9629 - Laserfiche WebLink

Home Browse Search

91 F. Collated Responses. The above format should be used when collating comments from other bureaus into a Departmental response. However, if lengthy comments are provided by more than one bureau, the comments by the other bureaus can be presented separately within the Departmental response, as long as there are no inconsistencies or differing positions. Differing positions should be resolved between the bureaus. Unresolved issues between bureaus will be resolved at the REO or OEPC level, as appropriate. The Departmental response should be a unified, single consistent response. 3.7 Style for Comments on Draft and Final EISs. Service comments must be clear, specific, succinct, and based on facts, published literature, and expert opinion. Literature sources should be referenced when possible. A. Presenting a complete, factual analysis is important to convincing the action agency to adopt the Service's recommendations. The tone of the comments should be constructive, objective, and professional. Comments should not contain extraneous information or excessive quotes from the document, have unnecessary descriptions of the proposed action, or give detailed descriptions of the affected environment, or offer unsupported conclusions. Further studies or information should only be requested when necessary for adequate evaluation of the proposed action or alternatives. B. Do not use a question when commenting. Instead, clearly state the problem and the recommended solution. C. If the comments are to be ultimately signed by the Secretary, REO, or another official in DOI, do not refer to the Service in the first person. Never use the word "I." You may use phrases such as "The Service suggests," "the Service has advised the Department," etc. Also, be careful not to preempt the Secretary's future prerogatives. Be clear as to whose position you are referring to. For example, state whether it is a DOI position or a Service position. If you are unsure, assume the latter.