4. Qualifications and
Experience
NEPA Requirements
Throughout the U.S., ERM
provides full-service NEPA
support to private sector clients,
federal agencies, and state
agencies with NEPA-equivalent
programs.
Major actions that have the potential to affect the human
environment and that involve federal funding or require
a permit or other authorization from a federal agency
are subject to the requirements of the National
Environmental Policy Act of 1969 (NEPA). Under
NEPA, project proponents must:
Evaluate the environmental and social
consequences of their proposed actions;
2.
One thing that sets ERM apart
from our competition is our
ability to "think outside of the
box". For every project, we
tailor our approach to meet
specific goals and unique
challenges.
1.
Document those effects in a NEPA compliance
document, such as an Environmental Assessment
(EA) or an Environmental Impact Statement (EIS);
and
3.
Undertake a public consultation process that
informs the public about the project and its
potential consequences and offers the public the
opportunity to voice concerns or provide input on
the project.
NEPA compliance requires consideration of many other
Federal regulations.
Our experience in both private
and public sector work sets ERM
apart from other consultancies
and gives us key insights into
emerging private sector issues and
practical knowledge of public
agency procedures and
requirements.
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
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ERM specialist teams have been
involved in the successful
completion of some of the most
complex NEPA projects in the
United States.
ERM has conducted NEPA
projects in 46 of the 50 states.
State-Level Programs Similar to
NEPA
Nineteen states now have some form of state-equivalent
to NEPA, such as California's Environmental Quality
Act (CEQA) review, or New York's State Environmental
Quality Review Act (SEQRA), and others. ERM is highly
experienced in coordinating the federal and state
requirements to avoid redundancy and potential
conflicts and to ensure efficient and successful
completion of both the federal and state processes.
States with Programs Similar to NEPA
California
Nevada
Connecticut
New Jersey
District of Columbia
New York
NEPA and other Federal
Regulations
Georgia
North Carolina
Hawaii
Puerto Rico
While each NEPA project is unique, there are three
primary paths for NEPA compliance depending on the
degree of the project's environmental impact.
Indiana
South Dakota
Maryland
Virginia
Massachusetts
Washington
Minnesota
Wisconsin
Montana
ERM has successfully coordinated federal NEPA and
state NEPA-equivalent processes in nine states.
Currently, ERM is the third party contractor for a joint
federal/state NEPA process for the Northmet Project, a
proposed open pit mining operation in northeastern
Minnesota. ERM is working closely with the Minnesota
Department of Natural Resources, the lead state agency,
and the U.S. Army Corps of Engineers, the lead federal
agency, to prepare the EIS and to ensure state and
federal NEPA and related requirements are met.
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
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Third Party and Applicant
Prepared NEPA Processes
In a traditional NEPA process, the lead review agency
for a proposed action is responsible for preparation of
the required NEPA documentation (i.e., EA or EIS).
ERM regularly provides comprehensive NEPA support
for lead review agencies, such as our work for the
Federal Energy Regulatory Commission presented in the
Selected ERM NEPA Experience Table in this section.
ERM was the third-party EIS contractor and participated
in the Cooperative Consultation Process (CCP), an
alternative public involvement approach, for New York
Power Authority's St. Lawrence Hydroelectric Project
and Portland General Electric's Clackamas River
Hydroelectric Project. Both of these projects reached
negotiated settlements and gained agency approval and
ERM's work was praised by both the applicants and the
agencies.
NEPA Experience
Alternative NEPA procedures, such as Applicant
Prepared Environmental Assessments (APEA) and
third-party contracting, allow applicants and third
parties to prepare NEPA documents. These alternative
procedures are popular with the private sector because
they allow the applicant to have more control over the
schedule and more flexibility in structuring the public
involvement process. ERM has been at the forefront of
these innovative alternative processes.
ERM's experience preparing EISs and EAs that are fully
compliant with NEPA is very broad and includes a wide
variety of projects and geographic areas of coverage. We
have prepared over 100 NEPA documents for more than
a dozen federal agencies in the past five years. Our
proposed project management team has managed the
preparation of more than 150 EISs and EAs, including
over 30 for the FERC. We have extensive experience
with related consultation requirements pursuant to the
National Historic Preservation Act, the Endangered
Species Act, the Clean Water Act, the Clean Air Act, the
Coastal Zone Management Act, and others.
Selected ERM NEPA Experience Table
Projects
Project Type
(Sector)
State
Lead
Agency/
Cooperating
Agency
Public
Involvement
EA/ EIS
Major Issues
?
?
?
?
?
?
?
?
?
?
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
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Selected ERM NEPA Experience Table
Projects
Project Type
(Sector)
State
Lead
Agency/
Cooperating
Agency
Public
Involvement
EA/ EIS
Major Issues
?
?
?
?
?
?
?
?
?
?
Related Project Experience
Following is a brief summary of select projects
undertaken by ERM that are relevant to the Proposed
Project. References for the first three projects are
provided in Section 6 of this proposal.
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Processing Facility EIS--NorthMet Mine and Ore
ERM has been selected as the third-party contractor to
the Minnesota Department of Natural Resources (DNR),
U.S. Forest Service (USFS) and the U.S. Army Corps of
Engineers (USACE) for the preparation of an
Environmental Impact Statement (EIS) for the PolyMet
Mining, Inc., NorthMet Mine and Ore Processing
Facility Project (Project). The Project will produce
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copper metal, and concentrates of nickel, cobalt,
palladium, platinum, and gold from three open pits.
The Project will include bedrock dewatering, mineral
processing, waste rock management, and reuse of a
former taconite tailings basin. The primary ore contains
sulfides which have the potential to produce acidic
waste products, requiring proper management in order
to avoid impacts to the environment.
withstand intense public scrutiny and potential public
opposition.
The project also involves construction of support
infrastructure, including road, rail, electric transmission,
and pipelines. This is the first sulfide mine in Minnesota
and is subject to intense agency, tribal, and public
scrutiny.
ERM is preparing a joint state/federal EIS that will
satisfy the Minnesota Environmental Policy Act (MEPA)
and associated Minnesota Rules parts 4410.0200 to
4410.6500, as well as the National Environmental Policy
Act (NEPA) and its implementing regulations
concurrently. To accomplish this, ERM's team,
assembled from across North America, includes
technical specialists covering a range of scientific and
technical disciplines who are experienced in EIS
development in the mining sector.
ERM has reviewed resource documents and project
plans; identified additional data needs; coordinate
project open houses and public meetings; conducted
initial impact assessment; and assisted in the
development of an "Agency Alternative" that the Project
Sponsor has adopted that provides enhanced
environmental protection (e.g., subaqueous disposal of
reactive waste rock, improved tailings basin cover,
increased water reuse to reduce makeup water demand,
enhanced geotechnical stability). USEPA and several
tribes (Chippewa bands) have become active
participants in the process and ERM is facilitating a
series of workgroups with them to review and resolve
key project issues.
ERM is currently preparing a detailed EIS to evaluate
the new Agency Alternative that meets applicable
MEPA and NEPA requirements, includes a robust
alternatives and cumulative effects assessment, and will
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
ERM's phased approach to characterization of the
Project's waste products.
Common Facilities Pipeline System Expansion--
The Midwest has experienced increased demand for
natural gas over the past several winters and retail gas
demand is projected to continue to grow. Much of this
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supply comes from the western U.S. and western
Canadian sources that serve natural gas demand in the
region.
proposed
constructing and operating extensions to its existing
natural gas pipeline system to meet the needs of its
subscribers by providing a reliable and timely supply of
natural gas. These extensions would serve the growing
demand for residential and industrial uses in
southeastern Minnesota, Iowa, and northeastern
Nebraska.
The overall project and system expansion included four
components. The Ventura North portion of the project
included installing about 1 mile of a 36-inch main line
extension in northcentral Iowa. The Lacrosse-Tomah
portion of the project included installing almost 5 miles
of from 6-inch loop lines up to 36-inch main lines in
southeastern Minnesota and northcentral Iowa. The
East Leg portion of the project included installing about
8 miles of 6-inch loop lines, 8-inch branch lines, and up
to 36-inch main lines in northcentral and central Iowa.
The West Leg portion of the project included installing
about 12 miles of 8-inch branch lines and up to 30-inch
main lines in western Iowa and northeastern Nebraska.
ERM was part of the team that conducted the fieldwork for
and prepared the four Federal Energy Regulatory
Commission (FERC) Prior Notice permit packages for the
overall project.
This project was conducted under an extremely fasttrack schedule because
had to begin
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
construction in the spring of 2008 to meet its contractual
obligations with its subscribers. Our contract was not
signed until the end of October 2007, essentially at the
end of the fieldwork season, and work began in
November. Teams were quickly mobilized over a 2week period, fieldwork was completed prior to
Thanksgiving, and the first set of draft resource reports
were submitted by December 15. The remaining draft
sets of Resource Reports were prepared and submitted
to
throughout January and February,
completing them in only 4 months (typically a 6-month
process to complete just one set of reports).
ERM visited the State Historic Preservation Officers
(SHPOs) to collect archaeological and historical
information, initiated tribal consultation with 22 tribes,
and conducted reconnaissance cultural resources field
studies. Once the cultural reports were submitted to the
SHPOs, the Minnesota SHPO identified an area of
concern and requested that systematic shovel testing be
conducted. Once again, ERM signed a task order,
mobilized staff, and began conducting the shovel testing
in a little more than a week in mid-December.
During that time the ground began to freeze and snow
fall, so ERM quickly adjusted to the changing conditions
by finding, contracting with, and mobilizing a Bobcat
with an auger to assist in digging in the frozen topsoil.
This shovel testing continued into early January, but
was successfully completed and that project component
remained on schedule.
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ERM prepared the water use and quality; fish, wildlife,
and vegetation; cultural resources; land use, recreation,
and aesthetics; and the air quality and noise Resource
Reports for
Prior Notice applications to
FERC. FERC staff not only approved these applications
without revisions, they complimented
by stating
that they were some of the best that had been submitted
to FERC.
Bemidji-Grand Rapids 230-kV Transmission Line--
Minnesota Office of Energy Security
Northern Minnesota has experienced increased demand
for electrical energy, and that demand is projected to
continue to grow, in a rural part of the state. Additional
transmission line capacity is required to meet that
growing need. In addition, the area is heavily affected
by severe winter weather and additional measures are
needed to improve the long-term reliability of the local
and regional electrical system (i.e., northwestern
Minnesota and eastern North Dakota).
The NorthMet Mine and Ore Processing Facility
will be the first commercial scale sulfide metal mine
to be evaluated under the
Minnesota Environmental Review Program.
To meet these needs, a consortium comprised of Otter
Tail Power Company, Minnesota Power, and Minnkota
Power Cooperative, Inc. proposes to construct and
operate the 68-mile long Bemidji-Grand Rapids 230-kV
Transmission Line Project. This project is one of four
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Group 1 projects in the Capacity Expansion 2020
(CapX2020) initiative in the state. ERM was hired as the
Third-Party contractor (TPC) to work with the
Minnesota Office of Energy Security (OES) and the U.S.
Department of Agriculture Rural Utility Service's (RUS)
Development Utilities Program to prepare the joint
Environmental Impact Statement (EIS) for the project.
The proposed single-circuit Bemidji-Grand Rapids 230kV Transmission Line Project would be constructed on
wooden 2-pole H-frame structures. These structures
would range from 70 to 90 feet tall and would be spaced
600 to 1,000 feet apart. The proposed transmission line
would generally follow the Great Lakes Gas
Transmission Company's pipeline right-of-way, from
the Wilton Substation located west of Bemidji to just east
of Deer River, where it then would follow a Minnesota
Power 115-kV transmission line to the Boswell
Substation located northwest of Grand Rapids,
Minnesota. This route would cross portions of the
Chippewa National Forest and the Leech Lake Indian
Reservation. An alternative route proposed by the
consortium generally would follow U.S. Highway 2 and
then the pipeline rights-of-way of Enbridge Pipelines
LLC.
ERM worked as an extension of the OES's staff to
identify issues, collect additional information, and
prepare the draft and final Environmental Impact
Statements. ERM began by assisting in organizing and
participating in the five public scoping meetings for the
project, as well as two inter-agency working group
meetings. ERM assisted in facilitating those meetings as
well as taking notes. A Public Scoping Summary report
then was prepared to categorize, by key topic in the EIS,
and summarize all verbal and written comments
received during the scoping period.
ERM also collected additional desktop biological and
cultural resources information for three new alternative
routes. This information was placed into the GIS
databases, along with the two proposed routes, to
conduct a comparative screening analysis of all five
routes. New maps and tables were then prepared
comparing the potential environmental, land use, and
socioeconomic impacts of the five routes.
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ERM also served as the TPC to assist the OES in
complying with the Minnesota Power Plant Siting Act
(PPSA) and associated rules, and prepared the EIS. The
EIS was prepared as a joint EIS to meet U.S. National
Environmental Policy Act (NEPA) requirements. These
two processes had different timelines and data needs for
evaluation of the proposed alternatives. As such, ERM
worked with the state OES along with the RUS, and
other federal agencies to ensure that both federal and
state requirements and concerns were appropriately
addressed.
within the watershed as well as potential future
dischargers to the river in order to determine the basinwide assimilative capacity of the river. ERM developed
a statistical model of river flow, temperature and water
quality relationships and concluded that the proposed
withdrawal would not compromise the assimilative
capacity of the lower Roanoke River.
Water Supply Project--City of Virginia Beach
ERM prepared an Environmental Impact Statement
(EIS) for the City of Virginia Beach Water Supply
Project. The proposed project involved a 60 million
gallon per day (mgd) interbasin transfer of water from
Lake Gaston in the Roanoke River Basin of North
Carolina via a 76-mile-long pipeline to the City of
Virginia Beach and surrounding municipalities. The
project was very controversial and had been the subject
of several previous environmental impact assessments,
several court challenges, and over 15 years of
contentious argument regarding its environmental
effects.
ERM conducted a detailed water supply and demand
analysis evaluating population growth trends, per capita
water use, and average water demand by sector through
the year 2030. This water demand was compared with
the safe yield of existing and programmed water
supplies, including raw water sources, distribution
systems, treatment capacities, reservoir capacity, and
groundwater availability, to confirm a water supply
deficit of approximately 60 mgd.
ERM modeled the entire 9,600 square mile basin using
HEC-5 to simulate the effects of the withdrawal on river
hydrology and reservoir routing. The model also took
into consideration existing and future consumptive uses
of water within the river basin that would affect flow
conditions. ERM evaluated water quality impacts of the
withdrawal within Lake Gaston, downstream along the
Roanoke River, and in estuarine portions of Albemarle
Sound. We reviewed existing NPDES permit conditions
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
The key issue was the effect of the withdrawal on the
Roanoke River system, including hydrology, water quality,
and fisheries.
ERM also analyzed the effect of the reduced river flows
resulting from the withdrawal on salinity relationships
in Albemarle Sound, focusing specifically on the
potential for saltwater intrusion. Our analysis
concluded that the combination of relatively high
outflow, small cross-sectional area, and low flow
augmentation effectively blocked saline water from
entering the lower river.
The Roanoke River provides critical spawning habitat
for striped bass. Research has indicated that low spring
flows result in shortened egg development time and
longer travel times for larval striped bass to reach
rearing areas. Several resource agencies expressed
concern that the proposed withdrawal would increase
the frequency of low flows in the spring, adversely
affecting striped bass spawning. ERM performed an
independent analysis of the relationship between striped
bass stock decline and regulated spring flows in the
Roanoke River. Using HEC-5, ERM concluded that
proposed flow augmentation by the City of Virginia
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Beach would offset the effects of the proposed
withdrawal and would not adversely affect striped bass
spawning. Under worse case conditions, the proposed
withdrawal would result in only a 3.3 hour increase in
striped bass egg and larval travel time to Albemarle
Sound, which is negligible compared to natural
variability due to wind and tides.
ERM concluded that the proposed withdrawal would
not have any significant adverse effects on the Roanoke
River and recommended approval of the project.
Although challenged all the way to the U.S. Supreme
Court, the EIS was upheld. The project has now been
constructed and is in operation.
Environmental Impact Review and Permitting
A multi-state pipeline company wanted to construct a
70-mile-long pipeline across mid-Michigan to provide
refined petroleum products to over 25 counties. The
project required rapid permitting to support the
expedited construction schedule.
ERM completed a comprehensive Environmental
Impact Review (EIR), which is a state-level EIS
equivalent, to characterize resources and associated
impacts. ERM inventoried natural and social
resources, conducting research and field and aerial
assessments of wetlands, streams and floodplains,
wildlife, geology and soils, groundwater and wells,
historic cultural resources, aesthetics, noise, natural
resource areas, and socioeconomic factors.
ERM also identified resource impacts and developed
mitigation measures to facilitate permit approvals. ERM
provided permit coordination, application, and followup activities with State and local agencies, including the
Michigan Public Services Commission, MDEQ, and the
State Historic Preservation Office. ERM also provided
expert witness services in several contested case
hearings to support the findings of the EIR.
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
A multi-team approach was used to expedite field
assessments along the entire 70-mile long corridor in a
shortened timeframe.
Environmental permits and clearances were successfully
obtained from all agencies to allow construction of the
southern half of the pipeline. Permits and approvals
obtained included MPSC Certificate of Public
Convenience and Necessity, MDEQ wetland and stream
crossing, MDNR threatened and endangered species
clearance, multi-county soil and sedimentation control
and drain crossing permits, and NPDES discharge
permits for stormwater and hydrostatic test water.
The southern segment was successfully constructed with
ERM staff providing full time on site environmental
inspection. ERM provided on-site certified inspectors to
ensure contractor compliance with wetland, soil
erosion/sedimentation control, stream and drain
crossing, and other environmental protection, mitigation
and restoration measures. The northern half of the
pipeline corridor was revised to accommodate MPSC
routing concerns, and similar permits were successfully
obtained for the revised route.
Environmental Assessment--Proposed F-16
Beddown
The U.S. Air Force proposes to station up to eighteen
new F-16 Model E/F aircraft at the 162 Fighter Wing
(FW), based at the Tucson International Airport (TIA), in
Tucson, Arizona. The 162 FW is tasked with training
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international and domestic pilots in F-16 operations and
air-to-air and air-to-ground tactical operations using
several military training routes (MTRs), Military
Operating Areas (MOAs), and the Barry M. Goldwater
Range (BMGR). The proposed action would result in an
annual increase of 1,800 sorties. The Air National Guard
contracted with ERM to evaluate the environmental
effects of the proposed action and to prepare an
Environmental Assessment in compliance with the
National Environmental Policy Act. NEPA compliance
must be completed within 5 months in order to meet
internal Air Force decision deadlines.
ERM evaluated the effects of the new aircraft and
increased sorties on noise levels in and around TIA and
determined that no noise-sensitive uses would be
adversely affected. There were no other significant
adverse effects at TIA.
the Sonoran Pronghorn antelope. The U.S. Fish and
Wildlife Service (USFWS) had just recently prepared a
Biological Opinion on the effects of military operations
at the range on the Pronghorn, focusing on the effects of
aircraft noise and on the use of inert and live munitions.
The proposed action would increase the number of
sorties and would involve the use of live munitions.
ERM finished the EA ahead of schedule. The Air
National Guard has recommended that the EA ERM
prepared be their new standard for EAs. ERM is on
schedule to finish the EA ahead of schedule.
Environmental Permitting Services for Multi-state
Pipeline Network--Confidential Pipeline Client
A multi-state pipeline company needed to perform
repairs and other maintenance of a liquids petroleum
pipeline network pipeline spanning 700 miles across
multiple Midwest states. The multiple projects required
rapid federal, state, and local permitting to support the
construction schedule.
ERM assembled a team of engineers, biologists,
geologists, and GIS experts to support a comprehensive
permitting program. Database research and field
surveys are being completed for wetlands, threatened
and endangered species, wildlife habitat, soils, lakes and
streams, and contaminated sites.
ERM prepared a Biological Assessment evaluating
the effects of the proposed action on the pronghorn,
and concluded that the proposed action is not likely
to adversely affect the pronghorn. ERM consulted
further with the USFWS and provided some
supplemental information on maximum instantaneous
aircraft noise levels.
ERM also prepared a draft EA for review by various
state and federal agencies and local stakeholders. ERM
also evaluated the effects of the increased sorties at
environmental resources in the MTRs, MOAs, and on
the BMGR. There are several federally-listed threatened
and endangered species found at BMGR, in particular
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Using the results of the surveys and data gathering,
ERM is working with the pipeline company to develop
project plans and designs to minimize and mitigate
environmental impacts. ERM has prepared soil erosion
and sedimentation control plans, stormwater pollution
prevention plans, wetland protection measures, stream
and bank restoration plans, rare species mitigation
plans, and NDPES discharge plans. ERM also
developed spill response plans, investigated petroleum
releases from legacy operators and third-party accidents,
and developed and implemented remediation plans.
Permit applications have been prepared and submitted
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to federal, state, and local agencies. ERM has also
provided support to the client to ensure permitting
compliance during construction at numerous sites.
On behalf of its client, ERM has obtained local, state, and
federal permits and approvals from USACE, USFWS,
MDEQ, MDNR, IDNR, IDEM, SHPO, and numerous
counties in multiple states. Permits have been obtained
to support projects in over 50 locations, and projects
have been completed with no violations. Multiple
release sites have been closed or are in the process of
working toward closure.
Permitting and Development Support
ERM provided permitting and development support for
the
, a proposed
petroleum refinery and integrated gasification combined
cycle (IGCC) power plant complex to be located in
southeastern South Dakota. ERM prepared a regulatory
permitting roadmap for the project, as well as a detailed
scope of activities that would be required to prepare an
Environmental Impact Assessment for the project (a
formal EIS was not required for the project). ERM
conducted a critical issues analysis for the selected site
to determine, at a screening level, whether there were
any environmental, regulatory or socioeconomic issues
that could potentially result in a barrier to permitting
the
.
Following completion of the critical issues analysis,
ERM completed or coordinated sub-consultants to
complete a number of studies for the project including:
an economic impact study with a comprehensive
multiplier analysis; a socioeconomic baseline study to
assess the current regional setting with respect to labor,
housing, and public infrastructure; an ecological
reconnaissance to determine the general ecological
setting of the proposed site and surrounding areas; a
cultural resources survey to assess whether
archaeological resources are present within the
proposed project development area; a noise impact
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
analysis including modeling of projected noise levels
during operation; and an odor analysis which utilized
the results of air dispersion modeling to assess the
predicted extent of perceivable odor impacts.
Additionally, ERM completed a screening-level health
impact analysis to assess the predicted carcinogenic risk
to nearby receptors due to long-term inhalation of
emissions from the facility during operations.
Throughout the project, ERM interacted directly with
the engineering services contractor in order to provide
input to the environmental considerations of the design.
As part of this interaction, ERM assisted with
development of a detailed breakdown of projected
project construction and operation labor hours and labor
and materials costs. This detailed information was used
to complete the economic impact multiplier analysis.
ERM provided assistance with public interaction
including: preparation of materials for and participation
in three kiosk-style open house informational sessions at
separate locations in the vicinity of the proposed project;
and participation in three public meetings during which
members of the community provided comments and
questions on the proposed project. ERM also prepared a
Green Charter for the project which outlined the
approach that the project would take in order to ensure
that design and operation is performed in an
environmentally and socially sustainable manner. ERM
supported engagement with regulatory stakeholders for
the project, including consultations with the U.S. Fish
and Wildlife Service, U.S. Army Corps of Engineers,
South Dakota Department of Environment and Natural
Resources, South Dakota Department of Transportation,
and National Park Service.
Manual,
ERM developed a comprehensive environmental
compliance manual addressing permitting for
natural gas pipeline system.
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Northeast Gateway Deepwater Port--
Massachusetts Bay
Under contract to
,
ERM served
as the third-party contractor to assist the U.S. Coast
Guard in the environmental review of the Northeast
Gateway Deepwater Port and pipeline. The Port was
licensed under the Deepwater Port Act and its
associated pipeline lateral received a Certificate of
Public Convenience and Necessity from the FERC under
section 7(c) of the Natural Gas Act. The U.S. Coast
Guard was the Lead Federal Agency for the NEPA
review of the Port and Pipeline; the FERC acted as a
cooperating agency.
Golden Pass LNG Import Terminal and Pipeline--
Texas Gulf Coast
ERM provided siting, licensing, environmental and
engineering support for the Golden Pass LNG Import
Terminal and associated Pipeline under Section 3 and
Section 7 of the Natural Gas Act, before FERC. ERM
coordinated the environmental, socioeconomic, and
cultural resource assessments necessary to locate, design
and permit the facility and pipeline. ERM prepared the
RR to be submitted with the FERC Application for the
terminal and pipeline, and provided engineering liaison
support.
ERM provided licensing, environmental, engineering,
economic, and permitting support for a 1.4 BCFD LNG
import terminal on the Delaware River in southern New
Jersey for
. ERM was responsible the entire
Environmental Resource Report, including coordination
with the cryogenic and coastal design engineers. ERM
conducted a detailed alternatives analysis to support
facility siting and design, prepared the project Health
and Safety Plan. ERM coordinated with the U.S. Coast
Guard regarding the Letter of Intent and Project
Operations Plan, and was also responsible for securing
all necessary permits from New Jersey and Delaware.
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Storage Facility--
The
proposed to
construct and operate a gas storage facility in Martin
County, Florida, capable of converting natural gas to
LNG for onsite storage and regasifying the LNG for
delivery in Southeastern Florida during periods of peak
demand without service interruptions in the pipelines.
ERM was the Third-Party contractor working with
FERC to perform an environmental review of the
project. The NEPA Document was completed on
schedule and under budget.
Permitting--
ERM assisted
in permitting the "lift and lay"
replacement of approximately 2 miles of 30-inch natural
gas pipeline in Montgomery County, Maryland. ERM
obtained Environmental Resources Management 40
wetland, floodplain, endangered species, forest
conservation, cultural resource, stormwater
management, and sediment/erosion control permits
from various federal, state, and local agencies.
Permitting--
ERM provided wetland assessment, delineation, and
permitting services to
for pipeline
installations, replacements, and maintenance activities.
ERM secured individual wetland permits for pipeline
installation and replacement activities for
throughout central Maryland and eastern Pennsylvania.
ERM worked closely with the U.S. Army Corps of
Engineers in 2003 to expedite the wetland permit review
process so that
could minimize pipeline loss of
service on pipelines that required maintenance within
regulated wetlands.
EIS Services for
ERM completed all services necessary for the
environmental permitting of a 7.5-mile natural gas
pipeline to supply a new 830 MW merchant electrical
generating facility. A complete environmental impact
Page | 31
The world's leading sustainability consultancy
assessment of the pipeline route was completed,
including identification, impact assessment, and
development of mitigation measures for wetlands,
streams, floodplains, erodible soils, archaeological sites,
threatened and endangered species, and other natural
resources. On behalf of its client, ERM secured
environmental clearances and permits from the state
public utilities regulatory agency, U.S. Fish and Wildlife
Service, the state environmental regulatory agency, the
state historic preservation office, and the local county
drain commission. Construction inspection services
were also provided to ensure compliance with project
specifications and environmental permit conditions.
ERM prepared an Environmental Resource Report for
an 89-mile-long, 30-inch natural gas pipeline associated
with the Golden Pass LNG Project for submittal to the
FERC pursuant to Section 7 of the Natural Gas Act. The
RR addressed the full set of environmental issues
including wetlands, streams, historic sites, land use,
noise, and erodible soils.
EIA--
Pipeline
Natural Gas
ERM developed engineering and environmental
documents to support a competing application for an
approximately 90- mile-long natural gas pipeline in
Maine, New Hampshire, and Massachusetts.
Environmental Consulting--New York Power
Authority
The New York Power Authority (NYPA) retained ERM
as a third-party contractor to participate in a
Cooperative Consultation Process (CCP) and to prepare
an EIS in the relicensing of the St. Lawrence - Franklin
D. Roosevelt (FDR) Hydroelectric Project (FERC Project
No. 2000) on the St. Lawrence River in St. Lawrence and
Franklin Counties, New York. ERM took direction from
the Federal Energy Regulatory Commission (FERC) and
the New York State Department of Environmental
Conservation (NYSDEC, a NEPA Cooperating
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Environmental Resources Management 41 Agency,
regarding any consultation or support services, and in
the preparation of the EIS.
Siting--Maryland Department of Natural
Resources
ERM conducted a detailed analyses to support the State
of Maryland's evidentiary proceeding to site, design,
construct and operate a natural gas pipeline related to
the Potomac Electric Power Co.'s proposed natural gas
fired Combined-Cycle Power Plant along the Potomac
River in Charles County, MD.
ERM provided detailed technical engineering, economic
and environmental studies to support the certification,
public risk and safety review, engineering feasibility and
environmental permitting evaluation of an extensive
construction and operation plan to expand natural gas
pipeline service in the coastal areas of the lower
Potomac River. ERM experts reviewed the gas pipeline
construction and operations plan, assessed alternative
construction techniques for an extensive high quality
wetland community that the pipeline would cross, and
performed catastrophic risk assessments to identify
potential safety risks to materials, human health and the
environment in a probabilistic risk assessment analysis.
Permitting--
Gulf Coast
ERM developed a Section 404 permit for the on-shore
and immediately off-shore portion of an on-shore
natural gas pipeline gathering system for Rainbow
Pipeline operated by
. This pipeline
segment was part of a larger 600 mile long system. Field
studies included an environmental survey of wetlands
and off-shore benthic areas. An investigation of historic
shoreline erosion rates was also performed. A
comparative environmental assessment of construction
alternatives was performed as part of the permit. ERM
also assisted the client with regulatory agency
negotiations.
Page | 32
5. Project Schedule and
Work Plan
Schedule and Work Plan
ERM uses project planning
software such as Microsoft
Project as needed to help
schedule control.
ERM finished the Environmental
Assessment for the Proposed F-16
Beddown ahead of schedule. The
Air National Guard has
recommended that the EA ERM
prepared be their new standard
for EAs. ERM is on schedule to
finish the EA ahead of schedule.
ERM understands the critical need to set and maintain
an expedited pre- and post-filing schedule while
producing a defensible SEIS, particularly given past
project delays and the high level of scrutiny
surrounding the Keystone XL Project. We also
understand that any delays or unaddressed issues in the
process of completing a legally defensible SEIS could
affect the implementation of the Project by
TransCanada. Therefore, ERM has developed a Project
team and expedited schedule under which we will
provide a complete and legally defensible Final SEIS.
In the RFP, the Department has provided a project
completion period of the first quarter 2013, or 9 months
from proposal submittal. ERM is prepared to commit to
this schedule subject to certain conditions described
below regarding factors outside of ERM's control.
However, the ERM Project team proposes a project
schedule that will result in completion of the Project
within this timeframe. ERM is committed to allocating
the necessary resources and manage the Project to meet
the task milestones described in the attached schedule in
order to drive the Project to the expected completion
date.
ERM is currently working on three EISs: Buckeye, a
wind farm project in Ohio for the USFWS; NorthMet, a
copper and nickel mine in Minnesota for the USACE;
and an NEPA Document for Monk Seal habitat in
Hawaii for NOAA.
These projects are being managed out of our Annapolis,
Minneapolis, and Alaska offices respectively and these
obligations will not affect our ability to maintain the
Project schedule.
ERM and the key staff assigned to this Project offer
highly qualified, experienced professionals, who bring
the necessary environmental, regulatory, and technical
experience in the application of NEPA to large, complex
and often controversial projects. The proposed ERM
Project team will provide the Department with a strong
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
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The world's leading sustainability consultancy
group that can quickly and efficiently assess the
Department's previous FEIS and supplemental
information and prepare a comprehensive and
defensible SEIS within budget and on schedule,
satisfying the Department's expectations and all
applicable regulatory requirements. ERM has
committed our team and has the additional resources
necessary to manage work loads as needed to meet the
proposed schedule and maintain flexibility if
modifications to the proposed schedule are required (see
Section 3, Project Organization and Management
Approach).
Once the Notice to Proceed has been received, ERM will
immediately develop and maintain the master project
schedule consistent with the determination and
requirements of the Department and the scheduling
conditions at that time. ERM uses project planning
software such as Microsoft Project as needed to help
schedule control. Using Microsoft Project, ERM will
develop a resource-loaded schedule that covers the
entire life of the Project. In so doing, we have been able
to anticipate what skills will be needed and when they
will be needed, allowing us to plan for changes in staff
loading over the course of the Project. ERM will provide
a draft schedule for review at the Kick-off Meeting.
Some key milestones that will inform the SEIS review
process are not yet known; these include the results of
new field studies along the revised route and the NDEQ
evaluation report and permit. ERM understands the
need for schedule flexibility and working with the
Department will adjust the schedule as needed to
accommodate project and process changes.
Schedule Control
ERM uses project planning software such as Microsoft
Project as needed to help schedule control. Using
Microsoft Project ERM will develop a resource-loaded
schedule that covers the entire life of the Project. In so
doing, we have been able to anticipate what skills will
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
be needed and when they will be needed, allowing us to
plan for changes in staff loading over the course of the
Project.
Steve Koster, as Project Manager, will be responsible for
planning, scheduling, and progress tracking consisting
of startup planning for each task; regular project team
meetings to provide real-time update of project status
and to facilitate communication regarding changes in
schedule, strategy, or project design; detailed project
planning and focusing on critical path items and
deliverables; and individual task progress review and
reports. This level of project planning will be a necessity
given the fast track leading to the submittal of PDSEIS to
the Department on Day 90.
Organizational Policy and
Structure
ERM has a well-established partnership model that
forms the foundation of our organizational policy and
structure worldwide. We maintain a ratio of
approximately one partner per 10 employees, and a
partner is assigned to every project. ERM's partnerproject manager model allows each partner to stay
engaged with our clients, stay in touch with backlog and
hiring needs, and provide QA/QC on all proposals and
deliverables. ERM has grown organically, and our
organizational partnership model has been intact for
over 35 years.
ERM stresses a "flat" organizational structure based on
the partnership model described above, and
collaboration between offices is encouraged and
incentivized. The lack of local profit centers ensures that
we act in our client's best interest regardless of project
location. We recognize the importance of having
experienced project managers that are dedicated to our
projects at strategic locations, supported by local staff
and subcontractors to minimize travel, costs, and
associated environmental impacts (i.e., greenhouse
gases).
Page | 34
The world's leading sustainability consultancy
Schedule
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Page | 35
The world's leading sustainability consultancy
Global Management System
Scope, schedule, and budget tracking are critical
elements of successful project management. In 2006,
ERM implemented a GMS, a secure, web-based project
management tool accessible to all of ERM's global
employees. GMS is used by the Project Manager to set
up each project in concert with the proposed tasks for
each authorization. Once a project is entered into GMS,
task and subtask budgets are conveyed to staff, who
then use their access to track labor and other expenses
consistent with the budgets established. On a weekly
basis, all of ERM's global employees log their project
work hours and expenses into GMS. The ERM Project
Manager can then query the system for immediate
project status reports. GMS allows projects to be
established independent of geographical location,
enabling efficient cost tracking and accountability for
each authorization.
Subcontractors will typically be selected based on
specialty capabilities, geographical presence, or
competitive pricing. ERM stresses teamwork with our
subcontractors, and integrates their staff into each
project though briefings, tailgate meetings, and frequent
communications. ERM treats our subcontractors fairly,
and pays them within an average of 45 days. At the
same time, we hold our subcontractors accountable to
the same high standards we expect of our own staff.
?
Measure, both along the way and upon completion,
how we did and what we learned.
Our requirements are implemented by experienced
Project Managers trained in our Management System
with required peer review by a Principal at appropriate
Environmental Resources Management 33 points in the
Project, including review of all deliverables prior to
submittal. The result is a set of consistent project
management behaviors for the entire project team.
Communications
Clear lines of accountability and reporting are critical to
successful project management and communications.
Our organizational chart, in Section 3, summarizes roles
and lines of reporting for the Project. Key personnel
communicate almost continuously about scope,
schedule, and budgets related to individual tasks.
Monthly Progress Report
For typical projects, ERM will submit a monthly
progress report (MPR) to the Department Project
Manager by the 10th of each month. The MPRs will
summarize the work completed and problems
encountered during the previous month, and projected
activities for the coming month. In addition, an updated
project schedule and a summary of costs billed-to-date
will be included with each MPR.
Quality Assurance and Quality
Control
Client goals and expectations are met through consistent
application of ERM's Management System designed to
assure that large, complex projects meet or exceed
expectations. One element of this system contains
project management requirements that cover the three
stages of client service delivery including:
?
Define and understand client needs and
expectations at the proposal stage;
?
Manage the Project's agreed to scope, schedule and
budget, including any agreed to scope changes; and
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Page | 36
6. References
Firm Project References
Client / Project
Name /Phone
Steve Koster, PE --
Project Manager References
Client / Project
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Name /Phone
Page | 37
7. Conflicts of Interest
ERM has no business
relationship with TransCanada
or its affiliates, and in the
attached is certifying that no
conflict of interest exists for
working on this Project.
Pursuant to 40 CFR 1506.5(c), contractor selection is
based on ability and absence of conflict of interest. ERM
fully recognizes the importance of maintaining the
absence of both real and perceived organizational
conflicts of interest as an independent third-party
contractor. This is certainly true for this Project and for
all projects utilizing a third-party contractor role.
ERM has no business relationship with TransCanada
or its affiliates, and in the attached is certifying that no
conflict of interest exists for working on this Project.
As required by the RFP, ERM is submitting the
following completed documents:
Attachment B1--OCI Representation Statement
?
Detailed description of the internal processes
undertaken to conduct our internal OCI review
Attachment C--OCI Ongoing Obligations Certificate
Attachment D--OCI QUESTIONNAIRE
?
OCI Questionnaire Supplement
?
OCI Questionnaire Supplement Figure
Attachment E--Contractor CII Non-Disclosure
Agreement
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Page | 38
The world's leading sustainability consultancy
ATTACHMENT "B1"
OCI REPRESENTATION STATEMENT
Name of Person or Organization:
Environmental Resource Management (ERM)
I hereby certify (or as a representative of my organization, I hereby certify) that, to the best of my knowledge and belief, no
facts exist relevant to any past, present or currently planned interest or activity (financial, contractual, personal, organizational
or otherwise) that relate to the proposed work; and bear on whether I have (or the organization has) a possible conflict of
interest with respect to (1) being able to render impartial, technically sound, and objective assistance or advice; or (2) being
given an unfair competitive advantage. I provide a detailed description of the internal processes undertaken to conduct our
internal OCI review in the attached page(s).
Signature:
Date:
Name:
Steven Koster, PE
Organization:
ERM
Title:
June 27, 2012
Senior Associate Partner
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Page | 39
ERM Policy and Procedure for Client Representation Checks ("CRC") in
North America
At ERM, we maintain strong relationships with our clients. We communicate with each other to prevent perceived
impropriety, inappropriate use of confidential information, or the perception that ERM has created a conflict between
duties owed to different clients. Toward that end, we have developed a procedure to identify client representation
issues arising out of potentially sensitive client engagements. This procedure has been followed to ensure that ERM
has no conflict with the proposed Keystone XL Pipeline Project.
?
Step 1: Internal Research the Target Company of this CRC - as much information as possible is established about
the Target Company and context for the project. Global and Key Clients lists are reviewed as well as other internal
sales tool resources to see what work (if any) has been done or is ongoing with the Target Company.
?
Step 2: A CRC email inquiry is sent to key business unit leaders, practice leaders, and other appropriate key
personnel throughout ERM.
?
Step 3: Responders (a) check ERM's client databases, (b) confidentially check ERM's institutional knowledge of
the particular company, and (c) respond with information regarding what work ERM has done, or is doing, with
the company.
?
Step 4: "Follow up" communications with ERM staff are completed as needed and any additional research is
performed.
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Page | 40
ATTACHMENT "C"
OCI ONGOING OBLIGATIONS CERTIFICATION
I recognize that OCI is an ongoing obligation. Should I or my organization become aware of any actual or
potential OCIs during performance of this contract, I or my organization will advise the Department of State and
(Contractor/Applicant Name) and propose mitigation or explain why none is needed. I provide a description of
internal controls for ensuring OCI does not arise during the Project on the attached page(s).
Signature___________________________________
Name:
Senior Associate Partner
Organization:
June 27, 2012
Steven Koster, PE
Title:
Date:
ERM
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Page | 41
ATTACHMENT "D"
OCI QUESTIONNAIRE
Name of Person or Organization:
Environmental Resource Management
1.
Will you (or your organization) be involved in the performance of any portion of the proposed work?
(X)
No.
()
Yes. The portion of the proposed work; the proposed hours and dollar value; and the type of involvement
are fully disclosed on the attached pages.
2.
What is (are) the major type(s) of business conducted by you (or your organization)? Please reply on the attached
pages.
3.
Do you (or your organization) have any affiliates? All questions in this questionnaire apply to affiliates as well.
Whenever possible, each affiliate should submit a separate questionnaire (for instance, to avoid completing a large
number of questionnaires), this questionnaire must incorporate information regarding all affiliates.
()
No.
(X)
Yes. The name and a description of the major type(s) of business that each affiliate conducts are disclosed
on the attached pages.
4.
Will any of the following be involved in performing the proposed work: (a) any entities owned or represented by you
1
(or your organization); (b) your organization's Chief Executive or any of its directors; or (c) any affiliates?
()
No.
(X)
Yes. A full disclosure and discussion is given in the attached pages.
5.
Are you (or your organization) an energy concern? 2
(X)
No.
1
()
6.
Yes. A full disclosure and discussion is given on the attached pages.
Within the past three years, have you (or your organization) have a direct or indirect relationship (financial,
organizational, contractual or otherwise) with any business entity that could be affected in any way by the proposed
work?
(X)
No. ERM has no existing contract or working relationship with TransCanada.
()
Yes. List the business entity(ies) showing the nature of your relationship (including the dates of the
relationship) and how it would be affected by the proposed work under this solicitation.
1 The term "affiliates" means business concerns which are affiliates of each other when either directly or indirectly one concern or individual controls or has the power to control another, or when a
third party controls or has the power to control both.
2 The term "energy concern" includes:
i. Any person significantly engaged in the business of developing, extracting, producing, refining, transporting by pipeline, converting into synthetic fuel, distributing, or selling minerals for use
as an energy source, or in the generation or transmission of energy from such minerals or from wastes or renewable resources;
ii. Any person holding an interest in property from which coal, natural gas, crude oil, nuclear material or a renewable resource is commercially produced or obtained;
iii. Any person significantly engaged in the business of producing, generating, transmitting, distributing, or selling electric power;
iv. Any person significantly engaged in development, production, processing, sale or distribution of nuclear materials, facilities or technology; and
v. Any person -(1) significantly engaged in the business of conducting research, development, or demonstration related to an activity described in paragraphs (i) through (v); or
(2) significantly engaged in conducting such research, development, or demonstration with financial assistance under any Act the functions of which are vested in or delegated or
transferred to the Chair of the Commission.
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Page | 42
7.
What percentage of your total income for the current and preceding fiscal years resulted from arrangements with any
of the entities identified in Question 6 above?
_0_% For the current fiscal year -- from _____________ to ____________.
_0_% For the preceding fiscal year -- from _____________to _____________.
_0_% For the second preceding fiscal year -- from _____________to _____________.
8.
Do you (or your organization) currently have or have you had during the last 6 years any arrangements (for example,
contracts and cooperative agreements) awarded, administered, or funded -- wholly or partly -- by the Department of
State or any other Federal agency which relate to the proposed Statement of Work?
(X)
No.
()
Yes. A full disclosure and discussion is given on the attached pages.
9.
Do you (or your organization) have or have you ever had any contracts, agreements, special clauses, or other
arrangements which prohibit you (or your organization) from proposing work to be performed in this solicitation or
any portion thereof?
(X)
No.
()
Yes. A full disclosure and discussion is given on the attached pages.
10.
Do you (or your organization) have any involvement with or interest (direct or indirect) in technologies which are or
may be subjects of the contract, or which may be substitutable for such technologies?
(X)
No.
()
Yes. A full disclosure and discussion is given on the attached pages.
11.
Could you (or your organization) in either your private or Federal Government business pursuits use information
acquired in the performance of the proposed work; such as:
(a)
Data generated under the contract?
(b)
Information concerning Department plans and programs?
(c)
Confidential and proprietary data of others?
(X)
No.
()
Yes. A full disclosure and discussion is given on the attached pages.
12.
Under the proposed work, will you (or your organization) evaluate or inspect your own services or products, or the
services or products of any other entity that has a relationship (such as client, organizational, financial, or other) with
you (or your organization)? This could include evaluating or inspecting a competitor's goods and services.
(X)
No.
()
Yes. A full disclosure and discussion is given on the attached pages.
13.
To avoid what you perceive as a possible organizational conflict of interest, do you (or your organization) propose to:
exclude portions of the proposed work; employ special clauses; or take other measures?
(X)
No.
()
Yes. A full discussion is given on the attached pages.
()
No possibility of an organizational conflict of interest is perceived. This answer is briefly justified on the
attached pages.
I hereby certify that I have authority to represent my organization, if applicable, and that the facts and representations
presented on the pages of this questionnaire and on the ____ pages of the attachment(s) to it and my OCI Disclosure
Certification are accurate and complete.
Signature:
Date:
Name:
Steve Koster, PE
Organization:
ERM
Title:
June 27, 2012
Senior Associate Partner
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Page | 43
ATTACHMENT "D"
OCI QUESTIONNAIRE
ERM - Supplement
Question 2
Response
ERM has seven different business areas, yet all fall under a general heading of environmental services. ERM
provides environmental services in the private and public oil and natural gas industry in upstream, mid-stream
and downstream sectors.
The major business areas for ERM include:
?
?
?
?
?
?
?
Impact Assessment Practice (the proposed third-party Department SEIS would fall under this practice
area, although specialists would be drawn from other practice areas in developing the proposed SEIS);
Sustainability and Climate Change Practice;
Risk Management Practice;
Performance Assurance Practice;
Contaminated Site Management Practice;
Air Quality and Noise Practice;
Transaction Services Practice.
Additional information on ERM business practice areas can be provided to the Department upon request.
Question 3 Response
All of ERM's affiliates conduct work similar to that described in the response to Question 2. The names and
structure of ERM and its affiliates are attached as Figure 1 on the following page.
Question 4 Response
ERM staff will be involved in performing the NEPA work as specified in the solicitation.
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Page | 44
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ATTACHMENT "E"
CONTRACTOR CII NON-DISCLOSURE AGREEMENT
On behalf of [contractor name], I certify that [contractor name] will abide by the following terms with respect to critical infrastructure
information (CII) that the company has access to because of its work for the Department of State.
?
Only authorized company employees with a need for the information will be given access to CII [contractor name]
will maintain a list of each employee who is given access to CII, including a listing of each project for which the
employee has been given CII.
?
[Contractor name] will not provide CII to or discuss CII with anyone outside the company, except that CII may be
discussed with the Department and other agencies as directed by the Department, the project's owner, operator,
or applicant.
?
Any copies made of CII will be marked as CII and treated as CII.
?
CII will be used only in performance of [contractor name]'s work for the Department of State. When [contractor
name] has completed work on the Project, all CII will be returned to the Department of State.
?
I acknowledge that a violation of this agreement may result in negative consequences and could alter [contractor
name]'s ability to contract with the Department of State in the future.
By:
Steve Koster, PE
Title:
Senior Associate Partner
Representing: ERM
Date:
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
June 27, 2012
Page | 46
8. Resumes
ERM has assembled a Project
team consisting of highly
experienced key personnel, with
deep staff resources across all
scope of work disciplines to
provide specialized expertise
across the Project platform.
Successful completion of any program or project
requires understanding the client's needs, technical
competence, managerial skills, and the ability to prepare
and execute detailed work plans consistent with
applicable goals, regulations, and guidance documents.
ERM has assembled a team of highly qualified and
experienced professionals whose skills meet all program
requirements, and whose qualifications, education, and
responsibilities are tailored to the RFP requirements to
successfully accomplish the diverse and complex work
that is anticipated under this program.
Resumes for the ERM Team key personnel are included
in this section.
ERM is committing Steve
Koster, PE as Project Manager
and Andrew Bielakowski as
Deputy Project Manager for the
duration of the Project.
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Page | 47
United States Department of State -- RFP #6152012
Keystone XL Project - Supplement Environmental Impact Statement Preparation
Page | 48
Steven J. Koster, P.E.
Project Manager
Steve Koster has more than 25 years of experience in
environmental impact assessment, permitting, and
impact mitigation for oil and gas projects.
Mr. Koster has managed multi-disciplinary teams to
support development in multiple aspects of the oil and
gas sector including pipeline, exploration and
production, and retail. His management experience
includes environmental impact assessments,
environmental studes, and permitting of dozens of liquid
petroleum and natural gas pipeline projects. He has
overseen baseline studies and impact assessments for
federal NEPA and/or state EIS throughout the Midwest;
provided community, tribal, and stakeholder
engagement support on highly visible and controversial
siting and permitting projects; served as expert witness
and provided litigation support in various judicial
venues; and negotiated permit conditions with
regulatory officials.
Mr. Koster has served as Partner-In-Charge or Project
Manager for numerous NEPA EIS and EA projects, siting
studies, and state/federal permitting projects. Projects
have included surface water and groundwater
hydrologic studies and modeling, wetland delineations,
threatened and endangered species surveys and taking
permits, aquatic surveys, wildlife assessments, soil
erosion and sedimentation control permitting, air quality
assessments, noise and visual studies, socioeconomic
analyses, stakeholder mapping and engagement plans,
and public meetings and presentations.
Professional Affiliations and Registrations
Registered Professional Engineer, State of Michigan
American Society of Civil Engineers
Air and Waste Management Association
Fields of Competence
Liquid and natural gas petroleum pipelines
NEPA compliance
Scoping, Environmental Impact Statements, and
Environmental Assessments
Groundwater hydrogeological investigations
Federal and state environmental permitting -
wetland, stream, stormwater, and soil
Ecological studies
Stakeholder and tribal engagement
Litigation support and expert witness testimony
Education
M.S., Environmental Engineering, The University of
Michigan, 1985
B.S., Civil Engineering, The University of Michigan,
1984
B.S., Letters and Engineering, Calvin College, 1984
Certification and Training
Environmental Site Assessment, ASTM
40-Hour OSHA Health and Safety Training for
Hazardous Material Operations and Emergency
Response
Risk-Based Corrective Action
Certified Storm Water Operator, State of Michigan
Delivering sustainable solutions in a more competitive world
Key Projects
Spartan Pipeline EIA and Permitting, 2004. Partner--ln-
Charge and Project Manager for Environmental Impact
Assessment of the Spartan Pipeline, a 63-mile long liquid
petroleuin pipeline constructed in Michigan. Completed
assessments and evaluated potential impacts on natural
and cultural resources, including spill imp act modeling.
Evaluated route alternatives and developed mitigation
measures to reduce impacts on wetlands, streams, soils,
groundwater supplies, air quality, noise, and
socioeconomic aspects. Project included permit
co ordination andnegotiation with multiple federal, state,
and local regulatory agencies. Provided community and
media relations support and expert testimony in multiple
contested case hearings and litigation support for
Michigan Supreme Court appeal. Managed team of
environmental field staff for permitting compliance
monitoring during project construction.
Mariner West Pipeline, ongoing - Partner--in-Charge for
environmental studies and permitting support for a
crude oil to ethane pipeline conversion project from the
Marcellus Shale region through several states in the US
Midwest. Project involved wetland delineations,
wetland mitigation planning support, Phase I and II
environmental site assessment, and cultural resource
assessments.
Various Trasmission Line EIS Projects, 2007-2010.
Partner-In-Charge for third-party support and
preparation of numerous ElS's under a third party
contract with the State of Minnesota in coordination with
multiple federal and state agencies, including a NEPA
EIS for the 68--mile Bemidji-Grand Rapids transmission
line through the US. Forest Service Chippewa National
Forest, a state-level MEPA EIS for the Pleasant Valley-
Bryon transmission line EIS, and a MEPA EIS for the
Hiawatha transmission line in Minneapolis.
l/Vhite Pines Wind EIS, 2008-2010. Partner-In-Charge for
NEPA EIS and permitting for a new 70 MW wind energy
facility and transmission line in the U.S. Forest Service
I-luron-Manistee National. Forest. ERM was responsible
for_ supporting the FS throughout the NEPA process,
including scoping, resource studies, impacts analysis,
alternatives and mitigation evaluation, EIS preparation,
and public comment management.
Various Natural Gas Pipelines, 2000-2.005. Partner-In-
Charge for Environmental Impact Assessments of
multiple natural gas pipelines for landfill gas recovery
and construction of power generating plants, focusing on --
wetland, stream, soil erosion, and historical resource
06/09
impacts. Projects included preparation and submittal of
permit applications to State and local agencies.
Buckeye Wind EIS, ongoing. Partner-ln~Charge for
NEPA EIS for Habitat Conservation Plan and Incidental
Take Permit for lndiana bat for a proposed wind farm in
Ohio. Working under the direction of the USFWS and in
cooperation with the wind developer, ERM prepared the
EIS under a precedent-setting permitting process
pursuant to the federal Endangered Species Act. Project
included scoping evaluation, HCP review, alternatives
evaluation, and impacts and mitigation analysis for draft
and final EIS preparation.
Wolverine Pipeline, ongoing. Partner-ln'--Charge and
Project Manager for permitting of multiple projects
associated with expansion and maintenance of a 700-mile
liquids petroleum pipeline network in Michigan, Indiana,
and Ohio. Projects included wetland permitting,
threatened and endangered species permitting, soil
erosion and stormwater permitting, and hydro geolo gic
investigations and spill response associated with legacy
crude oil and refined liquids releases.
Mine (MN) EIS -- ongoing. Senior Technical
Lead for Third~Party NEPA EIS for the first proposed
sulfide mine in Minnesota. This is a joint federal
(USACE, USFS) and state (Wnnesota DNR) project that
I also included the U.S. EPA and multiple tribes as
Coordinating Agencies. This project required evaluation
of impacts, cumulative effects, and alternatives for
development of EIS documents, with a particular focus
on issues surrounding potential acid rocl< drainage and
approximately 800 acres of wetlands impacts. Lead for
biological and social impact analysis.
Marcellus Union Pipeline, 2011. Project Manager for
Fatal Flaw Analysis of a planned 4.0 0-mile petroleurn
pipeline in the Midwest. Project identified permitting
recjuirements and constraints, including potentially
sensitive environmental and social considerations.
Rail Corridor Alternatives Study, 2007. Partner--ln-
Charge and Project Manager of a multi-part confidential
rail siting study for a major power utility in the Midwest.
The project identified preferred alternatives for
delivering coal to six existing and new baseload power
plant sites by rail and Great Lakes vessels. Rail corridors
were identified, evaluated, and prioritized using
technical, environmental, and socioeconomic criteria.
S}l<
Andrew Bielakowski
Deputy Project Manager/Cultural Resources
Mr. Andrew Bielakowski is a Project Manager and Senior
Cultural Resources Specialist with more than 12 years of
experience. He has managed the permitting and
environmental compliance of numerous large-scale energy
development and maintenance projects subject to high
levels of environmental review and scrutiny.
Mr. Bielakowski has reviewed and negotiated the
regulatory requirements of various federal, state, and local
agencies associated with these projects in multiple states.
He has managed and conducted environmental field
surveys. He has prepared various federal, state, and local
agency permit applications, including U.S. Army Corps of
Engineers Section 404 Authorization, Section 401 Water
Quality Certification, Stormwater Pollution Prevention
Plans (SWPPP), Federal Energy Regulatory Commission
(FERC) Certificate of Public Convenience and Necessity
(Certificate)/Section 7(c) applications, applicant-prepared
Environmental Assessments (EAs), and third-party
Environmental Impact Statements (EISs). He has also
managed or supported agency and tribal consultation
efforts.
Mr. Bielakowski has worked for several U.S. federal
agencies as a Historic Preservation Officer (Department of
Army, National Park Service, and Forest Service). He is an
accomplished archaeologist familiar with modern and
traditional fieldwork techniques and equipment. He has
worked on a number of challenging and remote projects
and sites. Mr. Bielakowski has conducted fieldwork in the
United States, Mexico, Albania, Egypt, South Korea, and
the Caribbean.
Additionally, Mr. Bielakowski developed and managed an
overall Archaeological Program for a niche service
consulting firm. In this role, he was responsible for
ensuring technical oversight and quality assurance for
fieldwork and reporting; planning, supervising, and
conducting cultural resource surveys; preparing project
reports, research designs, scopes of work, proposals,
budgets, and time/cost estimates on projects for federal,
state, local, tribal, and commercial clients.
06.24.12
Fields of Competence
NEPA compliance
FERC compliance and resource reports
Environmental assessments and impact statements
Federal, state, and local permitting and compliance
Feasibility and siting studies
Ecological and cultural resource studies
Historic Preservation and Section 106 compliance
Native American and Alaska Native consultation
Archaeological survey, testing, and data recovery and
mitigation
Expert witness testimony
Professional Affiliations, Registrations, and Training
FERC Environmental Review and Compliance for
Natural Gas Facilities Seminar
Construction Erosion and Stormwater Installer
Certification
Construction Erosion and Stormwater Site Management
Certification
Design of Construction Stormwater Pollution
Prevention Plans (SWPPPs) Certification
EPA Watershed Management Certification
NEPA Compliance and Cultural Resources
Section 106 Review
Section 106 Advanced Seminar: Reaching Successful
Outcomes in Section 106 Review
Identification and Management of Traditional Cultural
Places
Native American Consultation
Working Effectively with Tribal Governments
Certification
OSHA 40-hour HAZWOPER General Site Worker
Training
Society for American Archaeology (SAA)
American Anthropolgical Association (AAA)
Meets U.S. Secretary of the Interior's (36-CFR-61)
Professional Standards for Historic and Prehistoric
Archaeology.
Education
M.A., Archaeology, University of Toronto, Toronto,
Canada, 2000
B.S., B.A., Anthropology, Classical Civilizations,
Philosophy, Loyola University, Chicago, Illinois, 1998
ANDREW BIELAKOWSKI
Key Representative Projects"
Northern Natural Gas Company - Northern Lights 2009-
2010 Zone EF Expansion Project - 2007-2010
Project Manager for 52 miles of 16-, 20-, and 30-inch-
diameter natural gas pipeline, and various ancillary
facilities in Minnesota. Responsible for overseeing all
environmental permitting, survey, and agency
consultations for construction. Managed and contributed
to the preparation of the FERC Section 7(c) Environmental
Report Application and applicant-prepared EA.
Present -Xcel Energy - Big Stone South to Brookings
County Project - 2011
Project Manager for 70 miles of 345 kV electric
transmission line and two substations in South Dakota.
Responsible for siting routing studies; stakeholder
engagement and public involvement; field studies and
surveys; agency coordination and consultation; state
licensing; and permitting.
TransCanada USA Operations, Inc. -- Various Natural
Gas Pipeline Projects - 2007-2010
Project Manager for various length and diameter natural
gas pipeline projects in Iowa, Kentucky, Michigan,
- Minnesota, Missouri, North Dakota, and Wisconsin.
Prepared federal, state, and local permit applications,
developed managed environmental field surveys,
and conducted tribal and agencyconsultations.
CenterPoint Energy - Various Natural Gas Pipeline
Projects - 2007-2010
Project Manager Cultural Resource Manager for various
length and diameter natural gas pipeline projects in
Arkansas, Illinois, Louisiana, Minnesota, Mississippi,
Oklahoma, and Texas. Prepared federal, state, and local
permit applications, developed managed
environmental field surveys, and conducted tribal and
agency consultations.
ExxonMobiI and TransCanada - Alaska Pipeline Project -
2010-2011
FERC Technical Lead for strategizing and implementing
the FERC's Pre-filing Process and drafting Resource Report
4 (Cultural Resources) of the FERC Section 7(c)
Environmental Report Application for 750 miles of 48-inch-
diameter pipeline from the North Slope of Alaska to the
U.S.--Canada border.
British Petroleum and ConocoPhillips - Denali - The
Alaska Gas Pipeline - 2009-2010
FERC Technical Lead and Cultural Resource Manager for
730 miles of 48-inch-diameter natural gas pipeline, one gas
treatment plant, and four compressor stations in Alaska.
Responsible for managing cultural resource surveys, tribal
consultation, and NHPA compliance.
06.24.12
Enbridge Pipelines L.L.C. - Alberta Clipper, and
Southern Lights Diluent Projects - 2006-2010
Cultural Resource Manager for 324 miles of 36-inch-
diameter diluent crude oil pipelines in Wisconsin,
Minnesota, and North Dakota. Responsible for managing
cultural resource surveys, tribal and agency consultation,
and NHPA compliance.
Minnesota Pipe Line Company - MinnCan Project -
2004-2009
Cultural Resource Manager for 300 miles of 24-inch-
diameter petroleum pipeline in Minnesota. Responsible
for managing cultural resource surveys and NI-IPA
compliance.
FS - Nortl1Met Project 2011-Present
Tribal Liasion and Cultural Resources Manager for the
third party preparation of a state-federal NEPA)
EIS for Polymet Mining Corp.'s proposed copper-nickel-
precious metals mine in the Mesabi Iron Range of
northeastern Minnesota.
El Paso Corporation - Ruby Pipeline - 2010-2011
Third-party cultural resource compliance monitor for 680-
mfle, 42-inch interstate natural gas pipeline in Oregon,
Nevada, Utah, and Wyoming. Reviewed and monitored
variance requests and alternative mitigations to assure a
high level of environmental and cultural resource
compliance during construction.
TransCanada Pipelines Limited - Wisconsin 2007
Expansion Project - 2005-2006
Cultural Resource Manager for 70 miles of 8-, 16-, 30-, and
42-inch-diameter natural gas pipeline in Wisconsin and
Responsible for managing cultural resource
surveys, tribal consultation, and NHPA compliance.
Federal Energy Regulatory Commission - Spectra Energy
Transmission's New Iersey-New York Expansion Project
- 2010
Cultural Resource Manager for 21 miles of large-diameter
natural gas pipeline, two compressor stations, and three
metering stations in New Jersey and New York.
Responsible for review of cultural resources report of the
FERC Section 7(c) Environmental Report' Application,
development and preparation of preliminary,
administrative, drafting draft and final versions of the EIS,
and agency coordination.
Rockies Express LLC - Rockies Express Pip eline-East
Project - 2007-2009
Project team member for 639 miles of 42-inch-diameter
natural gas pipeline in Missouri, Indiana, and
Ohio. Responsible for assisting in management of cultural
resource surveys, NHPA compliance, and agency
consultation.
ANDREW BIELAKOWSKI
David W. Blaha, AICP
NEPA Specialists
Mr. Blaha has 30 years of experience in environmental impact
assessment, natural and cultural resource management, and
land planning for local, state, regional, and federal governments
in the U.S. and internationally. He is thoroughly familiar with
the regulatory/procedural requirement of NEPA and has
extensive experience with Section 7 of the Endangered Species
Act, Section 106 of the Natural Historic Preservation Act, and
Executive Orders for wetlands, floodplains, and environmental
justice. He has extensive experience in multi-media permitting
of large (>$1billion) and often controversial infrastructure
projects. Special expertise in evaluating energy, mining,
military, water resource, telecommunication, transportation,
and land use projects.
Professional Affiliaions & Registration
American Institute of Certified Planners, 1986
American Planning Association
American Water Resources Association
National Association of Environmental Professionals
Fields of Competence
Environmental impact assessment for a wide variety of
projects including pipelines, military operations, mining,
airports, reservoirs, marinas, hydroelectric power projects,
LNG import terminals, gas pipelines, highways, transit,
housing, parks, and industrial development.
Water resources, including water supply planning and water
quality management. Analyses of sources, quantities, types,
transport, and fate of pollutants. Skilled in the development
of watershed and wellhead protection plans for surface and
groundwater supplies and comprehensive river basin studies.
Wetland ecology, including wetland delineation, functional
assessments, mitigation design, permitting, and protection
planning.
Delivering sustainable solutions in a more competitive world.
Education
Master of Environmental Management, Duke University,
1981
Bachelor of Arts, Biology, Gettysburg College, 1978
Key Projects
Crown Landing Liquefied Natural Gas Project, New Iersey -
2006. Project Manager for a 1.4 BCFD LNG Import terminal for
BP consisting of a marine terminal and an on--shore
re gasification facility on the Delaware River. Responsible for
preparing the Environmental Report portion of the application
for filing with the Federal Energy Regulatory Commission
under Section 3 of the NGA and state permitting in DE.
Liquefied Natural Gas Project, U.S - 2006. Project Manager for
a 4 MMTPA LNG Import Project for a confidential client
consisting of a marine terminal and an on--shore re gasification
facility. Responsible for preparing the Environmental Report
for FERC under Section 3 of the Natural Gas Act, Project Health
and Safety Plan, Phase ll due diligence investigation, and
federal and state permitting.
FGS Natural Gas Storage Project (FL) EIS - 2009. Project
Manager for preparation of EIS for construction of natural gas
.. liquefaction facilities with a capacity of 100 two LNG
Jrage tanks with a capacity of 8 Bcf, and natural gas
Iaporization and a 4:--mile 20--inch--diameter send--out pipeline
capacity of 800 on a 145 acre brownfield site in Martin
County, FL as a 3rd Party EIS contractor With the Federal Energy
Regulatory Commission (FERC). Key issues included effects on
endangered species, Wetlands, and public safety.
Buckeye Wind Project (OH) EIS ongoing. Senior Technical
Advisor and author of the cumulative effects assessment for a
Party EIS for a 250 MW Windfarm in Ohio on behalf of the
USFWS. The EIS was triggered by the need for an Incidental
Take Permit (ITP) for impacts to the Indiana bat, a federally
listed endangered species. If issued, this ITP Would be the first
issued for Indiana bats for a windp ower project in the US.
Condor Airspace Modification EIS - ongoing.
Project Director responsible for preparing an EA evaluating the
effects of modifying the Condor 1 and 2 Military Operations
Area (MOA) for the 102" Fighter Wing based. at Otis AFB in
Falmouth MA for the Air National Guard with the Federal
Aviation Administation as a cooperating agency. Proposal
involved lowering the floor to 500 feet above ground level to
improve air-to-ground training. Key issues involved noise
fects on recreational uses along the Appalachian Trail and
"rural areas of ME and NH.
2007-05
Lake Gaston (VA) EIS 1998. Project manager for the
development of an EIS evaluating alternative Water supply
sources for the City of Virginia Beach. Major issues include
effects on shortnose sturgeon (an endangered
species), water quality and reduced waste assimilative capacity
from the proposed 60 water diversion. Mobilizedand
coordinated 30 multidisciplinary staff from 3 offices in order to
expedite high priority project. Completed DEIS on schedule in
6 months. The FEIS and ROD were appealed to the US Supreme
Court, which upheld the agency decision.
U.S. Army Corps of Engineers, Baltimore District - 1997 - 2002.
Program Director for $4 million multi~year environmental
planning contract involving NEPA documentation, base master
planning and environmental restoration studies
Middle Cuyahoga River Flow Study, Ohio - 2004. Analyzed
effects of 4.2 MGD water iversion by the City of Akron for Water
supply purposes on Water quality, assimilative
capacity, aquatic community, recreation, and aesthetics.
Calculated natural 7Q10 flow using flow data from a surrogate
Watershed. Testified as an expert at a trial in state court.
Clackamas River Hydropower (OR) EIS 2003. Project
Coordinator for third party EIS contract for the 187 MW
Clackamas project for Portland General Electric using the FERC
collaborative process option. Serving as facilitator for Land Use
and Recreation Worgroups. Key issues are endangered
salrnonids and US. Forest Service 4 authority.
Air National Guard, Andrews Air Force Base, MD -- ongoing.
Environmental Planning (NEPA) Program Manager for 10 year
contract _with ANG providing NEPA, master planning, GIS,
and wetland services nationwide. Supervised preparation of
over 20 EA's addressing various airport construction projects,
aircraft conversions, and training exercises.
Camp Murray (WA) EA -- 1999. Coordinated completion of an
EA assessing the environmental impacts of 9 various
construction activities for the Air National Guard. Prepared
Biological Assessed potential impacts to Bald Eagles under
Section 7 of the Endangered Species Act and obtained USFWS
concurrence in less than one month in order to preserve
construction funding.
Deiaha
Jeannette Blank
Wetlands, Terrestrial Vegetation, Wildlife
Jeannette has 14 years of experience as a biologist, and
compliance and permitting specialist for multidisciplinary projects throughout Alaska and the Rocky
Mountain west. She has conducted numerous
vegetation surveys and functional assessments for
wetland, riparian, sage-steppe, grassland and mixed
forest communities within arid, temperate and arctic
ecosystems.
Jeannette also has expertise in environmental permitting
and compliance, with special emphasis on the Federal
Clean Water Act and National Environmental Policy
Act. She has T/E Species evaluation experience. Other
areas of expertise include wetland mitigation,
contaminated soil investigations, revegetation plans,
water quality, wildlife studies, and project health and
safety.
Through her biological and permitting work, she has a
strong foundation in agency collaboration at the federal,
state and local level. At the federal level, she has
worked closely with FHWA, FERC, EPA, USCOE,
USFWS, NPS, USFS, USDA, DOD, NOAA, and BLM. At
the state and local level, she regularly works with
natural resource agencies who oversee water quality,
water quantity, vegetation, wildlife, and habitat
conservation.
Fields of Competence
Wetland delineation & functional assessment
Wetland mitigation
Plant ecology & revegetation
Permitting & Compliance (Clean Water Act)
Biological Assessments & Effects Determinations
(National Environmental Policy Act)
T/E Species Studies
Treatment wetlands
Saline & sodic soils
Water quality
Project health & safety
GIS
Education
MS, Earth Science
Montana State University, 2004
BS, General Science (Biology emphasis)
University of Oregon, 1997
Training and Certifications
Constructed Wetlands for Water Quality Treatment
(Institute for Water Quality Education)
Wetland Delineation (Wetland Science Institute)
Wetland Regulations: Federal, State and Local
Regulations & Permitting in MT (MDEQ/MSU)
BLM Certified Wildlife Biologist
HAZWOPER
DOT/IATA
Key Industry Sectors
Mining
Oil & Gas
Power
Transportation & Construction
Delivering sustainable solutions in a more competitive world
Key Projects
Alaska Pipeline Project Wetland Delineation and
Functional Assessment, AK. Senior Wetland scientist
and field team lead. 2011.
Mapped and evaluated Wetland function along 800--mile
proposed natural gas pipeline corridor for a preliminary
FERC license application. Mapped wetlands using U.S.
Army Corps protocol and survey-grade GPS units with
sub meter accuracy. Assessed Wetland function using
hydrogeomorphic methods and mapped associated
hydrologic features. Worked in remote locations for
multiple weeks per field rotation following bear
awareness and remote team communication protocols.
Performed technical data QC and digitized wetland
maps using ESRI Assisted in development of
GIS-based wetland functional assessment model to
quantitatively evaluate wetland function and value
throughout pipeline corridor. Collaborated on
development and implementation of independent
wetland mapping study tailored to FERC sp ecifications
to evaluate the quality of wetland mapping generate by
the primary project mapping method. Co- authored final
project reports for FERC and USCOE review. Provided
recommendations to Project Engineers regarding Winter
and summer wetland construction techniques.
Biological Assessment for Alaska's Unified Plan.
Biologist and Tfli species specialist. 2012.
Biologist and co-author of species effects and
determination of effects section of a Biological
Assessment report that assesses the potential impacts
oil and hazardous spill response actions may have on
AlasloconMobil's Point Thomson
Project on Alasl