Public Involvement for Transmission Projects
Transmission projects often span long distances, have the potential to affect a wide variety of resources, and involve numerous stakeholders and landowners. Effective and timely communication of all aspects of a transmission project - including the project purpose and need and potential impacts - is necessary to encourage a joint understanding of complex issues by all stakeholders in order to obtain informed input. Effectively planned and executed public involvement is therefore critical to the success of transmission projects.
Transmission project proponents often create public involvement plans at the outset of a project to help plan for effective communications through different stages of the project, from planning through construction. Public Involvement Plans incorporate both required and elective public involvement strategies to create an ongoing “conversation” with stakeholders. This page provides several recommended tools that transmission project proponents can use when developing a Public Involvement Plan to maximize the potential to communicate accurate information and create understanding about a project.
What is Public Involvement?
Public Involvement is the process of sharing of information between the project developer, regulatory entities, and interested parties including the general public. Public involvement may be conducted for various reasons including fulfilling permitting requirements for local, state or federal agencies, and/or to provide accurate information, consult and seek input, to obtain informed input that can be considered in identifying and comparing project alternatives, and to collaborate toward a solution that minimizes impacts. A well-organized and comprehensive public involvement campaign can greatly benefit a transmission project by reducing the schedule and the long-term cost of the project. On the other hand, a lack of planning and careful stakeholder identification can add considerable time and preventable cost.
When Public Involvement is Required
Public involvement is typically required for transmission projects by local, state, and/or federal permitting regulations, often in the form of public workshop meetings or hearings, and at key points in a routing process leading up to the permitting process. Specific requirements will vary with each project and jurisdiction. Some permitting processes do not require public workshop meetings, but instead require some level of outreach such as mailing of notification letters to landowners within a specified distance of the proposed project area, or publication of project notices in local newspapers or media outlets.
While a minimum set of activities may be required, it is important to acquire public feedback early in the planning process by conducting elective public outreach to supplement the requirements. As an example, public hearings may be the only required public communication activity for a permitting process. If the proponent waits until the hearing to obtain public feedback, major issues may be raised and cause continuance, delay, or denial of a permit. It is recommended to obtain public feedback and identify fatal flaws early in the process and proceed to the hearings having vetted major public concerns.
When creating a Public Involvement Plan, local land use policies, state permitting requirements, and agency resource management plans should be reviewed to identify opportunity and avoidance criteria to guide the identification and assessment of alternatives. Federal requirements for public involvement vary by required approval and approving agency. Public involvement, through formal agency scoping meetings, is required as part of the National Environment Policy Act (NEPA) for Environmental Impact Statement (EIS)-level projects, and for some Environmental Assessments (EA). NEPA emphasizes public involvement in government actions affecting the environment by requiring that the benefits and the risks associated with proposed actions be assessed and publicly disclosed . Some EA or Categorical Exclusion projects may not require, or may only require minimal public involvement; however, skipping public involvement is not recommended. In these cases, employing elective strategies is strongly recommended to provide a forum for public engagement even when not required by the legal process. Links to Federal guidance for some agencies’ NEPA-level public involvement requirements are included in the Federal Guidance/Requirements section below.
Beyond the Requirements: Elective Public Involvement Strategies
Transmission line project proponents should elect to implement public involvement strategies in addition to what is required by permitting jurisdictions. Elective public involvement does not have to meet any particular parameters or requirements and can be designed to fit each project individually. Various methods and schedules can be deployed to best fit the goals of the project and the characteristics of the stakeholders.
Augmenting public involvement requirements with elective activities such as pre-NEPA routing meetings, social media communications, and other strategies is recommended and can benefit a project by promoting an ongoing and transparent level of public engagement throughout the routing and permitting process. Opposition to transmission line projects could delay a project and result in considerable cost and time losses. Even though opposition may not be avoided completely by holding an ongoing “conversation” with the public, these strategies can help demonstrate transparency on the part of the proponent. Elective public outreach activities help to establish better trust with the involved public and public officials by providing project information upfront, seeking input, demonstrating the input received is considered (if not incorporated into the project design), and explaining decisions as they are made. Maintaining this active level of engagement throughout the process is recommended to encourage quicker identification of critical issues and promote effective resolutions. The efforts of the proponent to reach out and effectively communicate with interested stakeholders throughout the project may aid their permitting efforts by providing defensibility and transparency to the routing and permitting process during permit review.
Public Involvement Benefits and Challenges
Public involvement has many benefits for a transmission line project. Public involvement can act as an early warning system for the public and agency concerns about a project. In many cases, involving the public early and often during the planning and routing phases of a project is effective in anticipating and identifying issues and sensitive areas that can be avoided or mitigated before the project schedule is impacted. Public involvement also serves to create a channel of communication between the stakeholders, proponent, and decision makers. This is beneficial to ensure that the public has a trusted process in place to provide input in a positive and constructive manner. Developing this channel of communication and deploying a strong message allows the proponent to control what is being communicated about the project. This builds understanding and can help to garner support for the proponents’ goals. These benefits can collectively reduce the long-term project schedule and cost by addressing issues and developing solutions during early planning stages.
While there are many benefits to conducting public involvement, there are also challenges. Public involvement can take considerable time and resources and may require advance planning, especially if high levels of controversy are anticipated. There are always many different groups that may have an interest in the project; therefore it is recommended to cast a wide net by using many channels of communication. Plenty of time should be planned to gather, verify, and maintain a comprehensive mailing list, especially on multi-state projects. It is recommended to begin the public involvement process early and maintain the channels of communication throughout the project so that credibility is established and the public trusts the process and can contribute input throughout. In order to keep these stakeholders engaged, the proponent must communicate the importance and value of their input so that concerns are identified and considered.
Best Practice Recommendations
Stakeholder Identification – Identifying the appropriate stakeholders can be a challenge. Research should include local government elected officials, departments and agencies, state level departments officials and representatives, and federal agencies, and even individuals or groups within the proponents’ own company. Identify local and national non-profits and non-government groups that may be interested. Identify local landowners and local business owners and organizations (such as local chambers of commerce and economic growth organizations). Local landowner data may be obtained from counties. This data is obtained from tax records and is typically available for purchase. Placing advertisements in newspapers or local circulars that contain project contact information may help to identify and reach those missed by the research methods discussed above. NOAA provides strategies for identifying relevant stakeholders in their report: Stakeholder Engagement Strategies for Participatory Mapping.
Identify Issues of Concern – It is recommended to research similar transmission projects, and other infrastructure projects in the same area as the proposal. Note the important issues and prepare position statements and responses. Prepare collateral materials to address these topics. One way to identify issues of concern through public involvement is to employ participatory mapping strategies. Participatory mapping is an exercise of working with the public to identify and map publically valued resources and use it as a tool for decision-making. Participatory mapping is used to spatially recognize important issues as determined by the public and can be employed at public workshops and used by the proponent to avoid areas of sensitivity. Participatory mapping is explained in depth in the NOAA report: Stakeholder Engagement Strategies for Participatory Mapping.
Establish a multi-channel approach – There is no “magic bullet” to identifying and contacting potential stakeholders. Everyone will obtain their news and information using a different method. It is critical to plan and conduct public meetings, create a website for project information and social media accounts (Facebook, Twitter, and YouTube), send press releases to local papers and media, place announcements in local newspapers and radio stations, establish an email list through Mail Chimp or other providers, and send direct mail. It is not recommended to rely on one method to reach potential stakeholders. It is important to establish these channels and the project messaging. The American Association of State Highway and Transportation Officials (AASHTO) Standing Committee on the Environment published the report: Potential Use of Social Media in the NEPA Process, discussing the various applications of social media to enhance communications. The report discusses that social media should be used to supplement other forms of public outreach and can help to broaden the net cast by proponents to include the internet savvy stakeholder.
Engage stakeholders early and often, during the planning and routing process – Public involvement should begin at a very early stage in the planning process and continue throughout the routing process, and through construction. By reaching out to the public at these early stages, the proponent can start fostering relationships with local stakeholders early to establish credibility and gain input before key decisions are made. Local stakeholders can provide unique perspective and intimate knowledge of local geography and land use. The project developer can follow up with key groups based on their interest and anticipated level of involvement, and incorporate outreach to those groups into the public involvement plan.
Engage the public before applications are submitted – This is one major reason that permit applications can be deemed incomplete. It is recommended to engage the public prior to submitting applications and incorporate the input received into project plans to the extent possible, and demonstrate the effort made to involve the public.
Plan and commit time and resources – Plan upfront for public involvement; history illustrates that this investment of time, if not done upfront, is required later in the project at a higher cost, extended schedule, and overcoming a lack of credibility. A strong strategy described in a Public Involvement Plan or communications plan will help the team properly implement the campaign. A comprehensive plan should include internal communications, regulatory communications, and public communications. These types of plans are not set in stone and can be refined throughout the course of the project as input is received, new information is collected, or best practices are identified.
Encourage participation – The public can sometimes believe that their input is inconsequential to the decision-making process. Communicate the process of public involvement and the opportunities for them to become involved. Show the public that their comments are being heard, recorded, and the consideration given in the decision making or planning process as appropriate. This will help to encourage helpful and valuable input.
Communicate clear and concise messages – Make sure that the project message is clear, concise and will resonate with the public. If the project information is confusing or not clearly communicated, it could be taken out of context and the stakeholders are less likely to be engaged and provide useful and informed input. Carefully craft the project messaging so that it can be understood by stakeholders with no background in electrical transmission or the energy industry. Include enough detail for the public to understand the process, how alternatives are identified and compared, and the possible impacts related to the project. Include a strong justification of why the project is needed by addressing reliability and electricity supply issues, economics, benefits, and public policy as necessary.
Form partnerships – Reach out to those parties who may be interested in partnering with the project team including local government representatives. Form positive relationships and utilize these stakeholders as a resource for routing and for reaching out to other interested parties. Working closely with affected communities and groups is readily acknowledged as key to greater, faster public acceptance of transmission line routing. Proponents should also partner with the decisional agencies public involvement staff to help define permitting requirements and the project communications plan.
Public scoping is the process of obtaining public feedback on the scope of the Environmental Impact Statement or Environmental Assessment, including what alternatives and environmental impacts should be analyzed. Most major federal agencies have specific public scoping guidance.
- BLM NEPA Handbook
- Scoping Guide for RUS funded projects
- Effective Public Participation Under NEPA, DOE, Environment, Safety and Health Office of NEPA Policy and Assistance
- USFWS NEPA Reference Handbook
- Forest Service Handbook 1909.15
- Indian Affairs NEPA Guidebook
- National Park Service – NEPA Handbook and Director’s Orders