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Other EPA social media guidance
Note: EPA’s official use of discussion forums is still evolving. We’re collectively learning from the variety of approaches to issues that our various discussion forums address. This guidance will be issued as a standard in the Fall 2010. Your comments and suggestions will be used to keep the processes and best practices current and up-to-date. The Office of Public Affairs (OPA) and the Office of Environmental Information (OEI) will discuss potential changes with the EPA Twitter community before issuing changes.
Note: Remember that your official activities on-line are subject to the ethics regulations as well as other federal and agency laws, policies and regulations. In addition, existing policies and guidance for accessibility, privacy, external site links, cookies and writing style apply to social media tools as well. References to these are included at the end of this document.
Background: What is a Discussion Forum?
A discussion forum, built on a blogging platform, is an on-line site where readers are invited to respond to your formal or semi-formal concepts or questions. It differs from a blog. A blog reader has the expectation of regular posts to which they can respond, the posts on a blog may pose questions, but are just as likely to convey information which the author feels is interesting or relevant. A discussion forum is created expressly to generate discussion or solicit opinions around a specific topic.
Contact: Your content coordinator should contact Kay Morrison in OPA’s Office of Web Communications (OWC) for approval of a discussion forum.
Why use a Discussion Forum?
- A discussion forum is built on the blog platform and therefore provides a mechanism for your target audience to provide their thoughts on the topics you present.
- Because the blog “comments” mechanism is familiar to many people, and because it is fairly simple even for those to whom it is not familiar, the barrier to leaving comments is relatively low.
- Your discussion forum should be set up it to display comments only after you approve them. *EPA policy is that comments are moderated if the tool allows for moderation or if the tool doesn’t have moderation capabilities, then you “moderate” the comments manually after the comments are posted (at the end of the day, every morning, etc. as appropriate).
- A discussion forum can be ongoing, like a blog, or it can be open for responses for a limited time. At the end of the submission period the forum can be closed for discussion, but can continue to be readable as long as necessary.
Steps for Discussion Forums
Please read this entire document BEFORE you begin. This document describes the general process and standards for developing EPA discussion forums:
- Approval
- Create and manage your Discussion Forum
- Promote your content
- Moderate comments
- Metrics
- Close the forum
Approval
Requests for discussion forums should be reviewed and approved by OWC before you begin posting content. Read this entire document before you begin.
Get approval from:
- Your manager; and
- Your content coordinator (see http://www.epa.gov/webgovernance/leadership.html to find your content coordinator); and
- OWC (your content coordinator will get this for you).
Create and manage your Discussion Forum
1. Build in sufficient time for setting up your discussion forum
- OPA will need at least two weeks for approvals, promotional and press materials.
- OEI will need at least two weeks to schedule and build your discussion forum on the blog platform.
- OGC will need two weeks for review and approval of your proposal.
2. Define your strategy (your content coordinator will use the answers to these questions to secure approval from OPA and OGC will use the answers in their review)
- What is the purpose and description of your discussion forum?
- Is your discussion forum related to a specific rulemaking? If so:
- o What rulemaking does it relate to?
- o How is the discussion related to the rulemaking?
- o At what stage of the rulemaking will the discussion forum be used? (pre-proposal, post-proposal)
- What is the goal for your discussion forum?
- How does it serve the agency mission and your program goals?
- Who is your specific audience? Who will you reach out to for participation?
- Will you work with other programs, regions, federal agencies, or other partners to develop content?
- What is your communication strategy?
- Do you have the resources to create the content, promote this project, moderate the responses, and respond to questions and problems presented by your discussion forum?
- Will you participate in the discussion (engaging with responders)?
- What do you propose to name your discussion forum?
- When do you propose to launch it? How long will it be open for discussion? Are there events or dates that your discussion forum should be part of?
NOTE: When asking questions to generate conversation among your community, be sure your questions are open ended to avoid having to file an information collection request (ICR) with OMB under the Paperwork Reduction Act (PRA). For more information about ICRs, check out the Information Collection Request Center.
Responses posted by discussion forum participants can be handled in different ways depending on the purpose of the forum. You should state clearly in the forum (comments policy page, “About” page, or frequently asked questions page) how reader responses will be handled.
For example, if readers’ responses are part of informal information gathering, you would invite readers to “Share your thoughts” and also state that their responses will not be a part of any official decision making process. If there is a docket, then you’ll explain how to access the docket to leave official comments.
EXAMPLE http://blog.epa.gov/cwaactionplan/
If readers’ responses are part of a formal process, you would invite readers to “Comment” and also state that their comments will be a part of any official decision making process. You should also state whether and how comments will become a part of the formal record or docket - for example, will you manually move their comments to a docket? Before using a discussion forum for a formal process that involves submission of comments to a formal record or docket, contact your OGC attorney to discuss potential legal issues.
EXAMPLE http://blog.epa.gov/metalminingblog/
Determine how you’ll deploy the questions or topics. Often all your questions/topics are posted all at once, instead of on a regular, ongoing basis. Consider outreach mechanisms (email, Facebook posts, Greenversations blog post, etc.) that invite your readers regularly to share their thoughts. You might focus on one question or topic at a time, although all the topics are available throughout the period your discussion forum is open.
Be sure to state clearly what you intend to do with the responses your readers leave. Whether you consider their thoughts in your decision making process or engage with your respondents on an on-going basis, state your intentions and follow up on it.
If you plan to close your discussion forum be sure to state clearly the end date, note that the forum will continue to be available to read, and provide contact information if someone has questions about the discussion forum.
3. Write your content
- Create a basic “intro” page that explains the purpose and content of the forum, open and close dates if applicable, and what will be done with responses.
- If you want the intro page to always be the first page your readers see you will need to make sure it has the most recent date (resave it) and is therefore the first page they see.
- Create “About” content explaining some background on the program.
- State that you will read, but not necessarily respond to, all comments posted on the discussion forum.
- Write the topics or questions in plain language.
- Write open-ended, generalized questions, not categorical questions. Comments and answers should not depend on a finite set of answers. Begin questions with phrases like “How would you…” or “Why do you…” so that users are free to share their thoughts however they wish.
- Avoid questions with Yes/No answers, poll or multiple choice questions, or questions like “What kind of a car do you drive” with answers from a fixed set of possibilities. (The purpose is to not accidently get into a PRA/ICR situation. We can certainly ask these questions but not without first getting an ICR from OMB.)
- Separate the topics so that each one can stand alone, and so that a responder can decide to leave comments on any single question, or any series. Don’t attempt to force the responder to answer questions in sequence.
- Make your forum as interesting to your audience as possible; this will encourage participation. Someone not immediately associated with the content should review the questions to make sure the questions or topics are clear and understandable.
- Avoid phrases like “Welcome to ” and “New”
- Comply with ethics and Hatch Act considerations. Remember that you are speaking for the Agency, so you cannot endorse any particular product, service or enterprise and that you cannot engage in partisan political activity. (Links available in References Section)
4. Get approvals for your content
Your content should go through multiple approvals
- Your manager and your office’s communication expert(s)
- Your content coordinator
- Your office’s legal expert (and the OGC Web 2.0 group to be determined)
- OWC
5. Work with OEI to build your forum
Once your initial concept has been approved you can work concurrently with OEI to build your discussion forum on the agency’s blog platform.
- OEI will base it on the EPA blog template. This will give you a professional look, consistent with other EPA blogs and discussion forums, and common set of design elements, plug-ins and structure.
- Use the EPA Comment Policy - http://www.epa.gov/epahome/commentpolicy.html. Work with OEI and OPA to properly incorporate the comment policy into your discussion forum. This process is currently (April 2010) under development. The comment policy is official.
- Check for broken links on any pages copied out of Greenversations.
- You’ll need a banner graphic for the top of your pages.
- Go ahead and put the draft content into the blog (on which your forum is built) - it will help you get comfortable with the tool, you can test the comments process and ask colleagues to look at your pages to ensure that it is readable and conforms to your program’s requirements.
- Keep it private until you’re approved to go live (approval from your manager, OGC, and OWC).
Promote your content
To succeed with your discussion forum you need to let your audience know it is there. Use traditional and new means to get the word out. Reach out repeatedly throughout the open period of your discussion forum. Consider using:
- EPA news release
- EPA home page banner (link to primary discussion forum)
- EPA Twitter (establish and promote your Twitter hashtag)
- Other agency social media platforms such as Facebook and MySpace
- Notify your stakeholders via more conventional methods: email, mail and at meetings/conference calls
- Greenversations blog post to help your launch. Craft an informal blog post that can be posted on Greenversations, Facebook and elsewhere. The post should include the following information:
- Who you are and what you are doing. Be candid that you are experimenting with new ways of gather public input on an EPA rule/program.
- The discussion forum URL and a discussion hashtag for Twitter.
- Consider using the blogging community to help you market your forum. Are there related blogs, to which you might reach out, that would promote your discussions?
- The timing of your launch blog post should be considered. Anecdotally, the Greenversations post for the Clean Water Action plan was done on late Friday afternoon, which enabled that post to stay in the “Greenversations blog latest entry: ” section of the EPA home page until Monday. Surprisingly, Friday and Saturday there were over 1K views each day on the clean water action plan discussion forum, by Monday, it had dropped to 800.
- Post links on your Web page and ask related programs to link to it. EPA’s exit disclaimer needs to be included for non-federal sites.
Moderate comments
Ensure that you have at least one primary moderator and several back up moderators. Talk to people who’ve already managed discussion forums to find out how much time you should expect to spend moderating comments.
- Comments should be moderated throughout the business day. You do not need to moderate comments during off hours and weekends, but comments should be moderated on the next business day after submission. You should have personnel trained to moderate throughout each business day.
- Clearly state your moderation schedule. If you only moderate during business hours state that. Review and moderate comments several times during the day, more often if you are getting a lot of comments. Have a backup moderator, or several, who are familiar with moderating comments and will follow your protocol.
- Not all pages need to accept comments. Comment fields can be turned off on your introductory page, about the project page, etc.
- Comments that fall outside the comment policy should be handled as described below under “Never delete comments.”
- You should respond to belligerent/non-germane comments via e-mail. Send an e-mail to the commenter, explaining why the comment was not published and offer them an opportunity to re-submit their comment in a publish-able form.
- Publish critical comments. Criticism of EPA is out there whether we respond to it or not; disengaging from the public does not diminish criticism of EPA.
- If you get comments in Spanish or another language, you need to have help in translating the comment so you can moderate it accurately. It’s OK to do a quick check using an online translator but don’t rely on this for accurate translations; NEVER craft a reply using text from an online translator.
- Never delete comments!
- Machine spam that isn’t prevented by the platform’s spam filter should be marked spam in the moderation panel. Comments that are clearly spam will (probably) appear repeatedly, be limited in concept or language. You’ll learn to recognize these. They will usually have a link and possibly words related to some type of merchandise or service (possibly unsavory).
- Comments that are not approved because they are belligerent, off topic, offensive or otherwise do not conform to your comments policy should be copied, in their entirety (include the date/time stamp) into a text document or spread sheet. Indicate the reason that comment was not published. That comment can then be marked spam. This way if you need to support your decisions to approve/disapprove any comments you will have a record. You’ll also have a record for FOIA requests.
Metrics
- Use the tools provided by the blog platform to track the overall number of views, and views per post.
- Also keep track of the number of comments over time (use a spread sheet to keep these numbers by date)
- Notice if you see a sudden rise in comments. Try to find out why - did some blogs link to your discussion forum? Was there a story about it in the news? Did this affect the tone or quality of the comments you’re receiving?
Close the forum & thank respondents
- When your discussion forum is closed for comments clearly state that it is no longer active. Thank those who participated.
- Provide links to additional information if there are some. EPA’s exit disclaimer needs to be included for non-federal sites.
- State what is being done with their responses.
- Follow up when action is taken - update the text on the discussion forum, reach out in the manner you did when you launched the forum. Make it clear that you’ve heard what they said.
Other Observations
Keep a running list of “lessons learned” from the concept to completion. Your experiences will be useful to others interested in creating a discussion forum, and you may find them helpful when you’re ready to create another forum.
The Enforcement and Compliance program, in August of 2009, held a three week discussion forum on the Clean Water Enforcement Action Plan. A “table of ideas” document was published to summarize the comments received on their discussion forum, and other outreach efforts, and EPA’s response to them. The affiliations of the commentors to the forum is shown as “public.” The CWA discussion forum received about 150 responses.
Links to EPA Discussion Forums (some might no longer be accepting comments)
http://blog.epa.gov/oswerforum/
http://blog.epa.gov/metalminingblog
http://blog.epa.gov/opengovplan/
http://blog.epa.gov/rulegateway/
http://blog.epa.gov/waterforum/
http://blog.epa.gov/enforcementnationalpriority/
http://blog.epa.gov/cwaactionplan/
References
Ethics:
EPA Policy:
Guidance:
Additional resources: