A. How comments should be focused
Your comments on other agencies' environmental documents
- encourage those agencies
to contribute to the protection, preservation, maintenance, safety,
and enhancement of existing and potential units of the National Park
System; other significant park and recreation values; and historic structures,
archeological resources, and other cultural resources including historic
properties listed on the National Register of Historic Places, unique
cultural resource values including properties listed on the National
Register of Historic Landmarks, and unique natural resource values including
areas listed in the National Registry of Natural Landmarks.
- ensure that the sponsoring
agency recognizes benefits and adverse effects to resources within our
areas of jurisdiction and expertise, and that those effects are presented
in an understandable form to the general public and to decision-makers.
- adequately describe practicable
alternatives that are less damaging to NPS interests and concerns, and
see that these are evaluated realistically and adopted where feasible.
- discuss mitigation measures
to offset unavoidable adverse effects, and propose them as an integral
part of the proposal or alternatives.
B. Early involvement
Your ability to influence the proposals of other agencies
is greatest at the early stages, before they invest in extensive planning
and become committed to a specific alternative means of accomplishing
an objective. For this reason, make every effort to provide input and
technical assistance at the scoping stage or earlier. This will greatly
enhance the credibility of your comments on the draft EIS or a later document.
Consultation should continue up through the completion of the decision
C. Commenting as a cooperating (or joint lead) agency
vs. as a reviewing agency
- Cooperating agency
If the NPS has jurisdiction by law (having permitting or funding authority
over some aspect of the proposal) or special expertise, you should request
that the NPS be made a cooperating agency in preparation and review
of an EIS. The request should be sent to the lead agency (the federal
agency preparing the document), and rights and responsibilities should
be defined between NPS and the lead agency in a memorandum of understanding
or a memorandum of agreement. As a cooperating agency, you may ask for
the right to either prepare or review with veto authority
a section of the document where NPS has particular expertise or interest.
You may also ask or be asked to join in IDT meetings, public involvement
sessions, or other integral pieces of the NEPA process. You should request
permission to become a cooperating agency as early as possible, so that
you can participate fully. You may also share the analysis and document
preparation responsibility by becoming a joint lead with another federal
or state agency (1506.2 (c)). Your park's responsibility may be expanded
to research or write several sections of the document if this is the
If you are affected by or interested in a proposal, but do not have
jurisdiction by law or special expertise, you may still request cooperating
- Reviewing agency
As a reviewing agency, NPS may request changes in the document, additional
information, mitigation measures, analysis of additional alternatives,
and so forth. The degree of response to these requests is largely at
the discretion of the lead agency.
on Departmental Review of Section 4(f) Evaluations
to next section>>
Return to top of page