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                                                                                                            February 17, 2005

To:             Associate Directors
Regional Directors
Cost Center Directors

From:         James F. Devine
                  Senior Advisor for Science Applications

Subject:      USGS Participation in the NEPA Activities of another Federal Agency: Review of Environmental Impact Statements

The Survey manages its National Environmental Policy Act (NEPA) compliance responsibilities as specified in Chapter 9 of Departmental of Interior Manual (DM), Part 516. These procedures specify that Bureau review of an environmental impact statement (EIS) or environmental assessment (EA) developed by another Federal agency must be coordinated by the Environmental Affairs Program (EAP) with the Department and approved at the USGS Headquarters’ level.

Field participation in the NEPA review process normally is limited to providing the EAP with data and information relevant to assessing the potential impacts of the proposed Federal action. On occasion, staff also may be requested to conduct a supplemental review of an EIS or EA when a scientist has unique or extensive knowledge or expertise that is very relevant to the proposed action. Supervisors are asked to consider these reviews a regular part of their employee’s responsibilities to the public and other Federal agencies. Funding to support the review will not be available from the EAP except in special circumstances.

However, Federal agencies often will directly contact a Survey manager and scientist for data, information, consultation, services, and reviews related to their NEPA activities.  Such cooperation is encouraged and often can lead to new program opportunities. In all circumstances, NEPA review policy, procedures, and signatory requirements prescribed in DM Part 516, Chapter 9 must be followed including notifying the EAP of the receipt of a draft EIS or EA, and plans to participate in the NEPA process of another Federal agency. This required notification will ensure that all appropriate procedures are followed and that staff are afforded an opportunity to contribute to the official Departmental comments. Ultimately, it is the responsibility of the Cost Center Director to ensure that appropriate policies and procedures are followed.

The overarching policy when participating in the NEPA process of another Federal agency is as with all work conducted by the USGS:

The reputation of USGS science for excellence and objectivity is the Survey’s most important asset. Consequently, representatives of the USGS shall not at any time recommend or appear to advocate or prescribe a particular public policy or course of action, verbally or in writing.

USGS comments on an EIS or EA are considered an administrative report and will become part of the public NEPA record under the control of the proponent Federal agency. Chapter 7.6 of DM Part 516 states that “prior to the public availability of another Federal agency’s final EIS (or EA), the Department (and bureaus) shall not independently release to the public its comments on that agency’s draft EIS (or EA).”

Supplemental guidance on the role and responsibilities of Survey employees when participating in the NEPA process of another Federal agency is available at the EAP web site at  Questions and comments about the Survey’s NEPA policies, procedures, and guidelines should be addressed to Lloyd Woosley (, Chief EAP, at (703) 648-5028. Your cooperation is appreciated.