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Lesson 9. Risk Assessment and NEPA. Lesson 9: Objectives. Understand why NEPA was created. Know what types of actions require NEPA analysis and documentation. Understand risk management. Be familiar with environmental risk assessment concepts. The National Environmental Policy Act (NEPA).
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Lesson 9 Risk Assessment and NEPA
Lesson 9: Objectives • Understand why NEPA was created. • Know what types of actions require NEPA analysis and documentation. • Understand risk management. • Be familiar with environmental risk assessment concepts.
The National Environmental Policy Act (NEPA) • Requires environmental consideration for all federally funded actions • Evaluate potential effect to human health and the environment
NEPA • The environment includes air, land, noise, water, natural resources, cultural resources, socioeconomic conditions, and even aesthetics • Some people refer to NEPA as the umbrella act because it requires compliance with all environmental laws and regulations
Environmental Consideration at the Unit Level • NEPA requires KSARNG decision makers to analyze the environmental effects of proposed programs, projects and actions before initiating them • The degree of NEPA documentation depends on how significant the action is expected to have on the environment (REC, CX, EA, EIS)
Things to Consider • All training sites have environmental plans and procedures • Waste and Material Management Plans • Natural and Cultural Resource Management Plans • Site-specific SOPs • Local Training Areas • Don’t change the environment until someone discusses the environmental considerations with DOFE-E
Considering an FTX • The following information is typical of the information needed to consider the environmental effects of an FTX • Background information on the units • Number of troops and vehicles in the FTX • Description (Commander’s narrative) • Knowledge of the environment of the training area • Knowledge of the specific activities planned
ARNG Environmental Checklist • Units or facilities (proponents) should: • Prepare an ARNG Environmental Checklist • Attach the checklist to the proposal documentation and submit it to DOFE-E NLT 60 days prior to activity
ARNG Environmental Checklist • The KSARNG Environmental Program Manager will review the proposal and checklist in order to: • Validate the information contained in the checklist • Determine compliance with NEPA procedures outlined in 32 CFR 651 (formerly AR 200-2) • Recommend the appropriate action and prepare a Record of Environmental Consideration (REC)
Categorical Exclusion (CX) • A CX is an action that the Army has determined does not have a significant effect on the environment • Examples include: • Normal personnel, fiscal, and administrative services • Routine repairs of buildings, roads, airfields, grounds, equipment, etc • Routine procurement of goods • Construction that does not significantly alter land use • Training entirely of an administrative or classroom nature • Deployment of military units on TDY where existing facilities are used and the activities have no significant impact
Categorical Exclusions • The Environmental Program Manager determines whether the action falls under a Categorical Exclusion (CX) • If it does not, • DOFE-E determines conditions that must be met to make it a CX, or if it still does not meet the requirements of a CX • DOFE-E initiates the preparation of an Environmental Assessment (EA)
Record of Environmental Consideration (REC) • If the action can be CXed DOFE-E prepares a REC. The REC is a record that briefly describes: • The proposed action and its anticipated time frame • The responsible proponent • Any potentially negative impacts on the environment and any required actions to minimize them
Environmental Assessments • An Environmental Assessment (EA) is prepared to: • Determine the extent of environmental impacts of an action • Decide whether those impacts are significant • Provide the public with a brief description of the proposed action and the writers opinion of the effects of that action
Environmental Assessments • Available alternatives are included, which allows the public to examine different methods of achieving the intended action • After public review, an EA may be finalized by: • Preparing a Finding of No Significant Impact, or • Preparing an Environmental Impact Statement (EIS)
Actions Requiring an EA • If the action cannot be CXed, or has potential significant impacts, an EA is required. Examples: • Special FTXs on KSARNG land of a nature or magnitude not within the normal AT cycle • Changes to established installation land use that generates impacts on the environment • Projects affecting archaeological or historic sites • Actions which could potentially have a cumulative impact on soil erosion, prime or unique farmland, wetlands, floodplains, water supplies, etc • Acquisition and use of a new weapon system or a new piece of tactical equipment
Risk Management • The systematic process of identifying the potential hazards of an action and eliminating or reducing them • The purpose of environmental risk management is to reduce environmental damages while optimizing training
Benefits of Risk Management • Increased training realism and effectiveness • Increased combat survivability • Detection of risks before losses • Reduced deaths, injuries, and property damage • Reduced liability • Regulatory compliance • Risks are quantified
Rules of Risk Management • Accept no unnecessary risks • Make risk decisions at the proper level • Accept risks if benefits outweigh the cost
Steps of Risk Management • Step 1.Identify all hazards • Step 2.Assess environmental-related hazards • Step 3.Develop controls and make risk decisions • Step 4.Implement controls • Step 5.Supervise and evaluate
Practical Exercise Environmental Risk Assessment Scenario