ML20154F247

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Forwards Plain Language Action Plan for USNRC in Response to Vice President Gore Guidance Memo .Designates NRC Deputy Director for Regulatory Effectiveness to Serve as Senior Officer Responsible for Clinton Memo
ML20154F247
Person / Time
Issue date: 09/28/1998
From: Shirley Ann Jackson, The Chairman
NRC COMMISSION (OCM)
To: Cheek A
AFFILIATION NOT ASSIGNED
References
NUDOCS 9810090132
Download: ML20154F247 (11)


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y 9 [ "4 UNifED STATES p \ NUCLEAR ftEGULATORY COMMISSION WASHINGTON, D.C. 2006H001 E E September 28, 1998

%.....# I CHAIRMAN Ms. Annetta Cheek National Partnership for Reinventing Government 75017* Street, NW.

Suite 200 Washington, D.C. 20006

Dear Ms. Cheek:

I have enclosed the Plain Language Action Plan for the U.S. Nuclear Regulatory Commission l (NRC) i . response to Vice President Gore's guidance memorandum of July 28,1998. I am also i designating the NRC Deputy Executive Director for Regulatory Effectiveness to serve es our senior official responsible for implementing President Clinton's Memorandum for the Heads of Executive Departments and Agencies of June 1,1998.

Should you have any questions about NRC's pir.in language plans and activities, please contact Walter E. Oliu at 301-415-7166, e-mail address: weo@ nrc.aov. l Sincerely, Shirley Ann Jackson Enc:vsure: As stated

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on 9810090132 900928 PDR COMMS NRCC CORRESPONDENCE PDR 090004

A Plain Language Action Plan U.S. Nuclear Regulatory Commission l The Nuclear Regulatory Commission (NRC) is committed to improving its communications with the public at large and other stakeholders by directing the NRC staff to use plain, understandable language whenever possible in documents and at public meetings. We have developed the following plan to accomplish the goals of the Presidential Memorandum on Plain Language:

1. Establish an agency internal web site to assist NRC employees in complying with the plain language initiative. As a beginning, the site will contain the following information:

i e President Clinton's Memorandum to Agencies of June 1,1998 e Vice President Gore's Memorandum and implementation Guidance of July 28,1998 e Existing NRC plain language guidance documents and directives

+ "The ABCs of Better Correspondence: An in-House Guide to Help You Create Effective Official Correspondence"

+ " Glossary of Nuclear Terms"

+ "NRC Editorial Style Guide"

+ "NRC Collection of Abbreviations"

+ Management Directive 3.57, " Managing Correspondence"

+ Management Directive 6.3, "The Rulemaking Process"

+ "NRC Regulations Handbook"

+ Course materials from the three-day workshop " Clear Writing" e Links to www.olainlanauaae.aov and other relevant sites 1 Due Date: January 15,1999

2. Through an agencywide network announcement, inform employees about the President's f and Commission's expectations. Use the same mechanism to keep employees informed as the site is updated and expanded.

Due Date: January 15,1999 l

1 5stablish a Plain Language presence on the agency's external web site that would include narrative introducing the concept, President Clinton's and Vice President Gore's guidance to agencies, and a form requesting that NRC stakeholders comment on how well NRC is  !

complying with the letter and spirit of the plain language initiative.

Due Date: January 15,1999 in addition, the NRC has customized the HELP drop-down menu of Corel Wordperfect 8 to include "NRC Abbreviations," the "NRC Editorial Style Guide," and a " Word Usage Guide" to commonly confused terms. Employees can access and use these guides from within the hord 1

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2 peg : documents they're working on. This feature is currently being installed as part of an ongoing software upgrade to all agency desktop computers in headquarters and the regions.

Completion Date: January 31,1999 In addition, NRC has a number of projects under development which are designed to ensure that plain language is sustained over the long term. By way of background;in the spring of 1997, the Commission directed the Executive Council to create a special coordinating committee to propose recommendations to further the Commission's objective of improving public communications with all stakeholders, and particularly with the general public. The resulting plan recommended ways to improve the quality, clarity, and credibility of agency communications, with an emphasis on using plain language to communicate the necessarily technical matters involved in nuclear oversight. It recommended that the NRC identify public concerns earlier, provide clearer oral and written communications, involve the public earlier in NRC activities, respond more effectively to public concerns, and improve public access to information. The recommendations endorsed by the NRC's Executive Council and adopted by the Commission which should support the objectives of the Presidential Memorandum include:

e Adopt a format for both technical reports (broader than that which now exists) and public meetings so that each starts with a clear, plain language executive summary.

  • Expand and enhance the glossary of nuclear expressions now posted on the NRC external web site and include often-used expressions v ith clear definitions in plain language.
  • Distribute the glossary to all NRC employees with guidance to limit use of jargon and encourage use of plain language definitions in writing.
  • Post the expanded glossary on the NRC external web site and encourage members of the public to comment on the clarity of definitions and request the inclusion of additional expressions or explanations for terms considered less than clear.
  • Periodically, have the Commission and senior NRC officials stress to all employees the need to convey our findings and conclusiens not only clearly, but in a carefully balanced way, neither overstating nor minimizing our concerns.

e include in the annual performance appraisal of all appropriate individuals a specific element dealing with both the clarity of their communications (written and oral) and their responsiveness to the public.

We are currently fulfilling the President's mandate to use plain language in all new documents (other than regulations) by October 1,19V 'Ne are developing a strategy to review appropriate documents issued prior to this date by January 1,2002, to ensure they meet similar standards.

We also plan to meet the January 1,1999, deadline for using plain language, to the extent it is practical in view of the technical nature of our regulations, in all proposed and final rulemaking documents published in the Federal Register. Feedback will be requested from the public on

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)' - the clarity of our proposed rules, bcth in the Federal Register, end on our rulemaking page on the NRC extemalweb site.

To sustain change over the long term, and to ensure that our efforts are ongoing, I have appointed the NRC Deputy Executive Director for R3gulatory Effectiveness as the senior official overseeing this important project. He will coordinate his efforts with Anthony Galante, Chief information Officer, and William Beecher, Director of Public Affairs.

,00/2s/98 'TlEi14'i14'FAI 2026320350 NATIONAL PERFORMANCE REM @0b2

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TH E VICE PRESiOENT

,. g g wa s H i tt <; r o n MEMORANDUM To Heads of Executive Departments and Agencies PROMS.The Vice President DATE: July 28, 1998 .

RE:

. Implementing the Presidential Memorandum on Plain Language Here is the guidance w nromised when the President issued the plain language presiden.. memorandum on June 1.

This is a critical initiaca.ve that is important to me. I expect you to trake it happen.

If you need some help getting started, call NPR at 694-0075.

Attaclunent (2)

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. ~How to Comply with the President's Memo on Plain Language This information will help you comply with the President's June 1,1998, memo on plain language in govemment writing. The first section gives instructions to agency heads for designating plain language contacts and developing action plans. The second section gives general guidance and explains some of the terms in the memo. The third section provides specific infortnation for documents related to rulemaking. The last section provides specific information for other types of documents like letters, forms, and instructions.

Plain Language Contacts and Action Plans Whatyou need to do now:

By August 15,1998, each agency head must designate a senior official responsible for implementing the President's memo. This person will serve as a point ofcontact within your agency and represent you on the Plain Language Action Network (PLAN). PLAN will be an interagency committee charged with making plain language standard in all govemment communication. Morley Winograd, Senior

Policy Advisor to the Vice President and Director of the National Partnership for Reinventing Govemrrnt (NPR), will chair PLAN.

11 i By SeptemberAfl998, each agency must design its own plain language action plan, which sets out strategies for:

contmunicating the President's expectations to employees,  ;

. equipping staff with needed tools,  !

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. meeting the deadlines in the memo, and sustaining change over the long term.

Remember the principles of plain language when you develop this plan. Keep it short and clear. Don't spend more time on the plan than you do writing your documents in plain language!

Send names and action plans to Annetta Cheek at the National Partnership for Reinventing Government (75017* St., NW, Suite 200,20006) by the deadlines above. If you have questions, call (202) 694-f 0075.

GeneralInformation

'What does the presidential memo mean by "the public?"

The memo covers all the material.a you write to your external customers. "The public" does not mean just the generalpublic.

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1 How do I write in " plain language"?

If you use the techniques in Writing (1scr-Friendly Documents, a handbook available on the Intemet

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at www.nlainlanguage. gov , you will meet the President's expectations for " plain language. "In general:

- Organize your material to serve the needs of your reader.

- Write sentences in the active voice and use "you" and other pronouns.

- Use common, everyday words in short sentences.

.Use easy-to-read design features like lists, tables, graphics, and " white space."

- Write short sentences and sectiota.

d What are " common, everyday words?

Common, everyday words are words and phrases your average reader is familiar with and likely to prefer over legalistic or bureaucratic terms. For example:

Compare this:

When the process of freeing a vehicle that has been stuck results in ruts or holes, the operator will fill the rut or hole created by such activity before removing the vehicle from the immediate area.

To this:

If you make a hole while freeing a stuck vehicle, you must fill the hole before you drive away.

There is a specific list of everyday words that you should substitute for legalistic or bureaucratic terms on the plainlanguage. gov web page in the reference library.

Doesn't plain language " dumb down" important government communications?

. Won't I ler.e the precision i need to enforce the law?

Using plain language will improve the clarity of your communication. ' Clarity and precision usually go hand in hand. If your reader needs specific technical or legal details, put them in. But think carefully about what's really necessary. Make sure yo'u're not including informationjust because you always include it. )

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. l How do I organize my document to serve the needs of my reader?

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l To serve the needs of your reader:

- Explain how you've organized the document and how to use it. ,

- Use descriptive headings to help your reader find specific information more easily.

- Summarize complicated topics before you describe all the details.

- Place items ofmost interest to your reader at the beginning.

- Start by answering general questions and move on to specific questions later.

- Describe a process in chronological order.

- Include only information your reader really needs.

Must I write everything in questions and answers?

No, but the question-and-answer format is extrenaly useful for organizing your raaterial around your reader's interests. It's a more direct way to speak to your reader, and it helps you sharpen the point

- you want to make. This technique works very well IF your questions reflect the reader's real concems.

i How long should my sentences be?

Your sentences should average l$ - 20 words, and never be longer than 40 words. Cut out words that aren't really necessary. For example:

Compare this:

The Secretary of the Interior may, in specific cases or in specific geographic areas, adopt or make applicable to off-reservation Indian lands all or any part of such laws, ordinances, codes, resolutians, mies or other regulations of the State and political subdivisions in which the land is located as the Secretary shall determine to be in the best interest of the Indian owner or owners in achieving the highest and best use of such property.

To this:

We may apply State or local laws to off-reservation lands. We will do this only ifit will help the Indian owners make the best use of their lands.

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. _ My agency puts out thousands of documents each year. Where do we start?

Use common sense. Start with the documents that reach the most people and create the most confusion.

Is there someone at my agency responsible for plain language?

Your agency will designate a senior official to be responsible for implementing your plain language program. You may also have one or two other contacts in addition to this senior official. We will post all these names on the Plain Language Website (www.plainlanguage. gov).

Where can I get help in rewriting my documents in plain language?

Start with your agency plain language official. The Plain Language Website at  :

www.plainlaneusee.nov offers more detailed guidance, good examples, related reference documents, I links to other plain languag'e sites, and a list of people willing to give you advice and assistance. If you still need help, e-mail a message to info @plainlaneunge.nov .

l Documents Related to Rulemaking What types of rulemaking documents should I write in plain language?

The President's memo directs you to use plain language in all new proposed and final rulemaking documents, including direct final and interim final rules, beginning January 1,1999. You do not have to use plain language in final rules that you published in traditional style before that date, but we strongly recommend that you do. Also use plain language in notices of data availability, technical amendments, Advance Notices of Proposed Rulemaking, and other notices related to rulemaking. You should also improve the clarity of regulatory support documents like background information documents, economic assessments, risk assessments, and other technical support documents.

- What if I'm just revising a portion of an existing rule?

l Use common sense. You should be able to use most of the elements of plain language, even if you're only revising a portion or adding to an existing rule.

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, Do 1.have to redo all our existing rules in plain language?

No, the presidential memo does not require this. But you are supposed to rewrite existing rules as time l and resources permit. Again, start with the rules that impact the most people or are the most confusing.

l How will I know if my rulemaking document is in plain language?

Ask for input from people who use the rule. Do reader testing through surveys, focus groups, or protocol testing. Another option is to include a statement like the following in the preamble of a proposed mie:

Clarity of this regulation.

Executive Order 12866 and the President's memorandum of June 1,1998, require each agency to write all rules in plain language. We invite your comments on how to make this proposed rule easier to understand. For example:

Have we organized the material to suit your needs?

- Are the requirements in the rule clearly stated?

- Does the rule contain technical language orjargon that isn't clear?

- Would a different format (grouping and order of sections, use of headings, paragraphing) make the rule easier to understand?

Would more (but shorter) sections be better?

- Co"Id we improve clarity by adding tables, lists, or diagrams?

What else could we do to make the rule easier to understand?

Other Types of Documents What other types of documents should I write in plain language?

Write in plain language all forms, letters, instructions, and other documents that tell people how to obtain a benefit or comply with a requirement. Some generic examples are:

- An acceptance or rejection letter.

- A request for information you need to process an application or request.

- A violation or enforcement notice.

- A publication that tells how to meet a requirement or obtain a benefit.

Some specific examples are:

- An OSHA publication explaining safety requirements for factories.

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- A Bureau of Land Management publication explaining how to adopt wild horses.

- A Social Security Administration pamphlet explaining how to apply for survivor's benefits.

Must I rewrite old documents in plain language?

Yes, rewrite documents created before October 1,1998. Your agency may need to develop a strategy for doing this work in phases. If your readers tell you that certain materials are already clear, don't redo them, and don't rewrite material you no longer provide to the public.

How will I know if my document is in plain language?

Ask your customers. Do reader testing through surveys, focus groups, or protocol testing. You might also include a statement at the end of your document like this:

Plain LanguageInstructions We try to write clearly. If you can suggest how to improve the clarity ofthese instructions, call or write (appropriate contact).

au could also post notices in offices where you distribute forms or instructions. For example:

Our Commitment to Plain Language We've tried to make all ofourforms, notices, letters, andpamphlets easy to understand. lfyou can suggest how to write our documents more clearly, call or write (appropriate contact).

The Amcrican people expect clear information from their govemment, and the President and the Vice President take this expectation very seriously. Plain language in all of our communication is the very foundation of good service to our customers.

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