Environmental Permitting for Greenfield Sites

Environmental engineers inspect water quality,Bring water to the lab for testing,Check the mineral content in water and soil,Check for contaminants in water sources.

Greenfield sites and environmental permitting come with a unique set of challenges. From greenfield manufacturing sites to renewable energy projects, one of the biggest hurdles engineers face is navigating the complex landscape of site selection, permitting, and environmental regulations. When project teams fail to address these challenges early, it can result in significant delays in what is usually an aggressive project schedule.

Engaging an environmental consultant during the pre-engineering phase is a critical step in ensuring that your greenfield project stays on schedule. From assessing environmental impacts to navigating local, state, and federal regulations, early planning can help you avoid costly mistakes and unexpected delays.

 

Common Environmental Challenges in the Development of Greenfield Projects

While every greenfield construction project comes with challenges, there are certain obstacles known as “fatal flaws” that can cause everything to come to a halt. These roadblocks can often be avoided by performing an analysis during the site selection and pre-engineering phases of the project. During this comprehensive assessment, your environmental consultant will review several factors that could trigger a “fatal flaw” and affect the viability of potential greenfield project sites.

Water Scarcity

A sustainable water supply, whether from groundwater or surface water, is critical for greenfield sites. Water scarcity can be a limiting factor because it significantly increases costs, which can, in turn, make your project nonviable. Assessing water supply and costs associated with ensuring ample and sustainable access early helps you prepare for any scenario.

Wastewater Treatment

Numerous regulations, including the EPA’s Clean Water Act (CWA), apply to the proper treatment and disposal of wastewater. If your proposed greenfield site does not have the proper infrastructure to handle wastewater, the cost of repairing the issue might require additional financing.

Threatened/Endangered Species (T&E) and Wetlands

Environmental regulations around T&E species affect not only how you can build on a greenfield site but also when you can begin construction. Wetlands in particular can be complex to navigate due to jurisdictional determinations with the US Army Corps of Engineers, the variety of species to be evaluated, and the need to precisely time site preparation around nesting seasons and migration. Your environmental consultant will review all applicable T&E and wetland regulations to define potential issues specific to your construction project.

Historical Land Use

Determining historical land use and cultural significance is complicated by the availability of information, especially in rural areas where detailed records may be nonexistent. The due diligence process involves your engineers and environmental consultant obtaining records from various sources, site reconnaissance, and, when applicable, meeting with government and/or tribal authorities to review project plans.

Both former industrial sites and cultural sites (such as burial grounds) trigger additional regulatory requirements and measures to prepare the land for construction. If the limitations are too significant, the site could be deemed nonviable for your intended use.

Carbon Intensity Review

The carbon intensity of the potential electrical, water supply, and other utility options for your greenfield site should be evaluated to ensure that they meet the carbon intensity thresholds for your whole project.  A qualified environmental consultant should be able to not only calculate the carbon intensity of your proposed operation, but accurately evaluate the carbon intensity of the proposed utilities for the greenfield sites you’re evaluating.

Permitting and Regulatory Complexities

A common misconception is that permits can be obtained within a few weeks before breaking ground at your greenfield project site. In reality, rezoning and environmental permitting can often take a year or more.

Air Permitting Assessment and Submission

The Environmental Protection Agency’s (EPA) Clean Air Act comprises a comprehensive but convoluted set of regulatory requirements, many of which have variations implemented at the state and local levels. Because of this, the air permitting process can be lengthy and complex.

Air emission analyses must occur at the earliest stages possible to define the applicable air permitting regulations and emission factors for the processes involved. Permit modifications are sometimes unavoidable, but remember that each instance can cause further delays to the project.

Submitting too many permit modifications or conflicting information might also cause regulatory agencies to think you are attempting “sham permitting,” which occurs when permit conditions do not accurately reflect the project’s planned mode of operation. This tactic is used to expedite the construction process but ultimately causes delays. A qualified environmental engineering consultant takes the necessary steps to submit the most accurate information possible and ensure the legitimacy of your permit applications.

Local Policies and Community Roadblocks

Even when everything looks clear from a regulatory standpoint, there are issues at the local level that affect whether your project can move forward. The first potential roadblock is zoning and issuing Conditional Use Permits (CUPs). Rezoning can be a lengthy process that extends project timelines. Greenfield projects, even those such as wind farms and solar energy farms, can also be met by local resistance, which can cause significant delays in local officials granting CUP approvals. A qualified environmental consultant should be able to help you prepare to navigate these potential obstacles.

Set Your Project Up for Success by Engaging a Consultant Early in the Process

Waiting too long to involve an environmental consultant can be a costly mistake. By getting the right experts involved during greenfield site selection and pre-engineering, you can identify potential fatal flaws and plan a realistic project timeline that accounts for every regulatory and permitting scenario.

Pinnacle Engineering’s team is skilled in site assessment and environmental permitting for greenfield sites and renewable energy projects. Our team understands the nuances of federal, state, and local regulations and the reporting requirements of government agencies. As a full-service partner, we get involved at the front end of your project to ensure the timely submission of permit applications and provide attainable and sustainable solutions to complex challenges. Request a consultation to get started.