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
i 

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 
ii 

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. 
1 

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. 
2 

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 DESCRIPTION 

3 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):
3 

EXHIBIT DESCRIPTION 

G general location map showing all project works, project boundary, land 

ownership 

F 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 DESCRIPTION 

F general design drawings of the principal project works, showing the 

major structures 

G a map of the project showing its location and principal features, project 

boundary, impoundments, contiguous/noncontiguous features, and 

federal and nonfederal land ownership 

R (E) 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 
4 

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 
5 

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. 
6 

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. 
7 

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: 
8 

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. 
9 

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: 
10 

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 
11 

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 
12 

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. 
13 

APPENDIX 1 

Exhibit Guide to Regulatory Requirements 
14 

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 developmto appropriate ex G Pg. 108; §4conform 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 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 requPg. 120 

§4.70  Transmission Line  unconstructed  constructed 

drawings F, G, and E for unconstructed lines connected to a licensed project >5MW must meet drawings F, G, and E for unconstructed lines connected to a licensed project < 5 MW, or any coconnected to a licensed project must meet requirements of §4.61, Pg. 122 

§4.90  Conduit Exemption 

§4.92(f) - refer to specs at §4.41(g) Pg. 127 

§4.92(d) - refer to specs at §4.41(h) pg. 127 

prepare exhibit pursuant to §4.3Pg. 127 

§4.101  Exemption <10 MW 

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

§4.107(d) - refer to specs at §4.41(h) Pg. 133 

prepare exhibit pursuant to §4.3Pg. 133 

§4.81  Preliminary Permit 

§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.ec

Conservation of Water and Power Resources, then select Parts 1 – 399 for a detailed table of contents for each regulation cited abo
15 

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 
16 

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. 
17 

[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 42973-

01, 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-
18 

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); 
19 

 (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 
20 

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 
21 

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. 
22 

 (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. 
23 

[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) 
24 

APPENDIX 3 

Sample Project Boundary Drawing and GIS Data 

GIS vector data, GIS reference points (3 per drawing), and Exhibit G TIFF files imported, georeference

USGS 7.5–minute quadrangle map. When white background is eliminated from the exhibits, project boproperly 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–min

map. White background is eliminated from the Exhibit G, and project boundary does not align properly appears the drawing should be shifted west to align properly. Note the inset drawing also has three referequired. 

27 

29 

APPENDIX 4 

Frequently Asked Questions (FAQs) about 

Exhibits, Digital Drawings, and GIS Data 
30 

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 
31 

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. 
32 

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 
33 

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 
34 

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 1⁄2 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. 
35 

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. 
36 

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)). 
37 

 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. North_DD West_DD 

0 G1-1 38.8711 -121.6317 

1 G1-2 39.8514 -121.6103 

2 G1-3 39.8533 -121.6344 

3 G2-1 39.8220 -121.6267 
38 

Federal Lands Polygon Data Table 

ID Location Owner Trans_Line Acreage 

0 T22 R3 S4 BLM YES 5.21 

1 T22 R3 S4 USFS Lassen NF YES 14.2 

2 T23 R3 S10 BLM NO 100.09 

3 T25 R4 S26 BLM NO 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 Datum Notes 

0 Rainbow 950.3 NGVD 29 reservoir 

1 Rainbow 902.2 NGVD 29 tailwater 

2 Burnt Creek 455.7 MSL reservoir 

3 Hobo 1290.2 NAD 83 reservoir 

4 Holebrook 602.7 NAVD 88 reservoir 
39 

Shoreline Classification Polyline Data Table 

ID Reservoir Location Shoreline_Classification Length 

0 Rainbow G-2 Environmental Management 45.5 

1 Rainbow G-3 Residential 15.8 

2 Rainbow G-2 Public Recreation 3.5 

3 Rainbow G-1 Project Operations 1.12 

4 Rainbow G-7 Commercial .03 

Recreation Amenity Point Data Table 

Proj 

No 

Development 

Name 

Rec 

Amenity 

Rec Amenity 

Type 

Amenity 

Status 

LAT LONG FERC 

Cite 

date 

Notes 

P- 

#### 

 Falls Park Day 

Use Area 

Picnic Area Constructed 

or 

Unconstruct 

 6 

tables 

P-

#### 

 Falls Park Day 

Use Area 

Interpretive 

Display 

Constructed 

or 

Unconstruct 

 history & 

fishing 

info 

P-

#### 

 Falls Park 

Campground 

Campground Constructed 

or 

Unconstruct 

 4 

camp 

sites 

P-

#### 

 Tailwater 

Fishing 

Tailwater 

Fishing 

Constructed 

or 

Unconstruct 

 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. 
40 

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. 
41 

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. 
42 

APPENDIX 5 

Form FERC-587 

for Projects Located on Federal Lands 
43 

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.) 
44 

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. 

 

 
45 

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 Pending 

 Preliminary Permit Issued 

If preliminary permit is issued, give expiration date: __________________________ 

5. EXHIBIT SHEET NUMBERS OR LETTERS 

Section 6 5 4321

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. 
46 

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. 

 
47 
48 

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: Check one: 

 License Pending 

 ______Preliminary Permit Issued 

If preliminary permit is issued, give expiration date: 

7. Federal Tract(s) 8. Exhibit Sheet Number(s) 

 Identification 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. 
49 

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 Bureau of Land Management 

NORTH DAKOTA Branch of Land Resources (MT-932) 

SOUTH DAKOTA 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 Bureau of Land Management 

OKLAHOMA Branch of Lands and Minerals Operations (NM-943C-2) 

KANSAS PO BOX 27115 

TEXAS SANTA FE NM 87502-0115 
50 

OREGON Bureau of Land Management 

WASHINGTON 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 Bureau of Land Management 

NEBRASKA Branch of Land Resources (WY-931) 

 PO BOX 1828 

 CHEYENNE WY 82003-1828 

ARKANSAS Bureau of Land Management 

IOWA Branch of Lands (ES-930) 

LOUISIANA 7450 BOSTON BLVD 

MINNESOTA SPRINGFIELD VA 22153 

MISSOURI

DISTRICT OF

COLUMBIA

PUERTO RICO

and all states east 

of the Mississippi 

River