NorthWestern Energy Group, Inc. · NASDAQ:NWE
NorthWestern Energy — Technical Presentation (September 2018)
28 slides from NorthWestern Energy's technical presentation, September 2018
Slide 1: FERC Hydropower Re-Licensing Outreach Training
FERC Hydropower Re-Licensing Outreach Training Mike Tust and Peter McBride September 2018
Slide 2: Agenda
Agenda • Project Overviews • Intro to FERC • Processes for Re-Licensing • ILP Pre- and Post-Filing • TLP Pre- and Post-Filing • Additional Topics • Q/A 2
Slide 3: Overview of Montana Projects Coming up for Re-Licensing
Overview of Montana Projects Coming up for Re-Licensing 3
Slide 4: Intro to FERC
Intro to FERC 4
Slide 5: FERC's Office of Energy Projects (OEP)
FERC’s Office of Energy Projects (OEP) Director Deputy Director Senior Policy Advisor Energy Infrastructure Assistant Director Policy Group Management & Operations Division of Pipeline Division of Gas- (DHL) Division of Division of Hydropower Division of Dam Safety Environment & Administration & & I
Slide 6: OEP's Hydropower Roles
OEP’s Hydropower Roles • DHL: Issue licenses or exemptions to construct, operate, and maintain non- federal hydropower projects • DHAC: Enforce the conditions of each license or exemption and conduct environmental inspections • DDSI: Conduct dam safety inspections 6
Slide 7: Div. of Hydropower Licensing (DHL)
Div. of Hydropower Licensing (DHL) • Efficiently process applications • Prepare and issue environmental documents • Address agency, tribal, and public concerns fairly • Analyze recommendations and incorporate reasonable conditions into licenses • Equal consideration for environmental and development
Slide 8: Licensing Process
Licensing Process 8
Slide 9: Overview of Re-Licensing Process
Overview of Re-Licensing Process • Starts 5 to 5 ½ years prior to license expiration • Process split into pre- and post-filing stages – Pre-filing involves info gathering to inform the content of a license application – Post-filing involves FERC evaluation and decision on a filed application • Three
Slide 10: Three Licensing Processes
Three Licensing Processes Traditional Licensing Alternative Licensing Integrated Licensing Process (TLP) Process (ALP) Process (ILP) Projects with effective, Projects with less complex Projects with complex self-driven collaborative issues and study needs; no issues and study needs; pre-filing proce
Slide 11: Integrated Licensing Process
Integrated Licensing Process Default Pre-filing Scoping Conduct Initial Proposal Meetings & Study Plan Studies & & PAD Public Development Prepare Comment Application 1 year 2-3 years FERC Post-filing FERC Review & Environmental FERC Decision License Public Document & (License Application Comment Pub
Slide 12: Notice of Intent (NOI) and Pre-Application Document (PAD)
Notice of Intent (NOI) and Pre-Application Document (PAD) • NOI and PAD due 5 to 5 ½ years prior to license expiration • Required contents (§5.5-5.6) • Applicant may request to be non-federal Rep. for Endangered Species and Historic Preservation Act consultations • If applicant wants to use ALP or T
Slide 13: Scoping Meetings and Public Comment
Scoping Meetings and Public Comment ILP Pre-Filing Applicant Files NOI/PAD 60 days FERC Notices NOI/PAD for Public Comment, Requests for Studies, and Issues Scoping Document 1 30 days Scoping Meetings and Site Visit Held 30 days Scoping Comments and Study Requests Due 13
Slide 14: Study Planning
Study Planning ILP Pre-Filing Study Requests 45 days Proposed Study Plan 90 days (Study Plan Meeting held within first 30 days) Comments on Proposed Study Plan 30 days Revised Study Plan 30 days (additional comments due within first 15 days) OEP Director’s Study Plan Determination 14
Slide 15: Study Dispute Resolution
Study Dispute Resolution • Mandatory conditioning agencies may dispute the determination for studies directly relating to the exercise of their conditioning authorities − Within 50 days of notice of dispute, a three-member panel of technical experts make recommendation to OEP Director − Within 70 da
Slide 16: Study Request Criteria
Study Request Criteria • Goals and objectives of study • Relevant resource management goals • Relevant public interest considerations • Existing information; need for additional? • Nexus to project operations and effects on resources • Methodology; consistent with accepted practice? • Estimates of e
Slide 17: Study Request/Comment Tips
Study Request/Comment Tips • Be detailed • Provide a clear nexus • Be specific - clearly state what you’re requesting and why you’re requesting it (don’t just list problems with what’s being proposed/required) • Explain how results will be used to inform the development of license requirements • Don
Slide 18: Applicant Conducts Studies
Applicant Conducts Studies ILP Pre-Filing Initial Study Report Filed (1 year after Study Plan Determination) 30 Days Study Report Meeting Held and Summary Filed 30 days Comments Filed 30 days Applicant Responses Filed 30 days OEP Director Resolves Disagreements/Amends Study Plan (if needed) 18
Slide 19: Applicant Prepares Application
Applicant Prepares Application ILP Pre-Filing • Preliminary Licensing Proposal (PLP) or Draft License Application (DLA) filed no later than 150 days before license application due – PLP describes existing and proposed facilities and operation, draft environmental analysis by resource area, and study
Slide 20: ILP Post-Filing Process
ILP Post-Filing Process FERC Reviews Comments and Application; Prelim Terms/ Application Filed Notice of Filing Additional Info Conditions; Requests; REA Applicant Reply Notice Issued Comments 14 Days 60-120 Days (approx.) 105 Days Comments on FERC Issues EA Draft EA/EIS; FERC Issues Final FERC Deci
Slide 21: Key Elements of the ILP
Key Elements of the ILP • Process plan with timeframes set by regulation • Early scoping and study plan development with FERC involvement • FERC-approved study plan and, if needed, study plan dispute resolution • Feedback-loop on studies • Defined timeframes for FERC completing its NEPA analysis pos
Slide 22: TLP Pre-Filing Process
TLP Pre-Filing Process Initial Public Consultation on NOI/PAD and Meeting and Site Studies and Info Request Use Visit (30-60 days Needed for of TLP; FERC from TLP Development of Approves TLP approval) Application First Stage Consultation Draft License Application (90 File License Conduct Studies day
Slide 23: TLP Post-Filing Process
TLP Post-Filing Process Notice of Filing Review of Ready For Env (Includes Analysis Notice; Application; FERC Conducts Solicitation for Stakeholder and Addtl. Study Additional Info NEPA Scoping Applicant Reply Requests) Requests Comments Comments on FERC Issues EA Draft EA/EIS and FERC Issues Final
Slide 24: License Term Policy
License Term Policy Commission’s new policy (Oct. 2017): • 40-year default for original & new licenses • FERC will consider greater/lesser term: To coordinate license terms for projects in the same river basin Defer to explicit term in settlement agreement For significant measures in new license
Slide 25: Project Boundary - basics
Project Boundary - basics • Project boundary: the geographic extent a licensee must own or control for licensed project purposes • Land ownership not required, provided licensee holds all necessary interests (e.g. easement) or permits to carry out project purposes • Boundary includes all lands, wate
Slide 26: Project Boundary - details
Project Boundary - details • Boundary must enclose only those lands: – Necessary for operation and maintenance – Necessary for other project purposes (e.g., rec, shoreline control, or resource protection) • Located no more than 200 feet from the exterior margin of the reservoir except where addition
Slide 27: Environmental Baseline
Environmental Baseline • Environment as it exists at the time of relicensing, not pre-project conditions • However, available knowledge of pre-project conditions may help inform FERC’s judgement concerning appropriate mitigation and enhancement measures 27
Slide 28: Q/A
Q/A 28
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