Can the plain error mess be cleaned up?

This week the Booker plain error mess got even messier.  The Seventh Circuit in Paladino joined the Second Circuit adopting something of a plain error middle-ground (and the Second Circuit reiterated its Crosby approach in Williams), while the First Circuit in Antonakopoulos joined the Eleventh Circuit in taking a tough line on plain error (and the Eleventh Circuit reiterated its Rodriguez approach in Duncan).   Meanwhile, in an effort to undue the most generous plain error standard, the government has sought en banc review of Hughes in the Fourth Circuit and Ameline in the Ninth Circuit (the Ameline briefs are collected here).

In the midst of these developments, I asked here whether the Supreme Court might try to clean up the plain error mess.  The problem is that, even if SCOTUS were to grant cert. on this issue, it might still be a year or more before we would get a definitive decision.  These realities have me pondering whether Congress or the US Sentencing Commission could, on a quicker timeline and in service to the goal of sentencing uniformity, do something now to harmonize plain error decision-making.  Though I doubt either Congress or the USSC will act in this arena, it is fascinating (and quite challenging) to think through whether and how Congress or the USSC could even try to clean up the plain error mess.