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Comments on Request For Information regarding Reducing Regulatory Reform issued February 3, 2011 (Federal Register /Vol. 76, No. 23 /Thursday, February 3, 2011 /Notices).

I have reviewed the Request For Information regarding Reducing Regulatory Reform issued February 3, 2011 (Federal Register /Vol. 76, No. 23 /Thursday, February 3, 2011 /Notices). In the Department of Energy‟s (DOE) attempt to meet its obligation to implement Executive Order 13563, „„Improving Regulation and Regulatory Review,‟‟ issued by the President on January 18, 2011, I recommend DOE make a bold move to change their paradigm from traditional NEPA practices and push the envelope by incorporating a proven NEPA compliance methodology already used effectively in a segment of DOE. The methodology is formed around a policy-level Environmental Impact Statement (EIS) and subsequent tiering structure of Records of Decisions (RODs) rather than the traditional use of supplemental EISs, Environmental Assessments (EAs), and Categorical Exclusions (CEs). Broadening the use of this tiering of RODs methodology agencywide would facilitate expedited NEPA compliance and decisionmaking as well as effective policy implementation monitoring.