Integrated Licensing Process

FERC issued a final rule adopting the Integrated Licensing Process (ILP) in July 2003; on July 23, 2005, the ILP became the "default" relicensing process. The ILP is "intended to streamline FERC's licensing process by providing a predictable, efficient and timely licensing process that continues to ensure adequate resource protections" www.ferc.gov. The efficiencies expected to be achieved through the ILP are founded in three fundamental principles:

• Early issue identification and resolution of studies needed to fill information gaps, avoiding studies post-filing
• Integration of stakeholder permitting process needs
• Established time frames to complete process steps for all stakeholders, including FERC (from http.www.ferc.gov)

The ILP has 5 main components:

1. Assemble and issue an information package, also known as a Preliminary Application Document (PAD)
2. Hold public meetings pursuant to the National Environmental Policy Act
3. Consult with state and federal agencies and Native American tribes on studies and develop a study plan for FERC approval
4. Conduct studies
5. Develop a Preliminary Licensing Proposal and File License Application with FERC

Overview of ILP

Pre-filing Steps

1. Applicant Files Pre-application Document (PAD) with Notice of Intent to File License Application (5 to 5.5 years prior to license expiration)
• PAD brings together all existing, relevant, and reasonably available information about the project and its effects on resources; and
• PAD also includes a well-defined process plan that sets the schedule for developing the license application and a list of preliminary studies and issues.
2. FERC Conducts Scoping
• The purposes of scoping are to identify and refine issues, discuss existing information, explore information gaps, and finalize the process plan; and
• Stakeholders discuss the issues and provide study requests that will be consolidated into a “Study Plan”.
3. Applicant Files Proposed Study Plan
• Applicant holds a meeting(s) to discuss the proposed study plan and informally resolve study disagreements;
• Applicant files revised study plan;
• Director of the Office of Energy Projects approves the revised study plan with any modifications after considering all information in the record;
• Agencies with mandatory conditioning authority may request the use of a formal dispute resolution process;
• Applicant conducts the studies as approved;
• Applicant files preliminary licensing proposal with the Commission, agencies, and public for comment;
• Applicant files final license application with the Commission and provides copies to agencies, tribes, and the public; and
• After the application is filed, the Commission has defined time frames to prepare and issue its environmental analysis pursuant to National Environmental Policy Act.

Understanding the Study Criteria

Ideas for Implementing and Participation in the Integrated Liciensing Process