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Recommendations for BLM Streamlining Planning & NEPA

A. Focused Analysis: How can the BLM reduce duplicative and disproportionate analyses?
1. Solution #1 – Develop Guidance that Broadly Interprets Plan Conformance to Reduce the Need for Plan Amendments
Provide for a broader interpretation of “plan conformance” to reduce the need for plan amendments. Pursuant to current regulation (43 C.F.R. § 1601.0-5(b)), plan conformance means that an action is either “specifically provided for in the plan” or “if not specifically mentioned, [] clearly consistent with the terms, conditions and decisions of the approved plan or plan amendment.” The term “clearly consistent” with respect to “terms, conditions and decisions of an approved plan or plan amendment” could be broadly interpreted (via written policy) to reduce the need for plan amendments.
2. Solution #2 –Provide Enhanced Staff Training
BLM must provide its staff specific training to strictly follow the current planning regulations and manage third party contractors assisting the agency with their analysis. Analysis should focus on the truly significant impacts and minimize discussion and consideration of nominal effects for the sake of coverage of every conceivable impact. Read more…

Recommendations for BLM Streamlining Planning & NEPA

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