NEPA Interim Guidance For Projects
Offiice of Consstruction and FacilitiesMaanagementt (003C2)Washington, DC 200012022-632-4632www.ccfm.va.govNEEPAAInteerim GuidaancceforProojecctsev.)PG--18-17 (re30 Septemmber 20100
Executive SummaryThis document presents the requirements of how the National Environmental Policy Act(NEPA) relates to VA facility operation and construction projects and is presented for useas functional interim guidance during this period of significant construction / renovationactivity while the Implementing Regulations are being re‐written.The following provides a "Cliff Notes" preview of NEPA as it applies to projects for the VA.Background NEPA is a long standing (originally 1970's) requirement for environmentalreview of federal "actions."The definition of the word "Action" is pretty broad and includes substantially more thanconstruction, such as: lease, sale, or purchase of land; providing funding; or providingpermits for private actions.Under NEPA federal agencies are required to "determine if their proposed actions havesignificant environmental effects and to consider the environmental and related social andeconomic effects of their proposed actions." Note that NEPA is a decision making process,integral to the Action, rather than a separate environmental requirement.The Process The NEPA process is "done" at the completion of one of three levels ofevaluation (see attached flow path diagram):1. Categorical Exclusion (CATEX)2. Environmental Assessment (EA) with a Finding of No Significant Impact (FONSI)3. Environmental Impact Statement (EIS) with a Record of Decision (ROD)CATEX is a category of Actions that the agency has determined do not individually orcumulatively have a significant effect on the quality of the human environment. If theaction does not clearly meet any of these criteria, or seemingly does but has "extraordinarycircumstances," then it must be evaluated through completion of an EA.Example CATEXs are routine actions such as: facility or grounds maintenance; minorrenovation or replacement in kind; administrative actions. The list of CATEX actions areagency specific and are specified in their implementing regulations.At the facility level numerically, most of the Actions generally fall into this CATEX category.EA takes a broad look at the potential impacts of the Action on the environment whichincludes both natural and historical resources, as well as human impacts such as socio‐economic, visual, and noise. The NEPA process also requires an EA to clearly state thepurpose and need for the proposed Action as well as review all reasonable alternatives,including no action. If there are no significant impacts (i.e. any potential issues areroutinely handled through issuance of permits, consultations, modifications to design, orother agreements) a FONSI can then be issued following a public comment periodconcluding the NEPA process. If there are substantial issues and/or public controversy, theprocess continues on through completion of an EIS.Part 1, Page 1 of 15VA NEPA Interim Guidance ‐ Projects30SEP10 draft
At an individual facility, based upon their size and scale, an EA is most commonly theappropriate level of NEPA evaluation for Major, a number of NRMs, significant energy, andsome Minor projects.EIS is a more extensive process with additional public involvement and specificrequirements such as publication of Notice of Intent and a formal Scoping process. The EISprocess also requires involvement of Environmental Protection Agency (USEPA),publications in the Federal Register, and several mandated timelines for public comment,review, and wait periods. At the conclusion of the process, the ROD, reviewed by USEPA, isa legally binding document.The number of projects at a facility which would require an EIS level of effort is quite small.Siting of a new full‐sized medical center, however, would likely require an EIS based uponpotential for impacts.This NEPA Interim Guidance ‐ Projects provides VA personnel with the tools with which toachieve compliance with the law, as well as likely more comprehensive projectdevelopment and execution.In addition to this VA document, there are many other reference documents. For example,the Council on Environmental Quality (CEQ), which sets the overall NEPA policyrequirements, has published a 55‐page booklet "A Citizen’s Guide to the NEPA" which canbe found at: http://ceq.hss.doe.gov/nepa/Citizens Guide Dec07.pdfPart 1, Page 2 of 15VA NEPA Interim Guidance ‐ Projects30SEP10 draft
AcknowledgementsVA NEPA Implementing Regulations Steering CommitteeThomas W. Moran, P.E. Environmental Engineer, CFM ‐ ChairmanJack Staudt, P.E. Environmental Engineer, VHA 10NJody McClarin, Environmental Engineer, CEOSHCathleen Johnson, Program Specialist, OAEMGeorge Setlock, VISN 19 and VISN 21 Environmental Program ManagerFrank Duncan, Environmental Engineer, NCAMichelle DeGrandi, Esq., OGC EnvironmentalLisa Mahoney, Esq., Environmental Engineer, The Clark Group LLCReviewersWendy Kady, VISN 6 IH/GEMS CoordinatorNelson Cancio, Environmental Engineer, CFM Western Regional OfficeAnne‐Marie Naficy, VISN 20 Capital Assets ManagerDave Hill, Facilities Manager, Canandiagua VA Medical CenterDan Therrien, Project Manager, CFM Central Regional OfficePam Russell, GEMS / Industrial Hygiene Manager, Minneapolis VA Health Care SystemKathleen Schamel, VA Historic Preservation OfficerRobert Yager, Chief Engineering, Omaha ‐ VA Nebraska‐Western Iowa Health Care SystemPart 1, Page 3 of 15VA NEPA Interim Guidance ‐ Projects30SEP10 draft
Department of Veterans AffairsNEPA Interim Guidance ‐ ProjectsTable of ContentsI. Executive SummaryII. AcknowledgementsIII. Section 1A. IntroductionB. Background: Overview of the National Environmental Policy Act (NEPA)C. The Process: Understanding the Value of NEPAChart: Decision Process and NEPA ProcessD. The NEPA ProcessE. Department of Veterans Affairs NEPA RegulationsF. NEPA for Veteran Affairs Planning and ProjectsChart: VA Project / NEPA Process (small projects)Chart: VA Project / NEPA Process (large projects)IV. Section 2 – The Environmental Planning and Review ProcessA. OverviewB. PurposeC. WhenD. WhoE. ScopingF. Categorical Exclusion (CATEX)VA CATEX ListExtraordinary CircumstancesSimple CATEXAdvanced CATEXG. Environmental Assessment (EA)i. Draft EAii. Public Involvementiii. Determination (FONSI or EIS)Part 1, Page 4 of 15VA NEPA Interim Guidance ‐ Projects30SEP10 draft
H. Environmental Impact Statement (EIS)i. Notice of Intent and Scopingii. Public Involvement / Draft EISiii. Final EISiv. Record of Decision (ROD)I. Supplemental EA or EISJ. Programmatic EA or EISK. Involving Third Partiesi. Cooperating Agenciesii. Public ParticipationL. Coordination with NHPAM. Compliance Permitting / Due DiligenceV. Section 3 – ReferenceA. Regulatory Context/Legal RequirementsB. TerminologyC. VA ContactsVI. Section 4 – AppendixA. Example CATEXB. Sample EA Table of ContentsC. Sample EA Scope of WorkD. Example Finding of No Significant Impact (FONSI)E. Draft Notice of Availability for an Environmental AssessmentPart 1, Page 5 of 15VA NEPA Interim Guidance ‐ Projects30SEP10 draft
Department of Veterans AffairsInterim NEPA Guidance Projects – Section OneIntroductionThe purpose of this Department of Veterans Affairs Interim NEPA Guidance (Interim Guidance) is toexplain the requirements for environmental planning and how the process integrates with projectplanning and agency decision‐making. It is important for project managers and decision‐makers tohave a clear understanding of the requirements for evaluating environmental information whileengaging in agency activities. By integrating environmental analysis into the project planning anddecision‐making process, project managers and decision‐makers can make more informeddecisions and better avoid unforeseen circumstances.This Interim Guidance will assist VA officials, employees, and contractors to plan and implementprojects in compliance with the federal laws and regulations designed to protect the environment.The Interim Guidance contains a brief description of the National Environmental Policy Act (NEPA),explains how VA can use the NEPA process to improve decisions and comply with environmentallaws, and provides guidance on the types of environmental analysis and documentation necessaryfor VA projects. This guide is primarily focused on VA facility and construction projects, but NEPAapplies to all VA actions (defined as: any decision, policy, project, plan, program, etc. subject toDepartment of Veterans Affairs control and responsibility which has the potential for anenvironmental impact).Efforts are currently in process to re‐write the VA's NEPA Implementing Regulations (38 CFR Part26), which will be a combination of codified regulations and VA Directive and/or Handbook. Thetimeline for full completion of this regulatory process is quite lengthy. VA is currently undergoingan unprecedented recapitalization of existing facilities nation‐wide, as well as construction of brandnew medical centers, cemeteries, and office support type facilities. The intent of this document is toprovide Interim Guidance to decision makers and project managers for integration of project andenvironmental planning to minimize environmental impacts and ensure NEPA compliance. ThisInterim Guidance does not attempt to cover NEPA evaluation of all possible VA Actions, ratherfocuses nearly solely the most pressing set of Actions, namely construction / renovation projects.Background: Overview of the National Environmental Policy Act (NEPA)NEPA requires federal agencies to consider the impacts of their actions on the human environment.It is a long‐standing law, originally enacted in 1969, signed into law in 1970. NEPA is triggeredwhen a federal agency proposes to engage in any action that may have environmental effects.Agency “actions” subject to NEPA encompass a diverse range of activities, such as: construction;lease, sale or purchase of property; grants or permitting; programs or policies that are under theAgency's control and have the potential for environmental impact(s). Agencies must comply withNEPA at all stages of a federal action, from planning to implementation. NEPA does not replacePart 1, Page 6 of 15VA NEPA Interim Guidance ‐ Projects30SEP10 draft
other environmental laws and regulations. Instead, NEPA serves as a decision‐making approach toidentify and assess potential environmental impacts as early in the decision‐making process aspossible. NEPA seeks to educate agency decision‐makers on the environmental, socio‐economic,and cultural effects of federal actions. Compliance with NEPA provides additional information thatcan be used alongside project feasibility studies and economic analyses to help project managersand agency staff make good decisions.NEPA requires federal agencies to comply with NEPA regulations promulgated by the Council onEnvironmental Quality (CEQ). The CEQ oversees the NEPA process and ensures federal agenciescomply with the Act. CEQ NEPA regulations guide agencies through the NEPA process byestablishing minimum requirements for NEPA review. These minimum requirements include theneed for public involvement and an assessment of reasonable alternatives.All federal Agencies must create their own specific NEPA procedures, in consultation with the CEQ,to guide agency practitioners, decision‐makers and the public. An agency’s NEPA procedures adaptthe NEPA process to the particular agency’s needs and scope of activities. The agency and all of itsemployees must follow the agency’s NEPA procedures, CEQ NEPA regulations, and other relevantregulations.UNDERSTANDING THE VALUE OF NEPANEPA integrates with the planning and design process for any project. Through theNEPA process, project planners and decision‐makers avoid unnecessary delays inproject development and make informed decisions among alternatives based onenvironmental information.In order for an agency to comply with NEPA, decision‐makers must reviewenvironmental documents at the same time as other planning documents. Anagency‐wide approach to the NEPA process improves the ability of all programoffices to respond to environmental information and proceed with projectdevelopment in compliance with environmental laws and regulations while avoidingunnecessary delays.NEPA is a tool for decision‐making. The NEPA process is a part of the projectdecision process as illustrated in the diagram. NEPA is good project managementbecause it allows the best decision to be made relative to potential impacts to thehuman environment while avoiding unforeseen circumstances and avoidingunnecessary delay.Part 1, Page 7 of 15VA NEPA Interim Guidance ‐ Projects30SEP10 draft
The NEEPA ProceessThe purppose of NEPAA is to ensure that informaation regarding potentiall environmenntal impacts ofnd citizens beefore decisioonsany federral, or federaally funded, action is availlable to public officials anare madee and before actions are taken. NEPA should be sttarted as earlly in the proccess as possiible.In the NEEPA context, "environmennt" includes natural and historical ressources, as well as humannimpacts such as socioo‐economic, visual, and nooise.The first step in the NEPA processs is to identiffy the purpose and needd for the projject and definnethe proposed action. The next sttep is to begiin preliminarry scoping of potential ennvironmentaalposed action.impacts and potentiall alternativess to the propCompliannce with NEPPA for a givenn project or decision is acchieved in onne of three ways:ying the projject or decisiion as a categgorical excluusion (CATEEX) and makking1. by identifypecial considderationsure theree are no extraaordinary cirrcumstancess requiring sp2. by conduccting an enviironmental assessmentt (EA) resultiing in a findiing of nont impact (FFONSI) (if apppropriate) onn the projectt or decisionsignificanmpact statement (EIS), considering the findings of3. by preparring an envirronmental imment in decidding whetherr and how too proceed witth the projecct or decisionn, andthis statemissuing a record of deecision (ROD)NEPA ProcesssProjecct Decision Process Set Orgganizational GGoals &Objectiives Develoop Alternativees Compaare & EvaluateeAlternaatives Choosee Among Alteernatives Implemment Decisionn Command, Lead, & Manage DDetermine Puurpose & Needd DDevelop Alterrnatives GGather Data & Analyze Imppacts CCompare & EvvaluateAAlternativesand Mitigationn PPrepare Documents OObtain Commments MMake Decisionn OObtain Commments MMitigate & MoonitorPaart 1, Page 8 of 15VA NEPAA Interim Guiidance ‐ Projjects30SEP10 draft
Categorical Exclusions (CATEXs) are actions that a federal agency has determined to be veryunlikely to individually or cumulatively have a significant impact on the environment. If a federalagency knows a particular type of action will not generate a significant environmental impact,based on agency experience, then the agency may elect to categorically exclude the action fromfurther environmental review. Agencies generate agency‐specific lists of categorical exclusionsbased on experience and these lists are formalized through the regulatory process. VA’s currentCATEX list can be found in 38 CFR Part 26. If the action does not clearly meet the agency‐specificcriteria, or seemingly does but has “extraordinary circumstances,” then the action must beevaluated through completion of an EA.An Environmental Assessment (EA) looks at the effects of a proposed action and reasonablealternatives to achieve the agency’s objectives. The EA is intended to be a concise document that (1)briefly provides sufficient evidence and analysis for determining the significance of the action andwhether to prepare an EIS; (2) aids an agency’s compliance with NEPA when no environmentalimpact statement is necessary; and (3) facilitates preparation of an Environmental ImpactStatement when one is necessary. If the analysis finds there are no significant impacts, a Finding ofNo Significant Impact (FONSI) can be issued concluding the NEPA process. The FONSI is a legallybinding document. If there are substantial issues and/or public controversy, the NEPA processcontinues on through issuance of a Notice of Intent (NOI) completion of an EIS.An Environmental Impact Statement (EIS) is a more extensive process with additional publicinvolvement and specific requirements such as formal publication of notices and a scoping process.The EIS process also requires involvement of the Environmental Protection Agency (USEPA),publications in the Federal Register, and several mandated timelines for public review andcomment periods. At the conclusion of the process, a Record of Decision (ROD) is issued and this isa legally binding document.Whether VA prepares a CATEX, EA, or EIS, each of these processes should involve some form ofpublic involvement. This could mean posting a CATEX on a website, inviting the public tocomment on an EA, conducting a public meeting, or publishing a Notice of Availability for an EIS inthe Federal Register. NEPA may also require formal agency consultation if the project or itsimpacts overlap the jurisdiction of another federal agency. The NEPA process including publicinvolvement and coordination is covered in more detail in Section 2.A summary of the whole process is illustrated in the “NEPA Process Diagram” below.Part 1, Page 9 of 15VA NEPA Interim Guidance ‐ Projects30SEP10 draft
EPA Impllementingg RegulationstDeparttment of Veterans Affairs NEVA’s NEPPA implemennting regulations are codiified in the Federal Regisster at 38 CFRR Part 26. Laastulations no loonger meet thhe needs of the Agency. VA is currenttlyupdated in 1989, the current regung new agency NEPA regulations andd Directive/HHandbook to reflect the Agency’s currentdevelopinns, organizattion, and mission. The neew regulationns will enable VA to betteer addressoperationvide adaptabbility for the future.current environmentaal challengess of their actiions and provk will providee clarity on roles and respponsibilities forThe new regulations and Directivee/Handbookmental planniing within VAA and explainn how enviroonmental plaanning relatees to VAenvironmhe regulationns will also exxplain the rellationship beetween VA anndprogramss, plans, and projects. Thntal planningg process. Similar actionss willlocal, statte, regional, and tribal agencies in thee environmenndbe analyzzed the samee way under NEPA acrosss all VA progrram offices. VA will gain efficiency anPA approach that emphassizes a programmatic anaalysis ofefficacy frrom an agency‐wide NEPenvironmmental planniing and analyysis.Parrt 1, Page 10 of 15VA NEPAA Interim Guiidance ‐ Projjects30SEP10 draft
Specifically, the new VA NEPA regulations will update the current list of VA CATEXs. The CATEXs aswritten in the current regulations are too broad, requiring too much interpretation to use properly.The new regulations will present a CATEX list tailored to VA projects.The new regulations are expected to be promulgated in 2011. In the meantime, while as a federalagency, VA remains responsible for complying with NEPA analysis and documentationrequirements on all actions, this NEPA Interim Guidance ‐ Projects is intended to provide directionto VA employees on environmental planning and NEPA for projects as they currently represent thelargest, and most pressing, set of NEPA actions across the Agency.NEPA for VA Planning and ProjectsVA officials, employees, and contractors must comply with NEPA for federal actions undertaken bythe Agency. For example, NEPA is required when VA acquires land for hospitals, cemeteries, andother installations or when VA proposes to do a Minor project at one of its facilities. NEPA must bestarted early in the planning process ‐ before acquiring federal lands, accepting donations, orcontracting for the purchase of lands or before finalizing the design for an Minor project. NEPApromotes good project management and avoids unforeseen circumstances from
Interim NEPA Guidance Projects – Section One Introduction. The purpose of this Department of Veterans Affairs Interim NEPA Guidance(Interim Guidance) is to explain the requirements for environmental planning and how the pr
CEQ and the California Governor’s Office of Planning and Research (OPR) developed this handbook to provide advisory guidance on conducting joint NEPA and CEQA review processes. The CEQ oversees Federal agency implementation of NEPA, which includes writing the CEQ NEPA Regulations. 1. and preparing guidance and handbooks for Federal agencies .
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