Comment from Annetta Cheek, Center for Plain Language

This regulation is not in the spirit of the President’s requirement for transparency and clarity in government operations. It also does not meet the requirements of Executive Orders 12866 and 12988 that regulations be written in plain language that clearly sets forth the legal implications of the regulatory requirements. As written, the regulation is difficult to comply with because the requirements and standards it contains are not clearly written. In the current post-oil-spill environment, it is especially important that instructions to industry be easy to understand and comply with. To meet the requirements of the Executive Orders, you need to rewrite the regulation so that it uses – logical structure active voice pronouns accessible language and other plain language methods We have attached a complete rewrite of the reg. text that meets these criteria and preserves the integrity of the rule. It also meets the standards in the Federal plain language standards found at http://www.plainlanguage.gov/howto/guidelines/reader-friendly.cfm We have also attached a few comments on the preamble text.