Strategies for Navigating Through 106

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1 Strategies for Navigating Through 106 Katie Egan-Bruhy Commonwealth Cultural Resources Group, Inc Milwaukee, Wisconsin

2 Preliminary Assessment and Identification of Fatal Flaws Delineation of Study Corridor Early Identification of Deeply Buried Sites Pros and Cons of Phase II Evaluation vs. Avoidance Memoranda of Agreement

3 Essential to consult with FERC and SHPO on what may be perceived as potential fatal flaws in project development phase Need full understanding of nature of resource and previous research What may be perceived as Fatal Flaw, may or may not be such Has resource been field verified Land-use history should be considered regarding integrity Does SHPO or agency perceive resource as non-negotiable

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6 Continual refinement of alignment results in necessity to return to previously surveyed tracts multiple times resulting in project delays Realignments commonly occur at: Waterbody crossings Wetland margins Widening the survey corridor at onset in these areas would reduce need to return to survey tracts Notably these are commonly locations of archaeological sites and affords lattitude in alignment through sites

7 REX 48 DTLs 12 or 25% identified with National Register eligible deeply buried sites <7% of surface sites National Register eligible

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9 Phase II While site may be found National Register eligible many are not; therefore, time and cost limited to Phase II Avoidance Cost of redesign Time and cost of landowner negotiation Delays relating to resurvey and potential identification of new sites Additional construction costs associated with realignment

10 Consultation Early and Often Limiting factors Landowner access unsurveyed tracts Including Deep Test Locals Completion of Phase II evaluations Mitigation of adverse effects Mitigation Data recovery Offsetting adverse effect to interested parties Public Benefit

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12 To Avoid, or not Avoid Private gas/crude transmission applicants face resource conflicts akin to highway/roadway, but without the selfregulation/determination of a public agency Routing is often encouraged along existing transmission/utility corridors, many of which are already sited through or around important resources (and not just archaeological!) As existing transmission/utility corridors increase width to increases capacity and meet demand, looping and/or colocating potentially impacts important resources as avoidance becomes increasingly difficult Technical Conference on Environmental Permitting & Construction February 2-4, 2015 The Westin Riverwalk - San Antonio, TX 12 2/2/2015

13 Managing Resources Balance between construction, operations, and maintenance responsibilities AND resource type, National Register of Historic Places (NRHP) eligibility, and/or other standards of resource sensitivity Managing cultural resources not just a condition of significance or eligibility for inclusion on the NRHP Technical Conference on Environmental Permitting & Construction February 2-4, 2015 The Westin Riverwalk - San Antonio, TX 13 2/2/2015

14 Managing Resources Example from Bakken Breakout (2012) article Treasure trove of archaeology stopping preferred bypass route around Williston North Dakota has an abundance of sites that aren t often field verified and/or evaluated but simply avoided Williston Bypass (while a highway project) impacted the climate for cultural resource protection in ND on oil and gas projects in ways that we have yet to fully comprehend Preferred route abandoned: just over 11 miles (3 of which were greenfield) & 8000 (YES!) cultural features Technical Conference on Environmental Permitting & Construction February 2-4, 2015 The Westin Riverwalk - San Antonio, TX 14 2/2/2015

15 Example 1-Site boundary impacted, features avoided 2 Precontact sites 12 stone features over large area 3 existing pipelines within the site Solution (?) evaluate impacted portion and avoid features Next pipeline? Technical Conference on Environmental Permitting & Construction February 2-4, 2015 The Westin Riverwalk - San Antonio, TX 15 2/2/2015

16 Example 2-Site boundary avoided for now Precontact site 19 stone features over a large area 2 existing lines within the site, 1 existing routed north to avoid Water to north and south Next pipeline? Technical Conference on Environmental Permitting & Construction February 2-4, 2015 The Westin Riverwalk - San Antonio, TX 16 2/2/2015

17 Example 3-Site boundaries avoided for now 2 Precontact sites 11 stone features over a large area; 2 stone features 3 existing pipelines north of sites Projected workspace modified to avoid Next pipeline? Technical Conference on Environmental Permitting & Construction February 2-4, 2015 The Westin Riverwalk - San Antonio, TX 17 2/2/2015

18 Example 4-Site boundary avoided for now Precontact site Single stone feature 3 existing pipelines south of site Projected workspace modified to avoid, but with potential difficulty Next pipeline? Technical Conference on Environmental Permitting & Construction February 2-4, 2015 The Westin Riverwalk - San Antonio, TX 18 2/2/2015

19 Example 5-Site boundary avoided almost Precontact site 3 stone features 2 existing pipelines south of site Projected workspace modified to avoid, but with difficulty HDD needed as well Next pipeline? Technical Conference on Environmental Permitting & Construction February 2-4, 2015 The Westin Riverwalk - San Antonio, TX 19 2/2/2015

20 Important Planning Concepts Avoidance of stone features preferred in North Dakota Resistance to detailed examination of sites because of resource sensitivity, regardless of NRHP eligibility or potential (yet unknown) research values Resistance to HDD in some cases because of perceived risks presented by frac-out and long-term maintenance activities Requires educating permitting agencies in the detailed engineering measures/technology utilized to reduce risk Technical Conference on Environmental Permitting & Construction February 2-4, 2015 The Westin Riverwalk - San Antonio, TX 20 2/2/2015