Demystifying Environmental

Consultant offers advice on getting through the NEPA process

Examples include NavAid installations, making minor facility renovations, and reconstruction of perimeter or security fencing. A CatEx is based on the FAA’s experience with a particular kind of action and its environmental effects. The FAA has studied the action in previous EAs, found no significant impact on the environment based on the analyses, and validated the lack of significant impacts after the implementation.

When a proposed action is included in the FAA’s CatEx list, the airport must demonstrate and the FAA must check to make sure that no extraordinary circumstances exist that may cause the proposed action to have a significant effect in a particular situation. Examples of extraordinary circumstances include effects to endangered species, protected cultural sites, and wetlands.

If there are no extraordinary circumstances indicating that the proposed action effects may be significant, then FAA can approve the CatEx and allow the airport to proceed with implementation of the proposed action. Because of the FAA CatEx list and the experience FAA has within those categories, the CatEx is a simple and direct document that provides an airport the ability to satisfy NEPA requirements without enduring a lengthy process.

Environmental assessment
The EA is a more intense examination of the same NEPA criteria as a CatEx, and is intended to determine the significance of the environmental effects and to look at alternative means to achieve the FAA’s objectives. The public, other federal agencies, and outside parties may provide input into an EA — and then comment on the draft EA when it is published. According to FAA, an EA is intended to be a concise document that provides sufficient evidence and analysis for determining whether to prepare an EIS.

If the EA demonstrates there is no significant impact to the environment, FAA will issue a Finding of No Significant Impact (FONSI). The FONSI (which still can’t escape a wry smile when repeated to unknowing participants) is a document that presents the reasons why FAA has concluded that there are no significant environmental impacts projected to occur upon implementation of the proposed action. The FONSI may address measures that FAA will take to reduce or mitigate potentially significant impacts.

Environmental impact statement
When the EA determines that the environmental consequences of a proposed action may be significant, an EIS is prepared. An EIS is the most detailed evaluation of the proposed action and alternatives. The public, other federal agencies, and outside parties may provide input into the preparation of an EIS and then comment on the draft EIS when it is completed.

If FAA anticipates that a proposed action may significantly affect the environment, or if it is environmentally controversial, FAA may choose to prepare an EIS without having to first prepare an EA. After a final EIS is prepared and at the time of its decision, the FAA will prepare a public record of its decision, addressing how the EIS findings — including consideration of alternatives — were incorporated into FAA’s decisionmaking process.

A Record of Decision (ROD) is the final step in the EIS process. The ROD is a document that:

  • states what the decision is;
  • identifies the alternatives considered, including the environmentally preferred alternative; and
  • discusses mitigation plans, including any enforcement and monitoring commitments.

In the record of decision, FAA discusses all the factors — including any considerations of national policy that were contemplated when it reached its decision — on whether to and how to proceed with the proposed action.

The terms CatEx, EA, FONSI and ROD are common framework elements that form the basis of NEPA documentation for federal actions. The terms and actions are not complex when understood from the perspective of NEPA’s basic interdisciplinary intent. From the CatEx to the ROD, each of these elements shares common characteristics and terminology that build on one another.

Understanding NEPA as a multi-level framework serves to simplify an airport’s explanations when it engages the community and staff.

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