Pipeline Abandonment
US Army Corps of Engineers Galveston District Approves 1st Decommission In-Place Permit Modification for Offshore Pipelines
Per 30 CFR 250.1750, a pipeline may be decommissioned in place when the Regional Supervisor determines that the pipeline does not constitute a hazard to navigation and commercial fishing regulations, unduly interfere with other uses of the OCS, or have adverse environmental effects. Until recently, the Galveston District of the US Army Corps of Engineers enforced a 2001 district policy to uphold general and individual permit language of the original construction permit. In many cases, the original permits dictate that pipelines were to be removed upon termination of use. In March 2016, the District rescinded the 2001 policy citing the policy restricted the agency’s ability to evaluate on a case by case basis and does not consider the agency’s existing evaluation process outlined by 33 CRF Part 325, Appendix B.
Per the newly issued interim guidelines, the USACE will carefully consider requests to modify permits to decommission in place a pipeline by conducting a public interest review and an alternatives analysis documented in accordance with NEPA. At a minimum, the public interest review must address the direct, indirect, and cumulative effects of decommissioning a pipeline in place on factors including, but not limited to, navigation, safety, water quality, federal projects, economics, fish and wildlife values, and general environmental concerns. For these same factors, the USACE must consider the alternative analysis for a minimum of 2 alternatives: 1) Pipeline Removal and 2) the Applicant’s Preferred Alternative or decommissioning in place. A preliminary public interest review and alternatives analysis must be submitted with the request to modify the permit by the applicant and will be published in the Federal Register on a 30-day public notice.
CK is proud to be an integral part of the team which completed an approved permit modification request to decommission a pipeline in place from the USACE Galveston District. CK has 30 years of experience in Department of the Army permitting, which includes modification requests and preparation of detailed environmental assessments and all-encompassing alternatives analyses in accordance with NEPA guidelines.
Our Senior Practitioners
Tre Wharton, is a senior environmental scientist overseeing Biological and NEPA investigations, as well as Regulatory issues including Department of the Army permits for work in wetlands and Coastal Use Permitting for projects located within the Louisiana Coastal Zone.  Mr. Wharton has managed natural resource projects which include a NEPA component requiring an Integrated Natural Resources Management Plan and Environmental Assessment for military installations, and an Endangered Species Management Plan, Environmental Assessment, and a Site-Specific Environmental Impact Assessment (EIA) for the proposed expansion of federal projects. Mr. Wharton is part of C-K’s Environmental Spill Response Program (ESRP).
Wade Bryant Wade Bryant is a Senior Environmental Scientist with CK’s Ecological Team and comes to CK after 25 years of federal service.  Mr. Bryant was a Senior Ecologist with the US Geological Survey for twenty-two years and worked for the US Fish and Wildlife Service Division of Environmental Contaminants and the Division of Refuges.  Mr. Bryant spent 4 years as a science advisor to the Federal On-Scene Coordinator for the Deepwater Horizon Oil Spill.  Mr. Bryant has expertise in the design and implementation of aquatic monitoring programs, wetland ecology, ecological risk assessment, and statistical analysis/modeling.  Mr. Bryant has extensive experience providing technical support to federal agencies including: US Coast Guard, NOAA Office of Response and Restoration, Bureau of Safety and Environmental Enforcement, USFWS Endangered Species Program, Department of Interior Section 106 Compliance Office, and the Department of Justice.
Christina Perez, is an environmental specialist with CK’s Ecological Team. Ms. Perez has prepared environmental impact analyses and environmental assessments for proposed offshore development and offshore pipeline abandonment. Additionally, Ms. Perez has led numerous wetland delineation, stream and habitat assessments, and wildlife survey projects for clients through Louisiana, Mississippi, Texas, Oklahoma, Kansas, and Ohio.  Ms. Perez holds CK’s US Fish and Wildlife Service collection permit for surveys of the endangered American burying beetle (Nicrophorus americanus) throughout Oklahoma, Texas, Arkansas, Kansas, and Nebraska. She has also obtained numerous USACE jurisdictional determinations, Department of the Army permits, and agency concurrences and serves on CK’s Emergency Response Team.
Our Senior Practitioners
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