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Branch of Environmental Assessment
(BEA)
National Environmental Policy Act
(NEPA)
Streamlining and Plain English
These
procedures were initially issued by the Associate
Director for Offshore Minerals Management in June 1995 and
November 1997.
Write Environmental Impact
Statements (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.
Decision makers 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:
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Simplifying scenarios by eliminating highly speculative,
detailed assumptions and assumptions that are not needed
to support the level of analysis appropriate for a
programmatic or lease sale EIS |
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Summarizing the Oil Spill Risk Analysis (OSRA)
results in one place in the EIS and incorporating by
reference the more detailed OSRA report. |
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 its 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. The EIS analysts should use more information
from actual spill events. For example, they should 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. |
