Troutman Sanders LLP: FERC Office of Energy Projects Issues Best Practices Manual

On July 28, 2012, FERC’s Office of Energy Projects (“OEP”) released a 32-page manual titled “Suggested Best Practices for Industry Outreach Programs to Stakeholders” (“Manual”).  In doing so, OEP states that the purpose of the Manual is to identify best practices for natural gas project developers to “effectively engage stakeholders in the application process for siting, construction and operation of interstate natural gas facilities and LNG terminals.”

The Manual itself details several components that are typically incorporated into a successful stakeholder outreach program, including senior management support, internal collaboration, engagement and education of stakeholders, training of project staff, and utilization of technology.  Moreover, OEP’s conception of stakeholders includes any entity that could be affected by the project, rather than focusing exclusively on affected landowners.  OEP notes in the Manual that a successful stakeholder outreach program will employ public outreach efforts such as sending introductory letters to stakeholders, developing a project-specific website, and holding public meetings.

The Manual also details how the FERC pre-filing process is intended to engage stakeholders at the earliest stages of project development.  While the pre-filing process is only mandatory for LNG terminals – and voluntary for pipeline and storage projects – OEP encourages all major pipeline projects to undertake the pre-filing process because it provides a structured way for developers to remain engaged with stakeholders.  The Manual states that “if used effectively, the pre-filing process can streamline the review once an application is filed.”

A copy of the Manual is available here.

About Troutman Sanders:

Troutman Sanders LLP is an international law firm with more than 600 lawyers in 16 offices located throughout North America and Asia. Founded in 1897, the firm’s lawyers provide counsel and advice in practically every aspect of civil and commercial law related to the firm’s core practice areas: Corporate, Energy and Industry Regulation, Finance, Litigation and Real Estate. Firm clients range from multinational corporations to individual entrepreneurs, federal and state agencies to foreign governments, and non-profit organizations to businesses representing virtually every sector and industry. See for more information.

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