Lesson 9

1. Lesson 9 Risk Assessment and NEPA

2. 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.

3. The National Environmental Policy Act (NEPA) • Requires environmental consideration for all federally funded actions • Evaluate potential effect to human health and the environment

4. 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

5. 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)

6. 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

7. 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

8. 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

9. 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)

10. 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

11. 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)

12. 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

13. 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

14. 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)

15. 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

16. 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

17. 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

18. Rules of Risk Management • Accept no unnecessary risks • Make risk decisions at the proper level • Accept risks if benefits outweigh the cost

19. 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

20. Practical Exercise Environmental Risk Assessment Scenario

21. Questions?