The Office of Energy Projects finalized the Federal Energy Regulatory Commission’s (FERC) Guidance for Horizontal Directional Drill Monitoring, Inadvertent Return Response, and Contingency Plans (HDD Guidance).
After FERC released its draft of the HDD Guidance, they “received comments from 15 entities including natural gas pipeline companies, engineering consulting firms, trade organizations, environmental interest groups, and state environmental departments.” Those led FERC to make revisions to address those comments. The comments that “either were too location-specific, were already adequately/accurately addressed as written, or regarded topics that were not relevant to the HDD Guidance” were not included in the modifications.
“The HDD Guidance is intended to assist the industry with preparation of their project HDD plans for FERC staff review.” FERC stressed that the “guidance does not substitute for, amend, or supersede the Commission’s regulations under the Natural Gas Act of 1938 or the Commission’s and Council on Environmental Quality’s regulations under the National Environmental Policy Act.” It does not grant additional rights or impose new legal obligations.
“The purpose of this guidance is to describe the technical components of an HDD Plan including drilling fluid composition and management, monitoring procedures, and response procedures for an inadvertent return of drilling fluid to the ground surface (IR).” They also provided an outline for an HDD Plan, which is formatted into “an effective presentation based on our experience, but is not mandatory and may be modified (including the use of footnotes where necessary for clarification) for individual projects.”