Suggested Best Practices for Industry Outreach Programs to Stakeholders

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TABLE OF CONTENTS

I. Introduction ..............................................................................................................................3

II. Stakeholder Outreach .................................................................................................................5

III. Components of a Stakeholder Outreach Program ..................................................................7

Management Commitment ........................................................................................................7

Internal Collaboration ...............................................................................................................7

General Training .........................................................................................................................8

Stakeholder Engagement and Education ..................................................................................8

Documentation and Tracking ....................................................................................................9

IV. Implementing Outreach Principles .........................................................................................11

Outreach Levels .........................................................................................................................11

Project Development ................................................................................................................12

Stakeholder List ........................................................................................................................12

Initial Project Brieﬁngs .............................................................................................................13

Public Outreach Materials ........................................................................................................13

Initial Communications ...........................................................................................................14

V. FERC Review Process ................................................................................................................17

Pre-ﬁling .....................................................................................................................................17

Applications ...............................................................................................................................22

Post-Certiﬁcate ..........................................................................................................................24

VI. Ongoing Public Awareness.......................................................................................................25

FERC Regulated Activities .........................................................................................................25

DOT Programs ..........................................................................................................................26

VII. Conclusion ................................................................................................................................27

I. Introduction

The Federal Energy Regulatory Commission (FERC or Commission) is an independent agency that regulates the

interstate transmission of electricity, natural gas, and oil. FERC also authorizes the siting, construction, and operation

of facilities for transporting natural gas in interstate commerce, for liqueed natural gas (LNG) import and export

terminals, and for non-federal hydroelectric projects.

Over the past decade the natural gas industry has

experienced a period of signicant growth. This

growth, along with increased public awareness of

the Commission’s review process and heightened

controversy over pipeline projects, has resulted in

greater public involvement in the development and

siting of natural gas facilities. As a result, the stas of

FERC and other federal, state, and local agencies have

become increasingly interested in providing guidance

for stakeholder involvement both within and outside the

agencies. At FERC, we

are addressing this issue, in part,

by organizing and attending conferences, seminars,

public meetings, and workshops designed to explain

and explore issues related to siting natural

1 “We,” “us,” and “our” refer to the environmental sta of FERC’s Oce

of Energy Projects.

gas projects. In addition, we routinely work with the

project sponsors and stakeholders to identify and

resolve issues prior to the ling of an application

through use of the Commission’s pre-ling process.

The pre-ling process provides an opportunity and a

means for the Commission’s sta to involve the public

early. It also reduces the time it takes to develop the

record on which the Commission makes its decision

while ensuring the highest levels of environmental

protection and public participation.

For several years we have discussed with the natural

gas industry the importance of a strong and ecient

stakeholder outreach plan that incorporates the use

of public outreach tools and involves greater training

for industry representatives. Some companies have

embraced this idea and established model programs,

while other companies have yet to implement a

stakeholder outreach program. Consequently, we met

with some of the companies with well-established

stakeholder outreach programs to review how they plan

for and execute outreach on individual projects. We

combined the results of those discussions with our own

experience to identify some of the best practices for

stakeholder outreach.

The purpose of this document is to present those best

practices and highlight the tools we believe can be used

to eectively engage stakeholders in the application

process for siting, construction, and operation of

interstate natural gas facilities and LNG terminals.

II. Stakeholder Outreach

In our experience, project sponsors have realized substantial benets from implementing a stakeholder outreach

program as part of their project development model. Companies are better able to successfully navigate the

Commission’s review processes by creating a respectful, educational, and transparent approach to engaging

stakeholders. Although not all projects will experience the same level of benet, we believe that the absence of

public outreach in the planning of a project leads to unnecessary delays. A formal company program for stakeholder

outreach, managed by a company representative who is working collaboratively with other project development

team managers from the onset of project development, greatly increases the chances that a project will proceed in a

timely, ecient, and credible manner.

“Outreach” is generally dened as two-way

communication between individuals and/or groups of

individuals or organizations focused on information

exchange, without expectation of immediate outcomes.

The goal is to create and sustain mutually benecial

relationships. As used here, “Stakeholder Outreach”

refers to the programs and processes used by companies

to communicate with, listen to, and solicit feedback

from any entity that could be aected by or is interested

in the planning, construction, and/or operation of a

project. Stakeholders include, but are not limited to,

potentially aected landowners; nearby residents;

concerned citizens; elected representatives; federal,

state, and local government ocials; non-governmental

organizations (local or national advocacy groups and

chambers of commerce, etc.); Native American tribes;

community leaders; and the media.

III. Components Of A Stakeholder Outreach Program

Based on our experience and review of existing

stakeholder outreach programs, successful programs

incorporate the following components:

• senior management support;

• integrate the thoughts and ideas of the entire

project development team;

• training programs for project sta;

• engage and educate stakeholders, including

permitting agencies and potential opponents

about the industry, as well as the project; and

• utilize technology (e.g. GIS database management

systems and interactive web based tools) to

manage and document stakeholder interactions.

Management Commitment

The establishment and implementation of a successful

stakeholder outreach program requires the support

and commitment of all levels of management. Without

this commitment and adequate resources, even well-

intentioned programs can fail. As a result, even projects

that are technically, commercially, and nancially

sound can be unnecessarily delayed. Incorporating a

stakeholder outreach program into the budget of the

project elevates its importance and shows management

commitment.

Internal Collaboration

Companies should ensure that stakeholder outreach

representatives are part of the project development

team from the outset and develop the outreach plan

to align with project goals and schedules. Public

perception can determine whether a project follows a

path of predictable success or contentious uncertainty.

Early outreach team involvement can ensure that

contacts with key stakeholders are made at the

appropriate stages in the project development to help

maintain schedules (e.g., presenting project details to

elected ocials rst).

General Training

Many companies we spoke with agree that a specic

and detailed training program for right-of-way

agents is benecial because the agents usually make

the rst contact with landowners. Of course, that is

not where the communication ends. On any given

project, engineers, environmental professionals,

surveyors, construction personnel, etc., have contact

with landowners and should be prepared to represent

the company and the project in a responsible

manner. Therefore, part of the strategy to achieve

successful public outreach is the training of all project

representatives—all company sta and contractors

that could come into contact with stakeholders. It is

important for project representatives to make a good

rst impression and then deliver a consistent and

clear message throughout the project life. One of the

companies we consulted coined the phrase “Ambassador

Training”, believing in the long-term benet of a positive

representation of the company. As a result, training

is provided to everyone within the company about

natural gas, the company’s safety program, and the

company’s commitment to the community where they

do business. It is also helpful if this training provides

an understanding of the various natural gas facility

permitting processes. This type of training provides

employees with the ability to respond when approached

by anyone in the general public to discuss a project or

natural gas in general. While many companies presume

their employees know the general facts about their

company and the industry that they work in, that is

not always the case. Providing consistent messaging

and timely feedback can improve the level of trust with

stakeholders.

Stakeholder Engagement and Education

Companies should be aware that most stakeholders,

including many agency representatives, do not have

experience with natural gas projects, particularly those

projects regulated by FERC. As a result, the project will

generally benet from an oer to provide information

and training to those agency personnel regarding the

construction and operation of natural gas facilities and

the FERC review process. This often results in improved

communication and working relationships. The training

and education could take the form of workshops,

written materials, videos, eld visits to proposed facility

locations, or visits to active construction areas. The

Interstate Natural Gas Association of America (INGAA)

website has a collection of useful videos (see ingaa.org).

Along with educating agencies about natural gas

facilities, having educational materials for the general

public is crucial to an outreach plan. Company websites,

routine project mailings, open houses, and additional

informational meetings are some eective tools.

While most stakeholder outreach focuses on a specic

project, many companies have broader outreach eorts

related to ongoing operations. This provides a good

opportunity to explain the use and benets of natural

gas, and to describe company activities through mass

media options such as billboards, television ads, social

media, etc.

The Interstate Natural Gas Association of

America Committment to Landowners

The Interstate Natural Gas Association of

America member companies agreed to adhere

to 8 Commitments and to review them with

any personnel expected to be in contact with

landowners or other stakeholders on interstate

natural gas pipeline projects (http://www.ingaa.

org/Topics/Pipelines101/LandownerCommitment.

aspx). In addition, interstate natural gas pipeline

companies are encouraged to perform additional

right-of-way agent training to assure issues and

questions are addressed in a consistent manner

during pipeline project planning.

What are these eight commitments?

1. Respect and Trust

2. Accurate and Timely Information

3. Negotiate in Good Faith

4. Respect the Regulatory Compact

5. Respond to Issues

6. Outreach

7. Industry Ambassadors

8. Ongoing Commitment to Training

Documentation and Tracking

A company should document its public outreach

eorts and agency meetings. Some companies use a

comprehensive stakeholder database system designed

as an open platform and reporting tool. The system

enables a company to track and edit stakeholder lists,

event records, individual landowner contacts, and issues

compiled from public meetings and/or mass mailings.

Individual stakeholders can be linked to events to create

a comprehensive contact record that is fully searchable

by keyword. In addition, reports and/or lists can be

generated based on categories such as municipality,

organization, or project segment. This type of system

can be useful for tracking comments and questions and

ensuring timely responses.

Filing this information with FERC throughout the

environmental review process creates a record of the

company’s outreach eorts, allowing for additional

transparency. This also aids FERC sta in ensuring that

all substantive project issues are addressed.

IV. Implementing Outreach Principles

Numerous opportunities exist within the project development process to implement stakeholder outreach. The tools

discussed in this chapter can be used to improve the development of a project.

Outreach Levels

Interstate natural gas transmission and LNG projects

vary greatly in scope and complexity. Location, facility

type and size, construction techniques, sensitive

environmental resources, landowner concern, and

regulatory agency involvement are just some of the

factors that inuence the development of a natural

gas project. Therefore, a company’s outreach program

should be tailored to meet the needs of an individual

project. To help companies determine the appropriate

level of outreach eort best suited for a particular

project, we have developed the following three project

categories.

Category I

This category includes projects that require an

environmental impact statement (e.g., projects

comprised of large diameter pipelines in new rights-of-

way and/or with new major aboveground facilities near

population centers). These projects often are more likely

to be controversial based on substantial stakeholder

concern about the project location or eects. An

eective stakeholder outreach program for a Category I

project will consider all or most of the tools described in

this document.

Category II

Generally, construction of projects in this category

would not require preparation of an environmental

impact statement (e.g., projects comprised of pipeline

loops, smaller-diameter lateral pipelines, and/or

modications to existing aboveground facilities).

Although smaller in scale than those in Category

I, projects in Category II could also be considered

controversial. An outreach process that uses a number

of the tools described in this document is appropriate

for projects in this category.

Category III

The construction and operation of projects in this

category would have little to no potential to signicantly

impact the environment and/or to be controversial (e.g.,

projects comprised of activities mostly within existing

rights-of-way or at aboveground facility sites). Although

projects in this category could be easily referred to as

insignicant and/or benign, companies should still have

some components of outreach built into the projects.

Project Development

A public outreach program for any project should begin

while the commercial aspects and project scope are still

being determined. During this early stage of project

development, the project team is created. A project

team typically consists of individuals who can eectively

fulll the following roles:

• Project Developer

• Engineer

• Project Manager

• Attorney

• Regulatory Agency Representative

• Right-of-Way (Lands) Representative

• Environmental Analyst

• Government Aairs Representative

• Stakeholder Outreach Representative

• Media/Public Aairs Representative

• Local Operations Representative.

The Commission sta suggests that companies consider

working with public relations specialists in the project

area that are familiar with elected ocials and the local

and regional political issues. These rms can assist in

disseminating project information to the media and

initial key stakeholders and in developing a complete

stakeholder outreach plan. It is very important to

understand the culture of the project area where a

natural gas facility is proposed.

INITIAL KEY STAKEHOLDERS - Will vary by

project, but will generally include federal, state,

and local elected representatives; permitting

agency ocials; and other community leaders.

Often, the rst public communication occurs while

the commercial feasibility and scale of a project is still

under development pending the outcome of an open

season solicitation. Many companies develop a news

release for the open season announcement and send

the announcement to a wide range of stakeholders

in the general project area. Upon completion of the

open season, companies should develop another news

release describing the results and any further project

denition (i.e., the capacity of the project, more specic

project locations, and the overall generic schedule for

the project). Be prepared to discuss the open season

process at initial briengs, community meetings, and

agency meetings.

Stakeholder List

In order to begin presenting a project to the public,

the project team should undertake a thorough search

to identify all parties who may be aected by or may

be interested in the project. Computer programs

are available that can gather information from local

databases, which can make developing and updating

a list of potential stakeholders much easier, but this

information must still be veried. Acquiring accurate

data and maintaining the stakeholder list is one of

the most important tasks on a project. This will avoid

the costs of returned or undeliverable mail, and guard

against stakeholder claims that they were not notied.

Development of a stakeholder list begins as soon as

the project scope has been initially identied (prior to

initiation of pre-ling activities at FERC).

A complete stakeholder list includes:

• Aected landowners and businesses

• Federal, State, and Local legislators

• Federally recognized tribes

• County and Municipal elected ocials

• Federal, State, and Local

Agencies

• Local community leaders

(including homeowners associations)

• Local emergency responders

• Local special interest groups

• Non-governmental organizations.

This list will evolve as

a project changes, and

needs to be updated

frequently. The

stakeholder list should

be commensurate with

the level of outreach

necessary for a project.

Initial Project Brieﬁngs

To help the project team manage expectations, provide

a project brieng during an inial meeng with key

stakeholders. These briengs educate public ocials

about the purpose and need of the project, the open

season results, the preferred location of proposed

facilities, the project schedule, and any public benets

to be realized by project implementation. Preparing

for project briengs by gathering information about

legacy or emerging issues will aid in focusing meetings

on concerns relevant to the project area. Be sure to ask

about the desired frequency for future update meetings.

Keeping community leaders informed about a project

also helps to ensure they are knowledgeable about a

company’s plans to interact with their constituents and

provide them with the capability to respond to inquiries.

During these project briengs, it is useful to assess the

political climate, issues, and barriers that may aect

the project and develop an understanding of any local

community perceptions or concerns regarding the

company, aliates, or the industry in general. These

initial project briengs provide an opportunity to

develop partnerships with special interest groups,

municipalities, and community business organizations.

Public Outreach Materials

Before a project can be introduced to the public,

companies should develop outreach materials specic

to the project. Depending on the project category (see

pages 11-12), the variety of public outreach materials

and scope of information presented may dier. At a

minimum, public outreach materials should include

information about the company, FERC, specic project

18 CFR 157.6(d)

(2) Denes the

stakeholders that need

to be identied for a

project.

information, and any key messages that are important

to relate to stakeholders.

In developing public outreach materials, give extra

consideration to materials for widespread use. For

example, project fact sheets/cards should not only be

provided to the stakeholders, but to all personnel (e.g.,

contractors, surveyors) who may come in contact with

stakeholders.

This helps to ensure that consistent information

about a project is communicated to the public. A

project website can eectively describe the project to

stakeholders and be a valuable resource to store and

convey information. All Category I and most Category

II projects should have a project website. A project

website can include many of the public outreach

materials suggested below. Most importantly, include

a toll-free hotline number and e-mail address on the

website and on all public outreach materials so that

stakeholders can easily access additional information

and contact a company representative that will respond

to questions or concerns. To ensure the public is aware

of project developments, we suggest that companies

update outreach materials frequently and disseminate

them as necessary.

Public Outreach Material Examples

• Project-Specic Website

• Press Release

• Project Summary

• Landowner Letters

• Company Asset and Market Area Maps

• Project Maps (including individual landowner

maps)

• Project Fact Sheets/Cards

• Project Brochures

• Power Point Slides for Presentations

• Construction Methods Graphics

• Compressor Station Fact Sheets

• Safety Brochures

• Regulatory Steps Information Sheet

• FERC Process Flowchart

• FERC Landowner Brochure

• FERC Upland Erosion Control, Revegetation, and

Maintenance Plan

• FERC Wetland and Waterbody Construction and

Mitigation Procedures

• FAQs

• Information on the purpose and benets of the

project, especially local benets

Initial Communications

Introductory Letter

Once a project is dened and the input gained from

the initial project briengs has been considered,

companies should prepare an introductory letter to

send to all stakeholders. This letter provides the basic

project information discussed previously. If available,

it is benecial to include individual parcel maps for

landowners that might be impacted by a project.

Community Meetings

After holding initial project briengs with key federal

and state public ocials and announcing the project, it

is often useful to present the project at local meetings

such as: city; county; township; parish; borough; rotary

club; homeowner associations; chamber of commerce

etc. At this time the community may have only begun

learning about the project and it is important to reach

out early and provide stakeholders with information.

Ideally, these meetings would be held prior to beginning

survey work so that landowners have the opportunity

to ask questions of and get answers from the company

before anyone approaches them to seek permission to

come onto their land to conduct a survey.

Stakeholders routinely request that the companies

themselves hold a formal question and answer meeting

to address their questions during the early stages of

a project. Commission sta believes this is benecial.

Often a local elected ocial or a local agency will

conduct these meetings; the company and FERC

sta may attend to answer stakeholder questions, as

appropriate. These types of meetings are generally

more productive when hosted and moderated by a local

entity acting as/serving as a neutral party.

Agency Meetings

Companies should present projects to key permitting

agencies as early as possible (a requirement if utilizing

the Commission pre-ling process). Introductory

agency meetings provide an opportunity to outline the

project, establish relationships with agency sta, discuss

the FERC process and recent/past project experiences,

and identify potential issues early in the process. Early

involvement with the key permitting agencies can

improve the overall eciency of the many review

processes and help keep a project on schedule.

V. FERC Review Process

Pre-ﬁling

The FERC pre-ling process is designed to engage

federal and state agencies, tribes, landowners, non-

governmental organizations (NGO), and any additional

stakeholders to identify and resolve issues at the

earliest stages of project development. The process

is mandatory for LNG terminals but voluntary for

pipeline and storage projects, although the Commission

encourages the use of the pre-ling process for all

major pipeline projects. The pre-ling process provides

an opportunity for constructive discussions about

potential issues and environmental concerns, and

early consideration of alternative pipeline routing and

aboveground facility locations. Further, it allows for

FERC sta and all stakeholders to review and discuss

the company’s draft resource reports and additional

environmental information before the company les an

application. If used eectively, the pre-ling process

can streamline the review once an application is led.

It allows the Commission to focus on any remaining

signicant issues, and to make more timely decisions.

Unlike the traditional ling process, where FERC sta

starts its environmental review after the ling of an

application, the pre-ling process involves sta devoting

signicant resources to the potential project prior to the

ling of an application. While the pre-ling process is

best suited to Category I and II projects, companies are

encouraged to consult with FERC sta when making the

decision on whether or not to use the pre-ling process.

The pre-ling regulations at 18 CFR 157.21(c) require

an initial consultation with the Oce of Energy Projects

(OEP). During the initial consultation, the company

and FERC sta will discuss the scope of the project, the

public participation plan, the content of the pre-ling

request, and the items required to complete the pre-

ling request.

A company’s request to use the pre-ling process must

contain the information described in 18 CFR 157.21(d),

which includes a:

• Project Description – The project description

describes all planned facilities and their

location(s), all project eorts to date (surveys

completed, etc.), and any outreach eorts made

prior to ling.

• Public Participation Plan – This plan outlines

how the public will be kept informed prior to

construction and for the life of the project, as

discussed further in this document.

• Stakeholder List – This list includes names and

addresses of all project stakeholders. Based on

the project, this list may change, but a working

list should be submitted to FERC sta with the

pre-ling request. See the discussion below of

§157.21(f)(3) for more information.

The FERC pre-ling starts once the Director of OEP

approves the request to enter pre-ling. There are

certain outreach eorts that are required by FERC pre-

ling regulations. Any previous outreach eorts should

continue and will serve to supplement the FERC pre-

ling regulations.

A pre-ling docket number (using the PF prex) will be

assigned to the project when the company les its pre-

ling request letter. This docket number is an important

part of the pre-ling process and enables stakeholders

to stay informed of all information led or issued on

any given project. The Commission encourages all

applicants to let stakeholders know to take advantage

of the eLibrary and eSubscription services to track

projects. More information on how to participate in the

Commission process can be found at www.FERC.gov.

Open Houses

Generally, open houses are held within 30-45 days after

receiving a PF docket number. An open house allows

the applicant to publically and formally introduce a

project to stakeholders. The format of the open

house allows stakeholders, especially those that could

be directly aected by

the project, to engage

with various applicant

representatives and

have one-on-one

discussions. In

addition, FERC sta or

its consultant attends

the open house to

educate the public

about the

Commission’s pre-

ling and application

review process and its

responsibilities

regarding the siting and construction of jurisdiconal

natural gas facilities. For this reason, coordination with

FERC sta on the location, date, and logistics of each

open house meeting is important.

The number of open houses held for each project

depends on the size and scope of the project and

the facilities associated with it. One open house is

typically held for each pipeline loop or for each county

depending on the scope of the project. It may be

appropriate to hold additional open houses at a later

date if the project scope or route changes.

Consider soliciting input about appropriate locations

18 CFR 157.21(f)(1):

Within 7 days of pre-

ling approval, and

after consultation with

Commission sta, establish

the dates and locations

at which the prospective

applicant will conduct open

houses and meetings with

stakeholders (including

agencies) and Commission

sta.

and timing from local/municipal ocials and public

relations rms when scheduling an open house. This

will assist with dissemination of information to the

community and possibly maximize turnout. Things

to consider in choosing locations include minimizing

driving distances, timing of other local events, and

seasonal activities such as harvest periods.

Prior to the open house, the applicant should:

1. Develop an Open House Checklist—decide on

format and stang levels.

2. Mail a letter to stakeholders notifying them of the

scheduled open house (date, time, and location)

and indicate that FERC sta will be in attendance.

3. Develop media kits to notify the media and the

public prior to an open house. Include newspaper

advertisements or press releases (sent one week

prior to the open house), posters in town halls,

and a media advisory notice 24 to 48 hours before

the event.

4. Ensure the project website has been updated with

the date, time, and location for each open house.

5. Provide appropriate written and graphic materials

including:

• Project Fact Sheet

• General and detailed maps (e.g., pipeline

system map, project area map, aerial maps,

USGS quadrangles). Large, clear maps/

alignment sheets showing potential pipeline

routes and aboveground facility locations

along with hard copy mapping illustrations.

A program utilizing Google Earth or similar

technologies using a computer or TV monitor is

very benecial

• Corporate materials, including information

about existing infrastructure in the area.

Include similar materials for each company

involved if the project is a joint venture

• Typical right-of-way and construction method

drawings

• Facilities models and diagrams (e.g., images/

simulations of typical compressor stations,

meter stations, valves, and pigging facilities

and visual impact simulations for aboveground

facilities that include views from the

surrounding areas)

• Construction/restoration or natural gas facilities

photos

• Company contact information

• Permit/Approval process list

• FERC Landowner Brochures

• Videos (e.g., before, during, and after

construction)

• Media kits (including news releases)

• Social media links

• Informational signs with company logo

• Company information on safety records,

easement negotiations, construction, and

operations.

Stakeholder Contact

Applicants are

responsible for

maintaining a

stakeholder mailing

list and updating

the list as required

(e.g., returned mail,

pipeline reroutes,

alternatives).

Applicants should

18 CFR 157.21(f)(3):

Within 14 days of pre-

ling approval, contact all

stakeholders not already

informed about the project,

including all aected

landowners as dened in

paragraph 157.6(d)(2).

notify anyone not previously informed about the project

within 14 days of entering pre-ling. Applicants should

send a letter to local agencies and ocials notifying

them of the project.

To keep stakeholders informed, consider issuing

a newsletter on a regular basis (at least monthly

during pre-ling) and provide updates on the project,

upcoming events, milestones, etc.

Typically, applicants will contact the following entities

regarding the project:

• Governor’s oce

• Legislators representing the project areas

• Local/municipal ocials in the project areas

• Members of Congress (and key sta) representing

the project areas

• Congressional delegation representatives in state

oces

• Aected and adjacent landowners

• Federal, state, and local resource agencies

• Native American tribes

• Public Utility Commissions

• State, local, and municipal administration

ocials, including economic and development

and energy ocials

• Community leaders

• Environmental groups

• Non-governmental organizations

• Local/neighborhood associations

• Business leaders

• Other interested parties.

Applicants should ensure that the stakeholder mailing

list is as up to date as possible. It should then be

submitted directly to the FERC environmental project

manager. The

Commission will

include entities on

the stakeholder list on

its mailing list for the

project.

• Applicants should clearly identify any changes

made to the mailing list (e.g. crossed out,

highlighted, or otherwise clearly identied).

• Applicants should submit updates to the mailing

list to Commission sta on a monthly basis.

Applicants should also consider ling all outreach

mailings with FERC, which will place them in e-Library,

as a means to reach the widest possible audience with

its outreach materials.

Before a company les a formal application with

FERC or another agency, it should consider additional

stakeholder outreach activities, such as providing key

stakeholders with information about the formal ling

process, and issuing a news release to designated media

outlets.

Status Reports and Agency Meetings

During pre-ling,

applicants should

summarize all project

activity including

stakeholder outreach

activities in a monthly

report and le it with the

Commission. This

status report, in addition

18 CFR 157.21(f)(4):

Within 30 days of pre-

ling approval, submit a

stakeholder mailing list to

the Commission sta.

18 CFR 157.21(f)(6):

On a monthly basis, le

status reports detailing

the applicant’s project

activities including

surveys, stakeholder

communications and

agency meetings.

to regularly scheduled conference calls, keeps FERC

informed of progress and ensures that sta is aware of

any issues as they arise. It also ensures that appropriate

outreach is occurring with agencies tasked with

reviewing a project. FERC sta may also hold agency

meetings for the project. The purpose of these meetings

is to gain expertise from the agencies and encourage

cooperation in FERC’s National Environmental Policy Act

review.

Applicants may be asked to attend meetings between

FERC sta and other agencies and should be prepared

to provide a brief overview of the project and discuss

any agency-specic issues.

18 CFR 157.21(f)(7):

Be prepared to provide

a description of the

proposed project and

to answer questions

from the public at the

scoping meetings held

by OEP sta.

Scoping Meetings

Scoping meetings for a project are held at the

discretion of FERC sta. A scoping meeting is a FERC-

run formal meeting that provides an opportunity for

stakeholders to orally comment (oral comments hold

the same weight as written

comments), present

written comments, and to

receive information about

the project and FERC’s

review process. Oral

comments are transcribed

and placed into the FERC’s

Public Record.

Prior to the scoping meeting, applicants should:

1. Communicate with the FERC environmental

project manager about the logistics and FERC

sta’s expectation of the applicant at the meeting.

2. Update the project website with the date, time,

and location of each scoping meeting.

3. Arrive approximately one hour before the FERC

scoping meeting begins with project materials

(maps, alignment sheets, aerials, etc.) and be

prepared to answer landowner questions before

and after the meeting.

4. In some cases you may be asked to prepare a

brief presentation (5-10 minutes) about the

project and to answer project-specic questions

on the record during the FERC scoping meeting.

The company employee(s) responsible for the

presentation should be familiar with the project,

construction details, and have experience

speaking with the public (i.e., a company

executive is not always the best choice).

Responding to scoping

comments is extremely

important and can set

the stage for judging

the eectiveness of the

pre-ling process. If the

applicant is willing and able

to make adjustments or

accommodations to address

issues raised during scoping, site visits, or stakeholder

meetings, applicants should widely publicize them. In

addition to ling the information with the Commission,

consider sending relevant information directly to

aected landowners and posting it on the project

website.

Site Visits

Site visits provide an

opportunity for FERC sta

and stakeholders to see the

project area rst hand, and

for FERC sta to hear about

local issues. Notes from

these meetings are put in

the public record. They are

not conducted for every

project.

These visits also provide another opportunity for

applicants to:

• Speak with the interested stakeholders that

attend to explain construction procedures in the

eld.

• Describe how the project will be constructed,

157.21(f)(8):

Be prepared to attend

site visits and other

stakeholder and

agency meetings

arranged by the

Commission sta, as

required.

especially to landowners of aected properties.

• Discuss unique situations and/or environmental

concerns with agencies and stakeholders.

Applicants should have alignment sheets and any site

specic mapping available during the site visit.

Applications

At the end of the pre-ling process, the company

sponsor will le a formal application with the

Commission. Commission sta will review the

application within ten business days to ensure that the

application meets the minimum ling requirements

in 18 CFR 380.12. The Commission will subsequently

issue a Notice of Application and FERC sta will begin

its preparation of the environmental document and

other non-environmental information to inform the

Commissioners at FERC when they make a decision on a

project.

Public Notiﬁcation

In addition to satisfying the Commission’s landowner

notication requirements described in 18 CFR 157.6(d),

we recommend that applicants continue to implement

stakeholder outreach eorts initiated in the project

development and/or pre-ling phases of the project.

Maintaining contact with key stakeholders, many of

whom represent or are charged with acting in the

interest of the public, can improve the relationships

crafted earlier in the development phase of the project.

The Commission maintains a publicly available

administrative record; applicants should encourage

stakeholders to take advantage of the Commission’s

§157.21(f)(9):

Within 14 days

of the end of the

scoping comment

period, respond to

issues raised during

scoping.

eLibrary and eSubscription services to access and

monitor that record. However, applicants should not

assume that stakeholders are tracking the project

through the Commission’s administrative record.

Continue updating websites, issuing press releases,

providing supplemental mailings/notices and direct

communications as necessary to ensure stakeholders

and the general public are aware of the progress of the

project through the Commission’s process and any state

processes.

There may be other site visits and stakeholder meetings

that occur after the ling of the application that could

be held by the applicant, local ocials, or FERC sta.

Applicants should continue every eort to aid in

making notications to stakeholders. The Commission’s

environmental project manager will also play a part in

this process by mailing periodic project updates to the

Commission’s stakeholder mailing list. These project

update brochures are particularly important when there

are several months between key milestones during our

project review.

Agency Correspondence

As described previously, federal, state, and local agency

representatives (government ocials) are considered

key stakeholders due to their resource expertise and/or

permitting authorities. In addition to directly notifying

these key stakeholders via phone, mail, or email when

an application is led, applicants should provide or

be prepared to provide agencies with copies of the

application including all materials, appendices, and

maps.

Continual communication is a vital component of

any public outreach program and this must include

permitting agencies. Agencies often tell FERC sta that

after ling an application, communications from the

applicant are greatly reduced. Maintaining frequent

and open communication is crucial to ensure all parties

are aware of issues that could aect the schedule.

An applicant should convene agency meetings with

federal, state, and local agencies following the ling

of an application to ensure agency representatives

understand the contents of the application, and in

turn, the applicant fully understands the agency review

processes that will follow. An applicant should answer

all questions about the application, conrm that the

agencies know who the appropriate project contacts

are, and ensure that the agencies are fully aware of how

the project will proceed.

Throughout the application review process, especially

following the issuance(s) of an environmental document

(EA or EIS), applicants should maintain communication

with the agencies. Be aware that public disclosure rules

vary greatly and applicants should know the restrictions

on their communications.

Issuance of Environmental Documents

Once we issue an environmental document, the

applicant should update its website accordingly to

help inform the key stakeholders of this milestone. The

public comment period for an EA is normally 30 days,

starting from the date of issuance. For a draft EIS, the

public comment period is at least 45 days, which starts

when the Environmental Protection Agency publishes

the Notice of Availability in the Federal Register. If

we hold one or more public comment meetings, we

will announce the date, time, and location of the

meeting(s) either in the environmental documents

or in a later notice. Comment meetings provide the

public with a forum, very similar to the scoping meeting

discussed above, to give comments on the analysis and

conclusions of the environmental document and to

ask questions about our processes and next steps. An

applicant should review the comments FERC receives

and consider ling a response if it has substantial and

constructive information to address a concern. In

addition, we may request an applicant to respond to

certain comments, if we think additional information is

needed.

Post-Certiﬁcate

If a project is approved by the Commission, the

applicant should inform key stakeholders and aected

landowners of the approval, and before construction

provide as appropriate:

• project schedule including construction and

restoration activities;

• other agency permits and conditions;

• a description of the environmental inspection

program, including inspections that may be

performed by FERC and others;

• the project’s single point of contact for landowner

issues and an outline of the applicable complaint

resolution process, including the Commission’s

“Helpline”; and

• the land agent contact information (if dierent

from land acquisition) that will be responsible for

their property.

In addition to maintaining stakeholder involvement,

an applicant’s outreach program should also strive

to maintain resource agency involvement, especially

through project construction and restoration. As

described previously, an eective stakeholder outreach

program informs the public and agencies about

the various construction-related activities including

pre-construction meetings, permit requirements,

construction schedules, environmental inspection

procedures, reporting commitments and requirements,

and measures that would be implemented to address

environmental issues (i.e., non-compliance, landowner

complaints). Stakeholder outreach can also be

benecial as applicants work to obtain any remaining/

outstanding permits.

During construction and restoration of the project,

public contact will most likely occur in the eld.

Therefore, all eld personnel are potentially subject to

public interaction and should be considered part of

the stakeholder outreach program and process. Field

personnel should be trained about appropriate public

contact and refer questions to the designated company

representative(s). It is critical, especially in any contested

proceeding, that the requisite training and construction

kicko programs include the company’s procedures

and policies for handling questions and complaints

in the eld. Be prepared to address aected property

owners’ questions/issues which may include next

steps, easement negotiations, eminent domain, and

construction practices.

During construction it may be useful to summarize

construction progress and permitting and compliance

activities in regular updates to stakeholders.

If the project schedule is delayed, project

sponsors should inform all stakeholders and

update public outreach materials.

VI. Ongoing Public Awareness

FERC Regulated Activities

After the project is built and in operation, outreach

eorts should not stop—it is a good practice to continue

to engage stakeholders about your facilities. In fact the

majority of activities that occur on pipeline facilities

within any given year are category III projects. Blanket,

Section 2.55, and maintenance projects fall under this

category. These activities are required to maintain

and operate natural gas facilities, and involve right-

of-way activities that often require communications

with stakeholders. All projects that involve ground

disturbance require landowner notication, and in

addition, just as when starting a new project, operations

personnel should consider:

• Issuing regular newsletters;

• Developing and maintaining appropriate brieng

materials for recurring and periodic activities;

• Providing regular updates to: governors’ oces;

landowners; municipal and county ocials in

areas with proposed facilities; congressional

delegation representatives in both federal

and state oces; legislative leaders in areas

with proposed facilities; other key legislators

and sta; public utilities commissions; tribes;

appropriate federal and state agency ocials;

municipal planning boards; community leaders;

local associations; neighborhood groups;

environmental and other non-governmental

organizations; state, county, regional, and

municipal economic development ocials;

business leaders and chambers of commerce;

• Identifying other parties interested in the project,

meeting with them to address concerns, and

providing them with periodic updates;

• Responding honestly and in a timely manner to

concerns raised by public ocials;

• Developing opportunities for partnerships

with municipalities and civic and business

organizations; and

• Participating in various business and civic

organizations.

DOT Programs

The U.S. Department of Transportation - Pipeline &

Hazardous Materials Safety Administration (PHMSA)

regulates the safety of natural gas pipelines during

their operation. PHMSA regulations require pipeline

operators to develop and implement public awareness

programs that follow the guidance provided by the

American Petroleum Institute (API) Recommended

Practice (RP) 1162. These public awareness programs

are required to provide pipeline safety information to

the aected public, emergency ocials, local public

ocials, and excavators. Pipeline operators must also

provide information about how to recognize, respond

to, and report pipeline emergencies, the importance

of using the one-call notication system prior to

excavation, and the location of transmission pipelines

to enhance emergency response and community

growth planning. Additionally, PHMSA regulations

require pipeline operators to periodically evaluate their

programs for eectiveness and enhance programs as

necessary, in intervals of no more than four years. For

more information please visit: http://primis.phmsa.dot.

gov/comm/PublicAwareness/PublicAwareness.htm.

Through its Community Assistance and Technical

Service (CATS) program, PHMSA works to advance

public safety, environmental protection, and pipeline

reliability by facilitating clear communications among

all pipeline stakeholders, including the public, the

operators, and government ocials. An important aim

of the CATS program is to reach out to all pipeline safety

stakeholders. Responsibilities of CATS managers include:

• Communicating information to help communities

understand pipeline risks and improve pipeline

safety and environmental protection

• Fostering eective communications regarding

pipeline safety among PHMSA, other federal

agencies, state pipeline safety regulators, elected

and emergency ocials, pipeline operators, and

the public

• Serving as “honest brokers” in facilitating permits

required for safety-related pipeline repairs.

CATS managers are located within each PHMSA region

and contact information can be found at: http://primis.

phmsa.dot.gov/comm/CATS.htm.

Pipelines and Informed Planning Alliance

The Pipelines and Informed Planning Alliance

(PIPA) Best Practices for Risk-Informed Land Use

& Development near Transmission Pipelines is

a stakeholder initiative led and supported by

the PHMSA. PIPA’s goal is to reduce risks and

improve the safety of aected communities and

transmission pipelines through implementation

of recommended practices related to risk-

informed land use and development near

transmission pipelines. PIPA’s report, Partnering

to Further Enhance Pipeline Safety In Communities

Through Risk-Informed Land Use Planning,

contains recommended practices which describe

actions that can be taken by key stakeholders,

including local governments, transmission

pipeline operators, property developers/owners,

and real estate commissions (www.pipa.info.com).

We recommend companies support this eort and

work with PHMSA to achieve PIPA’s goal.

VII. Conclusion

The development of stakeholder outreach programs and the successful implementation of those programs

throughout the “life” of a project (i.e., from project inception to abandonment) has become increasingly important as

public awareness of and involvement with these projects continues to grow. As outlined in this document, numerous

opportunities exist to strategically apply outreach principles and tools to ensure all involved parties understand the

actions aecting them. Additionally, stakeholders will be able to provide valuable insight and comments. Ultimately,

we believe better communication and education will lead to decisions and actions that ensure the highest levels

of environmental protection, provide opportunities for public participation, and improve timely processing for

infrastructure projects in order to meet the public demand for energy.

ACKNOWLEDGEMENT

The experience of FERC sta and the shared advice and

knowledge from industry representatives helped shape

the best practices developed in this document. We

gratefully acknowledge the contributions of time and

information provided by those industry leaders who

have established outreach programs. We particularly

thank David Hanobic, Jessica Harris, Alisa Lykens, Kelley

Muñoz, John Peconom, and Maggie Suter of FERC sta

and former FERC staers, Lauren O’Donnell and Douglas

Sipe, who prepared these best practices for stakeholder

outreach.