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Ed Burns's avatar

Excellent article on a very complex subject. You've touched on all the major internal organizational points.

In perhaps a future article, you may want to deal with some of the outside permitting process risk factors, which you've touched on with the recommendation of leveraging "best practices" and "historical data" as internal practice but now adding the need for a forward looking "scouting" effort in order to expose potential delay problems.

Here, and at the top of my own list is the need to develop an early and comprehensive take on the regulatory and approval process potential pitfalls as presented by the governing authorities' own capabilities and manpower constraints, which greatly vary. Additional exogenous forces impacting approval schedules would be the current backlog of competing projects requiring government approval.

Making an early effort to get a good understanding of these influences will be rewarding in setting more realistic schedules and hence, budgets.

As one who has labored for decades in the trenches of large EPC industry project management teams, more recently having been involved in domestic utility transmission & distribution and BESS energy projects, I have seen quite a variation in permitting requirement as our project needs transited from one jurisdictional area to the next.

Best always,

Ed Burns

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Peter Bonner's avatar

Thanks, Ed — Good points about the external factors. Yes, backlog and workload challenges as well as other external factors (e.g, variations in how different agency attorneys interpreted the regs) came up as we did our research. These are very real bottlenecks. It seems few agencies have the data to make good forecasts.

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Ed Burns's avatar

Hello again Peter. Yes, specific historical data is tough to come by and may vary from agency to agency, regardless. However, the discipline of maintaining generic checklists has always proven helpful to me. A checklist of possible permits to be required along with turnaround timeframe would be very useful.

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Sharon F.'s avatar

Peter, it would help if you would share the details of the two projects. I acknowledge that organizing production is important, but I do wonder about the three months to an FEIS. Let's take the three months or 90 days. At least 45 of those are gone for the required comment period, which leaves 45 say 20 for the DEIS and and 25 for response to comments and final. But those days, unlike the comment period include weekends. What about cooperating agency requests, consultation with various regulatory agencies? It would be interesting to compare the two projects in greater depth.

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Peter Bonner's avatar

Thanks, Sharon — I remember they were able to do some concurrent scheduling for review and comment to get to the three months. Let me see about a deeper dive.

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