Managing the engineering/environmental planning interface process for pipeline projects
Waters of the US data
Waters of the US (Waters) are the federally defined boundaries of water resources protected by
the Clean Water Act. Waters include: streams, estuaries, mud flats, lakes, and swamps. The
process of identifying Waters requires that an appropriately skilled person survey the entire
project site where earth will be moved and mark in the field the boundaries of Waters using
guidelines issued by the USACE. This process requires consideration of many variables
including the types of vegetation, the characteristics of the soil, and the presence of water at the
site during the year. The boundaries of Waters are not as consistently clear as the edge of a
river’s banks or the limits of standing water in a swamp. This can cause much confusion when a
project’s civil survey also locates the presence of water for the purposes of identifying required
engineering practices such as weighting the pipeline. Pipeline designers should be aware of data
similarities such as this during alignment sheet production.
Each District of the USACE has different requirements for data that are to be collected, but nearly
all require the boundary of each Waters to be surveyed. Typically, the boundary of Waters can
be surveyed using mapping-grade GPS (sub-meter accuracy). Once the Waters are surveyed
they should not be adjusted without consulting the project team’s environmental planner, even in
situations where they may not look as though they match aerial photography, etc. Discrepancies
should be noted and addressed to the environmental planners to assure that the permitting and
licensing processing is not interrupted.
Managing the boundaries of Waters usually creates the most labor intensive interface between
engineering and environmental planning. Careless management of this data has caused the
misrepresentation of Waters on maps resulting in a regulatory agent finding a discrepancy in the
field and subsequently their denial of a permit. Another significant problem caused by
mismanagement of Waters data is the incorrect calculation of impacts to Waters. Some projects
are required to pay a fee for impacting wetlands based on the area impacted. Incorrect
calculation of the wetland area impacted can result in significant cost to a project
Endangered species data
The location of endangered species is critical to the construction of a pipeline. Nearly every
significant pipeline project that requires a federal permit is required to consult with the US Fish &
Wildlife Service (USFWS) to provide evidence that the project does not significantly impact
federally “listed” endangered species. In the process of consulting with the USFWS, the project
team may be required to perform an analysis of the project’s proximity to the locations of listed
endangered species. The team’s environmental planners gather the known locations of
endangered species from data sets kept by the USFWS and other local agencies, and
additionally, sometimes from field surveys capturing GPS data. The results of both processes
produce information that can be critical to the routing, construction, and post-construction
maintenance of a pipeline.
Endangered species data will comprise a large amount of data, but it must be handled with the
utmost care. One of the most significant but largely unknown issues involving endangered
species data is a requirement for confidentiality. Endangered species are protected under federal
and sometimes state law because of their infrequency and potential for extirpation, or even
extinction. As such, the locations of endangered species become critical to the management of
the existing populations of these species. Managing existing populations does not just mean the
prevention of development, but also the protection from poachers. Every project should be
conscious that endangered species data should be released only to authorized agencies and
typically, it will never be released to the general public.
If a project encounters endangered species it may be required to deviate from traditional pipeline
design practices. It is not unusual for a project to be required to mitigate impact to endangered
species by: horizontally directionally drilling a river with endangered fish; limiting clearing of trees
in endangered bird habitat (even avoid specifically designated trees!); monitoring the cleared
right-of-way during construction for endangered turtles; or, following construction, maintaining the
right-of-way in a particular manner for endangered plants. All of these requirements can cost
pipeline projects large amounts of money. Suitable management of endangered species data
should be applied to ensure a pipeline project is designed to mitigate appropriately, not
excessively.
Cultural resources data
Cultural resources comprise areas and structures listed or eligible for listing on the National
Register of Historic Places. The location of cultural resources can be gathered by existing data
sets and/or by field surveys. Cultural resources should be kept confidential and can require
pipeline design considerations as with endangered species.
FERC data
Projects under the jurisdiction of the FERC may require the preparation of reports that outline the
impacts to the above mentioned resources and a few more. Additional FERC-required resources
gathered during field surveys include: drinking water resources; land use; geologic resources;
and residences.
Drinking water resources are sources of public, private, and agricultural drinking water. These
can be intake pipes in rivers, cisterns, groundwater wells, and more. A FERC regulated project
must mitigate impacts to drinking water resources and an accurate survey is important for the
project to control cost. FERC regulated projects require a field survey of the project’s
construction work spaces to identify the locations of drinking water resources, and this is typically
done with mapping grade GPS. A project’s civil survey may also locate drinking water sources
such as groundwater wells. The two surveys (civil and environmental) may be locating the same
data, causing expensive repetition, however the two surveys may not be using the same data
definition, thereby eliminating the ability to use only one survey. This issue should be addressed
at the beginning of each survey, while considering the data’s spatial requirements, the data’s
attributes, field survey schedules, and field survey costs.
The entire footprint of the project must be mapped to determine the impacts to the various types
of land uses affected by construction and operation of the project. Land use categories may be
broad, such as “forest”, but they can be as detailed as necessary to appropriately represent the
land uses in the many climates within the United States. There is no requirement for land use to
be mapped using GPS, but the exercise of mapping land use is typically done by heads-up
digitizing using an aerial photography base. For a FERC application the aerial photos must be
less than one year old or updated by ground-truthing. Land use is an excellent opportunity for
application of mobile-GIS-mapping without using a GPS component.
Geologic resources can be broken into two categories: geologic sources of economic benefit (e.g.
oil fields, sand pits); and geologic conditions that can inhibit construction and/or restoration (e.g.
severe erosion, karst terrain). Geologic resources are required to be surveyed for and typically
are located with mapping GPS equipment. As with drinking water resources, there may be an
overlap with the civil survey and the project team must plan to efficiently locate these resources
and appropriately manage the resulting data.
Places that people reside must be located and the project must mitigate impact to them.
Residences comprise condominiums, apartment high rises, and single-family homes. The FERC
puts strict requirements on construction activities within 50-feet of residences. As with drinking
water resources and geologic resources, there may be an overlap with the civil survey and the
project team must plan to efficiently locate these resources and appropriately manage the
resulting data.
Engineering data
Environmental data represents natural resources that regulatory agencies require the project to
study, and by itself it only shows their locations and what they are. To complete applications for
permits and licenses and prepare reports the project typically has to incorporate data generated
by the pipeline design team. The project footprint is required by almost every project to analyze
what and how much of environmental resources are impacted. Typically, the project footprint
should be divided into areas representing the construction work spaces and the operation work
spaces. This information is used to determine the amount and degree of impact.
The location of the pipeline itself is also required for environmental data generation. The pipeline
centerline will be used to determine how long resources are crossed for, where resources are
located, and how close resources are to it. This information can be critical to the permitting
process. Some streamlined state and federal permits are granted on a “total linear length of
crossing” basis. That’s to say, in some parts of the country there have been environmental
permits designed to accelerate the permitting process if the project qualifies by crossing a limited
length of resource. Also, the centerline is used to create a location of resources based on their
proximity to the pipeline (a.k.a. mileposting).
