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Consultant gives tips for NEPA success

To be effective, comments on a draft decision document must be clear, concise and relevant. They need to stick to facts, be science-based and targeted to specific points in the document.
Carol Ryan Dumas

Capital Press

Published on January 17, 2018 8:31AM

Ranchers attend the University of Idaho Rangeland Livestock Symposium in Twin Falls on Jan. 10, where they learned how to be better involved in the NEPA process.

Carol Ryan Dumas/Capital Press

Ranchers attend the University of Idaho Rangeland Livestock Symposium in Twin Falls on Jan. 10, where they learned how to be better involved in the NEPA process.

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TWIN FALLS, Idaho — All major actions by federal agencies or any projects using federal funding require an analysis under the National Environmental Policy Act. It is a process that can takes years and cause considerable frustration.

But it is also an opportunity for ranchers and others to bring new information, concerns and solutions to the table, Roger Blew, an environmental consultant from Idaho Falls, told ranchers during the University of Idaho Rangeland Livestock Symposium last week.

“You have to understand and simply accept agency folks have to abide by NEPA. Your input needs to help agencies be compliant with NEPA,” he said.

Being knowledgeable about NEPA and the opportunities to participate has become increasingly important for anyone who has an interest in the outcome of a federal decision, he said.

The process starts with a scoping phase, when an agency asks the public to suggest issues and potential impacts of concern. Anyone who has something he’d like the agency to consider needs to bring it up in the scoping phase because he likely won’t be able to bring it up later, he said.

Next comes the public comment phase on a draft decision document, which provides another opportunity to be involved. The goal of this phase is to provide input on whether the agency adequately described the proposed action, considered the full range of reasonable alternatives and adequately analyzed the potential impacts, he said.

“The agency must consider every public comment that is reasonable or factual,” he said.

If the comment isn’t substantive, the agency doesn’t even have to address it or respond to it, he said.

“One of the misperceptions about NEPA public comment is that they’re a vote,” he said.

But mass postcards or emails to an agency are ineffective because they provide no new information and the agency has to sort through them, he said.

“For your comments to be effective, they must be concise, clear and relevant,” he said.

And they have to be based on science and facts, so leave the rhetoric out of it, he said.

One technique he recommends is targeting each comment to a specific page, line, sentence, table or figure in the document. That makes it easy to be clear, concise and relevant.

“The worst comments are a long narrative, which might leave the agency guessing what exactly you’re referring to,” he said.

He also recommends organizing the comments using bullet points or headers to identify and separate each specific topic.

“It makes it easier to read. The easier you can make it for agency personnel the more likely your comments will make a difference,” he said.

Writing effective comments takes time, and he advises ranchers not to procrastinate — the comment period might only be 30 days. They should review the decision document thoroughly and start writing and organizing their comments as soon as possible.

It is also important to be involved in the process from the beginning and get to know agency personnel, he said.



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