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Weekly UpdatesAs all natural resource extraction businesses know, development of Alaska's assets requires working with a myriad of overseeing government agencies, obtaining numerous permits and complying with vast volumes of regulatory rules.
For Alaska's largest single resource development project, construction and operation of the 800-mile trans-Alaska oil pipeline and its related infrastructure, government agencies that provide the required oversight responsibility have formed a separate, stand-alone organization-the Joint Pipeline Office.
"Prior to TAPS construction, everyone recognized that there would be thousands of permits needed and dozens of state and federal agencies involved," said Rhea DoBosh, communications director at the Joint Pipeline Office. "It benefits the agencies and industry to have a one-stop shop, to ease the difficulty in working the way through the process."
Six state and six federal agencies that share similar regulatory or management responsibilities related to oil and gas pipelines in Alaska make up Alaska's Joint Pipeline Office, headquartered in Anchorage with field offices in Fairbanks and Valdez. Core agencies with management responsibility are the Alaska Department of Natural Resources and the U.S. Bureau of Land Management, as the land managers.
Representatives from six of the 12 agencies are co-located in the main office, working to coordinate oversight of pipelines, and issue right-of-way leases and other permits needed for oil and gas projects. "Some agencies do not need daily contact, so they don't have liaisons, because they don't work with these projects on an everyday basis," DoBosh said. "We have 'as needed' involvement from some agencies."
Heading up the Joint Pipeline Office is the state pipeline coordinator, on the state side; and the Authorized Officer on the federal side. Currently, those positions are held by Mike Thompson and Jerry Brossia, respectively.
Currently, about 65 employees are now working in the Joint Pipeline Office structure. Budgets for the office include BLM's spending, which had a $4.3 million budget for the fiscal year 2005, and $3.1 million for the State Pipeline Coordinator's Office for the fiscal year 2005, according to the 2004-2005 JPO annual report.
Funding for the budgets comes from industry, through a number of memorandum of agreements signed between agencies and developers that define what regulatory work must be completed for each project and what the anticipated cost will be for completion of that work, DoBosh said.
In this, the third evolution of a consolidated governmental entity with regulatory and oversight responsibilities for Alaska's oil pipeline and other oil and gas transportation lines, cooperative agreements have been developed between agencies to share staff, knowledge, equipment and office space. The goal of the Joint Pipeline Office is to eliminate duplication of work, provide a more customer-oriented organization and to simplify complicated and lengthy government processes, according to the organization.
Three key areas of focus for the Joint Pipeline Office are environmental issues, safety issues and integrity issues, DoBosh said.
ANNUAL WORK PLANS DEVELOPED
Each year, the Joint Pipeline Office develops a work plan that includes objectives, authority, strategy, commitments, functions and organizational structure. General objectives sought in the work plan include compliance with the federal grant and the state lease for the pipeline corridor, as well as other relevant state and federal laws, regulations and industry-accepted codes and standards.
Also, JPO strives for continued safe movement of oil through TAPS through risk reduction by understanding hardware condition, ensuring follow-through on Reliability Centered Maintenance (RCM) action items, effective failure planning, and addressing noncompliance promptly.
The agencies also work to protect the environment and public safety through monitoring modification, maintenance and operation of high-risk systems.
JPO requires prompt and effective response to incidents and events on TAPS to assess, contain, correct and clean up damage, as well as to prevent recurrence. Another goal is to sustain a TAPS culture respectful of commitments made to Alaska Natives, diversity and concerned employees.
The agency tracks follow-through on renewal commitments made in the Final Environmental Impact Statement (FEIS) mitigating measures, the Record of Decision (ROD), and the Commissioner's Final Written Determination.
Finally, JPO provides management of TAPS oversight information to provide detailed tracking, trending and reporting capabilities.
THREE-TIERED SYSTEM
The coordinated agency uses a three-tier system for addressing issues, according to DoBosh. The basic or initial step is a surveillance, which typically deals with issues on a specific item or part of a pipeline system.
The next "building block" is an assessment or engineering report, DoBosh said, which typically deals with a broader range of items for the topic of concern.
Finally, a Comprehensive Monitoring Report deals with the pipeline system in a very broad way, she said. Typically it involves a study completed over some time with substantial tracking information and database.
The existing monitoring program identifies deficiencies and establishes formal notification of those deficiencies and correction expectations to Alyeska Pipeline Service Co., imposes correction deadlines, tracks and retains information and verifies results, according to JPO's annual report. Oversight results and reports are generated from electronic records maintained on the program.
GAS LINE APPLICATIONS BEING PROCESSED
As part of the Joint Pipeline Office, the State Pipeline Coordinator's Office section administers 91 pipeline right-of-way leases, including the 800-mile TAPS. BLM administers three right-of-way grants, with TAPS being the only operational pipeline.
Also included in the Joint Pipeline Office is the State Gas Pipeline Group, which is currently processing several right-of-way lease applications. Those include two applications to transport natural gas from Prudhoe Bay to Alberta, Canada, submitted by TransCanada Alaska Co. LLC and the Alaska Northwest Natural Gas Transportation Co.
The JPO group also is processing an application from the Alaska Natural Gas Development Authority for a natural gas pipeline conditional right-of-way lease from Glenallen to Palmer.
Finally, the State Gas Pipeline Group is processing two overlapping conditional right-of-way lease applications submitted in 2006, from the vicinity of Point Thomson to Prudhoe Bay. One application is for a gas pipeline and the other is for an oil pipeline, according to the 2004-2005 annual report of the Joint Pipeline Office.
HISTORICAL VIEW
The roots of the current Joint Pipeline Office can be traced back to 1969, when a technical team within the Department of Interior studied pipeline construction and environmental concerns to come up with construction stipulations and state and federal controls for the trans-Alaska oil pipeline.
In early 1971, when the pipeline utility corridor was established, separate oversight agencies were established. Alaska Pipeline staff were created in Washington, D.C., reporting directly to the director of BLM, with the Division of Pipeline, Alaska State Office, reporting to the BLM Alaska State Director.
Then in 1974, just prior to the start of construction, Alaska's governor established the State Pipeline Coordinator's Office, to ensure the best available environmental and engineering practices were applied to the design and construction of TAPS. The Department of Interior created and established the Authorized Officer in the Department of Interior, shifting BLM's Division of Pipeline personnel to that new position for monitoring pipeline projects. The Alaska Pipeline Office also was established in 1974 within the Division of Pipeline in BLM's state director's office in Anchorage.
In order for construction to proceed, multiple government agencies issued a total of 1,350 permits and 870 Notices to Proceed authorizations under the federal grant and the state lease, according to a JPO chronology.
During the height of TAPS construction in 1975, state and federal organizations employed 184 people. That number decreased in 1976 to 145 employees, and to 125 workers in 1977.
The State Pipeline Coordinator's Office was disbanded in early 1977, when construction was completed on the pipeline. Federal oversight with the Alaska Pipeline Office continued reporting to the Department of Interior, eventually transferring responsibilities to the BLM's Alaska State Office.
CURRENT STRUCTURE
Several reorganizations were made through the years, with the current version of the Joint Pipeline Office established in 1990, influenced primarily by talk of construction of a natural gas pipeline by Yukon Pacific Corp. and the 1989 Exxon Valdez oil spill.
That environmental disaster, which involved spilling 11 million gallons of North Slope crude oil in Prince William Sound, illustrated the need for a continued coordinated regulatory agency, DoBosh said.
"Another key responsibility, right off the bat, was that the agencies hadn't worked as well together during the Exxon Valdez spill as they should have. It was obvious that things could have worked smoother with more coordination," she said. "The spill plans were inadequate, so JPO began working with Alyeska to improve those plans, as one of the first main responsibilities."
Development of the oil spill plan was "a couple hard years of effort ... it's still one of the key areas we handle today," DoBosh said.
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