NEPA Procedures - Streamlining and Plain English
These procedures were initially issued by the Associate Director for Offshore Minerals
Management in June 1995 and November 1997.
Write EISs and other decision documents in “plain English”
The basic tenant of "plain English"--a writing structure that helps people
process information--is consistent with NEPA regulations that say EISs shall be concise,
clear, to the point (40 CFR 1500.2), and in plain language (40 CFR 1502.8). Plain English omits superfluous words, writes in
the positive, and eliminates redundant information. Plain English does not omit
complex information; it does make information easier to understand. Decisionmakers
and stakeholders need information on oil spills and associated risks presented in a clear
and concise manner. Authors and writer-editors should receive training in
"plain English."
Reduce the complexity of documents
If we can reduce the complexity of our documents, then our readers can locate and
concentrate on the information they need for their decision making, and we will get our
message across more effectively. Reducing the complexity of our documents will also
shorten them. If we can shorten our documents, interested parties may read and
understand more of our information/message.
The complexity of EISs can be reduced by:
Writing in plain English will also help reduce the complexity of our documents.
Key elements of plain English include eliminating redundant information and reorganizing
content logically.
Place discussions of oil spills and impacts in context
We should always provide a context when discussing oil spills or their impacts.
Putting discussions into context includes explaining assumptions, explaining why a spill
may or may not occur, and reminding the reader about mitigating factors. For most
EISs, we should use the probability of occurrence of one or more large spills in the
analysis and conclusions rather than the mean number or an assumed number of spills.
Implement quality control and quality assurance for EISs
The quality of the writing and information relative to oil spills within a single EIS
should be consistent. Readers are confronted at times by information that appears,
or actually is, contradictory. Writing in plain English would also improve the
quality and consistency of our EISs. Each Region and the Headquarters Environmental
Division should have their own EIS processing team. The team would be responsible
for the overall document, assuring schedules and consistency. The EIS summary should
be written by a writer-editor or a skilled technical writer and should strictly conform to
the NEPA regulations (40 CFR 1502.2). Adequate time must be provided for analysts to
prepare well-written sections and for the writer-editor and managers to review the
document thoroughly.
Provide a “Plain English” Oil Spill Effects Summary
This improvement relates to how we explain oil spills generically. It would be
helpful to the reader to have one place to go to find a review of the effects of an oil
spill on various resources in the proposed area. The overall summary of the
information on the effects of an oil spill should be no more than two pages. The
summary may be within the EIS or a companion to the EIS. The summary should be
written for the non-technical reader. The author of the summary needs to create a
document that cannot be taken out of context. The summary will allow the reader to
review in one place, in context, the effects of an oil spill on resources within the area
defined by the EIS.
Include Information on Actual Oil Spills and Effects in the EIS
The analyses in the EIS are based on models and assumptions. EIS analysts should
use more information from actual spill events. For example, review accident reports
and other information from a pipeline spill in the Gulf of Mexico, its immediate impacts,
the response to the spill, and any information on the numbers and/or types of resources
impacted.
For more information, contact Judy Wilson.
