NASORLO LWCF State Assistance Modernization Committee

NASORLO LWCF State Assistance Modernization Committee Created under administration of President Susan Moerschel First Chair Lauren Imgrund Purpose to review LWCF State Assistance Program guidelines, seek feedback from NASORLO membership and propose administrative changes as deemed appropriate and necessary Current Committee: John Beneke (AR) Mary Fitch (OH) Eric Feldbaum (NH) Cleve Hardman (LA) Tim Hogsett (TX) Susan Moerschel (DE) Antoinette Norfleet (GA) Synthia Waymack (VA) Doug Eiken (advisory)

Some of the Initial Committee Issues Administrative Costs Temporary Non-Conforming Uses Technology Real Estate Appraisals SCORP Small Conversions

Temporary Non-Conforming Uses Current LWCF Manual “All requests for temporary uses for purposes that do not conform to the public outdoor recreation requirement must be submitted to and reviewed by the State. The State, in turn, will submit a formal request to NPS describing the temporary non-conforming use proposal. Continued use beyond six-months will not be considered temporary, but will result in a conversion of use and will require the State/project sponsor to provide replacement property pursuant to Section 6(f)(3) of the LWCF Act. NASORLO Request Extend use period NPS Response Would like to go to 3 years, but current policy based on Congressional direction…change could require Congressional action or Federal Register posting…NPS consulting with legal counsel

Technology National data base of LWCF assisted lands and facilities Useful for administrative purposes such as 6f protection and other post- completion compliance Very useful for showing the importance and widespread use of State Assistance funding Political purposes Issue addressed in another session

Real Estate Appraisals NASORLO Request NASORLO members often manage several federal grant programs. We seek consistency on appraisal standards such as NPS allowing USPAP appraisals in lieu of “Yellow Book” Other DOI entities such as US Fish and Wildlife already have made this change NPS Response Exploring options

SCORP Current LWCF Manual “To be eligible for LWCF assistance for acquisition and development grants, each State shall prepare a Statewide Comprehensive Outdoor Recreation Plan (SCORP), and update it at least once every five years.” NASORLO Request Extend SCORP eligibility to 10 years. No formal NPS response to date

Small Conversions Current LWCF Manual “Small conversions are composed of small portions of Section 6(f)(3) protected areas that amount to no more than 10 percent of the 6(f) protected area or five acres, whichever is less. The replacement property is contiguous to the original Section 6(f)(3) area . NASORLO Request Remove 5 acre and contiguous replacement requirements NPS Response policy has been revised..5 acre requirement removed, and requirement for replacement property to be contiguous to original 6f area has been revised to the replacement property must be contiguous with the current site, or another existing park or recreation area. In addition, small conversions must qualify as a categorical exclusion under NEPA.

Other Issues Raised in Committee Timing of annual apportionment, Have had discussions at high levels of DOI, and with key Congressional oversight committee staffers Reapportionment guidelines and loss of funds Annual application windows in grants.gov and implications on administration Overhead utility lines policy removed in 2008 NPS manual revisions Requirement for oversight review by new Secretary of the Interior for all grants exceeding $100,000 ORLPP review process and delays

Future Committee issues?