United States Department of the Interior

23 FEB 1977

SUBJECT: ORGANIZATION AND MANAGEMENT--Review of Environmental Statements required by the National Environmental Policy Act of 1969 (P.L. 91-190)

Reference is made to WRD Memorandums 73. 43, 73.105, 75.165, and 76.105, same subject.

The Director recently received a memorandum (attached) from the Departmentís Office of Environmental Project Review (OEPR) pointing out that in responding to requests for technical assistance, WRD district offices sometimes refer requestors to Geological Survey headquarters or to OEPR. Similar referrals are sometimes made in district office reviews of various kinds of environmental documents.

It is Departmental and Survey policy that only formal Draft and Final Environmental Statements prepared by or approved by a Federal agency pursuant to Section 102(2)(c) of NEPA should be referred to OEPR for coordinated review. When such documents are received by a district office directly from another agency, the district office should notify the other agency that requests for review anywhere in the Department should be addressed to OEPR.

However, reviews of less formal environmental documents, such as project descriptions, environmental assessments, environmental reports, negative declarations, and preliminary draft environmental statements, as well as requests for technical assistance, should be responded to by district offices without referring the requestor to Survey headquarters or OEPR. Reviews of preliminary draft environmental statements should state that the comment do not necessarily represent the views of the Department. Responses to the other kinds of documents should state that the information or comment provided is intended as technical assistance. These provisions appear in DM 516.3. We have also noted that in regard to draft environmental statements on highway and airports that have been properly routed from OEPR through the Director and WRD headquarters to a district office, some district offices state that their review does not represent the official position of the Survey. Such reviews are in fact the official and the only Survey review of hydrologic aspects.

To summarize: (1) only in the case of formal Draft or Final Environmental Impact statements should another agency be referred to the Departmentís OEPR; (2) formal documents referred to Districts for review by this office should not carry any disclaimer; your review is the Geological Surveyís only input on hydrologic aspects of highway and airport projects; and (3) informal documents should be treated as any other information request -- with a direct response limited to WRDís field of competence and a notation that the response is intended as technical assistance, or, in the case of preliminary draft environmental statements, does not represent a policy position of the Geological Survey or the Department of Interior.

If you have a complicated situation that requires a judgement at headquarters level please feel free to call directly to:

Daniel B. Krinsley, Chief
Environmental Impact Analysis Program
FTS: 928-7455

J.S. Cragwall, Jr.
Chief Hydrologist


WRD Distribution: A, FOLS, SL