GUIDELINES TO NRDC feb 24 2014

Responding to Non-concurrences, ContinuedContinuedResponding todissentAlways welcome honest opposition. Consult with devils' advocates andfield their tough questions. They can--x Raise ethical concerns.x Contribute new information.x Provide new insights to old information.x Challenge a proposal's validity.x Suggest creative solutions.x Counteract special pleading.x Disclose hidden agendas.NegotiatingBefore sending a non-concurrence forward, try to negotiate differences.x Try reasoning and persuasion. This may be all that's needed to convincesomeone who objects but doesn't want to make an issue of it.x Make concessions that won't change the action's substance but will satisfythe opposing party.For more tips on negotiating, review Chapter 6.Considering nonconcurrencesIf unable to resolve a non-concurrence, prepare a Consideration of Nonconcurrence,either as a signed statement or memorandum for record(MFR). Rebut the non-concurrence in a concise, logical argument.See sample format at Appendix C, page C-5.Where to placeconsiderationstatementPer local SOP, place the consideration statement in one of three locations:OptionLocation of statement1 Type statement at the bottom of the nonconcurrence statement.2 Type statement at the bottom of the decision paper.3 Attach consideration of nonconcurrence to the statement ofnonconcurrence and place it as the last tab to decision paper.Note: Give a courtesy copy of your statement to the nonconcurring parties.NRDC GRC – Staff Handbook 8-9