Matrix Comparing Three Licensing Processes
| Integrated Licensing Process (ILP) | Traditional Licensing Process (TLP) | Alternative Licensing Process (ALP) | |
|---|---|---|---|
| Consultation w/ Resource Agencies and Indian Tribes | - Integrated | - Paper-driven | - Collaborative |
| FERC Staff Involvement | - Pre-filing [beginning at filing of Notice of Intent (NOI)] - Early and throughout process |
- Post filing (after the application has been filed) - Available for education and guidance |
- Pre-filing (beginning at filing the NOI) - Early involvement for National Environmental Policy Act (NEPA) scoping as requested |
| Deadlines | - Defined deadlines for all participants (including FERC) throughout the process | - Pre-filing: some deadlines for participants - Post-filing: defined deadlines for participants |
- Pre-filing: deadlines defined by collaborative group - Post-filing: defined deadlines for participants |
| Study Plan Development | - Developed through study plan meetings with all stakeholders - Plan approved by FERC |
- Developed by applicant based on early stakeholder recommendations - No FERC involvement |
- Developed by collaborative group - FERC staff assist as resources allow |
| Study Dispute Resolution | - Informal dispute resolution available to all participants - Formal dispute resolution available to agencies with mandatory conditioning authority - Three-member panel provides technical recommendation on study dispute - OEP Director opinion binding on applicant |
- FERC study dispute resolution available upon request to agencies and affected tribes - Office of Energy Projects (OEP) Director issues advisory opinion |
- FERC study dispute resolution available upon request to agencies and affected tribes - OEP Director issues advisory opinion |
| Application | - Preliminary licensing proposal or draft application and final application include Exhibit E (environmental report) with form and contents of an EA | - Draft and final application include Exhibit E | - Draft and final application with applicant-prepared environmental assessment or third-party environmental impact statement |
| Additional Information Requests | - Available to participants before application filing - No additional information requests after application filing |
- Available to participants after filing of application | - Available to participants primarily before application filing - Post-filing requests available but should be limited due to collaborative approach |
| Timing of Resource Agency Terms and Conditions | - Preliminary terms and conditions filed 60 days after Ready for Environmental Analysis (REA) notice - Modified terms and conditions filed 60 days after comments on draft NEPA document |
- Preliminary terms and conditions filed 60 days after REA notice - Schedule for final terms and conditions |
- Preliminary terms and conditions filed 60 days after REA notice - Schedule for final terms and conditions |