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Scope Creep in FERC License Implementation

Scope Creep in FERC License Implementation. Joint NWHA and NHA Northwest Regional Meeting Panelist: Stephanie Burchfield. One Fish Agency Biologist’s Perspective. Yes, license implementation costs creep at most hydroelectric projects after licensing Why does it happen?

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Scope Creep in FERC License Implementation

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  1. Scope Creep in FERC License Implementation Joint NWHA and NHA Northwest Regional Meeting Panelist: Stephanie Burchfield

  2. One Fish Agency Biologist’s Perspective Yes, license implementation costs creep at most hydroelectric projects after licensing Why does it happen? How to deal with it?

  3. Why does it happen? • Not enough detail in License Application or Settlement Agreement • Not able to access funds for 30-60% design until license issued; conceptual designs miss many of the costs • Tests, models, or design work indicates initial concept won’t work and alternatives cost more

  4. Why does it happen? • New players enter late in the game and want their interests addressed • Agency staff changes and new guy/gal has different (i.e., BIGGER) agenda • The “Punt” phenomenon

  5. How to Deal with it? Talk with agencies about alternatives to high cost design – sometimes new design might be better for fish and cost less Might it be more cost-effective to accept agencies’ requests early in process, rather than to fight for years and end up with more requirements? Don’t rely on cost caps – FERC doesn’t accept them, and neither can agencies

  6. How to Deal with it? Include construction methods and effects in ESA consultation to avoid more delay and consultation Invest in the implementation team – mutual education, trust, understanding, good faith efforts Seek flexibility from all parties – agencies may be willing to accept alternatives if equally effective and if initial concepts aren’t working

  7. Conclusions No one agency or individual is “to blame” Flexibility on all sides to find reasonable solution Identify interests and intentions behind a measure and seek to address them Julie’s 4-step grieving process for FERC projects: get to the “acceptance phase” rather than dwell in denial and anger The longer you resist, the more it will cost

  8. Questions?

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