Step 1: Assessment

20201020 Appendix B 7 Step Guide Sop Onhr [pdf]

Is Consultation Needed or Advantageous?

At the outset of a proposed Federal action, it is important for the Office to assess whether consultation with the NHC is necessary or advantageous.[1]  To conduct this assessment, it is important to consider the following:

  • What is the proposed Federal action and its scope?
  • Is it controversial or precedent setting?
  • Is the NHC aware of the proposed Federal action and if so, what is the NHC’s level of awareness, interest, or concern in the proposed Federal action?
  • What are the NHC implications, if any?

If at this stage, the proposed Federal action is neither controversial nor precedent setting, there is a low awareness or negligible interest, and/or there are no implications to the NHC; then it may be appropriate to conclude that the Action (see definition) does not require consultation with the NHC.

However, if any answers to the preceding questions is in the affirmative or there is significant awareness, interest, or implications within the NHC, then the Action warrants further assessment.

In particular, it is important to consider the following:

  • How would the NHC be affected, both adversely and positively?
  • How might the NHC be affected or offer unique solutions?
  • Is consultation required by statute or policy (even if consultation is not required by statute or policy there may be other reasons to consult)?

Additionally, it is important to consider the Hawaiʻi-wide context under which the Action is being conducted and how consultation might be conducted. For example, it is reasonable to assess the advantages or disadvantages to consulting with the NHC at a point in time, given the scope of the Action may be coinciding with other circumstances or Federal Actions. Would the NHC be confused, overwhelmed, or conflate multiple Federal Actions?  Would it be advantageous to delay consultation or coordinate with other federal agencies on their consultation actions?

If, through the Office’s assessment of the Action, it is determined that consultation is necessary or advantageous to the Action, then the Office should proceed to the next step in the consultation process.


[1] In cases where the Office is not initiating the Action, but has agreed to partner with another Federal office, department, or bureau, the Office will seek adoption of this 20201022 Consultation Appendices Sop Onhr [pdf]
 for that particular action.

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