Collectively, the three agencies manage tens of thousands of circuit miles of transmission lines; hundreds of substations and switchyards; and thousands of miles of access roads and numerous communication sites. Communication sites are used both for personnel to communicate and for remote grid operations. These facilities are vital for the stable and reliable delivery of electricity. Maintenance of this transmission infrastructure is critical to ensure the reliable and safe flow of electricity in the 29 states in which the agencies operate (Arizona, Arkansas, California, Colorado, Idaho, Iowa, Kansas, Kentucky, Louisiana, Minnesota, Missouri, Montana, Nebraska, Nevada, New Mexico, North Carolina, North Dakota, Oklahoma, Oregon, South Dakota, Texas, Utah, Virginia, Washington and Wyoming).
Federal agencies are required to comply with the regulations (36 CFR Part 800) implementing Section 106 of the National Historic Preservation Act for each of their maintenance undertakings. The standard practice is to implement individual programmatic agreements for each project, but a nationwide programmatic agreement is a viable alternative. Given the scale of the assets requiring maintenance and the number of repetitive projects undertaken on an annual basis, federal regulatory compliance could become more efficient using a nationwide programmatic agreement.
A nationwide programmatic agreement would outline a consistent Section 106 review process across the agencies’ service areas. It would also allow more focus on complex undertakings with a greater likelihood of triggering an adverse effect.
The proposed agreement would address:
- Routine operations and maintenance of transmission lines and substations (e.g., projects to replace damaged or degraded poles or transmission structures, improve landings, helicopter landing zones and staging areas, and remove impairments)
- Routine operations and maintenance of communications sites (e.g., projects to replace antennae, repair structures, repair or install fiber optic cable, and replace/install communications equipment in existing facilities).
- Access road repair and improvement (e.g., projects to replace culverts, remove ruts from roads, widen roads, add gravel to roads, access gate upgrades and clear ditches)
