BARROW UTILITIES & ELECTRIC CORP — Notice of Amendment

520080027m_notice of amendment_12312008_text.pdf, page 1Official PDFU. S Department of Transportation Pipelliirte and Hazardous Mafeiriialls Safety Admlnlsfrafiloirii 12300 W Dakota Ave, Suite 110 Lakewood, CO 80228 NOTICE OF AMKNOMKXT December 31, 2008 Mr Ben Frantz General Manager Barrow Utihties k, Electric Coop PO Box 449 Barrow, AK 99723 CPF 5-2008-0027M Dear Mr Frantz On June 16, 2006, the Pipehne and Hazardous Materials Safety Administration (PHMSA) pubhshed an Advisory Bulletm requesting all pipehne operators to submit their Pubhc Awareness Program pursuant to 49 CFR Part 192 616 PHMSA then established a Clearinghouse to compare each operator's Pubhc Awareness Programs agamst the recommendations in the industry standard API RP 1162, which is incorporated by reference into the regulations previously cited Smce this was a new regulation, our staff worked with each pipehne operator in the nation to provide guidance m developmg the Pubhc Awareness Programs and assisting the operator in correcting any regulatory deficiencies On the basis of the Clearmghouse findings, PHMSA mformed your staff by email (see attached) of 73 identified aspects of your Pubhc Awareness Program that deviated from our regulations The PHMSA representative tasked with working with Barrow Utihties and Electric Cooperative Incorpol atecl (BUECI) lllformecl 1Tle that at this tllne the followlllg lnacleqilacles still exist ln your pubhc awareness program. 1. $192. 616 Public Awareness (a) Except for an operator of a master meter or petroleum gas system covered under paragraph (j) of this section, each pipehne operator must develop and#

520080027m_notice of amendment_12312008_text.pdf, page 2implement a written continuing pubhc education program that follows the guidance provided in the American Petroleum institute's (APE) Recommended Practice (RP) 1162 (incorporated by reference, see $192. 7). (b) Yhe operator's p~ogram must follow the general program recommendations of APl RP 1162 and assess the unique attributes and characteristics of the operator's pipeline and facilities. (c) The operator must follow the general program recommendations, including baseline and supplemental requirements of APl RP 1162, unless the operator provides justification in its program or procedural manual as to why compliance with all or certain provisions of the recommended practice is not practicable and not necessary for safety. (d) Yhe operator's program must specifically include provisions to educate the pubHc, appropriate government organizations, and persons engaged in excavation related activities on: (1) Use of a one-call notification system prior to excavation and other damage prevention activities; (2) Possible hazards associated with unintended releases from a gas pipeline facility; (4) Steps that should be taken For public safety in the event of a gas pipehne ~ elease; and (e) The program must include activities to advise affected municipalities, school districts, businesses, and residents of pipeline facility locations. (f) Yhe program and the media used must be as comprehensive as necessary to reach aH areas in which the operator transports gas. (g) Yhe program must be conducted in English and in other languages commonly understood by a significant number and concentration of the non-English speaking population in the operator's area. (h) Operators in existence on June 20, 2005, must have completed their written programs no later than June 20, 2006. The operator of a master meter or petroleum gas system covered under paragraph (j) of this section must complete development of its written procedure by June 13, 2008. Upon request, operators must submit their completed programs to PHMSA or, in the case of an intrastate pipeline facility operator, the appropriate State agency. (i) The operator's program documentation and evaluation results must be available for periodic review by appropriate regulatory agencies.#

520080027m_notice of amendment_12312008_text.pdf, page 3(j) Unless the operator tjransports gas as a primary activity, the operator of a master meter or petroleum gas system is not required to develop a public awareness program as prescribed in pajragraphs (a) through (g) of this section. instead the opera(or must develop and implement a written procedujre to provide its customejrs public awajreness messages twice annually. 1f the master meter or petroleum gas system is located on property the operator does not control, the operator must provide similar messages twice annually to persons controlling the property. I'he public awareness message must include: (I) A descnption of the purpose and reliability of the pipeline; (2) An overview of the hazards of the pipeline and prevention measures used; (3) 1nformation about damage prevention; (4) How to recognize and respond to a leak; and (5) How to get additional information. The operator did not have a program that met the regulatory criteria as of June 20, 2006 On October 30, 2007, the operator was informed by email of the outstandmg deficiencies (see attached) however as of this date corrections to achieve regulatory comphance have not been made Res onse to this Notice This Notice is provided pursuant to 49 U. S. C ) 60108(a) and 49 C. F. R ) 190 237 Enclosed as part of this Notice is a document entitled Response Options for Pipeline Operatoi"s in Compliance ProceeCings Please refer to this document and note the response options Be advised that all material you submit in response to this enforcement action is subJect to bemg made pubhcly available If you believe that any portion of your responsive material quahfies for confidential treatment under 5 U. S C 552(b), along with the complete original document you must provide a second copy of the document with the portions you beheve quahfy for confidential treatment redacted and an explanation of why you beheve the redacted infoiTnation quahfies for confidential treatment under 5 U. S C 552(b) If you do not respond withm 30 days of receipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice and authorizes the Associate Administrator for Pipehne Safety to find facts as alleged m this Notice without further notice to you and to issue a Final Order If, after opportunity for a hearmg, your plans or procedures are found inadequate as alleged m this Notice, you may be ordered to amend your plans or procedures to correct the madequacies (49 C F R ) 190. 237) If you are not contesting this Notice, we propose that you submit your amended procedures to my office within 60 days of receipt of this Notice This period may be extended by written request for good cause. Once the inadequacies identified herein have been addressed m your amended procedures, this enforcement action will be closed#

520080027m_notice of amendment_12312008_text.pdf, page 4In correspondence concermng this matter, please refer to CPF 5-2008-0027M and, for each documeht you submit, please provide a copy m electronic format whenever possible Sincerely, Chris Hoidal Director, Western Region Pipehne and Hazardous Materials Safety Aditunistration cc: PHP-60 Comphance Registry PHP-500 R Remeke (4123167} Enclosures Response Options for Pipeline Operators in Compliaizce Proceedings Copy of Email to BUECI regarding Deviations from RP 1162 Recommendations (dated October 30, 2007)#

520080027m_notice of amendment_12312008_text.pdf, page 5Page 1 of 13 From: Reineke, Ross &PHMSA) Sent: & Tuesday, October 30, 2007 3 31 PM To: anesteby@bueci org Cc: Reineke, Ross &PHMSA) Subject: FW Public Awareness Program Review Completed - Barrow Utilities and Electnc Cooperative Inc Dear Operator, The Clearinghouse has finished comparing your public awareness program to the recommendations in API RP 1162. The e-mail below includes all aspects of your program that the Clearinghouse noted as deviating from the recommended practice. Please review this information and let me know if you plan to make any changes to your program. According to Section 6. 2 of API RP 1162, there are 12 considerations for operators to examine when deciding on the implementation of supplemental elements. The Clearinghouse noted that your program does not address all of these considerations. Your program needs to describe the process used to decide on the use of supplemental elements and a clear description of supplemental elements actually implemented. Beviation from ~ 1162 Recommendations: I Question: Answer Page Number: Comments P) Question Answer Page Number Comments: Question: Section 2. 5A. Does the program include a Management Statement o f Support? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. Section 7. A. Does the program list the position titles of employees involved in program administration? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. Section 7. 8. Does the program describe the roles and responsibilities of the positions involved in program administration? 6/23/2008#

520080027m_notice of amendment_12312008_text.pdf, page 6Answer: Page Number: Comments: +) Quest'ion Answer Page Number: Comments: g Question: Answer: Page Number: Comments: 0) Question: Answer: Page Number . Comments 7) Question Answer . Page Number: Comments: g) Question: Answer: Page Number: Comments: 1) Question Answer: 6/23/2008 Page 2 of 13 Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. How will Hazardous Liquids and Gas Transmission operators deliver basehne awareness messages to the Affected Public? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a public awareness program for a transmission system and a local gas distribution system What is the frequency for Hazardous Liquids and Gas Transmission operators to dehver basehne awareness materials to the Affected Pubhc? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a public awareness program for a transmission system and a local gas distribution system. Do the Hazardous Liquids and Gas Transmission operator basehne awareness materials to the Affected Pubhc include Pipehne purpose and reliability? Not Included Not included for the Affected Public Do the Hazardous Liquids and Gas Transmission operator baseline awareness materials to the Affected Public include Awareness of hazards and prevention measures undertaken? Not Included Not included for the Affected Public Do the Hazardous Liquids and Gas Transmission operator baseline awareness materials to the Affected Pubhc include Damage prevention awareness? Not Included Not included for the Affected Pubhc Do the Hazardous Liquids and Gas Transmission operator baseline awareness materials to the Affected Public include One-call requirements? Not Included#

520080027m_notice of amendment_12312008_text.pdf, page 7Page Number: Comments: /0 Question . Answer: Page Number: Comments: Question . Answer Page Number: Comments: V Question Answer: Page Number . Comments . gj Question: Answer: Page Number: Comments: %uestion . Answer Page Number: Comments: /S) Question: Answer: Page Number: Comments: 6/23/2008 Page 3 of 13 Not included for the Affected Public Do the Hazardous Liquids and Gas Transmission operator basehne awareness materials to the Affected Pubhc include Pipeline location information (description of the purpose of pipehne markers and the information on them, ref $4. 6. 1)? Not Included Not included for the Affected Public Do the Hazardous Liquids and Gas Transmission operator baseline awareness materials to the Affected Public include How to get additional information? Not Included Not included for the Affected Pubhc Do the Hazardous Liquids and Gas Transmission operator basehne awareness materials to the Affected Public include Availability of hst of pipeline operators through NPMS? Not Included Not included for the Affected Pubhc How will Hazardous Liquids and Gas Transmission operators dehver basehne awareness messages to Emergency Officials? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. What is the frequency for Hazardous Liquids and Gas Transmission to deliver basehne awareness materials to Emergency Officials? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. Do the Hazardous Liquids and Gas Transmission operator baseline awareness materials to Emergency Officials include Pipeline purpose and reliabihty? Not Included Not included for Emergency Officials#

520080027m_notice of amendment_12312008_text.pdf, page 8I i) Question: Answer: Page Number: Comments: /7 Question: Answer: Page Number: Comments: /P Question Answer: Page Number: Comments: t[j Question: Answer: Page Number: Comments: &) Question . Answer Page Number: Comments: g / Question: Answer: Page Number: Comments: g2j Question 6/23/2008 Page 4 of 13 Do the Hazardous Liquids and Gas Transmission operator basehne awareness materials to Emergency Officials include Awareness of hazards and prevention measures undertaken~ Not Included Not included for Emergency Officials Do the Hazardous Liquids and Gas Transmission operator baseline awareness materials to Emergency Officials include Potential hazards? Not Included Not included for Emergency Officials Do the Hazardous Liquids and Gas Transmission operator basehne awareness materials to Emergency Officials include Pipeline location information (description of the purpose of pipeline markers and the information on them, ref $4. 6. 1) and availability of NPMS~ Not Included Not included for Emergency Officials Do the Hazardous Liquids and Gas Transmission operator baseline awareness materials to Emergency Officials include How to get additional information? Not Included Not included for Emergency Officials How will Hazardous Liquids and Gas Transmission operators dehver baseline awareness messages to Local Public Officials? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. What is the frequency for Hazardous Liquids and Gas Transmission operators to dehver baseline awareness materials to Local Pubhc Officials? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. Do the Hazardous Liquids and Gas Transmission operator baseline awareness materials to Local Public Officials include#

520080027m_notice of amendment_12312008_text.pdf, page 9Answer: Page Number Comments: ~3 Question: Answer: Page Number Comments ' eL&)Question Answer Page Number: Comments: Question: Answer: Page Number: Comments: ~) Question: Answer: Page Number Comments Question: Answer: Page Number: Comments: hatt) Question: Answer: Page Number: Comments: 6/23/2008 Page 5 of 13 Pipeline purpose and rehability? Not Included Not included for Local Public Officials Do the Hazardous Liquids and Gas Transmission operator basehne awareness materials to Local Public Officials include Awareness of hazards and prevention measures undertaken? Not Included Not included for Local Public Officials Do the Hazardous Liquids and Gas Transmission operator baseline awareness materials to Local Public Officials include Emergency preparedness communications? Not Included Not included for Local Pubhc Officials Do the Hazardous Liquids and Gas Transmission operator basehne awareness materials to Local Pubhc Officials include One-call requirements? Not Included Not included for Local Public Officials Do the Hazardous Liquids and Gas Transmission operator basehne awareness materials to Local Pubhc Officials include Pipehne location information (description of the purpose of pipehne markers and the information on them, ref (4. 6. 1) and availability of NPMS? Not Included Not included for Local Public Officials Do the Hazardous Liquids and Gas Transmission operator baseline awareness materials to Local Pubhc Officials include How to get additional information? Not Included Not included for Local Public Officials How will Hazardous Liquids and Gas Transmission operators dehver basehne awareness messages to Excavators? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a public awareness program for a transmission system and a local gas distribution system.#

520080027m_notice of amendment_12312008_text.pdf, page 102& Question: Answer: Page N'umber: Comments: 3e) Question: Answer Page Number: Comments: 3 j Question: Answer Page Number: Comments: 72- Question. Answer: Page Number: Comments: Question . Answer: Page Number: Comments: 7q) Question: Answer: Page Number: Comments: 7& Question: Answer: Page Number: Comments: 6/23/2008 Page 6 of 13 What is the frequency for Hazardous Liquids and Gas Transmission operators to deliver baseline awareness materials to Excavators? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a public awareness program for a transmission system and a local gas distribution system. Do the Hazardous Liquids and Gas Transmission baseline awareness materials to Excavators include Pipeline purpose and rehabihty? Not Included Not included for Excavators Do the Hazardous Liquids and Gas Transmission baseline awareness materials to Excavators include Awareness of hazards and prevention measures undertaken? Not Included Not included for Excavators Do the Hazardous Liquids and Gas Transmission baseline awareness materials to Excavators include Damage prevention awareness? Not Included Not included for Excavators Do the Hazardous Liquids and Gas Transmission basehne awareness materials to Excavators include One-call requirements? Not Included Not included for Excavators Do the Hazardous Liquids and Gas Transmission baseline awareness materials to Excavators include Leak recognition and response? Not Included Not included for Excavators Do the Hazardous Liquids and Gas Transmission baseline awareness materials to Excavators include How to get additional information? Not Included Not included for Excavators#

520080027m_notice of amendment_12312008_text.pdf, page 11~~) Question Answer Page Number: Comments: 3 7 Question: Answer Page Number: Comments: gg) Question: Answer: Page Number: Comments: Question: Answer: Page Number: Comments: Question: Answer: Page Number . Comments . Question: 6/23!2008 Page 7 of 13 Is the Hazardous Liquids and Gas Transmission operator a member of all appropriate one-call centers? Not Included Letter page 1 Cited that direct contact is used with excavators instead of a one-call notification system Section 6. 2 Does the program describe the process and procedure used to determine whether supplemental elements will be implemented in response to High Consequence Areas? No The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a public awareness program for a transmission system and a local gas distribution system. How will Gas Distribution operators dehver baseline awareness messages to the Affected Public who reside along the pipeline system? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a public awareness program for a transmission system and a local gas distribution system. How will Gas Distribution operators deliver basehne awareness messages to the Affected Public who are customers of the gas company~ Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. What is the frequency for Gas Distribution operators to deliver basehne awareness materials to the Affected Pubhc who reside along the pipeline system? Not Included The operator submitted excerpts &om their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. What is the frequency for Gas Distribution to deliver basehne awareness materials to the Affected Public who are customers of the gas company?#

520080027m_notice of amendment_12312008_text.pdf, page 12Answer . Page Number ' Comments: 0&) QuestIon: Answer: Page Number: Comments . Question: Answer: Page Number: Comments: Q) Question Answer: Page Number: Comments: Question ' Answer: Page Number: Comments: 'g) Question: Answer: Page Number: Comments: Question: Answer: Page Number . Comments . 6/23/2008 Page 8 of 13 Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a public awareness program for a transmission system and a local gas distribution system. Do the Gas Distribution basehne awareness materials to the Affected Pubhc include Pipeline purpose and reliability? Not Included Not included for the Affected Pubhc Do the Gas Distribution basehne awareness materials to the Affected Public include Awareness of hazards and prevention measures undertaken? Not Included Not included for the Affected Pubhc Do the Gas Distribution basehne awareness materials to the Affected Public include Damage prevention awareness (including one-call requirements)? Not Included Not included for the Affected Public Do the Gas Distribution basehne awareness materials to the Affected Public include How to get additional information? Not Included Not included for the Affected Pubhc How will Gas Distribution operators dehver baseline awareness messages to Emergency Officials? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. What is the frequency for Gas Distribution operators to dehver baseline awareness materials to Emergency Officials? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a public awareness program for a transmission system and a local gas distribution system.#

520080027m_notice of amendment_12312008_text.pdf, page 13+8) Quest&on . Answer: Page Number Comments: ~ 'Question: Answer: Page Number: Comments: Question: Answer: Page Number: Comments: 57) Question: Answer: Page Number: Comments: DP Question: Answer: Page Number: Comments D3g Question: Answer: Page Number: Comments: 4 + Question: Answer: Page Number: Comments: 6/23/2008 Page 9 of 13 Do the Gas Distribution basehne awareness materials to Emergency Officials include Pipeline purpose and rehability? Not Included Not included Emergency Officials Do the Gas Distribution baseline awareness materials to Emergency Officials include Awareness of hazards and prevention measures undertaken? Not Included Not included Emergency Officials Do the Gas Distribution basehne awareness materials to Emergency Officials include How to get additional information? Not Included Not included Emergency Officials How will Gas Distribution operators dehver baseline awareness messages to Local Pubhc Officials? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. What is the frequency for Gas Distribution operators to dehver basehne awareness materials to Local Pubhc Officials? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. Do the Gas Distribution basehne awareness materials to Local Public Officials include Pipeline purpose and reliabihty? Not Included Not included for Local Pubhc Officials Do the Gas Distribution baseline awareness materials to Local Pubhc Officials include Awareness of hazards and prevention measures undertaken? Not Included Not included for Local Pubhc Officials#

520080027m_notice of amendment_12312008_text.pdf, page 145&) Question: Answer ' Page Number: Comments: Question . Answer: Page Number: Comments: C7/Question: Answer: Page Number: Comments: ~) Question . Answer: Page Number: Comments: Question: Answer: Page Number: Comments Question: Answer: Page Number: Comments Question: Answer . Page Number: Comments 42- Question 6/23/2008 Page 10 of 13 Do the Gas Distribution basehne awareness materials to Local Public Officials include Emergency preparedness coi11IIllllllcations . Not Included Not included for Local Public Officials Do the Gas Distribution basehne awareness materials to Local Public Officials include How to get additional information? Not Included Not included for Local Public Officials How will Gas Distribution operators dehver baseline awareness messages to Excavators? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. What is the frequency for Gas Distribution operators to dehver basehne awareness materials to Excavators? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a public awareness program for a transmission system and a local gas distribution system. Do the Gas Distribution baseline awareness materials to Excavators include Pipeline purpose and reliability? Not Included Not included for Excavators Do the Gas Distribution baseline awareness materials to Excavators include Awareness of hazards and prevention measures undertaken? Not Included Not included for Excavators Do the Gas Distribution basehne awareness materials to Excavators include Leak recognition and response? Not Included Not included for Excavators Do the Gas Distribution basehne awareness materials to#

520080027m_notice of amendment_12312008_text.pdf, page 15Answer: Page Number:- Comments: Question: Answer . Page Number: Comments . Question . Answer: Page Number: Comments: GS Question Answer: Page Number Comments Question: Answer: Page Number Comments: Question: Answer: Page Number: Comments: tu8) Question: 6/23/2008 Page 11 of 13 Excavators include One-call requirements? Not Included Not included for Excavators Do the Gas Distribution basehne awareness materials to Excavators include How to get additional information? Not Included Not included for Excavators Is the Gas Distribution operator a member of all appropriate one-call centers? Not Included Letter page 1 Cited that direct contact is used with excavators instead of a one-call notification system Section 6 2 Does the program describe the process and procedure used to determine whether supplemental elements will be implemented in response to Third-party damage incidents? No The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. Does the program describe the process and procedure used to determine whether Supplemental Elements will implemented in response to any factor other than High Consequence Areas and Third party damage? No The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. Section 8. 3 Does the program include an annual audit or review of whether the program has been developed and implemented according to the guidelines in RP 1162? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a public awareness program for a transmission system and a local gas distribution system. Section 8. 3 How will the operator measure program#

520080027m_notice of amendment_12312008_text.pdf, page 16Answer: Page Number . - Comments: I Question: Answer: Page Number Comments 7o) Question: Answer: Page Number: Comments . 7( Question: Answer: Page Number: Comments: 7&) Questton: Answer: Page Number: Comments: Question: Answer: Page Number . 6/23/2008 Page 12 of 13 implementation? Deviates from RP The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a public awareness program for a transmission system and a local gas distribution system. Section 8. 4 Does the program include an effectiveness evaluation methodology for Percentage of each audience reached with desired messages? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. Section 8. 4 Does the program include an effectiveness evaluation methodology for Understandabihty of the content of the message? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a public awareness program for a transmission system and a local gas distribution system. Section 8. 4 Does the program include an effectiveness evaluation methodology for Desired behaviors by the stakeholder audience? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. Section 8 4 Does the program include an effectiveness evaluation methodology for Achieving bottom-line results? Not Included The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a pubhc awareness program for a transmission system and a local gas distribution system. Section 8. 5 Does the program specify an evaluation of effectiveness no more than four years apart? Not Included#

520080027m_notice of amendment_12312008_text.pdf, page 17Page 13 of 13 Comments: The operator submitted excerpts from their Natural Gas System Procedures Manual and a few sample messages and not a plan for implementing a public awareness program for a transmission system and a local gas distribution system. Please respond at your earhest convenience. Thank you, Ross Reineke PHMSA/ Western Region- CATS Manager 720-963-3182 6/23/2008#