8.6 NPS Review of Non-NPS NEPA Documents Style and Format for Environmental Review Comments
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NPS environmental review comments on NEPA and related documents should normally be organized in the format described in this section, although the format occasionally will not fit some of the comments that NPS prepares. Individual review instructions are provided in the EQD and OEPC transmittal forms that accompany the document to the NPS reviewing office.
NPS comments being prepared for submission to other Interior bureaus, including responses to requests for technical assistance, should be in a memorandum format. Comments going directly to non-Interior agencies should be in letter form.
Comments prepared for consolidation with those of other Interior bureaus (e.g., comments addressed to OEPC, the REO, or an Interior lead bureau) should be prepared in memorandum format for signature as directed in the EQD transmittal. The subject line of the memorandum should be identical to that of the incoming OEPC memorandum, and it should include the document's ER or DEC number, which should also appear at the upper left corner of the memorandum.
The comments on NEPA and related documents can be logically arranged under four headings: general comments, interrelated review comments, specific comments, and summary comments, unless the review is only a page or two and these headings would produce needless repetition and a stilted appearance. The reviewer should choose a format that conveys NPS or Departmental information and views, and pinpoints changes the recipient should make. The four headings recommended for use in longer NEPA and related reviews are discussed below. The locations of the interrelated review comments and specific NEPA comments may be interchanged as necessary to produce the most coherent review.
A. General comments
This topic heading, if used, should summarize any major NPS concerns with the adequacy and accuracy of the document and should provide comments of a general nature. Any major concerns about the project itself should appear here, concentrating on, but not necessarily limited to, the recommended or selected alternative and its impacts.
This section should include any specific comments that otherwise occur repeatedly throughout the review. Any previous technical assistance, cooperation, reports, or other planning information provided by NPS for the project should be noted.
B. Interrelated review comments
The CEQ regulations (1502.25) require that NEPA analyses be integrated with those for other environmental laws and executive orders (e.g., section 4(f) comments, Endangered Species Act comments, Fish and Wildlife Coordination Act comments). Reviewers should ascertain whether the document under review is intended to fulfill such other requirements. If so, address compliance, as appropriate, with such requirements in separate sections of the review. When NPS serves as lead bureau in consolidating the Department's comments, it is especially important to be aware of these interrelated review requirements so that other Interior bureau review responsibilities are adequately represented in the consolidated departmental comments.
C. Specific NEPA comments
The format of this section containing EIS or EA comments should follow the organization of the document being reviewed. Page and paragraph numbers should be cited to relate comments to the text. Comments should be written in a form designed to help the sponsoring agency in modifying the next draft or the final work.
Assertions of omissions or inadequacies should be specific, not general, and should suggest how to correct the deficiency. Needed additions or deletions should be stated precisely. If you criticize a lead agency's predictive methods, you are obligated to describe the methods you prefer, and to give the reasons why, as the CEQ regulations point out (1503.3).
Comments should address significant overlooked or downplayed impacts of a proposed action. They also should ensure that alternatives that would benefit or have less adverse impact on NPS concerns are included and presented adequately. Comments on the EIS section describing the affected environment are appropriate only if a significantly affected component is not described adequately.
D. Summary comments
If you favor an alternative or project modification that would be beneficial to or have less adverse impact on areas of NPS jurisdiction and expertise, this should be highlighted in the summary section.
Comments and positions on the acceptability of project impacts on areas of NPS jurisdiction or expertise should be included in this section. Comments on the proposal should consider:
Insofar as possible, this section should point out how to make the proposal acceptable with regard to our areas of jurisdiction and expertise. On draft documents, this section should indicate what our position might be unless recommended changes are made.
Summary comments should always state any action relating to the proposal that the Department or NPS has taken, or may take, in accordance with the requirements of various statutes, rules, and regulations for which the department or NPS holds jurisdiction by law. The comments also should note any potential further reviews that NPS may make in considering the issuance of easements or other permits that the proposal would require, and the likely NPS position. If a CEQ referral on a project appears likely, the summary comments should so indicate, and state the particular concern.
This section should close with an offer to meet with the sponsoring agency to discuss comments and concerns. The offer of continued cooperation and assistance is especially important if significant resources are involved or if NPS has complex views and positions that are difficult to describe thoroughly in a letter. Names of NPS personnel who can be of assistance should be listed along with their titles, addresses, and telephone numbers.