation and discussion of these protocols. In addition,
this section indicates that the summary of habitat conditions observed at each sampling
location is provided in Attachment D. However, NMFS has not been able to locate this
information in the DEIS.

The summary of observations that are provided in this section describe some of these
stream crossings as low gradient riffles with substrates dominated by cobble and gravel,
and temperatures ranging from 19.6-21.6° C. In addition, section 4.5.2.3 of the OBIS
indicates that these surveys confirmed that fi ve of the stream crossings would be at riffle
and pool complexes which meet the ACOE's criteria for a special aquatic site. NMFS
maintains that, according to EFH designation descriptions for Atlantic salmon in the EFH
Omnibus Amendment (NEFMC 1998), such conditions support the presence of Atlantic
salmon. This designation states that Atlantic salmon EFH includes all aquatic habitats in
the watersheds of the identified rivers and their tributaries (including the Passamaquoddy
Bay, the St Croix, Dennys, and Pennamaquan Rivers), to the extent that they are currently
or were historically accessible for salmon migration. Specifically, the following
conditions exist where returning Atlantic salmon adults are found migrating to the
spawning grounds: water temperatures below 22.8° C, and dissolved oxygen above 5
ppm. Generally, the following conditions exist where Atlantic salmon parr are found:
clean, well-oxygenated fresh water, water temperatures below 25° C, water depths
between 10 cm and 61 cm, and water velocities between 30 and 92 cm per second, and

bottom habitats of shallow gravel/cobble riffles (NEFMC 1998). Both the Maine
Department of Marine Resources (MEDMR) (February 1,2008, Section 4.5.2.3) and
ASC (Feb 21, 2007) have provided comments regarding the presence of salmon in the St.
Croix River, the Magurrewock Stream, and the Wapsaconhagen Brook, further
substantiating the presence of suitable salmon habitat in these stream reaches. The FEIS
should provide more detailed information regarding how these conclusions were made,
and what conditions or parameters have eliminated the stream reaches that are crossed by
the pipeline from consideration as possible salmon habitat, and specifically as EFH for
Atlantic salmon.

As noted in our April 27, 2006 scoping letter, particular attention should be focused on
possible adverse impacts on winter flounder habitat as a result of this project. Adult
winter flounder utilize this area for spawning and feeding, while eggs, larvae, and
juveniles use the area for development during these early life stages. Section 4.5.2.2
indicates that winter flounder were observed in subtidal areas near the proposed pier
during site surveys conducted in 2006. However, neither the DEIS or the EFH
assessment specifically discusses the adverse impacts this project may have on winter
flounder habitat in the project area. The FEIS should provide detailed analysis of
possible impacts on winter flounder habitat from the pier construction and operations, as
well as the water intakes and discharges related to vessel operations, fire suppression
systems, and hydrostatic testing of the LNG tanks.

Impacts resulting from suspended sediments

Section 2.3.1.2 of the DEIS discusses the construction of the pier facility within Mill
Cove. Large diameter steel pipe piles will be utilized to support the trestle and loading
platform. These piles would be vibrated and driven through any surficial soils on the
seabed to the top of the underlying rock where they would be seated into competent
bedrock. The level of suspended sediments resulting from this process is described in the
DEIS as being temporary and minor. However, specific information regarding the
anticipated levels of suspended sediments has not been presented. The DEIS specifically
notes that "the use of construction timing windows to avoid sensitive periods such as
spawning, migration, and peak fishery activity is a viable mitigation method. Timing
may also include avoiding equipment relocation activity during specific periods of the
diurnal tide to avoid excessive disturbance to the bottom and reduce sediment
resuspension by construction vessels." FERC has recommended in the DEIS that
Downeast continue to consult with the appropriate agencies (specifically NMFS and
MEDMR) prior to the end of the DEIS comment period to determine any recommended
seasonal or construction timing restrictions to minimize impacts on marine species during
all proposed in-water work. Furthermore, Downeast is required to file, prior to the end of
the DEIS comment period, with the Secretary copies of correspondence with consulted
agencies and proposed mitigation measures. To date, this consultation with NMFS has
not occurred.

Furthermore, NMFS remains concerned with the potential for suspended sediments
resulting from LNG vessel passage. As noted in the DEIS, the depth at the proposed
marine berth would be approximately 45-50 feet at mean low water, and typical LNG

vessels draw -40 to -41 feet. The FEIS should address the potential for the acute and
chronic resuspension of sediments resulting from the presence and operation of the LNG
vessel.

Acoustic impacts
Section 4.5.2.2 of the DEIS notes that noise generated from construction activities such
as operation of equipment and pile driving could adversely affect fish, marine mammals,
and turtles. While the DEIS discusses the range of potential impacts resulting from the
proposed project, FERC has recommended that Downeast continue to consult with the
appropriate agencies prior to the end of the DEIS comment period to determine
appropriate mitigation strategies to minimize acoustic impacts on marine species.
Furthermore, Downeast is required to file, prior to the end of the DEIS comment period,
with the Secretary copies of correspondence with consulted agencies and proposed
mitigation measures. To date, this consultation with NMFS has not occurred.

Entrainment offishery resources

With regard to water usage for engine cooling, ballast, fire suppression testing, and
hydrostatic testing, NMFS is concerned with entrainment of fish eggs and larvae of a
variety of federally-managed species and prey species identified in the ichthyoplankton
survey. The DEIS indicates there will be a substantial seawater usage of up to 78.5
million gallons per unloading event. In addition, these estimates represent times when
the vessel is at port, and do not include water usage occurring during approach and
docking. Appendix 0 of the DEIS estimates the number of eggs and larvae entrained
within the vessel for a range of species, as well as "equivalent adults." Such impact
estimates include 517,000 eggs and larvae per year and adult equivalents ranging from 5
to 467 individual fish. However, the EFH assessment describes the total egg and larval
loss as 81,000 per visit, with Downeast proposing up to 60 visits per year, for an annual
total of 8,480,000 eggs and larvae. The estimated egg and larval losses should be
clarified within the FEIS.

While the document utilizes the equivalent adult assessment method, NMFS maintains
that this method focuses solely on finfish survival to maturity, and does not account for
ecosystem and food web benefits derived from the egg and larvae of these species as a
source of prey for other species. In order to fully account for adverse impacts resulting
from the facility, NMFS recommends the assessment include an analysis of ecosystem
and food web benefits foregone as a result of operational impacts on eggs and larvae.

Notwithstanding this issue, NMFS previously recommended that FERC include in the
FEIS additional methods of avoiding or minimizing egg and larval entrainment. While
alternative water recirculation systems have been considered, the DEIS does not discuss
the intake velocities on the LNG vessel relative to the above referenced entrainment data
and water usage. The FEIS should consider the potential for modifications to reduce the
intake velocities as much as possible in order to minimize adverse impacts on fishery
resources. In light of the Environmental Protection Agency's National Pollutant
Discharge Elimination System (NPDES) 316(b) guidance standard of 0.5 fps for

protection of fishery resources, a lower intake velocity would result in reduced

entrainment impacts on ichthyoplankton resources.

Discharge of thermal effluent

As noted in the EFH assessment, water withdrawn from Passamaquoddy Bay for engine
cooling would be returned to the bay at elevated temperatures. However, estimates of
temperatures and impact area are inconsistent within the EFH assessment. For example,
page 10-18 of the EFH assessment states that thermal impacts would be minor and
insignificant due to an increase of 1° C or less over a maximum of a 26-square-meter
area. However, page 2-11 of the EFH assessment states that there will be an increase in
water temperatures of 5-1 0° F, and reach ambient conditions at approximately 15-30
meters from the point of discharge. Table 10.3.2-3 notes temperature ranges for EFH
species within Passamaquoddy Bay. Of the 14 federally-managed species listed, 12
species have life stages with temperature ranges less than 10° C. NMFS is concerned that
thermal discharge increases may adversely impact habitat of federally managed species.
Specific thermal increases and plumes for this facility should be clarified within the
FEIS.

Impacts related to pipeline construction

The proposed LNG send-out pipeline would consist of approximately 29.8 miles of 30­
inch diameter pipe that would likely interconnect with the exiting interstate natural gas
transmission system of Maritimes and Northeast pipeline. The Oowneast LNG pipeline
will employ the hydraulic directional drilling (HOD) method at nine of the waterbodies
crossed by the send-out pipeline, including vernal pools, streams where riffle and pool
complexes have been observed, and the crossings at the St. Croix River and the
Magurrewock Stream. Section 4.3.2.3 of the OBIS indicates that Oowneast has
developed appropriate measures in the event of a "frac-out" incident. However, FERC
has recommended in the 0 BIS that Oowneast should consult with state and federal
resource agencies to develop site specific HOD plans for each proposed HOD crossing,
as well as a contingency plan for crossing the feature in the event that HOD is
unsuccessful. At this time, NMFS has not been consulted regarding site-specific HOD
plans.

Cum ulative Impacts

The Maritimes and Northeast pipeline expansion is discussed in the OBIS only for
purposes of disclosure, and is not a part of the proposed Oowneast LNG project.
However, this pipeline expansion has the greatest potential for cumulative impacts if
additional pipeline loops are required for each of the LNG projects being developed in
the vicinity, and described in Table 4.13-1 (Section 4.13.3). Therefore, NMFS feels that
particular attention should be paid in the development of this expansion project to ensure
that the pipeline requirements of other LNG projects in the area are accounted for, and
the environmental impacts associated with the expansion projects will not be additive.

NMFS encourages the consideration of a shared or co-located send-out pipeline route for
the various LNG projects proposed in the vicinity and described in Section 3.8.2. This
alternative would require only one right-of-way, and would greatly reduce associated

environmental impacts. Since the potential benefits of a co-located pipeline would only
be realized through synchronization of pipeline construction schedules (Section 3.8.2),
NMFS maintains that present and future LNG projects in the area should include this
information in their analysis. The FEIS should provide a pipeline construction schedule
that also addresses attempts to synchronize pipeline construction schedules and co-locate
the send-out pipeline with other LNG projects.

Compensatory mitigation
Although Oowneast LNG proposes to compensate for direct impacts on 9.0 acres of
inland wetlands by establishing conservation easements (Section 4.4.1.2), there is no
similar compensatory mitigation proposed for marine resources. NMFS recommends that
the applicant analyze the anticipated effects to, and anticipated recovery times of, marine
fishery resources and habitats as a result of the proposed project, and propose
compensatory mitigation for impacts that cannot be avoided. The compensatory
mitigation plan should include temporal losses of living marine resources as a result of
the proposed project. The development of the compensatory mitigation plan should be
coordinated with federal and state resource agencies.

Biological Monitoring
Operational monitoring should assess whether impacts on ichthyoplankton and
zooplankton resources resulting from the proposed seawater intakes are consistent with
those anticipated in the OEIS. The monitoring plan should be linked to a plan for
adaptive management of the LNG facility to allow for operational or mechanical
modifications to prevent or minimize adverse impacts on the marine environment. The
development of the biological monitoring plan should be coordinated with federal and
state resource agencies, and included within the FEIS

Magnuson-Stevens Fishery Conservation and Management Act Essential Fish

Habitat Conservation Recommendations

As noted in the EFH assessment included in the OEIS, this portion of Passamaquoddy
Bay has been designated as EFH under the MSA for 33 federally-managed species,
including, but not limited to, winter flounder (Pseudopleuronectes americanus), witch
flounder (Glyptocephalus cynoglossus), windowpane flounder (Scophthalmus aquosus),
Atlantic cod (Gadus morhua), Atlantic herring (Clupea harengus), and pollock
(Pollachius virens). The proposed project would adversely affect EFH due to
construction and operational activities, as described above. While additional information
has been requested for the FEIS, NMFS believes that sufficient information has been
received in order to continue the required EFH consultation. In order to sequentially
avoid, minimize, and mitigate for adverse effects to EFH, NMFS recommends pursuant
to Section 305(b)(4)(A) of the MSA that FERC adopt the following EFH conservation
recommendations:

1) In order to protect fishery resources and habitats, seasonal work restrictions

should be required for all in-water construction activities. These seasonal

 restrictions should be coordinated with federal and state resource agencies as

described within the DEIS.

2) In order to minimize adverse effects to egg and larval resources resulting from
the operation of the LNG vessel and terminal, intake velocities should be limited
to a maximum of 0.5 fps at the intake point.

3) As recommended by FERC, the applicant should consult with state and federal
resource agencies to develop site specific HDD plans for each proposed HDD
crossing, as well as a contingency plan for crossing the feature in the event that
HDD is unsuccessful.

4) A biological monitoring plan should be developed and presented within the FEIS.
The biological monitoring plan should specifically address entrainment of
ichthyoplankton and zooplankton resources resulting from operation of the
facility, and be linked to a plan for adaptive management. The applicant should
work in consultation with NMFS in developing the biological monitoring plan.

5) Compensatory mitigation should be required to offset temporary and permanent

losses to benthic resources and habitats as a result of pipeline and terminal
construction and operation. The compensatory mitigation plan should include
temporal losses of living marine resources and habitats as a result of the proposed
project. This plan to offset losses to NMFS trust resources should be presented
within the FEIS. The applicant should work in consultation with NMFS in
developing the compensatory mitigation plan.

Please note that Section 305(b)(4)(8) of the MSA requires FERC to provide NMFS with
a detailed written response to these EFH conservation recommendations, including a
description of measures adopted by FERC for avoiding, mitigating, or offsetting the
impact of the project on EFH. In the case of a response that is inconsistent with NMFS'
recommendations, Section 305(b)(4)(8) of the MSA also indicates that the federal agency
must explain its reasons for not following the recommendations. Should the federal
agency's decision be inconsistent with NMFS' EFH conservation recommendations,
pursuant to 50 CFR 600.920(k), scientific justification should be provided.

Please also note that these EFH conservation recommendations are based on the
information contained within FERC's DEIS. Upon publication of the FEIS, a distinct
and further EFH consultation must be reinitiated pursuant to 50 CFR 600.920(1) ifnew
information becomes available, or the project is revised in such a manner that affects the
basis for the above EFH conservation recommendations.

Fish and Wildlife Coordination Act recommendations

In addition to the EFH provisions of the MSA, the Fish and Wildlife Coordination Act
(FWCA) requires federal agencies to consult with federal and state natural resource
agencies regarding activities or licensing that impact fish and wildlife resources. In order
to sequentially avoid, minimize, and mitigate for adverse effects to fishery resources and

habitats resulting from the construction and operation of the proposed LNG facility and
pipeline, NMFS maintains that FERC adopt the above referenced recommendations.

Conclusions
In summary, NMFS maintains that the construction and operation of the proposed LNG
terminal and pipeline will result in adverse effects to fishery resources and habitats. In
order to fully assess impacts resulting from the proposed project, additional information
and clarification should be presented within the FEIS. NMFS recommends that seasonal
work restrictions be developed in consultation with federal and state resource agencies,
that a 0.5 fps intake velocity to reduce egg and larval entrainment be adopted for LNG
operations, and that site specific HDD plans be developed. In addition, we recommend
that a biological monitoring plan be presented within the FEIS. Finally, NMFS
recommends that compensatory mitigation be provided to offset temporary and
permanent impacts on fishery resources and habitats. If you have further questions
regarding these comments, please contact Christopher Boelke at 978-281-9131. For
questions regarding threatened and endangered species or the ESA Section 7 consultation
process, please contact Kristen Koyama at 978-281-9328 ext. 6531

Sincerely,

I
~Ok
Peter D. Colosi
Assistant Regional Administrator
for Habitat Conservation

cc:

Jay Clement, ACOE

Frank Delgiudice, ACOE
Elizabeth Higgins, US EPA
Tim Timmerman, US EPA
Wende Mahaney, USFWS
Thomas Chapman, US FWS
Shannon Jones, FERC
Brian Swan, ME DMR
Tom Bigford, OHC

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