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”
- Reduce the complexity of documents
- Place discussions of oil spills and impacts in context
- Implement quality control and quality assurance for EISs
- Provide a “Plain English” Oil Spill Effects Summary
- Include Information on Actual Oil Spills and Effects in the EIS
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."
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:
- 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
- Summarizing the Oil Spill Risk Analysis (OSRA) results in one place in the EIS and incorporating by reference the more detailed OSRA report.
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.
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.
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.
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.