Writing a Service Manual Chapter

1. Writing a Service ManualChapter Tips, tools, and techniques for writing chapters for the Fish and Wildlife Service Manual

2. What do I do first? • Don’t sound like a bureaucrat.Write using plain language: • Employees and the public should be able to understand your chapter • Read 116 FW 1, Plain Language in Fish and Wildlife Service Documents • Visit www.plainlanguage.gov

3. Then do a little homework • Read 011 FW 2 and 011 FW 3 • Manual chapters on how to write chapters and our clearance process • 011 FW 2 includes a template, examples, and writing tips • If it’s a new chapter, look at the Service Manual Index to determine where your chapter will fit: • www.fws.gov/policy/manuals/ • Make sure there isn’t already a chapter that covers your topic • You can search under each series, or you can enter your topic in our search engine

4. Next, call Krista Bibb in the Policy and Regulations Branch (PRB) • Krista will: • Help you plan your project • Guide you through complexities like getting comments from the Directorate and the public on a draft chapter • Help you understand the process and troubleshoot any problems you encounter • Edit your chapter for plain language early in the process so the chapter is as easy to understand as it can be • Phone: (703) 358-1914 • Email: Krista_Bibb@fws.gov

5. Who’s the audience for your chapter? • Your primary audience is our employees • But our policy must be transparent to the public so they understand it too • Avoid technical jargon (see plain language tips) • Do not write using language that only technical experts will understand continued…

6. Who’s the audience for your chapter? An example… • Imagine you’re writing a chapter on cooperative farming at National Wildlife Refuges. • You explain in the policy what the Refuge Manager may allow farmers to do and what’s prohibited. • A cooperating farmer wants to better understand why he is not allowed to do something. • He finds our policy online and reads and rereads it, but cannot penetrate the bureaucratic language. Frustrated and confused, he calls the Refuge Manager. • You’ll make it easier on the Refuge Manager and the public if you clearly explain our policy so that the average intelligent person can understand it. People shouldn’t have to study a policy for hours to figure out what it means.

7. A word about policy vs. regulation • Do not regulate in our Service Manual • You can tell employees what they may do and how to do it, but you should not use the Manual to tell the public what it may or may not do • To tell the public what it may or may not do, you write a regulation, not a policy in our Manual

8. Policy Language: The Project Leader must ensure that hunters with permits hunt only during the local (county and State) hunting season. Grants specialists must collect XYX Forms from applicants by October 1, 2009. Regulatory Language: Hunters with permits may hunt on the refuge only during the local (county and State) hunting seasons. Grantees must complete and send us the XYZ Form by October 1, 2009. Policy vs. Regulation – Example Language The difference is subtle. Call Krista in PRB if you need help.

9. Beginning your first draft: Organize your information before you write • Plain language is about more than easy-to-read sentences. It also means the information is logically organized. • Think about and record a few things before you begin working on the technical content: • Why are you writing the chapter? That’s your purpose. • Who or what does the chapter apply to? That’s the scope of the chapter. • What laws, regulations, and policy allow us to do what’s in the chapter? Those are the authorities. • Then you can start organizing the guts of the chapter continued….

10. CLICK for an example Organize your information before you write • Don’t begin crafting sentences until you’ve got the basic ideas on paper • Use whatever outlining method works for you • Many authors prefer to informally brainstorm ideas • Then put them in a logical order

11. Here’s a way to organize your thoughts(Vehicle maintenance is the topic) Step 1: Brainstorm Step 2: Organize the storm Scheduled inspections Maintenance facilities -Sketch out main points -Sketch out main points • Fuel, oil, and lube • Fuel and motor oil • Other lubricants • Tires • Preventive maintenance • Who writes Region’s procedures • Adverse conditions • Penalties for not scheduling preventive maint. • GSA’s schedules • Maintenance facilities • Ours • GSA’s • Commercial • Scheduled inspections • Point 1, 2, etc. • Warranties • Point 1, 2, etc. • Signs of operator abuse • Point 1, 2, etc. -Sketch out main points -Sketch out main points Warranties Fuel, oil, and lube -Sketch out main points -Sketch out main points -Sketch out main points -Sketch out main points Preventive Maintenance Signs of Operator abuse -Sketch out main points -Sketch out main points -Sketch out main points -Sketch out main points -Sketch out main points -Sketch out main points

12. Start writing • Use the template in 011 FW 2 • You’ve already written the first few sections of the template: • What is the purpose of this chapter? • What is the scope of the chapter? • What are the authorities? • Use your outline to draft the remaining sections • You may want to wait to write the section called “Who is responsible for the policy?” last. It’s easier to write it after you’ve written everything else.

13. Click here for some guidance on how to use helping verbs. Write, read, and revise • Avoid writer’s block -- start writing and don’t worry too much what it sounds like • Reread your work and see what you missed • Flesh it out and reorganize if you need to • Then start polishing your work continued…

14. Write, read, and revise • Good writing is an evolving process. • If you try to make it perfect the first time, your attempts at perfection limit your creativity.

15. Your draft is ready for review:Overview of the Review and Clearance Process Final clearance • Affected ADs, • PRB, • PERMA, • AD-M&A Most policies Directorate Review (if new or major changes) Director’s review and approval Informal review- Krista in PRB Significant policies undergo more review Published in Federal Register for public comment OMB has opportunity to review “significant” policies • The following slides describe each of these steps

16. Informal review • Once you’re happy with your draft: • Email it to Krista in PRB BEFORE you prepare a surname package • Krista: • Edits the chapter for plain language, checks for consistency with other policy, and checks your citations • Will email the chapter back to you to finalize • PRB’s early review of chapters saves time in the long run • PRB also will help you obtain review from the Office of the Solicitor (SOL). Ask her about this step.

17. How do you obtain Directorate comments? • You need to send your chapter out for Directorate review if: • It is new, or • Revisions will impact the way the Regions do business • Prepare a memo from the Director to the Directorate asking for their review (click here or call Krista and she’ll send you a template) • Allow at least 30 days for the Directorate to comment continued…

18. The Surname package to request Directorate comments • Prepare the package like you would for other correspondence. Your package may be entirely electronic and uploaded to our Data Tracking System (DTS). If your program requires a hard copy, then put it together as this graphic depicts. Old Chapter (if applicable) Note to Reviewers Yellow surname copy of Memo from Director to Directorate asking for review Exhibits, etc. Any Important Background New or Revised Chapter

19. Enter a record into our Data Tracking System (DTS) • Enter the information about the surname package in DTS • In DTS, assign the package to the first official who you want to surname it. • Be sure to click “email” when you assign the official the record so that he/she knows it’s in the inbox. • Note: Most programs’ leadership will surname electronically in DTS. When it is assigned to PRB, we will put together a hard copy package for the Director’s office. If your program requires hard copy, then that copy should go from office to office as the officials surname in DTS.

20. Incorporating Directorate comments • After the Director signs the memo, the Correspondence Control Unit (CCU) sends it and the draft chapter to the Directorate using the DTS • Members of the Directorate will post their comments in DTS continued…

21. Incorporating Directorate comments • Incorporate the comments you receive from the Directorate and finalize the chapter • If you don’t incorporate a comment, explain why. Prepare a summary of comments and how you incorporated them (click here for an example you can use as a template)

22. Getting comments from the public by publishing in the Federal Register • You should seek public comments on a policy if it: • Has an annual effect on the economy of $100 million or more or adversely may affect in a material way the economy; a sector of the economy; productivity; competition; jobs; the environment; public health or safety; or state, local, or tribal governments or communities. • Creates a serious inconsistency or interferes with another agency’s action(s). • Has clear and substantial impact on important public policies or private sector decisions. • Raises highly controversial issues related to interagency concerns or important Administration priorities. continued…

23. Getting comments from the public by publishing in the Federal Register • Raises novel legal or policy issues arising from legal mandates, the President’s priorities, or the principles of Executive Order 12866. • Materially alters the budgetary impact of entitlements, grants, user fees, or loan programs. • Is about innovative or complex scientific or technical issues. • Your program wants to get comments from the public for other reasons.

24. Getting comments from the public by publishing in the Federal Register: OMB may review first • If you believe a chapter meets any of the criteria in the previous slide, you must ask PRB to include it on the “90-day list.” • Our “90-day list” is a list of regulations and policies ready for review by the Office of Management and Budget (OMB) during the next quarter of the fiscal year. • If OMB designates your chapter as “significant,” you must send it to OMB for clearance before you may publish it in the Federal Register continued…

25. Publishing in the Federal Register • After incorporating Directorate comments, send the chapter to OMB, if required • Incorporate any OMB comments • Then: • Write a notice of availability (contact PRB regulatory staff for help writing the notice and preparing the surname package for the notice) • The notice should include a URL where people can find the draft policy (we save money by publishing a notice and not the entire chapter) • When the notice publishes, it will have a link to the policy so people can read it • Incorporate appropriate public comments • You may choose to publish another notice when the Director signs the final chapter

26. Elements of the Final Surname Package • Your final surname package may be entirely electronic (in DTS). • Upload the following documents in DTS: • Note to reviewers • Summary of comments and how they were addressed • Final chapter and any exhibits • Other supporting information (if it’s a revision, it is helpful to upload a redline copy of changes) • If your managing Directorate member requires hard copy, you must also include a di-228, Clearance Record in the package • Prepare a routing tree in DTS with all the offices you want to surname the chapter • Route the record to the first office in the routing

27. Who should surname the final package? • Your Division Chief and Assistant Director • Any other Assistant Director whose program has significant responsibilities in the chapter • Then these officials in this order: • Chief, Branch of Policy and Regulations (AMAD-PERMA-PRB). If entirely electronic in DTS, PRB will prepare a hard copy for the Director’s signature at this stage. PRB also will work with you to obtain a surname from the Office of the Solicitor, if you haven’t already gotten it, or to make any necessary revisions they require. • Chief, Division of Policy, Economics, Risk Management, and Analytics (AMAD-PERMA) • Assistant Director – Management and Administration (AMAD) • Correspondence Control Unit (CCU): CCU will assign it to the Director’s office

28. If the Director signs the policy, CCU sends it back to PRB PRB: Notifies you it’s signed and publishes it online Sends out a Servicewide notice in DTS about its publication, assigned to the Directorate for distribution Keeps the original signatures for the Directives files If the Director does not sign the policy: The Director’s office may call and ask for a briefing, or CCU may return the surname package to you asking for revisions or corrections Then what happens?

29. Your chapter…. • Is posted on the Service Manual website under its series, and • On the “What’s New?” page

30. Visit your chapter from time to time • Make a note on your calendar to reread your chapter at least once a year • Update the policy when it’s no longer accurate • Keeping our policy up-to-date saves time and money because people can easily find the answers they need to do their work