With the advent of the National Environmental Policy Act of 1969 and Clean Water Act of 1972, environmental quality, protection and enhancement have been at the forefront of proposed pipeline activities for nearly a half century.
Considerable effort and coordination goes into planning pipeline projects with respect to wetlands, threatened and endangered species, waterbodies, existing infrastructure, and residential and commercial developments. Environmental consultants work with pipeline companies in all stages of pipeline planning and development to identify the least environmentally damaging routes, apply for and receive all required permits, and assist in construction and post-construction monitoring activities.
For a typical pipeline project, the first order of business from an environmental standpoint is the collection of baseline biological data. However, even before initiation of field efforts, major roadblocks or impediments can be identified from the comfort of the office. Consultants often use desktop fatal flaw analyses to help pipeline companies identify potentially project-delaying obstacles that can be addressed in the planning stage or avoided altogether.
Several sources are available in a web-based or GIS format, such as the federal Fish and Wildlife Service (FWS); National Wetland Inventory (NWI); FWS Environmental Conservation Online System, federal Department of Agriculture Web Soil Survey and Army Corps of Engineers (ACE) National Levee Database. In addition, project-level sensitive resource information is often available from state and local agencies.
The information gathered during a fatal flaw analysis provides engineers and planners with pertinent environmental information that may aid in the preparation of survey protocols, clarification of construction timelines and the identification of sensitive biological resources in order to minimize or avoid effects. In addition to biological resources, cultural resources and areas of environmental concern or impaired property may be identified through reviews of government databases and other historical resources.
Field data collection for pipeline projects is commonly the most important component of the environmental process. The information collected in the field is used throughout the environmental permitting process across federal, state and local agencies, providing a baseline for compensatory mitigation requirements and eventual post-construction restoration and monitoring. Therefore, the data collection process must be thorough and efficient, while at the same time conducted in a manner consistent with the client’s safety protocols and procedures.
If too much effort is put into making sure that every minute detail is documented, then project timelines may be extended. If expediency is the priority, data integrity and personnel safety may be jeopardized, potentially causing unnecessary circumstances for all parties involved.
During field efforts, personnel must balance safety, quality and time. Successful consulting firms employ experienced personnel who have managed and conducted biological surveys for projects of varying complexity in a wide range of environments.
As is often the case, projects can cross multiple regulatory agency boundaries, necessitating a wide range of data collection protocols to satisfy the various agency and inter-agency requirements. For each project, specific survey and safety protocols should be developed, providing for efficient data collection and a seamless transition into the permitting process.
There are numerous regulatory agencies that may be involved during pipeline construction. Federal agencies may include the ACE, FWS, EPA, National Marine Fisheries Service, Federal Energy Regulatory Commission and Pipeline and Hazardous Materials Safety Administration (PHMSA).
State agencies, such as wildlife and environmental departments, transportation departments, historic preservation officers, coastal zone management authorities and levee boards, can also require consultation and permitting.
In addition, county/parish and municipal governments often require permits. Some of the keys to efficient permitting include leveraging your field data across multiple permitting efforts, maintaining clear communication with the regulatory agencies and understanding the requirements of each agency’s permitting process. Experience shows that excellence in these areas can lead to permitting timelines and outcomes consistent with those set forth in the planning stage of the project.
Of course, there are variables outside the realm of influence. Many regulators have multiple pipeline projects on their desks, some of which will take priority over others. Also, unforeseen requests for additional information can extend a permit timeline. When delays are identified, communication with the entire project team is of upmost importance. From project managers to engineers to construction managers, all parties involved must be made aware of the changes in the timeline. Proper communication can circumvent or minimize delays in construction.
Once construction is underway, many permits require that the permittee meet certain special conditions during and after construction. These conditions can include biological monitoring for species of concern, storm water pollution prevention, hydrostatic test water sampling and analysis, construction best-management practices, certified clean fill material or post-construction vegetation monitoring.
Environmental inspection services, whether conducted by the pipeline company or through the use of a consultant, help to ensure construction practices are in compliance with the permits. Inspections can consist of daily communication with the project managers and site supervisors, daily to weekly right-of-way inspections, post-inspection reports, water sample collections and analysis, and communication with landowners concerning environmental issues.
The environmental permitting process doesn’t necessarily end after construction is complete. For instance, if wetland effects were mitigated through the establishment of project-specific mitigation sites, those sites need to be monitored at varying intervals, sometimes for years, to document that the function of the affected wetlands were successfully replaced.
Post-construction monitoring, either on- or off-site, is often a condition of permits obtained during the process. Right-of-way revegetation is one of the most common post-construction requirements. Monitoring efforts should employ personnel experienced in assessing right-of-way revegetation failures to determine the underlying cause through physical, chemical and biological analyses, and recommend an appropriate course of action.
Author: Charles Jones is director of Ecological Services at Matrix New World Engineering’s Baton Rouge, LA office where he leads the company’s operations in the Gulf Coast. He has over 20 years of experience in wetland delineation and holds a bachelor’s degree in wildlife conservation from Louisiana Tech University.