
Licensing Phases and Delays
- Pre-filing consultations (6 months–2+ years): Projects like Swan Lake (P-13318) spent ~3 years in early-stage consultations before submitting final applications.
- Study disputes and information gathering: Mandatory environmental studies and interagency disputes often extend timelines, particularly under the Traditional Licensing Process (TLP) where FERC involvement is limited post-filing.
- NEPA compliance: Environmental review scoping and documentation add 1–3 years, depending on whether projects use the Integrated Licensing Process (ILP) (collaborative pre-filing) or TLP (post-filing reviews).
Process Variability
- Expedited pathways: FERC’s 2020 reforms aim to cap closed-loop PSH licensing at two years post-application, but historical data shows actual durations ranging from 3.6–8.9 years from Notice of Intent (NOI) to license issuance.
- Process type comparison:
- ILP: Collaborative pre-filing, FERC-approved study plans, and pre-emptive dispute resolution theoretically shorten timelines but still face delays (e.g., Eagle Mountain: 6.4 years NOI-to-license).
- TLP: Post-filing reviews and limited FERC oversight often prolong timelines due to conflicting agency requirements.
Post-Licensing Hurdles
- Construction deadlines: All recently licensed PSH projects requested FERC deadline extensions beyond the standard two-year construction start window.
- Additional permits: Projects must secure state water rights, land-use permits, and environmental clearances post-FERC licensing, adding 1–5 years.
Project-Specific Timelines
| Project (FERC ID) | Process Type | NOI to License Issuance | Construction Status |
|---|---|---|---|
| Eagle Mountain (P-13123) | ILP | 6.4 years | Pre-construction, multiple extensions |
| Gordon Butte (P-13642) | ALP | 3.6 years | Pre-construction, extended deadline |
| Swan Lake (P-13318) | ILP | 8.9 years | Pre-construction pending permits |
FERC’s recent reforms aim to streamline closed-loop PSH licensing, but persistent delays stem from study disputes, NEPA reviews, and post-license permitting.
Original article by NenPower, If reposted, please credit the source: https://nenpower.com/blog/how-does-the-licensing-process-impact-the-timeline-of-psh-facility-construction/
