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June 21, 2013
In Reply Refer To:
1610 (210) P
Instruction Memorandum No. 2013-144
Expires:  09/30/2014
To:                   All Washington Office and Field Office Officials
From:               Director
Subject:           Transitioning from Printing Hard Copies of National Environmental Policy Act and Planning Documents to Providing Documents in Electronic Formats
Program Areas:  National Environmental Policy Act, Land Use Planning, Communications.
Purpose: This Instruction Memorandum (IM) directs Bureau of Land Management (BLM) state, district, and field offices to ensure National Environmental Policy Act (NEPA) and land use planning (LUP) documents are available to the public electronically to the extent practicable, consistent with regulations and records retention requirements, so as to minimize the number of hard copies printed and thereby reduce BLM printing costs.
Policy/Action: All BLM offices shall maximize the use of electronic media as the primary means by which these documents are distributed and made available to the public. During formal review periods, offices should 1) inform the public of the BLM’s intent to reduce overall printing costs; 2) provide reasonable access to electronic and digital format documents through standard distribution methods; and 3) refer the public to a project’s ePlanning or Internet project website (if ePlanning is not yet deployed) in lieu of providing hard copies.
Making Electronic and Digital Copies Available
For LUP or project-level decision-making processes where the BLM intends to prepare an environmental impact statement (EIS), offices will create and maintain clear, easy to find, and informative web pages that make the documents and supporting information available to the public in an accessible and downloadable format. Digital formats of documents should be structured such that executive summaries, chapters, appendices and maps are created as individual files or folders rather than a single large file.  Where possible, the document files or folders should be in a searchable format. Offices will also routinely post environmental assessments (EAs) of interest to stakeholders on the appropriate state, district or field office websites under the Planning and NEPA web page. Planning and project websites should include access to the relevant supporting documents and files (e.g., maps, tables, and contact information) normally included in printed copies of NEPA and planning documents.
Offices should maximize the use of the ePlanning application for NEPA and planning activities.  The ePlanning application was specifically developed to provide increased accessibility and transparency in BLM planning and NEPA analysis efforts through use of the Internet to support paperless document development; ePlanning further provides an additional means for distributing electronic documents for both peer and public review and comment.
Electronic and digital NEPA and LUP document files should be available in a widely-accessible format (e.g., Planning Application and searchable Portable Document Format (PDF) for CD-ROM and DVD distributions and USB drives or hypertext markup language (HTML) for Internet web pages). Electronic versions of documents must be complete and match the official administrative copy page by page. Offices must meet all legal requirements of Section 508 of the Rehabilitation Act of 1973 (29 U.S.C. 794d). Refer to Department of the Interior policy statements such as Environmental Statement Memorandum (ESM) 13-7, “Publication and Distribution of Department of the Interior National Environmental Policy Act (NEPA) Compliance Documents via Electronic Methods” (Jan. 7, 2013), for more information about the proper electronic formats to be used when making NEPA and LUP documents available (see http://www.doi.gov/pmb/oepc/environmental-memoranda-series.cfm).
Reductions in Hard Copy Printing
The Council on Environmental Quality (CEQ) has recognized that communication technologies can increase effective public involvement, and that these technologies can help manage increased public participation. The CEQ regulations also caution that technologies must be combined with existing non-technological public involvement and communication techniques:  “There was widespread agreement that neither the electronic distribution of information and documents nor other information technology tools can substitute for traditional public involvement mechanisms, such as scoping and hard copy document publication and distribution.”  (NEPA Task Force Report 2003). 

The Department of the Interior’s policy is “to promote electronic distribution of its NEPA compliance documents to benefit the public review and disclosure process.”  The policy also cautions, however, that “paper copies must always be available for and distributed to those requesting them to permit their review within established time frames” (ESM 13-7). For instance, various stakeholders (e.g., individuals without the ability to read or process electronic documents and some tribes) may require paper copies or presentations in other media. In advance of document printing and distribution, offices should consider providing the necessary public outreach through mailings or e-mails requesting that stakeholders and organizations inform the agency if they want a hard copy of a document, just the executive summary, or an electronic or digital media copy. This step will assist the BLM to more accurately ascertain numbers of hard copies to be printed, thereby reducing agency printing costs.

Offices should print a sufficient number of hard copies to meet standard distribution needs of libraries, agencies and document repositories and for use and reference by the public requesting the document. Agency staff should be encouraged to use and refer to electronic format documents, to the extent practicable. 

Offices will also seek opportunities for reducing the size (page count) of hard copies produced. For instance, where there is a demand for hard copies of lengthy EISs, offices may, consistent with 40 CFR 1502.19, opt to print only a summary of the review document to be available in hard copy, along with a CD-ROM of the entire document that includes all maps and appendices. Offices may also choose to print the document and provide copies of the appendices, maps, and supporting documents electronically in a digital format using the various media and technology outlined above.
Hard copies of NEPA documents must be made available under certain circumstances to meet regulatory requirements. The CEQ regulations require that documents be made available in accordance with the Freedom of Information Act (FOIA). Under the Department of the Interior’s FOIA regulations, requestors may, with certain exceptions, specify the format in which they wish to receive information responsive to a request (43 CFR 2.9). In addition, while BLM planning regulations do not require that hard copies of LUP documents be provided to the public, the regulations acknowledge that, upon request, the BLM will make single copies available. The regulations provide, however, that “fees for reproducing requested documents beyond those used as part of the public participation activities and other than single copies of the printed plan amendment or revision may be charged according to the Department of the Interior schedule for Freedom of Information Act requests in 43 CFR part 2” (43 CFR 1610.2(i)).
Offices responsible for printing the documents are in the best position to know the appropriate number of hard copies necessary. Offices should use their discretion and knowledge of the public’s interest in the document and other needs to:  1) determine the appropriate number of printed copies; 2) minimize that number to the extent possible; and 3) reduce the number of printed pages by providing summaries where possible. Offices should consult with a BLM state office or National Operations Center print specialist to determine costs and benefits related to printing large NEPA and planning documents.
Timeframe: Effective immediately.
Budget Impact:  This policy will reduce costs associated with printing NEPA and planning documents and supporting materials. 

Background: Each year the BLM prints numerous hard copies of NEPA and LUP documents, some of which can be thousands of pages in length. The financial costs associated with printing and mailing or shipping to distribute these documents is considerable. For example, some BLM projects have required in excess of $100,000 for printing and distributing documents. The number of copies can exceed the actual demand, and the excess copies are disposed of or recycled.

In recent years, increased availability of and public access to the Internet and other information media and technologies have given stakeholders greater access to the BLM’s decision-making processes, as well as their supporting NEPA analyses, while providing more opportunities for participation and transparency. These media greatly improve the BLM’s decision-making process by expanding public access to documents for formal and informal review. This access reduces costs by reducing the necessity for the BLM to produce hard copies of NEPA and LUP documents. 

The CEQ’s NEPA implementing regulations (at 40 CFR 1506.6) and the BLM’s land use planning regulations (at 43 CFR 1610.2) require that NEPA and LUP documents be made available to the public.  Existing BLM NEPA and LUP guidance has emphasized the traditional method of public outreach during review periods through hard copy document publication and distribution.
The Department of the Interior promotes the electronic distribution of NEPA documents in ESM 13-7, while re-emphasizing the need to make some hard copies available to requesting stakeholders. The ESM also provides guidance on preferred electronic formats, as well as processing and distribution requirements. 
Executive Order 13589 - Promoting Efficient Spending (November 9, 2011) directs Federal agencies to reduce spending and identify opportunities to promote efficient and effective spending, and encourages agencies to “limit the publication and printing of hard copy documents and to presume that information should be provided in an electronic form, whenever practicable, permitted by law, and consistent with applicable records retention requirements.” 
Executive Order 13514 “Federal Leadership in Environmental, Energy, and Economic Performance” (October 5, 2009) directs Federal agencies to integrate environmental considerations into their daily operations and management decisions, and to create innovative ways to reduce greenhouse gas emissions, increase energy efficiency, conserve water, reduce waste, and use environmentally-responsible products and technologies.
The purposes of the E-Government Act of 2002 (44 U.S.C. 101)include promoting the Internet as a means to increase opportunities for public participation in government, promote better decision-making processes, and reduce costs for Federal agencies; the Paperwork Reduction Act of 2000 (44 U.S.C. 3501-3520) contains general provisions to provide information to the public “in an efficient, effective, and economical manner” (3506(d)1(c)) by making effective use of information technology.
Manual/Handbook Sections Affected:  This IM supplements guidance provided in the BLM NEPA Handbook (H-1790-1), specifically section 13.2, and in the Land Use Planning Handbook, chapter 3 (H-1601-1).
Coordination:  The Washington Office, Division of Decision Support, Planning, and NEPA (WO-210) coordinated this guidance with the Directorate of Communications (WO-600), BLM state offices and the Office of the Solicitor.
Contact: Questions regarding this policy may be directed toAndrew Strasfogel, Senior Planning and Environmental Analyst; Division of Decision Support, Planning, and NEPA (WO-210), 202-912-7281.
Signed by:                                                       Authenticated by:
Jamie E. Connell                                              Robert M. Williams
Acting, Principal Deputy Director                       Division of IRM Governance,WO-560

Last updated: 06-26-2013