Oil and Gas Exploration Sector

Jetta Operating Company, Inc., Brazoria County, Texas

Issue: It is an extremely complex task to obtain access and permits to perform 3-D seismic investigation. This work requires authorizations; permits; and/or coordination with land owners, local authorities, public safety organizations, state and federal resource protection agencies, etc. With less than one month to project kick-off, Jetta Operating Company, Inc. (Jetta) determined proposed seismic operations to be conducted within portions of the San Bernard National Wildlife Refuge required a permit from the US Fish and Wildlife Service (USFWS). A land agent with whom Goshawk had previously worked in sensitive habitats recommended our services to Jetta.

Action: Goshawk quickly coordinated with project engineers, geologists, and land agents to determine the extent of the proposed actions and outlined opportunities to reduce impacts within refuge lands. Goshawk contacted the Refuge Manager to determine the most expedient way to obtain the appropriate permits. Goshawk filed a permit application and, with responsive input from the entire Jetta team, compiled a Plan of Operations within one week.  While the USFWS evaluated the document, Goshawk distributed the plan to team members to incorporate the requirements into their project schedule and equipment requisitions. 

Outcome: A meeting with the USFWS Refuge Manager and Jetta team members was conducted on the proposed site to discuss implementation of the Plan of Operations and specific items of concern. The permit authorization was signed at the end of the meeting and the project was allowed to proceed on refuge lands. Thanks to the flexibility of all parties involved, the permit was obtained in less than one month.

ConocoPhillips Company, DeWitt County, Texas

Issue: After a ConocoPhillips project manager stated the trouble they were having negotiating a Section 10 Permit with the US Army Corps of Engineers (USACE), a Goshawk client recommended our services.  Another party had submitted the permit application more than nine months before Goshawk was contacted. The ConocoPhillips project proposed the installation of a pipeline across the Guadalupe River (a Section 10 [navigable] waterbody) and several tributaries that were also regulated by the USACE. 

Action: Goshawk immediately gathered project stakeholders including surveyors, engineers, construction contractors, company representatives, and USACE to discuss the project. Goshawk’s cultural resources staff quickly developed a research methodology that would address the agency’s concerns and cause minimal project delays or modifications. Goshawk proposed a cultural resource survey, augmented by backhoe trenching, to rapidly evaluate the potential for the project to impact cultural resources along the Guadalupe River banks. This action required coordination with the Texas Historical Commission, General Land Office, and the Guadalupe-Blanco River Authority, in addition to USACE. Upon USACE’s approval of the research methodology, the cultural resource survey was quickly completed with two crews, and a report was submitted to the regulatory authorities. 

Outcome: An extension of a known cultural resource site was identified and documented; and minor modifications were made to the project to avoid all identified resources. From the Waters of the US determination to the completion of a cultural resource survey (including development of a scope of work), the entire project was submitted to USACE within one month. All regulatory agencies granted concurrence within two months, and the project was completed soon thereafter.

EOG Resources, Inc., McMullen County, Texas

Issue: The US Army Corps of Engineers (USACE) issued a cease-and-desist order during the construction of a 9-mile pipeline for impacts to Waters of the US associated with insufficient stormwater controls. This pipeline was essential for the transportation of product to market for numerous wells. EOG Resources, Inc., hired Goshawk to resolve the cease-and-desist order and resume construction.

Action: The cleared pipeline right-of-way (ROW) traversed 11 Waters of the US (including the Frio River) at 19 separate locations. Due to the density of known cultural resources in close proximity to the ROW, USACE required a cultural resource survey.  Goshawk identified eight new sites, revisited five previously recorded sites, and adjusted site boundaries accordingly. All sites were previously disturbed by ranching activities (repeated root-plowing to clear brush) and/or ROW clearing. No sites produced features and only one site was recommended for further investigation; however, USACE did not concur and recommended testing at eight of the 13 sites. Additional testing on adjacent private land (outside of the ROW) was not possible.  Therefore, alternate mitigation measures were investigated to offset the assumed loss of cultural resources.

Outcome: Goshawk coordinated with several public and private resource protection agencies to create a novel mitigation approach that was cost effective and could be completed relatively quickly. The mitigation included a preservation component through a non-profit organization and an educational component through a major Texas university. Goshawk helped the company resolve the enforcement action and complete construction within nine months of the cease-and-desist order’s issuance.