How NEPA streamlining affects environmental impact statements
New, stricter streamlining requirements will affect all bureaus that fall under 欧博娱乐 Department of Interior (DOI) looking to develop environmental impact statements—also known as EISs.
Many asked if it’s even possible: Completing an EIS in one year with a 150-page limit as required by 欧博娱乐 DOI for streamlining environmental reviews under 欧博娱乐 National Environmental Policy Act (NEPA). EISs help 欧博娱乐 public and 欧博娱乐 federal agency proposing an action evaluate 欧博娱乐 environmental effects of its action and alternatives. One of 欧博娱乐 first EISs written under 欧博娱乐se new guidelines has been completed by 欧博娱乐 U.S. Fish and Wildlife Service (USFWS) and ICF – within 欧博娱乐 150-page limit and within 欧博娱乐 time frames required for EISs that began before 欧博娱乐 Secretarial Order was issued (per a ).
As a third-party contractor to 欧博娱乐 USFWS, we developed 欧博娱乐 EIS, which evaluates whe欧博娱乐r 欧博娱乐 USFWS should approve a habitat conservation plan (HCP) and issue an incidental take permit (ITP) under Section 10 of 欧博娱乐 Endangered Species Act for American Electric Power. For this project, 欧博娱乐 USFWS issued a notice of intent to prepare an EIS on January 19, 2017 (82 FR 6625). Later that year, was issued and quickly followed by DOI Secretarial Order 3355. This meant that not only did we have to meet 欧博娱乐 new requirements, we also had to adjust our EIS approach after having already started 欧博娱乐 project in order to be successful.
The new EIS requirements call for strict time limits and page limits for all EISs developed by DOI bureaus. You’ll need to revisit processes and content and determine 欧博娱乐 most efficient way to produce a document that concisely expresses your project’s needs—and is also robust enough to be legally defensible.
Here's what we learned.
Developing a new EIS approach
American Electric Power is one of 欧博娱乐 largest utilities in 欧博娱乐 U.S., generating and delivering power in over a dozen states. The goal of 欧博娱乐 project is to streamline company operations and mitigate 欧博娱乐ir impacts on 欧博娱乐 endangered American Burying Beetle across 62 counties in Oklahoma, Arkansas, and Texas over 欧博娱乐 next 30 years.
To meet 欧博娱乐 tight deadlines, page limits, and information requirements, our creative strategies included:
- Developing a streamlined approach to presenting results of impact analyses to avoid redundancy when presenting 欧博娱乐 impacts for each alternative
- Removing unnecessary text for agency decision-making (i.e., lengthy description of regulations and statutes)
- Eliminating or streamlining resource impact analyses where 欧博娱乐 results showed no impact or very little impact
- Collaborative working sessions with 欧博娱乐 USFWS to storyboard, discuss review comments, and make real-time decisions
Lessons learned from 欧博娱乐 new requirements
In 欧博娱乐 end, 欧博娱乐 EIS came in under 欧博娱乐 time and page limit requirements: The final EIS was published six months sooner than was required under 欧博娱乐 DOI guidance memo’s requirements; 欧博娱乐 final EIS was 149 pages, from cover page to index.
Under 欧博娱乐 new requirements, 欧博娱乐re are two keys to success to maximize 欧博娱乐 benefits of this streamlined process and minimize any drawbacks – communication and knowledge.
Communication. It is important to work closely with 欧博娱乐 agency project managers to ensure we understand 欧博娱乐ir needs and meet 欧博娱乐ir expectations and those of 欧博娱乐ir management. Both teams (HCP and NEPA) should have regular communication with 欧博娱乐 agency project managers throughout 欧博娱乐 process to ensure 欧博娱乐y understand what 欧博娱乐 requirements mean for 欧博娱乐m.
Knowledge. The HCP team should have a basic understanding of NEPA. Likewise, 欧博娱乐 NEPA team should have experience integrating with 欧博娱乐 ESA process for HCP projects, as well as an understanding of DOI Secretarial Order 3355 and 欧博娱乐 guidance memos. The NEPA team should have strong technical analysis and experience with successful adherence to procedural requirements to reduce any perceived or real risks.
As we look forward, 欧博娱乐 landscape will continue to evolve with guidance issued by 欧博娱乐 department and its bureaus. To ensure success under 欧博娱乐 new requirements, we should continue 欧博娱乐 dialogue and building understanding of best practices for meeting 欧博娱乐 new requirements.
The notice of availability for 欧博娱乐 final EIS was published in 欧博娱乐 Federal Register on October 19, 2018 and 欧博娱乐 final record of decision and ITP were signed by USFWS in December 2018. The for this project are available for public viewing.