When does the commenting period end?
Commenting closes on Friday, October 14th.
What is the preferred method of commenting?
We suggest using the Google Docs version of the documents for commenting, since it allows for real time collaboration and immediate interaction. The files are available in Google Docs in the following folder State Standard Project Statement Commenting
If I use Microsoft Word are there any specific instructions I should follow?
Yes, please turn on track changes and use the commenting feature in MS Word. In addition please save the file with a different name. We suggest appending your name or the name of your agency to the end of the file name. Send the commented word file as an attachment via email to the point of contact designated in the table below.
I was not able to attend the webinar was it recorded?
Yes, we recorded the September 19th webinar and it can be viewed from the following link Standard Project Statement Webinar
How can I get in touch with the Point of Contact for each of the standard project statements?
Scott Knight (304)876-7465 scott_knight@fws.gov
Phil King (304) 876-7469 phil_king@fws.gov
Kelly Price (304) 876-7743 kelly_price@fws.gov
Ryan Oster (304)876-7926 ryan_oster@fws.gov
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13 Comments
Anonymous
Sep 28, 2016A few questions:
1) How would you categorize projects (Project Type etc.) that are focused on hunting/harvest statistics analysis that are used in developing hunting seasons from one year to the next?
2) How would you categorize projects (Project Type etc.) that are focused on database development/ management for hunted species?
3) How would you categorize projects (Project Type etc.) that are focused on database development/ management for lands the WDFW owns or manages?
John Pierce
Washington Dept Fish and Wildlife
Anonymous
Sep 29, 2016Overall, there seems to be some inconsistency between project statements (e.g. some of the results and expected benefits sections are bulleted and some are not; objectives are listed under approach and some are not; some objectives are well defined while others are not, etc.). There appears to be duplication of effort in regard to compliance documentation (e.g. there is an explanation and a narrative yet compliance documents must also be accompanied with the grant agreement)? All in all a good start. Thank you for allowing us to review and comment.
~NYSDEC
Ryan Oster
Sep 30, 2016Thank you for the comments. We appreciate them. In regards to your comments about inconsistency. Yes, you are correct that some project statements (particularly in the Approach and Results/Benefits sections) are drafted using bullets, while others are drafted using narrative style. We did that intentionally to highlight that there is no standard form or format, only required elements that need to be included in the project statement. Some people prefer to write in narrative style, while others find bullets more appealing. Either is fine, as long as the level of detail and the required elements are provided in the project statement.
In regards to the objectives, we are trying to stick with the standard objectives that were developed by the TRACS working group. We have seen many people struggle with determining what is the Objective vs Approach, particularly as they enter project statements into TRACS. Additionally, looking at projects statements in TRACS, we have observed that most appear to be developing objective statements that are not specific and quantifiable as required under 50 CFR 80.82(c)(2). Hence the development of the standard objectives and the emphasis on a very well detailed Approach section.
The compliance section was an area that we observed significant regional preferences as to how best to provide this information. And that makes perfect sense as Compliance issues vary dramatically across the country from Region to Region and state to state. As long as detailed information (in the Approach section) is provided in the project statement, you should be just fine. That is why we put the note in the last section (General) as some Regions/States like the information provided here, meanwhile others felt it was duplicative and already provided elsewhere in the project statement or in supplemental documents.
Thanks again for the kind words and we are very pleased thus far with the comments we have received. We appreciate your comments to help improve this effort.
Michael Sawyers
Oct 21, 2016We agree with NYSDEC’s comment on compliance. It is not necessary or required by 50 CFR 80 to provide this level of detail specifically related to compliance within the project statement. The state agency already provides information and documentation that is sufficient for the federal agency to concur that the proposed activities are in compliance.
Anonymous
Oct 04, 2016B Compton (Idaho) raised questions within the Fish_Hatchery.docx about the State obligation to make determinations whether the activity complies with ESA, NHPA, and NEPA.
Anonymous
Oct 14, 2016Scott Knight
Oct 14, 2016Thank you for your comment. Could you be more specific on areas where you believe the detail goes beyond the requirement? Meeting the regulatory requirements in an effective and efficient manner was one of our primary objectives. We would be glad to take another look at something you believe to be excessive.
Sheila Cameron
Oct 14, 2016From our perspective, most of these statements include information that we are already providing. Although some of it is rearranged and the the standard objectives aren't currently in use. One area of possible confusion is where items are nice or helpful but not required by regulation. These could be identified similarly as those that are dealt with differently by different regions.
Michael Sawyers
Oct 21, 2016We concur that confusion may arise with what elements are nice to include, but not required by regulation.
Julie Kempf
Oct 19, 2016Greetings!
Indiana DNR doesn’t have the ability to use Google docs without approvals from our IT department. Most of our comments are general in nature, so we will provide all of them in this one comment.
General:
Boating Access:
Coordination:
Land Acquisition – Recreation:
Research:
TRACS Strategy Matrix: We recognize this was provided for information only and probably is not comprehensive, but as we reviewed it we had a couple of comments.
Overall, we were fairly pleased with these examples. We liked the simplicity, but most of our grants have multiple grant objectives. For that reason, it is unlikely that any of our grants would adopt the single-objective standard format.
We recommend clearly stating the intent of standardized project statements. That is, some states or FWS offices may interpret that everything in the statements is required, rather than using the statements as guidelines. Another possible unintended result is that the unit of measure for any given objective and program must match what is provided in the template. Maintaining flexibility is critical as program needs and objectives change over time.
Thank you for the opportunity to comment.
Doyle Brown
Oct 14, 2016I didn't have a lot of time to review the project statements due to Region 3 FAC meeting last week and digging out all this week. I was reviewing the land acquisition templates and agreed with many of the comments offered by Julie Kempf. I indicate who the project leader is on every grant for element #7 (Project Investigator) so it is never a N/A element.
I too like the simplicity, however recognize there are state agency desires and USFWS Regional needs which may require more narrative than shown. Some of our new project leaders would like to follow the lean approach, however our Department wants to see documents which provide enough depth to be understood by anyone (including a federal auditor).
If I find more time I will review more of the statements.
Thanks!
Michael Sawyers
Oct 21, 2016In several of the Standard Project Statements, we were surprised to see the timeline broken down into quarters. This is a greater level of detail than is provided in the performance reports. Providing this level of detail from the outset reduces flexibility of the grantee to accomplish the goals and objectives of the grant in the timeline described. Extenuating circumstances could completely derail the proposed timeline and the grantee would no longer be capable of meeting the objectives in the timeline described.
Michael Sawyers
Oct 21, 2016General Comments:
50 CFR 80.82(c)(13) does not require these “General” elements of the project statement to be its own section. Rather, the burden is on the state agency to provide adequate information for the Regional Office to concur that the project is substantial in character and design and complies with all applicable federal laws, regulations, and policies. In Massachusetts, each grant submission is accompanied by compliance documentation signed by the project leader or signatory authority as appropriate. Requiring this information within the grant narrative is above and beyond the requirements of this section.
There are several elements included in these Standard Project Statement examples that are not required by 50 CFR 80. What justifies the inclusion of these elements? Based on the requirements of 50 CFR 80, the following elements are not required in the project statement: Indirect Cost Statement, Single Audit Reporting Statement, and Conflict of Interest Statement. Additionally, Useful Life is not required for projects that do not have capital improvements greater than $100,000.00. In-kind Match and Pre-award Costs would be described in the budget breakdown and should not stand alone in the project statement. This is based on the assumption that the budget narrative/justification would stand alone as a separate document. If it were to be incorporated into the project statement as suggested here, this would not be a duplicative statement.
Reporting the TRACS Action Levels within the project statement is not required by 50 CFR 80 when submitting grants to the Regional Office for approval and obligation of funds. The intent of TRACS is a performance reporting tool, not a grant submission and approval tool.