Environmentalists Push Hard to Use Life Cycle Approach to Scoping

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By Jay Vincent, The Saint Consulting Group

When it comes to scoping for projects needing state or federal permits, the regulatory regime typically requires that a scoping process include study of the impacts on the site and the area surrounding it. But environmentalists want to change that. Instead, they want the scope of the environmental impact statement (EIS) to be so broad as to include all of the potential impacts that may come from the creation of the facility. What they are demanding is a “life – cycle approach”.

So, if it is natural gas power plant under consideration, they want to study not only the site of the power plant but the areas where the natural gas is likely coming from. If it is an export terminal, they want to know where the grains, potash or coal may be coming from and what the impacts are from the mine or farm to the export terminal.

A recent letter from the EPA to the Army Corps of Engineers regarding the EPA’s belief that a “thorough and broadly-scoped cumulative impacts analysis” be conducted on a proposed Oregon coal export terminal is an early victory for environmentalists looking impose a new permitting regime. At a minimum, it is a nose under the tent and one that can have a detrimental impact to the United States economic recovery and long term trading prospects. So what should developers be doing to mitigate this move from the current regime to the life-cycle approach. It is easy.

1. Be open and transparent

2. Don’t be afraid to do EXTRA studies

3. Get out in front by doing studies early even if it means doing them again when the official scoping starts

4. Get out front on health impacts not just the economic impacts

Without the information when the process of public involvement begins, firms will get flat footed because environmentalists will spend short money on studies because they know the credibility it builds in their efforts to stop projects. This is a real area of concern for many clients and the industries we serve as a whole. There are a hundred other things firms can do stop environmentalists from forcing onerous conditions and scoping requirements upon them. If you would like to chat about them please feel free to reach out at vincent@tscg.biz

Jay Vincent is senior vice president for business development for The Saint Consulting Group and business leader for the energy practice.

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