May 29, 2020

Plaquemines Parish Government
Plaquemines Parish Permit Department
Buras Levee District
102 Avenue G, Suite C
Belle Chase, LA 70037
Attention: Ms. Valarie Ragas

PERMIT REQUEST
FORM OF NO OBJECTION
This Letter of No Objection is not a regulatory permit and does not authorize the implementation of any project without
documented approval from all appropriate regulatory authorities.
Permit Applicant:

Venture Global LNG

10-01-2019
Date of Request:
N/A
Agent:
Applicant's Request: Approval to construct the Plaquemines LNG Liquefaction and Export Project along the
Mississippi River which will consist of the following: two temporary berths, one temporary material offloading facility
(MOF), one conveyor and hopper pad crossing the levee, three temporary levee ramps, three permanent berths, and
one permanent pipeway/accessway crossing the levee. This will also include a pipe bridge crossing the existing NonFederal Back Levee and adjacent canal for the Gator Express Pipeline. The pipe bridge will support two, 42-inch
diameter natural gas pipelines which will connect to a proposed export terminal. The closest structure will be
approximately 15-feet from the Mississippi River Levee.
Received 7/31/2019 via CD
Project Location: All work will take place on the protected side and floodside of the right-descending Mississippi
River Levee and on the protected side and floodside of the New Orleans to Venice - Woodpark to Pt. Celeste Levee,
Plaquemines Parish, Louisiana.
Project Coordinates:............................................. 29° 35'

30.810" , -89° 54'

06.830"

The above referenced request has been examined by Coastal Protection and Restoration Authority, and no
objection is proffered for this request, provided:

1.

The work is accomplished in accordance with the 408 Drawing Set developed by Matrix PDM Engineering.

2.

The soil improvement will consist of in-situ soil mixing and will not require excavations. If excavation is
required for the soil improvement, an approved stability analysis of the levee with considerations for the
excavations is required.

3.

Levee fill, defined as any material placed within the theoretical levee section or within 15-feet of the levee
toes, must meet the following criteria. Fill must have an organic content of no greater than 9%, as determined
by ASTM D2974, Method C. The plasticity index of the new fill must be 10 or more by Atterberg Limits by
ASTM D4318, and the material is classified as either a CH or CL by ASTM D2487, with less than 35% sand
retained on the No. 200 sieve by ASTM D1140. Levee fill material is to be added in 6-inch lifts and compacted
according to ASTM D698 (90% of maximum dry density).

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4.

That permanent structures are located no closer than 15-feet from the levee toe in accordance with Louisiana
Revised Statute 38:225.

5.

That permanent structures maintain a minimum clearance of 15-feet above any part of the levee at all times.

6.

An erosion prevention plan for the culverts placed beneath the levee ramps shall be furnished to CPRA,
USACE, and the levee district.

7.

This Letter of No Objection is only for stated work within or in the vicinity of the Levee District right-of-way,
and must be accomplished in accordance with the details set forth in the applicant's request and the
conditions contained herein. Any changes to the limits or scope of the proposed work must be submitted for
additional review. The Levee District must be contacted in writing prior to commencement and at the end of
activities. The applicant is responsible for obtaining and providing copies of any permits or lease agreements
necessary from the U.S. Army Corps of Engineers, the U.S. Coast Guard, the Louisiana State Land Office,
the Louisiana Department of Transportation and Development, the Louisiana Department of Natural
Resources - Office of Coastal Management, the Louisiana Department of Wildlife and Fisheries, the Parish
Government and/or any other applicable agencies, as well as documented approval from the area
landowner(s) prior to the initiation of the work. The applicant is responsible for adhering to the provisions of
any existing permits. The proposed work must not restrict the Levee District's maintenance operations, or any
potential flood fight activities at the levee, nor shall it obstruct or impede drainage, or create areas of standing
water on the levee batture. The applicant must employ and maintain suitable erosion protection measures at
the project site to the satisfaction of the Levee District. The applicant or owner must immediately notify the
Levee District of any seepage or sand boils that occur during high water conditions. All materials associated
with the proposed work must be removed from the area upon completion of the project and the area must be
returned to its original state of existence or better. Any damage done to the levee, floodwall or other flood
control structure, revetment, or surrounding project area, resulting from the proposed work must be repaired
or replaced by the applicant. Should any change in the location of the existing levee, river, floodwall, drainage
canal, waterway, or generally prevailing conditions in the vicinity, or should any changes in the area be
required in the future, in the public interest, the applicant shall make such changes in the project as
necessary. Any required changes or repairs shall be at the applicant expense. This letter of no objection is
offered with no opinion or approval of the design or engineering feasibility of the work.
Failure to abide by the conditions and requirements set forth in this Letter of No Objection may constitute noncompliance with the State of Louisiana comprehensive master coastal protection plan and may subject the
levee district and/or the applicant/agent to any and all procedures and actions by CPRA or the CPRA Board
pursuant to La. R.S. 49:214.5.2(A)(6) and as may be necessary to ensure compliance with such
comprehensive master coastal protection plan.

8.

That all subsurface work is performed and backfilled prior to the Mississippi River attaining or exceeding +
11.0 feet NGVD, on the Carrollton Gage at New Orleans, unless the applicant receives documented approval
to the contrary from the U.S. Army Corps of Engineers-New Orleans District.

9.

That within thirty days of project completion, "as built" drawings certified by a professional engineer registered
in Louisiana shall be furnished to this office. The drawings must show the actual location and profile of the
features for the project in relation to the levee centerline. Certification by the professional engineer that the
installation does not exceed the limits shown on the approved plans must also be furnished.

10.

Operation and maintenance activities, levee access, and emergency coordination of the portions of this
project that affect flood control structures are subject to a perpetual maintenance agreement between the
applicant and the U. S. Army Corps of Engineers and/or the local levee district.

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11.

This Letter of No Objection (LNO) is conditioned upon the applicant/agent providing the following to CPRA,
USACE, and the levee district, before commencing any activity allowed under the LNO. Final work products
deemed necessary for granting of this Letter of No Objection associated with this project shall be stamped
(construction ready drawings, designs, reports, as-builts differing significantly from final plans, etc...) by each
professional engineer responsible for their relevant field of practice for the project. Failure to provide
information requested or failure to abide by the conditions and requirements contained herein shall constitute
grounds for rescinding this Letter of No Objection. In such an event, CPRA will provide notice to USACE and
the levee district that the LNO has been rescinded.

12.

That no equipment, vehicles, or materials of any kind are parked or stored on the levee or on its slopes
without prior approval from the levee district.

13.

That the penetration of any revetment by the driving of piles and/or pile clusters will be appropriately repaired
in accordance with U.S. Army Corps of Engineers Plan File No. H-18-45204.

14.

If no pile load tests are to be performed, piles shall be designed using a minimum Factor of Safety of 3 in
compression. If static pile load tests are to be performed, piles shall be designed using a minimum Factor of
Safety of 2 in compression. If dynamic pile load tests are to be performed, piles shall be designed using a
minimum Factor of Safety of 2.5 in compression. A minimum Factor of Safety of 3 in tension shall be used for
all cases. Pile load tests shall be performed as per ASTM Standards and all pile load test reports shall be
furnished to CPRA, USACE, and the levee district within thirty days of completion.

15.

That any existing piles that are to be removed are cut off beneath the mudline

16.

That the work is to be completed according to the recommendations provided in the geotechnical reports and
the supplemental reports prepared by Fugro Consultants, Inc on 16 January 2017, 13 April 2017, 29 October
2019, and 21 February 2020. If any change is made to these assumptions, it is the responsibility of the
applicant to submit this information to CPRA for further review.

17.

For levee crossings, an approved stability analysis is required for equipment which weighs more than a total
of 72,000 pounds. All necessary documentation shall be signed and sealed by a professional engineer
registered in Louisiana and furnished to CPRA, USACE, and the levee district.

18.

Open trenches parallel to the levee which are three feet deep and greater are limited to 50 feet of excavation
open at one time.

19.

All excavations must meet OSHA Standards

20.

That the applicant places no more than one foot of fill above the natural ground elevation, or degrades or
removes no more than one foot of fill below the natural ground elevation, specifically cited in the area
between the floodside levee toe/floodwall and the bank of the waterway.

21.

That excavated areas are backfilled as expeditiously as possible using clay material whose composition and
density equals or exceeds that of areas adjacent to, and along the perimeter of the excavation boundary, or
with native material.

22.

That the metal structure has a minimum of the equivalent of two coats of 8-mils coal tar epoxy. If a cathodic
protection system will be used then it must conform with current industry (e.g. NACE) standards. Operation
and maintenance of the system shall be the responsibility of the system owner.

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23.

That the work and/or installation pose no hazard to area navigation.

24.

That barges and marine vessels are moored in such a manner to accommodate rising/falling river stages, and
to prevent damage to the existing tree screen, levee, revetment, batture, or riverbank under all weather
conditions. Any damages must be repaired at the applicants expense and to the satisfaction of the U.S. Army
Corps of Engineers.

25.

That the applicant install and maintain any hazard markers and/or navigation aids that may be required by the
U. S. Department of Homeland Security, United States Coast Guard.

26.

That the ground surface is properly swaled or contoured to drain to subsurface drainage areas and away from
the flood control structure.

27.

That all earthwork fill is properly compacted, and the finished slopes fertilized and seeded, all to the
satisfaction of the levee district.

28.

That the applicant is responsible for maintaining the existing level of flood protection at all times to the
satisfaction of the levee district.

29.

That the work will not damage the floodwall, floodgate, or levee and must not obstruct the operation of these
structures.
Yours very truly,

18133/bw/tj/ar
cc:
Ignacio.Harrouch@La.Gov
U.S. Army Corps Of Engineers-Levees
Mr. Billy Wall

for Ignacio Harrouch, Operations Division Chief
Coastal Protection and Restoration Authority of Louisiana