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Monitoring and Mitigation

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Row numberNameAffiliationHome TownState or CountryType of CommentCommentAttachment
1DavidConocoPhillips CompanyBartlesvilleOKMonitoring Environmental Mitigation CommitmentsSee Attachedhttp://www.whitehouse.gov/files/ceq/05242010cop_ceq_nepa_comments_0.pdf
2Larissa MarkNational Association of Home BuildersWashingtonDCMonitoring Environmental Mitigation CommitmentsOn behalf of the over 175,000 members of the National Association of Home Builders (NAHB), I respectfully submit these comments in response to the Draft Guidance Clarifying Appropriateness of “Findings of No Significant Impact” and Specifying When There is a Need to Monitor Environmental Mitigation Commitments as published in the Federal Register on February 18, 2010. If you have any questions please contact Susan Asmus at 202-266-8538 or Larissa Mark at 202-266-8157.http://www.whitehouse.gov/files/ceq/05242010NAHB_CommentsOnNEPAMitigationandMonitoringDraftGuidance.doc
3Kate KurganAASHTOWashingtonDC, USAMonitoring Environmental Mitigation CommitmentsPlease find the attached comments. http://www.whitehouse.gov/files/ceq/aashto_final_comments_on_ceq_mitigation_guidance.pdf
4Thomas G. EchiksonAmerican Chemistry Council, American Petroleum Institute, National Association of Manufacturers, National Petrochemical RefinersWashingtonDCMonitoring Environmental Mitigation CommitmentsEnclosedhttp://www.whitehouse.gov/files/ceq/acc-api-nam-npra_comments_on_draft_nepa_guidances_0.pdf
5Sharon CoxAlaska Miners AssociationAnchorage AlaskaMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/alaska_miners_association_inc.pdf
6T. Peter RuaneAmerican Road & Transportation Builders AssociationWashingtonDCMonitoring Environmental Mitigation CommitmentsAttached please find comments from the American Road & Transportation Builders Association regarding the recently proposed guidance on NEPA Mitigation and Monitoring. If you have any questions or problems with the document, please call (202) 289-4434 ext. 207 or email ngoldatein@artba.org. Thank you.http://www.whitehouse.gov/files/ceq/artba_comments_re_nepa_mitigation_and_monitoring.pdf
7Jim ButlerBarrick GoldSalt Lake CityUtahMonitoring Environmental Mitigation CommitmentsSee attached.http://www.whitehouse.gov/files/ceq/barrick_gold_0.doc
8Paul NazarykBHPBillitonWaterflowNew MexicoMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/bhp_billiton.txt
9Joe MontanezCalifornia Department of TransportationSacramentoCaliforniaMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/ca_dot.pdf
10John M. FitzgeraldSociety for Conservation BiologyWashington, D.C.District of ColumbiaMonitoring Environmental Mitigation CommitmentsSCB has submitted a final set of comments on Mitigation and Monitoring by US Mail but as a back-up I am submitting as an attachment,a semi-final version of the M&M comments which will be superceded by the mailed document.http://www.whitehouse.gov/files/ceq/ceq_mm_comnt_5-23-10.doc
11John M. FitzgeraldSociety for Conservation BiologyWashington, D.C.District of ColumbiaMonitoring Environmental Mitigation CommitmentsAttached in final e form below a comment from SCB on Monitoring and Mitigation.http://www.whitehouse.gov/files/ceq/ceq_mm_comnt_5-24-10-1pm.doc
12Steven R. BelindaTheodore Roosevelt Conservation PartnershipBoulderWYMonitoring Environmental Mitigation CommitmentsPlease accept the attached document as comments from the Theodore Roosevelt Conservation Partnership. TRCP fully supports the proposed changes and guidance. The TRCP is a 501c3 non-profit corporation that works to preserve the traditions of hunting and fishing. By building consensus among our individual and organizational partners we work to advance policy solutions on natural resource management issues of common concern. By speaking in a single voice on these key issues the TRCP represents a unique voice in the conservation debate. Together with our conservation partners, the TRCP is the voice for tens of thousands of sportsmen on important policy issue. http://www.whitehouse.gov/files/ceq/ceq_nepa_mitigation_and_monitoring_guidance.pdf
13Ken HamiltonWyFBLaramieWyomingMonitoring Environmental Mitigation CommitmentsWyFB comments are attachedhttp://www.whitehouse.gov/files/ceq/ceq_nepa_mitigation_comments.doc
14Simon M. kihiaWashington state Department of Natural ResourcesOlympiaWashingtonMonitoring Environmental Mitigation CommitmentsAttached is the comment letter submitted by Washington State Department of Natural Resourceshttp://www.whitehouse.gov/files/ceq/comment_letter_to_sutley_of_ceq_5.24.10.pdf
15Ben YamagataCoal Utilization Research CouncilWashingtonD.C.Monitoring Environmental Mitigation CommitmentsSee attached.http://www.whitehouse.gov/files/ceq/curc_comments_on_nepa_gcc_guidance.pdf
16David Urbanprivate citizennanaMonitoring Environmental Mitigation CommitmentsSee attached.http://www.whitehouse.gov/files/ceq/david_urban.txt
17Judy ShoreDenaliAnchorageAlaskaMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/Denali_0.txt
18Bobbie FrankLocal government association CheyenneWyoming Monitoring Environmental Mitigation Commitmentsplease see attachedhttp://www.whitehouse.gov/files/ceq/final_5-10_ceq_nepa_mitigation_comments.doc
19David P. TennyNational Alliance of Forest OwnersWashingtonDCMonitoring Environmental Mitigation CommitmentsPlease see attached letter.http://www.whitehouse.gov/files/ceq/final_ceq_comments_0.pdf
20Dianna NobleTexas Department of TransportationAustinTexasMonitoring Environmental Mitigation CommitmentsSee Attached...http://www.whitehouse.gov/files/ceq/FinalLetterTedBolingCEQ.pdf
21Dan ReganInterstate Natural Gas Association of AmericaWashington District of ColumbiaMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/INGAA_0.pdf
22Robert S. LynchIrrigation and Electric Districts Association of ArizonaPhoenixArizonMonitoring Environmental Mitigation CommitmentsSee attached.http://www.whitehouse.gov/files/ceq/irrigation_and_electrical_district_association_of_arizona.doc
23Nadine PadillaMASEGrantsNMMonitoring Environmental Mitigation CommitmentsPlease see attached letter.http://www.whitehouse.gov/files/ceq/MASE_CEQcomments_052410-1.pdf
24Mary LankfordSublette County, WyomingPinedaleWyomingMonitoring Environmental Mitigation CommitmentsSee Attachedhttp://www.whitehouse.gov/files/ceq/mitigation_and_monitoring.txt
25David Ives DOC/EDAWashington DCMonitoring Environmental Mitigation Commitmentsplease see attached document for the Economic Development Agency's comments on the draft guidance.http://www.whitehouse.gov/files/ceq/monitoring_nepa_guidance_review_eda_051810.doc
26David UrbanNaitonal Mitigation Banking AssociationEvanstonIllinoisMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/national_mitigation_banking_association.txt
27T. Bently WigleyNational Council for Air and Stream Improvement, Inc.ClemsonSouth CarolinaMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/NCASI.pdf
28Dustin Van LiewNational Cattlemen's Beef Association & Public Lands Council Washington DCWashington DC Monitoring Environmental Mitigation CommitmentsNCBA & PLC comments on NEPA monitoring and mitigationhttp://www.whitehouse.gov/files/ceq/ncba-plc_nepa_ghg_mitigation_and_monitoring_comments_0510_-_final.pdf
29Jerry BonannoNuclear Energy InstituteWashington, DCUnited States of AmericaMonitoring Environmental Mitigation CommitmentsThe Nuclear Energy Institute's comments on the CEQ's draft mitigation guidance are attached.http://www.whitehouse.gov/files/ceq/nei_comment_letter_ceq_mitigation_guidance_final.pdf
30Dan KeppenFamily Farm AllianceKlamath FallsOregonMonitoring Environmental Mitigation CommitmentsPlease see attached letter.http://www.whitehouse.gov/files/ceq/nepa_regualtions_may_2010.pdf
31Katie SweeneyNational Mining AssociationWashingtonDistrict of ColumbiaMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/NMA_0.pdf
32Darlene WeaverOregon Department of TransportationSalemOregonMonitoring Environmental Mitigation CommitmentsSee attached PDF (2 pages)http://www.whitehouse.gov/files/ceq/odot_comments_on_mitigation_and_monitoring_draft_ceq_guidance_may_2010.pdf
33Stephanie YoungThe Partnership ProjectWashingtonDistrict of ColumbiaMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/partnership_project.pdf
34Mike SmithQuestar Exploration and Production CompanyCheyenneWyomingMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/Questar.txt
35Craig JohnsonRio TintoSouth JordanUtahMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/rio_tinto_0.txt
36Leslie Garrett AllenSouthern CompanyBirmingham AlabamaMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/southern_company_0.pdf
37Deidre G. DuncanHunton & Williams LLPWashingtonDCMonitoring Environmental Mitigation CommitmentsSee attached letter.http://www.whitehouse.gov/files/ceq/spectra_comments_on_ceq_mitigation_guidance.pdf
38Ray D. HedrickSalt River ProjectPhoenixArisonaMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/SRP_0.pdf
39Stephen MinickTexas Association of BusinessAustinTexasMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/texas_association_of_business.doc
40Bob BarnesThe Nature ConservancyArlingtonVirginiaMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/TNC.doc
41Linda F. BakerUpper Green River AlliancePinedaleWyomingMonitoring Environmental Mitigation CommitmentsSee attached.http://www.whitehouse.gov/files/ceq/upper_green_river_alliance.doc
42Hillary Brickey BrennanUtility Water Act GroupWashington District of ColumbiaMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/utility_water_act_group.pdf
43Holly PropstWestern Business RoundtableLakewoodColoradoMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/western_business_roundtable.pdf
44Susan Jane BrownWestern Environmental Law CenterEugeneOregonMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/western_enviornmental_law_center.pdf
45Mary LankfordSublette County, Wyoming Pinedale Wyoming Monitoring Environmental Mitigation CommitmentsSee Attached to accompany submitted commentshttp://www.whitehouse.gov/files/ceq/white_house_ceq_comments_0.doc
46Cary E. BrusNerd Gas Company LLCCasperWyomingMonitoring Environmental Mitigation CommitmentsMay 24, 2010 White House Council on Environmental Quality NEPA Process Guidance SUBMITTED VIA WEB SITE: http://www.whitehouse.gov/administration/eop/ceq/initiatives/nepa/submit?topic=Monitoring Environmental Mitigation Commitments Subject: Comments on NEPA Mitigation and Monitoring Guidance To Whom It May Concern: Nerd Gas Company, L.L.C. would like to submit comments supporting responsible development of new guidance governing Mitigation and Monitoring actions in the federal process for National Environmental Policy Act (NEPA) projects and actions. Nerd Gas Company, located in Casper, Wyoming, is dedicated to the efficient and responsible exploration and production of hydrocarbons in the northern Rocky Mountain region in order to provide energy and the associated tax base necessary for our communities, state and nation to remain financially strong and independent. We believe that the CEQ proposal to require mitigation is illegal, outside the boundary of law, and we do not support it. Further, the CEQ proposal would do more to slow an already sluggish NEPA process – the worst thing to do in the current economic climate. The Council does have a role to issue guidance; however, such guidance should stick to high level processes, not actions on the ground. Many agencies already use mitigation and monitoring, and those processes can always be improved – the basic process framework should be the only thing addressed by this guidance. While transparency in government is generally a positive thing, this could be taken to an extreme that is not realistically feasible for federal employees to implement. If this guidance were finalized as currently written, it would add significant workload to already overworked federal employees and stall all activity or interactions that the public has with the federal government. Especially in the current economy, government agencies should implement processes to make it easier to do things, not more difficult. The NEPA process is already very expensive, and this guidance would add to that expense. Under the current budget constraints, and considering the need for timeliness in resource management decisions on the ground, we would urge the Council to make the process easier for everyone, not more difficult to manage or work with. We have several more general concerns with the mitigation and monitoring guidance – particularly that the guidance goes far beyond the bounds of what NEPA was created to do. The NEPA itself is a procedural statute – it includes no mandates for action or non-action. Rather, NEPA’s goal is to analyze alternatives and identify potential environmental impacts associated with each alternative. The proposed guidance would significantly increase and expand the parameters of NEPA, and goes beyond the bounds of the legal jurisdiction of that law. If this guidance were to be implemented as written, it would lead to complete gridlock of any projects on federal land across the country. In the current economic climate, it would be irresponsible and unwise for the federal government to add bureaucratic impediments to projects that would create jobs and allow for continued economic development in rural and urban communities. Mitigation and monitoring, by themselves, are necessary and should be dealt with at the appropriate levels within each agency. This guidance, as written, provides an innumerable source of new points for litigation. If the guidance is finalized as currently written, we would be obligated to take up a legal challenge to the expansion of the mitigation and monitoring program beyond what is required in NEPA itself. In Robertson v. Methow Valley Citizens Council, the Supreme Court held that NEPA does not obligate agencies to require mitigation of impacts; rather, several court decisions have held that mitigation measures developed or recommended during the NEPA process need only be developed “to a reasonable degree.” Again, we would encourage the Council to develop basic guidance allowing for mitigation and monitoring plans within the NEPA process, without requiring such plans and creating additional bureaucratic roadblocks to activities on federal lands. Regarding specific goals, as written in the guidance, we have the following reaction: “Proposed mitigation should be considered throughout the NEPA process” Mitigation may be considered, and uses of best management practices or other measures should be strongly suggested. However, the NEPA process was designed to identify potential environmental impacts from activities on public land, not necessarily to pass judgment on any one alternative over another. Therefore, no contingencies should be mandated on the process which would restrict the ability of land managers on the ground to make their most informed decision to approve a FONSI or Decision Record. “mitigation measures…should be identified as binding commitments” This specific goal of the guidance overreaches the Act itself more than any other. Nowhere in NEPA is authority given for agencies to enact binding requirements before approval of activities on federal land. If monitoring after a project has been approved in a manager’s decision record or FONSI, an agency cannot legally retract that decision or change the terms of the decision after the fact. If mitigation is implemented, the federal government does not have the authority to enforce any changes after a decision has been made. “public participation and accountability should be supported through proactive disclosure of, and access to, agency mitigation monitoring reports and documents” Placing additional steps into the NEPA process by adding a public participation component to any mitigation measures defeats the purpose and efficiency of completing an EA versus an EIS. While we admire the goal of having more transparency in government, this would place an undue burden on federal employees. One of the challenges of NEPA as the process works today is that any environmental review and ongoing mitigation measures take an inordinate amount of time to complete – hence you have Members of Congress exempting specific projects in their districts from the NEPA process to bypass the gridlock that already exists. If this guidance is enacted as currently written, the gridlock that we see today would be considered a best-case scenario in a new world where no projects could be completed in any reasonable amount of time. One other issue that concerns us is the use of “outside resources” or experts by agency staff in the development of mitigation measures for any federal project. Any such experts should be true, neutral third parties with impartial and unbiased scientific credentials. If outside resources other than academic or scientific experts are used, consultations should also include adjacent landowners, local governments, and any other impacted entities in the discussion. We would be highly concerned with any one group having more influence or access in the process than another, and would caution the CEQ to ensure that any guidance ensures the use of impartial experts, such as university researchers. Thank you for allowing us to comment on this effort. Pease take these comments into consideration as you finalize the guidance on whether to expand Mitigation and Monitoring efforts in the NEPA process for all federal agencies. Nerd Gas Company looks forward to continuing to provide comment throughout this effort. Sincerely, Nerd Gas Company, L.L.C. By: Cary E. Brushttp://www.whitehouse.gov/files/ceq/white_house_council_eq_-_comments_on_nepa_mitigation_and_monitoring.pdf
47Jim MagagnaWyoming Stock Growers AssociationCheyenneWyomingMonitoring Environmental Mitigation CommitmentsSee Attached.http://www.whitehouse.gov/files/ceq/WSGA_0.doc
48Bruce PenderyWyoming Outdoor CouncilLanderWyomingMonitoring Environmental Mitigation CommitmentsSee attached commenthttp://www.whitehouse.gov/files/ceq/wyoming_outdoor_council.pdf
49Charles AltonConsultantNew Port RicheyFLMonitoring Environmental Mitigation CommitmentsThe guidance needs to be expanded to include a broader array of innovative options for agencies. My specific comments are attached. comments
50Joy Keniston-LongrieSeattle Public UtilitiesSeattleWashingtonMonitoring Environmental Mitigation Commitments"Findings of No Significant Impact": 1. Periodic Re-evaluation: SPU supports periodic re-evaluation of existing & proposed categorical exclusion categories & potential impacts. Establishing required periodic re-evaluation of 'categorical exclusions' such as every 5-10 years seems reasonable and is critical to meet intent of NEPA. 2. Public Involvement: SPU supports the proposed enhancements to public involvement to ensure outcomes of transparency, better utilization of emerging tools and technology (such as the web and other paperless methods) as well as traditional and non-traditional means of communications to ensure under-represented groups (environmental justice) have equal opportunity to have a voice in decision-making process. It is has been our observation, however, through numerous projects and programs with a federal nexus, whether associated with Combined Sewer Overflow program, Superfund, or siting and building water supply and drainage and municipal waste projects, that federal agencies are not practiced in strategies necessary to achieve the above outcomes. This is the expertise of local government, and it would be useful to evolve better collaborative forums to develop useful models that may be learned and practiced broadly. The federal government, CEQ in the lead, should act as convener of such forums perhaps through such national organizations as ASPA, AWWA, Governor’s Conference and Mayor’s Conference. SPU has provided regional/national leadership in developing and implementing a Race/Social Justice Initiative and an Environmental Justice toolkit for public engagement. Please see attachment #1. 3. Document, Monitor & Evaluate Categorical Exclusions: SPU supports the need to have written record of decisions, justification and a system to track, monitor and evaluate. Funding for the resources to monitor and evaluate categorical exclusions should be borne by the applicants, not the general tax payer. Monitoring of environmental mitigation: 1. Mitigation considered throughout NEPA Process: SPU supports strengthening the mitigation analysis throughout the entire NEPA process, and encourages CEQ to further support mitigation analysis into design, materials specifications and construction methodologies, as well as on-going operations and maintenance of a project --- long after the formal NEPA process is completed. 2. Mitigation Decisions Binding & Mitigation Monitoring Program: SPU supports this, and encourages CEQ to develop guidelines so that mitigation reporting, monitoring and performance outcomes are clearly part of the permit conditions, including funding, timelines and penalties for non-compliance. CEQ also needs to support a funding mechanism for this, since currently many federal agencies have the authority, they just do not have the resources to implement in a meaningful way. 3. Public Participation & accountability: SPU supports this and encourages CEQ to develop guidelines and a revenue stream to ensure on-going resources supported by project proponent applicants to ensure this is not one more unfunded federal mandate. Enhanced Public Tools: 1. Web-page & Other Paperless tools - Support. Need to be sure adequate resources available to support. Mechanism to pay for the resources to do this (people, hardware & software). Guidelines needed for timelines information should be on web (i.e. not just during active public involvement process, but how long after project NEPA complete -- during construction? during operation? during monitoring?) 2. Equal access for all - Environmental Justice & Equity -- traditional and non-traditional communication and public involvement. What about people who do not read or for whom English is a second language? Please refer to Attachment #1 for an example of how SPU has tried to address these issues, perhaps this model could be incorporated in the CEQs recommendations to modernize NEPA.


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