What do NEPA and Swimming Have in Common? Streamlining!

Swimming-Inspired Tips for Streamlining your NEPA Document

I recently joined a local “masters” swim group and in the midst of a recent swimming set, it occurred to me we can draw a parallel between swimming streamlining and National Environmental Policy Act (NEPA) streamlining! I know, I’m a total NEPA nerd!

A critical part of swimming faster begins with holding good form off the wall – also known as holding the streamline position. Staying streamlined reduces resistance, maximizes your speed off the wall, minimizes energy loss, and sets you up for a fast finish. In swimming, going fast is more a function of your form and endurance. You can hone your form and swim faster by applying best practices.

Though I must admit it’s hard to keep the proper streamline form, especially when the swim set is long and tough, keeping form pays off with faster times. I can say the same for NEPA! In NEPA as in swimming, even though it’s hard at times, don’t let poor form slow your project down!

Streamlining is THE current NEPA buzzword. So what does it mean? It means accelerating your NEPA process in order to complete Environmental Assessments (EAs) and Environmental Impact Statements (EISs) in less time and in fewer pages. For example, some agencies have issued new mandates that significantly cut the time to prepare their EAs and EISs by more than half (1 and 2 years, respectively). Until now, this has been a big hurdle because, according to the National Association of Environmental Professionals Annual NEPA Report issued November 2018, the average time to prepare EISs has been more than four years.

Having recently attended a NEPA streamlining symposium and managed the preparation of several streamlined NEPA documents, I want to share with you some tips to help you streamline your NEPA document.

Here are our Top Five NEPA streamlining tips.

1. Prepare Focused Analysis (Streamline from the Start):
   • Develop a clear mutual understanding of the scope of work…EARLY. Once a request for proposal is issued (and prior to submittal of a cost proposal), have a scope clarification call with all parties to confirm the government-contractor team is on the same page with the scope; brainstorm what the resource areas of concern are likely to be. Don’t just carry forward all resource areas because that’s what you’ve always done.
   • Take a hard look and identify those resource areas that are likely to require only a limited analysis due to anticipated negligible or no impact. Not only will this help hone the level of effort, but it sets up a concise analysis on those resources that truly matter. A focused document makes for a shorter review time too!
2. Plan Early to Accommodate Future Changes (Stretch):
   • Project descriptions almost always change – typically after a submittal or two! To proactively address this, develop flexible project descriptions and project areas early so that the analysis can accommodate the changes when they happen.
   • Analyze a broader footprint to provide flexibility to potentially avoid or minimize the need for additional analysis (and modifications) in response to on-going design changes. This forward-thinking approach provides 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.
3. Hold Regular Bi-Weekly Meetings (Reinforce Streamlining):
   • Facilitate project understanding, minimize later questions, and achieve project efficiencies by holding regular team meetings. These bi-weekly meetings also keep the team informed on schedule progress and can resolve action items. They also help to hold the team accountable (even when it gets tough) and achieve the schedule goals.
   • Prepare focused agendas in advance of each meeting, keep the meetings streamlined (focused!) and fast-paced, and immediately send out meeting notes and the invite for the next one! Because you’ve already committed to streamlining your document (see Tip #1), use these meetings to help stay the streamlining course throughout your project!
4. Use a Template (Follow the Black Line):
   • Use agency templates. This enables reviewers to focus on the project description and analysis and not on new format or style or boiler-plate text. The use of a NEPA template can be a big time saver if the review team is aware and does not comment on “stock” language that the lead agency has prepared and approved during the template development.
   • Periodically review and refresh your template to make sure the information is still current (e.g., updating the template to reflect the forthcoming changes to the Clean Water Act definitions of jurisdictional features).
5. Schedule Comment Review/Resolution Meetings (Team Workout):
   • Hold in-person comment resolution meetings where all key team members assemble to review, discuss, agree, and make real-time changes to the document (especially important for fast-track projects).
   • These meetings enable the team to absorb and implement feedback quickly and shave days — if not weeks — off a project schedule.

By applying these and other tips, you will realize faster NEPA completions without sacrificing quality. You’ll find that just as one’s swim times will improve by streamlining one’s strokes, you will finish your NEPA documents faster the more you apply these streamlining techniques!

We look forward to continuing to guide you in improving the efficiency of your NEPA process so you can win the day. Contact us today to schedule a free consult: ryan.pingree@scoutenv.com.