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

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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.
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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.
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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
•
•
•
•
•
•
•
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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.
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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.
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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
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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).
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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,
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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
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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
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Improving and Streamlining NEPA 31
environmental management, auditing, and performance standards known as the ISO 14000 series;
the ISO 14000 series speaks to the merits of pollution prevention, particularly from the standpoint
of establishing a top-level policy committed to pollution prevention.
The following section describes a systematic strategy developed by the author for effectively
integrating P2 objectives with DOE Hanford Site projects and operations. This integrated NEPA/P2
strategy received two Secretary of Energy commendations. The purpose of the following example
is to illustrate how a federal facility’s NEPA planning process can be used to efciently implement
a P2 program.
Because project requirements, procedures, operations, and the details of each agency’s NEPA
process vary, the readers should consider this example from the perspective of how it can be adapted
to their own specic internal projects and programs.
2.6.1 NEPA PROVIDES AN IDEAL IMPLEMENTATION MECHANISM
With very few exceptions, all proposed federal actions are potentially subject to NEPA’s require-
ments. For this reason, NEPA provides the ideal mechanism or framework for efciently reviewing
new (proposed) federal actions that may present opportunities to reduce pollution and waste gen-
eration. While P2 is not specically mentioned, its inherent objectives are captured in the purpose,
goals, and requirements of NEPA, and its implementing regulations. Signicant cost savings may
be realized by properly integrating NEPA with P2.
NEPA regulatory direction is consistent with the purpose and goals of an integrated NEPA/P2

strategy (Table 2.5). Table 2.6 shows that NEPA’s policy is consistent with that of P2. As indicated
TABLE 2.5
NEPA’s Regulatory Direction is Consistent with an Integrated Pollution Prevention Act
• Ultimately, of course, it is not better documents but better decisions that count. NEPA’s purpose is not to generate
paperwork—even excellent paperwork—but to foster excellent action. (§ 1500.1[c])
• The NEPA process is intended to help public ofcials make decisions that are based on understanding of environmental
consequences, and take actions that protect, restore, and enhance the environment. (§ 1500.1[c])
• Use all practicable means, consistent with the requirements of the Act and other essential considerations of national
policy, to restore and enhance the quality of the human environment and avoid or minimize any possible adverse effects
of their actions upon the quality of the human environment. (§ 1500.2[f])
TABLE 2.6
NEPA’s Policy is Consistent with the Pollution Prevention Act
• “…to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the
health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the
Nation … (Sec. 2 [42 USC § 4321])
• use all practicable means [to:]
fulll the responsibilities of each generation as trustee of the environment for succeeding generations;
assure for all Americans safe, healthful, productive, and aesthetically and culturally pleasing surroundings;
attain the widest range of benecial uses of the environment without degradation, risk to health or safety, or other
undesirable and unintended consequences;
achieve a balance between population and resource use which will permit high standards of living and a wide sharing
of life’s amenities; and
enhance the quality of renewable resources and approach the maximum attainable recycling of depletable resources.”
(NEPA, Sec. 101 [42 USC § 4331][b], 1969)
•
•
•
•
•
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© 2008 by Taylor & Francis Group, LLC
32 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners
in Table 2.7, NEPA is to be combined and integrated with other environmental requirements and
processes whenever practical; and, as demonstrated in Table 2.7, NEPA provides both an effective
and efcient environment framework for incorporating P2 objectives into new actions.
2.6.2 NEPA PROVIDES A COMPREHENSIVE DECISION-MAKING PROCESS
A component essential to NEPA as well as to some aspects of P2 is a requirement to rigorously
analyze environmental impacts, alternatives, and mitigation measures. As depicted in Table 2.8, the
NEPA regulations provide specic direction for analyzing actions such as P2 measures.
NEPA provides decision-makers with many advantages not found in other environmental pro-
cesses. Moreover, while NEPA mandates rigorous requirements for performing environmental
analyses, it places no substantive restrictions on agencies regarding the nal decision that may be
reached. NEPA only requires that the nal decision has been adequately investigated, such that a
decision-maker can make an informed decision regarding the course of action to be taken. NEPA,
therefore, allows decision-makers to consider many diverse factors, such as environmental impacts,
economics, schedules, technology, risk, and other practical considerations, in reaching a nal
decision.
Although P2 is often touted as a cost savings measure, some waste reduction actions may actu-
ally result in cost increases. In practice, decision-makers may be faced with having to make difcult
tradeoffs between the goals of P2, other environmental requirements, scarce resources, cost, and
agency requirements. Fortunately, NEPA provides decision-makers with a exible and analytical
planning process for evaluating such tradeoffs and resolving dilemmas in an effort to reach a ratio-
nally based and legally defensible decision.
2.6.3 PROCESS FOR INTEGRATING NEPA AND P2
A set of checklists has been prepared by the DOE for assessing a diverse range of activities in terms
of potential P2 measures. These checklists have been used by employees to identify measures that
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 requirements with other environmental review and consultation requirements. (§ 1500.4[k])
• Combining (combine?) environmental documents with other documents. (§ 1500.5[i])
TABLE 2.8
NEPA Direction for Analyzing Actions such as Pollution Prevention Measures
• Use the NEPA process to identify and assess the reasonable alternatives to proposed actions that will avoid or minimize
adverse effects of these actions upon the quality of the human environment. (§ 1500.2[e])
• Study, develop, and describe appropriate alternatives to recommended courses of action in any proposal which involves
unresolved conicts concerning alternative uses of available resources as provided by Section 102(2)(E) of the Act.
(§ 1501.2[c])
• To assess the adequacy of compliance with Sec. 102(2)(B) of the Act the statement shall, when a cost-benet analysis
is prepared, discuss the relationship between that analysis and any analyses of unquantied environmental impacts,
values, and amenities. (§ 1502.23)
• Rigorously explore and objectively evaluate all reasonable alternatives … (§ 1502.14[a])
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Improving and Streamlining NEPA 33
could be taken to implement specic P2 measures. It is important to note that P2 measures may be
applicable to a proposed action even though the action may not result in a signicant impact.
Figure 2.1 depicts a high-level integrated strategy developed for the U.S. Department of Ener-
gy’s Hanford Site. The NEPA process provided the framework for efciently implementing a com-
prehensive P2 program. Figures 2.2 through 2.4 describe the details of implementing the integrated
NEPA/P2 strategy.
21
The readers should consider how this site-specic strategy could be modied
and adopted to other sites or programs.
The following discussion focuses on describing the implementation of a P2 program rather
than describing specic aspects of the NEPA process itself. As depicted in Figure 2.1, an integrated
NEPA/P2 process begins with identifying a need to take action.
Identify need for taking action
Is

categorical exclusion
applicable?
Prepare EA?
Some entity such as a P2
Program Office reviews the
proposal for P2 measures
See
Figure 2.3
Prepare NEPA request form
Review proposed action:
- Identify preliminary P2 measures
NEPA determination meeting:
- Determine NEPA level
- Provide initial P2 guidance
Begin EIS process
See
Figure 2.4
See
Figure 2.2
Project office
NEPA practitioner
Agency NEPA office
Yes
No
No
Yes
FIGURE 2.1 Proposed process for integrating pollution prevention measures with NEPA.
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34 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners

2.6.3.1 Categorical Exclusions
Typically, a review is performed to determine if a proposed action can be categorically excluded
from further NEPA review. Specic details of a categorical exclusion (CATX) process may change
from agency to agency, depending on an installation’s internal procedures, requirements, and con-
straints. Consequently, this section will not dwell on the specic implementation details of the inte-
grated NEPA/P2 process that was developed for the Hanford Site. Instead, readers should consider
how a P2 program can be adapted to their specic internal CATX process. A generalized summary
of the integrated NEPA/P2 process is described below.
The CATX response is depicted by the diamond labeled “Is categorical exclusion applicable?”
in Figure 2.1. If the response is “yes,” the reader is directed to Figure 2.2. Figure 2.2 details the
process used in determining if and when P2 measures are applicable to an action that is eligible for
a CATX.
P2 not applicable
Some entity such as a
P2 Program Office
Incorporate P2
measures into
EMS (if practical)
Submit CATX to agency’s NEPA
office for approval
Prepare and attach P2 checklist
to CATX. Transmit copy of P2
checklist to some oversight
entity such as a P2 program
Office for review
Are P2 measures
applicable?
Determine applicability of P2
Prepare CATX documentation
Yes

Figure 2.2
Documented CATX?
No
No
Yes
Input
Transmit
checklist
Pursue action
FIGURE 2.2 Process for integrating pollution prevention measures with the CATX process.
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Improving and Streamlining NEPA 35
Some agencies recognize two types of CATXs: (1) documented and (2) nondocumented. This
step is depicted by the diamond labeled “Documented CATX?” in Figure 2.2. If the CATX requires
no documentation (“no” path, diamond labeled “Documented CATX?”), this strategy 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
Scoping
direction
Prepare P2
checklist
Transmit copy of
P2 checklist to
some entity such
as a P2 Program
Office for review
Describe and
analyze P2
measures in EA

Incorporate P2
into mitigation
measures
Submit EA for
review and
approval
Append P2
checklist to EA
Document in EA
that no
“reasonable” P2
measures were
identified
Is P2
applicable?
Determine
applicability of P2
Review proposed
action
Figure 2.3
No
Mitigated EA?
Input from P2
entity such as a
P2 Program
Office
Document
adopted P2
measures in
FONSI

Incorporate
P2/mitigation
into EMS (if
practical)
Yes
Yes
No
Input
Input
Issue FONSI
FIGURE 2.3 Process for integrating pollution prevention measures into EAs.
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36 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners
“ Documented CATX?”), a review is performed to determine if P2 measures are applicable to the
proposed action.
The action is pursued if no practical P2 measures are identied (“no” path, diamond labeled
“Are P2 measures applicable?”). If practical P2 measures are identied (“yes” path, diamond labeled
“Are P2 measures applicable?”), an appropriate P2 checklist(s) is prepared and attached to the docu-
mented CATX for review. If appropriate, the P2 Program Ofce (or equivalent) provides input and
Prepare P2 checklist(s)
Transmit copy of P2
Checklist to P2 office
Public P2 input
Identify, screen, and
describe reasonable
P2 measures
Review reasonable
alternatives for potential
P2 measures

Begin internal scoping
Figure 2.4
Some entity
such as a P2
Program Office
Document
adopted P2
measures in
the ROD
Begin public scoping.
Request comments on P2
Review P2 scoping
comments
Analyze P2 measures for
proposed action,
alternatives, and mitigation
measures
Finalize EIS
Implement
adopted P2
measures
using EMS
(if applicable)
P2 Post-EMS
monitoring
and
auditing
Input
Input
Input

FIGURE 2.4 Process for integrating pollution prevention measures into EISs.
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Improving and Streamlining NEPA 37
assistance in preparing the P2 checklist. A copy of the completed P2 checklist is transmitted to
some responsible entity such as a P2 Program Ofce. Where practical, any adopted P2 measure
could be implemented and monitored through an environmental management system (EMS), such
as the one outlined in Section 2.7.
2.6.3.2 Environmental Assessment Process
A different strategy is followed for actions involving preparation of an environmental assessment
(EA). This process might be triggered by lling out a NEPA request form (see box labeled “Review
proposed action,” Figure 2.3). The NEPA request form could be modied to require an initial
screening for potential P2 measures; a review is then performed to determine the applicability of
P2 measures. The proposed action is reviewed to identify potential measures for achieving NEPA/
P2 goals such as reducing or preventing pollution, waste minimization, and energy conservation.
Where appropriate, the P2 ofce assists in identifying potential P2 measures.
If no P2 measures are considered practical (“no” path, diamond labeled “Is P2 applicable?”),
this fact is documented in the EA; the EA then continues along the standard NEPA path.
If P2 measures are deemed to be applicable (“yes” path, diamond labeled “Is P2 applicable?”), a
P2 checklist(s) should be prepared indicating methods that can be implemented to minimize waste
and to prevent pollution. A copy of the completed P2 checklist(s) is transmitted to the P2 ofce or
equivalent.
As appropriate, P2 measures identied in the P2 checklist(s) are incorporated into the descrip-
tion of the proposed action and reasonable alternatives described in the EA. Any applicable P2
measures should then be reviewed to determine their effectiveness.
If a mitigated EA is prepared (“yes” path, diamond labeled “Mitigated EA?”), applicable P2
measures could be incorporated into the mitigation measures.
The P2 checklist(s) is appended to the nal EA to be submitted for review and approval. If the
EA is eligible for a nding of no signicant impact (FONSI), the decision to adopt any applicable
P2 measures described in the EA should be documented in it. Where practical, any adopted P2

measures could be chosen through the NEPA process (e.g., FONSI/record of decision [ROD]) and
implemented/monitored with an EMS.
2.6.3.3 EIS Process
Where a proposed action involves preparation of an EIS (Figure 2.4), an effort could be performed
during the internal scoping process to identify potential P2 measures for achieving NEPA/P2 goals
such as reduction or prevention of pollution, waste minimization, and energy conservation. Where
appropriate, the P2 ofce (or equivalent) provides assistance in identifying potential measures.
As indicated in the box labeled “Prepare P2 checklist(s)” in Figure 2.4, a P2 checklist(s) can be
lled out indicating potential methods that could be implemented to minimize waste and prevent
pollution. A copy of the completed P2 checklist(s) should then be transmitted to the P2 ofce.
Potential pollution prevention measures identied in the P2 checklist(s), combined with input
obtained from the public scoping process, are reviewed to identify specic P2 measures for
investigation. Reasonable P2 measures should then be incorporated into the description of the pro-
posed action, and reasonable alternatives described in the EIS. The measures are then analyzed to
determine their effectiveness and potential impacts. The analysis should also consider options and
costs for implementing P2 measures.
The P2 checklist(s) is archived as part of the administrative record and the completed EIS is
submitted for review and approval. The decision to adopt any of the P2 measures investigated in
the EIS would be documented in the ROD. Where practical, any adopted P2 measures could be
monitored and implemented through an EMS. The EMS could be used in a monitoring and auditing
capacity to ensure that the P2 measures are correctly implemented.
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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 and the relatively new
ISO 14001 EMS. A nal report was issued to the President of the National Association of Envi-
ronmental Professionals (NAEP) in 1997, outlining a process for integrating NEPA with an ISO

14001 EMS, which was published in 1998.
*,22
In 2000, this report was reviewed and approved by the
NAEP Board of Directors and issued to the Council on Environmental Quality (CEQ) as a strategy
that should be promoted to federal agencies. The following section summarizes this strategy.
Although this strategy is directed at integrating NEPA with an ISO 14001 certied EMS, it can
also be integrated with any EMS that is consistent with the ISO 14001 standard. Hence, as used in
this chapter, the term EMS is interpreted to mean an EMS consistent with the ISO 14001 series of
standards. This strategy has since been generalized to describe a process for integrating any envi-
ronmental impact assessment (EIA) process with an EMS.
23
2.7.1 AN ISO 14001 CONSISTENT EMS
The ISO 14000 environmental management standards dene specic procedures to assist an orga-
nization in complying with applicable statutes, regulations, and environmental requirements; min-
imizing how the organization’s activities negatively affect the environment, and for continually
improving on the above. ISO 14000 is similar to the ISO 9000 quality management system in that
both focus on the management process used (e.g., how a product is produced) rather than on the
ultimate quality of the product itself.
An EMS is part of an organization’s management system. The EMS species requirements and
procedures for implementing the organization’s environmental policy. ISO 14001 provides an interna-
tionally accepted specication for the EMS. The ISO 14001 EMS has the following ve components:
Detail procedures for dening an environmental policy with a commitment to pollution
prevention, continual improvement, and compliance with relevant environmental legisla-
tion and regulations.
Specic procedures for identifying an organization’s (products/services/activities) environ-
mental aspects, legal and other responsibilities, and environmental management programs.
Implementation and operation procedures; includes identication of responsibilities, train-
ing and awareness, documentation, and operational controls.
Developing measurable targets for meeting environmental objectives; verication and cor-
rective action procedures; includes monitoring and measuring performance to meet targets

for continual improvement.
Review by management to ensure that the EMS is addressing changing conditions and
information.
Presidential Executive Order 13148 directed federal agencies to develop EMSs by the year
2005.
24
As explained in more detail later, strong parallels exist between the goals and requirements
of NEPA and the specications for implementing an EMS. Because there is a general expectation
under an ISO 14001 EMS that action(s) will be taken to improve environmental quality, perfor-
mance of an integrated NEPA/EMS can provide a mechanism for infusing NEPA’s substantive
national policy goals into federal decision-making.
Figure 2.5 shows a simplied process for implementing an EMS. The EMS provides a struc-
tured system (plan-do-check-act) in which a set of management procedures is used to systematically
*
Eccleston C.H., “ A Conceptual Strategy for Integrating NEPA with an Environmental Management System,” issued to
the President of the National Association of Environmental Professionals, 1997. Issued to CEQ, 1990/2000.
•
•
•
•
•
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Improving and Streamlining NEPA 39
identify, evaluate, manage, and address environmental issues and performance. The EMS provides
organizations with a mechanism which helps ensure that necessary actions are taken to integrate
environmental safeguards and compliance into day-to-day operations and long-term planning with
respect to an organization’s (e.g., including federal facilities) activities, products, and services.
As depicted in Figure 2.5, the EMS employs a rigorous monitoring cycle for managing and con-
tinually improving an organization’s (federal facility) environmental performance. The continuous

improvement cycle is achieved by identifying how the organization’s activities affect environment
quality. This is accomplished through
assessing an organization’s environmental aspects (described later),
establishing dened environmental targets and objectives,
training staff and dening departmental and personal responsibilities,
cyclical monitoring and implementing corrective actions as necessary to avoid or mini-
mize impacts, and
instituting procedures and controls for responding to emergencies.
An EMS provides an effective mechanism for tracking, monitoring, and improving the implemen-
tation of the agency’s selected alternative, including mitigation measures and other commitments
established in nal NEPA documents; monitoring such commitments can support internal auditing
requirements and identication of appropriate corrective actions.
Both NEPA and EMS processes involve a review of activities to identify those with potentially
signicant environmental impacts and to implement measures to avoid, minimize, or eliminate
the causes of adverse environmental impacts. For reasons such as these, an integrated NEPA/EMS
methodology can substantially improve an agency’s environmental performance and thus environ-
mental quality and may reduce the cost of complying with NEPA and EMS requirements. Some of
the key advantages of an integrated NEPA/EMS system are
incorporating NEPA documents and schedules into EMS objectives and targets;
archiving the NEPA administrative record and NEPA documents as part of the EMS sys-
tem for maintaining records;
integrating NEPA mitigation commitments with other related regulatory requirements and
EMS objectives and targets;
•
•
•
•
•
•
•

•
Establish policy
Develop plan to implement the policy
Implement the plan/policy
Monitor and develop a plan for
correcting deficiencies in the policy
Review performance of the plan/policy
Revise plan/policy
FIGURE 2.5 Simplied overview of a typical EMS.
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40 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners
including NEPA impact assessments as part of the process of identifying the environmen-
tal aspects under an EMS; and
monitoring the implementation of the selected NEPA alternative and applicable mitigation
and monitoring commitments.
Some agencies have already begun pursuing an integrated NEPA/EMS strategy. For example,
new Forest Service planning regulations require 126 Forest Service administrative units to imple-
ment EMSs containing procedures for identifying and monitoring environmental conditions. The
preamble to the Forest Service regulations declares that:
… through the implementation of EMS, administrative units will be continually collecting and evalu-
ating the data necessary to create any document that may be required by NEPA. This will make the
creation of accurate and relevant NEPA documents more efcient.
25
(emphasis added)
2.7.2 WHY NEPA AND ISO 14001 COMPLEMENT EACH OTHER
As depicted in Table 2.9, each system has its strengths and weaknesses; moreover, a weakness in
one system tends to be offset by the strengths of the other.
Some of the principal characteristics outlined in Table 2.9 are described below.
•

•
TABLE 2.9
How an ISO 14001 Consistent EMS and NEPA Complement Each Other
Characteristics EMS NEPA
Substantive mandate Substantive actions are expected to be taken
which lead to continual improvement in
environmental performance (and thus
environmental protection).
Lacks a legally binding substantive
mandate to protect the environment.
Goal ISO’s goal is to provide environment
protection by identifying impacts. Its
continual improvement system is
used to reduce these impacts and improve
performance.
NEPA’s goal is to provide environment
protection by ensuring
that environmental factors are
considered during the early planning
process.
Planning function A planning function is required which
provides a system for ensuring that
decisions are appropriately
implemented. However, ISO 14001
does not prescribe a detailed process
for performing the planning function.
A comprehensive environmental
an environmental system for ensuring
that decisions are properly
implemented.

Impact assessment
requirements
An investigation of “environmental
aspects” is required. However, little
specicity is provided regarding the
requirements for performing this
investigation.
Species detailed direction for
performing an analysis of direct,
indirect, and cumulative impacts.
Life cycle Details how to perform a life-cycle analysis
(ISO 14040 series).
An analysis of reasonably foreseeable
impacts over the life cycle of the action
is required.
Signicance Lacks detailed direction for interpreting
or determining the meaning of signicance.
In addition to the context, 10 specic
factors are detailed in the NEPA
implementing regulations for
determining the signicance of
environmental impacts.
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planning process is defined, but it lacks
© 2008 by Taylor & Francis Group, LLC
Improving and Streamlining NEPA 41
TABLE 2.9 (Continued)
How an ISO 14001 Consistent EMS and NEPA Complement Each Other?
Characteristics EMS NEPA
External input A nonpublic procedure used to record

and respond to external parties is
required, but ISO 14001 does not
prescribe detailed requirements.
Species a detailed public participation
and formal public scoping process for
identifying actions impacts, and
alternatives, and for eliminating
nonsignicant issues.
Other environmental
requirements
A top-level environmental policy is
required, including a commitment to
prevention of pollution, which is very
broadly dened.
CEQ guidance and Executive Orders
direct federal agencies to integrate
pollution prevention measures,
environmental justice, biodiversity, and
other considerations with NEPA.
Mitigation Provides a system that can be used to
ensure that mitigation measures are
implemented.
Mitigation measures are required to be
identied and analyzed, but are not
normally required to be chosen or
implemented.
Preventive and corrective
action
ISO 14001 species procedures that
can be used to (1) identify

circumstances where NEPA
commitments or mitigation measures
are not being correctly implemented;
(2) correcting nonconformities;
(3) mitigating their impacts; and
(4) developing plans to avoid
nonconformities.
A NEPA adaptive management (AM)
system can provide an effective process
for taking corrective actions, and
making mid-course corrections.
Records and documentation An EMS species detailed procedures
for controlling and maintaining
records needed to demonstrate
conformance with the EMS standard.
An EMS can be used for maintaining
NEPA records.
Monitoring Monitoring is mandated as part of the
continual improvement cycle.
Encourages (and sometimes requires)
post monitoring measures.
Continual improvement A continual improvement process is a basic
concept inherent in an EMS.
CEQ has promoted a cyclical process
known as AM.
Audits ISO 14001 denes internal auditing
requirements for periodically
assessing conformity to the EMS; the audit
results must be presented to management.
NEPA conformance and commitments

may be reviewed and audited where
such commitments are linked to EMS
objectives and targets. An EMS audit
provides a means for ensuring that
NEPA process and commitments are
being correctly implemented.
2.7.2.1 Policy and Plan
The NEPA regulations identify categories of federal activities (i.e., policies, programs, projects,
and plans) that are subject to NEPA review. The establishment of federal policies and plans are
therefore actions that may be subject to the requirements of NEPA. Thus, federal policies and plans
established as part of an EMS may potentially be subject to NEPA requirements, particularly where
policies/plans entail signicant environmental impacts, issues, or consequences.
While environmental planning is a mandatory element within an EMS, the ISO 14001 standards
provide only limited specications for performing the planning function. For example, specic
procedures and requirements with regard to scoping, investigating environmental aspects, dening
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42 NEPA and Environmental Planning: Tools, Techniques, and Approaches for Practitioners
temporal and spatial bounds, interpreting signicance, and other requirements are at present only
vaguely inferred or dened.
In contrast, the NEPA regulations provide highly prescriptive direction and requirements for
ensuring that an accurate and scientically defensible analysis is prepared which provides decision-
makers with information sufcient to reach an informed decision. Moreover, these requirements are
reinforced by nearly four decades of experience gained by agencies through their engagement with
diverse missions and environmental issues.
Properly integrated, a combined NEPA/EMS system can provide a synergistic process for plan-
ning actions and implementing decisions in a manner that protects and enhances environmental
quality, while minimizing cost.
2.7.2.2 Procedural versus Substantive
While an agency must comply with the procedural aspects of NEPA, the courts have largely ruled that

an agency is not obligated to select an environmentally preferable alternative or to demonstrate that its
decision conforms to the environmental goals (i.e., substantive mandate) established in Section 101 of
the Act. Thus, NEPA’s contribution is derived not from a substantive mandate to choose an environ-
mentally benecial alternative but from its procedural requirement, which forces decision-makers to
rigorously evaluate and consider the effects of potential actions on the environment, just as they would
balance other traditional factors such as cost and schedules.
In contrast, an ISO 14001 consistent EMS involves a general expectation that some type of
substantive action(s) will be taken to improve environmental quality. There is at least the expecta-
tion that environmentally benecial actions will be taken, and undertaken in a cyclical process of
continual environmental improvement. Thus, an EMS can provide at least a limited mechanism for
enforcing the substantive environmental mandate that NEPA lacks.
Likewise, NEPA requires analysis of mitigation measures but places no substantive burden on
decision-makers to choose or enact them. In contrast, ISO 14001 requires organizations to establish
objectives (goals) for improving the environmental quality performance in relation to signicant
aspects. Similarly, environmental targets are established for measuring and achieving those objec-
tives; targets establish specic and measurable criteria for meeting the objectives.
Achieving these objectives may involve implementing actions similar to NEPA’s mitigation
measures. Again, NEPA prescribes more rigorous requirements for planning and investigating miti-
gation measures, while an EMS provides the “teeth” for implementing such measures.
2.7.2.3 Analytical Similarities
Under ISO 14001, the cause of an effect is essentially termed an “environmental aspect.” Aspects
are those specic activities that affect the environment. For example, facility environmental aspects
might include production of hazardous waste, wastewater efuents, consumption of fuel, air dis-
charges, trafc, and deliveries or loud plant operation noises. While the environmental aspects must
be determined, their environmental consequences or impacts on environmental resources do not
necessarily have to be evaluated.
In contrast, the NEPA regulations provide highly prescriptive requirements for ensuring that an
accurate and defensible analysis of impacts is performed, which will provide a decision-maker with
information that can support informed decision-making. NEPA is more demanding than ISO 14001
as it requires not simply a review of environmental “aspects,” but a comprehensive analysis of the

actual direct, indirect, and cumulative impacts.
Moreover, as previously stated, the NEPA process is reinforced by nearly four decades of fed-
eral experience accumulated by a diverse range of federal agencies, each with its own mission and
a spectrum of environmental issues to resolve. From a planning perspective, NEPA provides a more
comprehensive and rigorous process for ensuring that environmental impacts are identied, evalu-
ated, and considered before a decision is made to pursue an action.
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Improving and Streamlining NEPA 43
2.7.2.4 Life Cycle Analysis
As practical, NEPA requires that an analysis be performed over the entire life cycle of an action,
including connected actions. Both short- and long-term effects must be considered. To the extent
possible, the reasonably foreseeable impacts of future actions must be identied and evaluated. In
contrast, the ISO 14040 series describes in detail how a life-cycle analysis could be performed.
2.7.2.5 Public Participation
Public participation is an element essential to the NEPA process. The public scoping process is
designed to seek and solicit comments from the public, other agencies, and subject matter experts.
Decisions made regarding signicance and the choice of alternatives are highly dependent on the
concerns of stakeholders. In contrast, the ISO 14001 series provides no requirement for public par-
ticipation, only a requirement to develop a plan for external communications and inquiries.
Lack of such a requirement can be viewed as a weakness in many parts of the ISO 14001
standard. Thus, NEPA’s long experience with public participation and scoping helps to balance the
weaknesses of the EMS.
A theme central to both the NEPA and the EMS is the concept of signicance. NEPA requires anal-
ysis of potentially signicant impacts of federal actions. Under ISO 14001, signicance is dened
vaguely and contains few factors for use in reaching a determination.
In contrast, the concept of signicance permeates NEPA’s regulatory provisions. The regula-
tions include a detailed denition of signicance and in addition to context provide 10 specic
factors decision-makers are to use in making such determinations (§ 1508.27). Again, NEPA
brings many years of experience to bear on the problem of how best to determine signicance.

2.7.2.7 Integration of Environmental Requirements
Federal agencies are instructed to integrate NEPA with other environmental reviews (e.g., regu-
latory requirements, permits, agreements, project planning, and policies) so that procedures run
concurrently rather than consecutively; this requirement reduces duplication of effort, delays in
compliance, and also minimizes the overall cost of environmental protection:
25
Identify other environmental review and consultation requirements … prepare other
required analyses and studies concurrently with, and integrated with the environmental
impact statement … (§ 1501.7[a][6], emphasis added)
Any environmental document in compliance with NEPA may be combined with any other
agency document … (§ 1506.4, emphasis added)
Integrate the requirements of NEPA with other planning and environmental review proce-
dures … (§ 1500.2[c], emphasis added)
The ISO 14001 standard also requires that organizations identify applicable legal and regulatory
requirements. The intent is to ensure that organization activities meet applicable legal and
regulatory requirements. To this end, an EMS provides a mechanism for efciently ensuring that regu-
latory and other requirements are identied and incorporated into an integrated NEPA/EMS process.
2.7.2.8 Integrating Pollution Prevention
The CEQ has issued guidance indicating that, where appropriate, P2 measures are to be coordinated
with, and included in the scope of, an NEPA analysis.
26
Some federal agencies have also issued
similar directives. The ISO 14000 series speaks to the merits of P2, but mainly from the standpoint
of establishing a top-level policy committed to P2.
•
•
•
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2.7.2.6 Significance
© 2008 by Taylor & Francis Group, LLC

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 actu-
ally incorporated at the operational level, whereas NEPA provides an ideal framework for evaluat-
ing and integrating a comprehensive P2 strategy/plan into federal proposals.
2.7.2.9 Preventive and Corrective Action
ISO 14001 requires organizations to establish procedures for taking action to mitigate impacts
caused by its activities and for implementing corrective and preventive actions.
Findings and recommendations resulting from EMS monitoring and audits provide the basis for
managing corrective/preventive actions. This is similar to NEPA’s concept of adaptive management
(AM) (described later).
2.7.2.10 Records and Documentation
An ISO 14001 consistent EMS requires that organizations establishing procedures for controlling
documents related to the implementation of the EMS. Such records may include environmental
aspects (and their corresponding NEPA impacts), regulatory requirements, and monitoring data.
This record system can also be used to maintain the NEPA administrative record.
2.7.2.11 Implementation, Training, Monitoring, and Continuous Improvement
Under an ISO 14001 EMS, all personnel whose work could result in a signicant environmental
impact must receive appropriate training. Such requirements can help ensure that the NEPA deci-
sion is correctly and safely implemented.
The NEPA regulations strongly encourage, and in some instances mandate, incorporation of
monitoring. Generally, however, the courts have not insisted that agencies incorporate monitor-
ing as part of the NEPA process. In contrast, monitoring is a basic element inherent in an EMS.
A properly integrated NEPA/EMS ensures that monitoring is correctly executed.
2.7.2.12 Internal Auditing
ISO 14001 requires periodic internal environmental audits of the EMS. The audit is conducted to
verify whether the EMS conforms to the ISO standard and is being properly implemented.
Mitigation and other NEPA-related commitments may be included as part of the EMS audit.
Thus, the EMS audit provides another mechanism for ensuring that agency NEPA commitments
are appropriately implemented.
2.7.3 STRATEGY FOR INTEGRATING AN EMS WITH NEPA

The NEPA planning process is generally triggered through identication of a need for a proposed
action; the process focuses on identifying, assessing, and minimizing impacts of the alternatives to
the proposal. In contrast, an EMS addresses the full range of construction and operational activi-
ties (i.e., proposals, operations, services) with the intent to continually improve an organization’s
environmental performance throughout its life cycle.
By establishing applicable environmental objectives and targets, an EMS can help ensure per-
formance and implementation of commitments and mitigation measures through tracking and mon-
itoring programs.
Figure 2.6 illustrates a high-level, general-purpose process developed by the author for integrat-
ing an EMS with the NEPA.
22
Figure 2.6 conceptually describes three discrete functions or phases
(blocks 2, 3, and 4) that are performed principally using the standard NEPA process:
1. Planning

3. Decision-making
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2. Analyzing potentially significant impacts
© 2008 by Taylor & Francis Group, LLC
Improving and Streamlining NEPA 45
Similarly, the integrated NEPA/EMS system is composed of three additional functions (blocks
1, 5, and 6, as well as a continuous improvement loop) that are performed principally using an EMS
process:
1. Establish policy
2. Implement plan/policy
3. Monitoring
2.7.3.1 Policy and Planning Phase
The strategy described in Figure 2.6 is initiated with the establishment of a high-level organizational
environmental policy and a commitment to environmental quality (see rst block, Figure 2.6).
Next, an effort is mounted to develop a specic plan for implementing the environmental policy

(see second block, Figure 2.6); in reality, this might only be performed once.
1
Establish policy
2
Planning phase
Begin environmental impact
assessment (EIA) process
and integrated environmental
planning
3
Analyze
significant impacts
Prepare emergency response plan
5
Implement plan
Train personnel and execute
decision and any applicable
mitigation measures
6
Monitoring
Review performance of policy/plan
4
Decision-making
Determine course of action.
Issue FONSI/ROD
Incorporate pollution
prevention and
related environmental
planning factors
Corrective action

Revise plan to correct
deficiencies and
improve performance
Continuous
improvement
loop
Optional path
EMS phase
NEPA phase
EMS phase
FIGURE 2.6 General-purpose strategy for integrating the NEPA process with an ISO 14001 EMS.
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