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September 11, 2009 - ASCE Comments and Suggestions - National Environmental Policy Act exclusions

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September 11, 2009

Matt Harrington
National Environmental Coordinator
Ecological Sciences Division
Department of Agriculture
Natural Resources Conservation Service
1400 Independence Avenue SW
Washington, DC, 20250

Dear Mr. Harrington:

I am writing on behalf of the more than 146,000 members of the American Society of Civil
Engineers (ASCE) in support of the interim final rule issued by the Natural Resources
Conservation Service (NRCS) on July 13, 2009, that excludes from the requirements of the
National Environmental Policy Act (NEPA) actions that the agency has determined do not
individually or cumulatively have a significant effect on the human environment. 74 Fed. Reg.
33,319.

The NRCS rule would assist the agency in providing emergency funding under the American
Recovery and Reinvestment Act (ARRA) while meeting the mandates of ARRA and NEPA for
undertaking actions in the most expeditious manner and in compliance with NEPA. ASCE
concurs that this approach will ensure protection of essential environmental amenities while
allowing the agency to move forward with funding for vitally needed conservation plans on
public and private lands. ASCE believes that sustainable development is the challenge of
meeting human needs for natural resources, industrial products, energy, food, transportation,
shelter and effective waste management while conserving and protecting environmental quality
and the natural resource base essential for future development. Sustainable development
requires finding innovative ways to achieve needed development while conserving and
preserving natural resources. 

Thank you for your attention to these comments. Please contact Michael Charles of the ASCE
Government Relations Department at 202-789-7844 or at mcharles@asce.org if you have
additional questions.

Sincerely yours,

D. Wayne Klotz, P.E., D.WRE
President