Contacts with Key External Constituents
February 1, 2011
In Reply Refer To:
1120 (CA-912) P
EMS TRANSMISSION: 2/1/11
Instruction Memorandum No. CA-2011-010
Expires: 09/30/2012
To: California State Management Team and Public Affairs Officers
From: Acting State Director
Subject: Contacts with Key External Constituents
Although all contacts with external constituents and agencies are important to BLM-California, it is critical that our managers and public affairs officers/specialists (PAO-PAS) take special care regarding their contacts and their staffs' contacts with key constituencies, particularly members of Congress, news media, and organizations such as Congress' General Accountability Office and the Department's Inspector General.
To ensure these important contacts are handled appropriately and in a timely, professional manner, this general guidance is provided. However, every contact is different and unique and managers and PAO-PAS are encouraged to use their professional judgment in the final analysis in representing the Bureau before these important constituents.
Congressional Relations: As we look forward to working with the 112th Congress, I want to acknowledge the positive working relationships you have established with the California delegation and encourage you to continue to build on those relationships. While doing so, it is important that you review existing guidelines regarding Congressional relations. The policy from the Director (see IM-2010-029) outlines several critical issues, including guidelines on pending legislative proposals, Congressional outreach, and prohibited lobbying activities. I encourage you to review this IM, available on our intranet, with your staffs.
It has been my experience that the BLM managers and staff in California use good judgment and adhere to these rules, and we are fortunate to have had very few problems. However, we expect a number of sensitive proposals to be discussed in the coming sessions, and it is important that managers continue to coordinate with the State Office External Affairs staff who work closely with the Washington Office, Division of Legislative Affairs (WO-620).
The BLM-California specific policies regarding Congressional relations follow:
- Congressional relations are an important aspect of each District and Field Managers’ job,
and I encourage you to develop positive working relationships with field staffs of our
members throughout the State.
- While you are encouraged to respond directly to Congressional inquiries sent to your
office about matters within your local jurisdiction, you should consult with your PAO-
PAS regarding these responses. Please ensure that a copy of any written response signed
by a District Manager or Field Manager (along with the member’s incoming letter) is sent
to External Affairs at the State Office.
- In terms of personal contacts or meetings with Congressional staff, you are also
encouraged to handle these when the subject matter is within your jurisdiction. A written
notification summarizing the meeting discussions, outcomes and participants should be
sent to External Affairs. Likewise, the External Affairs staff will work hard to keep you
updated of State and Washington level Congressional contacts.
- For matters involving legislative proposals, it is critical that you coordinate early with
your PAO-PAS and the External Affairs staff. The PAO-PAS and External Affairs staff
will work with you to ensure you stay consistent with the national policies set by the
Washington office in accordance with the Department.
- All information provided to the BLM regarding possible legislation by members is
strictly confidential until released by the members or authorized by the Washington
Office. BLM managers and staff are to defer all public questions regarding the content or
details of the potential legislation to the member involved, unless specifically authorized.
The BLM does not comment or share information on behalf of members. It is the
member's proposal, not the BLM's, and it is up to the member to provide information to
the public.
- BLM is often asked officially to provide bill or map drafting services. Such requests go
to or come from the Washington Office, but the work is often done in the field. Such
information is confidential and is not to be shared with anyone other than the member
involved. If anyone outside the BLM or the member's office asks about the details, those
questions are to be referred to the member.
- BLM-California is not authorized to comment on pending legislation nor offer agency
opinions on its merits. Once introduced, and if a hearing is held, the committee of
jurisdiction will ask the Administration for its official views. At that time, a witness
representing the Administration, as well as the Department and the BLM, will provide
official testimony. That will represent the BLM's official position.
- BLM employees are prohibited by law from lobbying Congress on pending legislation.
BLM managers and PAO-PAS are encouraged to review the Department's ethics policy
regarding lobbying found online at www.doi.gov/ethics/lobby.html and IM 2010-029.
These Congressional guidelines are intended to further enhance BLM-California’s good working relationship with our 55 members of Congress. As always, BLM-California's goal is to be responsive to members of the California delegation while clearly recognizing the different roles of the Field, District and State Offices, the Washington Office, and the Department in this process.
Media Relations: Media coverage of BLM's activities in California is very important in helping to inform the public about management of their public lands and resources. Media reporters play a vital role in gathering information for publication and disseminating it in the public interest. Assisting reporters in getting accurate information and interviewing the most knowledgeable BLM personnel is a key function of our PAO-PAS staff.
All California BLM employees are encouraged to work closely with their PAO-PAS staff to determine the best individual to meet the media's needs and deadlines. All employees are authorized to speak to the media about matters within their direct area of expertise, but they are not required to do so. The decision regarding the most appropriate Bureau spokesperson should be made after close consultation with your District or State Office PAO-PAS, who will coordinate with Washington as appropriate.
Some key guidelines to follow when considering granting a media interview:
- You are representing the BLM officially in a media interview, not yourself; any
comments to the media are therefore official comments, and must be as accurate as
possible and consistent with established BLM policy.
- You are only authorized, when appropriate, to speak about BLM matters; you are never
authorized to speak for other agencies.
- If you receive a media call, always check with your PAO-PAS or your supervisor before
responding to determine if you are the most appropriate spokesperson.
- If you decide to do the interview, your PAO-PAS is available to assist you in preparing
for the interview.
- BLM national policy requires that when a BLM employee speaks to a national media
outlet, that contact must be reported to the BLM's Public Affairs Division in Washington.
These commonsense media guidelines are designed to ensure the media receive the best service possible, so that they can fulfill their obligations to the public they inform. They are also designed to ensure BLM employees in California understand the media's needs for timely, accurate information and the agency's needs for satisfying the public's right to know as much about the BLM management of their public lands and resources as possible.
General Accountability Office (GAO): GAO is an independent, nonpartisan agency that works for Congress. It performs an important "watchdog" role over all Federal agencies, including the BLM. Its particular focus is on the expenditure of public funds. The head of GAO is the Comptroller General of the United States. GAO assists the Congress to ensure the accountability of Federal agencies. It has five basic functions: auditing agency operations, investigating allegations of illegal and improper activities; reporting on how well government programs and policies are meeting their objectives; performing policy analyses and outlining options for congressional consideration; and issuing reports and legal opinions.
BLM-California has been the focus of a number of GAO reviews and reports. During the information-gathering stage, it is critical that BLM personnel be as responsive to GAO investigators as possible. For GAO to perform its important function, it must have the most accurate and timely information possible. It is equally important that GAO contacts be reported to the appropriate BLM manager for coordination across staffs and offices, and perhaps with other States and the Washington Office.
As with the news media, the issue is making sure the appropriate staffs provide the most up-to-date and accurate information. Not only should BLM-California employees notify the BLM management of initial contacts by GAO, but once the appropriate personnel provide the information requested, there should be a follow-up contact to record the information provided, the date, and any other pertinent information for the record. This will be important once GAO finishes its report, which is often, as a courtesy, supplied to the BLM in draft for comment or correction.
Inspector General's Office (IG): Although technically not external, the IG staff that work for the Department of the Interior perform an oversight function that works generally in the same manner as the GAO. Basically, the IG performs audits, investigations, evaluations, inspections, and other reviews of the Department’s programs and operations. The IG identifies risks and vulnerabilities that directly affect, or could impact, DOI’s mission and the responsibilities of its bureaus and entities.
All BLM-California employees are required and encouraged to cooperate fully with IG requests. As with the GAO, however, it is important that the IG gathers data from the most knowledgeable staff and receives the most accurate information in the timeliest manner possible. Contacting management at the time of the initial contact, participating fully with the IG staff, and providing management follow-up notification is important to ensuring proper coordination within and across BLM offices in the State.
Summary: As stated at the onset, these are general guidelines and designed to facilitate, not restrict or limit, Bureau staff involvement with the key external constituents identified. As always, our number one goal is to serve the public, who greatly benefit from the work of these external entities.
If you have any questions about these guidelines, please contact the BLM-California's External Affairs Office at 916-978-4610.
Signed by:
James Wesley Abbott
Acting State Director
Authenticated by:
Richard A. Erickson
Records Management