Name of Person or Organization: Environmental Resources Management (ERM) 

COMPLETE EITHER THE REPRESENTATION OR THE DISCLOSURE -

NOT BOTH 

OCI Representation Statement 

I hereby certify (or as a representative of my organization, I hereby certify) that, to the best of my 

knowledge and belief, no facts exist relevant to any past, present or currently planned interest or activity 

(financial, contractual, personal, organizational or otherwise) that relate to the proposed work; and bear 

on whether I have (or the organization and any of its affiliates has) a possible conflict of interest with 

respect to (I) being able to render impartial, technically sound, and objective assistance or advice; or (2) 

being given an unfair1 competitive advantage. 

Signature: Date: 

Name: Title: 

Organization: 

OCI Disclosure Statement 

I hereby certify (or as a representative of my organization, I hereby certify) that, to the best of my 

knowledge and belief, all relevant facts -- concerning past, present or currently planned interests or 

activities (financial, contractual, organizational or otherwise) that relate to the proposed work and bear on 

whether I have (or the organization has) a possible conflict of interest with respect to (I) being able to 

render impartial, technically sound, and objective assistance or advice, or (2) being given an unfair 

competitive advantage--are fully disclosed on the following page(s) and formatted to show: 

);> For ease of presentation, the OCI infonnation is divided into four parts, indicating whether 

the possible OCI is: organizational, contractual;-financial, or other; 

);> The company, agency, organization in which I (or my organization) have a past, present, or 

currently planned interest or activity (financial, contractual, organizational, or otherwise); 

);> A brief description of the relationship; 

);> The period of the relationship; 

};> The extent of the relationship (such as value of financial interest of work; percent of total 

holdings, total work, etc.); and 

);> A mitigation plan, if necessary. 

Signature: ~-~·----. Date: August 12, 2016 

Name·: Stuart A. Buchanan Title: Partner 

Organization: Environmental Resources Management 

An unfair competitive advantage does not include the normal flow of benefits from the performance of the contract. 

Page B-1 

Enclosure 1 
Name of Person or Organization: Environmental Resources Management (ERM) 

OCI Questionnaire1 

l. Will you (or your organization) be involved, or have you previously been involved, in the 

perfonnance of any portion of the project under this solicitation, aside from your organization's 

proposed work as a third-party contractor? 

( ) No. 

(X) Yes. The portion of the proposed work; the proposed hours and dollar value; and the 

type of involvement are fully disclosed on the attached pages. 

2. What is (are) the major type(s) of business conducted by you (or your organization)? Please reply 

on the attached pages. 

3. Do you (or your organization) have any affiliates? 

( ) No. 

(X) Yes. The name and a description of the major type(s) of business that each affiliate 

conducts are disclosed on the attached pages. 

4. Will any of the following be involved in perfonning the proposed work under this solicitation: 

(a) any entities owned or represented by you (or your organization); (b) your organization's Chief 

Executive or any of its directors; or (c) any affiliates?2 

(X) No. 

( ) Yes. A full disclosure and discussion is given in the attached pages. 

5. Are you (or your organization) an energy concern? 

(X) No. 

( ) Yes. A full disclosure and discussion is given on the attached pages. 

6. Do you (or your organization) have a direct or indirect relationship (financial, organizational, 

contractual or otherwise) with any business entity (including a parent company, affiliate, or any 

other business arrangement). that could be affected in any way by the proposed work under this 

solicitation? 

( ) No. 

(X) Yes. List the business entity(ies) showing the nature of your relationship (including the 

dates of the relationship, and the dollar value of any financial relationship) and how it 

would be affected by the proposed work under this solicitation. 

All questions in the questioMaire apply lo parent companies and affiliates as well. Whenever possible, each affiliate should submit a 

separate questionnaire. However, in the event each affiliate does not submit a separate questionnaire (for instance, to avoid 

complc:ting a large number of questionnaires). this questionnaire must incorporate information regarding all affiliates. 

See Definitions in Chapter 4 (defining affiliates as businesses that directly or indirectly control or have the power to control another, or 

when a third party controls or has the power to control both businesses). 

Page B-2 

Enclosure 2 
Name of Person or Organization: Environmental Resources Management (ERM) 

7. What percentage of your total income for the current and preceding fiscal years resulted from 

arrangements with any of the entities identified in Question 6 above? 

0.22% For the current fiscal year: from 4/01/2016 to 7/31/2016. 

0.10% For the preceding fiscal year: from 4/01/2015 to 3/31/2016. 

0.07% For the second preceding fiscal year: from 4/01/2014 to 3/31/2015. 

8. Do you (or your organization) currently have or have you had during the last six years any 

arrangements (for example, contracts and cooperative agreements) awarded, administered, or 

funded-wholly or partly-by the Commission or any other Federal agency which relate to the 

proposed Statement of Work? 

(X) No. 

( ) Yes. A full disclosure and discussion is given on the attached pages. 

9. Do you (or your organization) have or have you ever had any contracts, agreements, special 

clauses, or other arrangements which prohibit you (or your organization) from proposing work to 

be performed in this solicitation or any portion thereof? 

(X) No. 

( ) Yes. A full disclosure and discussion is given on the attached pages. 

10. Do you (or your organization) have any involvement with or interest (direct or indirect) in 

technologies which are or may be subjects of the contract, or which may be substitutable for such 

technologies? 

(X) No. 

( ) Yes. A full disclosure and discussion is given on the attached pages. 

I I. Could you (or your organization) in either your private or Federal Government business pursuits 

use information acquired in the performance of the proposed work under this solicitation; such as: 

(a) Data generated under the contract? 

(b) Information concerning Commission plans and programs? 

(c) Confidential and proprietary data ofothers? 

(X) No. 

( ) Yes. A full disclosure and discussion is given on the attached pages. 

12. Under the proposed work under this solicitation, will you (or your organization) evaluate or 

inspect your own services or products, or the services or products of any other entity that has a 

relationship (organizational, financial, or other, such as a client) with you (or your organization)? 

This could include evaluating or inspecting a competitor's goods and services. 

(X) No. 

( ) Yes. A full disclosure and discussion is given on the attached pages. 

13. To avoid what you perceive as a possible OCI, do you (or your organization) propose to: exclude 

portions of the proposed work; employ special clauses; or take other measures? 

(X) No. 

( ) Yes. A full discussion is given on the attached pages. 

( ) No possibility of an OCI is perceived. This answer is briefly justified on the attached 

pages. 

Page B-3 

Enclosure 2 
INFORMATION WITHHELD PURSUANT TO FOIA EXEMPTION 4 

Name of Person or Organization: Environmental Resources Management (ERM) 

I hereby certify that I have authority to represent my organization, and that, to the best of my knowledge 

and belief, the facts and representations presented on the seven pages of this questionnaire, including the 

supplemental responses attachment, are accurate and complete. 

Signature: ..::S;U~-· Date: August 12, 2016 

Name; Stuart A. Buchanan Title: Partner 

Organization: Environmental Resources Management 

Page B-4 

Enclosure 2 
INFORMATION WITHHELD PURSUANT TO FOIA EXEMPTION 4 

Name of Person or Organization: Environmental Resources Management (ERM) 

Supplemental Responses to OCI Questionnaire 

1. Will you (or your organization) be involved in the performance of any portion of proposed work? 

Environmental Resources Management (ERM) is responsible for 100 percent of the work for the thirdparty environmental assessment (EA) preparation and related activities for 

& Atlantic Bridge Project. 

ERM has been supporting the FERC staff in their National Environmental Policy Act (NEPA) review of 

the Atlantic Bridge Project since pre-filing was initiated in February 2015. The EA was released in early 

May and ERM is currently assisting FERC staff with tracking comments, reviewing supplemental filings 

by-and- and the preparation of the decision document. Work on the Atlantic Bridge 

Project is expected to be completed by the end of2016. 

2. What is (are) the major type(s) of business conducted by you (or your organization)? 

ERM provides environmental consulting services to clients worldwide, including private and public oil 

and natural gas industry clients in upstream, mid-stream and downstream sectors. In the U.S. ERM also 

provides third-party NEPA, public affairs, and construction compliance monitoring services for energy 

projects to local, state, and federal agencies. 

The major business practice areas for ERM include: 

• Impact Assessment & Planning (IAP; this category includes Third-Party FERC NEPA services 

contracts); 

• Risk Management (environmental, human health, safety and catastrophic risk assessment and 

management); 

• Performance Assurance (facility EHS compliance and auditing); 

• Contaminated Site Management; 

• Air Quality and Climate Change; and 

• Transaction Services. 

3. Do you (or your organization) have any affiliates? 

Natural Resource Group, LLC (NRG) began the work as the FERC third-party contractor for the Atlantic 

Bridge Project. ERM completed a stock purchase of NRG on September 30, 2014 and NRG continued to 

operate as a wholly-owned subsidiary of ERM until April 1, 2016, when NRG completed its integration 

into ERM and began operating as ERM. ERM is comprised of a number of legal entities, but operates as 

a single, global company. 

6. Do you (or your organization) have a direct or indirect relationship (financial, organizational, 

contractual, or otherwise) with any business entity which could be affected in any way by the 

proposed work? 

NRG and ERM contractually provided or are providing consulting services to the following business 

entities: 

During FYJ 5, NRG provided environmental 

pennitting support for . Revenues associated with this work totaled 

•••• This work is complete and none of this work is related to the Atlantic Bridge Project. 

Page B-5 

Enclosure 2 
INFORMATION .WITHHELD PURSUANT TO FOIA EXEMPTION 4 

Name of Person or Organization: Environmental Resources Management (ERM) 

During FY 15, ERM conducted a file review for a co-generation 

facility in Revenues associated with this service totaled-· ERM's work on this 

project is complete and none of this work is related to the Atlantic Bridge Project. 

DuringFYIS, FY16, and FY17, NRG and ERM has provided or 

is providing air regulatory reviews and preparation of compliance documentation for state and federal 

air requirements; assistance with development of soil erosion and sediment control drawings; 

development of environmental training materials; pennitting for small pipeline maintenance and 

replacement projects in ; permitting assistance for pipeline abandonment projects in 

- and ; a feasibility study for a confidential pipeline project in several western 

states; and bid support for a pipeline project in-· Revenues from this work totaled-· 

None of this work is related to the Atlantic Bridge Project. 

• . During FYIS, FY16, and FYl7, NRG/ERM has provided public 

. The project will deliver natural gas from 

markets. is one of six partners in the project and 

holds a 10% stake. Pro-rata share of NRG/ERM revenues attributable to - total-· This 

project is not related to the Atlantic Bridge Project. 

During the period covered by this review, NRG 

to provide third-party NEPA services to the FERC to assist with the 

review of the , Atlantic Bridge, and 

NRG/ERM is also providing construction monitoring for the 

This work was/is directed by FERC staff and none of the other work outlined above is related to these 

three projects. Revenues from this work totaled-. These third-party revenues for work 

conducted on behalf of the FERC were not used in calculating the percentages in Question 7 of the 

OCI Questionnaire. 

Page B-6 

Enclosure 2 
Name of Person or Organization: Environmental Resources Management (ERM) 

CONTRACTOR CEii NON-DISCLOSURE AGREEMENT 

On behalf of Environmental Resources Management (ERM), I certify that ERM will abide by the 

following tenns with respect to critical energy infrastructure infonnation (CEii) that the company has 

access to because of its work for the Federal Energy Regulatory Commission: 

» Only authorized company employees with a need for the infonnation will be given access to 

CEii. ERM will maintain a list of each employee who is given access to CEii, including a 

listing of each project for which the employee has been given CEIL 

» ERM will not provide CEii to or discuss CEii with anyone outside the company, except that 

CEil may be discussed with the project's owner, operator, or applicant. 

» Any copies made of CEil will be marked as CEii, and treated as CEii. 

» CEii will be used only in perfonnance of ERM's work for the Federal Energy Regulatory 

Commission. When ERM has completed work on the project, all CEii will be returned to the 

Commission. 

)> I acknowledge that a violation of this agreement may result in negative consequences and 

could affect ERM's ability to contract with the Commission in the future. 

By: ..::::~~---. 

Title: Partner 

Representing: Environmental Resources Management 

Date: August 12. 2016 

Page B-7 

Enclosure 3