The opponents of a liquefied natural gas terminal proposed for Coos Bay’s North Spit have offered three reasons to overturn the project’s land-use application.

In a brief received by the Land Use Board of Appeals earlier this week, the opponents argued that not enough consideration was given to environmental concerns, preservation of Indian artifacts and the possibility a pipeline to transport natural gas from the terminal might not be built.

The application, approved by Coos County Commissioners on Dec. 5, 2007, was appealed Dec. 26 by the Southern Oregon Pipeline Information Project, a nonprofit advocacy group formed solely to oppose the Coos Bay LNG terminal and pipeline projects.

At the time, the appellant simply indicated it would appeal the application without giving specific reasons why. The rationale was delivered in a 22-page brief received by LUBA staff on Monday.

The issues were similar to those raised at a public hearing on the land use application in August.

But while speakers at the hearing often spoke expansively about the problems the terminal might cause to the environment, the brief dealt in technicalities.

The brief noted the terminal construction will include 50-foot setbacks from Henderson Marsh, a salt-water wetland west of the project site. The condition was insufficent, the appellant argues, because the county didn’t explain how such a setback would adequately protect the marsh.

It also argues a wetland exists in the northwest portion of the construction area that will be used as a temporary grubbing stockpile. The county suggested the map used by the appellant was inaccurate, and instead relied upon a map prepared by the project’s proponent, Jordan Cove Energy Project, and approved by the Department of State Lands. This second map suggested there are no wetlands in the northwest portion of the project site.

The brief also suggests the county needed to include conditions to ensure Indian artifacts located in the construction area would be properly handled. The county required Jordan Cove to coordinate with the Coquille Indian Tribe or the Confederated Tribes of Coos, Lower Umpqua and Siuslaw Indians before removing any material from the construction site.

The appellant argued the county should have required a site plan, including specific plans and architectural drawings, prior to approval of the land-use application.

Finally, the appellant said the county should have included a condition that construction of a pipeline must be approved before construction can begin on an LNG terminal.

Jordan Cove now has a 21 days to file a brief of its own, after which the board will hear orals arugments and then rule on the case.

Project Manager Bob Braddock said he had reviewed the appellant’s main arguments and, without consulting an attorney, felt confident the county’s decision would be upheld.