The commenter argues that replacing the term "shall" with "must" or "will" in the FAR text is misguided because "shall" is the standard for creating binding legal obligations. They suggest that "will" is too conditional and "must" is better suited for tangible items, recommending a more nuanced use of "shall," "must," "will," and "may" depending on the specific context of the requirement.

A Contracting Officer argues that the proposed changes to the FAR are inefficient, vague, and create unnecessary complexity by removing explicit text and replacing it with links to external documents. The commenter specifically criticizes the move toward oral acquisition plans, the consolidation of emergency acquisitions, and the lack of clarity regarding agency-specific requirements.