BLM Desk Guide to Cooperating Agency Relationships - National ...

Unfortunately, requests for the BLM to be aCA are not always made in a timely manner.In some instances, the BLM has receivedrequests to be a CA after the development ofan administrative draft of a NEPA document.In these cases, the potential effectivenessof engaging in a CA relationship shouldbe evaluated, and alternative strategiesfor working together and meeting therequirements of NEPA may need to beconsidered.► What factors should go into theBLM’s decision whether or not tobecome a CA?In deciding whether to become a CA, theBLM should consider any BLM decisionsto be made and any BLM actions that areseparate from, but connected to, the leadagency’s proposal. Consideration shouldbe given to the level of BLM expertise withrespect to reasonable alternatives or anysignifi cant environmental, social, or economicimpacts associated with a proposed action.Consideration should also be given to whatresources the BLM has to commit to theprocess and document preparation.• Expanding the scope of a NEPA analysis toconsider connected and cumulative actionsof all CAs into a single document improvesoverall interagency coordination.• Agencies working cooperatively helpthe public to participate effectively andeffi ciently, with fewer meetings to attendand fewer letters to write. Participation ofmultiple agencies in a single NEPA processmay help the public better understand theentire scope of a proposal, rather thanlearning a piece of it now and anotherpiece later.• The BLM may provide suffi cient inputso that the NEPA analysis specifi callyaddresses the action that the agency mustconsider before making its decision. Thishelps to avoid the struggle of adaptinganother agency’s documentation to fi t theBLM’s proposed action.• The BLM may benefi t from a single NEPAanalysis that simultaneously considersactions separate from, but connected to,the lead agency proposal.Section 4. Cooperating Agency Relationships: Frequently Asked Questions► What are the benefits to the BLM ofparticipating as a CA?Participation as a CA in the preparation ofan EIS or EA provides the BLM with manybenefi ts (as described below) and shouldreceive serious consideration.• The BLM may adopt the EIS withoutrecirculating the document when, after anindependent review of the analysis, theagency concludes that its comments andsuggestions have been satisfi ed (40 CFR1506.3(c)).• The BLM, and the lead agency, maysave staff time and dollars through suchcooperation, as compared with eachagency preparing its own document.• The BLM may provide suffi cient input sothat the NEPA analysis document meets allDOI and BLM requirements or standards.► What are BLM’s roles and responsibilitiesas a cooperator? Where/howshould the BLM capture those rolesand responsibilities in writing?As a CA, the BLM should collaborate to thefullest extent possible concerning those issuesrelating to its jurisdiction and special expertise.This may include, but is not limited to, helpingto identify issues to be addressed; arrangingfor the collection and/or assembly of necessaryresource, environmental, social, economic,and institutional data; analyzing data;developing alternatives; evaluating alternativesand estimating the effects of implementingeach alternative; and carrying out any othertask necessary for the development of theenvironmental analysis and documentation.The BLM is strongly encouraged to enter intoan interagency MOU with the lead agency, onethat formally acknowledges their respective37