Managing Hydropower Project Exhibits (2014)

MANAGING HYDROPOWER PROJECT
EXHIBITS
Guidance Document

Federal Energy Regulatory Commission
Office of Energy Projects
Division of Hydropower Administration & Compliance
888 First Street, N.E.
Washington, DC 20426

August 2014

TABLE OF CONTENTS
Introduction ....................................................................................... 1
Exhibit Drawings ............................................................................... 2
Preliminary Permits .......................................................................... 2
Exemptions ........................................................................................ 2
License .............................................................................................. 3

Preliminary Permits and License Applications .................................. 4
Exhibit Drawing Details ..................................................................... 4
Drawing Formats ............................................................................... 5
Aperture Cards (Microfilm) .............................................................. 5
Electronic Files (Raster Data) ........................................................... 5

GIS Data Requirements ......................................................................7
Project Boundary Data (Polygon/Point Data) .................................... 7
Project Boundary Information (Text Data) ........................................ 8
Project Feature Data (Polygon/Polyline/Point Data) ......................... 8

Project Approval ................................................................................ 9
Filing Requirements – Approved Exhibits ......................................... 9
No Federal Lands Involved ................................................................ 9
Federal Lands Involved .................................................................... 10

As-Built Exhibits for New Construction ............................................ 12

APPENDIX 1
Exhibit Guide to Regulatory Requirements

APPENDIX 2
Selected Requirements from the Code of Federal Regulations

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APPENDIX 3
Sample Project Boundary Drawing (Exhibit G/K)
Sample Georeferencing Project Boundary Polygon Data to Exhibit - Correct
Sample Georeferencing Project Boundary Polygon Data to Exhibit - Incorrect
Sample Exhibit G with Land Ownership

APPENDIX 4
Frequently Asked Questions (FAQs) about Exhibits, GIS, and Electronic
Drawings
APPENDIX 5
Form FERC-587 for Projects Located on Federal Lands

This document was prepared by staff of the Office of Energy Projects, Division of
Hydropower Administration and Compliance, for instructional purposes and does not
necessarily reflect the views of the other members of the Federal Energy Regulatory
Commission.

ii

INTRODUCTION
Non-federal hydropower projects in the United States fall within the jurisdiction and
regulatory approval process of the Federal Energy Regulatory Commission. In the
hydropower project approval process, the project owner (licensee or exemptee) is
required to submit drawings showing all project features, project boundaries, and all
plans related to the development of the project (e.g., recreational plans). The drawing
sheets are considered exhibits and each is individually referred to as an exhibit drawing.
The drawings are submitted to the Commission for review, and, once approved; each
sheet of the drawings is assigned an exhibit number and sequential drawing number.
The Office of Energy Projects (OEP) assigns and tracks exhibit drawings for proposed,
licensed, and exempted hydropower projects. Along with the authorizing document
(Preliminary Permit, License, or Exemption), exhibit drawings are the primary source of
information about a hydropower project. Exhibit drawings are also necessary in order
to track the boundary of a project for land withdrawal from public use in accordance
with Section 24 of the Federal Power Act. The OEP coordinates with the U.S.
Department of Interior’s Bureau of Land Management (BLM) for proposed projects on
federal lands.
Once a project is authorized, the approved exhibit drawings must be transferred to a
digital image for filing with the Commission in electronic format. Given an industry shift
towards maintaining archival copies of drawings as digital images, the Commission has
ceased requiring drawings to be filed in microfilm format on aperture cards. Therefore,
this document focuses on electronic document storage of exhibit drawings.
This document describes the process of preparing, making a filing with the Commission,
the approval process, and retaining hydropower project exhibits. It also covers the
Commission’s requirements for managing project boundary and resource data in a
geographical information system (GIS) format.

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EXHIBIT DRAWINGS
When an applicant files for a preliminary permit, license, or exemption with the
Commission, the application document includes project exhibit drawings to describe
and show all project features, boundaries, and other information in sufficient detail to
provide a full understanding of the project. The exhibit drawings differ depending on
the type of application, and Appendix 1 provides an easy-to-use cite reference table.
Appendix 2 contains the text of the Commission’s regulations pertaining to exhibits and
drawings.
In general, maps and drawings are identified as Exhibit F, Exhibit G, or Exhibit R.
Exhibit Fs contain critical energy infrastructure information (CEII), as defined under
the Commission’s regulations at 18 CFR §388.113(c). Exhibit G’s show the project
boundary and principal project features. It is important to include the location of
permanent geographical features such as roads, rivers, and other structures that may be
found on a map and easily recognized in the field. In addition, the location of
recreational features that are part of the project need to be shown within the project
boundary. Exhibit R’s show site plans and details of Commission approved recreational
facilities that are part of the project. Recreation facilities and the associated
requirements are discussed in detail in the Commission’s guidance document Project
Recreation Facilities and As-Built Site Plan Drawing Guidance; which can be found on
the Commission’s internet site. Exhibits and filing requirements are described below:

Preliminary Permits
An applicant files a preliminary permit application for a proposed water power
project to secure priority of application for a license under Part I of the Federal
Power Act (FPA) while the permittee obtains the data and performs the acts
required to determine the feasibility of the project and to support an application
for License (18 CFR §4.80). The preliminary permit application must contain the
following exhibit drawings (18 CFR §4.81(d)):
EXHIBIT
3

DESCRIPTION
map(s) necessary to show clearly and legibly the project boundary,
principal project features, land ownership, environmental details

Exemptions
An applicant files an exemption application for a proposed water power project to
undertake the development of a small hydroelectric project at an existing dam.
Applications for Conduit or Regular Exemptions (5 MW or less) are filed
pursuant to 18 CFR §4.90 or §4.101 and are exempted from the license
requirements of Part I of the FPA. The exemption application must contain the
following exhibit drawings (18 CFR §4.92 or §4.107):

2

EXHIBIT
G
F

DESCRIPTION
general location map showing all project works, project boundary, land
ownership
a set of drawings showing the structures and equipment necessary to
show proposed features

All exhibit drawings must be of a quality, and contain enough detail for
Commission staff to review and make decisions regarding project impacts to the
surrounding environment. However, the Commission recognizes that certain
projects will be of such a small size that it may be possible to relax some of the
requirements for maps and drawings while achieving the same level of detail
regarding a) the location of the project and the extent of land area impacted by
the project works, and b) the proposed design of all power producing structures
and equipment. Only applications for a 10-MW exemption or conduit exemption
may qualify for a waiver to relax exhibit requirements, and any waiver of exhibit
requirements granted will be project specific. For additional information refer to
the Frequently Asked Questions regarding exhibit drawings, or contact FERC
staff.

License
An applicant files a License application for a proposed water power project to
undertake the development of a hydropower project as defined in Section 3(11) of
the FPA. Depending on the type of project (major or minor, constructed or
unconstructed, or transmission line), applications are filed pursuant to 18 CFR
§4.40, §4.50, §4.60, or §4.70. The License application must contain the following
exhibit drawings (18 CFR §4.39, §4.41, §4.51, §4.61, or §4.71):
EXHIBIT
F
G

R (E)

DESCRIPTION
general design drawings of the principal project works, showing the
major structures
a map of the project showing its location and principal features, project
boundary, impoundments, contiguous/noncontiguous features, and
federal and nonfederal land ownership
drawings showing recreational features; drawings showing mitigation
facilities for fish, wildlife, and botanical resources; drawings showing
measures to ensure project works blend with the surrounding
environment

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PRELIMINARY PERMITS AND LICENSE APPLICATIONS
For those projects proposed on federal lands, it is extremely important the FERC and
BLM concurrently track land withdrawals. By statute (Section 24 of the FPA), federal
lands are considered withdrawn upon receipt of a hydropower project application, so it
is important that the BLM be notified of the withdrawal as soon as possible and receive
a copy of the application, exhibits that identify the project boundary, and Form FERC587. The Commission’s licensing staff works with the applicant to make sure the BLM
receives the information promptly. Additional details regarding the appropriate
information to file with the BLM can be obtained by reviewing the forms in Appendix 5,
or contacting the Commission at 202-502-8836.
Exhibit drawings are filed in a variety of formats for review by the Commission. When
filing drawings for review, applicants are generally not limited to the format of the
drawing. Acceptable formats include paper, mylar, or electronic files of various formats
such as PDF, JPG, color or black and white drawings. All drawings must conform to the
regulatory requirements specific to the type of application filed. In addition, applicants
are required to file GIS data so Commission staff can verify the location of project
features and the project boundary. Once a drawing is approved by the Commission,
approved copies must be filed in a specific digital format that is described below.
Therefore, applicants should consider the Commission’s approval standards when
preparing exhibit drawings. Exhibit drawings that deviate substantially from the
standards will cause added effort for revisions.

EXHIBIT DRAWING DETAILS
Exhibit drawings are required for every hydropower project and are kept on file at the
Commission. There are three basic categories of exhibit drawing information the
Commission requires for hydropower projects:




project works,
project boundaries, and
project recreational facilities

All information on the drawings must be legible and conform to the standards and
specifications under the regulations at 18 CFR §4.39; which describes:





drawing size and scale and map features,
requirement that drawings must be stamped by a registered land surveyor,
requirement that drawings should be identified as CEII material,
electronic filings

The Commission eliminated the requirements in 18 CFR §4.39(a) to file maps and
drawings in aperture card format. In their place, the Commission will require an
electronic file which contains a digital image of each map or drawing. The digital image
for Exhibit F’s and G’s must adhere to the specifications in 18 CFR §4.39, and the
electronic file must also meet certain specifications. Any drawing labeled as a recreation
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exhibit (Exhibit R) must be no smaller than 11 by 17 inches when reduced, include a title
block, north arrow, and dimension scale.
Maps and drawings that contain project boundary information must also conform to the
standards and specifications under the regulations at 18 CFR §4.41; which describes:






all projects must have a boundary and exhibits identify principal features,
federal and non-federal lands must be identified,
project boundary standards must be described,
project boundary is required in a georeferenced electronic format
land ownership identification is required (applicant owned in fee, to be acquired
in fee, applicant rights to occupy, rights to occupy to be acquired)

Appendix 3 contains a sample of a properly prepared project boundary exhibit.
Appendix 4 contains frequently asked questions and answers regarding specific details
relating to the preparation of exhibit drawings.

DRAWING FORMATS
All exhibit drawings must be legible and contain the required information to enable a
full review of the proposed hydropower project. Paper drawings are the most common
format and usually consist of engineer drawings at 22” x 34” (ANSI D) or 24” x 36”
(ARCH D size), but must not be smaller than 11 inches on their shorter side (see 18 CFR
§4.39(d)). Electronic file format refers to any type of digital image raster file that can be
read on common computer systems. The Commission requires a specific electronic file
format for approved copies of exhibit drawings.

Aperture Cards (Microfilm)
Aperture cards refer to microfilm copies of drawings, and have been used as a trusted
long-term solution for archival and preservation storage. However, advances in digital
imaging for record management and distribution in electronic format provide many
benefits. Therefore, on June 1, 2014 the Commission stopped requiring
microfilm/aperture card copies of exhibit drawings. This regulation change was adopted
by the Commission in a Final Rule (Docket No. RM14-20-000) and published in the
Federal Register on July 24, 2014. The Commission continues to require high quality
digital format copies of all exhibit drawings.

Electronic Files (Digital Images)
There are recognized benefits associated with permanent digital image storage,
including high-speed retrieval, electronic data transmission and communication, speed
of drawings and faster initial drawing release. While digital media content requires a
computer and specialized software technology to view images, the benefits are evident.

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The Commission requires electronic copies of all drawings in a common, nonproprietary
digital format identified as TIFF CCITT Group 4 (officially known as T.6 coding
scheme). This format consists of a black and white digital image that minimizes file
storage space on computer servers, and is universally read by most computer software.
However, this specification also means that drawings should NOT be created in color
format, include complex shading patterns to identify features or areas, or include visual
imagery backgrounds as a reference. These features will increase the file size of a digital
drawing, and make it difficult to convert to a legible TIFF CCITT Group 4 format.
Digital images of the Exhibit drawings are required by the Commission. Electronic
copies of the images should be filed on CD disk format. The CD should be labeled
“Project Maps and Drawings”. Exhibit F drawings must be segregated from other
project information and identified as (CEII) material under 18 CFR §388.112 and
§388.113(c). Each exhibit drawing must be contained in a separate electronic raster
file; which meets the following format specification:
FILE NAME – MUST use the format (including commas and dashes)
P-####-####, G-1, Project Boundary, MM-DD-YYYY.TIF
IMAGERY - black & white raster file
FILE TYPE – Tagged Image File Format (TIFF), CCITT Group 4
(also known as T.6 coding scheme)
RESOLUTION –300 dpi desired, (200 dpi min)
DRAWING SIZE FORMAT – 22” x 34” (min), 24” x 36” (max)
FILE SIZE – less than 1 MB desired
The filename for each drawing must include: FERC Project-Drawing Number, FERC
Exhibit, Drawing Title, FERC approval date, and file extension in the following format
[P-1234-####, G-1, Project Boundary, MM-DD-YYYY.TIF]. If the file name is not in this
format, the filing will be rejected.
Each Exhibit G drawing that includes the project boundary must contain a minimum of
three known reference points (i.e., latitude and longitude coordinates, or state plane
coordinates), arranged in a triangular format for GIS georeferencing the drawing to the
polygon data. The spatial reference for the drawing (i.e., map projection, map datum,
and units of measurement) must be identified on the drawing and each reference point
must be labeled. The reference points must be based on a standard map coordinate
system. In addition, each project boundary drawing must be stamped by a registered
land surveyor.
Appendix 4 contains frequently asked questions and answers regarding specific details
relating to the preparation of exhibit drawings. It is extremely important that project
owners follow the requirements and specifications.

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GIS DATA REQUIREMENTS
When reviewing or approving a hydropower project boundary, FERC staff uses a
geographic information management (GIS) system to check project features and
boundary information. GIS systems have made significant advances over the years and
the industry has settled on several file formats that are interchangeable among systems.
The Commission has adopted a flexible GIS standard that allows project owners to file
GIS data in various formats.
All hydropower projects require a project boundary and require the project owner to
have the necessary land rights to operate the project. Most hydropower projects have
project boundary information at an accuracy required for property line surveys and real
estate transactions. In addition to paper maps and drawings, the Commission requires
project owners to file project boundary data in an electronic format that can be imported
and checked in a GIS system. The Commission has adopted the National Map Accuracy
Standards for reviewing this electronic hydropower project boundary data; which must
be positionally accurate at a scale of 1:24,000 in a GIS system. This accuracy translates
to ±40 feet positionally, and is not intended to replace the requirements for accurate
project exhibit drawings, or for project owners to maintain accurate records of land
ownership or easements associated with the project boundary or project operation.
Appendix 4 contains frequently asked questions and answers regarding specific details
relating to the preparation of GIS polygon data for project boundaries and reservoir
areas, and for point data regarding project features.

Project Boundary Data (Polygon/Point Data)
Project boundary data contained on Exhibit G drawings must be filed in a georeferenced
electronic format such as ArcView shape files, GeoMedia files, MapInfo files, or any
similar GIS format. The electronic boundary data must be positionally accurate to ± 40
feet and comply with the National Map Accuracy Standards for maps at a 1:24,000
scale. An electronic data file(s) is required for the project boundary, which identifies
each project development as a separate polygon, and a separate file for the reference
points. In addition, for those projects that occupy federal lands, a separate
georeferenced file(s) is required that identifies transmission line acreage and nontransmission line acreage affecting federal lands for the purpose of meeting the
requirements of 18 CFR §11.2. The file(s) must also identify the federal owners, land
identification, and acreage affected by the project boundary. The project boundary GIS
file must include the same reference points shown on each individual exhibit G. For
example, a project boundary point file created from three exhibit G files should contain
a minimum of nine reference points. If an individual drawing contains more than one
sectional drawing, then three reference points are required for each section. The latitude
and longitude coordinates, or state plane coordinates, of each reference point must be
identified. The file name shall include: FERC Project Number, data description, FERC
approval date, and file extension as shown in the sample below:

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P-1234, boundary polygon data, MM-DD-YYYY.shp
P-1234, boundary polygon federal lands data, MM-DD-YYYY.shp
P-1234, reference point data, MM-DD-YYYY.shp
NOTE: all files in .shp format must be accompanied by files with the following
extensions .dbf, .prj., and .shx
Depending on the GIS software used, all georeferenced polygon data (NOT point data)
can be included in a single file with multiple layers.

Project Boundary Information (Text Data)
The project boundary data file(s) must be accompanied by a metadata text file that
describes: the map projection used (i.e., UTM, State Plane, Decimal Degrees, etc.), the
map datum (i.e., North American Datum 27, North American Datum 1983, etc.), and the
units of measurement (i.e., feet, meters, miles, etc). The text file name shall include:
FERC Project Number, data description, FERC approval date, and file extension in the
following format [P-1234, project boundary metadata, MM-DD-YYYY.TXT]. These data
represent the spatial reference for the project and are necessary to locate the project
boundary in a GIS system.

Project Feature Data (Polygon/Polyline/Point Data)
Locating and tracking project features and resources is an important part of managing a
hydropower project. Many license article requirements require long-term tracking and
reporting to verify compliance with a particular issue. Keeping track of recreational
features is important because of the requirements to provide recreation opportunities at
hydropower projects. Tracking cultural resource sites usually requires a management
plan and preserves regional heritage. Finally, tracking the location of private marinas,
boat docks, and other non-project use of project lands helps to gauge overall demand for
project related resources and will help to implement an effective water safety plan. GIS
is a useful tool to track existing project related resources and develop new plans as
required by license articles. Both licensees and FERC can benefit from tracking project
features using GIS.
The Commission will track project resources and certain requirements through the use
of GIS related data. For projects with a shoreline management plan (SMP), the licensee
will need to provide GIS data on the project reservoir as well as shoreline management
classifications that are approved as part of the SMP. When approving project
recreational features, FERC will require a representative latitude/longitude location
point of the feature. The quality of all GIS data should have the same positional accuracy
required for the project boundary; which must be positionally accurate to at least ± 40
feet and comply with the National Map Accuracy Standards for maps at a 1:24,000
scale.

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PROJECT APPROVAL
When a hydropower license or exemption is issued by the Commission, the appropriate
exhibit drawings are approved and incorporated into the authorizing document. Only
those exhibit drawings that are relevant to the hydropower project are approved by the
Commission and assigned FERC drawing numbers. The authorizing license or
exemption will contain a section specifying the exhibit drawings incorporated into the
document. Older exemptions (1980’s era) frequently incorporate by reference the
exhibits submitted as part of the application. Once a drawing exhibit is approved by the
Commission it becomes an official record associated with the project history. Project
owners are required to electronic files that contain a digital image of each approved
exhibits drawing.

FILING REQUIREMENTS – APPROVED EXHIBITS
For each exhibit drawing approved by the Commission, a digital image must be created
and filed in electronic format. For approved exhibit G drawings, project boundary GIS
data must be filed, and for approved recreation features on an exhibit R drawing or a
shoreline management plan, relevant GIS data must be filed. This includes all licensed
and exempted hydropower projects. The license/exemption will also require the filing of
electronic files of the project boundary with the BLM if the project includes federal
lands. In addition, for those projects on federal lands, Form FERC-587 must be filed
with the Commission and the BLM. The following are examples of standard license
articles/ordering paragraphs. Licensees and exemptees should carefully read the
approving article/paragraph for specific instructions that may relate to their project.

No Federal Lands Involved
Within 45 days of the date of issuance of this license/order, as directed
below, the licensee shall file two sets of the approved exhibit drawings and GIS
data in electronic file format on CD disks with the Secretary of the Commission,
ATTN: OEP/DHAC.
a) Digital images of the approved exhibit drawings shall be prepared in electronic
format. Prior to preparing each digital image, the FERC Project-Drawing Number
(i.e., P-1234-1001 through P-1234-###) shall be shown in the margin below the
title block of the approved drawing. Exhibit F drawings must be segregated from
other project exhibits, and identified as (CEII) material under 18 CFR
§388.113(c). Each drawing must be a separate electronic file, and the file name
shall include: FERC Project-Drawing Number, FERC Exhibit, Drawing Title, date
of this License, and file extension in the following format [P-1234-####, G-1,
Project Boundary, MM-DD-YYYY.TIF]. All digital images of the exhibit drawings
shall meet the following format specification:

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IMAGERY - black & white raster file
FILE TYPE – Tagged Image File Format (TIFF), CCITT Group 4
(also known as T.6 coding scheme)
RESOLUTION – 300 dpi desired, (200 dpi min)
DRAWING SIZE FORMAT – 22” x 34” (min), 24” x 36” (max)
FILE SIZE – less than 1 MB desired
Each Exhibit G drawing that includes the project boundary must contain a
minimum of three known reference points (i.e., latitude and longitude
coordinates, or state plane coordinates). The points must be arranged in a
triangular format for GIS georeferencing the project boundary drawing to the
polygon data, and must be based on a standard map coordinate system. The
spatial reference for the drawing (i.e., map projection, map datum, and units of
measurement) must be identified on the drawing and each reference point must
be labeled. In addition, each project boundary drawing must be stamped by a
registered land surveyor.
b) Project boundary GIS data shall be in a georeferenced electronic file format
(such as ArcView shape files, GeoMedia files, MapInfo files, or a similar GIS
format). The filing shall include both polygon data and all reference points shown
on the individual project boundary drawings. An electronic boundary polygon
data file(s) is required for each project development. Depending on the electronic
file format, the polygon and point data can be included in single files with
multiple layers. The georeferenced electronic boundary data file must be
positionally accurate to ±40 feet in order to comply with National Map Accuracy
Standards for maps at a 1:24,000 scale. The file name(s) shall include: FERC
Project Number, data description, date of this License, and file extension in the
following format [P-1234, boundary polygon/or point data, MM-DD-YYYY.SHP].
The data must be accompanied by a separate text file describing the spatial
reference for the georeferenced data: map projection used (i.e., UTM, State Plane,
Decimal Degrees, etc.), the map datum (i.e., North American 27, North American
83, etc.), and the units of measurement (i.e., feet, meters, miles, etc.). The text
file name shall include: FERC Project Number, data description, date of this
License, and file extension in the following format [P-1234, project boundary
metadata, MM-DD-YYYY.TXT].

Federal Lands Involved
Within 45 days of the date of issuance of this license/order, as directed
below, the licensee shall file two sets of the approved exhibit drawings, Form
FERC-587, and GIS data in electronic file format on CD disks with the Secretary
of the Commission, ATTN: OEP/DHAC.
a) Digital images of the approved exhibit drawings shall be prepared in electronic
format. Prior to preparing each digital image, the FERC Project-Drawing Number
(i.e., P-1234-1001 through P-1234-###) shall be shown in the margin below the
title block of the approved drawing. Exhibit F drawings must be segregated from
10

other project exhibits, and identified as (CEII) material under 18 CFR
§388.113(c). Each drawing must be a separate electronic file, and the file name
shall include: FERC Project-Drawing Number, FERC Exhibit, Drawing Title, date
of this license, and file extension in the following format [P-1234-####, G-1,
Project Boundary, MM-DD-YYYY.TIF].
Each Exhibit G drawing that includes the project boundary must contain a
minimum of three known reference points (i.e., latitude and longitude
coordinates, or state plane coordinates). The points must be arranged in a
triangular format for GIS georeferencing the project boundary drawing to the
polygon data, and must be based on a standard map coordinate system. The
spatial reference for the drawing (i.e., map projection, map datum, and units of
measurement) must be identified on the drawing and each reference point must
be labeled. In addition, each project boundary drawing must be stamped by a
registered land surveyor. All digital images of the exhibit drawings shall meet the
following format specification:
IMAGERY - black & white raster file
FILE TYPE – Tagged Image File Format (TIFF), CCITT Group 4
(also known as T.6 coding scheme)
RESOLUTION – 300 dpi desired, (200 dpi min)
DRAWING SIZE FORMAT – 22” x 34” (min), 24” x 36” (max)
FILE SIZE – less than 1 MB desired
A third set (Exhibit G only) and a copy of Form FERC-587 shall be filed with the
Bureau of Land Management office at the following address:
State Director
Bureau of Land Management
City, State Zip
ATTN: FERC Withdrawal Recordation
Form FERC-587 is available through the Commission’s website at the following
URL: http://www.ferc.gov/docs-filing/forms/form-587/form-587.pdf. Although
instruction no. 3 requires microfilm copies of the project boundary maps in
aperture card format, electronic copies that meet the digital specifications in this
ordering paragraph should be substituted. If the FERC-587 cannot be
downloaded from the Internet, a hard copy may be obtained by mailing a request
to the Secretary of the Commission.
b) Project boundary GIS data shall be in a georeferenced electronic file format
(such as ArcView shape files, GeoMedia files, MapInfo files, or a similar GIS
format). The filing shall include both polygon data and all reference points shown
on the individual project boundary drawings. An electronic boundary polygon
data file(s) is required for each project development. Depending on the
electronic file format, the polygon and point data can be included in single files
with multiple layers. The georeferenced electronic boundary data file must be
positionally accurate to ±40 feet in order to comply with National Map Accuracy

11

Standards for maps at a 1:24,000 scale. The file name(s) shall include: FERC
Project Number, data description, date of this license, and file extension in the
following format [P-1234, boundary polygon/or point data, MM-DD-YYYY.SHP].
The filing must be accompanied by a separate text file describing the spatial
reference for the georeferenced data: map projection used (i.e., UTM, State Plane,
Decimal Degrees, etc.), the map datum (i.e., North American 27, North American
83, etc.), and the units of measurement (i.e., feet, meters, miles, etc.). The text
file name shall include: FERC Project Number, data description, date of this
license, and file extension in the following format [P-1234, project boundary
metadata, MM-DD-YYYY.TXT].
In addition, for those projects that occupy federal lands, a separate georeferenced
polygon file(s) is required that identifies transmission line acreage and nontransmission line acreage affecting federal lands for the purpose of meeting the
requirements of 18 CFR §11.2. The file(s) must also identify each federal owner
(e.g., BLM, USFS, Corps of Engineers, etc.), land identification (e.g., forest name,
Section 24 lands, national park name, etc.), and federal acreage affected by the
project boundary. Depending on the georeferenced electronic file format, the
polygon, point, and federal lands data can be included in a single file with
multiple layers.

AS-BUILT EXHIBITS FOR NEW CONSTRUCTION
If a hydropower project approval includes authorization for new project features, a
license article requires the licensee to file as-built exhibits with the Commission within
90 days of the date of completion of project construction. The exhibits are reviewed by
FERC staff to make sure they match the as-built conditions, and to determine their
compliance with the license. The terms and conditions of an exemption generally do not
require the filing of as-built exhibits. However, the Commission will require updated
exhibit drawings if the constructed features differ substantially from those authorized.

12

APPENDIX 1
Exhibit Guide to Regulatory Requirements

13

OEP Project Exhibit Drawing Requirements
Application for Preliminary Permits, Licenses, Exemptions: General Provisions
§4.39 Specifications for Maps & Drawings (Pg. 100)
§4.41(h) provides instructions for georeferenced project boundary data (Pg. 110)
License Type

Drawings
Exhibit F(L)

Boundary
Exhibit G(K)

Recreation
Exhibit R(E)

§4.40
Major Unconstructed
Major Modification

§4.41(g) - refer to specs,
also see §4.39
Pg. 109

§4.41(h) - refer to specs, also
see §4.39
Pg. 110

§4.41(f)(7) recreation development areas referenced
to appropriate ex G Pg. 108; §4.41(f)(8) drawings
conform to §4.39 Pg. 109

§4.50
Major Project
Existing Dam

§4.51(g) - refer to specs at
§4.41(g)
Pg. 118

§4.51(h) - refer to specs at
§4.41(h)
Pg. 118

§4.51(f) - drawings conform to §4.39
Pg. 116

§4.60
Minor/Major
Project<5 MW

§4.61(e) - refer to specs at
§4.41(g)
Pg. 121

§4.61(f) - refer to specs at
§4.41(h)
Pg. 121

Maps as required - consult requirements of §4.41(f)
Pg. 120

§4.70
Transmission Line
unconstructed
constructed

drawings F, G, and E for unconstructed lines connected to a licensed project >5MW must meet req of §4.41, Pg. 122

§4.90
Conduit Exemption

§4.92(f) - refer to specs at
§4.41(g)

§4.92(d) - refer to specs at
§4.41(h)

Pg. 127

pg. 127

§4.107(f) - refer to specs at
§4.41(g)
Pg. 134

§4.107(d) - refer to specs at
§4.41(h)

§4.101
Exemption <10 MW

§4.81
Preliminary Permit

drawings F, G, and E for unconstructed lines connected to a licensed project < 5 MW, or any constructed line
connected to a licensed project must meet requirements of §4.61, Pg. 122
prepare exhibit pursuant to §4.38
Pg. 127
prepare exhibit pursuant to §4.38
Pg. 133

Pg. 133

§4.81(d) drawings identified as EXH 3, need not conform to
precise specs of §4.39, must show boundaries, features, &
land ownership Pg. 124

Note: Page numbers refer to 18 CFR, updated April 1, 2014. An electronic version of the CFR can be found at http://www.ecfr.gov/ Select Title 18Conservation of Water and Power Resources, then select Parts 1 – 399 for a detailed table of contents for each regulation cited above.

14

APPENDIX 2
Selected Requirements from the Code of Federal Regulations
TITLE 18--CONSERVATION OF POWER AND WATER RESOURCES
CHAPTER I--FEDERAL ENERGY REGULATORY COMMISSION, DEPARTMENT OF
ENERGY
PART 4_LICENSES, PERMITS, EXEMPTIONS, AND DETERMINATION OF PROJECT
COSTS
PART 388--INFORMATION AND REQUESTS

15

PART 4_LICENSES, PERMITS, EXEMPTIONS, AND DETERMINATION OF PROJECT
COSTS
Subpart D_Application for Preliminary Permit, License or Exemption: General
Provisions
Sec. 4.39 Specifications for maps and drawings.
All required maps and drawings must conform to the following specifications, except as
otherwise prescribed in this chapter:
(a) Full-sized prints of maps and drawings must be on sheets no smaller than 22 by 34 inches
and no larger than 24 by 36 inches. NOTE: microfilm copies in aperture card format are no
longer required; electronic copies will be specified and the minimum and maximum size of
drawings has changed. See Commission Docket RM14-20-000. A space five inches high by seven
inches wide must be provided in the lower right hand corner of each sheet. The upper half of this
space must bear the title, numerical and graphical scale, and other pertinent information
concerning the map or drawing. The lower half of the space must be left clear. Exhibit G
drawings must be stamped by a registered land surveyor. If the drawing size specified in this
paragraph limits the scale of structural drawings (exhibit F drawings) described in paragraph (c)
of this section, a smaller scale may be used for those drawings. Potential applicants or licensees
may be required to file maps or drawings in electronic format as directed by the Commission.
(b) Each map must have a scale in full-sized prints no smaller than one inch equals 0.5 miles
for transmission lines, roads, and similar linear features and no smaller than one inch equals
1,000 feet for other project features, including the project boundary. Where maps at this scale do
not show sufficient detail, large scale maps may be required.
(1) True and magnetic meridians;
(2) State, county, and town lines; and
(3) Boundaries of public lands and reservations of the United States [see 16 U.S.C. 796 (1) and
(2)], if any. If a public land survey is available, the maps must show all lines of that survey
crossing the project area and all official subdivisions of sections for the public lands and
reservations, including lots and irregular tracts, as designated on the official plats of survey
that may be obtained from the Bureau of Land Management, Washington, DC, or examined in
the local land survey office; to the extent that a public land survey is not available for public
lands and reservations of the United States, the maps must show the protractions of townships
and section lines, which, if possible, must be those recognized by the Federal agency
administering those lands.
(c) Drawings depicting details of project structures must have a scale in full-sized prints no
smaller than:
(1) One inch equals 50 feet for plans, elevations, and profiles; and
(2) One inch equals 10 feet for sections.
(d) Each map or drawing must be drawn and lettered to be legible when it is reduced to a print
that is 11 inches on its shorter side. Following notification to the applicant that the application
has been accepted for filing [see Sec. 4.31(c)], prints reduced to that size must be bound in each
copy of the application which is required to be submitted to the Commission or provided to any
person, agency, or other entity.
(e) The maps and drawings showing project location information and details of project
structures must be filed in accordance with the Commission's instructions on submission of
Critical Energy Infrastructure Information in Sec. Sec. 388.112 and 388.113 of subchapter X of
this chapter.

16

[Order 54, 44 FR 61334, Oct. 25, 1979. Redesignated by Order 413, 50 FR 11678, Mar. 25, 1985;
Order 2002, 68 FR 51119, Aug. 25, 2003; 68 FR 61742, Oct. 30, 2003; Order 798, 79 FR 4297301, July 24, 2014]

● ● ● ●
PART 4_LICENSES, PERMITS, EXEMPTIONS, AND DETERMINATION OF PROJECT
COSTS
Subpart E_Application for License for Major Unconstructed Project and Major Modified
Project
Sec. 4.41 Contents of application.
Any application under this subpart must contain the following information in the form
prescribed:
...
(b) Exhibit A is a description of the project. If the project includes more than one dam with
associated facilities, each dam and the associated component parts must be described together
as a discrete development. The description for each development must contain: . . .; and
(6) All lands of the United States, including lands patented subject to the provisions of section
24 of the Act, 16 U.S.C. 818, that are enclosed within the project boundary described under
paragraph (h) of this section (Exhibit G), identified and tabulated by legal subdivisions of a
public land survey, by the best available legal description. The tabulation must show the total
acreage of the lands of the United States within the project boundary.
...
(f) Exhibit E is an Environmental Report. Information provided in the report must be
organized and referenced according to the itemized subparagraphs below. See Sec. 4.38 for
consultation requirements. The Environmental Report must contain the following information,
commensurate with the scope of the project: . . .
(7) (vii) A drawing or drawings, one of which describes the entire project area, clearly
showing:
(A) The location of project lands, and the types and number of existing recreational facilities
and those proposed for initial development, including access roads and trails, and facilities for
camping, picnicking, swimming, boat docking and launching, fishing and hunting, as well as
provisions for sanitation and waste disposal;
(B) The location of project lands, and the type and number of recreational facilities planned
for future development;
(C) The location of all project lands reserved for recreational uses other than those included in
paragraphs (f)(7)(vii) (A) and (B) of this section; and
(D) The project boundary (excluding surveying details) of all areas designated for recreational
development, sufficiently referenced to the appropriate Exhibit G drawings to show that all
lands reserved for existing and future public recreational development and the shoreline buffer
zone are included within the project boundary. Recreational cottages, mobile homes and year-

17

round residences for private use are not to be considered as public recreational facilities, and the
lands on which these private facilities are to be developed are not to be included within the
proposed project boundary.
(g) Exhibit F consists of general design drawings of the principal project works described
under paragraph (b) of this section (Exhibit A) and supporting information used as the basis of
design. If the Exhibit F submitted with the application is preliminary in nature, applicant must
so state in the application. The drawings must conform to the specifications of Sec. 4.39. . . .
(h) Exhibit G is a map of the project that must conform to the specifications of Sec. 4.39. In
addition, to the other components of Exhibit G, the Applicant must provide the project boundary
data in a georeferenced electronic format--such as ArcView shape files, GeoMedia files, MapInfo
files, or any similar format. The electronic boundary data must be positionally accurate to ±40
feet, in order to comply with the National Map Accuracy Standards for maps at a 1:24,000 scale
(the scale of USGS quadrangle maps). The electronic exhibit G data must include a text file
describing the map projection used (i.e., UTM, State Plane, Decimal Degrees, etc.), the map
datum (i.e., feet, meters, miles, etc.). Three sets of the maps must be submitted on compact disk
or other appropriate electronic media. If more than one sheet is used for the paper maps, the
sheets must be numbered consecutively, and each sheet must bear a small insert sketch showing
the entire project and indicate that portion of the project depicted on that sheet. Each sheet must
contain a minimum of three known reference points. The latitude and longitude coordinates, or
state plane coordinates, of each reference point must be shown. If at any time after the
application is filed there is any change in the project boundary, the applicant must submit,
within 90 days following the completion of project construction, a final exhibit G showing the
extent of such changes. The map must show:
(1) Location of the project and principal features. The map must show the location of the
project as a whole with reference to the affected stream or other body of water and, if possible, to
a nearby town or any other permanent monuments or objects, such as roads, transmission lines
or other structures, that can be noted on the map and recognized in the field. The map must also
show the relative locations and physical interrelationships of the principal project works and
other features described under paragraph (b) of this section (Exhibit A).
(2) Project boundary. The map must show a project boundary enclosing all project works and
other features described under paragraph (b) of this section (Exhibit A) that are to be licensed. If
accurate survey information is not available at the time the application is filed, the applicant
must so state, and a tentative boundary may be submitted. The boundary must enclose only
those lands necessary for operation and maintenance of the project and for other project
purposes, such as recreation, shoreline control, or protection of environmental resources (see
paragraph (f) of this section (Exhibit E)). Existing residential, commercial, or other structures
may be included within the boundary only to the extent that underlying lands are needed for
project purposes (e.g., for flowage, public recreation, shoreline control, or protection of
environmental resources). If the boundary is on land covered by a public survey, ties must be
shown on the map at sufficient points to permit accurate platting of the position of the boundary
relative to the lines of the public land survey. If the lands are not covered by a public land survey,
the best available legal description of the position of the boundary must be provided, including
distances and directions from fixed monuments or physical features. The boundary must be
described as follows:
(i) Impoundments. (A) The boundary around a project impoundment must be described by
one of the following:
(1) Contour lines, including the contour elevation (preferred method);
(2) Specified courses and distances (metes and bounds);

18

(3) If the project lands are covered by a public land survey, lines upon or parallel to the lines of
the survey; or
(4) Any combination of the above methods.
(B) The boundary must be located no more than 200 feet (horizontal measurement) from the
exterior margin of the reservoir, defined by the normal maximum surface elevation, except
where deviations may be necessary in describing the boundary according to the above methods
or where additional lands are necessary for project purposes, such as public recreation, shoreline
control, or protection of environmental resources.
(ii) Continuous features. The boundary around linear (continuous) project features such as
access roads, transmission lines, and conduits may be described by specified distances from
center lines or offset lines of survey. The width of such corridors must not exceed 200 feet unless
good cause is shown for a greater width. Several sections of a continuous feature may be shown
on a single sheet with information showing the sequence of contiguous sections.
(iii) Noncontinuous features. (A) The boundary around noncontinuous project works such as
dams, spillways, and powerhouses must be described by one of the following:
(1) Contour lines;
(2) Specified courses and distances;
(3) If the project lands are covered by a public land survey, lines upon or parallel to the lines of
the survey; or
(4) Any combination of the above methods.
(B) The boundary must enclose only those lands that are necessary for safe and efficient
operation and maintenance of the project or for other specified project purposes, such as public
recreation or protection of environmental resources.
(3) Federal lands. Any public lands and reservations of the United States (Federal lands) [see
16 U.S.C. 796 (1) and (2)] that are within the project boundary, such as lands administered by
the U.S. Forest Service, Bureau of Land Management, or National Park Service, or Indian tribal
lands, and the boundaries of those Federal lands, must be identified as such on the map by:
(i) Legal subdivisions of a public land survey of the affected area (a protraction of identified
township and section lines is sufficient for this purpose); and
(ii) The Federal agency, identified by symbol or legend, that maintains or manages each
identified subdivision of the public land survey within the project boundary; or
(iii) In the absence of a public land survey, the location of the Federal lands according to the
distances and directions from fixed monuments or physical features. When a Federal survey
monument or a Federal bench mark will be destroyed or rendered unusable by the construction
of project works, at least two permanent, marked witness monuments or bench marks must be
established at accessible points. The maps show the location (and elevation, for bench marks) of
the survey monument or bench mark which will be destroyed or rendered unusable, as well as of
the witness monuments or bench marks. Connecting courses and distances from the witness
monuments or bench marks to the original must also be shown.
(iv) The project location must include the most current information pertaining to affected
Federal lands as described under Sec. 4.81(b)(5).
(4) Non-Federal lands. For those lands within the project boundary not identified under
paragraph (h)(3) of this section, the map must identify by legal subdivision:
(i) Lands owned in fee by the applicant and lands that the applicant plans to acquire in fee;
and
(ii) Lands over which the applicant has acquired or plans to acquire rights to occupancy and
use other than fee title, including rights acquired or to be acquired by easement or lease.
[Order 184, 46 FR 55936, Nov. 13, 1981; 48 FR 4459, Feb. 1, 1983, as amended by Order 413, 50
FR 11684, Mar. 25, 1985; Order 464, 52 FR 5449, Feb. 23, 1987; Order 540, 57 FR 21737, May

19

22, 1992; Order 2002, 68 FR 51119, Aug. 25, 2003; 68 FR 61742, Oct. 30, 2003; 68 FR 63194,
Nov. 7, 2003; 68 FR 69957, Dec. 16, 2003]

● ● ● ●
PART 388--INFORMATION AND REQUESTS
Sec. 388.112 Requests for privileged treatment of documents submitted to the
Commission.
(a) Scope. (1) Any person submitting a document to the Commission may request privileged
treatment by claiming that some or all of the information contained in a particular document is
exempt from the mandatory public disclosure requirements of the Freedom of Information Act,
5 U.S.C. 552, and should be withheld from public disclosure.
(2) Any person submitting documents containing critical energy infrastructure information
(CEII) as defined in §388.113 should follow the procedures specified in this section.
(b) Procedures. A person claiming that information warrants special treatment as CEII or
privileged must file:
(1) A written statement requesting CEII or privileged treatment for some or all of the
information in a document, and the justification for special treatment of the information; and
(2) The following, as applicable:
(i) An original plus the requisite number of copies of the public volume filed and marked in
accordance with instructions issued by the Secretary;
(ii) An original plus two copies of the CEII volume, if any, filed and marked in accordance
with instructions issued by the Secretary; and
(iii) An original only of the privileged volume, if any, filed and marked in accordance with
instructions issued by the Secretary.
(c) Effect of privilege or CEII claim. (1) For documents filed with the Commission:
(i) The Secretary of the Commission will place documents for which privileged or CEII
treatment is sought in accordance with paragraph (b) of this section in a nonpublic file while the
request for privileged or CEII treatment is pending. By placing the documents in a nonpublic
file, the Commission is not making a determination on any claim of privilege or CEII status. The
Commission retains the right to make determinations with regard to any claim of privilege or
CEII status, and the discretion to release information as necessary to carry out its jurisdictional
responsibilities.
(ii) The Secretary of the Commission will place the request for privileged or CEII treatment
and a copy of the original document without the privileged or CEII information in a public file
while the request is pending.
(2) For documents submitted to Commission staff. The notification procedures of paragraphs
(d), (e), and (f) of this section will be followed by staff before making a document public.
(d) Notification of request and opportunity to comment. When a FOIA or CEII requester seeks
a document for which privilege or CEII status has been claimed, or when the Commission itself
is considering release of such information, the Commission official who will decide whether to
release the information or any other appropriate Commission official will notify the person who
submitted the document and give the person an opportunity (at least five calendar days) in
which to comment in writing on the request. A copy of this notice will be sent to the requester.
(e) Notification before release. Notice of a decision by the Commission, the Chairman of the
Commission, the Director, Office of External Affairs, the General Counsel or General Counsel's
designee, a presiding officer in a proceeding under part 385 of this chapter, or any other
appropriate official to deny a claim of privilege, in whole or in part, or to make a limited release

20

of CEII, will be given to any person claiming that the information is privileged or CEII no less
than 5 calendar days before disclosure. The notice will briefly explain why the person's
objections to disclosure are not sustained by the Commission. A copy of this notice will be sent
to the FOIA or CEII requester.
(f) Notification of suit in Federal courts. When a FOIA requester brings suit to compel
disclosure of information for which a person has claimed privileged treatment, the Commission
will notify the person who submitted the documents of the suit.
[Order 630, 68 FR 9869, Mar. 3, 2003, as amended by Order 630–A, 68 FR 46459, Aug. 6,
2003; 72 FR 63985, Nov. 14, 2007]
NOTE: see also Commission Order No. 702, Critical Energy Infrastructure Information, Docket
No. RM06-23-000, issued October 30, 2007, 121 FERC ¶ 61,107 (72 FR 63980, Nov 14, 2007)

● ● ● ●
PART 388--INFORMATION AND REQUESTS
Sec. 388.113 Accessing critical energy infrastructure information.
(a) Scope. This section governs access to critical energy infrastructure information (CEII).
The rules governing submission of CEII are contained in 18 CFR 388.112(b). The Commission
reserves the right to restrict access to previously filed documents as well as Commissiongenerated documents containing CEII.
(b) Purpose. The procedures in this section are available at the requester's option as an
alternative to the FOIA procedures in §388.108 where the information requested is exempted
from disclosure under the FOIA and contains CEII.
(c) Definitions. For purposes of this section:
(1) Critical energy infrastructure information means specific engineering, vulnerability, or
detailed design information about proposed or existing critical infrastructure that:
(i) Relates details about the production, generation, transportation, transmission, or
distribution of energy;
(ii) Could be useful to a person in planning an attack on critical infrastructure;
(iii) Is exempt from mandatory disclosure under the Freedom of Information Act, 5 U.S.C.
552; and
(iv) Does not simply give the general location of the critical infrastructure.
(2) Critical infrastructure means existing and proposed systems and assets, whether physical
or virtual, the incapacity or destruction of which would negatively affect security, economic
security, public health or safety, or any combination of those matters.
(d) Accessing critical energy infrastructure information. (1) An Owner/operator of a facility,
including employees and officers of the owner/operator, may obtain CEII relating to its own
facility directly from Commission staff without going through the procedures outlined in
paragraph (d)(3) of this section. Non-employee agents of an owner/operator of such facility may
obtain CEII relating to the owner/operator's facility in the same manner as owner/operators as
long as they present written authorization from the owner/operator to obtain such information.
(2) An employee of a federal agency acting within the scope of his or her federal employment
may obtain CEII directly from Commission staff without following the procedures outlined in
paragraph (d)(3) of this section. Any Commission employee at or above the level of division
director or its equivalent may rule on federal agency representatives' requests for access to CEII.

21

(3) A landowner whose property is crossed by or in the vicinity of a project may receive
detailed alignment sheets containing CEII directly from Commission staff without submitting a
non-disclosure agreement as outlined in paragraph (d)(4) of this section. A landowner must
provide Commission staff with proof of his or her property interest in the vicinity of a project.
(4) If any other requester has a particular need for information designated as CEII, the
requester may request the information using the following procedures:
(i) File a signed, written request with the Commission's CEII Coordinator. The request must
contain the following: Requester's name (including any other name(s) which the requester has
used and the dates the requester used such name(s)), title, address, and telephone number; the
name, address, and telephone number of the person or entity on whose behalf the information is
requested; a detailed statement explaining the particular need for and intended use of the
information; and a statement as to the requester's willingness to adhere to limitations on the use
and disclosure of the information requested. A requester shall provide his or her date and place
of birth upon request, if it is determined by the CEII Coordinator that this information is
necessary to process the request. Unless otherwise provided in Section 113(d)(3), a requester
must also file an executed non-disclosure agreement.
(ii) A requester who seeks the information on behalf of all employees of an organization
should clearly state that the information is sought for the organization, that the requester is
authorized to seek the information on behalf of the organization, and that all the requesters
agree to be bound by a non-disclosure agreement that must be executed by and will be applied to
all individuals who have access to the CEII.
(iii) After the request is received, the CEII Coordinator will determine if the information is
CEII, and, if it is, whether to release the CEII to the requester. The CEII Coordinator will balance
the requester's need for the information against the sensitivity of the information. If the
requester is determined to be eligible to receive the information requested, the CEII Coordinator
will determine what conditions, if any, to place on release of the information.
(iv) If the CEII Coordinator determines that the CEII requester has not demonstrated a valid
or legitimate need for the CEII or that access to the CEII should be denied for other reasons, this
determination may be appealed to the General Counsel pursuant to §388.110 of this Chapter.
The General Counsel will decide whether the information is properly classified as CEII, which by
definition is exempt from release under FOIA, and whether the Commission should in its
discretion make such CEII available to the CEII requester in view of the requester's asserted
legitimacy and need.
(v) Once a CEII requester has been verified by Commission staff as a legitimate requester
who does not pose a security risk, his or her verification will be valid for the remainder of that
calendar year. Such a requester is not required to provide detailed information about him or
herself with subsequent requests during the calendar year. He or she is also not required to file a
non-disclosure agreement with subsequent requests during the calendar year because the
original non-disclosure agreement will apply to all subsequent releases of CEII.
(vi) If an organization is granted access to CEII as provided by paragraph (d)(4)(iii) of this
section, and later seeks to add additional individuals to the non-disclosure agreement, the
names of these individuals must be sent to the CEII Coordinator with certification that notice
has been given to the submitter. Any newly added individuals must execute a supplement to the
original non-disclosure agreement indicating their acceptance of its terms. If there is no written
opposition within five (5) days of notifying the CEII Coordinator and the submitter concerning
the addition of any newly-named individuals, the CEII Coordinator will issue a standard notice
accepting the addition of names to the non-disclosure agreement. If the submitter files a timely
opposition with the CEII Coordinator, the CEII Coordinator will issue a formal determination
addressing the merits of such opposition.
(e) Fees for processing CEII requests will be determined in accordance with 18 CFR 388.109.

22

[Order 630, 68 FR 9870, Mar. 3, 2003, as amended by Order 630–A, 68 FR 46460, Aug. 6,
2003; Order 649, 69 FR 48391, Aug. 10, 2004; Order 662, 70 FR 37036, June 28, 2005; 71 FR
58276, Oct. 3, 2006; 72 FR 63985, Nov. 14, 2007]
NOTE: see also Commission Order No. 702, Critical Energy Infrastructure Information, Docket
No. RM06-23-000, issued October 30, 2007, 121 FERC ¶ 61,107 (72 FR 63980, Nov 14, 2007)

23

APPENDIX 3
Sample Project Boundary Drawing and GIS Data

24

GIS vector data, GIS reference points (3 per drawing), and Exhibit G TIFF files imported, georeferenced and overlain to
USGS 7.5–minute quadrangle map. When white background is eliminated from the exhibits, project boundary aligns
properly within regulatory specifications. Note the project boundary is a “closed” polygon.
26

GIS vector data, GIS reference points, and Exhibit G TIFF file imported and overlain to USGS 7.5–minute quadrangle
map. White background is eliminated from the Exhibit G, and project boundary does not align properly to features. It
appears the drawing should be shifted west to align properly. Note the inset drawing also has three reference points as
required.
27

APPENDIX 4
Frequently Asked Questions (FAQs) about
Exhibits, Digital Drawings, and GIS Data

29

Frequently Asked Questions (FAQs)
Preparing exhibit drawings for filing with the Commission requires attention to detail. If
there is one advice statement we must emphasize about preparing and filing exhibits, it
is to check and verify all work. This appendix provides questions and answers to a
number of issues associated with exhibit drawings and related GIS data.

EXHIBIT DRAWINGS
Q. When preparing exhibit drawings for license or exemption applications or
amendment filings with the Commission, what format is acceptable?

A. The most common drawing format for submitting exhibit drawings for FERC
review is paper. Exhibit drawings should be a minimum of 22” x 34” and a
maximum of 24” x 36”. Also, drawings must be legible when reduced to a print
that is 11” on its shortest (see 18 CFR §4.39(a) and (d)). Applicants may choose to
file their exhibits as full size drawings or in a reduced format (i.e., 11” x 17”). In
addition, more applicants are filing exhibit drawings in electronic formats such as
PDF, JPG images. These formats are acceptable for review, provided the maps
and images are at a scale sufficient to show the necessary project details.
However, upon approval by the Commission, the exhibits must be converted to
black & white drawings and filed in a digital format with the Commission. This
means that electronic TIFF files that contain a digital image of each approved
drawing will have to be prepared using full size drawings.
Q. What information needs to be included on exhibit drawings?
A. All exhibit drawings must include basic information relating to project
approved features as described in the regulations. Project boundary exhibits must
show a “closed” project boundary that is clearly identifiable. In addition, project
boundary exhibits must have a minimum of three reference points per “plan view
detail” on the drawing along with the coordinates for these points. These points
must be located around the project boundary in a triangular pattern that will
allow importing and georectification in a GIS system. Project boundary exhibits
must also include the GIS metadata information; which contains key information
about the coordinate system. Refer to the sample drawings in Appendix 3 for
more detail. Project owners who are preparing drawings to document recreation
facilities should follow the Commission’s Project Recreation Facilities and AsBuilt Site Plan Drawing Guidance.
Exhibit F drawings contain critical energy infrastructure information (CEII), as
defined under the Commission’s regulations at 18 CFR §388.113(c) and should be
labeled as such on the drawing. An Exhibit G drawing contains project location
and boundary information, as well as project features such as the powerhouse,
transmission line, and recreation features. However, if the drawing material

30

contains design details about the project, a licensee may consider moving the
information to an exhibit F drawing to provide CEII status. Additional details
regarding CEII documents can be found on the Commission’s web site at:
http://www.ferc.gov/legal/ceii-foia.asp Finally, Exhibit R drawings are required
to show details of approved recreational features. In general, these drawings are
not required to meet the geospatial standard requirements for Exhibit G’s.
However, the location of all approved recreation features must be identified on
the Exhibit G.
Q. Explain the need for three reference points on Exhibit G drawings, and how they are
used?
A. Three reference points are very important, and necessary for the Commission
to import the exhibit drawing to its GIS system. The points are used to
georeference the exhibit drawings and verify the project boundary polygon data
matches what is on the drawing. It is very important to place the reference points
around the exhibit in a triangular pattern. This way the drawing can be imported
and properly georectified. Project owners have asked if the points need to be
survey control monuments or location points established by a surveyor. NO. The
points can be any reference point on the exhibit drawing and are typically the
corner of a building, intersection of a road, or even unmarked space on the
drawing. However, the reference points must be the same ones included in the
GIS data and they MUST match when imported to the GIS system.
As an additional note, when Georeferencing exhibit drawings to a coordinate
system licensees should avoid using the North American Datum (NAD) 1927.
Using NAD 27 can produce reference errors when using GIS software programs.
If there is a need to use NAD 27, checking all work is highly recommended before
filing with the Commission.
Q. Do I need to survey the project boundary?
A. NO. Many project owners and surveyors have interpreted the regulations as a
mandatory requirement to undertake a boundary survey. All project owners are
required to have the necessary land rights for their project boundaries, and
surveys may be necessary related to real estate transactions when land is
acquired and easements obtained for the project boundary, or various easements
associated with project operations. Most hydropower project boundaries are
developed using a combination of methods specified in the regulations (see
Appendix 2, Sec. 4.41 (h)(2)) and probably required some associated survey
work. However, a new survey is not necessarily required for the preparation of
exhibit drawings.
If a project owner files project exhibits that, when reviewed on our GIS system,
does not show an accurate location of the project boundary and project features,
the owner will be required to revise the drawings. This may or may not require
the assistance of a surveyor to properly locate the erroneous features.

31

Q. Why do project boundary drawings require a licensed surveyor stamp?
A. Hydropower project boundaries must be accurate. As discussed above, most if
not all project boundaries were determined with the assistance of a surveyor at
some point in time. In reviewing hundreds of projects on our GIS system, we
discovered many errors in the location of project boundaries. Having a surveyor
review and stamp the plans helps to ensure the drawings meet a minimum
standard. While some surveyors have expressed concern about affixing their
stamp to a project boundary exhibit, we are not aware of any projects that have
been unable to receive a registered surveyor’s stamp. We do not require the
surveyor to be registered in the state where the project is located. The sample
below shows a surveyor stamp format that includes language attesting to the level
of review:

Q.
The regulations require project boundary exhibit drawings to identify any public
lands and reservations of the United States (federal lands), non-federal lands owned or
to be acquired in fee by the applicant, and non-federal lands over which the applicant
has acquired or plans to acquire the rights to occupy and use other than fee title,
including the right to be acquired by easement or lease. Why must I show this detailed
information on a proposed license application exhibit?
A. All project boundary exhibits must include sufficient information for the
Commission to make an informed decision about project related impacts,
including land ownership. In addition, when a hydropower project is authorized,
the licensee/exemptee’s right to use must encompass all project purposes under
Section 10(a) of the Federal Power Act. A licensee must acquire title in fee or the
right to use in perpetuity all lands within the project boundary. Standard article 5
is included in each license to addresses this right to use, and allows the licensee
five years from the date of license issuance to acquire these rights for operation
and maintenance of the project. If necessary, Section 21 of the Federal Power Act
provides the licensee with eminent domain authority to acquire these rights.
Applicants for a 10-MW exemption are required to possess, or have the option to
obtain, the real property interests necessary to develop, operate, and maintain
the project (see 18 CFR §4.31(b)(2)(ii)). Applicants for a conduit exemption are
32

required to prove, at the time of filing, there are sufficient property rights to
construct, operate, and maintain the project (see 18 CFR §4.92(a)(3)). Identifying
property rights information on the exhibit G drawings is the most effective way to
identify the licensee/exemptee’s responsibilities, and to monitor which lands it
may need to acquire. If a licensee/exemptee needs to acquire project lands
through the original license, relicense, or amendment process, we will expect to
see those lands explicitly identified on the exhibit drawings. If the licensee has
previously obtained all necessary land rights within the project boundary, we may
accept a note on the exhibit drawings that includes language attesting to the level
of property rights. One form of language that may be acceptable is shown below:

Q. The regulations require the project boundary around an impoundment or
noncontiguous features be described by, among other methods, specified courses and
distances. Adding this information to project drawings is very time consuming. Will the
Commission accept latitude/longitude points in conjunction with a reference grid as a
substitute for the course and distance method of boundary designation on the drawings?
A. All project boundaries must include enough information that will allow
platting of the boundary. Moreover, it is the project owner’s responsibility to have
all the necessary land rights within the project boundary. Prior to GIS systems,
the most common way to define surveyed boundaries was to label drawings with
courses and distances. This method is still required for most real estate
transactions that involve property line survey work. The course and distance (also
known as metes and bounds) method for determining a project boundary should
be very accurate because, in theory, it requires a survey control point (or marker)
to begin the process. A survey control marker provides an established, verifiable
horizontal/vertical position that is then used as a fixed reference in positioning
and correlating map features. Because these survey control markers can be
accurate to within hundredths of a foot, the accompanying course/distance data
is expected to have similar accuracy.
With the advent of GIS, there are many cost-effective options available that allow
the designer to locate the project boundary of a hydropower project. It is possible
to locate all points around the project boundary in one of many coordinate
systems, from which courses and distances can be determined. While the
Commission may consider latitude/longitude points in conjunction with a
reference grid on the exhibit drawing as an alternative to courses and distances, it
must be assured the same level of accuracy as the regulations require. Sufficient
notes must be added to the drawings to provide this assurance, and the drawings
should include a description of survey control markers used to help define the
project boundary, a description of the methodology used to develop the
latitude/longitude data, and a description of the level of accuracy for the project
33

boundary. All project boundary drawings must be accompanied by GIS data that
will allow the Commission to check the project boundary location. In addition, if
the drawings use the latitude/longitude points with a grid system the project
owner may be required to provide course and distance information if requested
by the Commission. These provisions should provide flexibility to project owners,
while maintaining adequate standards for project boundaries.
Q. I have a small hydro project and the requirements for drawings seem very
burdensome. Is there any way I can get a waiver?
A. All project exhibits must meet minimum standards. For example, Exhibit F
drawings contain details regarding the design of the powerhouse, generating
units, and appurtenant facilities related to power production. Exhibit G drawings
show the project boundary and principal features as a whole in relation to the
affected waterway and other permanent geographical features such as roads,
rivers, and other structures that may be found on a map and easily recognized in
the field. All drawings must be drawn to scale, must be legible, and must contain
a title block with pertinent project information. However, the Commission
recognizes that certain projects will be of such a small size that it may be possible
to relax some of the requirements for maps and drawings while achieving the
same level of detail regarding a) the location of the project and the extent of land
area impacted by the project works, and b) the proposed design of all power
producing structures and equipment. All exhibit drawings must be of a quality,
and contain enough detail for Commission staff to review and make decisions
regarding project impacts to the surrounding environment. Projects that may
qualify for a waiver are 10-MW exemptions and conduit exemptions. Any waiver
of exhibit requirements granted by the Commission will be project specific.
Exhibit F drawings must be of sufficient quality, clarity, and detail to identify the
project features. This would include the inlet structure, powerhouse and tailrace,
generating equipment, as well as a site plan and profile views. If turbine and
generator drawing details are available from manufacturer specification books,
they may be substituted for an original prepared drawing providing they fully
represent the proposed project. Providing all details are legible, applicants may
request a waiver to prepare the drawings on sheets not smaller than 8 ½ by 11
inches, or to use a different scale for sections and details.
Exhibit G drawings must include a vicinity map of the project area, and a detailed
drawing that shows all principal features as a whole in relation to the affected
waterway and other permanent geographical features. All project facilities must
be contained within a project boundary. The drawings must be drawn to scale,
contain a north arrow, and contain a location data points such that the project
site identified using a defined coordinate system such as latitude/longitude. In
addition, exhibit G drawings must show land ownership as required by 18 CFR
§4.41(h). Providing the proposed project is contained within a small footprint
(including transmission line) and does not affect federal lands, applicants may
request a waiver for certification of the drawing by a registered land surveyor.

34

Q. Although my exhibit drawings have been approved by the Commission, I have not
started construction of the project. I need to make design changes to the project design.
Therefore, can I wait to file copies of the drawings?
A. NO. Once a drawing exhibit is approved by the Commission it becomes an
official record associated with the project history. As such, project owners are
required to file electronic files that contain a digital image of each approved
exhibit drawing. If a change to the design is necessary, drawings must be updated
if: a) an amendment to the license or exemption is required prior to the start of
construction. This type of project change is usually significant (e.g., the change in
location of the transmission line) and requires a Commission order. The order
will require updated exhibit drawings to be filed, or b) the design changes are
minor and C0mmission approval is granted to incorporate the changes into asbuilt exhibits upon completion of project construction (e.g., a change in pipe size
that has been approved by the Commission’s Regional Engineer when reviewing
the construction plans and specifications). As-built exhibits are usually required
to be filed within 90 days upon the completion of construction.

APERTURE CARDS
Q. Why did the Commission stop requiring copies of drawings in aperture card format?
When did this change go into effect?
A. Given the fact that digital technology has progressed and reliable standards
exist for storing drawings in electronic format, the Commission has moved to an
all-digital format. Beginning on June 1, 2014 the Commission stopped requiring
project applicants and owners to file aperture cards. The regulatory change is
effective on September 8, 2014, pursuant to publication in the federal register.
However, when archiving project related exhibits for safe long term storage,
project owners and developers are free to choose whatever format they deem
necessary or convenient.

ELECTRONIC EXHIBITS (TIFF FILES)
Q. Explain how the Commission decided on a new standard for digital images of exhibit
drawings.
A. As discussed above, project owners may continue to archive copies of
approved exhibit drawings in aperture card format. However, the Commission
has adopted a digital image file format standard that should minimize the cost to
project owners. Drawings must be black and white graphic files that use a TIFF
format, CCITT Group 4 compression. We chose this standard because the format
minimizes computer storage space while maximizing the quality of the drawing
features. Any drawings not received in this format will be rejected by the
Commission.

35

Q. My project drawings were created on a CAD system and use various colors to show
project features. Why is this format not adequate?
A. Creating files and drawings in multiple colors may be an excellent solution for
project owners to readily identify project features. It can allow for the use of color
coding formats to identify project features or other information. However, when
output to electronic file formats, color drawings formats occupy tremendous
storage space and are slow to travel over computer networks. These solutions are
not necessarily efficient for managing large amounts of data at a national level or
for large corporations. Combining black and white drawings with various shading
or cross-hatch schemes is just as effective as color in displaying important project
information.
Licensees are experimenting with the use of orthophotographs as a backdrop on
which map features can be overlaid on a CAD system. Orthophotos have the
positive attributes of a photograph such as detail and timely coverage, and the
positive attributes of a map including uniform scale and true geometry.
Orthophotos are created by scanning aerial photographs and converting them
into a raster image file format. However, orthophotos do not convert well to a
TIFF CCITT Group 4 image because they are either color or gray scale images.
Licensees must be cautious in using orthophotographs to create Exhibit G
drawings. Exhibits that convert to poor quality TIFF files, or result in excessive
file sizes will be rejected.
Q. What are the common problems the Commission encounters with filed electronic
images?
A. Most of the problems are related to a lack of quality control. We have found
errors with drawings filed with the Commission, in the following order of
frequency:






Wrong file format name. All electronic files MUST follow the format
specified in the requirements. The Commission uses software to index and
retrieve all exhibit drawing images. The software requires the specific
format described in each order approving exhibit drawings.
Wrong raster file format. Images MUST be saved as black & white images
in a TIFF CCITT Group4 compression format (no LZW b/w compression,
no Huffman RLE compression, no color images, and no PDF files). The
TIFF CCITT Group4 format produces the highest quality image with the
least amount of storage space. The specification is also known as CCITT
T.6 bi-level encoding. Many project owners do not take the time to check
their work before filing the images with the Commission.
Image size. Exhibits should be a minimum of 22” x 34” and a maximum of
24” x 36” before converting to a digital image. These sizes will result in the
highest quality when converted to digital format and printed in hard copy.
All drawings must be legible when reduced to a print that is 11” on its
shortest (see 18 CFR §4.39(a) and (d)).

36





Fuzzy image. Digital images MUST have a minimum resolution of 200 dpi
for acceptable quality. Higher resolutions may be necessary when the
quality of the native drawing is poor, but should not exceed 300 dpi unless
absolutely necessary.
No data. The Commission has received CDs with missing data, or in some
cases, no data at all. In addition, we have received CDs that were created
with specialized software and cannot be opened. All project owners should
check their data on a separate computer before filing with the
Commission. In addition, filers must AVOID using regular mail service. All
incoming mail is screened with equipment that damages magnetic and
digital media.

GIS INFORMATION
Q. What format can project owners use to file project boundary polygon/point data?
A. The regulations are fairly clear about the GIS data required by the
Commission, and most GIS systems can import data in various formats. The
Commission uses an ESRI geodatabase for its GIS system and can also easily
import properly coded GeoMedia files. With a little more effort we can also
import MapInfo, MicroStation, and AutoCAD Map files. When supplying GIS
data to the Commission it is important to include all necessary data files. ESRI
GIS data is composed of four separate files (.shp, .shx, .dbf, and .prj) and the
boundary is made up of individual vector lines. However, because the
project boundary is a closed polygon or area, GIS data needs to be
filed in this format. Project owners may want to include additional
information such as aerial photographic images, geoTIFF images, or similar
maps if they help to provide additional verification of project features.
It is important that each polygon in the polygon data table include details
regarding the owner, acreage, and whether the acreage is associated with the
project transmission line. Similarly each reference point in the point data table
should include the exhibit number, reference point ID for that sheet, and
coordinates for the data point. Sample data tables are shown below:
Boundary Point Data Table
ID
Point_No.
0
G1-1
1
G1-2
2
G1-3
3
G2-1

North_DD
38.8711
39.8514
39.8533
39.8220

37

West_DD
-121.6317
-121.6103
-121.6344
-121.6267

Federal Lands Polygon Data Table
ID
Location
Owner
0
T22 R3 S4
BLM
1
T22 R3 S4
USFS Lassen NF
2
T23 R3 S10
BLM
3
T25 R4 S26
BLM

Trans_Line
YES
YES
NO
NO

Acreage
5.21
14.2
100.09
1.78

Q. What format can project owners use to file project feature polygon/polyline/point
data?
A. Since the project reservoir is a closed polygon area, the GIS data needs to be
filed in polygon format. In general, the reservoir area required is associated with
the operating water level described in the license. This level should reflect the
normal maximum water surface elevation for the reservoir. A separate polygon
should also be provided for the tailrace area below the reservoir and within the
project boundary. The licensee should identify the elevation and datum of the
reservoir polygon file. When the Commission approves a shoreline management
plan, we will require GIS polyline data associated with classifications of shoreline
use. Each polyline should be along the shoreline associated with the reservoir and
represent a linear classification of shoreline use. Finally, point data for project
features should be filed as a latitude/longitude point that best represents the
location of each feature being identified. If the licensee is using a GIS system to
manage the project, these points can be easily obtained. Otherwise, inexpensive
GPS receivers typically have accuracy sufficient to meet the Commission’s
requirements. The point should be along the shoreline for a water related activity,
and may be inland for land based features associated with the project. For point
data associated with project recreation facilities/amenities the associated
requirements are discussed in detail in the Commission’s guidance document
Project Recreation Facilities and As-Built Site Plan Drawing Guidance; which
can be found on the Commission’s internet site. Sample attribute data table for
polygon, polyline, and point data are shown below:
Reservoir Polygon Data Table
ID
Reservoir
Elev
0
Rainbow
950.3
1
Rainbow
902.2
2
Burnt Creek
455.7
3
Hobo
1290.2
4
Holebrook
602.7

Datum
NGVD 29
NGVD 29
MSL
NAD 83
NAVD 88

38

Notes
reservoir
tailwater
reservoir
reservoir
reservoir

Shoreline Classification Polyline Data Table
ID
Reservoir Location
Shoreline_Classification
0
Rainbow
G-2
Environmental Management
1
Rainbow
G-3
Residential
2
Rainbow
G-2
Public Recreation
3
Rainbow
G-1
Project Operations
4
Rainbow
G-7
Commercial

Length
45.5
15.8
3.5
1.12
.03

Recreation Amenity Point Data Table
Proj
No

Development
Name

Rec
Amenity

Rec Amenity
Type

P####

Falls Park Day
Use Area

Picnic Area

P####

Falls Park Day
Use Area

Interpretive
Display

P####

Falls Park
Campground

P####

Tailwater
Fishing

Campground

Tailwater
Fishing

Amenity
Status

LAT

LONG

FERC
Cite
date

Constructed
or
Unconstruct
Constructed
or
Unconstruct
Constructed
or
Unconstruct
Constructed
or
Unconstruct

Notes

6
tables
history &
fishing
info
4
camp
sites
fishing
pier

Q. Explain what the Commission does with the GIS information that is filed?
A. To understand what we do with the GIS information requires an
understanding of the process. First, we review all electronic drawing files for
acceptability (i.e., required information and drawing clarity). Next we import the
GIS data to our system. Then, the reference point data file is used to import each
exhibit drawing TIFF file to our GIS system. We georeference the drawing and
expect the project boundary on the TIFF file to match exactly with the polygon
data. We also expect the reference points to match exactly with those on the
exhibit drawings. If the project occupies any federal lands, we import the federal
land polygon data and check against the exhibit information for accuracy. We use
1:24,000 USGS quadrangle maps plus digital ortho photos (DOQs) to check
project boundary and location of project features. All information is stored in a
project geodatabase.
The Commission’s regulations specify the preparation of GIS project boundary
data must be accurate to 1:24,000; which translates to ±40 feet. However, since
the project boundary drawings are based on more accurate standards, if prepared
properly they should be very accurate when viewed on a GIS system. Therefore, if
the GIS polygon data matches exactly with the exhibit G drawing it will be more
accurate than 1:24,000.

39

Commission staff will use the GIS data for recreational, shoreline management,
and project features to verify compliance with license articles. In addition, as
applications are received for project related activities, or non-project use of
project lands, we use the GIS data as a review tool to verify consistency with
approved land uses and facilitate the license amendment process. Finally,
compiling project data in a spatial format will facilitate future resource planning.
Q. What are the common problems the Commission encounters with filed GIS
information?
A. As mentioned above, the most common problem with GIS data is missing
files. We also find errors with drawings filed with the Commission, in the
following order of frequency:








Missing data files. Each GIS data file needs to be accompanied by polygon
data, point data, and metadata. In addition, if the project is on federal
lands, separate polygon data must be filed for the portion of the project on
federal lands.
GIS data are not properly georeferenced. Project owners should always
make sure the GIS data will import to the proper spatial location. In some
cases, we have received GIS data that have located hydropower projects in
the middle of the Pacific or Caribbean oceans, or in Canada.
Boundary orientation to exhibit drawing. The Commission uses the
project boundary reference point file to import the electronic exhibit files
(TIFF files) and check them against the boundary polygon file. A project
boundary polygon file and point file must match exactly to the exhibit
drawing file. A failure to match means the vector file is incorrect or the
exhibit drawing is not accurate.
Boundary/exhibit orientation to quad and ortho photo maps. After
making sure the project boundary polygon and point data match exactly
with the exhibit image, Commission staff checks to make sure the project
is accurate to a scale of 1:24,000. Project owners may use their own aerial
photography or more accurate information to verify the location of project
boundary and should supply any supporting information to ensure
accuracy.

Q. I do not have a GIS system and must outsource the preparation of project boundary
exhibits and the associated GIS work. Before I make a filing with the Commission, how
can I be sure the files created by my contractor are accurate and will meet the
Commission’s requirements?
A. Since you do not have a GIS system, the best way to check any work
performed by others is to request screen snapshots of the GIS work. We found
this is a very effective way to communicate issues such as project boundary
alignment with the USGS quadrangle maps or DOQs, incorporation of adequate
reference points, and alignment between the Exhibit Gs and the polygon data. In
addition, you should make a checklist of the data files necessary for the CD you
will be filing with the Commission.

40

Q. How does FERC intend to use the GIS data filed for project boundaries?
A. The Commission imports project boundary data in two forms: a) entire
project boundary, and b) federal land parcels. GIS data are used to track
hydropower resources throughout the country, and specifically those projects
located on federal lands. Project boundary information is used in conjunction
with other GIS resource data and assists Commission staff in project related
reviews and resource assessments. Because the GIS data are only accurate to a
scale of 1:24,000, we do not use the information to replace project boundary
information or details that are supplied by project owners with a description of
the project. In addition, we do not consider the GIS data as a substitute for legal
boundary surveys.
Q. I am having trouble creating GIS data in a reasonable time frame for filing with the
Commission. Also, I am receiving cost estimates that vary widely between vendors.
What can I do?
A. Commission staff are available to assist all licensees in meeting their filing
requirements. Licensees are encouraged to provide draft GIS data files for
informal guidance throughout the review process. In general, staff provides
guidance to licensees and their consultants so there are no surprises when an
order is issued. After an order is issued, if a licensee is having difficulty meeting a
filing date for a valid reason, an extension of time to file exhibits and GIS data
may be granted.
Finally, we agree that contractor costs to comply with the Commission’s exhibit
and GIS data requirements may be high. However, it has been our experience
that high costs are associated with consultants who may not fully understand the
Commission’s requirements. Our staff work with many licensees and consultants
to facilitate the entire process of creating project exhibits and GIS data. If done
properly, using a GIS based system to create these documents will save money
over the longer term, especially for projects with resource tracking requirements,
or where there is development activity in and around reservoir areas. Licensees
are encouraged to contact Commission staff for tips on how to keep exhibit and
GIS data costs to a minimum.

41

APPENDIX 5
Form FERC-587
for Projects Located on Federal Lands

42

Form FERC-587
OMB No. 1902-0145
(Expires 07/31/2015)

INSTRUCTIONS FOR COMPLETING FORMS FERC-587
Form FERC-587 is issued to identify those project boundary maps associated with federal lands. There
are two versions of the form to account for the two different ways land is surveyed in the United States,
the Public Land States and the Non-Public Land States. The Public Land States version is used for
projects located on the western side of the United States, and is based on the Federal Township and
range system. The Non-Public Land States version is to be used for most of the projects located on the
eastern side of United States, including Texas, and is based just on county information.
To complete either form you must:
1. Identify the boundary maps in the license, preliminary permit, or in the application for license,
amendment of license, or preliminary permit.
2. Provide the project number assigned by FERC. Type or print legibly when entering information on the
form. Include your signature, and date completing the form.
3. Microfilm copies of the project boundary maps must be submitted with the land description forms as
directed by FERC. Each map must be reproduced on silver or gelatin 35 mm microfilm mounted on type
D (3-1/4" X 7-3/8”) aperture cards. The project number followed by a hyphen and sheet number or letter
must be typed on the front of each card in the upper right corner.
4. Mail a copy of the completed land description forms and aperture cards to:
Secretary
Routing Code PJ-12
Federal Energy Regulatory Commission
888 First Street NE
Washington, DC 20426
Another copy of the form FERC-587 must be filed with the Bureau of Land Management state office(s)
involved using the format below. Go to the following internet address to get mailing address for a
particular State Office ( http://www.blm.gov/nhp/directory/index.htm).
State Director
Bureau of Land Management
City, State Zip
ATTN: FERC Withdrawal Recordation
5. Keep the land description forms and project boundary drawings up-to-date. If the project boundary
changes, revised land description forms and drawings must be provided to the Commission immediately.
The revised land description forms must be fully completed so as to supersede (not supplement) earlier
forms. Mail updates in accordance with instruction 4.
If there are any questions, please contact the FERC at (202) 502-8872.
6. Where to send comments on the Public Reporting Burden. The public reporting burden for this
collection of information is estimated to average 1 hour per response, including the time for reviewing the
instruction, searching existing data sources, gathering and maintaining the data needed, and completing
and reviewing the collection of information. Send comments regarding this burden estimate or any
aspect of this collection of information, including suggestions for reducing this burden, to the Federal
Energy Regulatory Commission, 888 First Street., Washington, DC 20426 (Attention: Mr. Michael Miller,
ED-30); and to the Office of Information and Regulatory Affairs, Office of Management and Budget,
Washington, DC 20503 (Attention: Desk Officer for the Federal Energy Regulatory Commission). This is
a mandatory information collection requirement.)

43

To complete the Public Land States (Rectangular Survey System Lands) you need
to:
1. Identify the state in which the project is located. If the project lies within multiple states, then provide
the state for the township which the form refers.
2. Provide the FERC Project Number assigned by FERC (i.e., P-96). Only one project number should
appear on the form.
3. Identify the Township, Range and Meridian where the project lands and federal lands overlap. Each
township is depicted in a map by an identifying number according to where it falls (i.e. T9SR22E). The
east/west numbers are identified by the term "Range" and the north/south numbers are identified by the
term "Township". The completed land description form will identify the sections of the township affected
by the project (both federal and non-federal lands) and provide references to the maps that show the
project boundary in those sections. Complete a separate form for each township identified, regardless of
the ownership status of the lands.
4. Identify whether you are completing the form for a licensed project or a preliminary permit. Identify
whether the license is pending or issued. Provide an expiration date in case of a preliminary permit.
5. Using the township grid provided on the form, identify the section (s), in which the federal land is
located on the map. Every Section is numbered, from 1 to 36, depending upon its position within the
township. Specify the exhibit sheet (drawing) number, or letter within the appropriate township section.
If the FERC sheet numbers have been assigned, they must be used on the land description forms. In
those cases where FERC has not assigned sheet numbers, assign letter designations A, B, C, etc., in lieu
of FERC sheet numbers. Permittees and permit applicants must assign letter designations since FERC
does not assign sheet numbers for permits. The sheet numbers or letters are to be entered in the
appropriate place on the land description forms to provide references to the maps. (i.e., if sheets 74 and
75 show the project boundary in sections 13 and 24 of a township, the numbers 74 and 75 would be
inserted in the box on the land description form representing sections 13 and 24).
6. Provide the name and telephone number of the person completing the form, and the date the form is
submitted.

44

Form FERC-587
OMB No. 1902-0145
(Expires 07/31/2015)
LAND DESCRIPTION
Public Land States
(Rectangular Survey System Lands)

1. STATE

2. FERC PROJECT NO. __________________

3. TOWNSHIP

RANGE

MERIDIAN _____________

4. Check one:

Check one:

License
Preliminary Permit

Pending
Issued

If preliminary permit is issued, give expiration date: __________________________

Section 6

5. EXHIBIT SHEET NUMBERS OR LETTERS
5
4
3
2

1

7

8

9

10

11

12

18

17

16

15

14

13

19

20

21

22

23

24

30

29

28

27

26

25

31

32

33

34

35

36

6. contact's name
telephone no. (
Date submitted

_
)
_

This information is necessary for the Federal Energy Regulatory Commission to discharge its responsibilities under
Section 24 of the Federal Power Act.

45

To complete the Non-Public Land States ( Non-Rectangular Survey System Lands
in Public Land States) form you need to:
1. Identify the state in which the project is located. If the project lies within multiple states, then provide
the state for the counties which the form refers.
2. Provide the FERC Project Number assigned by FERC (i.e., P-00). Only one project number should
appear on the form
3. Identify the federal reservation that is located within the project boundary as shown on the maps.
4. Identify the federal land holding agency responsible for the federal land within the project boundary
as shown on the maps
5. Identify the county or counties the federal land lies in.
6. Identify whether you are completing the form for a licensed project or a preliminary permit. Identify
whether the license is pending or issued. Provide an expiration date in case of a preliminary permit.
7. Complete a land description form for each federal tract with lands inside project boundaries. If more
than one land description form is required to list the Federal tracts, page numbers must be shown in the
upper right corner of the form, e.g., page 1 of 2. Do not list more than one project or state on each form.
8. Provide sheet numbers or letters that should be entered on the lines provided under "Exhibit Sheet
Numbers) or Letter(s)" opposite to the corresponding Federal tract identification designated by the
Federal land holding agency. Specify the exhibit sheet (drawing) number, or letter within the appropriate
township section. If the FERC sheet numbers have been assigned, they must be used on the land
description forms. In those cases where FERC has not assigned sheet numbers, assign letter
designations A, B, C, etc., in lieu of FERC sheet numbers. Permittees and permit applicants must assign
letter designations since FERC does not assign sheet numbers for permits.
9. Provide the name, telephone number of the person completing the form, and the date the form is
submitted.

46

47

Form FERC-587
OMB No. 1902-0145
(Expires 07/30/2012)
LAND DESCRIPTION
Non-Public Land States
(and Non-Rectangular Survey System Lands in Public Land States)

1. STATE

2. FERC PROJECT NO. ____________________

3. FEDERAL RESERVATION: ___________________________________________
4. FEDERAL LAND HOLDING AGENCY: __________________________________
5. Counties: _________________________________________________________
6. Check one:
License
______Preliminary Permit

Check one:
Pending
Issued

If preliminary permit is issued, give expiration date:

7. Federal Tract(s)
Identification

8. Exhibit Sheet Number(s)
or Letter(s)

9. contact's name
telephone no. (
date submitted

_
)
_

This information is necessary for the Federal Energy Regulatory Commission to discharge its responsibilities under
Section 24 of the Federal Power Act.

48

BUREAU OF LAND MANAGEMENT STATE OFFICES
Last Updated September 21, 2009
ALASKA

Bureau of Land Management
Division of Alaska Lands (AK-963)
222 W 7TH AVE STOP 13
ANCHORAGE AK 99513-7504

ARIZONA

Bureau of Land Management
Division of Lands and Renewable Resources (AZ-930)
1 N CENTRAL AVE STE 800
PHOENIX AZ 85004-4427

CALIFORNIA

Bureau of Land Management
Branch of Adjudication and Records (CA-943.5)
2800 COTTAGE WAY SUITE W1623
SACRAMENTO CA 95825-1886

COLORADO

Bureau of Land Management
Branch of Realty Programs (CO-935)
2850 YOUNGFIELD ST
LAKEWOOD CO 80215-7210

IDAHO

Bureau of Land Management
Land Services Section (ID-943A)
1387 S VINNELL WAY
BOISE ID 83709-1657

MONTANA
NORTH DAKOTA
SOUTH DAKOTA

Bureau of Land Management
Branch of Land Resources (MT-932)
5001 SOUTHGATE DR
BILLINGS MT 59101-4669

NEVADA

Bureau of Land Management
Branch of Lands and Minerals Operations (NV-943.2)
PO BOX 12000
RENO NV 89520-0006

NEW MEXICO
OKLAHOMA
KANSAS
TEXAS

Bureau of Land Management
Branch of Lands and Minerals Operations (NM-943C-2)
PO BOX 27115
SANTA FE NM 87502-0115

49

OREGON
WASHINGTON

Bureau of Land Management
Lands and Minerals Adjudication Section (OR 936.1)
PO BOX 2965
PORTLAND OR 97208-2965

UTAH

Bureau of Land Management
Branch of Lands and Minerals Operations (UT-942)
PO BOX 45155
SALT LAKE CITY UT 84145-0155

WYOMING
NEBRASKA

Bureau of Land Management
Branch of Land Resources (WY-931)
PO BOX 1828
CHEYENNE WY 82003-1828

ARKANSAS
IOWA
LOUISIANA
MINNESOTA
MISSOURI
DISTRICT OF
COLUMBIA
PUERTO RICO
and all states east
of the Mississippi
River

Bureau of Land Management
Branch of Lands (ES-930)
7450 BOSTON BLVD
SPRINGFIELD VA 22153

50