Federal agencies recently memorialized their commitment to improving the efficiency of their environmental planning processes (i.e., National Environmental Policy Act [NEPA] documentation) without diminishing quality or informed decision-making. At Scout Environmental, we applaud this commitment and look forward to continuing to apply our innovations and project-based successes in completing NEPA documentation ahead-of-or on-schedule. In this month’s blog, I share some of our project-proven best practices for accelerating the completion of environmental planning documentation.
About a year ago (see April 2018 blog, Now’s the Time to Prepare Focused NEPA Documents, Faster!) I described how Mr. Boling, Associate Director for NEPA at the Council on Environmental Quality (CEQ) inspired NEPA practitioners to prepare more concise and faster NEPA documentation. Since that blog, Scout Environmental has worked with our client and industry partners to achieve ahead-of-schedule completions on several NEPA documents. Here are some project-proven techniques we found to be helpful:
- Programmatic Documentation. We recently completed two programmatic Environmental Assessments (EAs) (one was an EA/Overseas Environmental Assessment). The use of Programmatic EAs to address future covered actions can streamline the environmental planning process. In developing programmatic documents, we worked with our clients to ensure the team analyzed a wide range of future actions to facilitate future streamlined approvals. We strongly encourage the development of programmatic documentation, especially for recurring and predictable activities.
- Early Regulatory Engagement. All too often, the long pole in the NEPA schedule is completing regulatory approvals. Many regulatory agencies are short staffed and inundated with requests/applications for approvals.
- Proactive Engagement. We encourage our clients to proactively reach out to the responsible regulatory agencies for affected resources early in the process to give them a courtesy notification of the forthcoming action and incorporate any early input they may have.
- Understanding Agency Perspective. Having an experience-based perspective/understanding of regulatory agency’s main concerns, and proactively addressing them in the documentation also reduces the costly back and forth of requests for information. We work with our clients to identify these anticipated needs and make sure the submittal packages clearly address their concerns. Submitting complete (and anticipatory) packages streamlines the approval process.
- Site Visits. Schedule a site visit for the regulators to walk the affected area with the client and increase understanding of the resources, their condition, and potential for impact. It encourages questions and answers leading to efficient resolution. We have found that a few hour site visit can efficiently address questions that may have taken dozens of office days to resolve. Plus, the field visit provides the opportunity to develop and sustain relationships, relationships that will provide efficiencies for future agency reviews on other projects.
- Programmatic Agreements. Establish programmatic agreements (e.g., for cultural resources, certain species/habitats, etc.) that can be incorporated by reference in the analysis and can be used as a basis for any subsequent mitigation. While this would take time to develop, once in place, future projects will realize substantial time savings.
- Defining Larger Project Areas. We understand that many projects start off with a lack of clarity as to the extent of the project footprint and sometimes, project activities, which can result in project delays to perform additional analysis. On one project that was going to potentially be subjected to future minor modifications, we purposefully analyzed a broader footprint to allow flexibility to ideally avoid or minimize the need for additional analysis in response to on-going design changes. This forward-thinking innovation (borne on the back of lessons learned from other projects) provided the project team the ability to efficiently accommodate later minor changes in the project description without having to update/add on to the NEPA analysis.
- Focused Analysis. Inspired by Mr. Boling, we took a hard look at a recently submitted first Draft EA and reduced extraneous text and analysis that could be repackaged into a more concise (yet informative) discussion. With the clients’ support, we cut over 40% of the EA’s length; the resulting submittal went from 142 to 81 pages. The tighter, more-focused EA earned praise from the project team reviewers, especially as the revised analysis substantially reduced document review times.
- Asking the Right Questions Early. Scope-of-work confirmation calls give the contractor the opportunity to talk through the scope, approach, and key issues, making sure that the team is aligned and has identified all key issues. Waiting until the kickoff meeting is too late. Sometimes overlooked items are needed, and that results in delays to process project modifications.
- Tiger Team Meetings. While this is not a new idea, I believe there’s no substitute for bringing key reviewers and authors together to efficiently address comments and agree (on the spot) to resolution. We recommend these meetings be a standard step to immediately follow the first complete submittal (e.g., first Draft EA).
- Increased Partnership. We can accomplish so much more together. Working with actively engaged, client project managers results in greater efficiencies. Our collective experiences must be shared, especially so we can apply lessons learned and time saving techniques.
- Bi-Weekly Project Team Meetings. Again, not a new idea, but we have found that regular team meetings facilitate project understanding, minimize later questions, and result in improved efficiencies.
- Quality Submittals. Quality submittals result in fewer comments. Fewer comments require less time to respond, which results in accelerated next submittals. At Scout Environmental we pride ourselves on submitting quality documents every time, free from major technical errors and distracting grammatical/spelling errors. Which, in the end, result in faster projects. On a recent project, the Scout Environmental-led team was recognized for the overall quality of our deliverables, which when combined with a focused analysis and timely delivery, supported the Navy’s review times and contributed to shaving four months of the schedule.
In summary, the recent emphasis on improving the efficiency of environmental planning documentation is not new to us; we’ve been implementing and achieving aggressive timelines for some time now, to the benefit of our clients. We look forward to continuing to “lead the way” to improving the efficiency of the environmental planning process in partnership with our clients and industry. For further information, please contact me at email@example.com.