NPS Director's Order 12: Conservation Planning, Environmental Impact Analysis and Decision Making
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White Sands National Monument, NM2.6 Overview of the NEPA Process — Internal Scoping

A. Introduction

Internal scoping is simply the use of NPS staff (at the SSO, regional, park, or National Program Center level) to decide what needs to be analyzed in a NEPA document. It is an interdisciplinary process, and at a minimum it should be used to define issues, alternatives, and data needs. The IDT may also be used to formulate purpose and need; brainstorm any connected, similar, or cumulative actions associated with the proposal; decide on the appropriate level of documentation; put together a public involvement strategy; and decide other features of the overall NEPA process. The elements of internal scoping included by CEQ are listed in the box below.

External scoping, or early public involvement in the NEPA process, is discussed in section 4.8 (B) of this handbook under Public Involvement.

  Internal Scoping:
According to the CEQ elements of scoping (1501.7), you should use internal scoping to
  • eliminate issues that are not important.
  • allocate assignments among park IDT members or other participating agencies.
  • find/read any other NEPA documents related to this one.
  • identify any other permits, surveys, or consultations required by other agencies.
  • create a schedule that allows plenty of time to do NEPA well before a decision on the proposal is required.

B. Minimum requirements

Channel Islands National Park, CAAfter you have defined purpose and need, the potential actions to address purpose and need, and any connected or cumulative actions, and determined what the issues and impact topics are likely to be, the IDT should visit the site (if members are not already familiar with it) and speak with appropriate agencies or other experts to determine whether the potential for a measurable impact, significant impact, or resource conflict exists. You must record evidence of the site visit and agency communication in your project or analysis file on the ESF, or use a similar form or process. It is also important to identify a single point of contact for the IDT, in order to avoid miscommunication with other agencies. You must complete an ESF for any project that may have an impact on the human environment. If your park’s project is described on the list in section 3.3 of this handbook, and there is no potential for environmental impact, you do not need to complete an ESF. A sample ESF appears in appendix 1 of this handbook. It may be tailored for your park’s use, although certain of the criteria (see appendix 1) are mandatory.

The ESF requires familiarity with the site to complete. The ESF, as well as input from agencies and other experts, is used to decide the appropriate level of documentation for the NEPA analysis (section 2.10). If all agree that no potential for measurable impact to the human environment exists, and the requirements of section 3.2 are met, the action can be categorically excluded from further documentation, and you can complete the categorical exclusion form (CEF) (appendix 2) and attach it to the ESF. If an EA or an EIS is the appropriate choice, the ESF is the beginning of the analysis, or statutory compliance, file.

Further Link:

Other Examples of ESF (Get the Adobe Acrobat PDF Reader 5.0 to read the document.)

Intermountain Regional link for more examples

C. Actions already analyzed

The environmental impacts of an action may already have been fully examined in a previous NEPA analysis. If all impact topics have been analyzed in site-specific detail, and there are no changes to the proposal or in impacts to environmental resources from those previously analyzed, then no further environmental analysis is required, and you may prepare a memo to file, rather than an ESF. This memo should be reviewed and approved by the Superintendent or his/her designee, in consultation with the regional environmental coordinator.

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