Examples of Purpose and Need Statements
Page Last Updated: August 4th, 2010
Purpose and Need Statement for an Internally Generated Action
The purpose of the Proposed Action is to remove excess wild horses from the Twin Peaks HMA in order to manage population levels consistent with the established appropriate management levels (AMLs). The Proposed Action is needed at this time to balance wild horse populations with other resources, including wildlife habitat, wilderness study area values, cultural resources, and soil and vegetation resources. The Proposed Action is needed to reduce the impacts associated with an overpopulation of wild horses to ensure that rangeland and riparian resources are capable of meeting land health standards.
The BLM’s determination of excess wild horses is based on evaluations of resource conditions, and population monitoring in relation to use by wild horses, and other uses, including livestock grazing permits for cattle and sheep. Horse inventory data combined with land health evaluations indicate that current wild horse population levels are exceeding the capacity of the resources within the HMA to sustain wild horse use over the long term. Resource damage is occurring and is likely to continue to occur without timely action.
Purpose and Need Statement for an Externally Generated Action
Icarus Wing Energy America Corporation (Icarus Wing) has submitted a Standard Form (SF) 299 application to the BLM Desert Springs Field Office on September 20, 2009. The application requested a wind energy testing and monitoring right-of-way (ROW) grant for three Meteorological towers (METs) covering approximately 15 acres on public lands near Hotspot, Nevada. Icarus Wing proposes to collect, log, and transmit data on wind speed and wind direction at various predetermined heights above the ground. The wind data collected from the METs is needed to validate the wind resource for the potential future construction of a commercial wind energy park, including placement of wind turbine generators, which would generate renewable energy to be sold to public utilities, local municipalities, and possibly large commercial users under medium and long-term purchase agreements.
Agency Purpose and Need
The purpose of the proposed action is to provide Icarus Wing Energy America Corporation access to a limited number of appropriate locations to gather sufficient wind speed, direction and other meteorological data to ascertain whether there is sufficient and sustained wind energy to develop a renewable wind energy project capable of generating marketable electrical energy for commercial purposes. The need for the proposed action is to respond to a FLPMA right of way request submitted by the proponent to construct and operate three (3) Meteorological Towers (METs) on public lands administered by the BLM Desert Springs Field Office.
Purpose and Need Statement for a Land Use Plan EIS
FLPMA requires that the BLM "develop, maintain, and when appropriate, revise land-use plans" (43 United States Code [U.S.C.] 1712 [a]). The BLM has determined it is necessary to revise existing land-use plans (LUP) and prepare a new RMP for the ______ Field Office based on a number of new issues that have arisen since preparation of the existing plans. In general, the purpose of this RMP is to provide a comprehensive framework for the BLM's management of the public lands within the ______ Planning Area and its allocation of resources pursuant to the multiple-use and sustained yield mandate of FLPMA. In addition, the purpose of this plan revision is as follows:
- To consolidate the existing LUP and its amendments.
- To reevaluate, with public involvement, existing conditions, resources, and uses, and reconsider the mix of resource allocations and management decisions designed to balance uses and the protection of resources pursuant to FLPMA and applicable law.
- To resolve multiple-use conflicts or issues between resource values and resource uses. The resulting _______ RMP will establish consolidated guidance and updated goals, objectives, and management actions for the public lands in the decision area. The RMP will be comprehensive in nature and will address issues that have been identified through agency, interagency, and public scoping efforts.
- To disclose and assess the direct, indirect, and cumulative impacts of the reasonably foreseeable future actions resulting from the management actions in the Draft RMP/EIS and draft alternatives pursuant to the requirements of the National Environmental Policy Act (NEPA), its implementing regulations, and other applicable laws.
A revision to the 19___ RMP is necessary because there have been significant alterations in the _____ Planning Area in light of new information and changed resources, circumstances, and policies that may be relevant to the future management of public lands and allocation of resources under the multiple-use and sustained yield mandate. This determination is further corroborated by a Plan Evaluation, completed in 20____), which concluded that many of the decisions within the 19____ RMP are in need of revision.
There have been numerous changes in the laws, policies, and regulations that direct the management of the resources on public lands managed by the ____ Field Office. There has also been an increase in the amount of new information and resource data that need to be considered to better manage the public lands. Population in and visitation to the region have grown, and population demographics have changed, as have public awareness and use of lands within the _____ Planning Area. Specifically, there may be a need to evaluate management prescriptions and resource allocations to address the increases in recreation and visitor use, including scenic quality and open spaces, as well as the increased interest in oil and gas development. Land use plan decisions may be changed only through the amendment or revision process.
Purpose and Need Statement for an NLCS Land Use Plan EIS
The purpose of this Resource Management Plan (RMP) is to provide for long-term protection and conservation of the lands and resource values reflected in the legislation for the Dominguez-Escalante National Conservation Area and Dominguez Canyon Wilderness by establishing the appropriate uses and management of the NCA, including a comprehensive travel management plan and a wilderness plan. This RMP is needed to provide for management of these resources as a unit rather than as a collection of values, establishing the suite of management actions and activities necessary to conserve and protect for the benefit of future generations the unique and important values of the land, including the geological, cultural, archaeological, paleontological, natural, scientific, recreational, wilderness, wildlife, riparian, historical, educational and scenic resources of the public lands, as well as the water resources of area streams, based on seasonally available flows, that are necessary to support aquatic, riparian and terrestrial species and communities, as identified in the Omnibus Public Lands Management Act of 2009. While these lands have long been recognized for the outstanding resource and recreational values that they contain, their designation as a National Conservation Area creates a need to re-assess historic management and ensure that new management approaches provide a level of protection responsive to the legislation for the resources and resource values included in the NCA.
Purpose and Need Statement for a Grazing Permit Renewal
The purpose of the action is to fully process the term grazing permit (Authorization # 2701077) on the Metropolis Seeding Allotment in accordance with all applicable laws, regulations, and policies and in accordance with Title 43 CFR § 4130.2(a) which states, “Grazing permits or leases shall be issued to qualified applicants to authorize use on the public lands and other lands under the administration of the Bureau of Land Management that are designated as available for livestock grazing through land use plans.” The need for the action is to renew this grazing permit with terms and conditions for grazing use that would meet, or make significant progress towards meeting, the Standards and Guidelines for Rangeland Health, Resource Management Plan, and other pertinent multiple use objectives for the allotment.
The decision to be made is to determine the conditions and limitations necessary to issue a grazing permit that will comply with the BLM’s statutory obligations as outlined in 43 CFR § 4130.2 (a) and multiple use mandate specified in the Federal Land Policy and Management Act of 1976 (FLPMA), and conform to the fundamentals of Rangeland Health (43 CFR § 4180).
Example of a Poorly Written Purpose and Need Statement and Suggested Improvements
This shows an example of a poorly written Purpose and Need statement from an EA for a wild horse gather, discussion of improvements, and the revised statement.
Original PURPOSE: The purpose of this environmental assessment (EA) is to analyze the impacts associated with the Bureau of Land Management’s (BLM) proposal to remove excess and stray wild horses from the Wild Horse HMAs and nearby areas in the summer or fall of 2006. Approximately 125 adult horses would be removed from within the Lost Creek HMA and 155 from within the Stewart Creek HMA. Approximately 76 adults would be removed from the I 80 N area. Approximately 225 adult horses would remain on the range within the two HMAs. This would adjust the population levels within the two HMAs to within the acceptable range associated with the respective AMLs.
Comment: Notice that this is the purpose of the EA—this is incorrect! It should be the purpose of the proposed action not the NEPA document. Also, this purpose statement actually describes the proposed action (approximately 125 adult horses would be removed), which unreasonably narrows the focus of the alternatives to just the proposed action and the No Action.
We can modify the statement to be the purpose of the action, and broaden it to allow for alternative removal techniques, but not so broad as to open up a debate regarding forage allocation among livestock, wild horses, and wildlife.
Revised PURPOSE: The purpose of the Proposed Action is to reduce the number of wild horses to the Appropriate Management Level (AML) as described in the Great Divide Resource Management Plan and to remove horses that have strayed outside designated herd management areas (HMAs).
Original NEED: The proposed action is necessary because monitoring has determined that there are excess wild, free-roaming horses in both the Lost Creek and Stewart Creek herd management areas and there are stray horses nearby that must be removed in accordance with the provisions of the Wild Horse and Burro Act. More detail on those determinations is found in the attached Gather Plan for 2006 for the Rawlins Field Office (Appendix A).
Comment: Notice that the need for the action in this example is clear: Monitoring shows that there are excess horses within two HMAs. However, with most NEPA documentation, you can always make improvements. One improvement would be to again refer to the AML designations in the Great Divide RMP for these two HMAs.
Revised NEED: The proposed action is necessary because monitoring has determined that the number of wild horses has exceeded the AML for the Lost Creek and Stewart Creek herd management areas and there are stray horses nearby that must be removed in accordance with the provisions of the Wild Horse and Burro Act. More detail on those determinations is found in the attached Gather Plan for 2006 for the Rawlins Field Office (Appendix A).