C

Communicating the Message Effectively

INTRODUCTION

Effective communications with stakeholders are critical to implementing federal facility renewal strategies. The best means to implement these strategies is through a facility asset management system, based on the International Organization for Standardization (ISO) 55000 standards. ISO 55000 goes to great length on how to identify and work with stakeholders using a strategic asset management plan (which the committee refers to as an agency’s real property capital plan) and subordinate asset management plans. As detailed in this report, this invites a bolder, more direct way to communicate facility performance and budget needs to support agency mission achievement.

This appendix expands the concepts and discussion in Chapter 3 on facility asset management anatomy and its relationship to a facility asset management system to emphasize how these frameworks also provide a structure for communications. Figure C-1 and Table C-1, which illustrate these concepts, are repeated from Chapter 3 (see Figure 3-3 and Table 3-2) for easy reference. The appendix outlines an approach to promoting the benefits of a disciplined asset management system to agency policy makers, in order to improve the success of making the transformational changes described in this report.

FACILITY ASSET MANAGEMENT SYSTEM–BASED COMMUNICATIONS

When integrated, the facility asset management system anatomy and asset management system requirements establish a framework for communications.

TABLE C-1 Facility Asset Management System Anatomy and ISO 55001 Clause Comparison

SOURCE: Data sourced from International Organization for Standardization, 2014, ISO 55001: Asset Management—Management Systems—Requirements.

While this framework was covered more generally in Chapter 3, here it is discussed from a communications lens.

Step 0: Mission Execution

Mission execution is defined by U.S. Code and informed through the President’s Management Agenda and the Performance Management Framework, which are detailed in the Office of Management and Budget (OMB) Circular A-11, Section 200. This body of work defines agency authorities, priorities, and budgets, and its execution is governed by the revised Government Performance and Results Act of 1993. An agency must develop its federal facility renewal strategies in support of the agency’s mission and demonstrate that it does so in its real property capital plan (ISO 2014b, Clauses 4 and 7.4). This approach is consistent with the data integrity principle introduced in Chapter 3, which states that data used (and communicated) must service the decision-making needs of the asset management system. This principle is used to assure stakeholders that facility asset management objectives—and, in turn, facility performance—align with their needs and expectations. This also ensures that the agency’s real property capital plan upholds the agency’s fiduciary responsibility to manage its facility

assets efficiently and effectively, and to report achievement of this responsibility through reporting requirements detailed in OMB Circular A-136—Financial Reporting Requirements, which, in part, respond to any outstanding Government Accountability Office (GAO) managing federal real property high-risk issues (GAO 2011c).

Step 1: Organizational Objectives

Organizational objectives development, in alignment with communications covered in Step 0, fulfills federal agency requirements to establish strategic plans (OMB Circular A-11). In turn, this makes use of existing agency strategic planning policy and processes to manage facility assets in support of resource-and-investment decision making. These management activities are well practiced, but a review of agency strategic plans finds that there is little (and often no) attention given to facility asset management activities. This is remarkable given that approximately 10 percent of most agency management and operations budgets is consumed by facility assets. Therefore, the committee recommends that OMB fix object classifications (Schedule O) contained in OMB Circular A-11, Section 83, to ensure that costs incurred by facility assets are fully accounted in accordance with the balance sheet analysis principle introduced in Chapter 3.

ISO 55001 calls out the importance of understanding organizational objectives and using them to guide facility asset management objective development. In all cases, organizational objectives define the purpose behind federal facility renewal strategies; therefore, their description and constant upkeep are essential to developing and maintaining effective, responsive real property capital plans. This is why, in a number of front-end clauses, ISO 55001 emphasizes that the role of an asset management system is to promote achievement of organizational objectives, in order to ensure that stakeholder needs and expectations are considered and communicated throughout the process.

Step 2: Facility Asset Management Objectives

Facility asset management objectives are a response to organizational objectives; this relationship provides a basis of communications to assure stakeholders that facility management activities align with mission needs and expectations. Communications of this type push facility asset managers beyond classical facility management thinking and into management system thinking. Specifically, facility managers must frame asset management objectives so that they are meaningful to three specific types of decision makers:

• Mission operators and facility users need to understand that the work defined by facility asset management objectives reflects their concerns and expectations in a way that invites critical feedback.

• Financial and program managers need to understand how performance risk is managed through resource-and-investment decision making (e.g., what is the impact or potential consequence if a budget decreases by 5 percent?).
• Facility managers need facility asset management objectives to define facility performance criteria that are relevant to facility planning and asset life-cycle management decision making.

To address these needs, as a building block of communication, is the performance–budget integration principle introduced in Chapter 3 and further developed in Appendix F (see Figure C-2).

Although it is relatively simple, the performance–budget integration framework can be adapted to a full range of facility asset performance requirements (e.g., stakeholder expectations) that are meaningful to facility managers in terms of acquisition, design/construction, maintenance, and operating standards. This framework can also be used to equate facility requirement cost analysis, supporting broader planning, programming, budgeting, and execution decision making relevant to financial and program managers. The framework shown is supported by OMB and numerous agency policies, but is rarely represented from an asset management perspective. Doing so is one way to advance communications using an ISO 55000–based facility asset management system.

Step 3: Assessment of Asset Capabilities

Step 3, assessment of asset capabilities, builds on communication activities detailed above. In this area of the framework, facility asset management objectives defined in Step 2 are used as a basis to communicate actual facility performance as a product of a facility assessment or study. This is an essential part of an ISO 55001 asset management system as defined in Clause 9 (Performance Evaluation) requirements and emphasized through many asset management principles introduced in Chapter 3.

There are two primary decision-making levels where this assessment is critical. The first is evaluating the performance of facility assets and portfolios in comparison with user-defined facility asset management objective performance criteria and thresholds. This provides a foundation for a gap analysis, which is performed in the next step. In Step 3, the focus is on reporting the facts on actual facility performance for areas that matter to the three stakeholder groups listed in Step 2 (mission operators and facility users, financial and program managers, and facility managers). Doing this correctly substantiates the Evidence-Based Policymaking Act (also known as the OPEN Government Data Act) of 2018 requirements, implemented through OMB Circular A-130—Managing Information as a Strategic Resource, which likewise affect development of federal facility renewal strategies. The second level critical to decision making entails establishing trust

in the resource-and-investment decisions being made. If the foundational information used in federal facility renewal strategies is suspect, confidence in any decision will likewise be suspect. This is why performing and reporting data validation and verification, as detailed in Chapter 4, is so important. This foundation includes accurate inventory, status, and performance reporting. This is also why so much energy has been spent on improving facility inventory data, which is only a first step of broader federal facility asset management strategy—not an end objective.

Also on the facility asset management system pipeline is status reporting, as exemplified by the proliferation of facility dashboards and decision-support technologies. Coupled to this motivator is facility performance reporting, summarized in the introduction to the facility performance principle in Chapter 3. This principle focuses attention on four performance attributes that are critical to evaluating the performance of all facility assets: condition, functionality, availability (a method for facility status reporting), and utilization. These methods, interrelationships, and decision-making interdependencies involve communications that, in accordance with ISO 55001, must be detailed and documented in the agency’s facility asset management system (ISO 2014b).

Step 4: Risk Management and Resource Planning

Risk management and resource planning require tools and skills that are not typically the focus of a facility manager’s professional growth trajectory. Given that facility managers are critical to facility asset management system operations, it then becomes incumbent on the system to introduce and augment these capability needs. These requirements are detailed in OMB Circulars A-11 and A-123, but—as highlighted in Chapter 2, and detailed in Appendix E and GAO-19-57, Federal Real Property Asset Management: Agencies Could Benefit from Additional Information on Leading Practices—OMB policy can do more to explain how to improve federal facility performance management. Supporting this is the operational readiness principle introduced in Chapter 3, which defines an apex method for supporting communications and provides a simple basis for communications, bringing together mission operators, financial and program managers, and facility managers in a common decision-making framework. Appendix E provides an example of this principle at work in the Army National Guard Readiness Center Transformation Master Plan. Likewise, this approach establishes a basis for enterprise risk management for whole facility portfolio management activities. This is the natural outcome of an ISO 55000–based facility asset management system and fully supports OMB Circular A-123 requirements and their role in implementing OMB Circular A-11 requirements for better management of government spending in alignment with value-generating objectives.

Step 5: Real Property Capital Plans

Real property capital plans are not just plans; they are communications platforms. More specifically, they are places where agencies can organize strategic communications with key stakeholders with interests in facility performance. To start, OMB Circular A-11’s Capital Programming Guide requires the agency’s capital plan, of which the real property capital plan is a subset, to be used to inform budget development. This is carried out through agency planning, programming, budgeting, and execution processes. In terms of communications and risk management, the real property capital plan provides a critical role in responding to changes in the operating environment. Specifically, the real property capital plan, through periodic updates, provides an iterative communications framework for balancing and reconciling risk in a manner understood by key stakeholder groups, as depicted in Figure C-3.

This framework recognizes that risk must be continually evaluated from three perspectives. Furthermore, the facility asset management system must detail how these communications are performed to ensure and assure clarity of effort and purpose. In alignment with federal policy, ISO 55000, and recommendations made in this report, the real property capital plan (per ISO 55000 the strategic asset management plan) is the apex means to bring clarity to these important decision-making and communication needs. ISO 55001 is focused on this area and the importance of its application in guiding facility asset management system development to implement effective and impactful federal facility renewal strategies.

Step 6: Execution of Facility Programs

Execution of facility programs consumes a vast majority of the funding supporting facility operations, including acquisition, operations, maintenance and repair, real estate management, and services (utilities, communications, security). In the ISO 55000 construct, this activity is anticlimactic because it runs counter to the response-oriented, hero mentality prevalent in many facility operations. Performing this step effectively requires the setup of all the prior steps and substantial, systematic communications with key stakeholders. This is to ensure (via objective setting and performance evaluation feedback loops) and assure (via confidence and integrity building) that facilities are being managed well and achieving mission objectives in alignment with stakeholder expectations. Simply put, stakeholders that depend on a facility are the ultimate judge of how well that facility is being managed. Therefore, facility managers must continually ensure that their priorities align with organizational objectives and that their communications ensure that stakeholders understand this relationship and can participate in risk-based resource-and-investment decision making. It is important that stakeholders understand and accept the decisions and share the responsibility. As such, communicating in this area includes developing understanding, knowledge development, and performance reporting. All of these requirements are detailed in ISO 55001 as part of an effective facility asset management system.

Step 7: Performance Evaluation and Reporting

Performance evaluation and reporting are essential, often overlooked management activities for organizations beginning to implement disciplined facility asset management systems. While ISO 55001 includes many technical requirements supported by OMB Circular A-11 and A-123 requirements, it improves on these by clarifying how supporting management requirements must be coordinated to realize effective, impactful federal facility renewal strategies. This includes communications with agency executive leadership and superior decision makers in the executive branch and Congress. Supporting this, as detailed above, and as required in form through the performance management framework detailed in OMB Circular A-11, an agency’s real property capital plan provides a focal point for these communications. OMB M-20-03, “Implementation of Agency-wide Real Property Capital Planning” and OMB M-20-10, “Issuance of an Addendum to the National Strategy for the Efficient Use of Real Property” also address these ideas. Also, as detailed in the discussion of this framework in Chapter 3, Step 7 represents both an end and a beginning. This step establishes a continual improvement process dictating how the facility asset management system must provide feedback regarding the asset management objectives detailed in Step 3, highlighting the fact that facility asset management objectives are the fulcrum for all performance evaluations, calling to mind the adage that “only

what is measured can be managed.” Therefore, those developing a facility asset management system need to pay special attention to the selection of performance evaluations and the manner in which they are presented and communicated.

This section has detailed how an ISO 55000–based facility asset management system supports a wide range of communications needed to advance federal facility renewal strategies. OMB and most agency policies emphasize the importance of communications supporting effective facility management. The committee contends that current policy is helpful but insufficient for providing the breakthroughs required. That is why this report promotes the use of management system thinking to reframe risk, resource, and investment decision making, as well as stakeholder engagement. This bold, new approach will require substantial communications to develop this idea into working policies, as well as new and improved communications related to managing facility assets.

SUPPORTING AND JUSTIFYING FACILITY RENEWAL STRATEGIES THROUGH BUDGET DISCUSSIONS

This section extends the idea introduced in the last section on required communications to promote it as a policy that agencies can implement on their own. These aspects of communications generally get little attention from the classical facility management thinking perspective. This section develops an approach on how to communicate with and convince policy makers of the benefits derived from an ISO 55000–based facility asset management system, focusing specifically on how agencies can frame benefits in a way that clarifies risk and opportunities in making such a transformational change.

An agency’s real property capital plan leads the way in communicating agency-wide plans and performance objectives in order to assure stakeholders that their needs and objectives are being addressed fully. Stakeholder engagement objectives are clearly stated in internal control requirements and guidance contained in OMB Circular A-123 and its supporting GAO-14-704G (the Green Book, GAO 2014e). Such communication needs to

• Occur throughout all agency processes;
• Engage any stakeholder who would benefit from better federal facility asset management;
• Develop influential communication method strategies that proactively leverage policy; and
• Be clear, complete, comprehensive, appropriately nuanced, fact based, and rich in quality data.

Effective communication is needed in almost every step of the facility asset management system framework, including (1) strategic planning; (2) budgeting; (3) program evaluation, including periodic reevaluation to identify any

programmatic changes that may be warranted; and (4) responding to requests for information from Congress and other external parties.

As the committee noted earlier, agency use of an asset management system is a critical component of effective facility portfolio management. An effectively developed and implemented federal facility renewal strategy should be thought of as a proactive communications strategy. The strategy can ensure efficient asset management because it harmonizes a decision-making framework, coordinating all stakeholder engagements, gathering high-quality and reliable data, supporting informed decision making, and including performance evaluation to inform improvement activities stemming from the evaluation.

The committee appreciates that many senior executives and other senior managers communicate among themselves and with stakeholders on a near-daily basis. At the same time, the committee notes that effective communication using leading practices can enhance the performance of agency officials at all levels and is helpful to establishing a cohesive overall message for federal facilities renewal (see OMB M-20-10, “Issuance of an Addendum to the National Strategy for the Efficient Use of Real Property”). Agencies can leverage the federal budgeting process to communicate progress, as detailed in Chapter 6.

At the highest decision-making levels, the federal budgeting process involves competing for resources among agencies and other components within federal departments. As noted in Chapter 3, federal agencies need to generate value supporting mission achievement. Given that resources are limited in normal, nonemergency situations, agencies have to find a balance between many different needs for funds, including funding federal facility renewal. Few federal agencies receive everything they request. Therefore, effective communication seeking resources should start with an honest appraisal of the value proposition supported by facilities. This should define the difference between wants—that is, resources that would be nice to have but are not essential for mission capability—and needs—that is, resources essential for mission execution. Effectively identifying mission needs and prioritizing them before seeking resources improves confidence in the request. In practice, this needs-versus-wants consideration is essential to implementing OMB’s Circular A-11, Supplement—Capital Programming Guide. Doing so invokes several principles detailed in Chapter 3 and Appendix F, notably mission alignment, operational readiness, and performance–budget integration, while providing reasonable assurance to stakeholders, including Congress.

Agency program officials should then limit their request to only what they need; it is important to understand that their own agency, department, OMB, or Congress will not look favorably on requests that do not directly support mission achievement. This sometimes involves different audiences in the budgetary approval chain inside the department, at OMB, and among congressional appropriators and authorizers. These audiences may view the value of federal facilities beyond a narrow definition of agency mission execution to include

socioeconomic, environmental, energy, climate change, social responsibility, and national strategy objectives.

CONSISTENCY OF KEY COMMUNICATION PRINCIPLES

Effective communication relies on timeless principles of credibility, trust, and justification based on mission essential value. Implementing federal facility renewal strategies will be more persuasive when the case for renewal can be understood and trusted by key decision makers in their chain of command structure.

Credibility

Resource justifications using a disciplined asset management system applying principles outlined in Chapter 3 provide a rigor and framework that inspire confidence in budget decision makers. Full message transparency and an ongoing and frank dialogue with decision makers contribute to developing credibility. Organized messaging based on accurate and complete data, and robust internal audits and management reviews, as detailed in ISO 55001, Clause 9 (Performance Evaluation), are important for both developing an agency facility renewal strategy and establishing credibility for that strategy.

Trust

Successful federal facility renewal strategies must be responsive to how stakeholders measure value. These stakeholders include OMB officials, members of Congress and their staff, and senior agency decision makers. The relationships among facility and asset managers and these stakeholders may be limited to publication of the agency’s real property capital plan and must be considered part of real property capital plan development. Basing real property capital plans on a robust facility asset management system that reinforces quality, consistency, and continual improvement builds trust through methodical fulfillment of expected results. Therefore, agency facility renewal strategies are advantaged when real property capital plans clearly support mission achievement and stakeholder expectations; therefore, clear communication requirements must be spelled out in the agency’s facility asset management system.

EFFECTIVELY TARGETING COMMUNICATIONS WITH THE EXECUTIVE BRANCH

Facility managers and others along the budget approval chain should prepare facility renewal strategies in a manner that streamlines and simplifies budget development. Artful communications anticipate and respond to budget decision

making and demonstrate how risk is managed and value is generated. For instance, ISO 55000 promotes the view that asset management is about managing value and not about managing assets. In remarks to the committee, the Honorable John W. Henderson, assistant secretary of the Air Force for installations, environment, and energy explained:

Thus, requests for resources can be more effective if they include a convincing discussion of the contribution facilities make to mission capability. For example, the Air Force’s Mission Dependency Index (MDI) links facilities to mission execution or mission capability for this purpose. Communications using tools such as MDI become more persuasive if they include a reasoned discussion of the consequences of doing nothing, or of how receiving insufficient resources will increase risk of mission failure. For example, in 2009, GAO reported that

While the committee does not have evidence indicating whether the mission failure risk was communicated in the request for resources, the example highlights that such input can be compelling in requesting resources.

Communications need to include reliable and consistent data underpinning the request, which should increasingly build trust among the parties going forward. Federal departments can employ a process to target communications, using facility asset management objectives, to substantiate and justify budget requests. Effectively implementing such communications through real property capital plan development is a fundamental part of an ISO 55000–based facility asset management system.

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¹ Honorable John W. Henderson, meeting with the committee, on September 17, 2019.

Similarly, agencies can also make effective connections by having a highly technical response ready for those who are likely to prefer or need a higher level of detail or greater technical specificity. Having responses appropriate to the needs of the decision makers can help officials who have approval, authorization, or appropriation responsibilities but may not have as much time as they might like for the review process. OMB Circular A-123 and GAO’s Green Book offer some relevant key concepts that are completely compatible with ISO 55000. Specifically, management should use quality information to define facility asset management objectives. Management should then communicate the necessary quality information internally and externally using appropriate methods to specifically include real property capital plans, considering stakeholder needs, and including legal or regulatory requirements (GAO 2014e).

While federal agencies generally have planning, programming, budget, and execution processes, the committee notes that these policies generally focus on authorities and funding concerns but not on how to manage the value generated from facility assets, which is the exact purpose of ISO 55000 standards. This is another reason why selection and development of facility asset management objectives is so important. Specifically, these objectives should be developed to resonate with mission operators, financial and program managers, facility managers, and budgeting officials to ensure and assure that desired value-based objectives and benefits will be achieved. The art of pulling all of this together is the essence of federal facility renewal strategy development.

EFFECTIVELY TARGETING COMMUNICATIONS WITH THE LEGISLATIVE BRANCH

Communication between the executive and legislative branches can be challenging but need not be. Congress has a crucial role in determining what policies the federal government will pursue in the coming fiscal year through its appropriations and authorization processes. Agencies do well to view Congress as a partner seeking to enable mission achievement. In the same way that trust and credibility are built over time, communications with members of Congress or committee or member staff, such as allowed by agency policy and enabled through dissemination of real property capital plans, should also be considered when developing federal facility strategies. Specifically, development of real property capital plans should be attentive to both agency mission requirements and other requirements that may influence agency facility management. In this way, synergies may emerge that are helpful in improving agency mission achievement, supported by activities that also help achieve other authorized purposes.

Federal agencies can enhance their effectiveness by framing requests for resources to specific audiences involved in the budgeting process that may also have influence over agency budgets. At every step, agencies must comply with policies governing this type of communication. As contained in OMB

M-20-10—Issuance of an Addendum to the National Strategy for the Efficient Use of Real Property, federal agencies cannot secure capital unless appropriated by Congress (OMB 2020a). Moreover, the National Strategy itself notes the executive branch will need the support of its partners in Congress to identify additional flexibilities and resources to further relevant efforts and to recommend to Congress which properties should be disposed, consolidated, collocated, or reconfigured (Executive Office of the President 2015). Suggestions on what some of these could be are detailed in Chapter 6. Thus, federal agencies are invited to think creatively on how budget decision making can be used with strategic purpose to optimize agency mission achievement through coordination of other authorized objectives.

EFFECTIVELY TARGETING COMMUNICATIONS WITH THE PRIVATE SECTOR

Federal agencies may want to consider whether to engage private-sector stakeholders in communications related to infrastructure and real property assets—the agency’s real property capital plan is one way to do this. A helpful first step is deciding what can be communicated. Second, the agency must identify its constituency and its interest in agency mission execution. Third, the agency must determine the allowable parameters of this type of communication. A caution here is that private-sector entities may have different interests and priorities than the public sector. Outreach may cause the private-sector entity to focus on the department or its programs in ways that the agency did not intend.

A federal agency that decides to reach out to the private sector has many options. For example, an agency could reach out to beneficiaries of service delivery programs (e.g., veterans through veterans’ service organizations; nonprofit organizations that obtain ownership of lighthouses). As the committee notes in Chapter 2, OMB Circular A-123 is an excellent source of guidance related to enterprise risk management and internal controls, but like OMB Circular A-11, it does not provide a means to employ impactful facility renewal strategies. A key component of impactful renewal strategies is enhancing agency mission capability and service delivery. Private-sector outreach can produce informative input on the success of service delivery in some circumstances. Coordination with OMB would be critical to ensure that the executive branch department’s communications are consistent with current policy priorities.

Communications with the private sector may be through any number of infrastructure-oriented associations, such as the

• American Society of Civil Engineers,
• American Society of Military Comptrollers,
• Asset Leadership Network,
• Association of Asset Management Professionals,

• Association of Defense Communities,
• Association of Government Accountants,
• Counselors of Real Estate,
• Federal Real Property Association,
• Institute of Asset Management,
• International Facility Management Association,
• National League of Cities,
• Society of American Military Engineers, and
• Urban Land Institute.

Many other organizations may also be interested in the specific mission or service to be accomplished in the facility for which the agency is seeking resources. Federal agencies choosing to reach out proactively may also want to present relevant messages at association meetings or conferences.

The news media provides another opportunity to reach out, although agencies should have a clear understanding of who they are trying to reach and have an associated strategy for achieving the connection. In all cases, this type of engagement must be in compliance with agency policy. For example, if the agency is seeking to reach the public in a given location related to enhancing mission capability or service delivery through a facilities renewal activity, the agency may want to target communications to local media in the target location. In a basic way, release of pending procurement and contract information is one value-adding reason to do so. This approach could also be effective when trying to reach the infrastructure-oriented associations identified above. At the same time, federal agencies need to understand that the media’s independence means agencies could receive criticism by drawing attention to themselves. Examples of media outreach targets include news media, journals, and relevant business-to-business publications.

Last, agencies may also want to consider other means of engaging with the public. GAO’s internal control standards specify that management obtain quality information from external parties, including the public. Initiatives stemming from the Digital Accountability and Transparency Act (DATA) of 2014 and Performance.gov are excellent, preapproved conduits. The committee also believes that agencies should consider developing a means of engaging with the public through established processes such as Federal Register notifications, when appropriate, and public meetings. In 2013, GAO reported on an Army initiative to hold “community listening sessions” as part of an initiative at that time on the selection of installations from which to inactivate 10 Brigade Combat Teams. The Army conducted the listening sessions to give communities surrounding 30 installations an opportunity to provide input to the Army’s force structure reduction decisions. While Army officials described the listening sessions as an atypical part of the stationing process, officials also stated that they believed the

listening sessions were a valuable tool supporting the Army’s overall Brigade Combat Team inactivation decision process and could serve as precedent for future stationing decisions (GAO 2013b). Such initiatives should be detailed in an agency’s real property capital plan to give higher visibility when supporting agency facility renewal strategies.

Agencies should also consider whether a social media presence and campaign or relevant podcasts would be helpful if public engagement is appropriate and, if so, to proceed accordingly. If federal agencies pursue a social media presence, it would be prudent to develop policies and procedures for what to post, who can post, and where to post. Agencies may also need to coordinate with OMB. Additionally, agencies choosing to engage the public directly should evaluate periodically whether the engagement is having a positive effect and, if so, evaluate communication approaches as technology changes. Here, too, however, opening the door to social media presents the opportunity for anyone to publicly address the federal agency, so agencies should ensure that public affairs professionals are involved in decision making.