Dear Regulator: Writing to the Environmental Agency

By Vincent Dodge, Director Environmental Compliance, Dynegy – PJM & NE

I have provided environmental compliance support for the power generation industry for almost 25 years. The more I communicate, verbally or in written form, the more convinced I am of the difficulty in doing it well. My job depends on effective written communication with local, state, or federal agencies. Before I begin writing, I focus on four concepts:

1. Effective Communication is hard. Reminding myself of this fact, right off the bat, helps put me in the proper mind set. I didn’t major in English, and I am not a linguist. Like many of us who find ourselves in the unenviable position of writing to an environmental agency, I am an engineer and therefore somewhat challenged in all things non-technical. My dad (who was an English major) almost had a stroke when he discovered freshman English wasn’t even a requirement in my college curriculum. Literary difficulties aside, many common everyday issues make good communication difficult. Differences in beliefs, experiences, understanding, and vocabulary interfere to confuse our message.

2. “Greasing the skids” is an old ship building phrase that means “to facilitate,” or “to help matters run smoothly along the intended path.” Remember that writing a letter to the agency should not be the first step in our efforts to communicate with them. Never surprise them with a letter, and never send them written communication they are not already expecting. There should have been a conversation, a meeting, or a phone call preceding the letter. I use a letter to confirm the understanding, decisions, or actions that were previously agreed upon. Whenever I am communicating with the agency I have a desired result in mind. The bigger the desired result, the more “grease” is required.

3. What is the message? The meat of the message is the story but using a basic construction for the correspondence can significantly improve its effectiveness.

Identification – Clearly identify the facility, the date, and the event. The agency deals with many different events at many facilities. Don’t make them search through piles of old documents or email to try to understand what you are talking about.

Reason for writing – State the reason I am writing, clearly and simply, up front. There are usually only a few basic reasons to write to the agency. It can be to explain an event which occurred, respond to an agency request or notification, document a previous communication (meeting, discussion, etc.), or to update a previous event or communication.

Message – The Story (see below)

Conclusion – “Please contact me if you have any questions.” I like this kind of ending because it’s simple and I don’t want to send the agency something that requires them to respond. Also, if I have done a good job greasing the skids I already know there will be no questions.

“I am an engineer and therefore somewhat challenged in all things non-technical.” – Vincent Dodge. Dynegy

4. Tell a good story. The story is the most important part of the correspondence. It needs to effectively communicate our message to the agency. It needs a theme with a clear, concise, and logical progression that leads the reader to understand and follow to the conclusion we want them to walk away with.

Identify the concepts – Begin by having a clear idea of the overall message we want to communicate, and the pieces or concepts that will get us get there. The list of concepts needs to be as short as possible so that our story doesn’t get too long or go in too many directions.

Know your audience -Know and understand who will be reading the correspondence; Write to their level of understanding, not ours. While it is sometimes important to educate our audience so they understand our story, accomplish this when “Greasing the skids.”

Be concise – Don’t use 200 words if 75 will clearly tell the same story. If it is a response to questions from the agency be careful to clearly respond to all of the questions, but stick to answering the questions only. Don’t include details and information that are not absolutely necessary. Providing unneeded details of an action plan may require follow up correspondence later if minor plan deviations occur.

Don’t create deadlines and requirements – Don’t set deadlines, make promises, or require a response from the agency unless it is required.

Effective written communication establishes rapport with the agency and facilitates compliance.