RAPID/Best Practices/Transmission Line Siting and Permitting
Transmission Line Siting and Permitting
Disclaimer: Information contained on this page includes general information related to Best Practices for transmission line projects. It is not intended to comprise legal advice and accordingly must not be treated as such. The information contained herein is provided without any representation of warranties, express or implied. Utilization of the information contained herein does not create any relationship, express or implied, between a user of this document and the creators of this document. You must not rely on the information contained herein as an alternative to legal advice from a licensed professional legal service provider. If you have any questions about any legal matter raised in this document, resolution of such questions should be sought from an attorney or other licensed legal professional.
Identify and select the best practices suitable for the transmission project based on project specific variables (e.g., project location, jurisdictions and agencies involved, scale, resources affected, other recent or planned projects in the area, regulatory requirements, and schedule).
- Write a clear project purpose and need statement. A well written purpose and need will meet the following objectives:
- Describes how the project was developed
- Presents a shared understanding of the problems and objectives
- Assists in defining project scope
- Guides the development and evaluation of alternatives
- Avoids developing an ill-conceived project
- Supports legally defensible decisions
For additional information, please visit the Purpose and Need Best Practices Page on RAPID.
- Identify and review federal, state and local regulatory requirements and develop a permitting strategy and matrix to identify all federal, state, and local permits that may be required. From the permitting matrix develop a “roadmap” of federal, state, and local permitting processes to identify how and if the processes can work together efficiently in order to streamline the permitting effort. Utilize the permitting summaries and flowcharts on RAPID to assist in the development of the roadmap.
- Educate project participants about transmission lines including:
- The need for transmission
- Regional energy needs and how the project helps to meet regional capacity and reliability requirements
- Construction, operation and maintenance of transmission lines
- Potential environmental impacts and typical mitigation measures
For additional information, please visit the Introduction to Electric Power Transmission Presentation available on RAPID.
- Consider hiring a third-party facilitator to help guide project participants in working collaboratively and effectively to meet project objectives.
- Develop a Memorandum of Understanding (MOU) between agencies and other participants in the project. Developing a MOU is a way to formalize the collaborative process in an agreement that serves multiple purposes. MOUs can include the following:
- Defines the roles and responsibilities of major participants in the project
- Project schedules/timelines
- A mechanism for tracking progress
- A dispute resolution process
- Documentation procedures
For additional information, please visit the Memorandums of Understanding Page on RAPID.
- Consult with U.S. Department of Energy’s proposed Integrated Interagency Process (IIP). The IIP is a pre-application process that is intended to improve interagency and intergovernmental coordination focused on identifying information that should be developed, and actions that should be discussed at the outset of a transmission project in order to facilitate efficient and timely environmental reviews and agency decisions.
- Public outreach is important during all phases of a transmission line project. During the project initiation phase, public outreach should be implemented early to identify local agency, tribal, NGO, and other stakeholder concerns. Identifying these concerns early in the project will help in developing project alternatives that address these issues and concerns. Other public outreach activities that may occur during the project initiation phase include, but are not limited to, the following:
- Creating a public outreach plan that includes social media and website planning
- Hiring local public involvement or communication firms to develop strategic communications processes
- Focusing outreach efforts to private landowners along proposed routes and/or within the project study area
- Developing a comprehensive project website. Project website could include:
- Project purpose and need/overview
- Engineering and design alternatives
- Summary of regulatory process
- Project schedule
- Project fact sheets and frequently asked questions
- Environmental resources
- Interactive project mapping
- Project contact information
For additional information, please visit the Public Outreach Best Practices Page on RAPID.
- Resource data collection and mapping: Utilize online resources to collect and review data. Geographic information system (GIS) data typically collected during the routing process includes, but is not limited to:
- Existing transmission lines and corridors along with other utilities and linear facilities
- Biological resources data
- Groundwater resources data
- Historical and cultural resources data
- Land use resources data
- Paleontological resources data
- Recreation resources data
- Surface water resources data
- Transportation resources data
- Wetlands, floodplains, and riparian resources data
- Wildlife and fish resources data Online resources that may have useful data include:
- The Crucial Habitat Assessment Tool (CHAT), developed by the Western Governors’ Association and the Western Association of Fish and Wildlife Agencies
- Eastern Interconnection States’ Planning Council (EISPC) EZ Mapping Tool
- EISPIC Energy Zones Mapping Tool
- Regulatory and Permitting Information Desktop [www.openei.org/wiki/rapid (RAPID) toolkit]
- Environmental Data Task Force (EDTF) WECC Environmental Data Viewer
- Continue consultation with federal and state agencies and local jurisdictions early in the routing/siting process to identify issues, concerns, and additional opportunities and constraints.
- Conduct field reconnaissance to help “ground-truth” information obtained through data collection and mapping. Field reconnaissance may help to identify additional opportunities and constraints not identified through mapping or initial consultation efforts.
- Develop a comparative analysis of preliminary alternatives to help identify routes that meet the needs of the project and minimize agency and public concerns. A comparative analysis, can also help to focus efforts for additional field reconnaissance.
- Document all phases of the routing/siting process to incorporate into a routing study. Make routing study publicly available to promote transparency within the routing process.
- Continue public outreach efforts. Public involvement best practices specific to the routing/siting phase include:
- Use geographically-defined “Project Advisory Teams” made of local representatives to inform the routing process and public involvement process.
- Work with landowners to adjust the siting of the right-of-way.
- Prepare exhibits, notices, photographic simulations to be used for website, meetings, etc.
- Post maps on project website and consider using an interactive mapping tool on the website.
- Where multiple agencies are involved in permitting developing an MOU between the lead agency and cooperating or consulting agencies can be helpful to establish a “shared vision” of the environmental review process, timeframe for that process, and inputs and expertise needed from each agency.
- The applicant or project developer needs to develop and provide a clear definition of the project up front. The project definition should include all of the various components of the project, how the project will be constructed, what will occur during operation and maintenance, and how the project will be decommissioned.
- The applicant or project developer needs to establish a list of best management practices or environmental protection measures or mitigation that can be incorporated into the project design and implemented throughout. These measures should be consistent with other best practices and regulations that may affect the project.
- A list of all applicable regulations and laws and agencies that implement those regulations and laws needs to be stablished at the beginning of the project.
- Public outreach and input from the public should be sought early and often. Many environmental review and permitting processes require public outreach but often just doing the minimum may not bring the issues that the public are concerned about to the forefront. A project website that relays project updates and methods to comment on the website are key. Face-to-face meetings with affected agencies and public are also essential.
- Incorporate environmental and cultural risk assessment early in the project (routing/siting phase) to start planning for acceptable survey protocols throughout the project.
- Consider incorporating landscape-level mitigation principles and strategies during the routing phase.
Design/Engineering, Construction, and Operation and Maintenance
Best Management Practices (BMPs) that may be applicable to transmission lines projects, depending on location, voltage, right-of-way requirements, specific resources affected, and other project specific variables. These BMPs may not be applicable to all projects. The table below includes BMPs as they relate to design/engineering (D/E), Construction (C), and/or Operations and Maintenance (O&M).
|Best Management Practice||Design and Engineering||Construction||Operations and Maintenance|
|The Applicant will work with landowners to repair damage caused by construction, operation, or maintenance activities of the Project. Repairs will take place in a timely manner, weather and landowner permitting.||X||X|
|The Applicant will conduct construction, operation, and maintenance activities to minimize the creation of dust. This may include measures such as limitations on equipment, speed, and/or travel routes utilized. Water, dust palliative, gravel, combinations of these, or similar control measures may be used. The Applicant will implement measures to minimize the transfer of mud onto public roads.||X||X|
|The Applicant will conduct construction and scheduled maintenance activities on the facilities during daylight hours, except in rare circumstances that may include, for example, to address emergency or unsafe situations, to avoid adverse environmental effects, to minimize traffic disruptions, or to comply with regulatory or permit requirements.||X||X|
|The Applicant will maintain construction equipment in good working order. Equipment and vehicles that show excessive emissions of exhaust gasses and particulates due to poor engine adjustments or other inefficient operating conditions will be repaired or adjusted.||X||X|
|The Applicant will turn off idling equipment when not in use.||X||X|
|Access and Transportation|
|The Applicant will restrict vehicular travel to the ROW and other established areas within the construction, access, or maintenance easement(s).||X||X|
|Roads not otherwise needed for maintenance and operations will be restored to preconstruction conditions. Restoration practices may include decompacting, recontouring, and re-seeding. Roads needed for maintenance and operations will be retained.||X||X|
|Access controls (e.g., cattle guards, fences, gates) will be installed, maintained, repaired, replaced, or restored as required by regulation, road authority, or as agreed to by landowner.||X||X||X|
|When needed, the Applicant will use guard structures, barriers, flaggers, and other traffic controls to minimize traffic delays and road closures.||X|
|Accommodate existing and future planned transportation facility projects to the extent practicable into the final Project design and coordinate with appropriate jurisdictions to avoid or minimize disruptions to trails, streets, or drainage/irrigation structures.||X||X|
|In identified areas of traffic impact, conflicts between the Project traffic and background traffic such as movements of normal heavy trucks (dump trucks, concrete trucks, standard size tractor-trailers or flatbeds, etc.) would be minimized by scheduling (essential deliveries only) to the extent practicable during peak traffic hours/times and scheduling remaining heavy truck trips during off-peak traffic hours/times.||X||X|
|The quantity of sulfur hexafluoride (SF6) emissions from maintenance activities (and potential leaks in equipment) would be minimized through the use of hermetically sealed equipment, leak detection programs, and sulfur hexafluoride recycling programs.||X||X|
|The Applicant will work with landowners and operators to ensure that access is maintained as needed to existing operations (e.g., to oil/gas wells, private lands, agricultural areas, pastures, hunting leases).||X||X||X|
|The Applicant will minimize the frequency and duration of road closures.||X||X|
|The Applicant will work with landowners to avoid and minimize impacts to residential landscaping.||X||X||X|
|The Applicant will coordinate with landowners to site access roads and temporary work areas to avoid and/or minimize impacts to existing operations and structures.||X||X||X|
|The Applicant will make reasonable efforts, consistent with design criteria, to accommodate requests from individual landowners to adjust the siting of the ROW on their properties. These adjustments may include consideration of routes along or parallel to existing divisions of land (e.g., agricultural fields and parcel boundaries) and existing compatible linear infrastructure (e.g., roads, transmission lines, and pipelines), with the intent of reducing the impact of the ROW on private properties.||X|
|In existing forested areas where temporary work areas require tree clearing, replant temporary work areas with appropriate tree species.||X||X|
|Make reasonable efforts to avoid displacing structures on private property.||X||X|
|Fish, Vegetation and Wildlife|
|The Applicant will identify environmentally sensitive vegetation (e.g., wetlands, protected plant species, riparian areas, large contiguous tracts of native prairie) and avoid and/or minimize impacts to these areas.||X||X||X|
|The Applicant will identify and implement measures to control and minimize the spread of non-native invasive species and noxious weeds.||X||X|
|The Applicant will clearly demarcate boundaries of environmentally sensitive areas during construction to increase visibility to construction crews.||X|
|If construction- and/or decommissioning-related activities occur during the migratory bird breeding season, The Applicant will work with USFWS to identify migratory species of concern and conduct pre-construction surveys for active nests for such species. The Applicant will consult with USFWS and/or other resource agencies for guidance on seasonal and/or spatial restrictions designed to avoid and/or minimize adverse effects.||X||X|
|If construction occurs during important time periods (e.g., breeding, migration, etc.) or at close distances to environmentally sensitive areas with vegetation, wildlife, or aquatic resources, The Applicant will consult with USFWS and/or other resource agencies for guidance on seasonal and/or spatial restrictions designed to avoid and/or minimize adverse effects.||X||X|
|The Applicant will avoid and/or minimize construction within 300 feet of caves known to be occupied by threatened or endangered species.||X|
|The Applicant will design, construct, maintain, and operate the Project following current Avian and Power Line Interaction Committee guidelines to minimize risk of avian mortality.||X||X||X|
|The Applicant will minimize clearing vegetation within the ROW, consistent with a Transmission Vegetation Management Plan filed with NERC, and applicable federal, state, and local regulations.||X||X||X|
|Vegetation removed during clearing will be disposed of according to federal, state, and local regulations.||X||X|
|Any herbicides used during construction and operations and maintenance will be applied according to label instructions and any federal, state, and local regulations.||X||X|
|All vegetation clearing would comply with both state and federal spatial and timing windows, and would not occur during the avian breeding season applicable to each respective region.||X||X|
|Identify, control, and minimize the spread of non-native, invasive species and noxious weeds to the extent practicable, including ensuring that in-water equipment and vehicles are cleaned between waterbodies to minimize the chance of transferring non-native species between waterbodies.||X||X|
|The Applicant will maximize the distance between stationary equipment and sensitive noise receptors consistent with engineering design criteria.||X|
|The Applicant will minimize the number and distance of travel routes for construction equipment near sensitive noise receptors.||X|
|The Applicant will consider noise and radio/television interference in the design of bundle configurations and conductors. To minimize noise and radio/television interference, the Applicant will maintain tension on insulator assemblies and protect the conductor surface from damage during construction.||X||X|
|Investigate noise complaints in accordance with the Applicant’s communications program.||X||X|
|Public Health and Safety and Wastes Hazardous or Solid|
|The Applicant will train personnel on health, safety, and environmental matters. Training will include practices, techniques, and protocols required by federal and state regulations and applicable permits.||X||X||X|
|The Applicant will avoid remedial structures (e.g., capped areas, monitoring equipment, or treatment wells) on contaminated sites, Superfund sites, CERCLA remediation areas, and other similar areas. Workers will use appropriate protective equipment and appropriate safe working techniques when working at or near contaminated sites.||X||X|
|Emergency and spill response equipment will be kept on hand during construction.||X||X|
|The Applicant will restrict the refueling and maintenance of vehicles and the storage of fuels and hazardous chemicals within at least 100 feet from wetlands, surface waterbodies, and groundwater wells, or as otherwise required by federal, state, or local regulations.||X||X||X|
|Waste generated during construction or maintenance, including solid waste, petroleum waste, and any potentially hazardous materials will be removed and taken to an authorized disposal facility.||X||X|
|Where required by FAA, or in certain areas to protect aviator safety, the Applicant will mark structures and/or conductors and/or shield wires with high-visibility markers (i.e., marker balls or other FAA-approved devices).||X||X|
|The Applicant will inspect the line from the ground and/or aircraft routinely. Damaged insulators or other equipment causing noise or radio/television interference will be identified and repaired or replaced.||X|
|The Applicant will properly ground permanent structures (e.g., fences, gates) to reduce the potential for induced voltage and currents onto conductive objects in the ROW.||X||X||X|
|The Applicant will impose speed limits during construction for access roads (e.g., to reduce dust emissions, for safety reasons, and for protection of wildlife).||X|
|Hazardous materials and chemicals will be transported, stored, and disposed of according to federal, state, or local regulations or permit requirements.||X||X|
|The Applicant will work with landowners and operators of active oil and gas wells, utilities, and other infrastructure to identify and verify the location of facilities and to minimize adverse impacts. Identification may include use of the One Call system and surveying of existing facilities.||X||X||X|
|The Applicant will minimize the amount of time that any excavations remain open.||X||X|
|The Applicant will provide sanitary toilets convenient to construction; these will be located greater than 100 feet from any stream or tributary or to any wetland. These facilities will be regularly serviced and maintained; waste disposal will be properly manifested. Employees will be notified of sanitation regulations and will be required to use sanitary facilities.||X|
|Develop and implement a Health and Safety Plan that describes regulatory requirements, procedures, and practices for conducting activities to help ensure a safe working environment, which for purposes of health and safety measures should include:
|The Applicant will develop and implement a communications program. Elements of this plan, which for purposes of health and safety should include:
|Soils and Agriculture|
|The Applicant will avoid or minimize adverse effects to surface and subsurface irrigation and drainage systems (e.g., tiles). The Applicant will work with landowners to minimize the placement of structures in locations that would interfere with the operation of irrigation systems.||X||X||X|
|Agricultural soils temporarily impacted by construction, operation, or maintenance activities will be restored to pre-activity conditions. For example, soil remediation efforts may include decompaction, recontouring, liming, tillage, fertilization, or use of other soil amendments.||X||X|
|The Applicant will consult with landowners and/or tenants to identify the location and boundaries of agriculture or conservation reserve lands and to understand the criteria for maintaining the integrity of these committed lands.||X||X||X|
|The Applicant will work with landowners and/or tenants to identify specialty agricultural crops or lands (e.g., certified organic crops or products that require special practices, techniques, or standards) that may require protection during construction, operation, or maintenance. The Applicant will avoid and/or minimize impacts that could jeopardize standards or certifications that support specialty croplands or farms.||X||X||X|
|The Applicant will work with landowners and/or tenants to consider potential impacts to current aerial spraying or application (i.e., crop dusting) of herbicides, fungicides, pesticides, and fertilizers within or near the transmission ROW. The Applicant will avoid or minimize impacts to aerial spraying practices when routing and siting the transmission line and related infrastructure.||X||X|
|The Applicant will work with landowners to develop compensation for lost crop value caused by construction and/or maintenance.||X||X||X|
|The Applicant will stabilize slopes exposed by its activities to minimize erosion.||X||X|
|The Applicant will minimize compaction of soils and rutting through appropriate use of construction equipment (e.g., low ground pressure equipment and temporary equipment maps)||X||X|
|If signs of contaminated soils are uncovered during construction activities, work would be stopped in the area of potentially contaminated soils until appropriate Project representatives could be consulted.||X|
|Water, Wetlands, and Floodplains|
|The Applicant will avoid and/or minimize construction of access roads in special interest waters.||X||X||X|
|The Applicant will identify, avoid, and/or minimize adverse effects to wetlands and waterbodies. The Applicant will not place structure foundations within the Ordinary High Water Mark of Waters of the United States.||X|
|The Applicant will establish streamside management zones within 50 feet of both sides of intermittent and perennial streams and along margins of bodies of open water where removal of low-lying vegetation is minimized.||X||X||X|
|If used, the Applicant will selectively apply herbicides within streamside management zones.||X||X|
|The Applicant will construct access roads to minimize disruption of natural drainage patterns including perennial, intermittent, and ephemeral streams.||X|
|The Applicant will not construct counterpoise or fiber optic cable trenches across waterbodies.||X||X|
|The Applicant will locate spoil piles from foundation excavations and fiber optic cable trenches outside of streamside management zones.||X|
|Dewatering will be conducted in a manner designed to prevent soil erosion (e.g., through discharge of water to vegetated areas and/or the use of flow control devices).||X||X|
|The Applicant will design converter station sites to avoid adverse changes to the base flood elevation within the 100-year floodplain.||X|
|The Applicant will minimize fill for access roads and structure foundations within 100-year floodplains to avoid adverse changes to the base flood elevation.||X||X||X|
|The Applicant will locate and minimize impacts to groundwater wells and springs within the construction ROW.||X||X||X|
|If blasting is required within 150 feet of a spring or groundwater well, the Applicant will conduct preconstruction monitoring of yield and water quality in cooperation with the landowner. In the event of damage, the Applicant will arrange for a temporary water supply through a local supplier until a permanent solution is identified.||X|
|If any groundwater wells are needed to support operational facilities, withdrawal volumes will be limited so as not to adversely affect supplies for other uses.||X||X|
|The Applicant will ensure that there is no off-site discharge of wastewater from temporary batch plant sites.||X|
|The Applicant will seek to procure water from municipal water systems where such water supplies are within a reasonable haul distance; any other water required will be obtained through permitted sources or through supply agreements with landowners.||X|
|The Applicant will avoid and/or minimize damage to drainage features and other improvements such as ditches, culverts, levees, tiles, and terraces; however, if these features or improvements are inadvertently damaged, they will be repaired and or restored.||X||X||X|
|Limit, to the extent practicable, the amount of vegetation removed along streambanks and minimize the disruption of natural drainage patterns.||X||X|
|All permanent and temporary crossings of waterbodies would be suitably culverted, bridged, or otherwise designed and constructed to maintain low flows to sustain the movement of aquatic species. The crossings would also be constructed to withstand expected high flows. The crossings would not restrict or impede the passage of normal or high flows.||X||X||X|
The best practices listed in the “Best Practices Action” may not be applicable to all transmission line projects. Project participants must consider whether the best practices listed are applicable – or could be applicable with certain alterations – to a specific project depending on the project location, scale, the resources and ecosystems affected, agencies, jurisdiction, and regulatory requirements including mitigation requirements. The best practices are intended to help overcome the challenges of designing, siting, permitting, constructing, and operating transmission lines, such as:
- A project purpose and need statement for National Environmental Policy Act compliance that is not clear or well defined
- Lack of coordination between government agencies that cause uncertainty of the process and the actual time of permitting
- Project participants that may not be familiar with transmission lines or the permitting process
- Lack of communication between project participant (i.e., agencies, tribes, stakeholders, the public)
- Not engaging the public/stakeholders early in the process or continuously throughout all phases of a transmission line project
Examples of best practices are included under the Best Practice Actions section.
The best practices listed in the “Best Practice Actions” section are focused on transmission projects, but may be applicable to other infrastructure projects as well. The following plans may be developed to avoid or minimize negative affects on environmental resources due to construction, operations and maintenance and/or decommissioning of a transmission line or other infrastructure project:
- Transportation and Traffic Management Plan: describes measures to avoid and/or minimize adverse effects associated with the existing transportation plan.
- Blasting Plan: describes measures designed to minimize adverse effects due to blasting
- Restoration Plan: describes post-construction activities to reclaim disturbed areas
- Spill Prevention, Control and Countermeasures (SPCC) Plan: describes the measures designed to prevent, control, and clean up spills of hazardous materials.
- Storm Water Pollution Prevention Plan (SWPPP): describes the practices, measures, and monitoring programs to control sedimentation, erosion, and runoff from disturbed areas.
- Transmission Vegetation Management Plan (TVMP): describes how vegetation within the right-of-way will be managed and/or removed to help prevent power outages, fires, and other problems.
- Avian Protection Plan (APP): describes a program of specific and comprehensive actions that, when implemented, reduce risk of avian mortality. The APP is consistent with Avian Power Line Interaction Committee (APLIC) guidelines.
- Cultural resource management plans: describes historic properties treatment and unanticipated discoveries.
- Construction Security Plan: describes measures designed to avoid and/or minimize adverse effects associated with breaches in Project security during construction including terrorism, sabotage, vandalism, and theft.