Updates from the OCMP: Minding the Federal Consistency Review Shop

Since my last post, the direction of my fellowship has shifted yet again.  I have hinted in previous posts that I have been given a lot of latitude to take the work in any direction I see fit – so the project has grown and shrunk and grown again as I learn more about the system in which I’m working.  This is really my favorite type of environment to work in – I like dynamic work, following random threads, learning new things, and not always knowing what’s next.  That being said… this latest shift was not as welcome because it came as a result of the departure my mentor from state service: over the last three months, I have been taking on a lot of the tasks of the State-Federal Relations Coordinator and minding the federal consistency review shop while the Oregon Coastal Management Program (OCMP) has been hiring my mentor’s replacement.     

Though it has been unfortunate I have not had as much time to dedicate specifically to the further development of tribal coordination procedures, I’ve been leaning into the opportunity to learn the ins and outs of a federal consistency review.  I thought I had a decent grasp, but I’ve found I was just scratching the surface.  (hubris!)  With my new appreciation for the complexity of the position and requirements of a federal consistency review, I feel better positioned to generate procedures that will work for the next Coordinator. 

For example, being in the Coordinator’s shoes has really underlined the importance of developing effective, clear, and fairly simple procedures for involving the tribes.  The reality of the position (and, really, I think this is true for lots of dynamic/ high-tempo professions) is that things sometimes have to fall off the plate.  Therefore, procedures have to be realistic and mindful of varying levels of bandwidth for them to outlast their creator.  So, I have been thinking quite a bit about where I can create efficiencies – generating message templates, simplifying methods to identify who needs to be contacted, and updating checklists that help the Coordinator track where they are in the process.  My appreciation for reasonable and sustainable processes is a common theme throughout my professional career so far, and has probably already come up in a previous blog post…

In other news, I am really happy to report that a major component of my main project has been able to continue during these last months.  Working with one of my Tribal advisors and the Oregon State Historic Preservation Office (SHPO), I have been developing a proposal to add more policies related to archaeological resources into the suite of policies that are considered during a federal consistency review.  Policies must meet certain criteria to be called “enforceable” and be approved by NOAA for inclusion in a coastal management program.  Enforceable policies are the backbone of a federal consistency review – federal permit applicants and federal agencies proposing actions must make a statement that they believe their project is consistent with these policies. The OCMP then concurs, concurs with conditions, or object to the applicant’s determination that their project is consistent based on our independent review and the input of our network partners

For this reason, the inclusion of these additional enforceable policies of importance to the Tribes is a substantial step forward in emphasizing the OCMP’s commitment to the protection of archaeological resources.  I am currently developing letters to distribute to the Tribal Councils to provide notification about the change, discuss the significance, explain the implementation process, and request their feedback.  This is a months-long process that will very likely outlast my tenure with the OCMP, so I am excited to get it moving! 

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2 thoughts on “Updates from the OCMP: Minding the Federal Consistency Review Shop

  1. Thanks for this great post, Kyle. I think that one of the greatest benefits of being a fellow is the opportunity to dips your toes into lots of different projects, processes, and experiences; and it sounds like you have had that plus a full immersion into State/Federal relations. So glad to hear that one of your main projects is getting some good traction too!

  2. And it’s sometimes frustrating to start projects but not be able to finish them, so I appreciate your perspective that it’s all part of the process. Thanks for breaking down the policy side of things on these important issues.

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