USFS is Proposing to Revise Its NEPA Procedures – UPDATE


Issues and Talking Points Included
As we earlier announced the Forest Service is proposing to revise its National Environmental Policy Act (NEPA) procedures with the goal of increasing efficiency of environmental analysis. The Agency’s NEPA procedures are a key component of its overall environmental analysis and decision-making process.

The Agency is seeking public comment on the following four issue areas.

Processes and analysis requirements that can be modified, reduced, or eliminated
Approaches to landscape-scale analysis and decision making
Classes of actions that should be categorically excluded from NEPA’s environmental assessment and environmental impact statement requirements
Ways to expand and enhance coordination of environmental review and authorization decisions
A more detailed description can be viewed in the original Federal Register Notice.

BRC sent out an initial alert on January 12, 2018, and now wants to update our members with suggested issue/comment areas that they may want to expand on. BRC urges its members to add content to the aforementioned themes with site-specific examples or personal stories/illustrations.


Formalize and enhance “pre-scoping” to better inform the NEPA process.
Formally recognize key stakeholder input, e.g. include “community-based” action alternatives/elements that reflect consensus from a majority of engaged stakeholders.
Consider and offer non-Federal solutions to collective management challenges, such as allowing NGOs and non-profit recreation groups to assist in visitor education, trail/facility maintenance, and routine monitoring.
Historic and regularly permitted OHV, MTB, equestrian, running, and other events that occur on roads, trails and areas designated for public use should be approved based on prior or expedited analysis.
Modify the recreation permit process as currently implemented on Forest Service managed lands by implementing a simple, equitable, and predictable procedure for determining recreation permit fees.
Permitted recreation events for non-commercial clubs and organizations should be exempt from cost recovery when said activities occur on designated roads, trails, and areas.
Categorical exclusions (CEs) should be issued for recurring permitted OHV recreation events where the participant count is less than 500. CEs may be issued for periods of up to 5 years where recurring events use designated roads, trails, and areas.
Develop a “Recreation” CE that can be used to authorize on-the-ground management actions related to both motorized and non-motorized recreation facilities.
Comments must be received in writing by February 2, 2018.

Please submit comments via one of the following methods:

Public participation portal (preferred):
Mail: NEPA Services Group, c/o Amy Barker; USDA Forest Service, Geospatial Technology and Applications Center, 2222 West 2300 South, Salt Lake City, UT 84119.
All comments, including names and addresses when provided, are placed in the record and are available for public inspection and copying.

The Federal Register Notice can be viewed at LINK.

Thanks in advance and, as always, if you have any questions or concerns, please contact BRC.

Don Amador Ric Foster
Western States Representative Public Lands Department Manager Coalition Coalition
925-625-6287 208-237-1008 ext. 2
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