WorkshOPP: Tips for Powerful Comments

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Federal Energy Regulatory Commission

 

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Presentations and trainingsVideosPublished   2/23/2023

This workshop from FERC’s Office of Public Participation (OPP) provided useful information on what FERC is looking for in comments and how participants can be effective in filings.

 

Commissioner Danly made the following points: (minute 4:12)

  1. Any comment should be as brief as possible. Focus on being direct and persuasive.
  2. Be as clear as possible, unambiguous about your support or opposition. The title and file name might include, “Comments in opposition.” If you have mixed support and opposition, break out sections clearly.
  3. Don’t worry about offending the Commission. Be forceful and passionate, but not rude.
  4. Decisions are made based on the law and facts on the record. Don’t just express general grievance, be specific about impacts to you and your community.

 

Staff shared these top 5 tips: (minute 54:03)

  1. Organize yourself. Know the docket number, and what you are commenting on.
  2. State your objective quickly.
  3. Support your points.
  4. Be specific about impacts. Make comments personal.
  5. Know FERC’s role.

 

Additional useful suggestions from the workshop:

 

  • Get comments in early.
  • Comments aren’t votes. Receiving many comments stating the same thing (i.e. form letters) does not sway FERC in that direction. Make unique points in your comments.
  • FERC really values local perspectives.
  • Tribal comments receive special consideration.
  • Comments from elected officials draw notice, but do not necessarily change the outcome.
  • Joint comments are fine, not necessarily better or worse than filing individual comments.
  • FERC can only made decisions on what the applicant is proposing.
  • There is no benefit to making oral comments over written comments.

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