The CP links way less than the plan.
Bremer 15 – Professor of Law at the University of Notre Dame, J.D. from New York University.
Emily S. Bremer, “On the Cost of Private Standards in Public Law,” Kansas Law Review, https://kuscholarworks.ku.edu/bitstream/handle/1808/20310/5-Bremer_FinalPDFSheridan.pdf?sequence=1
The cost analysis of PHMSA’s standards suggests that incorporation by reference’s public access problem is neither as uniform nor as egregious as some have suggested. A majority of the standards were available online for free, independent of Section 24’s requirements. Although this access is almost always read-only, that should be sufficient if the goal is to allow the general public to read standards that have the force of law. That standards developers generally require users to agree to an intellectual property license appears similarly reasonable if the goal is to further public access while still preserving the ability of standards developers to recoup the significant costs of the standards development process. Although the cumulative cost to purchase a full set of the standards seems quite high even when taking into account available free access, it is unlikely that members of the general public will often find a need to purchase a full set. More likely, they will be interested to see one or just a few standards in connection with a particular rulemaking. From this perspective, the average and median costs of PHMSA’s incorporated standards do not seem to be “excessive.” The most expensive standards are the sections of ASME’s Boiler and Pressure Vessel Code. In light of the significant costs of developing and maintaining that code, and its importance outside the pipeline safety context, it is not immediately clear that even its price is unreasonable. What is clear is that Section 24’s approach was too aggressive as applied to most of PHMSA’s incorporated standards.