Presented at the 2018 National Assoication of Environmental Professionals (NAEP) confernece, this slide deck on Integrating NEPA and Environmental Management Systems is a call to action for leaders at agencies and consulting firms to use the EMS framework to help federal agencies expedite NEPA reviews and – more importantly – to help agencies make better decisions.

1. NAEP 2018 Annual Conference | March 11 - 14, 2018 | Tacoma, Washington
Session 41 | NEPA Tools| March 14
Integrating NEPA and EMS: A call to action
Steve Hall
NEPA Project Manager
Steve.Hall@easbio.com
206.441.1882
http://www.easbio.com/
Don’t know NEPA? See Wikipedia article HERE
Don’t know EMS? See Wikipedia article HERE
*

2. a NEPA expert…
NAEP 2018 Annual Conference| Tacoma,Washington| IntegratingNEPAand EMS: A call to action
“NEPA Island,” where NEPA is
practiced within the limited
range of the status quo

3. Corps of
Discovery
Join me in becoming a NEPA explorer…
NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
• Embarked under executive order
• Exploring territory already used
extensively by other cultures
• Expecting a continent of
opportunities
• Willing to take risks
• A well-skilled, interdisciplinary
team
• On a mission!
In the spirit of the Lewis and Clark Expedition, also known as the
Corps of Discovery, the NEPA profession needs courageous leaders
to explore the world of EMS and other proven technologies that lie
offshore of NEPA island.

4. • establish deadlines
Familiar Approaches to Expedite NEPA:
• control interagency coordination
• decrease judicial reviews
• increase accountability
• more categorical exclusions
NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
EA/
EIS
expedite

5. What about
the writing
process?
NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
Just like a manufacturer seeking to reduce
production time and costs and increase
product quality, federal agencies looking to
expedite NEPA reviews need to take a hard
look at the NEPA “production process.”

6. Writing process challenges
NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action

7. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
large writing
teams
WRITING PROCESS CHALLENGE EXAMPLE #1

8. What is that?
oh, just thinking about my
EIS section
free-style narrative
NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
WRITING PROCESS CHALLENGE EXAMPLE #2

9. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
Large amounts of
loosely structured
background
information make
NEPA documents
difficult to write and
difficult to read.
Of most concern,
lengthy “free-style
narratives” impede
decision makers from
getting the
information they need
to make informed
decisions.

10. complex review,
revision and
production cycles
NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
WRITING PROCESS CHALLENGE EXAMPLE #3

11. policy
decisions
at the
project
level
We talk about “one federal decision,” but
any NEPA project requires dozens if not
hundreds of policy decisions:
• criteria to establish need
• “reasonable” range of alternatives
• decision criteria
• Issues
• BMPs
• significance thresholds
• many others
These take a LOT of time and
energy to make from scratch for
each EA/EIS!
WRITING PROCESS CHALLENGE EXAMPLE #4

12. A need for
strategy and
structure
Common
Underlying Cause:
NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
EMS

13. what is an
EMS?
• ISO Standard 4001 – Environmental Management –
provides an internationally-recognized approach to
environmental impact assessment
• Offers a systematic approach to managing
“environmental aspects” (issues)
• Establishes environmental objectives/performance
standards
• Defines systematic, repeatable steps
• More than 350k companies around the world use
EMSs to manage environmental impacts and to
document regulatory compliance
LINK

14. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
Do
CheckLearn
Plan
The EMS system includes a cycle of
continuous improvement

15. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
“Little information
exists on the
costs and benefits
of completing NEPA
analyses”
LINK

16. a structure
of procedures and policies
used to systematically
identify, evaluate and
manage
environmental
impacts
NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
CEQ EMS Definition
LINK

17. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
What is it?
Integrated NEPA/EMS

18. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
Complementary
Processes

19. EMS provides the car and
map
NEPA sets the
destination
Complementary processes...
NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
EMS checks success
Continuous
Improvement

20. The Integrated NEPA/EMS
Plan + Inform + Decide + Act
Check + Learn + Improve
+
+
Structure + Standards + Policies+ ProceduresEMS
EMS
NEPA
= Integrated NEPA/EMS
NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action

21. The Integrated NEPA/EMS
multi-tool:
NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
 Strategic policy and guidance for project-specific planning
 Alternatives generator and screening tool
 Interagency MOU
 Regulatory compliance tool
 Information/knowledge management system
 Content and document management system
 Impact assessment and mitigation tool
 Multi-objective comparison and optimization tool
 Decision-making tool
 Area-, project-, and issue-specific management plans
 Administrative record capture, curation, and retrieval tool
 Monitoring and adaptive management plan
 More!

22. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
HOW?
Integrated NEPA/EMS

23. “Tiering avoids
duplication of
paperwork”
CEQ’s NEPA 40 Questions
NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action

24. • Programmatic EIS/ROD
• Describes actions and areas covered
• Strategically defines and addresses recurring
issues
• Explores and defines policies, procedures and
information structure
• Establishes clear scoping framework for project-
specific actions
• Defines formal Interagency agreements and
processes
• Creates a system for long-term monitoring,
adaptive management, and continual
improvement
The Integrated NEPA/EMS
How?
NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action

25. Project-specific review -- tiered to the
FEIS/ROD – begins with a uniformly
formatted EMS Scoping Report that
documents the systematic narrowing
of scope of EA/EIS, including:
• reasonable alternatives
• alternatives dismissed
• actions
• issues
• issues dismissed
• analytical methods
NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
Implementing EMS after EMS FEIS/ROD

26. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action

27. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
Concise, narrowly
scoped EAs or EISs focus
on the significant issues
identified in Scoping
Report, as incorporated
by reference
Environmental Assessment
Narrowly Scoped EAs and EISs prepared after Scoping Report

28. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
Systematically track
ongoing project-specific
and program-wide
environmental
performance
Monitoring and Adaptive Management
Ongoing monitoring and adaptive management

29. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
HOW?
Integrated NEPA/EMS

30. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
SCOPE
• Inventory current NEPA processes and
knowledge/information base. Interview and engage
all involved in current NEPA process.
BUILD
• Write EMS EIS workplan. Design and build EMS
through programmatic EIS process. Prepare ROD
that establishes EMS polices, procedures and
information framework.
IMPLEMENT
• Train staff. Systematically produce and document
focused decisions. Act, check, learn, adapt, review,
repair, build, expand, improve.
?
Three phases to a programmatic EMS

31. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
Integrated NEPA/EMS Management System is
Modular, Reusable, Improvable and Expandable

32. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
✓ Aligned, interdisciplinary writing teams
✓ Structured, parallel, and reusable content
✓ Efficient review cycles
✓ Clear policies and procedures
✓ Expedited schedules
✓ Better public documents and online content
✓ Better information
✓ Bolstered resilience to judicial review
✓ BETTER DECISIONS!!!
Integrated NEPA/EMS
Benefits

33. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
a call to action...
START HERE
• Political mandate
• Strong need
• Ready-made solution
• Need courage and
leadership to leave
NEPA Island

34. NAEP 2018 Annual Conference | Tacoma, Washington | Integrating NEPA and EMS: A call to action
Join me on a mission!
START HERE
• Political mandate
• Strong need
• Ready-made solution
• Need courage and
leadership
Steve Hall
NEPA Project Manager
Steve.Hall@easbio.com
206.441.1882