Utilities Take on the Role of Stakeholder Engagement for CCR Compliance
The Coal Combustion Residuals Rule is Different
While public input isn’t new to utilities — most permit applications or renewals require a public meeting — most public meetings are conducted by the regulatory agency. Now, depending on where a utility is in the groundwater monitoring process, the CCR rule requires the utility to conduct a public meeting to discuss corrective measures associated with CCR groundwater issues.
With the exception of a few states, the CCR rule is enforced by a third party which requires public input as part of the process. A solid stakeholder communication plan will help utilities with proactive compliance.
Stakeholder Communications Plan for CCR Compliance and Risk Mitigation
A stakeholder communications plan is a proactive plan that integrates the organization’s CCR compliance with a strategy to engage adjoining landowners and a broader stakeholder audience in the process. The plan helps identify specific and potential stakeholders and their interests in the process. The plan also indicates how and when to communicate with each stakeholder group. A solid engagement plan should include the following elements:
- Stakeholder and issues identification
- Key messages regarding the project, including goals, potential impacts and opportunities for engagement or information
- Communication tools and methods
- Engagement tracking protocol
In essence, a well thought out communications plan establishes rules and expectations for engagement, both as required by the rule and as potential risk mitigation. While stakeholder audiences may seem obvious, developing a plan puts an emphasis specifically on identification of stakeholders who may influence the compliance process, particularly the corrective measures process. The plan specifies the information to be communicated, including the level of detail needed and what is required for communication with stakeholders.
With the existing public engagement requirements in the CCR rule and the proposed changes in the rule requiring greater transparency in public communications, a good stakeholder communication plan can be critical. Thinking above and beyond the requirements of engagement will offer opportunities for more authentic and sincere public outreach, and minimize both social and political risk for the project.
Meet the Authors
Christine Harris is the power generation regulatory compliance lead. She is an industry-recognized program manager with an unmatched understanding of clients, developed in part by her 28 years of work for a utility. Christine works with our clients and internal teams to share her decommissioning know-how and compliance expertise for regulations including 316(b), coal combustion residuals and the effluent limitations guidelines. Her real-life understanding of client budgets leads her to seek smart, cost-effective options.
Katie Hatfield Edstrom, Ph.D., is the strategic communications power sector market lead. She is a skilled communicator with expertise in message construction, audience analysis and group facilitation. Katie applies the theory and knowledge from her role in an academic environment to help our clients develop and implement successful strategic communications plans. She excels in leveraging existing communication strategies and employing new technologies and tools to achieve the best possible outcome for our clients.
As a strategic communications manager, Tara Bettale understands the challenges our clients face when balancing the needs of multiple stakeholders. Prior to HDR, she served as a public information manager for Denver’s transit agency, the Regional Transportation District. Tara provides leadership and guidance during challenging stakeholder issues, creates innovative public outreach plans to mitigate social and political crises that could derail a project, and addresses issues and concerns with local agencies, business owners, and residents alike.