And then he proceeds to discuss the guidelines. I will request that it be put in the record. Mr. DINGELL. Without objection, the document referred to will be included in the record. [The document referred to and a related memorandum of April 16 follow:] Memorandum to: Regional Director, Western Region. SEPTEMBER 11, 1974. From: Acting Associate Director, Park System Management. We have read your memorandum of August 9 in which you presented à clarification of WRO guidelines for public meetings on various park planning projects. You elaborate easy-to-follow procedures for determining how completed draft planning documents will be made available for public review. These procedures should ensure that public involvement in reviewing these draft plans is acquired. Unfortunately, we are somewhat confused about another aspect of the subject of your clarifying remarks—i.e., paragraph 2 of Item 2 in your April 16 memorandum detailing "Guidelines for Preparation and Conduct of Public Meetings." You state that, unless otherwise determined by the Regional Director, public meetings will be held on "all proposed Development Concept Plans (and) all other significant proposals . . . along with the accompanying Environmental Impact Statement or Environmental Assessment." This statement implies that such meetings will be the rule and that failure to hold them will be the exception, although your clarification does reduce this emphasis somewhat. It also implies the desirability of holding public meetings on completed draft plans and their associated environmental documents. Certainly, carry-over projects that have not been subjected to public scrutiny during their development will often require a formal public meeting. That's the best we can do to achieve meaningful public involvement, short of backtracking to an earlier stage of the planning process where public input can be more effective. However, it would seem logical to develop different criteria for public involvement on new-start projects. Here, we have the opportunity to invoke public input early in the planning process. Workshops between the planning team and individual interested parties should be the cornerstone of participatory planning. The workshops should be informal, freewheeling and should consider the full range of potential planning alternatives. More formal and structured public involvement subsequently may be acquired through a public meeting on the environmental assessment in which the various planning alternatives, along with tentative NPS recommendations as to preferred alternatives, are presented. Although much less valuable as a forum for public involvement than the workshop, this public meeting does provide considerable opportunity for the public to influence the planning proposals at a time when they are still readily subject to change. Additional public meetings after the plan's proposals have been selected and the plan drawn up generally are superfluous. Meetings at this stage are often mere political exercises that provide a sounding board for those who, for one reason or another, remain dissatisfied with the plan. If the plan's impacts are significant or highly controversial, the plan will have an associated draft environmental statement on which public interests may provide written comments. The National Park Service must respond to these comments in writing and should amend the plan and draft environmental statement if the comments provide a persuasive case for doing so. In sum, we would anticipate that the number of public meetings on completed draft plans will decrease steadily as more and more are prepared according to our new procedures. Not having a copy of your April 16 memorandum, we don't know whether your original guidelines reflect this thinking. There is no way to substitute formal involvement at the end of the planning process for informal and frank interchanges during the formulation of the plan. Even though we may say at such public meetings that the plan is tentative and that the agency is genuinely receptive to public comments and willing to change its plan accordingly, the agency's commitment to the plan at this stage is substantial and changes are almost certain to be minor. Your August 9 memorandum also indicates that public meetings will be mandatory on all Master Plans and Development Concept Plans. We think that criteria based on potential controversiality and level of impact should be applied to all plans to determine whether a formal public meeting is needed. Wherever possible, this meeting should be held at the environmental assessment stage, rather than on the completed plan. It is safe to assume that all master plans are potentially controversial and entail significant environmental impacts—if not, we probably shouldn't have prepared the plan. However, development concept plans, particularly for small developed areas, could conceivably include only uncontroversial, low-impact, and relatively minor proposals. If informal public involvement on such minor plans at the workshop level has been adequate, we can envision cases where public meetings would be superfluous. We are glad to see that your region is providing guidance in the important area of public involvement in planning and hope that our comments have been useful. RICHARD W. MARKS. U.S. DEPARTMENT OF THE INTERIOR, WESTERN REGION, San Francisco, Calif., April 16, 1974. Memorandum to: Superintendents, Western Region, State Director, Hawaii, Subject: Guidelines for Public Meetings. The National Park Service is committed to a program of expanding the role of public involvement in our decision-making process. To accomplish this we must open up the full range of our policy-making, planning and management process to the public view. Further, we must take the initiative in providing expanded opportunities for citizen involvement. One of the most effective means of doing this is through public meetings on issues affecting individual parks. Attached to this memorandum is a set of guidelines on the preparation and conduct of such meetings, which, if followed, will effectively involve the public in a timely manner that will provide maximum impact for the views expressed. While most of these guidelines are mandatory, it is not our intention that all of them be followed literally in all situations. Local conditions may require some modifications. However, departures from established procedures should be reviewed and approved by the Regional Office. To insure that these public meetings are conducted in a manner that will result in maximum benefit to the Service and that the Regional Office and Washington headquarters be kept informed, I am assigning this responsibility for coordinating this program to the Office of Public Affairs. Larry Quist, who coordinated our Wilderness Program, will be the primary liaison between Region, the Denver Service Center and the field. I cannot stress too much the importance of a complete commitment on the part of each and every one of you to this program. I am aware of the extra work it will involve. But the benefits to you and the Service in terms of increased public understanding and support of our program is immeasurable. To illustrate the importance I attach to this program, I have decided that either the Regional Director or the Deputy Regional Director will personally attend each of these meetings. Thank you again for your cooperation. HOWARD H. CHAPMAN. GUIDELINES FOR PREPARATION AND CONDUCT OF PUBLIC MEETINGS 1. Coordination.-The Office of Public Affairs will have line responsibility for coordinating the scheduling and conduct of all public meetings covered by the subject areas defined below. The Public Meetings Coordinator will be responsible for keeping the Regional Office and Washington headquarters informed, in a timely manner, on the significance and scheduling of such meetings. It will be a joint responsibility of the concerned field area, the Regional Coordinator and the Denver Service Center to meet established deadlines. 2. Subject Areas to be Covered.-Since 1969, it has been Service policy that public meetings be held on Master Plan proposals before the final draft is submitted to Region for review and approval. This policy will be continued. In addition, Superintendents will be required to hold pre-planning sessions on lists of alternatives to obtain public input before the Master Plan Team prepares the preliminary draft. Also, public meetings will be held on all proposed Development Concept Plans, all other significant proposals, such as back country management plans, concessioner developments, major changes in transportation or traffic systems, etc. that have a direct impact on visitors-along with the accompanying Environmental Impact Statement or Environmental Assessment-unless otherwise determined by the Regional Director. 3. Advance Notice. The time, date, location and purpose of public meetings, should be publicized well in advance, through all available media. This should be done a minimum of 30 days prior to the meeting, with a follow-up news release one week in advance. The news release (see attached Exhibit I) should be sent to all media serving the area. The news release should be supplemented by personal letters of invitation to concerned organizations and individuals, including appropriate Government agencies and/or officials at all levels-local, county, State and Federal (see attached Exhibit II). If a legal notice is required, or deemed necessary, it should follow the format of the attached Exhibit III, which also provides instructions for the publication and afidavits required for the record. A legal notice is required when an Environmental Impact Statement or Environmental Assessment is to be presented at the meeting. A legal notice is also recommended, as a supplement to news releases, on other subjects of controversy or great public interest, to insure that notification is made to the public. 4. Advance Availability of Documents.-Steps should be taken to insure that the public has an opportunity to review the subject documents in a variety of convenient locations. To place copies in Park Headquarters and the Regional Office is not adequate. It is recommended that review copies be placed in public libraries, college and university libraries and other appropriate places accessible to the public (see attached Exhibit IV). These locations where documents are available should be listed in the original news release. This, of course, will be in addition to the advance distribution of documents legally required by the National Environmental Policy Act and by Park Service practice to Federal, State and local governmental agencies and recognized conservation organizations, which must be accompanied by a cover memorandum. It is essential that all field areas develop and maintain a comprehensive mailing list for distribution of documents pertaining to public meetings. In addition to government officials and agencies, and recognized conservation organizations, the list should include organizations of other major park users and/or concerned special interest groups who may or may not be in sympathy with our programs and objectives. 5. Meeting Sites.-Meeting sites should be selected with the aim of serving not only the immediate community surrounding the park but also major population centers. In all situations involving Master Plans, DCPs and other major proposals there shall be at least two meetings, one in or near the park and one will be held outside the park. If possible, the out-of-park site should be convénient to public transportation. 6. Meeting Format.-In general, the meeting format should provide for an orderly presentation of the issues, but also should be informal enough to encourage maximum discussion and participation by the audience. Everyone should leave the meeting feeling they had a fair opportunity to be heard. At the outset, the presiding officer should clearly explain the format, including "the ground rules" on length of oral statements, order of speakers, question and answer_period, adjournment time, etc. Although the format may vary somewhat depending on local conditions, the first step after the opening statement should be presentation of the plan. This should be as brief as possible, to allow a maximum amount of time for audience participation and to avoid the impression that National Park Service spokesmen are filibustering to cut down on the time available for public discussion. 7. The Presiding Officer.-In some cases, depending on the local situation, it may be desirable that someone other than the Superintendent be the presiding officer. Experienced people with NPS backgrounds are available on an expensesonly basis for this function. Names may be obtained from the Public Affairs Office. Selection of the presiding officer is extremely important, because the manner in which he or she conducts your meeting can literally mean the differ ence between success and failure, regardless of the other efforts that have gone into pre-planning. 8. The Record.—It is important that you have a reliable record of your meeting. The high cost will, in most instances, rule out professional court reporters. However, all meetings can be and should be tape recorded. Region will assist with equipment and personnel in this function. This record will prove extremely valuable to all of us in our post-meeting review and analysis. 9. The Wrap-up.-The closing statement by the presiding officer should stress that the record will remain open for an additional 30 days to receive written statements. Further, he should note that the National Park Service officials present will remain after adjournment for personal discussions with members of the audience. 10. The Follow-up.—A verbatim transcript of the meeting should be made available for public review as soon as possible, preferably within 21 days. Subsequent news releases, statements, etc. regarding the final version of the plan or proposal should always make reference to the previous public meeting. Mr. GUDE. Is there no reference to the workshops in regard to that? Mr. FINNEGAN. He states: *** workshops between the planning team and individual interested parties should be the cornerstone of participatory planning. The workshop should be informal, freewheeling and should consider the full range of potential planning alternatives. More formal and structured public involvement subsequently may be acquired through a public meeting on the environmental assessment in which the various planning alternatives, along with tentative NPS recommendations as to preferred alternatives, are presented. Although much less valuable as a forum for public involvement than the workshops, this public meeting does provide considerable opportunity for the public to influence the planning proposals at a time when they are still readily subject to change. Mr. GUDE. Was the comment in regard to workshops in the same memorandum as the statement in reference to the public meetings? Mr. FINNEGAN. Yes, Mr. Gude. Mr. DICKENSON. If I may, I would just like to emphasize once again that what you have just read represents a staff discussion and is not a policy directive. Since you have identified that as being addressed to the regional director, why it was in the context of a discussion. Mr. DINGELL. Just a minute. This is to the regional director, western region, from the Acting Associate Director, Park System Management, and you are going to tell me that does not have standing? Mr. DICKENSON. I believe in the first paragraph, Mr. Chairman, it indicated that it was an incoming document which is in the context of a discussion, seeking advice. Mr. DINGELL. That is not the way I read it. Mr. DICKENSON. Well then, I will have my memory refreshed. Mr. DINGELL. Maybe we are reading different documents, but I tend to read this as being an instruction from a superior to a subordinate NPS official. Mr. DICKENSON. The only policy directive that is effective must have the Director's signature or mine. There is no associate director authorized to sign a policy directive. Mr. DINGELL. I want you to say that again, because that is a very important point, and I would like to have that clearly in my mind. Say that again, because I want to be sure I got it. Mr. DICKENSON. Yes, sir, the policy directives of the National Park Service are to be signed by the Director or by the Deputy Director on his behalf. Mr. DINGELL. Well, I have here another memorandum dated September 20, 1973, to regional directors, northeast, southeast, midwest, southwest, western, Pacific, northwest regional directors for the National Capital Parks and Denver Service Center from the Acting Director, subject: "Concessioner's Participation in National Park Service Planning." Mr. DICKENSON. Well, the Acting Director would be appropriate. Mr. DINGELL. Signed by you. Now, is that a good document or not? Mr. DICKENSON. Anyone who is acting on behalf of the Director, either the Deputy or Acting Director, but associate directors do not have the authority to sign a policy directive. Mr. DINGELL. Well then, what is the significance of the document that we are discussing? Mr. DICKENSON. I am not really sure, except in my mind, sir; what has been read here is a discussion between two members of the Service trying to find some answers and some common ground. Mr. DINGELL. Well now, just getting into this matter, does it not strike you that it would be useful if we knew what went on then in these workshops? Mr. DICKENSON. Well, sir Mr. DINGELL. I get the impression that the workshops are held more or less as planning aids to unhappy folks in the background. Mr. DICKENSON. No, sir, let me relate, if I may, a session that we have had recently in the Great Smoky Mountains National Park which involved several jurisdictions in and around the Great Smoky Mountains National Park area, and the workshop format has been most successful in bringing people together in the very early stages-the nondecisionmaking, nonposition stage. Mr. DINGELL. Didn't you just advise Mr. Finnegan that you had never used this mechanism before? Mr. DICKENSON. I indicated in my testimony that we have been using it, but we just simply started calling it a workshop. We have had. informal planning meetings for years. Mr. DINGELL. Do you keep a transcript of these meetings? Mr. DICKENSON. No, sir. Mr. DINGELL. So you know what is said? Mr. DICKENSON. No, sir. Mr. DINGELL. You don't? Mr. DICKENSON. The only transcripts are at the public meeetings that follow later. Mr. BURTON. Maybe it is just semantics, but I thought what you were saying was that you didn't used to call them workshops. It used to be an informal planning thing, in that you had like documents there, your working plans for the people to discuss. Or did people just stand up and say we should have a firefall, we should not have a firefall, it should go at 10, it should go at 11? I mean, you had documents for them to work from? Mr. DICKENSON. That is right. Mr. BURTON. To look at and to suggest? Mr. DICKENSON. That is right. Mr. BURTON. And then after that was over, those were informal discussions, I take it, and then you went back in, and you did your plan over, I guess not off of transcripts, but just recollections of what the various people said? |