At SWCA, we know FERC. Our staff has worked on FERC projects and managed the environmental analysis for FERC-regulated natural gas pipeline and liquefied natural gas projects since the 1980s.
Our team has extensive knowledge of FERC filing requirements from individual Natural Gas Act Section 7(c) and 7(b) projects (traditional and pre-filing), to blanket certificate projects and auxiliary installations and replacements, and even projects regulated under Section 311 of the Natural Gas Policy Act. Regardless of the FERC authorization needed, SWCA has the intimate familiarity with the requirements necessary to get your project authorized.
Wondering what it takes to get your FERC project to the finish line? The information below presents some of the best practices that SWCA and its staff have learned over the last three decades:
- Communicate with FERC Project Manager: It’s a good idea to keep the FERC PM “in the loop” on project issues and proposed solutions, especially when using the FERC Pre-filing Process.
- Consult Regulations and Guidance Documents (every time)
- When determining what authority you need to construct/operate your project
- When determining filing requirements
- When determining best format for presentation of information
- When determining notification requirements
- Address all Filing Requirements
- Don't rely solely on “minimum” filing requirements. Address all filing requirements for a thorough and complete environmental report (ER).
- If there are filing requirements that do not apply to your project, provide an explanation in your environmental report.
- If there are requirements that have not yet been addressed, provide a reason and a schedule for addressing and filing information with FERC.
- Address all Notification Requirements
- Track Issues: As issues are identified by you or any applicable agencies, add them to a tracking list and ensure that they are appropriately addressed in the FERC ER.
- Be Accurate and Consistent:
- Project dimensions
- Construction and operational land requirements
- Quantified impacts on environmental resources
- Perform checks to ensure that the information among the various resource reports and environmental permit applications is consistent.
- Constructability Review: Make sure that the project is constructible as proposed. It is much more straightforward to ensure constructability early in the process, rather than relying on the variance process.
- Practice Diligence with all Permitting Requirements and Agency Clearances
- Make checklists of agency permitting requirements and make sure they are addressed.
- Include permitting information in FERC ER, as appropriate
- Develop and Preserve Relationships
- It’s helpful to ensure an understanding of the requirements of the many agencies involved in a complex FERC-regulated project.
- Your reputation with agencies and other stakeholders is critical.
- Provide Complete and Accurate Responses to Data Requests
- Applies to requests issued by FERC and other permitting agencies
- Complete and accurate responses allow the agencies to proceed with their required environmental reviews.
- Avoid, Minimize, and Mitigate: This is a tried-and-true method of ensuring that projects are permitted and constructed in the most environmentally responsible manner.
- Maintain Thorough and Accurate Documentation
- Identified issues and resolutions
- Agency communications
- Communications with other affected stakeholders
- Cumulative Impacts: Finally, it’s important to identify other projects and activities in and near the areas of project impacts and the potential for cumulative additive impacts on sensitive environmental resources.
For more information about our FERC services, CONTACT US.