What We Learned from the FERC 201 Workshops
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A brief presentation about insights, strategies, and next steps from the FERC 201 workshop series sponsored by the INGAA Foundation and facilitated by POWER Engineers. These ongoing workshops have promoted meaningful, productive, and interactive dialogue among owners/operators, agencies, and service providers in the interstate natural gas transmission industry.
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What We Learned from the FERC 201 Workshops
- 1. What We from the FERC 201 Workshops Insights, Strategies, & Next Steps by Stacey Atella Learned
- 2. WHAT ARE THE FERC 201 WORKSHOPS?
- 3. • Need for more in-depth discussion and dialogue between – Industry and Federal Agencies – FERC and Federal Agencies – Construction Contractors and Industry • Sponsored by INGAA Foundation and the EHS Committee Construction Task Force History
- 4. • Objectives – Establish a neutral forum • Examine emerging or reoccurring challenges • Exchange information and ideas • Promote shared learning in an open and collaborative environment – Promote meaningful, productive, and interactive dialogue – Focus on solutions • Desired outcomes – Increase understanding – Identify next steps, action items, and follow-up discussions Workshop Series Overview
- 5. FERC Pre-Filing and Environmental Reporting November 2014 2014–2016 Workshop Series Working with Other Federal Agencies March 2015 Construction Challenges July 2015 Post-Construction and Minor Projects May 2016 Permit Synchronization and Process Improvements August 2016 1 2 3 4 5
- 11. Slower agency response times Permitting- related construction challenges Not enough time or money to plan, but always enough to “fix” problems Trends
- 12. Challenges to Blanket Certificate projects Requests for more robust analyses and greater level of data/details Increased number of detailed questions and requests from commenters Trends
- 13. Want to know the message being communicated to the public ahead of time Don’t have time or resources to respond to no permit/no effect requests Need verification that applicant is authorized to consult General Agency Insights
- 14. Only provide information relevant to the authorization A single NEPA document must meet other agencies’ NEPA requirements Conduct engineering design earlier in the planning process General Agency Insights
- 15. FERC Insights Pre-Filing process is preferred “Pre” Pre-Filing outreach is beneficial Pre-Filing should take at least 7–9 months
- 16. Early agency outreach supported Notify FERC to avoid surprises Burden of proof for route selection falls on Company not commenter Outreach must be Consistent Documented Throughout the life of the project FERC Insights
- 17. Want to be engaged early USACE Insights 100% survey coverage not needed for complete application May request additional items beyond what FERC requests Cannot issue a conditional approval
- 18. Determine if Mineral Leasing Act requirements apply Need robust explanation for rejected alternatives Developing a new pre- application process BLM Insights
- 19. Avoid routing a project where an RMP amendment is needed Needed before project review can begin ROW application POD Cost recovery Consult prior to conducting field surveys BLM Insights
- 20. Issued ESA Compensatory Mitigation Policy Adding migratory bird conservation measures to IPaC USFWS Insights
- 21. MBTA philosophies differ by region Eastern U.S. focuses on mitigation Western U.S. focuses on protection of birds Engage the correct technical resource leads Field office for ESA consultations Regional office for MBTA coordination USFWS Insights
- 22. NRCS Insights Nationwide shapefiles for NRCS easements available Different levels of mitigation for WRP land impacts Penalty for landowner breaking WRP agreement Wetland impacts
- 23. Identify adequate workspace during planning and permitting Develop a well thought out access road plan Collocation may result in greater environmental disturbance Contractor Insights
- 24. Continue educating and engaging public and agencies Consider providing agencies with links to draft RRs as they are filed with FERC Seek to understand agencies’ concerns Work with agencies to effectively communicate expectations Improvement Strategies
- 25. Create agency “cheat sheets” identifying major concerns, requirements, and timeframes Ensure the right people are receiving submittals Provide clear differentiation when multiple projects occur simultaneously or in same geography Improvement Strategies Provide training opportunities Consider augmenting agency staff
- 26. Improvement Strategies Include a signature line on consultation letters • No effect • No historic properties affected Ensure permits and MOUs cover all phases and aspects of project • Easements • Maintenance • Access roads Use USFWS IPaC Tool for “no effect” determinations Maintain good records and documentation • Surveyed areas • Previously disturbed/ construction work areas
- 27. In Summary Federal agencies are open to… Learning more Maintaining an open dialogue Discussing options for permit synchronization Participants acknowledge… There is much work to do Knowledge needs to be transferred to the state/field office level
- 28. WHAT’S NEXT?
- 29. Results of Workshops 1–4 27 Specific action items Narrowed down to 8 Aka, the “TOP 5”
- 30. Top 5 Action Items Pre-application information sheet and checklist identifying pre-application meeting requirements, major resource concerns, submittal requirements, and timeframes for each of the major federal permits/authorizations 1 Lead: Federal agencies
- 31. Top 5 Action Items Guidance document on using and submitting remote sensing wetland data to the USACE Pipeline Construction Training course for federal/state agencies 2 Lead: INGAA Foundation Lead: USACE 2
- 32. Top 5 Action Items FERC Environmental Review Process training courses for federal/state agencies Programmatic agreement for Section 7 ESA consultations 3 Lead: FERC and USFWS (+ industry) Lead: INGAA Foundation 3
- 33. Top 5 Action Items Agency training toolbox materials (e.g., pipeline construction 101 video, resource- specific construction topics) 4 Lead: INGAA Foundation
- 34. Top 5 Action Items Guidance document on FERC regulations pertaining to “Ex Parte Rules and Expectations for Federal Agencies” Federal Agency Environmental Review Process 101 trainings/WebEx for industry 5 Lead: INGAA Foundation Lead: FERC 5
- 35. Next Steps Build on established relationships and understanding achieved so far1 Workshop 5—Permit Synchronization Process Improvements, Part II2 Annual workshops thereafter3
- 36. WHY DO YOU CARE?
- 37. Opportunity to discuss permitting issues In greater detail Multi-agency audience Process improvement tools Guidance documents Authorization- Specific Information Sheets Ongoing dialogue with federal agencies Challenges Regulatory drivers Trends Lessons learned Benefits
- 38. Stacey Atella Stacey.Atella@powereng.com (303) 716-8932 www.powereng.com Want to know more? We’re happy to share a brown bag presentation at your office.