How Planning Works

National Park Service (NPS) planners prepare a variety of planning and environmental documents to help guide park management. These documents can range from site-specific impact analyses on facility locations to broader park-wide plans for future use and management of the park. You can learn more about Park Planning throughout the NPS at the PEPC: Planning, Environment & Public Comment webpage. Planning at Golden Gate National Recreation Area (GGNRA) and other NPS sites is guided by Chapter 2 of the NPS Management Policies (2006). Plans are developed to be consistent with the applicable Key Management Documents for GGNRA and other park sites.

Park plans must also be consistent with all other applicable laws, regulations, and policies at the federal, state, and local levels. Two key laws which guide park planning are the National Environmental Policy Act (NEPA) and National Historic Preservation Act (NHPA), which partially dictate the processes and methods by which park plans are developed and their potential impacts and effects are analyzed.

Not Another Acronym!

You might notice a lot of lingo when you start digging in to park planning efforts. What does it all mean? Here are a few of the most common acronyms you’ll run in to:

• CE - Categorical Exclusion. An action that would not, under normal circumstances, have the potential for significant impact on the environment.
• CEQA - California Environmental Quality Act, NEPA’s California counterpart. Comprehensive projects often cross park boundaries, and thus must comply with both NEPA and CEQA.
• DO-12 - The National Park Service Director's Order 12 (DO-12) and its accompanying handbook set forth the policies and procedures by which NPS meets its NEPA requirements. The handbook serves as the "how-to manual" for NPS NEPA planning and compliance.
• EA - Environmental Assessment. A brief NEPA document that is prepared to help determine whether an action’s impact could be significant, or to evaluate an action that may have measurable, but less than significant, environmental impacts.
• EIS -  Environmental Impact Statement. A detailed NEPA document that is prepared when a proposed action or alternatives have the potential for significant impact on the human environment.
• FONSI - A “Finding of no significant impact”. A document which records the decision made based on the analysis in an EA.
• NEPA - National Environmental Policy Act, passed by Congress in 1969.
• NHPA - National Historic Preservation Act, passed by Congress in 1966.
• PEPC - The National Park Service’s website for Planning, Environment & Public Comment.
• Section 106 - The section of the NHPA that includes the review process which determines whether a proposal would harm a historic site and if so, a way to avoid or minimize that harm.

Check out PEPC’s complete glossary of terms to learn more.
 

Opportunities to Make Your Voice Heard

Public comments help identify the range of issues that should be addressed in major planning efforts. Public scrutiny of proposed actions helps to ensure that project actions are consistent with the National Park Service mission, enabling legislation, and other relevant laws and policies.

Each major planning process usually provides numerous opportunities for public involvement, and two formal periods of public comment.

Early Listening and Dialog

GGNRA engages in continuous, ongoing civic engagement outside of the NEPA process in many different ways, such as interpretive and educational programs, hikes and other recreational activities, volunteer events, and through regular interaction with stakeholder groups and community events. Staff use each of these opportunities and their other day-to-day interactions to listen and get feedback from park visitors and other community members. The public is also encouraged to reach out and share feedback outside of the formal planning process by connecting with the GGNRA Community Liaisons or other park staff. This valuable feedback, along with the direction provided in Key Management Documents and other existing plans is used to determine what planning projects the park will undertake.

Pre-Planning and Brainstorming

Often, and particularly for larger or more complex planning efforts, GGNRA will meet with stakeholders, communities, the public, or other interested parties prior to initiating the NEPA process to brainstorm and gather input on a proposed action, the purpose and need for taking action, and other issues. In accordance with the regulatory requirements and guidance issued by the Department of the Interior (DOI) and the Council on Environmental Quality (CEQ), GGNRA strives to complete environmental compliance in a streamlined manner, consistent with Secretarial Order 3355: Streamlining NEPA Reviews and Executive Order 13807, “Establishing Discipline and Accountability in the Environmental Review and Permitting Process for Infrastructure Projects.”

These orders establish requirements to complete NEPA reviews within certain timeframes and page limits which require some changes from the way these reviews have been done in the past, including conducting some public engagement during the pre-planning phases. You can learn more about the DOI, CEQ, and streamlining guidance at the DOI NEPA webpage, and can find the latest information about opportunities to help with pre-planning and brainstorming at the GGNRA Planning News & Events webpage or by signing up for the Park Planning Newsletters.

Project Scoping

Public scoping takes place when a planning effort begins the NEPA process. This part of the process helps determine the range of issues and alternatives to be addressed by project plans. At the time of scoping, the park provides a description of the project proposal, including a statement of the project’s purpose and need, as well as a list of project goals. The public is asked to submit comments, concerns, and suggestions related to these goals. There is no required length for a public scoping comment period, however, the standard NPS practice is a comment period of 30 days.

Public comments made during scoping directly influence the draft plan. Park staff continually review comments as they work to define the scope of what the plan will cover and develop alternatives to address any issues. Overviews of your comments are often a formal part of planning meetings; at times they are even posted at meetings so that public concerns are a constant presence and can be an active part of the discussion. Check out the Scoping Comment Tips below for suggestions on what information to include in your comment.

GGNRA posts information about upcoming scoping meetings at the GGNRA Planning News & Events webpage and also announces them by email in the Park Planning Newsletters.

Scoping Comment Tips

At the time of scoping, the park provides a description of the proposed action, including a statement of the project’s purpose and need and a list of project goals. The public is asked to submit comments, concerns, and suggestions related to these elements. Comments that contribute to developing alternatives that address the purpose and need for the action are also effective at this stage.

The most useful types of scoping comments consider the following:

•  Alternative approaches and ideas for accomplishing project goals

• The range of environmental and socioeconomic issues that need to be
  considered

• Other potential projects that might affect or be affected by this project

• Information that needs to be considered (such as related research) and why

• Information on how you use the park and how a project might affect that use

And answer these types of questions:

• What do you love about the Golden Gate National Recreation Area, and particularly the area where the project would be located?

• What do you do while you are there?

• What would you like to see protected?

• What kind of services or facilities would you like to see offered, improved, or removed?

GGNRA is not required to provide responses to public scoping comments and standard NPS practice is not to do so. Instead, the issues that are raised in public scoping comments are addressed during the process of preparing the EA or Draft EIS, and most issues are addressed to some degree in the text of the EA or Draft EIS itself.

Environmental Impact Analysis

NPS is required by the NPS Organic Act and NEPA to plan and to make informed decisions that help preserve park resources and values. NPS carries out this responsibility by preparing studies to assess the environmental impact of major projects. This analysis is documented in a Categorical Exclusion (CE), Environmental Assessment (EA), or Environmental Impact Statement (EIS). Public participation in the NEPA process is critical to ensure the analysis included in these documents is accurate.

Once an environmental impact analysis document is released, the public has the opportunity to examine sets of proposals (known as “alternatives”) and submit comments. The standard practice for EAs is to allow for a public review period of 30 days, commencing on the day the availability of the EA is announced. Draft EISs must have a public comment period of at least 45 days after publication of the Notice of Availability in the Federal Register, however, the standard practice for NPS is to allow a 60-day comment period. Take a look at our Tips for Commenting on EAs and EISs below for suggestions on what to include in your comments.

Tips for Commenting on Environmental Assessments (EA) and Draft Environmental Impact Statements (EIS)

You have the opportunity to examine and comment on sets of proposals (known as “alternatives”) when an Environmental Assessment or Draft Environmental Impact Statement for a project is released. Ideally, comments assess the adequacy of the document in disclosing and evaluating a project’s effects on the environment. 

These comments are most useful if they are as specific as possible and do the following: 

• Discuss a particular plan element or alternative 

• Identify incomplete or incorrect information 

• Offer reasons why a particular alternative or plan element would or would not work 

• Offer a reasonable, new plan element or completely new alternative that could help accomplish the stated goals 

• Point out discrepancies between legal mandates and proposals 

• Highlight deficiencies in the analysis of environmental consequences 

• Discuss the efficacy of proposed proposed mitigation measures

• Provide information on how you use the park and how particular proposals in the planning document would affect that use 

GGNRA considers all comments received within the designated comment period for any document, and analyzes those comments to determine which are “substantive”. All substantive comments are responded to, and comments that repeat the same basic message will typically be responded to collectively. 

Substantive comments are those that:

• question, with reasonable basis, the accuracy of the information in the NEPA document;

• question, with reasonable basis, the adequacy of the environmental analysis;

• present reasonable alternatives other than those presented in the NEPA document; or

• cause changes or revisions in the proposal.

In other words, substantive comments raise, debate, or question a point of fact or analysis. Comments that merely support or oppose a proposal or that merely agree or disagree with NPS policy are not considered substantive and do not require a formal response. (NPS NEPA Handbook, 2015)

As a formal part of the planning process, NPS staff read and analyze all comments submitted, and written responses to substantive comments are developed to address concerns. Park leadership also reviews and evaluates all responses, making them available along with any changes to the plan or impact analysis when the final plan is released or a decision is made. Comment letters, or a summary of comments received, are often posted on the project planning website.

For both EAs and EISs, the NPS will usually hold a public meeting to present information on the plan and environmental impact analysis, and to solicit comments. These meetings can be conducted in many formats depending on the project, including workshops, open houses, or site walks.

Opportunities to attend a public meeting can be found at the GGNRA Planning News & Events webpage, and chances to comment on NEPA documents for projects in GGNRA can be found on the park’s Planning, Environment & Public Comment (PEPC) website.