Knowledge Center

  • 4 Tips for Writing a Concise National Environmental Policy Act Document

    National Environmental Policy Act (NEPA) was written in 1969, the intent was to provide a mechanism that:

    • Provided decision-makers with environmental planning information.
    • Offered the public a way to participate in the decision-making process.

    The idea was to provide as concise of an answer as possible. Those writing the Act envisioned environmental assessments (EAs) that did not exceed 10 pages in length, and environmental impact statements (EIS) that were under 150 pages. Today, it is not uncommon for EAs to reach 500 pages and EIS to run into the thousands.  How can NEPA consultants reach the primary objectives for informed decisions and public involvement, when documents become so large and cumbersome that they become nearly impossible to understand?

    Here are some general guidelines to writing concise, focused and defensible NEPA documents that provide decision-makers with accurate information, and engage the public in the process.
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  • New Proposed Rule for the Definition of “Waters of the United States” Under the Clean Water Act

    Vicki CasteelDoes It Simplify or Complicate Determining Jurisdictional Waters? What the New Rule Does

    The Clean Water Act (CWA), administered by the US Environmental Protection Agency (EPA) and the US Army Corps of Engineers (Corps), protects the quality of our nation’s waterways. It regulates discharges of pollutants into US waters and sets quality standards for surface waters. Due to its widespread applicability and the costs associated with meeting its requirements, some see the CWA as overreaching. The most recent controversy surrounding the CWA is the introduction of a new proposed rule (published in the April 2014 Federal Register) that is intended to clarify the law’s regulations by:

    • Defining the term “waters of the United States” more clearly.
    • Clarifying protections for those waters.

    These clarifications are intended to make the process for determining the jurisdictional status of various types of waters simpler.
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  • PART III: Protecting Wetlands from Point Source Pollution

    Alyson EddieIn the first two parts of our blog series, our NEPA consultants addressed wetland mitigation, including the evaluation of functional quality and the various methods used to assess these functions. We now continue our discussion with the examination of point source pollution and the methods used to protect our wetlands.

    Section 402, a companion regulation to Section 404 of the Clean Water Act, regulates, among other things, the discharge of point source pollution (pollutants coming from a single source or action) into waters and wetlands of the US. Whereas Section 404 addresses dredge and fill impacts to waters of the US, the Section 402 regulation addresses potential water quality impacts.

    How does this affect your project? As we discussed in earlier blogs, by now you will have carefully shown the Corps that you will either be improving or impairing a wetland and have received an authorization (permit) from them to dredge and fill it in. If the project impairs a wetland, and you have negotiated a mitigation plan with the Corps to mitigate these impacts, you are now ready to start construction.
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  • Part II: Wetland Mitigation & Functional Assessment Methods

    Alyson EddieMethods that biological resource specialists’ use for assessing the functional quality of a wetland can vary from state to state. California employs the California Rapid Assessment Method (CRAM), whereas Florida’s state regulators first developed the Wetland Rapid Assessment Protocol (WRAP) and then developed a more detailed method known as the Uniform Mitigation Assessment Method (UMAM).

    As we discussed in Part I of this series, Utah has the UDOT Wetland Functional Assessment method. On a federal level, the Environmental Protection Agency (EPA) has developed a rapid assessment method for assessing wetland condition. Typically, the state-developed methods are most applicable to the wetland types and communities found within that state.
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  • Part I: Assessing the Functional Quality of Project Wetlands

    Alyson EddieAssessing the functional quality of wetlands, determining wetland mitigation using functional assessment methods, and protecting wetland projects during construction are all major areas of importance and concern in the environmental planning arena. The above issues will be examined in detail in a three-part series, beginning with assessment of the functional quality of wetland projects.

    Beginning a project in an area with, or near, wetlands can require a number of complicated steps before the project can be completed. If your project—whether restoration, transportation, energy, or development— impacts wetlands, you are likely to have to initiate the process of obtaining a Clean Water Act Section 404 wetland dredge and fill permit with the U.S. Army Corps of Engineers (Corps). You will find during the permitting process that, while wetland impacts in general should be avoided, avoiding wetlands is not always possible and not all wetland impacts are alike.
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  • Is Streamlining the National Environmental Policy Act Possible?

    “Any intelligent fool can make things bigger and more complex…It takes a touch of genius–and a lot of courage–to move in the opposite direction.” Albert Einstein

    Project proponents often express frustration at the resources, cost, and time required to complete the National Environmental Policy Act. The problem is that their NEPA projects tend to be over budget, beyond the project schedule, and require more resources than originally allocated. The resulting delays and increased costs are lengthening the time to get products to market.

    NEPA documents, especially environmental impact statements (EISs), have recently become more complex, complicated, and substantially lengthier. NEPA regulations (40 CFR Section 1502.7) direct that “the text of final environmental impact statements—shall normally be less than 150 pages and for proposals of unusual scope or complexity shall normally be less than 300 pages.” However, a random sample of 10 recent EIS documents from the EPA EIS Database averaged 660 pages.
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  • Process Mapping: How to Get the Most Out of Your Workforce

    Why map processes? It’s hardly a “sexy” topic, and generally, it’s avoided as a non-revenue generating activity that is not a productive use of time for many environmental consultants and planning professionals. However, if you find…

    • Tasks are done differently each time
    • Important steps are missed
    • Time is wasted on researching the right steps
    • Errors are common—costing time and money
    • New personnel are trained by overloaded peers or not trained at all

    … it’s time to consider a solid process manual. This can get everyone on the same page, produce efficient, consistent work processes, and save time and money on your environmental planning and design projects.
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  • Tips to Minimize Adverse Effects of Construction Vibrations on Historic Properties

    Kristopher Carambelas, RPAProjects that involve ground-disturbing activities oftentimes go to great lengths to avoid adversely affecting historic properties that are significant cultural resources such as buildings, structures, and even sites protected by Section 106. Some activities result in very obvious effects; others not so much. Thorough evaluation during the pre-construction planning process identifies most effects and makes recommendations to avoid, minimize, or mitigate adverse effects. Occasionally, some effects fly under the pre-construction planning radar.

    Construction vibrations are phenomena that are sometimes overlooked, yet these unseen products of blasting, demolition, pile driving, and compaction can travel well beyond a construction right-of-way and cause cosmetic and, in severe cases, structural damage to significant cultural resources. Discovering their effects after a project is underway can have costly consequences. Certain project elements may be delayed while a vibration monitoring plan is prepared. Disgruntled property owners may file damage claims. Project proponents may receive bad press. Time, money, and project supporters’ good will are potentially wasted.
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  • Cultural Resources – Stone Camp Dacite and the Greater Perry Mesa Community

    Cultural resources research on the archaeology of Central Arizona has focused mainly on the large settlements within Perry Mesa. Perry Mesa is a series of basalt-capped mesas and canyons along the Agua Fria River that resulted from the eruption of the shield volcano. This mesa-canyon complex covers an area of about 75 square miles and contains one of the most fascinating groups of ruins in Central Arizona.

    Beginning in 2006, as part of Logan Simpson-supported independent research, one of our senior archaeologists supervised a multiyear project of a previously unstudied prehistoric community that is undoubtedly part of the Perry Mesa system, which is located 10 miles east of Perry Mesa proper. Over this seven year period, a group of more than 20 volunteers, many of them Logan Simpson employees, surveyed and recorded over 150 prehistoric sites that are part of this unique community situated on the Tonto National Forest.
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  • Vegetation Sampling

    Richard Remington

    Logan Simpson Design’s biological resources staff is trained in a variety of vegetation sampling techniques. Vegetation inventory and mapping is a process that documents the composition, distribution and abundance of plant communities across the landscapes. Accurately describing and mapping vegetated land cover consistent with the national vegetation classification system is integral in providing comparable data in how vegetation is inventoried, studied, and applied to sound ecological science, land assessment, environmental planning and management.

     Vegetation sampling and mapping ranges from a broad scale delineation of ecological systems derived at a regional level to documenting fine-scaled vegetation associations and alliances at the local specific scale. Conducting detailed vegetation inventories and mapping are used in accuracy assessments of vegetation classes delineated on a vegetation map to provide the user with an estimate or index on the reliability that the vegetation type mapped actually matches the vegetation present on the ground.

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