Cheniere LNG O&M Services, LLC

Referring to Docket No. USCG-2009-0316: We request that the following excerpted existing proposed wording be replaced with our recommended wording, or wording of similar intent to our alternate proposed wording. Our recommended replacement wording follows immediately below the excerpt from the existing proposal, which is included here for reference: The relevant excerpt from USCG’s present EXISTING PROPOSAL: 33CFR Part 165 § 165.819 Security Zone; Sabine Bank Channel, Sabine Pass Channel and Sabine- Neches Waterway, TX. (a) Location. (1) The following areas are designated as fixed security zones: All waters within a 100-feet radius of LNG carriers moored at: (i) Golden Pass LNG facility located in Sabine, TX, in position 29?45'52??N 093?55'25??W; and/or (ii) Sabine Pass LNG facility located in Cheniere, LA, in position 29?44'31??N 093?52'18??W. --------- end of relevant excerpt ---------- Our recommendation is to change the above excerpted portion of the proposed wording to instead be written as follows (or similar to): § 165.819 Security Zone; Sabine Bank Channel, Sabine Pass Channel and Sabine- Neches Waterway, TX. (a) Location. (1) The following LNG facility berth basin areas are designated as fixed security zones whenever LNG carriers are moored within them, and no unauthorized vessels and/or persons shall approach within: (i) 100 feet to the north of a line, extending closest bank-to-closest bank, through the outermost mooring dolphins located at 29° 45’ 53.6” N / 093° 55’ 34.8” W and 29° 45’ 51.9” N / 093° 55’ 20.9” W marking the entrance to the berth basin area for the Golden Pass LNG facility located in Sabine, TX; and/or (ii) 100 feet to the southwest of a line, extending closest bank-to-closest bank, through the outermost mooring dolphins located at 29° 44’ 32.8”N / 093° 52’ 24.7”W and 29° 44’ 26.3”N / 093° 52’ 13.5”W marking the entrance to the berth basin area for the Sabine Pass LNG facility located in Cameron Parish, LA. --------- end of recommended substitute wording--------- Comments and reasons for our recommendation to change the USCG’s existing proposed wording are as follows: - The USCG’s existing proposed wording appears to allow any unauthorized vessels and/or persons (e.g. including divers or swimmers) to enter the berth basins of the two facilities while a LNG carrier is moored at a berth within such basin, so long as such vessels and/or persons remain outside of a 100 feet radius from the moored LNG carrier. This appears to allow such otherwise unauthorized vessels and/or persons to move freely around the confines of the remainder of the berth basin without overt restriction while authorized vessel movements may be concurrently occurring in support of the moored LNG carrier, such as vessels delivering stores aboard the LNG carrier and support tug movements within the basin. Such unauthorized presence(s) could materially interfere with the authorized supporting vessels’ operations as both potential security and safety risks. - A 100 feet minimum distance for unescorted-unauthorized vessels and/or persons to maintain from the LNGCs when inside a three-quarters enclosed basin, especially with berths existing on both sides of the basin, should be considered much too close to be considered as an effective security buffer. If the berthing facility was a parallel berth located adjacent to a navigable waterway, then perhaps a 100 feet minimum security zone might arguably be more acceptable –depending upon the circumstances. - The positions stated in our recommendation for the existing outer-most mooring dolphins for both Golden Pass LNG and Sabine Pass LNG facilities should be verified and corrected if necessary. The demarcation lines drawn through the outer-most mooring dolphins for the berth basin entrances should extend to the closest bank on each side of each berth basin entrance, which may mean that the line may take a short directional ‘jog’ between the mooring dolphin and the closest bank. - The Sabine Pass LNG facility is located in Cameron Parish, LA – not Cheniere, LA. - We have no comments regarding the remainder of the proposed rule / regulation, other than we are supportive of the USCG’s intent to clearly define the subject security practices. Thank you for considering our concerns.