North American Oil & Gas Pipelines

JUN 2018

North American Oil & Gas Pipelines covers the news shaping the business of oil and gas pipeline construction and maintenance in North America, including pipeline installation methods, integrity management innovations and managerial strategies.

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Page 27 of 43

28 North American Oil & Gas Pipelines | JUNE 2 018 tract pollinators and require less mow- ing and maintenance. Doing the right thing sometimes comes with its own set of challenges. For example, one challenge comes with the creation of habitat suitable for endangered species or species likely to be listed as endangered. The monarch butterfly, one of the most recognizable pollinator species, uses early successional habitats that are established by IVM practices. The butterfly leaves its Mexican winter home in March and migrates all the way to Canada and the northern U.S. states, breeding multiple generations along the way. They are facing challenges that may result in an endangered species listing in 2019. But NiSource and other companies have joined with the University of Illinois at Chicago in a voluntary conservation program to proactively enhance habitats while allowing necessary infrastructure maintenance activities. Voluntary Prevention A voluntary conservation program can help prevent the monarch butterfly from being listed on endangered species lists — and avoid the problems found in Indiana regarding bats. Creating or promoting certain habi- tats on rights of way for species that are endangered or likely to become endangered could seem like a risky plan. The reality is that any right of way, intentionally managed for polli- nator habitat or not, can potentially be monarch habitat. Should the mon- arch butterfly be listed as an endan- gered species, any work taking place on the right of way, whether on the pipeline facility itself or the vegeta- tion, may impact the species. Those familiar with the clearing re- strictions related to the endangered Indiana bat understand the challenges all too well. With much of the pipeline right-of-way in the butterfly's range, listing the monarch as threatened or endangered could impact operators and how they maintain their right of way especially in areas specifically de- signed to create new habitat. The U.S. Fish & Wildlife Service runs a voluntary program called the Candidate Conservation Agreement with Assurances, or CCAA. This is a tool that provides regulatory assurances to property owners, including easement holders, who voluntarily agree to manage lands so that threats to the potential endangered species are removed or reduced. A company that signs a CCAA with the Service is issued an enhancement- of-survival permit that provides the property owner with the assurance that they will not become responsible for additional conservation measures and will not incur additional future regulatory obligations if the covered species is listed under the Endangered Species Act. The property owner is only responsible for implementing and maintaining the conservation measures that they agree to in the CCAA. When evaluating the CCAA the U.S. Fish & Wildlife Service must determine that the benefits of the conservation measures to be implemented by a property owner under a CCAA, when combined with those benefits that would be achieved if the conservation measures were also to be implemented on other necessary properties, would preclude or remove the need to list the covered species. Applicants must only address those threats or the portion of the threats that they can control on the property enrolled in the CCAA. These threats are defined as covered activities and should include any operations and maintenance items that must take place on the right of way. To address the threats property owners can protect, manage and/or enhance existing populations or habitats on the enrolled property. IVM is one of the primary conservation measures that can be employed on rights-of-way to meet the requirements of the CCAA. The listing decision for whether the monarch butterfly is listed is coming in June 2019 and covers a range that in- cludes most of the United States. Like- minded organizations whose facili- ties are located on rights-of-way have pooled their resources to begin devel- opment of a CCAA. This type of agree- ment will allow individual applicants to work under a central plan. With guidance from the U.S. Fish & Wildlife Service, the Right-of-Way as Habitat Working Group led by the Uni- versity of Illinois at Chicago's Energy Resources Center is working with right of way managers from many industries on the development of a draft CCAA. This opportunity is available to utili- ties, oil and gas pipelines, railroads, De- partments of Transportation and any other industry with right-of-way inter- ests. The group is currently on track to have the draft completed and approved prior to the listing decision next year. Proponents of the monarch butter- fly are encouraging an all-hands-on- deck approach to help support recov- ery efforts. By getting coverage under a CCAA and using IVM as the primary conservation measure to create and enhance monarch butterfly habitats, companies will be able to meet the eco- logical goals along with the integrity management requirements that drive the company in its efforts to deliver their product safely and efficiently. Kelly Carmichael is vice president of environmental at NiSource, where he leads environmental policy, permitting and compliance, as well as sustainability functions. Utility and pipeline companies are increasingly recognizing the value of supporting pollinator conservation. Managing rights of way for habitat contributes to a company's sustainability and biodiversity metrics and provide a positive outcome for nearby communities.

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