Utility Regulators and the “Walk a Mile” Philosophy

How do you approach your relationships with your regulators? Are they best kept at a distance? Do you see them as an unnecessary nuisance? As adversaries? Or as not-so-silent business partners?

Before you reject that last proposition out of hand, think about it. Your regulators have a stake in your business, just like a silent partner. They want to make sure you are satisfying your customers. They have an interest in keeping your company solvent and capable, just not as much as you might like sometimes. And just like you, they prefer to keep public and news media criticism at a minimum.

They also bear the added burden of having to deal with the demands of frequently irascible politicians on a nearly daily basis. It’s a particularly difficult task, given the ever-changing nature of the political landscape, the players and the outsized egos involved.

Even in the best-run businesses, partners can be troublesome, and even aggravating. But prudent managers recognize their regulatory relations as a dialectical process – an ongoing discussion seeking to resolve conflicts between two sometimes contradictory ideas by establishing truths rather than disproving one side’s argument.

Okay, that’s waxing a bit too philosophical, but you get the idea.

So for the purposes of emergency preparedness and disaster management, how should we treat our distant and occasional partners?

Before the Event

• Invite them to have a look around. Find opportunities to show the regulatory folks how your process works and the systems you use.
• Develop relationships. You don’t have to be friends, just friendly. Talk whenever you get the chance. Let them know there’s a real person behind the memos and phone calls.
• Find out what your regulators are most interested in tracking and reviewing. Determine, in advance, the exact metrics they want to see. That way you will be able to design the best logs and record-keeping processes to satisfy their priorities.
• Exercise together. The next time you schedule a drill, ask for regulatory representatives to play a role. Have them send and receive situational messages that you have built into the scenario. Encourage them to be creative and put your processes under pressure, based on their own experiences in past events.

During an Event

• Have every section or department of your emergency team keep really good logs and records during every event. You never know when you are going to need them.
• When a regulator makes a request for information, always be upfront and honest. Provide as much information as you can.
• Don’t use confusing jargon. Speak in plain English. For example, talk about personnel, not crews.
• Provide frequent updates by a knowledgeable representative. Nothing against the regulatory relations folks in most utilities, but during a major event, your regulator is under intense pressure from a multitude of sources and they need specifics that you may not be able to provide. Don’t become the middleman – let them talk with someone who can answer the questions they have. This is hard – giving up a little control.

Post Event

• Summarize your restoration efforts and respond to any inquiries. If you’ve kept good logs and records digitally, using the metrics the regulators want to see, you will be able to respond faster and more completely, which will enhance your credibility.
• We’re not being naïve. Sometimes regulatory partners can make some pretty ridiculous requests, like asking you to assign a crew to each town. But utility restoration is no simple business. Help your regulatory partners understand your business before, during and after emergencies and you’ll minimize the off-the-wall demands.

Before you criticize someone, walk a mile in his shoes. That way, if he gets angry, he’ll be a mile away – and barefoot….