Strategies for Navigating Through
106
Katie Egan-Bruhy
Commonwealth Cultural Resources Group, Inc Milwaukee, Wisconsin
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
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
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
REX 48 DTLs
12 or 25% identified with National Register eligible deeply buried sites
<7% of surface sites
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
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
Private gas/crude transmission applicants face resource
conflicts akin to highway/roadway, but without the self-regulation/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
co-locating potentially impacts important resources as avoidance becomes increasingly difficult
To Avoid, or not Avoid
2/2/2015 Technical Conference on Environmental Permitting & Construction
February 2 - 4, 2015
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
Managing Resources
2/2/2015 Technical Conference on Environmental Permitting & Construction
February 2 - 4, 2015
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
Managing Resources
2/2/2015 Technical Conference on Environmental Permitting & Construction
February 2 - 4, 2015
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?
2/2/2015 Technical Conference on Environmental Permitting & Construction
February 2 - 4, 2015
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?
2/2/2015 Technical Conference on Environmental Permitting & Construction
February 2 - 4, 2015
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?
2/2/2015 Technical Conference on Environmental Permitting & ConstructionFebruary 2 - 4, 2015
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?
2/2/2015 Technical Conference on Environmental Permitting & Construction
February 2 - 4, 2015
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?
2/2/2015 Technical Conference on Environmental Permitting & Construction
February 2 - 4, 2015
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
Important Planning Concepts
2/2/2015 Technical Conference on Environmental Permitting & Construction
February 2 - 4, 2015
