2. Director’s Order 12 contains information concerning review of other agency proposals

3. 4.12 Evaluating Proposals by Others. The NPS will participate in the early and candid evaluation of proposals by other governments or private entities to avoid adverse environmental impacts to NPS units or other park or recreation resources subject to the provisions of federal law. This is an essential element of effective NPS stewardship. When participating in the environmental impact analysis processes of other entities, the Associate Director for Natural Resources Stewardship and Science will ensure that the NPS’s responsibilities for commenting are clearly defined and that the Service and its personnel work with federal, tribal, state and local governments in identifying and evaluating potential impacts to resources under NPS jurisdiction or within areas of NPS expertise.

4. Examples include, but are not limited to: *Consultation under provisions of Section 4(f) of the Department of Transportation Act; *Evaluation of noise, visual, or other impacts to national park system resources resulting from external activities; *Hydropower relicensing projects through FERC procedures

5. Examples include, but are not limited to: *Impacts of proposed projects on non-NPS areas that have benefited from NPS administered partnership programs (e.g. Land and Water Conservation Fund, Rivers and Trails, National Natural Landmarks, National Register Properties, etc.). *Analysis of cumulative ecosystem or other impacts upon the integrity of NPS-administered resources; and *The impacts of any federal activity on other park resources.

6. And the Big Issue Further, other agencies or project proponents will receive responsive and professional evaluation of the potential impacts of their proposals and whether such impacts may result in the derogation of national park system resources or values, or the derogation of other park and recreation resources subject to the provisions of federal law. The purpose of these efforts will be to assist other agencies in avoiding or successfully mitigating impacts to resources and values of NPS units, or on NPS programs administered under other statutory or administrative authorities.

7. Further Guidance DO 12 Handbook DO 12 Handbook has an entire chapter consisting of 10 pages on review of other documents. Review process relies on and reflects the Department’s review process. NPS comments on external projects are incorporated into Departmental comment letters.

8. Purpose of reviews: Maintain the integrity of the National Park System To espouse the full range of other recreation, natural and cultural resource roles of the NPS Assure that high quality impact analysis performed

9. Tools ER2000ER2000 http://165.83.197.41/ Web based distribution of Documents received by the NPS from the Department for review. Notifies NPS “experts” via e-mail at Regional and other central Offices of pending reviews and requests coordination at the Regional level. Modifications to system should enable park or interest specific notification. Or you can browse

10. The Sharpest Tool Be a cooperating agency via the NEPA process on external projects. Advantages for NPS Influence the process and proposals early and often Incorporate mitigation You can make friends

11. Advantages for others No last minute surprises Early incorporation of mitigation The earlier it is the easier it is to incorporate Realistic risk/cost assessment for other agencies and project proponents

12. Rules for cooperating agencies If it is going to have an impact on NPS resources or you know that it is likely to have an impact be a cooperating agency. If we have jurisdiction by law or expertise we are entitled to such status. Just ask them. Establish an agreement with other agencies.

13. Lessons If you snooze you lose. You have to be willing pay to play. So expect time and personnel costs Early costs are less painful than later costs Facts are more persuasive than rhetoric so get some facts. Get some facts now because “We don’t know anything about our resources” is not convincing. Pound on the things we know and that are “reasonably foreseeable”

14. Nice park, bad region doesn’t work. It just means the other agency gets to pick and choose. Our impacts aren’t as bad as yours because the purpose of our “Organic Act” is good.