What is status of pipeline public awareness program after one year?
Stakeholders might be generally defined as those persons living of working along the right-of-way, those who might have occasion to do excavation on or near the right-of-way, those who might be required to respond to pipeline emergencies and those who are the elected representatives of those along the right-of-way. In short, the stakeholders include the public (people who live and work along the pipeline route), excavators, emergency responders and local public officials.
What has the pipeline industry learned from the experience of complying with the new public awareness regulation during the past year? Questions were posed by email to three pipeline respondents. They are Chris Stockton, senior communications specialist for Williams, Houston, TX; Larry Springer, manager of public affairs for Enbridge Energy Company, Houston; and J Scrivner, manager of compliance for Boardwalk Pipelines, Owensboro, KY.
The Pipeline Safety Act of 2002 amended 49 U.S.C. 60116 to require that pipeline operators update their existing public education programs and submit the updated programs upon request to the Pipeline and Hazardous Materials Safety Administration (PHMSA) or the appropriate state pipeline safety agency. In May 2005, the new public awareness rule became effective and required pipeline operators to complete and implement their public awareness programs by June 20, 2006.
The new public awareness regulation, which incorporates the American Petroleum Institute's Recommended Practice 1162 (API RP 1162) by reference, requires operators to communicate specific messages with prescribed frequency to four key stakeholder audiences: affected public (those who live and work along pipeline routes), excavators, emergency responders and local public officials.
Q: Field/operations workers are an important element of a public awareness plan as they carry out the supplemental requirements in the regulation. What has been their general reaction to the regulation, and how are they participating in your public awareness program?
Stockton: In the beginning I think the new regulation was a little overwhelming, simply because they were unsure about any additional responsibilities they would inherit. In the past, our field locations handled 100% of the public education requirement identified in DOT Part 192. Today, our corporate communications department coordinates all of the baseline mailings, while the field handles supplemental face-to-face contact.
Springer: As the internal communications about our public awareness program have increased so has the interest and support of our field operations personnel. We hosted a "public awareness summit" meeting in spring 2006 for our key internal stakeholders to introduce the draft of our PA plan and to incorporate their ideas and insights into the final document. Our field operations personnel have responsibility for many of the supplemental activities in our PA plan, including facilitation of direct contacts with emergency responders and documentation of all other interaction between field personnel and our key public awareness stakeholders.
Scrivner: The initial reaction to the new regulations was not entirely positive--operations employees feared that they would have to perform a lot of extra tasks with no real benefit to the company. While the baseline mailing activities are handled from the corporate office, our field operations employees almost exclusively execute the supplemental activities for the company. For example, at times they meet personally with members of the stakeholder audiences, distribute promotional items such as company calendars to landowners, distribute a developer's handbook to contractors, attend meetings with ER officials, and conduct station and facility tours for the public.
Q: How much are you spending each year on the public awareness program (baseline and supplemental) how does this compare to what was anticipated?
Stockton: Generally speaking, we are spending about $500,000 annually on public education. More than half of these costs can be attributed to postage.
Springer: Our baseline (direct mail) program will reach more than 1.1 million addresses (affected public, excavators, emergency responders and local public officials) at an estimated cost of about $825,000. Supplemental activities include field operational support for group meetings with excavators and emergency responders, one-on-one visits with the departments and local public officials, support for regional public awareness programs, direct mailing of calendars to certain right-of-way landowners and more. It is estimated that we will invest at least $200,000-250,000 in these activities each year. While this is a three- to four-fold increase over our costs five years ago, we have recognized that our stakeholder communications will now have broader reach and be more effective and better documented. Therefore, these costs, while significantly higher, were anticipated and will help us reach our goal of a more informed public along our pipeline routes.
Scrivner: At Texas Gas, we spend approximately $250,000 a year on our public awareness-related activities.
Q: One requirement associated with RP 1162 is the need to measure the effectiveness of public awareness programs--something that may not always be easy to quantify. How are you meeting this requirement and what will you consider as "success"?
Stockton: This is the third year of our enhanced program, so we have had the opportunity to try several different measurement techniques. We've found that different measurement methods are more or less effective for different audiences. For example, business reply cards have worked great with our public officials, but poorly with excavators. I believe that a program's success is impossible to quantify with just one measure because there are so many other variables at work. Our program analysis includes a checklist of different components that, taken as a whole, provide a more balanced snapshot of the end results.
Springer: Both our natural gas and liquids businesses are actively participating in the joint natural gas/liquids industry survey and assessment program--cosponsored by the American Petroleum Institute, Association of Oil Pipe Lines and the Interstate Natural Gas Association of America--which is designed to first provide us with a baseline to measure our efforts and ultimately, a continuing gauge against which we can determine the effectiveness of our public awareness communications. The goal is to not only meet the requirements of API RP1162 to assess the effectiveness of our public awareness communications but also to ensure that we are spending our money wisely in our choice of message vehicles and communication channels. This will require us to keep an open mind on tactics and be willing to adjust our program as necessary to improve the efficacy of our public awareness communications.
Scrivner: In conjunction with our first API RP 1162 mailing, we used business reply cards to measure the effectiveness of the audiences' understanding of the topics covered. However, in the end we are really interested in how the API RP 1162 communications can improve public awareness about our pipelines and reduce bottom-line measures such as third-party damage, vandalism, and security incidents. We established baselines for some of these measures before we started the API RP 1162 activities and we regularly compare those results to check for improvements. Beginning in 2007 we intend to participate in the joint industry survey and assessment program cosponsored by API, AOPL, and INGAA.
Q: RP 1162 includes 12 baseline and supplemental messages. From a communications standpoint, how have you been able to communicate that many messages to a fairly diverse group of stakeholder audiences?
Stockton: Our approach has been to develop different materials for each of the four stakeholder audiences, ensuring that the messages and delivery methods are tailored to fit each audience's unique needs. For example, our brochure for the affected public provides a general overview of the industry, designed with interesting graphics and written from a lay person's perspective. The letter we send to emergency responders is brief and to the point, containing local contact information and an overview of facilities we operate in that responder's area.
Springer: In its baseline program, Enbridge has chosen to develop separate brochures for its affected public, excavator and emergency responder/local public official audiences. Additionally, because we operate both natural gas and liquids systems, we further refine those brochures to specifically address the product carried in each pipeline. Each brochure includes all key messages, but those messages are re-ordered and focused for each stakeholder group. Additionally, graphics in each brochure are included to appeal specifically to the targeted stakeholder group. Through our supplemental communications, we directly deliver key safety messages to firefighters and others who need to know about our operations and how to respond to a pipeline incident.
Scrivner: We mainly use a targeted mass mailing program that involves a RP 1162 compliant public awareness brochure and letter combination. The letter included in the packages is tailored to each of the four stakeholder audiences and includes information that would be appropriate for that particular audience. Also, we leverage our company's web site to disperse much more in-depth public awareness and pipeline safety information.
Q: Have you been able to integrate activities for school-age children into your public awareness program?
Stockton: Not as part of the baseline program, but from time to time our field locations do receive requests from schools to visit and answer questions about our industry. There is a great resource that AGA produced a few years ago called "Gilmore's Guide to Natural Gas" that is great for elementary school children. This type of outreach would be documented as a supplemental task.
Springer: We are reviewing options for this as one more supplemental activity and means of reaching adults who live along our pipeline route. This may include special materials and perhaps utilizing third-party groups to present schoolhouse programs. In Texas, we are required to identify all public schools within 1,000 feet of our pipelines and report that information to the Railroad Commission of Texas.
Q: In the development of your baseline and supplemental materials/messages what process has your company used to pre-test the effectiveness of the materials?
Stockton: Enbridge used a structured, but informal, process to pre-test our public awareness materials. Employees not involved in day-to-day operations of pipelines reviewed materials as members of the Affected Public audience. Informal focus groups made up of excavators and emergency responders reviewed and commented on materials directed to their specific audience. We used their comments to either confirm the design and textual content of our materials--or, in some cases, to help us rewrite text and upgrade the design in a way that improved the message clarity and flow.
Scrivner: We used internal focus groups of non-technical company employees to test the wording and presentation of the public awareness topics. We got a lot of good feedback through these internal focus groups and tailored our brochure wording, layout, and overall package design based off the feedback.
Q: The first year of your respective programs under the new regulation is now complete. Were there any surprises along the way?
Stockton: There were a number of lessons learned. For the vast majority of the affected public, this was the first time they have ever received information from a pipeline company. As a result, we received numerous requests from members of the affected public wanting more information about the pipeline's location. The only phone number listed in our affected public brochure was our emergency gas control number. In order to help Gas Control avoid having to field these non-emergency calls, we have added a separate 800-number and e-mail address to field general public inquiries.
Scrivner: This year has gone as expected. We were surprised at the high percentage of completed responses that we received in response to our business reply cards that were supplied with our public awareness package mailings. We continue to focus more of our public awareness efforts on targeting the appropriate supplemental activities along our pipeline system.
Moderator: Terri Larson is managing supervisor at Fleishman-Hillard (FH) and is a member of the firm "s global energy practice group. Before joining Fleishman-Hillard in Sept. 2006, she managed the public awareness programs for Enbridge Energy and Vector Pipeline and co-chaired a joint industry committee tasked with designing a survey program to measure effectiveness of pipeline public awareness programs.
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|Title Annotation:||reply from Chris Stockton, Larry Springer, and J. Scrivner|
|Publication:||Pipeline & Gas Journal|
|Date:||Jun 1, 2007|
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