NEPA and Environmental Planning : Tools, Techniques, and Approaches for Practitioners - Chapter 2 pot

21 2 Tools, Techniques, and Approaches for Improving and Streamlining NEPA This chapter describes tools, techniques, and approaches for improving and streamlining National Environmental Policy Act (NEPA) and environmental planning problems. As illustrated by the following story, the success that an agency has in streamlining or improving NEPA is, to a large measure, dependent on how that agency chooses to practice the Act. 2.1 NEPA AND PROCESSIONARY CATERPILLARS As many biologists will testify, processionary caterpillars meander their way through tree branches, each one with its head tted snugly against the rear extremity of its predecessor. The long, winding procession thus formed gives the caterpillars their aptly deserved designation. Intrigued by this behavior, the naturalist Jean-Henri Fabre lured a colony of these creatures onto the rim of a pot. In due time, the caterpillars began to snuggle up to one another, and after forming an interconnected chain eventually began to move around in a large circle. Since the chain had no beginning or end, Fabre expected that the caterpillars would soon tire of this unceasing parade and head off in a new direction. Such was not the case. Fascinated, Fabre placed a supply of food next to them, but to no avail. Undeterred by the food that was outside the domain of their circle, the caterpillars continued on. To his dismay, apparently propelled by sheer force of habit, the creeping circle continued edging ever onward in the same unceas- ing circle for 7 days and 7 nights. Finally, exhaustion and starvation did them in. The moral of the story is that they were unable to break convention and venture out beyond their established paradigm. 1 2.1.1 IMPROVING FEDERAL PLANNING Today, federal agencies are increasingly being asked to do more with less. Efciency is vital to the goal of successfully implementing its mission. Thus, to avoid going the way of the processionary caterpil- lars, agencies must be open to new and more effective paradigms for complying with environmental requirements. This goal requires an institutional framework within which modern methodologies can be applied to improve the planning process. Perhaps most importantly, there must be a top-down will- ingness to accept modern tools, techniques, and approaches for improving planning processes. Once innovative approaches have been instituted, practitioners must be trained to use them. For example, the U.S. Army reports that training is a particularly valuable instrument for streamlining NEPA. Professionals are kept abreast on the latest approaches for implementing its requirements. The following sections have been written to assist agencies in improving their environmental planning and analysis processes. 2.2 SLIDING SCALE AND THE RULE OF REASON Professional judgment and common sense must be exercised in determining the appropriate scope of an analysis. Because the following two principles provide powerful tools for reducing cost, delays, and the amount of effort expended in implementing NEPA, they will be referred to throughout this chapter. CRC_7559_CH002.indd 21CRC_7559_CH002.indd 21 2/5/2008 2:42:34 PM2/5/2008 2:42:34 PM © 2008 by Taylor & Francis Group, LLC 22 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners 2.2.1 THE SLIDING-SCALE APPROACH The sliding-scale approach recognizes that the amount of effort expended in performing an analy- sis is a function of the particular circumstances involved in each case. A sliding-scale approach is justied based on the following regulatory directions. Impacts shall be discussed in proportion to their signicance. There shall be only brief discussion of other than signicant issues. (40 CFR § 1502.2[b]) NEPA documents must concentrate on the issues that are truly signicant to the action in question, rather than amassing needless detail. (40 CFR § 1500.1[b]) Thus, environmental issues are investigated and regulatory requirements are applied using a degree of effort commensurate with their importance. In other words, the amount of effort expended in investigating or addressing a specic regulatory issue should generally vary with the signicance of the potential impact and its importance to the decision-making process. 2.2.2 RULE OF REASON Professional experience suggests that a strict or unreasonable application of a regulatory require- ment may lead to a course of action, decision, or level of effort that is wasteful or even absurd. The Rule of Reason is a mechanism used by the courts to inject reason into the NEPA process. In other words, common sense must be exercised in determining the scope, detail, and attention devoted to issues, alternatives, and impacts considered in the analysis. 2.3 STREAMLINING AN AGENCY’S NEPA PROCESS In the mid-1990s, a vice president of a contractor working at the U.S. Department of Energy’s Hanford Site issued a memorandum listing the top 10 processes responsible for delaying site projects. The site procurement and NEPA processes were both listed in this memorandum as signicant problems. Instead of denying that a problem existed or placing blame elsewhere, a proactive effort was mounted to identify approaches for improving the site-wide NEPA process. The author was assigned to an interdisciplinary team (IDT) to investigate and streamline this process. Two value engineering (VE) studies were performed. The rst study examined the NEPA pro- cess in an effort to identify root problems for inefciencies and develop a list of recommendations for streamlining NEPA. A second study was then performed to determine how NEPA could be better integrated into site planning and decision-making. As it turned out, the site planning process was complicated and was being performed by a number of independent departments. The goal of this second study was twofold: (1) to prevent project delays by ensuring that NEPA was triggered early in the planning process and (2) to improve the effectiveness of NEPA in contributing to the Department of Energy (DOE) decision-making process. A VE approach that was used to examine the NEPA process is briey summarized in the next section. As described in the companion book, Environmental Impact Statements, it is important to note that VE techniques can also be used as a tool for helping to assess the scope or issues consid- ered in an environmental impact statement (EIS). Data such as the length of time required to complete NEPA projects were not collected prior to the VE workshops described above. Therefore, there were no statistics available for gauging the level of success these VE workshops attained in terms of streamlining NEPA. However, there was a general consensus among management that the VE efforts led to a substantially streamlined NEPA process and also improved the ability of NEPA to contribute to the early decision-making process. Perhaps most important, as a result of these improvement efforts, NEPA was dropped from the list of 10 biggest problems on the Hanford Site. CRC_7559_CH002.indd 22CRC_7559_CH002.indd 22 2/5/2008 2:42:34 PM2/5/2008 2:42:34 PM © 2008 by Taylor & Francis Group, LLC Improving and Streamlining NEPA 23 An overview of the VE process and how it can be adapted to resolve problems in NEPA are described below. 2.4 VE IMPROVEMENT PROCESS The Society of American Value Engineers (SAVE) has revised the VE terminology, redening VE as the Value Methodology for which new standards have been published. However, consistent with com- mon usage in the engineering disciplines, this book will use the more traditional terminology of VE. 2 A VE workshop can be an intensely focused effort, such that a large amount of work can be accomplished in a very short period. In determining the preliminary scope, the goal is to leave no stone unturned. Typically, a VE facilitator leads an IDT through a number of rigorous procedures designed to break down preconceived and prejudicial notions and to consider new and alternative concepts that might lead to better solutions. 3 The facilitator is responsible for keeping the session focused and for promoting an open and nonhostile atmosphere where prevailing assumptions, mind- sets, and paradigms are challenged to identify more optimal solutions. Prejudicial and preconceived notions are openly challenged as the IDT identies factors and solutions that might otherwise be overlooked. The typical sequence of steps is shown below. 2.4.1 PRELIMINARY REVIEW As a rst step in the typical VE process, a preliminary review or pre-study (e.g., on a specic pro- posal, program, project, process, or design) may be useful in determining if the potential return on investment is sufcient to justify a formal VE workshop. Emphasis is placed on examining the proposal/activity to determine if potential alternatives show promise for increasing value. If a VE study is deemed to be cost-effective, the pre-study is also used to 1. dene the scope, objectives, and expected deliverables; 2. establish logistical elements necessary to ensure a successful result; 3. gather preliminary information; and 4. select the study group’s membership. If a decision is made to proceed into a formal VE workshop, a facilitator is assigned and charged with responsibility for leading the VE team. An IDT is carefully selected to include professionals possessing a diverse range of technical expertise and experience. The team challenges existing paradigms and assumption in an effort to identify new or alternative concepts that may lead to bet- ter solutions. 3 As outlined next, the general VE process consists of a sequence of distinct steps or phases. 2.4.2 SEVEN PHASES A standard VE study normally consists of the following seven distinct phases. Each of these phases, together with an emphasis on how they can be used to improve NEPA, is described in the following sections: Phase 1: Information phase Phase 2: Functional analysis phase Phase 3: Creativity phase Phase 4: Evaluation and analysis phase Phase 5: Development phase Phase 6: Presentation phase Phase 7: Post study/Implementation phase • • • • • • • CRC_7559_CH002.indd 23CRC_7559_CH002.indd 23 2/5/2008 2:42:35 PM2/5/2008 2:42:35 PM © 2008 by Taylor & Francis Group, LLC 24 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners With respect to streamlining the NEPA planning process, not all of the following phases are neces- sarily pertinent or need to be performed. Professional judgment must be exercised, on a case-by-case basis, in determining those phases that can be most effectively integrated with NEPA planning. 2.4.2.1 Phase 1: Information Phase Information pertinent to the scope of the proposal (or action under investigation) is collected and disseminated to the members of the VE study. Limitations and constraints that may affect the study results are identied and, if necessary, ranked with an assigned value. For example, information could be shared regarding how plans are formulated and who is responsible for making certain types of decisions. 2.4.2.2 Phase 2: Functional Analysis Phase A tool referred to as a “function analysis system technique (FAST) diagram” is frequently developed as part of a standard VE workshop. The FAST diagram can be used to critically evaluate “how” ver- sus “why” critical functions are currently performed or would be performed. For example, a FAST diagram might be prepared to question why certain steps in the planning process are carried out. Items that have high potential for added value may be earmarked for more detailed examination in the later study. However, a FAST diagram does not necessarily generate information useful to improving an agency’s NEPA process. Because of the amount of effort necessary to construct a FAST diagram, its utility (with respect to improving the NEPA planning process) should be carefully questioned before an effort is launched to prepare such a diagram. 2.4.2.3 Phase 3: Creativity Phase Team participants are encouraged to exercise creativity with the objective of identifying potential solutions for solving a particular problem. Methods such as brainstorming are used to generate innovative ideas for more detailed consideration. For example, ideas could be sought for streamlin- ing various aspects of the agency’s planning process. 2.4.2.4 Phase 4: Evaluation and Analysis Phase In this phase, ideas generated during the creativity phase are organized into concepts possessing similar features. These can then be solidied into potential alternatives and ranked using one of a variety of techniques. One ranking technique that has been used is referred to as “Criteria Weighting Matrix and Evaluation Analysis Ranking.” Another ranking technique known as the “Nominal Group Tech- nique” is described in Table 2.1. Options are then evaluated with respect to their advantages and disadvantages. For example, this phase could be used to single out ideas that show the most promise for streamlining the NEPA process. 2.4.2.5 Phase 5: Development Phase Potential improvement options deemed to have the greatest potential for improving the NEPA pro- cess during the analysis step are further evaluated and developed into viable, efcient, and cost- effective options or alternatives. 2.4.2.6 Phase 6: Presentation Phase Options for improving the NEPA process are documented in a report and presented as a study proposal. CRC_7559_CH002.indd 24CRC_7559_CH002.indd 24 2/5/2008 2:42:35 PM2/5/2008 2:42:35 PM © 2008 by Taylor & Francis Group, LLC Improving and Streamlining NEPA 25 2.4.2.7 Phase 7: Post Study/Implementation Phase The workshop recommendations are considered and evaluated by the team and management. Tasks are assigned to individuals who are then responsible for implementing the chosen recommendations for improving NEPA. 2.4.3 USING VE IN PREPARING AN EIS The Ofce of Management and Budget has directed federal agencies to apply VE in planning major federal projects exceeding a cost of $1 million. 4 As a result, both the EIS and the VE are mandated to be performed on major federal projects. However, this raises a question: Is this simply another case where overlapping or redundant requirements have been mandated? This question can best be answered by examining the underlying purposes of VE and NEPA. VE provides a tool box of problem-solving techniques for analyzing problems and identifying solutions. However, VE is not a planning process. In contrast, NEPA provides a comprehensive planning process, but lacks a set of intrinsic tools for effectively implementing its procedural requirements. Thus, VE offers a set of tools that, potentially, can manage various aspects of the EIS planning process. To date, this connection appears to have gone largely unrecognized. An integrated NEPA/VE planning approach for complex projects such as pre- paring a programmatic EIS may be advantageous as it provides an efcient means for complying with both Council on Environmental Quality (CEQ) and the Ofce of Management and Budget mandates. 2.4.3.1 Comparison of VE with NEPA Table 2.2 compares principal characteristics and goals of NEPA with those of VE. While NEPA and VE share strikingly similar goals and requirements, they are not redundant; in fact, not only are NEPA and VE compatible, but also they complement each other. Their commonality in goals provides a foundation in which VE can be used as a tool for increasing the effectiveness of an EIS planning process. However, it should be noted that although VE and NEPA share many common requirements, their underlying goals differ. While VE offers many tools and techniques useful in managing the NEPA process, its orientation is different. The objective of VE is toward identifying and solving root problems that are related to, but are not normally the underlying focus of, an EIS scoping effort. Accordingly, a successful strategy requires prudence in the selection of the appropri- ate VE techniques that will be useful in preparing specic aspects of an EIS. TABLE 2.1 The Nominal Group Technique Step 1: Generate ideas The facilitator asks group members to write down the important problems or options for resolving these problems. Team participants write their ideas on note cards. Step 2: Record ideas A round-robin approach is used to record the ideas generated in Step 1. This process continues until all items have been recorded. Next, to prevent confusion, the facilitator asks each participant to explain briey the items submitted. Participants are not allowed to criticize or critique any of the suggestions during this phase. Step 3: Polling A potentially long list of ideas must be narrowed down to capture the most salient ideas. Many methods exist for accomplishing this task. One common method is to have each participant write down three ideas considered to be the most important. These techniques are tabulated by the facilitator. A second round is then conducted to prioritize the nal list of ideas. CRC_7559_CH002.indd 25CRC_7559_CH002.indd 25 2/5/2008 2:42:35 PM2/5/2008 2:42:35 PM © 2008 by Taylor & Francis Group, LLC 26 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners 2.5 USING VE IN DETERMINING THE PRELIMINARY SCOPE OF AN EIS This section describes how the author used a modied VE workshop approach in performing a prescoping effort for a complex EIS. A paper previously published by the author describes this approach in more detail. 15 As described earlier, pursuing a standard VE study is deemed at times to be an ineffective use of scarce resources. A considerable degree of forethought and professional experience is therefore required in devising a cost-effective approach for using a VE approach in scoping an EIS. Accordingly, emphasis was placed on developing an approach where VE techniques could be used specically to focus and manage various aspects of the prescoping effort. Once a strategy had been developed, an agenda and workshop mission statement were prepared to provide a tangible map for implementing the strategy. The following process can be modied for use in perform- ing a public scoping process and in identifying, evaluating, and managing other issues in the EIS process. Results of this prescoping workshop provided an early indication of the issues, problems, and levels of effort that would be required if it was found advisable to prepare an EIS. Determining the preliminary scope also provided a basis for forecasting the cost and resources required in preparing the EIS. Table 2.3 provides a simplied agenda, while Table 2.4 describes the goals and objectives for this prescoping workshop. Table 2.3 should be revised, as necessary, for performing a formal public scoping process. 2.5.1 ASSEMBLING AN IDT To ensure that all relevant planning factors were captured, emphasis was placed on assembling an IDT of experts. Approximately 10 full-time and 15 part-time members participated. The prescoping workshop ran over four consecutive days. TABLE 2.2 Comparison of VE with NEPA VE NEPA VE provides management tools useful in planning. NEPA is a planning process. The Ofce of Management and Budget has mandated that VE be applied to the planning of all major projects. NEPA is the only federally mandated planning process applicable to all major federal actions. Uses a systematic and interdisciplinary process to arrive at a better value solution. Is predicated on use of a “systematic interdisciplinary” approach. 5 Provides an important tool for assessing planning problems. “Combines” 6 other federal planning processes during the “early” 7 planning phase. Based on an unbiased and rigorous process. Requires the use of a “public,” 8 unbiased, 9 and “rigorous” process. 10 VE should be applied early enough to assist in decision- making. It is not intended to justify decisions already made. An EIS must be prepared early enough to serve as an important contribution to decision-making. The EIS is not to be used to rationalize or justify decisions already made. 11 VE can be used to assess planning requirements (e.g., cost, schedule, environmental). NEPA allows the consideration of cost and other factors in the analysis and decision-making process. Necessitates a full and fair analysis of alternatives to improve the value of the nal product. An EIS analysis must provide a “full and fair discussion” of impacts and reasonable alternatives. 12 Promotes consideration of all possible alternatives. An EIS must explore and objectively evaluate all reasonable alternatives. 13 Alternatives form the “heart” of the EIS. 14 CRC_7559_CH002.indd 26CRC_7559_CH002.indd 26 2/5/2008 2:42:35 PM2/5/2008 2:42:35 PM © 2008 by Taylor & Francis Group, LLC Improving and Streamlining NEPA 27 A kick-off meeting was held prior to initiating the VE workshop to discuss its purpose and objectives, and to assign action items. The prescoping workshop mission statement and agenda were distributed at the meeting. Certain members were identied and requested to prepare presentations for the information sharing session to be held on the rst day. TABLE 2.3 Integrated EIS/VE Prescoping Agenda Day 1 1. Welcome and introductions (session guidelines and expectations). 2. Overview of the problem statement, agenda, VE, and EIS process. 3. Information sharing session. 4. Document potential decision-making assumptions. 5. Preparation of a FAST diagram for the no-action alternative. Day 2 1. Brainstorming session to identify criteria that might affect future decisions; and identify high-level decisions that might need to be addressed by the EIS. Rank decisions in importance. 2. Construction of a DIT (summarized below). Day 3 1 (a) List, consolidate, and prioritize preliminary scope of facilities, functions, and issues to be considered in the EIS. 1 (b) Based on the key issues, develop a list of facilities and functions that would need to be analyzed in the EIS. 2 (a) De-scoping: determine issues that will not be included in the preliminary scope of the EIS. 2 (b) Document issues that are important but not included in the preliminary scope so that they can be revisited at a later date. Some issues might be agged as candidates for later tiering. 3. Identify any outstanding issues or concerns. 4. Brainstorm ideas for reducing EIS cost and schedule in order to identify specic actions that can be taken to help streamline the scope and EIS process. Day 4 1. Wrap-up: Assign actions and prepare for managerial presentation. • • TABLE 2.4 Goals and Objectives of the Prescoping Workshop Goals of the scoping workshop • Determine preliminary scope of the actions, facilities, and operations requiring evaluation in the EIS. • Identify methods for streamlining the EIS process. • Dene the scope of decisions that might need to be considered in the future. • Reduce risk of later surprises (i.e., changes in scope resulting from inadequate communications or planning). • Provide a basis for determining the cost and schedule of the EIS. Objectives of the scoping workshop • Develop a FAST diagram of the no-action alternative. • Determine the underlying need for taking action. Identify the purpose (objectives) that the proposal will need to meet. • Construct a DIT to determine specic decisions that might need to be made (described in Chapter 8). • Identify key issues and concerns. • Identify factors that might inuence the decision-making process. • Determine issues that will not be included in the scope (de-scoping). • Document issues that are important but not to be included as part of this scope, so that these issues can be revisited at a later date (i.e., later tiering). CRC_7559_CH002.indd 27CRC_7559_CH002.indd 27 2/5/2008 2:42:35 PM2/5/2008 2:42:35 PM © 2008 by Taylor & Francis Group, LLC 28 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners 2.5.2 INFORMATION PHASE The prescoping workshop began with a review of the workshop mission statement and an explana- tion of the process and techniques used. The workshop then proceeded to the information phase, which was used to gather and share information that might have a bearing on determining the preliminary scope. Issues such as other ongoing NEPA activities, inconsistencies, gaps in NEPA documentation, related documents and studies, and other related or planned projects were identied during this phase. Information such as keywords, memories (e.g., ideas and concepts), issues and concerns, and assumptions were captured on ip charts. The facilitator was responsible for keeping the session focused on schedule. Except for cases where unusual circumstances exist, it is recom- mended that this phase be limited to no more than a few hours. An exercise was performed to identify key planning assumptions. A brainstorming exercise then followed in which the facilitator challenged the group to identify assumptions important to this planning effort. Assumptions identied during the remaining portion of the workshop were Similarly, an exercise was performed to identify principal planning documents and studies that might have a bearing on the preparation of the EIS. Capturing such information at this early plan- ning phase is important, not only because it may affect the scope, but also because it could prevent duplication and wasted effort. A ip chart list was also maintained for capturing special issues and concerns raised throughout the workshop. Such a list should be referred to both in preparing the formal EIS scoping process and in preparing the actual analysis. 2.5.3 DECISION-IDENTIFICATION PHASE An EIS cannot properly support subsequent decision-making if it does not correctly anticipate and address decisions that might require future consideration. While such an observation appears obvi- ous, it is not uncommon to nd that the EIS has been completed only to discover that it does not adequately anticipate the types of decisions that actually needed to be considered. Such discrepan- cies frequently result from disconnects between the scope of the analysis and the actual decision- making that follows. This observation is particularly true when dealing with complex actions or dynamic circumstances. For this reason, the prescoping workshop used a systematic approach developed by the author and referred to as decision-based scoping (DBS) and decision-identication tree (DIT), which is in marked contrast to the way most scoping efforts are typically conducted. A DBS approach is espe- cially well suited for large or complex EISs, and in scoping programmatic EISs. The DIT provided a systematic methodology for identifying and mapping potential decisions that might need future consideration by a decision-maker and which therefore need to be addressed in the scope of the EIS. The DBS and DIT are both detailed in Chapter 8. 2.5.4 UNDERLYING NEED AND PURPOSE: DEFINITION In support of the DBS approach, an effort was mounted to dene the underlying need for future action in a succinct manner. Identifying and properly dening the “need” for taking action can be deceptively complicated. The need might at rst appear intuitively obvious, yet on closer inspec- tion confusion or differing views as to its true meaning may arise. Note that Webster’s Dictionary denes “need” as “a want of something requisite, desirable, or useful.” To this end, the group was challenged to identify the underlying need(s). Responses voiced by the participants were recorded on a ip chart by the facilitator. Next, the group reviewed, sorted, and consolidated these responses to develop the required succinct denition of the primary or underly- ing need. Similarly, an exercise was conducted to determine potential objectives to aid in identify- ing the underlying purposes. As detailed in the companion text, Environmental Impact Statements, CRC_7559_CH002.indd 28CRC_7559_CH002.indd 28 2/5/2008 2:42:36 PM2/5/2008 2:42:36 PM © 2008 by Taylor & Francis Group, LLC continuously added to the flip chart list. Improving and Streamlining NEPA 29 precise denition of the underlying need is an important rst step to take because it can drive the range of alternatives that will be investigated later. 16,17 Not surprisingly, even a small change in the denition of need can have profound implications on the alternatives that are eventually chosen for analysis. Thus, correctly dening the need at this early stage can substantially improve the effec- tiveness of the planning process that follows. Once consensus was reached regarding the need, the IDT was tasked with dening the pur- pose for taking action. The term purpose should not be confused with the term need. “Purpose” is dened in Webster’s as a “goal” or “object” to be obtained. 2.5.5 ENHANCING EFFECTIVENESS OF THE EIS PROCESS An effort was also mounted to identify methods and approaches for reducing cost and expediting preparation of an EIS. Brainstorming techniques were used to elicit ideas from participants in an attempt to investigate every conceivable method for improving the efciency and effectiveness of the potential EIS. The facilitator recorded suggestions offered by the participants on ip charts. Special VE techniques were used to evaluate these suggestions. The evaluation consisted of three distinct stages or rounds. In the rst round, the group reviewed all the suggestions in an attempt to eliminate those that were clearly unreasonable or of little value. Item by item, the facilitator led the IDT through each suggestion in an attempt to identify which of them could be dropped. The rule used in this round was that unanimous consensus had to be obtained before an item could be eliminated. Because of time constraints, the second and third rounds that followed were actually combined into a single round for this EIS effort. Normally, the second round consists of consolidating and combining suggestions into manageable categories. The third and nal round normally involves the use of matrix weighting methods, such as a nominal group technique, in an effort to generate a nal list of concepts. On completing this task, the team formulated specic recommendations that could be undertaken to expedite preparation of an EIS. As a nal step, success-oriented criteria (e.g., cost and schedule considerations, ease of implementation, and budget constraints) were used to prioritize the recommendations for consideration by decision-makers. 2.5.6 INVESTIGATING THE NO-ACTION ALTERNATIVE Where an EIS is being prepared for a complex proposal or program, the IDT might also want to consider preparing a FAST diagram to assess activities currently being conducted as part of the no-action alternative. The FAST diagram technique is founded on the observation that a rigorous evaluation of functions underlining a particular process provides a basis for evaluating problems and alternatives. The FAST diagram provides a systematic tool for identifying these functions. Process functions were rst identied and described using sentences containing active verbs and proper nouns. Using these functions, a diagram was constructed illustrating “how” and “why” particular functions are conducted. Scanning the diagram from right to left reveals “why” particular functions are performed. Conversely, scanning the diagram from left to right reveals the sequence of “how” functions are conducted. When completed, the sequence of how functions are conducted should be internally consistent with the reason why each function is conducted. Next, an effort was undertaken to identify methods for improving or optimizing a program func- tion. A FAST diagram can provide a useful tool for understanding the current baseline, identifying functional requirements and relationships, and challenging preconceived assumptions and ideas. Where appropriate, other planning considerations such as resource and infrastructure requirements may also be identied. As described in Section 2.4.2.2, preparation of a FAST diagram can be resource intensive, con- suming a substantial amount of a scoping workshop schedule. And, as previously stated, in some cases a FAST diagram might contribute valuable information, whereas in other cases little or no CRC_7559_CH002.indd 29CRC_7559_CH002.indd 29 2/5/2008 2:42:36 PM2/5/2008 2:42:36 PM © 2008 by Taylor & Francis Group, LLC 30 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners benet would be derived from its construction. Lacking a clear and specic objective for its use, practitioners are ill-advised to devote scarce resources constructing a FAST diagram. For this rea- son, it is well to reiterate that prudence and professional judgment must be exercised in determining the appropriate use and application (if any) of a FAST diagram with respect to scoping. 2.5.7 ELIMINATING ISSUES FROM THE SCOPE One of the principal objectives of the scoping process is to eliminate unimportant issues. De- scoping is a powerful method for reducing the cost of an EIS and it is a requirement that is often underuti- lized. 18 Efforts should be focused on eliminating insignicant or irrelevant issues. Properly applied, such a method can substantially reduce time and resources required in preparing an EIS. Partly for this reason, an effort was mounted to identify candidate issues for elimination dur- ing the formal scoping process. Emphasis was placed on documenting issues that were considered important but eligible for deferral from the immediate scope of this EIS. These issues could thus be revisited, if necessary, at a later date (some issues might be agged as candidates for later tiering). 2.5.8 IDENTIFYING OTHER RELATED REQUIREMENTS Regulatory requirements can profoundly inuence cost, schedules, and the direction of future actions. For this reason, it is recommended that an exercise be performed to identify other related environmental and regulatory drivers. For example, a preliminary matrix might be prepared of potential regulatory requirements versus potential alternatives that eventually would be analyzed. A regulatory compliance matrix provides a “heads-up” so that the agency is not surprised by unanticipated requirements that may emerge later. The stage is now set for presenting the results. 2.5.9 FINALIZING THE PRESCOPING EFFORT The nal phase involved is presenting the results of the prescoping workshop. Focused toward peer review, this phase allows the agency and decision-maker(s) to review the potential scope to deter- mine if issues that have not been addressed remain. In this case, the general consensus was that construction of the DIT, in conjunction with the VE workshop, had been very effective in identifying what was otherwise a rather enigmatic set of potential issues and actions. With only one exception, the prescoping workshop successfully identied principal issues and actions considered essential for analysis. It is important to note that at this stage the scope is still preliminary and may evolve once addi- tional information or public scoping comments are received. Still this effort was very effective in providing an early indication of the scope, which was useful in planning the public scoping process, identifying agency consultations, preparing cost estimates and schedules, and developing prelimi- nary engineering and environmental support studies. Once this step has been completed, the stage is now set for preparing and issuing a notice of intent (NOI), which completes the prescoping phase. A facilitated workshop approach such as the one described above may also offer a useful tool for effectively managing and performing formal public scoping sessions. Such an approach also has the advantage of ensuring that each participant has an opportunity to provide feedback and voice opinions. 2.6 A STRATEGY FOR EFFICIENTLY IMPLEMENTING A POLLUTION PREVENTION PROGRAM In 1990, the U.S. Congress passed the Pollution Prevention Act. 19 President Clinton issued an executive order instructing federal agencies to implement pollution prevention (P2) measures in 1993. 20 Similarly, the International Organization for Standardization (ISO) has developed a series of CRC_7559_CH002.indd 30CRC_7559_CH002.indd 30 2/5/2008 2:42:36 PM2/5/2008 2:42:36 PM © 2008 by Taylor & Francis Group, LLC [...]... a top-level policy committed to P2 © 20 08 by Taylor & Francis Group, LLC CRC_7559_CH0 02. indd 43 2/ 5 /20 08 2: 4 2: 4 2 PM 44 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners As described in Section 2. 6, ISO 14001 provides a top-down policy for ensuring that P2 is actually incorporated at the operational level, whereas NEPA provides an ideal framework for evaluating and. .. specifications for performing the planning function For example, specific procedures and requirements with regard to scoping, investigating environmental aspects, defining © 20 08 by Taylor & Francis Group, LLC CRC_7559_CH0 02. indd 41 2/ 5 /20 08 2: 4 2: 4 1 PM 42 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners temporal and spatial bounds, interpreting significance, and other... CRC_7559_CH0 02. indd 33 2/ 5 /20 08 2: 4 2: 3 7 PM 34 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners Figure 2. 2 Documented CATX? No Yes Prepare CATX documentation Determine applicability of P2 Are P2 measures applicable? No P2 not applicable Yes Prepare and attach P2 checklist to CATX Transmit copy of P2 checklist to some oversight entity such as a P2 program Office for review... (blocks 2, 3, and 4) that are performed principally using the standard NEPA process: 1 Planning 2 Analyzing potentially significant impacts 3 Decision-making © 20 08 by Taylor & Francis Group, LLC CRC_7559_CH0 02. indd 44 2/ 5 /20 08 2: 4 2: 4 2 PM Improving and Streamlining NEPA Optional path 45 1 Establish policy 2 Planning phase Begin environmental impact assessment (EIA) process and integrated environmental planning. .. Performed primarily under an AM/EMS Corrective action • Revise plan to correct deficiencies and improve environmental performance FIGURE 2. 8 Monitor • Review performance of policy/plan Conceptual process for integrating NEPA s AM process with an EMS © 20 08 by Taylor & Francis Group, LLC CRC_7559_CH0 02. indd 51 2/ 5 /20 08 2: 4 2: 4 4 PM 52 NEPA and Environmental Planning: Tools, Techniques, and Approaches for. .. CRC_7559_CH0 02. indd 37 2/ 5 /20 08 2: 4 2: 4 0 PM 38 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners 2. 7 NEPA AND ISO 14001 The effectiveness of NEPA as a planning tool is sometimes diminished because it has not been properly either implemented or integrated into agency’s planning process In 1996, the author began investigating commonalities and similarities which existed between NEPA. .. administrative record and NEPA documents as part of the EMS system for maintaining records; • integrating NEPA mitigation commitments with other related regulatory requirements and EMS objectives and targets; © 20 08 by Taylor & Francis Group, LLC CRC_7559_CH0 02. indd 39 2/ 5 /20 08 2: 4 2: 4 0 PM 40 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners • including NEPA impact assessments... assumes that the action and its impacts are essentially trivial, and it is therefore not practical to review the action for potential P2 measures If the CATX requires documentation (“yes” path, diamond labeled © 20 08 by Taylor & Francis Group, LLC CRC_7559_CH0 02. indd 35 2/ 5 /20 08 2: 4 2: 3 9 PM 36 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners Figure 2. 4 Begin internal scoping... 2/ 5 /20 08 2: 4 2: 3 7 PM 32 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners TABLE 2. 7 Integrating NEPA with Other Environmental Processes • • • Integrate the requirements of NEPA with other planning and environmental review procedures required by law or by agency practice so that all such procedures run concurrently rather than consecutively (§ 1500 .2[ c]) Integrating NEPA. .. 45 2/ 5 /20 08 2: 4 2: 4 2 PM 46 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners Drawing on expertise and experience from a diverse array of planning requirements and entities, an interdisciplinary effort may be used in developing an implementation plan (IP) The IP might be prepared for a major federal program or installation In other cases, an IP might be prepared for a . ideas. CRC_7559_CH0 02. indd 25 CRC_7559_CH0 02. indd 25 2/ 5 /20 08 2: 4 2: 3 5 PM2/5 /20 08 2: 4 2: 3 5 PM © 20 08 by Taylor & Francis Group, LLC 26 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners 2. 5. tiering). CRC_7559_CH0 02. indd 27 CRC_7559_CH0 02. indd 27 2/ 5 /20 08 2: 4 2: 3 5 PM2/5 /20 08 2: 4 2: 3 5 PM © 20 08 by Taylor & Francis Group, LLC 28 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners 2. 5 .2. EAs. CRC_7559_CH0 02. indd 35CRC_7559_CH0 02. indd 35 2/ 5 /20 08 2: 4 2: 3 9 PM2/5 /20 08 2: 4 2: 3 9 PM © 20 08 by Taylor & Francis Group, LLC 36 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners “