National Environmental Policy Act and Resource Management Planning

United States Department of the Interior
BUREAU OF LAND MANAGEMENT
Wyoming State Office
P.O. Box 1828
Cheyenne, Wyoming 82009-1828
IN REPLY REFER TO:
1790 (930) P
May 23, 2014
EMS TRANSMISSION: 6/2/2014
Instruction Memorandum No. WY 2014-027
Expires: 9/15/2015
To: District Managers and Deputy State Directors
From: State Director
Subject: Update of Review Procedures for Environmental Documents
Program Areas: National Environmental Policy Act (NEPA) and Resource Management
Planning.
Purpose: This Instruction Memorandum (IM) establishes State Director (SD) goals for the
quality of Environmental Impact Statements (EIS) and other environmental documents prepared
in compliance with NEPA, and describes the process for achieving those goals. The information
and terminology used in this IM is based on the Department of the Interior’s (DOI)
Implementation of the NEPA final rule found at 43 Code of Federal Regulations (CFR) Part 46
effective November 15, 2008.
Policy/Action: District Managers (DM) and Field Managers (FM) have been delegated the
responsibility for the content and quality of all environmental documents prepared under NEPA,
including environmental documents developed to support planning decisions. “EIS” in this IM
refers to all environmental documents released to the public and includes Draft, Final, and
Supplemental EISs and Records of Decision (ROD). “Environmental Assessment” (EA) in this
IM refers to all environmental documents released to the public and includes the EA, Finding of
No Significant Impact (FONSI) and Decision Record (DR). Ancillary documents such as the
“Analysis of the Management Situation” prepared for a Resources Management Plan (RMP),
scoping notices, content analyses of public comments or technical specialists’ reports must meet
the quality goals but are not subject to the preliminary review process, unless requested by the
SD. This guidance applies to all Wyoming EISs and EAs whether prepared by the Bureau of
Land Management (BLM) staff, a third-party contractor, a BLM-paid contractor, or any
combination thereof.

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EIS and EA Quality Goals and Objectives
The BLM environmental documents will present all required components in a clear and concise
manner and plain language. All environmental documents are to present the following
information in a manner that may be easily understood by the public:
1. The proposed action under consideration;
2. The purpose and need for the proposed action;
3. Scoping (internal and external) conducted for the action
4. Alternatives to the proposed action including the “no action” alternative;
A. Alternatives analyzed in detail
B. Alternatives considered but eliminated from detailed analysis
5. The key issues to be addressed;
6. The affected environment relative to the proposed action; potential cumulative effects;
7. Environmental consequences of all the alternatives analyzed in detail, including the no action
alternative;
8. Cumulative effects of all the alternatives analyzed in detail; and
9. The rationale for the decision made by the Authorizing Officer (AO) in the ROD or DR.
All environmental documents – both EISs and EAs – must be issue-driven. In other words,
NEPA documents must clearly define the unresolved conflicts or key issues that may arise if the
proposed action would be implemented. The document must consider alternatives to the
proposed action that would resolve or mitigate the identified key issues. Environmental
documents should present only information that is pertinent to understanding the consequences
of the proposed action and its alternatives if implemented. Information in the document should
be well organized, easy to find and use.
To meet this goal, EIS and EA preparers will meet the following objectives:
• Comply (as appropriate) with the format and content requirements of:
o Council on Environmental Quality NEPA regulations (40 CFR Part 1500-1508)
o DOI NEPA regulations (43 CFR Part 46)
o DOI Departmental Manual 516, Chapter 11
o BLM NEPA Handbook (H-1790-1)
o BLM Land Use Planning Handbook (H-1610-1)
o BLM Planning for Fluid Minerals Handbook (H-1624-1)
• Write the document in plain language, and minimize jargon. Include a glossary of
technical terminology if it will facilitate the public’s understanding of the affected
environment and environmental consequences. Always keep in mind it is the public
who must understand our analyses and decisions.

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• Present alternatives, resources, issues, and analyses in the document at the level of detail
appropriate to the topic.
• Strive to simplify rather than complicate issues and discussions.
• Refer to or summarize easily available material rather than reproducing it verbatim in
the document.
• Use finding aids such as indexing to improve the use of the document.
• Employ publishing techniques such as text topic boxes, outline and bullet formats, dual
columns, table and graph design, maps, etc., to make the document easier to read.
State Office Quality Control Procedures1
The AO for all non-RMP related EISs is the DM and EAs is the FM unless otherwise delegated
(i.e., leasing EAs). The AO for all RMP related EISs and EAs is the SD. The AO is the
individual with delegated authority per the BLM Manual 1203 Supplement dated May 2010.
Upon initiation of the NEPA process for EISs or RMP related EAs, the Project Manager will
contact the Branch Chief, Planning, Social and Cultural Resources (WY933) to identify the State
Office (SO) program lead (Attachment 1) and the primary SO point of contact (POC) throughout
the NEPA process. At this time, the Project Manager will identify the anticipated complexity
and controversy concerning the proposal. The SO POC will work with the Project Manager to
guide and assist with the NEPA and planning processes and procedures in coordination with the
Branch Chief, WY933. This may include identifying scarce or unique skills or support needed
by the SO (e.g., air quality, socioeconomics) or other support (Reservoir Management Group
[RMG], National Renewable Engineering Laboratory [NREL], National Operations Center
[NOC]). This may also include identifying key components that should be incorporated into the
NEPA analysis (e.g., regional mitigation, adaptive management).
The Project Manager will coordinate with the SO POC to develop a range of alternatives and
ensure the SO is kept apprised of document development including schedules and key issues.
The SO POC is responsible for ensuring coordination between the Project Manager and
appropriate SO staff during document development including the range of alternatives.
Additionally, the SO POC will be responsible for communicating routinely with the Branch
Chief, WY933 on potential issues and schedules.
Throughout the NEPA process, Resource Specialists are encouraged to informally coordinate
with their SO program staff counterparts if they have program specific questions.
1 The remainder of this policy statement applies only to SO review procedures. District_or_Field_Offices may elect to
enact additional policy associated with review and/or communication procedures.

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It is also anticipated that Resource Specialists will share, discuss, and review resource sections of
the EIS on an informal basis with SO program leads, in order to expedite formal SO review.
This coordination will be done in conformance with District Office (DO) communication
protocols.
The SO may provide assistance throughout the process including:
? Working with the Project Manager early in the process to refine the proposed action,
develop the purpose and need for the action, identify preliminary issues and develop
alternatives, identify potential cooperating agencies;
? Providing guidance on how to address complex issues (e.g., Greater Sage-Grouse and
climate change);
? Providing input on developing responses to public comments.
Reviewing preliminary EISs
All EISs and other environmental documents where the SD is the AO will be reviewed by SO
program staff. Any other environmental document may be reviewed by SO program staff, at a
DM’s request. SO program staff includes:
? The appropriate SO POC;

? Program staff in WY920 and WY930; and

? The Public Room for printing related activities;

? The SO Cartographic Specialist.

The Project Manager must coordinate with the SO POC who will in turn coordinate with the
Branch Chief, WY933 to schedule the reviews. These reviews must have the following
characteristics:
? A comprehensive review conducted by program leads on the attached list.
? The SO review will take a minimum of 3 weeks, unless otherwise established with the
Deputy State Director (DSD) for WY930. An AO may request of the DSD 930 a review
period of less than 3 weeks but no shorter than 5 business days. All requests for review
periods of less than 3 weeks must be approved by the DSD.
? Documents submitted for review will be NEPA compliant and complete, as documented
through the NEPA Review Completeness Checklist (Attachments 2 and 3) for EISs and
RODs. Generally, the SO will not accept for review preliminary EISs that are sent in
portions, sections, or individual chapters. The SO will not accept incomplete or versions
of an EIS for review.
? Documents submitted for SO review will utilize page and line numbering.

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? Prior to circulating a preliminary document to the SO for review, the Project Manager
must coordinate with the SO POC to establish the nature and number of the review
documents. Preliminary EISs may be included as part of the administrative record,
therefore, there must be a finite and tangible document.
? The SO POC will provide comments to the Project Manager on an electronic comment
form (Attachment 4) or using a “track changes” document. The Project Manager will
keep a printed copy of the comments submitted in its administrative record.
? The Project Manager must describe how SO comments, suggested edits or
recommendations made are incorporated into the NEPA document to be sent for
publication. AOs will consider all SO comments and provide acceptable rationale for any
comments not incorporated. The DSD of WY920 or WY930, with the AO, will mediate
any disagreements. If issues cannot be resolved with the DSDs, they will be elevated to
the SD. A copy of the SO comments and the AO’s response to comments will be
provided to the SO POC in either electronic or written media at least 2 weeks prior to SD
briefing on the document.
? The SO POC will ensure SO comments to the Project Manager are constructive,
provide suggested edits or corrections and do not include conflicting direction or opinion.
If the SD determines that documents will be submitted to WO for review, the Branch Chief,
WY933 will review and ensure comments have been resolved prior to transmittal to WO.
Reviewing Environmental Assessments (EAs)

Generally, EAs prepared with the FM as the AO will not be subject to a required SO review.

However, all NEPA documents should meet the SD’s quality goals and objectives. When the

AO for decision making associated with an EA is the SD (i.e., planning decisions), a preliminary

EA will be subject to SO review as described above for an EIS.

The AO may request SO review of a preliminary EA at any time; however, the review
procedures and timeframes will be the same as those described for an EIS, including opportunity
to request a shorter review period.
The AO, through the DM, must notify the Branch Chief WY933 when an EA has been prepared
and a decision will be made for a proposed action that generated public interest or is of interest to
the State of Wyoming or local Governments. The SO must be notified prior to concluding a
FONSI and issuing a DR.
Identifying the Preferred Alternative
In accordance with 43 CFR 46.425, the Draft EIS will identify the preferred alternative if one or
more exists unless another law prohibits the expression of a preference.

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Identifying the preferred alternative is not required to be incorporated into the body of the
document, but can be disclosed in the NOA or Dear Reader letter.
Should the AO elect to not identify a preferred alternative in the Draft EIS or associated
publication materials, the SD will be briefed on the rationale. The SD reserves the right to grant
permission to print the Draft EIS without identifying a preferred alternative.
State Director Briefings
The SD will be briefed prior to submission of all NEPA related Federal Register notices to WO.
Federal Register notices are required when initiating a plan amendment or EIS (Notice of
Intent), publishing the Draft and Final EIS (Notice of Availability) and publishing planning
related EAs for public comment (Notice of Availability).
All planning related NEPA documents will be submitted for WO staff review. Prior to the SO
submitting these documents, the SD will also be briefed.
Additionally, the SD will be briefed prior to publishing all RODs and DRs for planning related
EAs.
The SD may request briefings at any other point in the NEPA process.
All briefing materials will be reviewed by District Public Affairs Specialists and transmitted to
the SO Public Affairs Officer prior to scheduling the SD briefing.
Coordinating with Washington Office and Solicitors Office
While developing the NEPA analysis, Project Manager requests for WO or Solicitor Office
input will be coordinated through the Branch Chief WY933 and at the SD’s discretion.
Document Publication
The following are the requirements to prepare a document for printing and for electronic
publishing (Web):
Process for document printing:
Ensure that the Project Manager and if applicable, contractor, is aware of the requirements
for document printing. It is advisable for the Project Manager to coordinate with the
designated point of contact in the Public Room regarding printing related activities to ensure
that the requirements for document printing are part of the contract with the contractor.
? All covers – paper, electronic and CD artwork – must comply with the BLM standard
planning document covers. This includes standard bars, the BLM acronym and BLM
emblem.
? All documents require a publication index number, obtained from designated printing
POC.

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? At least two hard copy samples, mailing labels and quantities to be produced (both paper
and CDs) must accompany the PDF files when they are submitted to designated
printing POC.
? Send document to designated printing POC three weeks in advance of the publication
date to provide time for preparation and printing.
Please note: If the BLM is paying to print the document and CDs (e.g., RMPs), the print job
must be placed on a Government Printing Office contract through the designated printing
POC. If the contractor or proponent is paying to print the document, then they are
responsible for printing costs and providing 17 copies to the SO Printing Specialist
(Superintendent of Documents requires 16 copies and the SO requires one archive copy).
Process for document electronic publishing (Web)
The Project Manager and if applicable, contractor, must also be aware of the different
requirements for electronically publishing the document to either the BLM Wyoming
Website or the ePlanning/eNEPA system. It is advisable for the Project Manager to
coordinate with the State Web Specialist to ensure that the requirements for electronic
publishing are part of the contract with the contractor.
? All documents must comply with the Rehabilitation Act of 1973, Section 508 for both
the BLM Wyoming website and ePlanning/eNEPA.
? It is preferred that documents are divided into files that are no larger than 10 megabytes
in size. This ensures that the documents are easily downloaded by the end user.
? All blank pages must be removed from the documents.
? All maps larger than 8.5 inches by 11 inches must be resized to 8.5 inches by 11 inches.
? All maps should be oriented so that the viewer does not need to rotate the map to view
it.
? If the document is being electronically published to the BLM Wyoming website, send
the document to the web specialist 3 weeks in advance of the publication date to
provide time for preparation and electronic publishing.
Time Frame: This IM is effective on the date of its issuance and will remain in effect until
formally modified or superseded.
Budget Impacts: There will be negligible budget impacts.
Background: Because of its diversity and abundance of natural resources and increased interest
in exploring and developing traditional and renewable energy resources within the State of
Wyoming, the BLM continues to receive a steady stream of applications for use of
BLM-administered lands, minerals and other resources. Unless categorically excluded as
described by the DOI or the BLM policy or both, all proposed actions are subject to NEPA
procedures prior to making a decision on the proposed action.

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While the majority of the environmental documents prepared by the BLM Wyoming are EAs, in
recent years it is not uncommon to have as many as 10 or more EISs in process concurrently for
which the SD is the AO.
Tracking NEPA processes for all EISs and ensuring compliance with the NEPA, DOI Federal
regulations and other Federal statutes is a complex job at all levels of the BLM. Adopting goals
and objectives and providing additional direction on preparing NEPA documents will facilitate
BLM Wyoming’s timely review, processing, and ultimately informed decision making based on
high quality, well-written EISs and EAs.
Manual/Handbook Sections Impacted. BLM Handbook 1790-1
Coordination: This IM was circulated among the staff of WY930, WY920 and WY912.
Contact: If you have any questions please contact Pam Murdock, Planning and Environmental
Coordinator at (307)775-6259 or pmurdock@blm.gov.
Signed by: Authenticated by:
Donald A. Simpson Sherry Dixon
State Director Administrative Assistant
4 Attachments
1 - Wyoming State Office Point of Contact/Program Lead (1 p)
2 - NEPA Review Completeness Checklist (4 pp)
3 - ROD Review Completeness Checklist (1 p)
4 - Comment Form (1 p)
Distribution

Asst. Director (200), Rm. 5644, MIB 1 (w/o atchs.)

FMs 1 (w/atchs.)

CF 1 (w/atchs.)