Brian Connaughton, VELCO

1. SECTION 106
CONSIDERATIONS FOR
ELECTRIC INFRASTRUCTURE
PROJECTS
TM
Moving Power. Moving Forward

2. Overview
• Introduction to VELCO
• What are historic,
architectural, archaeological
and cultural resources?
• Preparing for Assessments
• Defining Area of Potential
Effects (APE)
• Identify and Evaluate
• Data Collection
Considerations
• Determining Effects
• Mitigation and Compliance
• Post Construction
Considerations

3. VELCO
• Founded 1956 as nation’s first “transmission only” company
• Assures competitive, equal access for energy providers and our
owners
• Owned by Vermont’s electric distribution utilities
• Project work driven by federally enforceable reliability standards
• Recent electric reliability projects include numerous substations and
high-voltage transmission lines
• VELCO’s transmission system includes:
• Over 700 miles of transmission lines
• 51 transmission facilities (substations, switching stations, etc)
• 12,250 acres of managed ROW
• 600 miles of fiber optic system

5. Cultural Resources

6. Preparing for an Archaeological
Assessment
• Comprehensive Project Understanding
– Route alignment
– Access constraints
– Anticipated impacts
– Schedule and budget
• Have a clear understanding of the regulatory requirements
– Understand the rules and regulations
– Know the regulatory staff and SHPOs
– Have a clear understanding of expectations and requirements
• Evaluate archaeological consulting firms
– Ensure availability of field crews
– Relevant project experience
– Review and understand overall approach
– Develop a team

7. Section 106 Process
• An "undertaking" means a
project, activity, or program
funded in whole or in part under
the direct or indirect jurisdiction of
a federal agency. "Federal"
means under the jurisdiction of a
federal agency
• Make sure you know if your
project requires a Federal
undertaking and what Federal
agency is the “Lead Agency”

8. Defining the
Area of Potential Effects (APE)
• Geographic area or areas
within which an undertaking
may directly or indirectly cause
alterations to the character of
historic sites and/or properties,
if any such areas exist.
• Seek input from project team in
the development of the APE to
ensure that it is accurate and
will meet all project needs.
– Include all project areas
• Changes to the APE during
permitting and/or construction
can be costly and cause
delays.

9. Identify and Evaluate
• “Scoping” or “accessing
information needs.”
• Seek information from
knowledgeable individuals,
organizations and tribes.
• Make a “reasonable and
good faith effort” to identify
historic properties.
• Determine whether historic
properties are eligible for
the National Register.

10. Evaluate risk of encountering
archaeological resources when making
siting decisions

11. Data Collection Considerations
• Use all project data to support archaeological SOW
development/assessment
– Environmental data
– Accurate topographic information
– Information from company files
• Data collection must be phased so that it can “build” upon itself
– Topographic surveys will support wetland and stream assessments
– Wetland, stream and topographic information is then provided to
archaeologists to support the sensitivity assessments
– Resource assessment scheduling and data management is critical
• Why is this important?
– Develop a comprehensive and accurate SOW
– Ultimately reduces costs and time associated with archaeological
assessments

12. Cultural Resource Field Surveys
• Level of effort
– Time & Costs
– Use company staff to support (e.g.
reviews of access, etc.)
• Field Work Considerations
– Scheduling and field conditions
– Access Constraints
– Capabilities of work crews
• Data collection
– Develop standards
– Accurate data is extremely
important
• Reporting & Management
• Reviews of reports and other
deliverables
• Early and frequent coordination with
regulatory agencies

13. Determining Effect
• Consult with Lead
Federal Agency
– Comments from SHPO,
tribes, regulators, and
interested parties
• Make finding – no historic
properties affected or no
adverse effect
• Federal Agency (as
appropriate) makes the
final judgment
• Document results
• Involve the public and
make findings available

14. Site Avoidance

15. Impact Mitigation
• Seek agreements on how
adverse effects will be
resolved
• Memorandum of
Agreement executed upon
signature of consulting
parties
• Negotiating Reasonable
Permit Conditions
• Consider on-going work
practices associated with
maintenance crews
• Control and track
commitments

16. Construction and Compliance
• Managing Identified
Cultural Resources
• Project Trainings
• Implement Impact
Mitigation Measures
– Matting, suitable ground
conditions, etc.
• Vehicular Barriers
• Monitoring/Oversight
• Reporting and Agency
Inspections
• Establish company
procedures

17. Compliance Plans

19. Final Thoughts and Questions
• Consult early and
often
• Be engaged
• Clearly define the APE
• Quality data is a
necessity
• Avoidance is preferred
– Be creative
• Consider maintenance
constraints