NEPA Compliance Reviewing Services
For nearly 35 years, Shipley consultants have been reviewing agency NEPA documents for NEPA compliance and document readability. Our reviews have sometimes been formal written reports. On other occasions we have conveyed our review comments orally (either in person or on a conference phone call). We believe that NEPA should be used as a planning and a facilitation tool. That by doing so, better and more accurate decisions will be made.
Allow Shipley to help
- Document Review
- Policy & Procedure Manuals
- Agency Specific NEPA Process Desktop Manuals
Compliance Reviews over the Years
The following bullets list and explain some of our more interesting review assignments. Where possible, Jeff Stewart can provide written review reports; however, many of our earliest review reports no longer exist in Shipley Group files.
Here are a few of our review assignments:
· Early in 1980, a Shipley consultant got the assignment to review a programmatic Resource Management Plan/EIS from a BLM district in northwestern Utah. It was for the Randolph Planning Unit and focused on grazing in that district. This early review was not efficient, nor very useful to the BLM. At that early date, BLM had no review criteria, and Shipley had not developed any NEPA review criteria either. So the review mainly discussed ways to make the BLM document clearer and more readable. Many Shipley suggestions were not compliance errors, but merely personal preferences about phrasing. Note that the absence of written review standards ensures inefficient, vague review findings.
· In the late 1990’s Defense Logistics Agency (DLA) asked for a review of a lengthy EIS on the storage of unneeded mercury. DLA was assigned the storage responsibility because mercury had ceased to be a widely used mineral; temperature measurements are now taken with digital tools, not with mercury-filled thermometers. No commercial market for mercury is now available, so the DLA is responsible for safe storage in the interim. The interesting feature of the EIS was that the DLA was analyzing nearly 25 action alternatives. The Shipley review stressed the need to shorten the list of analyzed alternatives. Copies of the written review report are no longer available.
· In early 2004, the Shipley office received an electronic copy of a major land management EIS. It dealt with proposed changes to the national grazing regulations for the Bureau of Land Management. A Shipley consultant reviewed the electronic Draft EIS and submitted electronic comments, using the BLM’s recommended software. Concurrently, a Shipley consultant recorded review comments in the Shipley archive of newsletters. The comments appear in Newsletter 32 for April 2004.
· In 2009, a BLM district in New Mexico asked for a compliance review of an EA for field-development of oil and gas resources. An electronic copy of the Shipley review report is available from Sid Allen at the Shipley Group office.