Brief, Briefer, Briefest: write to be understood

1. Brief, Briefer, Briefest: write to be understood • Chris Regan • NEPA Compliance Program Manager • Environmental Services Office • Washington State DOT • April 3, 2013 • Boise, ID A conversation with ITD and others about WSDOT’s approach to writing clear environmental documents. Reader-Friendly Workshop

2. Why use Plain Talk? • In Washington, the Governor’s office requires state agencies to communicate clearly (Executive Order 05-03) • We write so others can understand. • People need it! (3 out of every 10 people have some type of reading challenge) Reader-Friendly Workshop

3. What’s the problem? • “ NEPA documents today are largely written (in unreadable language) for two constituencies: • Federal district court judges and federal agency permit-writers.” • — Doug MacDonald, WSDOT Secretary of Transportation • 23 September 2002 “ Documents are much too cumbersome for either the public or decision-makers to Identify relevant issues.” — AASHTO/ACEC 2004 Joint Survey Reader-Friendly Workshop

4. NEPA reinforces a concise approach 40 CFR 1500-1508: Most important, NEPA documents must concentrate on the issues that are truly significant to the action in question, rather than amassing needless detail. Emphasize the portions of the EIS that are useful to decision makers and the public 40 CFR 1502.8: Environmental impact statements shall be written in plain language and may use appropriate graphics so that decision makers and the public can readily understand them. 40 CFR 1502.2: Environmental impact statements shall be analytic rather than encyclopedic. Reader-Friendly Workshop

5. It’s a confusing world! Reader-Friendly Workshop

6. Write to be Understood • Use Shorter Sentences • Make your average sentences 17 words long • Use Common Language • Write words with fewer syllables (less than 3) • Write in an Active Voice • The doer does what? • Present Concepts in a Logical Order Reader-Friendly Workshop

7. Helpful hints – things to watch • Avoid wordy phrases: • “for the purpose of illustrating...” = “to illustrate • “has the ability to remove…” = “can remove” • End “government-ese”: • “The purpose of this letter is to inform you that we will …” = “We will …” • “The department would like to apprise your office of that fact that…” = “We would like you to know…” • Stop writing in the third person: • “The department requests that contractors submit bids by…” = “Contractors, please submit your bids to us by …” Reader-Friendly Workshop

8. Helpful hints – things to watch (cont.) • Remove redundancy: • “The intersection is a distance of 5 miles from…” • The meeting took place at 5:30 PM in the evening. • Writing should always begin with the main point • Use lists, bullets, or numbers to break up a long sentence • Use Descriptive Headlines to grab attention Reader-Friendly Workshop

9. Even with Smaller Documents Readability is key • Categorical Exclusions (CE) comprise > 90% of NEPA reviews • CEs are still NEPA documents and must include relevant information organized logically to tell a story • DCEs contain technical details that could tempt an author into attempting a dissertation Reader-Friendly Workshop

10. Reader-Friendly Document Tool Kit Toolkit on-line: http://www.wsdot.wa.gov/Environment/ReaderFriendly.htm Reader-Friendly Workshop

11. The Story (a great project team started all this) Our story begins in the heart of downtown Seattle along a 4 mile stretch of SR 99. Reader-Friendly Workshop

12. The Story (and they worked hard to tell it) • SR 99 is a critical route, carrying 25% of Seattle’s thru traffic. • SR 99 viaduct is deteriorating and vulnerable to earthquakes. • 1930’s era seawall has been eaten by gribbles. • Seawall failure would be catastrophic. Reader-Friendly Workshop

13. The Story (scope has changed, but lessons remain…) • The project will improve public safety and shape regional transportation and downtown Seattle for the next 100 years. • Both facilities are critical to the region’s infrastructure; no action could be devastating. Reader-Friendly Workshop

14. Tell a StoryHow do you tell a story? • Write clearly, use simple language • To write clearly you must think clearly • Explain the problem and why people should care • Make the reader a character in the story • Organize the document to tell a story Reader-Friendly Workshop

15. Tell a StoryExample of clear writing EXAMPLE SENTENCE Mitigation elements for projects are developed during project planning, often through the SEPA/NEPA process for assessment and avoidance of adverse environmental impacts and the subsequent steps for obtaining legally required federal, state, and local permits for project construction. REVISED SENTENCE WRITTEN CLEARLY WSDOT identifies mitigation measures for project impacts during the NEPA/SEPA process. Many of these measures become commitments for WSDOT and conditions of federal, state, and local permits required for the project. Reader-Friendly Workshop

16. Reader-Friendly Writing What are congested and highly congested intersections? Congested intersections are intersections that cause drivers considerable delay. As a driver you might wait between one and two minutes to get through a traffic signal at a congested intersection. At a highly congested intersection, you might wait two minutes or more to get through the traffic signal. Traditional Writing Intersections that are projected to operate with especially long delays or overcapacity during the PM peak hour are identified as “congested intersections”. These intersections are those that operate under LOS F conditions (average vehicle delay of greater than 80 seconds) or ICU greater than 100 percent. Congested intersections are further identified as “highly congested” if they exceed 110 seconds of average vehicle delay and have an ICU of great than 110 percent. Tell a StoryMake the reader a character in the story This paragraph explains how congested intersections affect drivers. This paragraph talks about LOS, PM Peak, and ICU—meaningless terms to most readers. Reader-Friendly Workshop

17. Engage the ReaderHow do you engage readers? • Define terms and spell out acronyms • Avoid jargon • Use easy to read layouts to keep the reader from being overwhelmed Reader-Friendly Workshop

18. Engage the ReaderDesign for your reader White space Explain the problem and why people should care. The story of your project will be more interesting to the reader if they can immediately under-stand its purpose and why they should care about it. This is also an engaging way to present the purpose and need of your project. Every WSDOT project is striving to fix some problem such as a safety issue, Header Text Reader-Friendly Workshop

19. Make It VisualHow do you make it visual? We see tables like this all the time. Reader-Friendly Workshop

20. Make It Visual Bar Charts These bar charts show the same information as the tables, only it is easier to show differences and similarities between alternatives. Readers can draw their own conclusions. Reader-Friendly Workshop

21. Make It Visual Noise Discipline Report • Graphic helps reader to understand complex technical information • A table or bar chart would not be as effective Reader-Friendly Workshop

22. Make It BriefHow do you make it brief? • Lead agencies must focus on relevant information • Summarize information and conclusions • Include detailed analyses, if any, as appendices • Reference throughout your document • Background information supporting your project can be attached as well. Reader-Friendly Workshop

23. Make It BriefInitial text describing construction sequencing Reader-Friendly Workshop

24. Make It BriefConstruction text summarized in a chart Reader-Friendly Workshop

25. Other important concepts • Analyze data, don’t just report it! • Draw conclusions • Clearly define project benefits – include environmental • Describe the features of the project that avoid impacts • Don’t just focus on the ‘sin and penance’ or worst case … • Develop an outline for all documents! • Annotate the outline with a brief description of what information will be covered • Include a rough description of ideas for graphics Reader-Friendly Workshop

26. What are WSDOT’s expectations? • Quality, readable documents – concise, plain English • Brevity, focus on relevant issues • Consistent look and feel Reader-Friendly Workshop

27. WSDOT Environmental Services staff resources Chris Regan (360) 705-7492 E-Mail: chris.regan@wsdot.wa.gov Carol Lee Roalkvam (360) 705-7126 E-Mail: roalkvc@wsdot.wa.gov Please see our website at http://www.wsdot.wa.gov/Environment/ReaderFriendly.htm Is there Federal Support for Reader-Friendly Documents? YES Federal Highways Administration (FHWA), EDC 2012 Initiatives includes improving document quality to promote efficient effective NEPA documents. FHWA cooperated with AASHTO and the American Council of Engineering Companies (ACEC) in preparing the report, Improving the Quality of Environmental Documents. Reader-Friendly Workshop

28. “Implementing Quality Environmental Documentation” • EDC 2012 Intitiative • “documents are difficult to comprehend, unnecessarily lengthy, do not meet legal requirements, or omit important information.” • Recommendations: • Use clear concise writing • Summarize technical reports • Choose easy to use document format • Use effective pictures and graphics • Make the level of detail relative to that issue’s importance Reader-Friendly Workshop

29. “Improving the Quality of Environmental Documents” A Report of the AASHTO/ACEC Joint Committee in cooperation with FHWA Reader-Friendly Workshop

30. What went into the joint report? • Key ingredients: • Results of survey & two joint workshops • Team review of works from many DOTs • Washington DOT’s Toolkit • Caltran’s Style Guide • NCHRP 25-25 (01) Blueprint Reader-Friendly Workshop

31. AASHTO & ACEC Task Force Survey NEPA Documents: • Are large, repetitive, complex, cumbersome • Are often inconsistent among different authors • Lack a coherent story and logical progression • Focus on being legally “air tight” vs. readable • Not particularly useful for decision making Reader-Friendly Workshop

32. Recommendations for improving quality • Follow core principles (next slide) • Use the scoping process to focus on key issues and to help tailor level of detail • Do a summary for circulation if the document is long • Incorporate data by reference Reader-Friendly Workshop

33. Core principles for improving quality • Principle 1:Tell the story of the project so that the reader can easily understand the purpose and need for the project, how each alternative would meet the project goals, and the strengths and weaknesses associated with each alternative. • Principle 2:Keep the document brief, using clear, concise writing; an easy-to-use format; effective graphics and visual elements; and discussion of issues and impacts in proportion to their significance. • Principle 3:Ensure that the document meets all legal requirements in a way that is easy to follow for regulators and technical reviewers. Reader-Friendly Workshop