Why I would give Congress a low approval rating

One annoying thing about the doomed project is that it relies so much on the exact text of a Congressional mandate, which is annoying because Congress apparently doesn't have a style guide, or if they do it doesn't match ours.

There are two specific examples. First of all, the word "shall". My office does not use it any more. I don't know exactly when we stopped, but it's bad. It's archaic; you'd never ever hear it in conversation and it has long since fallen out of daily use. It's vague; "shall" probably usually means "must" but sometimes it could mean "can" or "should", and how can the reader tell which? Regulations have to be clear. And this is exactly what they have to be clear on - whether something is or is not required. Occasionally we get subject matter experts using "shall" because they're in the habit of reading or even copy-pasting from 15-year-old material, but we tech writers just correct it and move on. Writing regulations in plain English is often a challenge and is sometimes not worth the trouble, but it's always something to aim for, and avoiding archaic, vague language on important points is a great place to start.

Congress, however, freely uses "shall". At least they did in the mandate on the doomed project. It's hard for me to lay down a definitive, blanket rule in the project about it when Congress is doing the reverse.

Also, there's the phrase "interim final rule". To us, it means nothing. As I've said, the normal process for a project has two publications: a notice of proposed rulemaking followed by a final rule*. Sometimes, for something where we're allowed to or really need to skip the notice phase, the notice is replaced by an interim rule, which is effective immediately but has a period for public comment and will be followed by a final rule for any necessary revisions. "Interim rule" is a defined term in our internal guidance, and is meaningfully distinct from everything else, and just makes sense in layman's terms. However, "interim final rule" is none of the above. It doesn't appear in our handbook or on the fancy laminated poster-sized flowchart of the rulemaking process and it seems intuitively contradictory, at least in my opinion.

But, again, Congress uses that term. I'm not sure what they think it means. It appears in the mandate for the doomed project more than once.

So the doomed project has "IFR" all over the place, and "shall" keeps popping up. Obviously, these are not major problems, but they're my problems, so they're annoying.

* Sometimes there's also a supplemental notice between those two for when things change signicantly before the final rule, and sometimes there's an advance notice before the notice for when our ideas about what we want to do aren't firm enough for a notice. But the notice (or IR) and the final rule are two basic steps that almost every project has.