Building Value Into The Nepa Process (Aka Why Is This Important)


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Building Value Into The Nepa Process (Aka Why Is This Important)

  1. 1. Building Value into the NEPA Process Peter W. Havens, CEP
  2. 2. Disclaimer The opinions and views expressed herein are strictly those of the author and presenter. They do not express the views or opinions of the Department of the Navy.
  3. 3. Introduction  40 CFR 1500.1 Purpose (c) 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. The NEPA process is intended to help public officials make decisions that are based on understanding of environmental consequences, and take actions that protect, restore, and enhance the environment.
  4. 4. The NEPA Process  NEPA is a procedural law A process described by law and regulation  The NEPA process is not isolated; The process exists because of a proposal for action  The “enterprise” to which the NEPA process is attached extends from “first light” to “implementation”  Therefore, the NEPA process also extends from first light to implementation
  5. 5. The process must generate value  Value must be generated by a process, otherwise the activity is wasteful  Value is determined by the “customer” or the recipient of the product output  Value accrues when we encourage the critical path and eliminate non-value added activity  Waste occurs when we measure the product at the end of the process and throw away those items that fail to meet specifications
  6. 6. Building value into the NEPA Process  Value of the NEPA process lies in its value to agency decision making  Improving how the process is conducted will generate more value than improving the document  Encouraging the NEPA process critical path activities will improve value to the decision maker
  7. 7. Decision Making Structure Decision Environmental Technical Economic Logistic (NEPA) (Engineering) (Cost) (Mission)
  8. 8. Consistency of Scope  Input to decision making must be based on the same scope  A scope change requires all disciplines to re- consider their conclusions  Consistency of Scope is required to  Conduct impact assessment  Develop mitigation  Prepare the NEPA document
  9. 9. Performance Criteria  Environmental Performance Criteria  Culvert openings no smaller than 8 inches  Avoid jurisdictional wetlands  Design/engineering solutions  Culvert constructed with 5, 8-inch PVC pipes  Move it up the hill  Performance criteria are required to  Improve efficiency of communication  Coordinating with design engineers  Inform decision makers of environmental constraints and opportunities
  10. 10. Programming, Budgeting and Design for Federal Actions  Military Construction Program  Lengthy, actions are identified 4 – 6 years in advance of the desired “program year”  Scope and Program year target may vary  Purpose and need are relatively stable  Decision making  Occurs throughout the programming and budgeting process  Continues through the design process
  11. 11. Programming and Budgeting  Critical path activities  Identifying and defining the NEPA Scope  Need  Purpose  Alternatives  Understanding and responding to significant issues  Defining and budgeting for mitigation  Planning for environmental documentation
  12. 12. Design  Critical path activities  Understanding and communicating the action scope  Communicating environmental constraints  Responding to value engineering changes  Consulting with agencies  Considering alternative mitigation measures and permit coordination
  13. 13. View of the decision maker  Mission support  Responsive, effective and efficient input  Balanced and considered decision  Truly representative NEPA documents  Confidence
  14. 14. Improving the NEPA Process  Improving the perceived value  Providing value to decision makers  Focusing on…  Consistency of Scope  Environmental Performance Criteria  Which leads to…  Improved decision making