Geothermal Regulatory Roadmap Project Review

exhaustedcrumMechanics

Oct 24, 2013 (3 years and 8 months ago)

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1

| US DOE Geothermal Program

eere.energy.gov

Public Service of Colorado Ponnequin Wind Farm

Geothermal Technologies Program

Geothermal Regulatory Roadmap

Project Review

Doug Hollett

Geothermal Technologies Program
Manager

Kate Young

NREL Principal Investigator





April 25, 2013

2

| US DOE Geothermal Program

eere.energy.gov

Status Update


Roadmap Content


Analyses


Web Interface


White Papers


Moving Forward

Meeting Agenda

3

| US DOE Geothermal Program

eere.energy.gov

Colorado


Colorado agency/industry review: March 6, 2013


Completed


through agency and legal review


Now available online


Texas


Texas agency/industry review: planned June 12, 2013


Content currently under development

GRR Content

Technol ogy

Whi te Papers

Web Interface

Roadmap

Future Pl ans

Permi tti ng Anal ysi s

4

| US DOE Geothermal Program

eere.energy.gov

GRR Content:

Colorado Permitting Concerns

Uncertainty

Since geothermal is so new to this state, state agencies (e.g. Department of Water
Resources) aren’t quite sure how they will handle every situation.

This causes angst and
misunderstanding with the general public (they think there are requirements that may or
may not be there, and are insisting the developer follow these "ideas”)

Leasing

State Land Board has not formalized their renewable energy leasing process
-

there are no
resources online or guidance for how to obtain a lease.

Plan to present recommendations
to the State Land Board soon (in April?).


Geothermal
Resource

is the heat, but does not include water
-

for example, EGS heat okay.

Water rights must be
obtained independently.

Tributary vs.
Nontributary

Status

DWR and CGS have suggested that a developer WANTS their resource to be tributary
because a
nontributary

source is limited by surface ownership, and by total volume
available by law (calculated 100
-
year life).

There would never be enough water in a non
-
tributary water right that is tied to land ownership for an ecumenically viable power plant.

Geothermal Well

Permitting

current process assumes non consumption of the tributary (see previous bullet) water.

If
any of it is consumptive, DWR is not yet sure how it will be handled
-

how to obtain a water
right.

NREL is working with DWR to flesh out that portion of the flowchart.

County Regulations

(1041 Permits)


Allows the counties to develop their own geothermal permitting and regulations
-

relates to
siting and zoning.



The state has received grant money for suggested guidelines which are in process and
scheduled for draft release March 15, 2013.

Flow charts will be developed as part of 1041
regs

and could be incorporated into the geothermal road
-
mappi ng effort.


In some areas, while 1041 permits are in the process of development a moratorium on
development has been adopted. (e.g. Chaffee County)

Technol ogy

Whi te Papers

Web Interface

Roadmap

Future Pl ans

Permi tti ng Anal ysi s

5

| US DOE Geothermal Program

eere.energy.gov

NREL/DOE

Industry

Agencies

Congress

Agencies

OUTCOMES

Develop
Framework

Collect Data

Conduct
Analyses

Develop
Language

Enact
Law/

Policy

Reduce Permitting
Time

Lower
LCOE

Increase
# of
Projects

Increase
Deployment

FY12

FY13

FY14

and

Beyond

Identify
Game
Changers


Reduce NEPA
permitting time


Centralized location
for all permitting


Cost Recovery/


Permit Fees

Analyze effectiveness of
currently operating centralized
permitting

Collect NEPA data and conduct
analysis

Provide analysis of successful
cost recovery programs

Industry

Agencies

Congress

Agencies

Bring People
Together

Permitting Analyses

Technol ogy

Whi te Papers

Web Interface

Permitting Analysis

Future Pl ans

Roadmap

6

| US DOE Geothermal Program

eere.energy.gov

Technol ogy

Whi te Papers

Web Interface

Permitting Analysis

Future Pl ans

Roadmap

Permitting Analyses:

Permit Coordination Office

Jurisdiction

Agency

Year
Started

Technology

Statute/Policy

Comments

Hawai’i

Hawai’i

Department of
Business,
Economic
Development, and
Tourism (DBEDT)

2008

Renewable

Energy as
defined in HRS
269
-
91

HRS 201N

Statute has 14

sections; plus 19
sections of
administrative
rules

The

DBEDT creates a permit
plan with the developer and

makes themselves

the accepting
agency for HEPA to help
circulate the information in the
Final EIS to all relevant agencies
more quickly.

Alaska

Alaska

Department of
Natural Resources

Office of Project
Management and
Permitting

1980

Large

Natural
Resource
Projects

AS 38.05.020(b)(9)

Statue receives
one

line within one
section of the
statute.

DNR

Commissioner can
coordinate the permitting and
review of large natural resource
projects. DNR recently began to
explore using the process for
“alternative energy.”

California

California
Renewable
Energy Action
Team (REAT)

2008

Solar and Wind

Executive Order #
S
-
14
-
08

Primarily for Mojave and
Colorado Desert regions

to help
meet California RPS.

Federal BLM

Regional BLM
Renewable

Energy Offices

Varies

by
office

Renewable
Energy

Policy

Documents

Office

is established and
implemented individually by each
BLM regional office.

Federal BLM

Regional BLM Oil
& Gas Pilot
Program Offices

2005

Oil and Gas

EPAct

2005

Started 7 offices. They

have
been so successful, that they are
developing 2 additional offices.

7

| US DOE Geothermal Program

eere.energy.gov

Analysis Suggestions?


Suggestions for current analyses?


Other ideas for analyses?


Anything else?

Technol ogy

Whi te Papers

Web Interface

Permitting Analysis

Future Pl ans

Roadmap

8

| US DOE Geothermal Program

eere.energy.gov

Technol ogy

Whi te Papers

Web Interface

Permitting Analysis

Future Pl ans

Roadmap

Permitting Analyses:

Cost Recovery Mechanisms

Statute/Policy

Authority

Agency

Resource Programs

Independent Offices
Appropriations

Act
of 1952

Federal Agencies are authorized to Charge processing

costs

All

All

Federal Land Policy
Management Act of
1976, Sec. 304

Specific Authorities to charge fees for processing
applications and

other documents related to public lands

BLM

Reality (Solar , Wind),
Geothermal, Oil and Gas,

Coal, Nonenergy leasable
minerals, Mineral materials,
Mining law

Energy Policy Act of
2005, Sec. 234

Provides for

25% of geothermal revenues made available to
DOI for implementation of Geothermal Steam Act
amendments for a period of 5 years, without FY limitation or
appropriations for a period of 5 years

DOI

Geothermal


Department of

Interior
Appropriations, FY
2010


Requires

BLM to collect a $6,500 APD Processing Fee

BLM

Oil

and Gas

43

CFR 3000
-
3870:
annually adjusted

Oil and Gas Leasing; Geothermal Resources Leasing; Coal
Management; Management of Solid Minerals other than
Coal; Mineral Materials Disposal; and Mining Claims Under
the General Mining Laws

BLM

Geothermal, Oil and Gas,

Coal, Nonenergy leasable
minerals, Mineral materials,
Mining law


9

| US DOE Geothermal Program

eere.energy.gov

Analysis Suggestions?


Suggestions for current analyses?


Other ideas for analyses?


Anything else?

Technol ogy

Whi te Papers

Web Interface

Permitting Analysis

Future Pl ans

Roadmap

10

| US DOE Geothermal Program

eere.energy.gov

Technol ogy

Whi te Papers

Web Interface

Permitting Analysis

Future Pl ans

Roadmap

Permitting Analyses: NEPA Data

NEPA Data


Populating a catalog of more than


150 recent geothermal NEPA documents


NEPA

documents collected
from:



BLM, USFS, BOR, DOE


Includes all phases of
development:







Information
can be sorted, analyzed and compared by
different criteria, such as by type of planned activity,
by state or field office, by type of NEPA document


Land Use Planning

Exploration

Well Field

Power Plant

Transmission

11

| US DOE Geothermal Program

eere.energy.gov

NEPA:

List of Suggested Data to Collect

Administrative Data


Agency (State, Office, Document
Number/Serial Number, leases)

Project Data


Applicant, Project Name, Project
Type (Exploration, Drilling/Field
Development, Utilization)



Scope (brief narrative)

Type of Analysis


Casual Use


Determination of NEPA
Adequacy


Categorical Exclusion


Environmental Assessment


Environmental Analysis





Consultation, Special Interest and
Concerns


Wildlife: Critical Habitat, Special
Status Species


Cultural Resources


Visual Resources


Timelines/Action Dates


Application date


Public Notice


Decision


Processing Time

Technol ogy

Whi te Papers

Web Interface

Permitting Analysis

Future Pl ans

Roadmap

12

| US DOE Geothermal Program

eere.energy.gov

1. Provide data for



future NEPA Analyses

User Story

BLM field office receives application for a reflective seismic survey. Agency personnel,
including geothermal permit processing agent, specialists (biologist, cultural specialist,
etc.) are unfamiliar with reflective seismic surveys or their potential impacts.

Database Input


Users search for “reflective seismic survey.”


Basic information is provided about the survey, including how it is conducted,
timeframes, output information, etc.,


Links are provided for further information and potential “training” (videos,
presentations, papers, etc.)


Lists of previous NEPA analyses conducted for reflective seismic surveys are listed,
including dates, timeframes, locations, impacted species and stipulations

Impact

The collection of this information helps to:


Reduce misunderstanding about potential activity impacts


Provide consistency among NEPA analyses conducted for similar activities


Potentially reduce time required to determine impacts and stipulations


Technol ogy

Whi te Papers

Web Interface

Permitting Analysis

Future Pl ans

Roadmap

13

| US DOE Geothermal Program

eere.energy.gov

2. Aid in Development of



Categorical Exclusions

Definition

Categorical exclusion means a category of actions
which do not individually or cumulatively have a
significant effect on the human environment ... and
... for which, therefore, neither an environmental
assessment nor an environmental impact statement
is required.


40 CFR 1508.4

Note that a categorical
exclusion can
significantly

reduce NEPA time requirements


Typical CE

3 months


Typical EA

10 months

Categorical exclusions (CEs) are actions which meet the definition contained in 40 CFR
1508.4, and,
based on past experience with similar actions
, do not involve
significant environmental impacts. They are actions which: do not induce significant
impacts to planned growth or land use for the area, do not require the relocation of
significant numbers of people; do not have a significant impact on any natural, cultural,
recreational, historic or other resource; do not involve significant air, noise, or water quality
impacts; do not have significant impacts on travel patterns; and do not otherwise, either
individually or cumulatively, have any significant environmental impacts.

23 CFR 771.117(a)


Technol ogy

Whi te Papers

Web Interface

Permitting Analysis

Future Pl ans

Roadmap

14

| US DOE Geothermal Program

eere.energy.gov

2. Aid in Development of



Categorical Exclusions


C
ategorical exclusions (CX) are developed based on previous
experience, so collecting information from existing geothermal NEPA
documents for similar actions (e.g. specific exploration or drilling
activities) can be the basis for development of categorical exclusions for
geothermal.


CXs can be:


Implemented by administrative policies


Mandated by congress (Sec. 390 EPAct of 2005 for O&G) or through
agency regulations.


Developed during land use planning process and within NEPA
documents for multiple well and development projects, that provides
for the use of individual CXs or determination of NEPA adequacy
(DNA).


Providing the upfront data collection and analysis can provide the federal
agencies the data needed for development of categorical exclusions.

Technol ogy

Whi te Papers

Web Interface

Permitting Analysis

Future Pl ans

Roadmap

15

| US DOE Geothermal Program

eere.energy.gov



BLM

USFS

DOE

USGS


Activity

O&G

Geothermal

O&G

Geothermal

Geothermal


---


Agency Activities


Land
Use Planning

EIS

EIS

---

---


Leasing

EA/DNA

EA/DNA

---

---



Geophysical
Exploration (including TGWs
)



No
new roads

CX
1

CX
3

CX
4

CX
6


Up
to 1 mile of new roads

EA/DNA
1

CX
3

EA/DNA

??



Drilling
Permits (into the reservoir)




Exploration wells

EA/DNA

CX
2

EA/DNA

EA

---


Development wells

CX
2

EA/DNA

CX
2

EA/DNA

NA

---


Infill
wells

CX
2

EA/DNA

CX
2

EA/DNA

CX
4

---



Other Activities


Off
-
lease
Pipeline

CX
2

EA/DNA

CX
2

EA/EIS

---

---


Utilization/Operation

EA/EIS

EA/EIS

EA/EIS

EA/EIS

CX
4,5

---


Minor
Maintenance

CX
2

EA/EIS

CX
2

EA/EIS

---

---

1
DOI Department Manual 516 11 (6)

2
EPAct 2005, Title III
-
Oil and Gas, Sec. 390
-
& BLM IM 2005
-
247

3
32 CFR 220.6(e)(8)

4
10 CFR 1021 (b)

5

Small facilities only

6

DOI
Department Manual 516
6.5


Technol ogy

Whi te Papers

Web Interface

Permitting Analysis

Future Pl ans

Roadmap

Permitting Analyses: NEPA

16

| US DOE Geothermal Program

eere.energy.gov

Technol ogy

Whi te Papers

Web Interface

Permitting Analysis

Future Pl ans

Roadmap

16


What links here Related changes Upload file Special pages Printable version Permanent lin
k Browse
properties

NEPA Document: EA at
Brady Hot Springs
(
DOI
-
BLM
-
NV
-
W010
-
2012
-
0057
-
EA)


General

NEPA Document Info

Technology

Geothermal Energy

Document Type

Environmental
Assessment


Applicant

Brady Power Partners

Consultant

Agency

Geothermal Area

Brady Hot Springs
Geothermal

Area

State

NV

Project Phase

Well Field
Development

Techniques

Hydro
-
Shearing

Comments

DOE/BLM Staff

Time Frames (days)

Lease to Application

Application Time

Process

Time

Total

Time

Participating

Agencies

Lead Agency

BLM

Managing

Field Office

Winnemucca

Funding Agencies

DOE

Surface Manager

BLM

Mineral Manager

BLM

Selected Dates

Lease Date

Pre
-
Application Meeting Date

Application

Date

Application

Document

NOI Date (EIS) Federal Register

Revised Application Date
Comments

Date Scoping Initiated

Preliminary EA/EIS

Final EA/EIS

Decision Document

Relevant

Numbers

Lead Agency Document Number

DOI
-
BLM
-
NV
-
W010
-
2012
-
0057
-
EA

Funding

Agency Document
Number

DOE/EA
-
1944

Funding Number

DE
-
PS36
-
08GO98008

Serial

Number/Case File
Number

N
-
65561

Lease Numbers

NVN 065558

CX Reference

NA

Tiered Document

DOI
-
BLM
-
NV
-
020
-
05
-
07
-
EA


Proposed Action


Ormat’s

well 15
-
12, l ocated north of the Hot Springs Mountains, approximately 50 mi l es
northeast of Reno, in Churchill County, Nevada; T. 22 N., R. 26 E., sec. 12 (Fi gure 1), was
i nstalled i n April 2007 to serve as a production well; however, further testing revealed that the
wel l does not have sufficient hydraulic connections with the geothermal reservoir and i t has
si nce remained i nactive.
Ormat

proposes to implement a hydro
-
stimulation program (EGS) to
i ncrease energy production by enhancing natural hydraulic connections within the existing
hydrothermal system. Hydro
-
stimulation i nvolves creating better hydraulic connections by
i njecting cool geothermal water (temperatures ranging from 90
-
140
°
F) to further open the
exi sting network of minute cracks i n the rocks deep underground, where natural fractures
al ready occur. During the process, geothermal water produced from the geothermal production
wel ls and processed at the geothermal plant would be i njected at wellhead pressures less than
1,400 pounds per square inch at depths ranging from approximately 4,245 to 5,096 feet below
ground surface. The stimulation plan outlines the i njection of cool geothermal water i nto three
verti cal intervals at varying pressures over a period of approximately three weeks. The increase
i n pressure would also accompany a pulsing of the rate of i njection. Tracer compounds would
be i njected at specific times during the stimulation to identify movement of geothermal fluid in
real time. Additional details are provided in the Tracer Testing section
of the report.



Applicant
-
Proposed Environmental Protection Measures





Impacts



Mitigation




Conditions of Approval








GEOTHERMAL POWER

Link to Document:
https://www.blm.gov/epl
-
front
-
office/projects/nepa/34003/42110/44613/2013
-
1
-
11_Brady_Hydro
-
Stimulation_EA.pdf



17

| US DOE Geothermal Program

eere.energy.gov

Areas(2)

Regions(0)

Activities (9)

17


What links here Related changes Upload file Special pages Printable version Permanent lin
k Browse
properties

Details

Geothermal Technique: Hydro
-
Shearing

GEOTHERMAL ENERGY

NEPA (2)

Docume
nt #

Document

Type

Project Phase

Project
Activities

Applicant

Decision Date

Total Time
(days)

DOI
-
BLM
-
NV
-
W010
-
2012
-
0057
-
EA

EA

Well Field
Development

Hydro
-
Shearing

Brady Power
Partners

11/20/2012

320


Technol ogy

Whi te Papers

Web Interface

Permitting Analysis

Future Pl ans

Roadmap

18

| US DOE Geothermal Program

eere.energy.gov

Analysis Suggestions?


Suggestions for current analyses?


Other ideas for analyses?


Other ideas for displaying results?


Anything else?

Technol ogy

Whi te Papers

Web Interface

Permitting Analysis

Future Pl ans

Roadmap

19

| US DOE Geothermal Program

eere.energy.gov

Technical White Papers

Task Description:

Develop technology characterizations of geothermal technologies to help
educate agency personnel on the technical details, field operations,
environmental impacts and permitting issues.


General Outline:


1.
Introduction

2.
Technology Description


2.1 Technology Overview


2.2 Technology Features

3.
Environmental Impacts and Permitting Issues


3.1 Environmental Impact Screening Criteria


3.2 Potential Environmental Consequences


3.3 Permitting Requirements and Issues






Future Pl ans

Roadmap

Permi tti ng Anal ysi s

Technical White Papers

Web Interface

20

| US DOE Geothermal Program

eere.energy.gov

Technical White Papers
-

Topics

FY13 White Paper Topics

FY14
White Paper Topics

Hydraulic Stimulation:


Multi
-
Stage Stimulation


Zonal Isolation


Diverters


Chemical Stimulation

Downhole
Fluids:


Stimulation Fluids


Tracers


Working Fluids


Nanotechnologies

Production
Drilling and

Well Completion:


Drilling
Muds


Casing


Cementing


BOPs


Injection Wells


Advanced Drilling Techniques


Step
-
Outs


Lateral/Horizontal Drilling

Geophysical
Surveys:


Seismic


MT


Gravity



Reservoir
Engineering:


Well Characterization Techniques


Flow Tests


Down
-
hole
Methods


Induction of
Fluid
Flow

Exploratory
Drilling:


Temperature Gradient Holes (TGH)


2M Probe
Surveys


Slimhole

Drilling

Produced
Fluids


Re
-
Injection


On
-
Site
Treatment


Shipment for T
reatment

Geoscientific

Surveys


Geological


Human Observation


Geochemical


Remote
Sensing

Other Stimulation:


Chemical Stimulation


Explosive Stimulation


Rock Mechanics


Fracture
Propagation







Future Pl ans

Roadmap

Permi tti ng Anal ysi s

Technical White Papers

Web Interface

21

| US DOE Geothermal Program

eere.energy.gov

Task

Time

Frame

Due
Date

Responsible Entity

J

F

M

A

M

J

J

A

S

Team Kick Off Meeting

1 day

Week of
1/22/2013

All entities

Develop Technical
Working Paper Construct

3 Weeks

2/15/2013

New West with support from
NREL

Finalize List of Paper
Topics

3 Weeks

2/15/2013

DOE, in
consultation
with BLM,
USFS, and DOD, and with
support from New West and
NREL



Data Collection and
Analysis for Paper #1

2 Weeks

3/1/2013

New West with support from
NREL

Draft Technical Working
Paper #1

5 Weeks

4/5/2013

New West with support from
NREL

DOE and partner agency
review of Paper #1

2 weeks

4/19/2013

DOE, in consultation with BLM,
USFS, and DOD

Incorporate Comments
and Finalize Paper #1

3 Weeks

5/10/2013

New West with support from
NREL

Data Collection and
Analysis for Papers #2
-
5

5 weeks

5/24/2013

New West with support from
NREL

Draft Technical Working
Papers #2
-
5

8 weeks

7/19/2013

New West with support from
NREL

DOE and partner agency
review of Papers #2
-
5

3 weeks

8/9/2013

DOE, in consultation with BLM,
USFS, and DOD

Incorporate Comments
and Finalize Papers #2
-
5

2 weeks

8/22/2013

New West with support from
NREL

Publish and Distribute
Papers #1
-
5

3 week

9/12/2013

DOE with support from New
West/NREL

Technical White Papers Schedule

April 25, 2013

22

| US DOE Geothermal Program

eere.energy.gov

White Paper Suggestions?


Suggestions for current topics?


Other ideas for outlines?


Anything else?

Future Pl ans

Roadmap

Permi tti ng Anal ysi s

Technical White Papers

Web Interface

23

| US DOE Geothermal Program

eere.energy.gov

Web Interface: Updates

Technol ogy

Whi te Papers

Web Interface

Future Pl ans

Roadmap

Permi tti ng Anal ysi s

Recen
t Updates to
OpenEI


Link to roadmap from Geothermal Gateway


Roadmap
pages now are available: by state, by
technology


Makes documents more accessible


New pages will be the support behind the new
web interface


Wizard interface (
Turbo
-
Tax
-
like interface)


in
process; plan to have mock
-
ups by next
quarterly meeting

24

| US DOE Geothermal Program

eere.energy.gov

Web Interface: State Pages

Technol ogy

Whi te Papers

Web Interface

Future Pl ans

Roadmap

Permi tti ng Anal ysi s

25

| US DOE Geothermal Program

eere.energy.gov

Web Interface: Technology Pages

Technol ogy

Whi te Papers

Web Interface

Future Pl ans

Roadmap

Permi tti ng Anal ysi s

26

| US DOE Geothermal Program

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Finalize paper #1 (Hydraulic Stimulation)


Draft and finalize papers #2
-
5

Upcoming Plans

Technol ogy

Whi te Papers

U
pcoming

Plans

Roadmap

Permi tti ng Anal ysi s

Web Interface


Finalize Texas roadmaps


Meet with Texas agencies/industry


Legal review with BHFS

Roadmap


Finish agency personnel interviews


Draft papers for GRC

Analysis


Clean and upload NEPA document metadata


Collect similar information for oil & gas


Analyze data and draft GRC papers with results

NEPA

White
Papers


Continue to add general information for each of the roadmap areas


Add data to the state pages to query on each technology page


Continue development of wizard interface, walking users through permit
trigger questions

Web
Interface