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`FERC has long needed more effective means of receiving public input
`concerning the projects that it reviews. I submit these recommendations
`to the FERC regarding the Creation of the Office of Public Participation:
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`FERC should review a certificate applicants’ initial notice of a project for
`accuracy, and such notice should be modified until FERC notifies the
`applicant that it may send the notice to landowners and other affected
`parties.
`• More broadly FERC should develop and enforce mandated guidelines to
`ensure the accuracy of all communications between industry applicants
`(and their agents) and landowners and other affected parties.
`FERC should require project applicants to provide it with the names and
`addresses of all persons to whom it is required to give notice, publicly
`disclose that information, and ensure that persons notified know that they
`have the right to intervene and know how to do so.
`FERC should require that an applicant must meet all the conditions of a
`‘conditional certificate’ prior to exercising the right of eminent domain and
`commencing construction.
`FERC should cease the practice of ‘tolling’ orders that can prevent
`stakeholders from having their day in court before the project is
`constructed.
`• Make stakeholder meetings public again, arrange them in public spaces
`within the impacted communities whenever possible so it is convenient
`for impacted communities to attend, and ensure adequate meeting notice
`of 90 days and adequate notice of minimum of 30 days for any venue
`changes.
`Provide opportunity for the public to testify in an open comment session
`in front of FERC commissioners at FERC meetings.
`Respond in a timely manner to all requests for Critical Energy
`Infrastructure Information (CEII) materials and reform guidelines for what
`does, and what does not qualify as CEII.
`Disallow significant project changes after all public participation periods
`have closed.
`Improve the FERC website to ensure all materials are easy to read and
`access.
`Comply with the National Environmental Policy Act (NEPA) by thoroughly
`addressing all public comments on proposed projects.
`Ensure that all FERC employees answering phones and emails give
`accurate information.
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