[Federal Register: April 4, 2006 (Volume 71, Number 64)]
[Notices]
[Page 16790-16820]
From the Federal Register Online via GPO Access [wais.access.gpo.gov]
[DOCID:fr04ap06-43]
[[Page 16790]]
=======================================================================
-----------------------------------------------------------------------
DEPARTMENT OF HOMELAND SECURITY
Environmental Planning Program
AGENCY: Department of Homeland Security.
ACTION: Notice of final directive.
-----------------------------------------------------------------------
SUMMARY: The purpose of this Notice is to inform the public that the
Department of Homeland Security (DHS or the Department) is issuing its
final policy and procedures for implementing the National Environmental
Policy Act of 1969 (NEPA) and related executive orders and
requirements. This Notice also responds to the comments received on the
draft Management Directive (draft Directive), published on June 14,
2004.
DATES: This Directive will be effective on April 19, 2006.
FOR FURTHER INFORMATION CONTACT: Mr. David Reese, Office of Safety and
Environment, Department of Homeland Security, 202.692.4224.
SUPPLEMENTARY INFORMATION:
Table of Abbreviations
CATEX--Categorical Exclusion
CEQ--Council on Environmental Quality
CFR--Code of Federal Regulations
DHS--Department of Homeland Security
Department--Department of Homeland Security
EA--Environmental Assessment
E.O.--Executive Order
FEMA--Federal Emergency Management Agency
FLETC--Federal Law Enforcement Training Centers
FONSI--Finding of No Significant Impact
FSE--Full Scale Exercise
FR--Federal Register
NEPA--National Environmental Policy Act
ODP--Office of Domestic Preparedness
ROD--Record of Decision
U.S.C.--United States Code
USCG--United States Coast Guard
Table of Contents
Background
Scope and Applicability
General Comments and Responses
Section by Section Comments, Responses, and Other Changes
Specific Comments on Categorical Exclusions and Responses
Management Directive 5100.1, Environmental Planning Program
Management Directive 5100.1, Appendix A, Timely and Effective
Environmental Planning in the Department of Homeland Security
Planning in the Department of Homeland Security
Management Directive 5100.1, Glossary
Background
DHS has the mission to lead the unified national effort to secure
the United States of America. It has the responsibility to prevent and
deter terrorist attacks and protect against and respond to threats and
hazards to the Nation. As a part of this mission, the Department
ensures safe and secure borders, facilitates lawful immigrants and
visitors, and promotes the free flow of commerce among nations.
This Directive establishes policy and procedures to ensure the
integration of environmental considerations into the unique mission of
the Department. It outlines roles and responsibilities for compliance
with the National Environmental Policy Act (NEPA), 42 U.S.C. 4321 et
seq., and other laws and requirements for stewardship of the
environment. This Directive also establishes a framework for the
detailed, balanced, and systematic consideration of environmental
stewardship in the planning and execution of DHS activities.
NEPA is the basic charter and foundation for stewardship of
environmental resources by the agencies of the Federal government
within the United States. It establishes policy, sets goals, and
provides a tool for carrying out national environmental policy. NEPA
requires agencies to use all practical means within their authority to
create and maintain conditions under which people and nature can exist
in productive harmony and fulfill the social, economic, and other needs
of present and future generations of Americans. 42 U.S.C. 4331.
This Directive includes processes for preparing Environmental
Assessments (EA), Findings of No Significant Impact (FONSI), and
Environmental Impact Statements (EIS). It also includes procedures for
DHS to establish new or revised Categorical Exclusions (CATEX). DHS
will use this Directive in conjunction with NEPA, the Council on
Environmental Quality (CEQ) regulations at 40 CFR parts 1500-1508, and
other pertinent environmental laws, regulations, and Executive Orders
(E.O.).
The Department published a draft Directive and a request for
comments in the Federal Register on June 14, 2004. 69 FR 33043; see
also 69 FR 42760 (Jul. 16, 2004) reopening comment period. The draft
Directive proposed DHS policy for meeting the requirements under NEPA,
including a proposed list of categories of DHS actions excluded from
further consideration under NEPA, known as categorical exclusions.
More than 7,500 letters and e-mails were received during the
comment period. The vast majority of those comments consisted of
identical letters and e-mails, where only the name and address
differed. The Department received fewer than 100 unique comments. The
Department has posted all unique comments and an example of each
identical form comment on the DHS public web site, listed below. These
comments are categorized and discussed below. This final Directive
incorporates clarifications and limitations added in consideration of
the public comments.
A copy of this publication, the draft Directive, all unique
comments received during the comment period, examples of form comments,
and a summary of the administrative record are available at http://www.dhs.gov/dhspublic/display?theme=13&content=5278
.
Scope and Applicability
This Directive applies to all of DHS, including its components.
Components may supplement this Directive, provided that any supplements
are consistent with the Directive. This Directive shall prevail in case
of any inconsistencies between this directive and supplementary
procedures. Currently, FEMA has NEPA regulations, 44 CFR Part 10, and
the U.S. Coast Guard has a Commandant's Instruction Manual on NEPA,
16475.1 series. These components will amend their procedures to conform
to this Directive.
General Comments and Responses
The draft Directive contained proposed policy and procedures for
DHS to comply with NEPA and ensure the integration of environmental
considerations into mission planning and project decision making. It
also proposed the means for DHS to follow the letter and spirit of NEPA
and comply fully with CEQ regulations. Both the draft and final
Directive encompass requirements in addition to NEPA and establish the
DHS Environmental Planning Program. The final Directive contains a
detailed set of policy and procedural requirements to implement NEPA
and the environmental planning function in a reliable, timely, and
cost-effective manner.
Following is a discussion of the comments. Comments of a general
nature are addressed first, followed by comments on specific sections
of the Directive. Since there were many comments on specific proposed
CATEXs, these comments and responses have been placed into a separate
grouping and are addressed one-by-one in the last section of comments
and responses.
1. Categorical Exclusions: Too Many and Too Broad. About 70
commenters noted that the Department's draft
[[Page 16791]]
Directive had an exceptionally large number of components responsible
for a vast array of activities and operations under its purview. It was
generally argued that many of these activities have a clear potential
for significant adverse environmental impacts. These comments indicated
a concern that the draft ignored what some commenters defined as an
accepted practice that the use of Categorical Exclusions be limited
primarily to routine administrative actions. Some comments stated that
the draft attempted to create a number of overly broad and vague
Categorical Exclusions for activities with the potential for
significant adverse environmental effects. Other comments noted that,
while federal agencies are accorded a degree of deference in creating
their Categorical Exclusions, they must still provide a sound and
factually supported basis for finding that certain agency actions will
not individually or cumulatively have a significant impact on the
environment. Some commenters also generally argued that some proposed
Categorical Exclusions go far beyond what is authorized by CEQ
regulations and relevant case law.
In response to these comments, DHS recognizes that the creation of
a Cabinet-level Department from numerous agencies and elements of other
agencies is certainly an historic and complex event. In addition, DHS
was mandated by the Homeland Security Act to functionally integrate its
activities to establish consistent business processes throughout the
Department. Numerous functional areas such as financial management,
procurement, human resources management, and asset management, either
have or are actively completing the establishment of common rules and
operating procedures throughout DHS. From an environmental planning
perspective, this meant establishing a common set of policy, guidance,
and implementing procedures for use by all DHS components.
To respond to this challenge, DHS used a very lengthy and complex
series of deliberations to create and support the CATEXs included in
this NEPA Directive. The Council on Environmental Quality's Regulations
for Implementing the Procedural Provisions of the National
Environmental Policy Act contemplates that CATEXs will serve as a tool
for agencies to conserve time and effort by defining categories of
actions that do not individually or cumulatively have a significant
effect on the human environment and are therefore exempt from the
requirement to prepare further analysis in an environmental assessment
or an environmental impact statement. 40 CFR 1500.4(p). This Directive
and the NEPA directives of most agencies include a list of CATEXs that
extend beyond routine administrative actions. The Department empanelled
a group of federal employees from its components with sufficient
expertise and experience to identify such categories of actions most
relevant to DHS, hereinafter referred to as the Panel. That Panel
critically analyzed the actions within the categories that they
identified to ensure that only actions with no potential for individual
or cumulative significant impact would be included in the list of
CATEXs. The Panel also took pains to ensure that the actions were
sufficiently limited to actions for which the Department maintained a
demonstrated history of successful performance with no significant
effect on the human environment. The CATEXs were developed on the basis
of an administrative record from the components that comprise the
Department and the experiences of the Panel members.
2. Alleged Conflict between NEPA Scoping Requirements and
Consultation Requirements under Section 106 of the National Historic
Preservation Act. One set of comments stated that the scoping
provisions that require involvement of other federal agencies, non-
federal interests, and the general public in defining the scope of
potential environmental impacts from a proposed activity do not
adequately fulfill requirements to consult with federally-recognized
Indian Tribes and Native Hawaiian organizations under Section 106 of
the National Historic Preservation Act when the proposal may impact a
historic property and could become a source of conflict.
DHS disagrees. These comments refer to an issue that was not
referenced, expanded, or limited by the draft Directive. Neither the
CEQ regulations that implement NEPA nor the draft Directive prescribe a
standard scoping process. Furthermore, the Advisory Council on Historic
Preservation's regulations for implementing Section 106 of the National
Historic Preservation Act, at 36 CFR part 800, provide for coordinating
Section 106 reviews with the NEPA process or using the NEPA process to
fulfill the requirements of Section 106. More specifically, 36 CFR
800.2(c)(2), requires consultation with federally recognized Indian
Tribes and Native Hawaiian organizations in fulfilling Section 106
review requirements.
The Department's Directive defines the need to coordinate with
federally-recognized Indian Tribes and Native Hawaiian organizations
during the NEPA process in Section 6. That policy is further reinforced
in Sections 1 and 2 of Appendix A, which states that the Department's
policy is to seek out and coordinate with other federal departments and
agencies, tribal, state, and local governments, non-governmental
organizations, and the general public early in the environmental
planning process. Furthermore, Executive Order 13175, ``Consultation
and Coordination with Indian Tribal Governments'' dated November 9,
2000, directs all federal departments to, among other things,
``strengthen the United States government-to-government relationships
with Indian tribes and establish regular and meaningful consultation
and collaboration with tribal officials in the development of Federal
policies that have tribal implications * * *'' Each component in DHS
provides the framework by which they consult and coordinate with tribes
concerning their specific program areas, including any environmental
planning activities that may involve tribes.
3. General Administrative and Editorial Changes. Names and titles
of offices and positions have been changed to reflect the current
organizational structure, program responsibilities, and nomenclature
within DHS. The abbreviation used for the term ``Categorical
Exclusion'' has been changed from ``CE,'' the term used in the draft,
to ``CATEX'' to avoid confusion with other commonly abbreviated terms
used in DHS. Other changes have been made in coordination with CEQ to
clarify language to ensure that this Directive would conform to CEQ
regulations. Redundancies have been eliminated. Grammatical changes,
structural changes, and clarifications have been made that are not
intended to change any of the draft's meaning or intent.
Section By Section Comments, Responses, and Other Changes
1. Management Directive, Section 6.F. There were no comments on
this specific section. However, language in this section has been
changed to clarify that no actions will be taken that limit
alternatives considered for any proposed action for which an EA or EIS
process is being conducted. These changes would not change the
obligation for DHS to ensure that the Record of Decision (ROD) and the
FONSI are public documents and will reflect the final decision.
2. Appendix A, Section 2.6., Public Involvement. There were no
comments
[[Page 16792]]
on this section; however, the opening paragraph was modified to more
clearly express DHS policy on public involvement in environmental
planning.
3. Appendix A, Section 2.6.A, Public Involvement. There were no
comments on this section; however, consideration of some comments on
Appendix A, Section 4.0 resulted in changes here. The extent of public
comment and involvement in the EA and FONSI process is defined in 40
CFR 1501.4(b) which states, ``The agency shall involve environmental
agencies, applicants, and the public, to the extent practicable, in
preparing assessments required by section 1508.9(a)(1)'' (where the
referenced section refers to environmental assessments). Neither NEPA
nor CEQ regulations prescribe a set period of public comment required
in the EA and FONSI process--apart from the FONSI publication required
in the special situations described in 40 CFR 1501.4(e)(2)--leaving it
up to the agencies themselves to define the degree of public
involvement deemed practicable under the circumstances. Appendix A,
Section 2.6.A has been revised, in consultation with CEQ, to clarify
that public involvement is required in the environmental impact
evaluation process that would be documented in an environmental
assessment under NEPA. Other changes have been made to clarify the
relationship of this section to other sections in the Directive.
4. Appendix A, Section 3.2. paragraph B. There were no comments on
this section; however, several commenters expressed a general concern
over the potential for CATEXs to be applied to smaller repetitive
actions in a manner that could avoid a more in-depth review under NEPA
of the potential for significant cumulative environmental impacts. The
wording of this section has been modified to more clearly state that
the CATEXs are not intended to be used in this repetitive manner.
5. Appendix A, Section 3.2. paragraph C. Commenters objected to the
treatment of ``extraordinary circumstances'' in connection with
Categorical Exclusions. Categorical Exclusions are categories of
actions that can be shown to have no potential for significant impact
on the human environment under normal circumstances and would require
no further analysis under NEPA. However, in recognition of the variety
of situations where DHS may take action, DHS had proposed a series of
extraordinary circumstances where an otherwise categorically excludable
action may have potential for significant adverse impact to the human
environment and would require further analysis under NEPA. Commenters
claimed that the draft Directive erroneously used a significance test
when legal precedent has established that a CATEX may not be used if
there is the potential for ``any adverse effect.''
DHS disagrees. Upon further review of the language in this
Directive, including consultation with the Council on Environmental
Quality, DHS believes that the manner in which it will apply
``extraordinary circumstances'' in this Directive is in conformance
with appropriate precedent. CEQ regulations specify that a CATEX may be
used if there is no significant effect on the human environment, with
exceptions to provide for those situations when there are
``extraordinary circumstances.'' 40 CFR 1508.4. Section 3.2 of the
Directive clearly defines that there are to be three ``tests'' by which
the application of any CATEX to a particular action are viewed on a
case-by-case basis. Sub-section (C) within section 3.2 defines one of
those tests as that of ensuring that no ``extraordinary circumstances''
exist. That particular test requires that, in a matter that might
otherwise be subject to a particular CATEX, ``* * * [n]o extraordinary
circumstances with potentially significant impacts relating to the
proposed action exist * * *'' Therefore, if potentially significant
impacts related to the proposed action exist, the CATEX may not be
applied. The consideration of this and the other ``tests'' contemplated
by Section 3.2 ensure that, where ``* * * the proposed action does not
meet these conditions or a statute does not exempt it or an emergency
provision does not apply, an Environmental Assessment (EA) or an
Environmental Impact Statement (EIS) must be prepared before the action
may proceed.''
The concern addressed by the comments in this area suggests that
the language in the Directive that states, ``* * * [s]pecific actions
that might otherwise be categorically excluded, but are associated with
one or more extraordinary circumstances, should be carefully evaluated
to determine whether a CATEX is appropriate * * *'' would allow the
application of a CATEX to a particular action with foreseeable
significant impact on the environment even where not exempted by a
statute or emergency provision. The wording of this section has been
revised to ensure that DHS will evaluate whether extraordinary
circumstances may exist and have a record of the consideration of those
extraordinary circumstances. Likewise, the language of Section 3.3.B
has been modified to clarify this intent.
Subparagraph (4) in this section has been revised from a lengthy
list of possible natural resources and other geographic designations to
simply require that procedures for applying categorical exclusions take
into account the potential to effect an environmentally sensitive area.
The effect of this change is to lengthen the list of concerns that must
be considered under this subparagraph. Consideration of the
extraordinary circumstances contained in Subparagraph (4) was
previously limited to only those subjects listed. The term
``environmentally sensitive area'' has been defined in the Glossary to
be more comprehensive in its inclusion of various types of natural
resources and geographic areas of special interest in an environmental
impact evaluation process. The effect of this change is to ensure that
a broader range of subjects will be addressed when Subparagraph (4) is
used in consideration of extraordinary circumstances.
A new subparagraph (11) has been added in consideration of public
comments and to conform to CEQ regulations to ensure that CATEXs are
not used in situations where a proposed DHS action is related to other
actions with individually insignificant, but cumulatively significant,
impacts.
6. Appendix A, Section 3.3.B, Record of Environmental
Consideration. There were no specific comments on this section. This
section has been revised to clarify the purpose and use of a Record of
Environmental Consideration and to conform to the changes in Appendix
A, Section 3.2.C, Extraordinary Circumstances.
7. Appendix A, Section 4.0, Environmental Assessments. Commenters
urged DHS to adopt a policy that would favor seeking public comment on
both Environmental Assessments and Environmental Impact Statements,
especially where issues are likely to be controversial.
Consideration of this recommendation resulted in several changes to
Appendix A, section 2.6.A, as described earlier. Appendix A, section
4.0, has also been revised to more clearly reflect a policy of
involving the public in EAs and to more clearly provide direction on
the appropriate public involvement process. A new section 4.1 has been
added to clearly describe the purpose of an environmental assessment
and the former section 4.1 was renumbered to section 4.2, with some
edits and clarifying language. The text that provided direction on
alternatives, the internal review process within DHS, the FONSI, and
the public involvement requirements has been moved to a new
[[Page 16793]]
section 4.3, Considerations in Preparation of an EA or a Programmatic
EA.
8. Appendix A, Section 4.3., Considerations in Preparation of an EA
or a Programmatic EA. This is a new section of the Directive.
Consideration of comments urging DHS to adopt a policy that would favor
seeking public comment on Environmental Assessments resulted in the
consolidation of information from several parts of the Directive into
this new section and the addition of some clarifying language. The
language in paragraphs A, E, and F now clearly emphasizes the policy to
encourage public involvement in the preparation of an EA. This section
now clearly describes its relationship to the public involvement
factors listed in section 2.6, and provides options to achieve the
public involvement policy. The legal importance of the FONSI and any
mitigation measures that may be in the FONSI have been clarified. The
responsibility of the agency to implement mitigation measures contained
in a FONSI has also been more clearly stated.
The sections following 4.3 have been renumbered to 4.4, 4.5, and
4.6, with appropriate editorial and language clarifications, to reflect
the addition of the two new sections 4.1 and 4.3.
9. Appendix A, Section 6.2, Classified or Protected Information.
Many comments stated that the draft Directive asserted unqualified
authority to keep potentially large amounts of information on the
environmental impacts of DHS operations secret and out of public view
in contravention of the disclosure requirements of NEPA and CEQ
regulations. The commenters argued that DHS should limit the
Directive's nondisclosure provisions strictly to information that
unambiguously qualifies for withholding pursuant to a Freedom of
Information Act (FOIA) exemption. They further contended that to do
otherwise would violate the provisions of NEPA and CEQ regulations
governing the disclosure and nondisclosure of information. The comments
also conveyed concern that certain provisions of the draft Directive,
as well as new categories of information endorsed in the draft
Directive, such as Critical Infrastructure Information (CII) and
Sensitive Security Information (SSI), will be used to withhold
information about the environmental impacts of DHS operations from the
public. Some comments argued specifically that the manner in which CII
and SSI were applied in the draft Directive exceeded the statutory
mandate. In general, these comments claimed that the draft Directive
was seeking to unacceptably restrict currently available types of
information relevant to the health, safety, and well-being of the
public in violation of the spirit and letter of NEPA.
The Department carefully reviewed the comments received regarding
public disclosure of information in environmental impact assessments
and other documents prepared under NEPA and determined that the
intention of the initial formulation of policy required clarification.
DHS intends to comply with all applicable statutes and regulations
aimed at securing the homeland and making environmental documents
publicly available. The Department has many responsibilities, including
the protection of certain information under statutes such as the
Homeland Security Act, 6 U.S.C. 101, the Aviation Transportation
Security Act, 49 U.S.C. 114, and the Maritime Transportation Security
Act, 46 U.S.C. 701. The Department also has responsibilities under
FOIA, 5 U.S.C. 552, to make information available to the public.
DHS will appropriately share information that was relied upon to
formulate decisions that have environmental implications. DHS
recognizes that there may be instances where we cannot disclose all
information that supports environmental determinations because the
information is otherwise protected from disclosure under the mandates
that the Department must follow. For example, classified information
may not be released pursuant to FOIA. See 5 U.S.C. 552(b)(1). Likewise,
SSI and Protected CII are exempted from disclosure under FOIA, pursuant
to 5 U.S.C. 552(b)(3). See 49 U.S.C. 114(s), 49 CFR part 1520, 6 U.S.C.
133(a), 6 CFR part 29. Other information will be available to the
public in accordance with FOIA. Section 6.2 has been revised to clarify
that FOIA will be followed in public disclosure of environmental impact
assessments and other documents prepared under NEPA.
Specific Comments on Categorical Exclusions and Responses
Categorical Exclusion A4. CATEX A4 governs certain administrative
and regulatory activities. This CATEX has been revised, in consultation
with CEQ, in order to avoid the potential for confusion in its
application and to ensure that it is not applied to the development of
documents that may recommend activities with potential to significantly
impact the quality of the human environment. Specifically, the
Department has limited the types of actions contemplated by this CATEX
to ensure that if activities under this CATEX result in proposals for
further action, this CATEX may only apply if those proposals are
already contemplated by another DHS CATEX. Upon further review, it was
found that this CATEX could be interpreted in a manner to include the
development of documents containing proposals with potential to
significantly impact the quality of the human environment. In
particular the development of documents, such as those cited in the
examples, could be interpreted broadly to include documents such as
reports on levels of business activity or plans for physical
infrastructure development that may have greater potential to
significantly impact the quality of the human environment. The
Department intends that the change will clarify the narrow focus of
this CATEX by expressly excluding from its contemplation the
development of any proposals for actions where the actions themselves
would not be covered by a CATEX.
Categorical Exclusion A6.\1\ This CATEX was the subject of comments
concerning: (1) The references to waste disposal and (2) public
information regarding the use of chemicals and low level radio nuclides
for analytical testing and research. Commenters expressed concern that
the analysis of impacts from waste disposal for permitted landfills may
have been done in the past, but that may not account for new waste.
Commenters also stated that using the existing categorical exclusions
from the Federal Emergency Management Agency and the United States
Coast Guard as a basis for this Categorical Exclusion was not
appropriate, since those CATEXs were limited to procurement and storage
of such materials and not to disposal. Commenters also expressed
concern that the public should not be limited in its ability to access
information regarding the use of chemicals and low level radio nuclides
for analytical testing and research. One comment, for example, wanted
DHS to demonstrate or document how ``* * * Chemicals and low level
radio nuclides for analytical testing and research * * *'' are being
used safely.
---------------------------------------------------------------------------
\1\ The proposed categorical exclusion A5 in the draft Directive
was deleted in this final version. All subsequent categorical
exclusions in the A section were renumbered, beginning with the
current categorical exclusion A5, to reflect this deletion.
---------------------------------------------------------------------------
To address the concern that the analysis of impacts from waste
disposal for permitted landfills may have been done in the past, but
that may not account for new waste, DHS included
[[Page 16794]]
language in example (g) that limits this CATEX to apply to only
activities of waste disposal in established, permitted landfills and
authorized facilities; thereby, emphasizing that the Department is held
to all of the same requirements that are applicable to commercial and
other federal generators of non-hazardous waste.
To address the concern that existing CATEXs from the Federal
Emergency Management Agency and the United States Coast Guard were not
appropriate to use as a basis for this CATEX, the following explanation
is provided. During the development of these CATEX, the Panel found
that various components of the Department, procure non-hazardous goods
and services and store, recycle, and dispose of non-hazardous goods
during the normal course of their activities in a manner like that of
FEMA and the United States Coast Guard. Activities of a similar nature,
scope, and intensity were found to be common throughout the Department
in both administrative and operational activities. The vast majority of
procurements, in conformance with procurement priorities, were found to
consist of commercially available goods and services. A more limited
number of procurements were for goods that were provided by commercial
sources specifically for military (which could include the U.S. Coast
Guard) or law enforcement purposes. Unique procurements were extremely
infrequent and mostly adaptations of commercially available goods and
services. It was also noted that other agencies have CATEX for similar
activities that are sufficiently descriptive such that it could be
determined that they included a much broader range of activities and
encompassed activities of generally greater scope and intensity than
any in DHS. In addition, all federal agencies, with very few
limitations, must meet the same requirements to protect the
environment. For example, the volume of goods and services procured and
wastes disposed by other agencies dwarf those of DHS and are performed
under the same regulatory policies with no significant impacts to the
quality of the human environment.
To address the concern that the public should not be limited in its
ability to access information regarding the use of chemicals and low
level radio nuclides for analytical testing and research, DHS modified
Example (e) within this CATEX to further define ``analytical testing
and research'' by clarifying that the intent for including examples of
those types of non-hazardous materials would be ``for laboratory use''
and would thus be subject to the detailed requirements for the handling
of such materials in established laboratories and similar facilities.
Changes to Section 6 of the Directive, described elsewhere in this
Notice, will also address this concern. Categorical Exclusion A7.\2\
When A7 was published in the draft Directive, it was the subject of
comments concerning the availability of public information generally.
The Department considered the comments regarding public information and
these concerns are addressed in the Department's response to comments
on section 6 of the Directive.
---------------------------------------------------------------------------
\2\ The proposed categorical exclusion A5 in the draft Directive
was deleted in this final version. All subsequent categorical
exclusions in the A section were subsequently renumbered to reflect
this deletion.
---------------------------------------------------------------------------
Upon consideration of the scope of this CATEX, two other changes
were made. A new limitation was added to state that ``If any of these
commitments result in proposals for further action, those proposals
must be covered by an appropriate CATEX'' to ensure that, if surveys or
other actions contemplated under these CATEX result in recommendations
for further action, those further actions will be appropriately
evaluated under NEPA. Example (c) was modified and limited by removing
the phrase ``Site characterization studies and environmental
monitoring, including siting, construction, operation, and dismantling
or closing of characterization and monitoring devices * * *'' from the
descriptive examples to ensure that this CATEX was limited to audits,
surveys, and data collection of a minimally intrusive nature. These
additions and changes will better address the studies and other
administrative activities contemplated by this CATEX. Categorical
Exclusion B2. CATEX B2 was the subject of comments concerning the
danger to the environment raised by access to observation posts. The
chief concern expressed was regarding the risk that establishment of
and access to observation posts might pose to the endangered Sonoran
Pronghorn antelope. Specifically, one representative comment stated
that ``* * * a well-established record overwhelmingly demonstrates that
construction, use of, and access to such observation posts is clearly
not appropriate for the [categorical exclusion].''
The Department considered the comments and concluded that this
CATEX does not encompass the development of new access roads or
observation posts. To emphasize the Department's concern in this area,
the Panel specifically limited the CATEX to, ``* * * existing roads or
established jeep trails.'' In order to further stress the intent of the
Department that this CATEX not be extended to areas where there is
potential for significant impacts on the quality of the human
environment, the language of this CATEX was modified to expressly limit
the use of jeep trails to those established by a governmental authority
which would have shared or primary responsibility for regulating the
roads or trails.
In addition, section 3.2 in Appendix A of the Directive contains a
list of conditions and extraordinary circumstances that must be
reviewed when applying this CATEX to a specific program or activity
within DHS. These conditions and extraordinary circumstances were
developed because, while the vast majority of DHS activities in this
category do not have potential for significant impacts to the
environment, activity proponents (Proponents) within DHS need to be
alert for rare and unique conditions that may require more extensive
evaluation of the potential for environmental impacts under NEPA. This
evaluation would include not only the immediate effect of DHS decision,
but also the potential environmental effects that may indirectly result
from implementing the decision and the cumulative effects of the
decision on the quality of the human environment. The Directive now
contains language that clearly and explicitly prevents the use of the
CATEX where there is ``A potentially significant effect on species or
habitats protected by the Endangered Species Act, Marine Mammal
Protection Act, Migratory Bird Treaty Act, or Magnuson-Stevens Fishery
Conservation and Management Act.''
Categorical Exclusion B4. This CATEX was the subject of comments
regarding the reference to training on specialized equipment.
Specifically, the comments stated that it should be limited to those
activities that do not disturb the surface in any way and have no
potential to disturb the environment. The Department considered the
comments regarding the reference to training, noting that there existed
redundant coverage of training with CATEX G1. The references to
training activities and training activity examples have been deleted
from this CATEX. Responses to comments on CATEX G1 further address the
concern regarding the reference to training on specialized equipment.
Categorical Exclusion B5. This CATEX was changed from the text
published for public comment to clarify
[[Page 16795]]
that the phrase ``* * * Support for community participation projects *
* *'' was intended to mean support for and participation in community
projects. The Department is inherently dependent upon community
involvement in providing the homeland security services required of it.
The public is the key customer, beneficiary, and stakeholder for the
products and services that the Department provides. It is essential
that the Department engage in civic and community events that both
serve the public and common good, as well as provide the Department
with access to and credibility with its private sector customers. This
change clarifies the nature of events and actions contemplated by this
CATEX that may be undertaken for such purposes.
This CATEX was also changed to limit the nature of activities
contemplated by adding the phrase ``* * * that do not involve
significant physical alteration of the environment * * *''. Although
this aspect of this CATEX was not the subject of any public comments,
it was determined that this limitation would serve to focus the
activities undertaken by the Department and its components within this
CATEX on those clearly lacking the potential to significantly impact
the quality of the human environment.
Categorical Exclusion B6. Although not the subject of any public
comments, this CATEX for the approval of recreational or public
activities or events at a location typically used for that type and
scope of that activity was specifically limited to ensure that the
activities contemplated under this CATEX would not involve significant
physical alteration of the environment. This was done to emphasize that
this CATEX is not to be applied if there is potential for significant
environmental impact.
Categorical Exclusion B8. CATEX B8 was the subject of comments
regarding NEPA review of security equipment. Specifically, the comments
generally stated that there are many security devices including x-rays
and detection devices that include the use of dangerous chemical,
biological, and radiological substances. The comments expressed the
concern that the evaluation and disposal of these devices could pose an
environmental risk.
Security equipment used within the department must meet the
appropriate requirements of the Nuclear Regulatory Commission (NRC),
the Food and Drug Administration (FDA), or the Federal Communications
Commission (FCC). In addition, most of the security equipment consists
of commercially available products that are also in use by private
industry and other government agencies.
Some of the security equipment contains trace amounts of chemical
or radiological substances or produce X-rays as part of the screening
process. These chemical and radiological substances and X-rays are
encapsulated, shielded, and secured within the interior of the
equipment. All of the Department's security systems must meet federal
requirements for allowable levels of radiation emissions. There are no
biological substances in the security equipment. In addition, all
components within the Department that use these types of equipment
perform periodic radiation surveys or wipe tests of all X-ray producing
equipment or equipment that contains a small radioactive source to
ensure compliance with 21 CFR 1020.40, Cabinet X-ray Systems, and NRC
licensing requirements. The systems are also surveyed and inspected
whenever they are relocated or maintenance is performed on the X-ray
components and shielding.
Disposal of security equipment is consistent with Federal Property
Management Regulations found at 41 CFR 101 and 102. Furthermore, DHS is
also required to minimize disposal through maximum reutilization and
specialized sales, and will ensure that maximum attainable recycling
and recovery are achieved in accordance with the Resource Conservation
and Recovery Act (RCRA), 42 U.S.C. 6901-6992, and participation in the
Department of Energy's Homeland Defense Equipment Reutilization (HDER)
Program.
DHS has an agreement with DOE to refurbish, calibrate, and issue
radiological detection equipment to local jurisdictions that request to
participate in the HDER Program. No radioactive test sources are issued
to local jurisdictions with this equipment, thereby limiting the
potential for any radiological contamination. If DOE determines that
equipment is not fit to refurbish, DOE is responsible for the
equipment's disposition.
This CATEX was changed to further demonstrate that the Department
must contemplate applicable requirements to protect the environment
when determining whether the removal or disposal of security equipment
to screen for or detect dangerous or illegal individuals or materials
would have the potential to significantly impact the quality of the
human environment.
Categorical Exclusion B9. CATEX B9 was the subject of comments
regarding the temporary use of barriers and jersey walls. Specifically,
comments sought clarification of the term ``temporary.'' ``Temporary,''
as contemplated in this CATEX, means that the barrier is easily
installed with no need to disturb soils or the surrounding areas, and
that it can be easily removed or moved to another area. Additional
comments indicated that ``temporary'' should be limited to a term of
time, with a time period of a week or less. Comments on CATEX B9 also
included concerns regarding: (1) The inclusion of diver/swimmer devices
that could harm marine species and habitat, (2) the evaluation of
blast/shock impact resistant systems in manners that could pose a risk
to migratory birds, endangered species, and air quality, and (3) the
reference to remote video surveillance systems that could cause
significant surface disturbance.
The Department does not deem ``temporary'' regarding the use of
barriers, fences, and jersey walls to mean one week or less. The term
temporary is used by the Department to refer to structures that are not
permanent and that, depending upon mission concerns, are eventually
removed. The Department views the reference to the temporary use of
barriers, fences, and jersey walls as sufficiently narrow in that only
barriers, fences, and jersey walls on or adjacent to existing
facilities are included in B9. A barrier, fence or jersey wall attached
to, or set adjacent to, an existing facility will not normally have an
adverse effect on the natural environment since the construction and
location of the barrier will normally take place on land that has
already been disturbed or built upon; consequently, the text has been
clarified by adding ``or on land that has already been disturbed or
built upon''. In addition, this CATEX has been modified to emphasize
that removal and disposal must be in compliance with applicable
requirements to protect the environment.
In response to the concern that activities and examples under this
CATEX may adversely impact the environment, the Department notes that
section 3.2 in Appendix A of the Directive contains a list of
conditions and extraordinary circumstances that were developed in
recognition that Proponents need to be alert for rare and unique
conditions in the application of this CATEX that may require more
extensive evaluation of the potential for environmental impacts under
NEPA. This evaluation would include not only the immediate effect of
DHS decision, but also the potential environmental effects that may
indirectly result from implementing the decision and the cumulative
effects of the decision on the quality of the human environment. These
extraordinary circumstances are
[[Page 16796]]
established as criteria to ensure that this CATEX would not be applied
to any activity that would have the potential to significantly impact
the quality of the human environment.
This CATEX was changed to further demonstrate that the Department
must contemplate applicable requirements to protect the environment
when determining whether the removal or disposal of physical security
devices or controls to enhance the physical security of existing
critical assets would have the potential to significantly impact the
quality of the human environment.
Finally, the phrase, ``* * * for land based and waterfront
facilities,'' was added to qualify, ``* * * blast/shock impact-
resistant systems,'' within the list of devices and controls to limit
and clarify the intent of the CATEX.
Categorical Exclusion B11.\3\ This CATEX was the subject of
comments regarding the impact of routine monitoring patrols.
Specifically, the comment indicated concern that routine monitoring
patrols can have an impact on the environment depending on the
intensity and number of persons involved in the patrols. The comment
argued that this concern is particularly important in the case of
patrols occurring in sensitive areas such as wilderness areas that may
be habitat to endangered species.
---------------------------------------------------------------------------
\3\ The proposed categorical exclusion B10 in the draft
Directive was deleted in this final version. All subsequent
categorical exclusions in the B section were renumbered, beginning
with the current categorical exclusion B10, to reflect this
deletion.
---------------------------------------------------------------------------
The Department considered the concerns associated with this comment
and noted that due to their generally more remote and undeveloped
state, protected wilderness areas, national wildlife refuges, national
forests, national monuments, marine sanctuaries, or critical habitat
for marine mammals or endangered species tend to attract illegal
entrants, smugglers, and potential terrorists who are seeking to avoid
detection. The volume and frequency of this illegal activity in these
environmentally sensitive areas results in harm to the natural
resources that these areas have been set aside to protect. The patrols
contemplated by this CATEX could serve as a deterrent to individuals
who might otherwise harm sensitive natural resources. In any case, this
CATEX could not be used for patrol activities that may be associated
with extraordinary circumstances.
DHS considered the concern that routine monitoring patrols under
this CATEX may have a significant effect on the environment, in
particular wilderness areas and critical habitat for endangered
species. Section 3.2 in Appendix A of the Directive contains a list of
conditions and extraordinary circumstances that were developed in
recognition that activity proponents need to be alert for rare and
unique conditions associated with routine monitoring patrols that may
require more extensive evaluation of the potential for environmental
impacts under NEPA. This evaluation would include not only the
immediate effect of the DHS decision, but also the potential
environmental effects that may indirectly result from implementing the
decision and the cumulative effects of the decision on the quality of
the human environment. These extraordinary circumstances are
established as criteria to ensure that this CATEX would not be applied
to any activity that would have the potential to significantly impact
the quality of the human environment.
Categorical Exclusion D1. This CATEX was the subject of comments
regarding the term, ``minor renovations and additions.'' Specifically,
the comment expressed the concern that activities taking place outside
of a building may have impacts on sensitive coastal resources that may
be adjacent to a project. The comment expressed the desire that the
categorical exclusion be limited to projects that are not located near
such resources.
DHS considered this concern regarding the potential for sensitive
coastal resources adjacent to a project. Section 3.2 in Appendix A of
the Directive contains a list of conditions and extraordinary
circumstances that were developed in recognition that Proponents need
to be alert for rare and unique conditions in the application of this
CATEX that may require more extensive evaluation of the potential for
environmental impacts under NEPA; more specifically, subparagraph (4)
of section 3.2 states that DHS Proponents need to be alert for a
potentially significant effect on an environmentally sensitive area. An
environmentally sensitive area is defined in the Glossary to include
coastal zones and other important natural resources that may be present
in coastal areas. This evaluation would include not only the immediate
effect of the Department's decision, but also the potential
environmental effects that may indirectly result from implementing the
decision and the cumulative effects of the decision on the quality of
the human environment. These extraordinary circumstances are
established as criteria to ensure that this CATEX would not be applied
to any activity that would have the potential to significantly impact
the quality of the human environment.
This CATEX was changed in that the example, ``* * *extending an
existing roadway in a developed area a short distance,'' was deleted to
ensure that its application would not extend to DHS activities that
would have the potential to significantly impact the quality of the
human environment.
Categorical Exclusion D3. This CATEX was the subject of comments
regarding: (1) pest control activities, and (2) the impact of repair
and maintenance activities on sensitive coastal areas. The comment
focusing on pest control activities expressed concern that there exists
the need for restrictions on pest control activities to avoid the
potential for a significant impact on endangered species, groundwater,
and public health.
DHS considered the concern with pest control activities and notes
that the reference to pest control was only an example of the type of
activity envisioned by the CATEX. In providing examples, the Department
does not seek to extend the CATEX to actions including extraordinary
circumstances that may result in the activity having significant
environmental effects. However, in response to these comments, the
wording of this CATEX was narrowed to clarify its application to
Department-managed properties. Pest control activities that may be
conducted at Department-managed properties would be incidental to the
management of the facility for mission requirements. DHS does not have
a natural resources management mission that may require the general
eradication of pests. Typical pest control activities would consist of
but not necessarily be limited to those actions necessary to meet
health requirements in and around cafeterias and residential
facilities, actions to maintain the integrity of structures, or the
Department's participation as one of many other property managers in
larger pest control programs run by other Federal or state agencies.
DHS also considered the comment concerning the impact of repair and
maintenance activities on sensitive coastal areas. Section 3.2 in
Appendix A of the Directive contains a list of conditions and
extraordinary circumstances that were developed in recognition that
Proponents need to be alert for rare and unique conditions in the
application of this CATEX that may require more extensive evaluation of
the potential for environmental impacts under NEPA; more specifically,
subparagraph (4) of section 3.2 states that DHS Proponents need to be
alert for a potentially significant effect on an environmentally
sensitive area. An environmentally sensitive area is
[[Page 16797]]
defined in the Glossary to include coastal zones and other important
natural resources that may be present in coastal areas. This evaluation
would include not only the immediate effect of the Department's
decision, but also the potential environmental effects that may
indirectly result from implementing the decision and the cumulative
effects of the decision on the quality of the human environment. These
extraordinary circumstances are established as criteria to ensure that
this CATEX would not be applied to any activity that would have the
potential to significantly impact the quality of the human environment.
Categorical Exclusion D5. This CATEX was the subject of comments
regarding dredging. Specifically, several comments suggested that
dredging activities can have a significant effect on marine and
riparian habitats, effecting endangered species, critical habitat,
water flow, flooding, waste management, and a host of other
environmental concerns. Additionally, some commenters suggested
limiting this categorical exclusion to the United States Coast Guard.
The Department notes that its components do not generally have
independent authority to conduct maintenance dredging without complying
with the many laws and requirements established to protect the
environment. This exclusion from further environmental analysis under
NEPA is adequately limited by the need to secure applicable permits and
any required approval for a disposal site. In the process of securing
these permits, agencies such as the Army Corps of Engineers and the
Environmental Protection Agency, as well as various state agencies,
would perform independent environmental reviews of proposed DHS
maintenance dredging activities. It is also noted that the U.S. Coast
Guard maintenance dredging operations, which are the greatest in scope
and intensity of any of these types of activities within DHS, have been
conducted for many years without significant impact to the human
environment.
DHS considered this concern regarding the potential for dredging
activities to have a significant effect on various environmental
resources. Section 3.2 in Appendix A of the Directive contains a list
of conditions and extraordinary circumstances that were developed in
recognition that Proponents need to be alert for rare and unique
conditions in the application of this CATEX that may require more
extensive evaluation of the potential for environmental impacts under
NEPA. More specifically, these conditions and extraordinary
circumstances include consideration of the potential for significant
effects on marine and riparian habitats, endangered species, critical
habitat, water flow, flooding, waste management, and various other
environmental concerns. These extraordinary circumstances are
established as criteria to ensure that this CATEX would not be applied
to any activity that would have the potential to significantly impact
the quality of the human environment.
Categorical Exclusion E1. CATEX E1 was the subject of a comment
regarding facilities that cross tidal, coastal, or navigable waters.
Specifically, the comment suggested that the activities contemplated by
this categorical exclusion are not of concern in upland areas; however,
if any of the facilities cross tidal, coastal, or navigable waters
there is the potential for environmental impacts.
The Department considered this comment and notes that its elements
do not have independent authority to conduct activities without
complying with the many laws and requirements established to protect
the environment. This exclusion from further environmental analysis
under NEPA is adequately limited by the need to secure applicable
permits and any required approvals from the appropriate federal, state,
and local regulatory agencies.
However, section 3.2 in Appendix A of the Directive contains a list
of conditions and extraordinary circumstances that were developed in
recognition that Proponents need to be alert for rare and unique
conditions in the application of this CATEX that may require more
extensive evaluation of the potential for environmental impacts under
NEPA. More specifically, Appendix A, section 3.2, subparagraph (4)
states that DHS Proponents need to be alert for a potentially
significant effect on an environmentally sensitive area. An
environmentally sensitive area is defined in the Glossary to include
coastal zones, tidal, coastal, or navigable waters, and other important
natural resources that may be present in coastal areas. An evaluation
of these extraordinary circumstances would include not only the
immediate effect of the Department's decision, but also the potential
environmental effects that may indirectly result from implementing that
decision and the cumulative effects of the decision on the quality of
the human environment.
Categorical Exclusion E2. CATEX E2 was the subject of comments
expressing concern regarding the precise definition of, ``developed
area'' or ``previously disturbed site'' which appear in paragraph (b),
and the potential for this categorical exclusion serving as a loophole
permitting an infinite amount of construction.
The Department considered the comment regarding the definitions of
``developed area'' or ``previously disturbed site.'' The comment
specifically addressed wetland resources, stating that it was
reasonable to believe that wetlands capable of restoration might be
considered ``disturbed areas.'' The comment explains by way of example
that any such disturbance of a wetland in a particular state that was
not related to restoration would possibly be inconsistent with the
enforceable policies of the federally-approved Coastal Management
Program within that state. In response to that concern, the Department
modified the text by replacing the phrase, ``* * * local planning and
zoning standards,'' with the phrase, ``* * * Federal, State, tribal,
and local planning and zoning standards and consistent with federally
approved state coastal management programs'' as a condition precedent
to any action taken under this CATEX.
The Department also considered the concern that this CATEX might be
read to permit an infinite amount of construction as long as it could
be artfully tailored to meet or to allegedly meet the specified
criterion. In response, the Department makes reference to section 3.2
in Appendix A of the Directive which contains a list of conditions and
extraordinary circumstances that must be reviewed in the application of
this CATEX to a specific program or activity within the Department.
These conditions and extraordinary circumstances were developed in
recognition that, while the vast majority of the Department activities
in this category do not have potential for significant impacts to the
environment, activity Proponents within the Department need to be alert
for rare and unique conditions that may require more extensive
evaluation of the potential for environmental impacts under NEPA. This
evaluation would include not only the immediate effect of the
Department's decision, but also the potential environmental effects
that may indirectly result from implementing the decision and the
cumulative effects of the decision on the quality of the human
environment.
Categorical Exclusion E4. CATEX E4 was the subject of comments
expressing concern regarding the destruction or disruption of adjacent
habitat during demolition activities. The Department considered the
comment regarding potentially significant impacts on
[[Page 16798]]
habitat areas adjacent to demolition activities. The comment
specifically expressed a concern that the categorical exclusion needs
to make provisions to prevent the destruction or disruption of adjacent
habitat during demolition activities. The comment asserts that while
activities may be otherwise in compliance with regulations compliance
does not ensure that projects will cease when they have a significant
effect on the environment.
In response to the concern that activities under this CATEX may
adversely impact adjacent habitat or may otherwise have a significant
effect on the environment, the Department notes that section 3.2 in
Appendix A of the Directive contains a list of conditions and
extraordinary circumstances that were developed in recognition that
activity Proponents need to be alert for rare and unique conditions in
the application of this CATEX that may require more extensive
evaluation of the potential for environmental impacts under NEPA. This
evaluation would include not only the immediate effect of the DHS
decision, but also the potential environmental effects that may
indirectly result from implementing the decision and the cumulative
effects of the decision on the quality of the human environment. These
extraordinary circumstances are established as criteria to ensure that
this CATEX would not be applied to any activity that would have the
potential to significantly impact the quality of the human environment.
Categorical Exclusion E5. CATEX E5 was the subject of comments
expressing concern regarding actions that might cause imbalance to a
stable ecosystem. The comment specifically addressed the concern that
natural resource management activities might actually imbalance natural
ecological functions and cause further environmental problems. The
comment stated that restoration often causes short-term adverse effects
in order to gain long-term beneficial effects and asserts that NEPA
analysis is necessary to balance these competing effects in different
timeframes.
In response to these comments, the Department modified the text
published for public comment by replacing the phrase, ``* * * to
enhance native flora and fauna,'' with the phrase, ``* * * to aid in
the maintenance or restoration of native flora and fauna,'' and added
the limiting term, ``* * * and control of non-indigenous species'' as a
natural resource management activity category within this CATEX. The
Department also clarified the scope of this CATEX by adding the
limiting term, ``* * * on Department managed property,'' to clarify
that this CATEX is limited to property under the control of the
Department. DHS made these changes to clarify that DHS is not a large
land managing agency and the scope of activities contemplated would not
encompass large scale land management activities, but would be limited
to those properties where DHS had direct management responsibilities.
In response to the concern that activities under this CATEX, such
as restoration, may cause short-term adverse effects in order to gain
long-term beneficial effects, procedures in the Directive require
consideration of extraordinary circumstances when this CATEX would be
applied to a specific action. Section 3.2 in Appendix A of the
Directive contains a list of conditions and extraordinary circumstances
that were developed in recognition that activity proponents need to be
alert for rare and unique conditions in the application of this CATEX
that may require more extensive evaluation of the potential for
environmental impacts under NEPA. This evaluation would include not
only the immediate effect of the DHS decision, but also the potential
environmental effects that may indirectly result from implementing the
decision and the cumulative effects of the decision on the quality of
the human environment. These extraordinary circumstances are
established as criteria to ensure that this CATEX would not be applied
to any activity that would have the potential to significantly impact
the quality of the human environment.
Categorical Exclusion E6. The Department received numerous comments
to this CATEX asserting that the proposed categorical exclusion should
be clearly limited to roads that would not cause new surface
disturbance. The comments noted that road construction can have
significant impact on the environment by increasing erosion,
contaminated runoff, and fragmenting wildlife habitat. The comments
suggest that the reference to ``previously disturbed areas'' needs
clarification.
In response to the comments, this CATEX was significantly revised
and narrowed in scope. The comments submitted for this categorical
exclusion noted that the important criterion to determine the potential
for significant environmental impact was not the extent of prior
disturbance, but rather the degree of environmental sensitivity. The
Department recognizes that new road construction is highly
controversial, and accordingly modified this CATEX by limiting the term
``* * * construction or reconstruction,'' to read, ``* * *
reconstruction.''
Furthermore, Section 3.2 in Appendix A of the Directive, contains a
list of conditions and extraordinary circumstances that were developed
in recognition that Proponents need to be alert for rare and unique
conditions in the application of this CATEX that may require more
extensive evaluation of the potential for environmental impacts under
NEPA. In particular, the extraordinary circumstances would require the
need to be alert for a potentially significant effect on an
environmentally sensitive area in the application of this CATEX. These
extraordinary circumstances are established as criteria to ensure that
this CATEX would not be applied to any activity that would have the
potential to significantly impact the quality of the human environment.
Categorical Exclusion E7. The Department received a general comment
regarding this and several other CATEXs that essentially asserted that
the Department maintained a relaxed threshold for what constitutes
information that has no significant effect on the human environment.
The comment referenced this categorical exclusion concerning
construction of trails as an example of that relaxed threshold.
In response to these comments, the Department first makes reference
to the specific limitation in the CATEX which limits its application to
construction of trails in non-environmentally sensitive areas where
run-off, erosion, and sedimentation during construction are capable of
mitigation through implementation of Best Management Practices.
Furthermore, the Department references Section 3.2 in Appendix A of the
Directive, containing a list of conditions and extraordinary
circumstances that were developed in recognition that Proponents need
to be alert for rare and unique conditions in the application of this
CATEX that may require more extensive evaluation of the potential for
environmental impacts under NEPA. These extraordinary circumstances are
established as criteria to ensure that this CATEX would not be applied
to any activity that would have the potential to significantly impact
the quality of the human environment.
Categorical Exclusion E9. CATEX E9 was deleted as redundant in that
all of its contemplated activities were included in other proposed, and
now finalized, CATEXs. Wells for drinking water, sampling wells, and
watering landscaping are included in E2 or E3. Septic systems are not
built independent from other facilities and
[[Page 16799]]
are therefore included in the activities described in E2, D3, or D4.
Field instruments, such as stream-gauging stations, flow-measuring
devices, telemetry systems, geo-technical monitoring tools, geophysical
exploration tools, water-level recording devices, well logging systems,
water sampling systems, and ambient air monitoring equipment are
included in E3.
Categorical Exclusion F1. This CATEX was clarified to more
accurately define its intent. It is more accurate to limit the actions
contemplated to those applicable to hazardous materials and the
relevant requirements and to provide a separate CATEX for actions
related to the handling and disposal of hazardous waste. In order to
ensure that this CATEX was sufficiently limited in that fashion without
expanding or modifying its intended scope, the CATEX published for
notice and comment as F1 has been limited by defining it as
``Categorical exclusion F1: Routine procurement, transportation,
distribution, use, and storage of hazardous materials that comply with
all applicable requirements, such as Occupational Safety and Health Act
(OSHA) and National Fire Protection Association (NFPA) requirements.
The Department received a comment on CATEX F1 that was related
primarily to hazardous waste disposal as opposed to hazardous materials
usage. That comment will be addressed in CATEX F2.
Categorical Exclusion F2. The Department received a comment on the
CATEX originally published as F1, asserting that no standard exists by
which to measure the routine use of hazardous materials/waste.
Specifically, the comment stated that absent a deeper explanation of
the activities being excluded, this categorical exclusion could easily
become a rubber stamp to nearly all agency activities with hazardous
waste. The comment expressed the additional concern that a categorical
exclusion for these activities could mask the cumulative effects of
routine hazardous waste use at agency facilities.
DHS considered this comment and separated hazardous waste handling
and disposal into CATEX F2 with specific limitations to assure
compliance with appropriate hazardous waste handling and disposal
requirements.
In response to the concern over cumulative effects, section 3.2 in
Appendix A of the Directive contains a list of conditions and
extraordinary circumstances that were developed in recognition that
Proponents need to be alert for rare and unique conditions in the
application of this CATEX that may require more extensive evaluation of
the potential for environmental impacts under NEPA. In particular, this
evaluation would include not only the immediate effect of the
Department's decision, but also the potential environmental effects
that may indirectly result from implementing the decision and the
potential cumulative effects of the decision on the quality of the
human environment. These extraordinary circumstances are established as
criteria to ensure that this CATEX would not be applied to any activity
that would have the potential to significantly impact the quality of
the human environment.
Categorical Exclusion F3. The Department received a comment
asserting that the former categorical exclusion F3 should be deleted
because it excludes detection and scanning devices that, in sufficient
numbers or with sufficient radiological effects, could pose a
significant threat to the environment and public health. The Department
also received a comment asserting that the former categorical exclusion
F2 was too broad since it does not provide for an exception for devices
with a significant amount of hazardous or radiological risk and/or
waste, nor does it set a limit for the cumulative use of such devices.
The Department considered these comments and realized that
clarification was required. In addition, further review found that the
former CATEX F2 and F3 language referencing the use of instruments that
contain hazardous, radioactive, and radiological materials and the
examples provided was somewhat redundant. Consequently, the CATEX that
was originally published as CATEX F2 has been combined with the CATEX
that was originally published as CATEX F3 and additional limiting
language has been added to ensure that DHS activities contemplated by
this CATEX meet all manufacturer specifications, as well as comply with
all requirements to protect the environment. It is important to note
that DHS meets all safety parameters for radiological devices as
provided within the NRC license for those devices. In addition, DHS
takes extra precautions with these devices, when installed, to ensure
that these devices are separated by distance from each other, the
operator, and the owners of the property being examined in conformance
with the NRC license and to avoid potential for threats to the
environment and public health. Furthermore, DHS does not accumulate
these types of equipment in central storage, maintenance, or
distribution facilities. No evidence of cumulative effects has been
demonstrated from DHS uses of these types of equipment.
Categorical Exclusion G1. Commenters agree with the language
proposed that limited the application of this CATEX to training
exercises using live chemical, biological, and radiological agents to
designated facilities, but contend that this does not go far enough.
Regardless of the facility, they believe the use of live agents cannot
be said to inherently have no potential for significant environmental
impacts. At a minimum, such activities should require a review of
extraordinary circumstances and the preparation of a Record of
Environmental Consideration.
DHS, in consultation with the Council on Environmental Quality,
considered the comments regarding the potential effects of training
activities with live agents. The language of this CATEX has been
modified to clarify that it does not apply to training that involves
use of live chemical, biological, or radiological agents except when
the training is conducted at a location designed and constructed to
contain such materials. Construction and operation of these types of
facilities remains subject to review under NEPA.
Categorical Exclusion G2. One commenter believed that references to
``conducting'' national, state, local, or international training
exercises should be deleted. While design and development for readiness
exercises may not significantly impact the environment, actually
conducting them may and the current language of ``projects'' or
``activities * * * to * * * conduct * * *'' could be interpreted as
including the actual operation of the exercise. The commenter stated
that the existing Federal Aviation Administration CATEX allowing for
planning grants does not support an exemption for conducting readiness
activities, nor does the Army CATEX for emergency or disaster
assistance provide for the proposed CATEX. The commenter also stated
that perhaps the intent was not to cover the actual exercises
themselves; rather, the documents providing for them; however, this is
not what the language provides.
DHS considered the comments regarding the potential for significant
environmental impact from the conduct of national, state, local, or
international training exercises and offers the following additional
explanation in response. Disaster contingency planning and training
exercises have been conducted by a variety of federal agencies for many
years with no significant environmental impact. The
[[Page 16800]]
Office of Domestic Preparedness (ODP), formerly in the Department of
Justice and now merged into DHS, has conducted terrorist attack
response exercises since 1997. The Federal Emergency Management Agency
(FEMA), which was merged into DHS Emergency Preparedness and Response
Directorate, has also conducted these types of training exercises for
many years to train for response to natural disasters. No evidence of
significant environmental impact has been demonstrated from the conduct
of these exercises by ODP or FEMA.
DHS provides direct support, technical assistance, and funding to
plan, conduct, and evaluate training exercises based on natural
disasters, accidents, and chemical, biological, radiological, nuclear,
or explosive terrorism. Exercises take place in communities around the
nation and involve members from several response disciplines. Realistic
training scenarios that involve local, state, and federal agencies are
necessary to simulate actual conditions and hone the skills first
responders will need in the event of a disaster, whether from terrorist
attack or other natural or manmade causes. Full-scale exercises (FSEs)
are the largest and most complex of these training activities and are
purposefully planned with the participation of the other relevant
governments and response organizations to provide as realistic a
scenario as possible without making unacceptable demands on available
emergency response resources or unacceptable impacts on the communities
or the environments where they occur. In particular, FSE activities
contemplated in the development of this CATEX are normally conducted in
venues such as sports stadia, fairgrounds, ports, or other sites where
large-scale activities normally take place.
Pursuant to the language of the proposed CATEX, training exercises
are required to be conducted ``* * * in accordance with existing
facility or land use designations.'' This means that the entire
exercise, including airborne emissions, waterborne effluents, outdoor
noise, and solid and bulk waste disposal practices, must comply with
existing applicable federal, state and local laws and regulations. The
CATEX on its face does not apply to ``* * * exercises that involve the
use of chemical, biological, radiological, nuclear, or explosive
agents/devices * * *'' that potentially could have an adverse
environmental impact.
Categorical Exclusion H2. The former CATEX published as H2 for
``Issuance of grants for the conduct of security-related research and
development or the implementation of security plans or other measures
at existing facilities'' has been deleted, since it was found to be
redundant with the laboratory operations in B1 and the physical
security activities in B9. The former CATEX H3 for ``Issuance of
planning documents and advisory circulars on planning for security
measures which are not intended for direct implementation or are issued
as administrative and technical guidance'' was found to include
activities that were redundant with the activities described in CATEX
A3.
Categorical Exclusion I1. The commenter suggested edits to ensure
that the use of a portable or relocatable facility does not impact
sensitive resources that may be near the facility. DHS accepted this
comment and made the recommended changes, as well as other grammatical
changes.
Categorical Exclusions J2 and J3 (published in the draft Directive
as categorical exclusions B13 and B14, respectively). Comments stated
that Categorical Exclusion B13 created an incentive for logging by
allowing commercial thinning of forests. Comments expressed concern
that there were no stated requirements for agencies to cite a purpose
for their logging activities such as to remove trees threatening
essential DHS facilities or blocking construction of the same. Comments
expressed concern that Categorical Exclusion B13 opened up the ability
of an agency to allow multiple, 70-acre areas to be cumulatively cut in
environmentally sensitive habitat. Comments requested explanation of
how many projects will be covered under Categorical Exclusion B13, how
many acres will be affected, how many board feet will be harvested, and
what type of trees will be affected. Comments also expressed concern
that Categorical Exclusion B13 may be used in a manner that would not
consider impacts to cultural heritage areas. Comments stated that,
while Categorical Exclusion B13 may be appropriate for certain agencies
within DHS, such as the Federal Law Enforcement Training Center, it
should not be a Department-wide categorical exclusion.
Regarding Categorical Exclusion B14, comments expressed concern
that it lacked requirements for agencies to provide a purpose for the
salvage of dead or dying trees, such as a requirement to remove dead
trees threatening essential DHS facilities or blocking construction of
the same. The comments also expressed concern that Categorical
Exclusion B14 would provide DHS with the opportunity to allow multiple,
250-acre areas to be cumulatively harvested in environmentally
sensitive habitat. Comments also expressed concern over consideration
of impacts to cultural heritage areas. Comments requested some
explanation of how many projects will be covered under Categorical
Exclusion B14, how many acres will be affected, how many board feet
will be harvested, or what type of trees will be affected.
DHS considered these comments and noted several similarities
regarding the potential for environmental impact from the activities
contemplated in these CATEXs. Upon review of the comments and the
administrative record, DHS determined that Department-wide Categorical
Exclusions for these activities were not necessary. Therefore, both of
these CATEXs have been limited in application to the Federal Law
Enforcement Training Center (FLETC).
Activities conducted under these CATEX would be performed for
operational, safety, or natural resources management purposes on FLETC
property. Examples of the situations where these CATEXs may be used
include, but would not be limited to, situations where trees that are
damaged by storms or disease or may be dead or dying would threaten the
operation of FLETC facilities, situations where forest management is
needed to encourage the return of native forest species or to promote
forest health, or where control of fuel load is needed to protect
residential or commercial property immediately adjacent to FLETC
property. In all cases, FLETC property managers would be expected to
employ forest management practices as defined by the Society of
American Foresters.
In addition, a commercial timber harvest program would not conform
to the mission of DHS and DHS does not manage sufficient land area to
sustain such a program. Consequently, there are no existing programs in
DHS to encourage any type of commercial forest use nor are any expected
to be established.
Categorical Exclusion K1. The commenters expressed concerns about
the use of this CATEX in sensitive habitats. They stated that limited
monitoring conducted by wildlife and land management agencies suggests
that there are systematic and on-going environmental abuses and
degradation caused by the Border Patrol during road dragging
activities. Specifically, these one-lane roads, according to the
commenters, quickly become two and three lanes in addition to the off-
road driving on the shoulder done to read foot prints in the sand. The
commenters
[[Page 16801]]
stated that much of the dragging takes place in important habitat for
several endangered species. In addition, the commenter asserted that
since ``trails'' are by definition limited to foot traffic, road
dragging should not be permitted on trails.
DHS considered these comments regarding the potential for
environmental impact from the activities contemplated in this CATEX. In
response to this comment, Customs and Border Protection believes that
it will provide adequate protection for the environment by limiting
this CATEX to road dragging that will not expand the width, length, or
footprint of the road or trail. Drag roads are roads and soft shoulders
that are purposefully made to be wide and are groomed daily for
evidence of the foot traffic from illegal entrants or smugglers. Many
of these roads have been actively maintained in this fashion since the
predecessor to the current Office of the Border Patrol was established
in 1936. This CATEX covers previously groomed and maintained roads and
trails and does not cover the creation of new drag roads; minor edits
have clarified that the purpose is for maintaining rather than creating
roads and trails. New drag roads would go through the same
environmental review that any new road development would require. Care
is taken by the Border Patrol agents to minimize impact to wildlife
assets in the normal course of their duties to defend the border areas
of the Nation.
Michael Chertoff,
Secretary of Homeland Security.
Management Directive 5100.1, Environmental Planning Program
1. Purpose
A. This Directive establishes policy and procedures to ensure the
integration of environmental considerations into Department of Homeland
Security (DHS or the Department) mission planning and project decision
making. Environmental stewardship, homeland security, and economic
prosperity are compatible and complementary. This Directive establishes
a framework for the balanced and systematic consideration of these
factors in the planning and execution of DHS activities.
B. This Directive establishes procedures that DHS will use to
comply with the National Environmental Policy Act of 1969 (NEPA) (42
U.S.C. 4321-4335) and the Council on Environmental Quality (CEQ)
Regulations for Implementing the Procedural Provisions of NEPA (40 CFR
Parts 1500-1508). NEPA is the basic charter and foundation for
stewardship of environmental resources in the United States. It
establishes policy, sets goals, and provides a tool for carrying out
federal environmental policy. NEPA requires federal agencies to use all
practicable means within their authority and consistent with other
essential considerations of national policy, to create and maintain
conditions under which people and nature can exist in productive
harmony and fulfill the social, economic, and other needs of present
and future generations of Americans.
C. This Directive provides the means for DHS to follow the letter
and spirit of NEPA and comply fully with CEQ regulations. This
Directive adopts and supplements CEQ regulations, and is to be used in
conjunction with them. This Directive encompasses other requirements
and establishes the DHS Environmental Planning Program.
2. Scope
A. Substantive or procedural requirements in this Directive apply
to DHS components as described herein and are to be used in program
planning and project development. This Directive applies to any
discretionary DHS action with the potential to affect the quality of
the environment of the United States, its territories, or its
possessions. It also addresses those DHS actions having effects outside
the United States, its territories, or its possessions under Executive
Order 12114, Environmental Effects Abroad of Major Federal Actions.
More specifically, this Directive applies to:
1. DHS mission and operations planning
2. Promulgation of regulations
3. Acquisitions and procurements
4. Asset management
5. Research and development
6. Grants programs
B. This Directive supplements CEQ regulation for implementing NEPA.
In the case of any apparent discrepancies between these procedures and
the mandatory provisions of CEQ regulations, CEQ regulations will
govern.
3. Authorities
This Directive is governed by numerous Public Laws, Regulations,
and Executive Orders, including, but not limited to:
A. Clean Air Act (16 U.S.C. 470 et seq.)
B. Coastal Zone Management Act (16 U.S.C. 1451 et seq.)
C. Endangered Species Act (16 U.S.C. 1531 et seq.)
D. Environmental Quality Improvement Act of 1970, as amended (42 U.S.C.
4321-4335)
E. Federal Water Pollution Control Act (33 U.S.C. 1251 et seq.)
F. Marine Mammal Protection Act (16 U.S.C. 1361 et seq.)
G. Migratory Bird Treaty Act (16 U.S.C. 703-712)
H. National Environmental Policy Act (42 U.S.C. 4321 et seq.)
I. National Historic Preservation Act (16 U.S.C. 470 et seq.)
J. National Marine Sanctuaries Act (16 U.S.C. 1431 et seq.)
K. Title 40 of the Code of Federal Regulations Parts 1500-1508
L. Executive Order 11514, Protection and Enhancement of Environmental
Quality, dated March 5, 1970, as amended by Executive Order 11991,
dated May 24, 1977.
M. Executive Order 11988, Floodplain Management, dated May 24, 1977.
N. Executive Order 11990, Protection of Wetlands, dated May 24, 1977.
O. Executive Order 12114, Environmental Effects Abroad of Major Federal
Actions, dated January 4, 1979.
P. Executive Order 12898, Federal Actions to Address Environmental
Justice in Minority Populations and Low-Income Populations, dated
February 11, 1994.
Q. Executive Order 13101, Greening the Government through Waste
Prevention, Recycling, and Federal Acquisition, dated September 14,
1998.
R. Executive Order 13123, Greening the Government through Efficient
Energy Management, dated June 3, 1999.
S. Executive Order 13148, Greening the Government through Leadership in
Environmental Management, dated April 21, 2000.
T. Executive Order 13149, Greening the Government through Federal Fleet
and Transportation Efficiency, dated April 21, 2000.
4. Definitions
A. All definitions of words and phrases in 40 CFR Part 1508 apply
to this Directive.
B. A glossary of words and phrases as used in this Directive is
included in Appendix A.
5. Responsibilities
Responsibility for oversight of DHS NEPA activities, unless
otherwise delegated, is as follows:
A. The Secretary of DHS (Secretary) recognizes the long term value
of incorporating environmental stewardship into the planning and
development of all DHS missions and activities and exercises the
ultimate responsibility in the Department to fulfill environmental
planning
[[Page 16802]]
requirements. To this end, the Secretary delegates specific authority
for environmental planning to the heads of the Directorates, service
chiefs, and other direct reports. The Secretary delegates to the Under
Secretary for Management, as the Departmental Environmental Executive,
the authority to establish an Environmental Planning Program and to
ensure that environmental planning requirements are functionally
integrated into DHS missions. The following objectives are to be used
in guiding environmental planning activities in DHS:
1. Timely and effective support
2. Sustainable capability
3. Consistency with national security, fiscal responsibility, and other
considerations of national policy
4. Full compliance with all appropriate environmental laws, Executive
Orders, regulations, and other requirements, such as environmental
management systems (EMS).
B. The DHS Department Environmental Executive (DEE) is the Under
Secretary for Management and has authority to fulfill the Secretary's
objectives by ensuring that the Department fully integrates
environmental planning requirements into all DHS missions and
activities. The DEE recognizes that environmental planning is an
important and necessary part of good management practice in the
Department. To this end, the DEE has delegated specific authority for
environmental planning to the Chief of Administrative Services, the
Director of the Office of Safety and Environmental Programs, and to
other DHS officials as set forth in this Directive. In exercising the
authority delegated from the Secretary, the DEE will:
1. Ensure that Under Secretaries and Designated DHS Officials
incorporate environmental planning and stewardship requirements into
their mission requirements to fulfill the Secretary's objectives, the
requirements of NEPA, CEQ Regulations, this Directive, applicable
Executive Orders, and other environmental planning requirements.
2. Support budget requests to meet the requirements of this
Directive.
3. Consult, as needed, with Under Secretaries and Designated DHS
Officials to ensure that they complete appropriate environmental
planning for highly sensitive programs or actions that may require the
attention of either the Deputy Secretary or the Secretary.
4. Delegate requests for environmental planning-related information
received at the Departmental level to the Chief, Administrative
Services for action.
C. The Chief of Administrative Services (CAS) has authority to
support the DEE in efforts to promote good management practice by
ensuring that environmental planning requirements are functionally
integrated into all of DHS missions and activities. To this end, the
CAS has delegated authority to establish a reliable and cost effective
environmental planning program to the Director, Office of Safety and
Environmental Programs. In exercising this authority, the CAS will:
1. Advise the DEE, as needed, on all environmental planning matters
in the Department.
2. Establish, as needed, appropriate Department-wide policy,
guidance, or training to enable the effective performance of
environmental planning throughout DHS.
3. Recommend, as requested by the DEE, appropriate action on budget
requests for environmental planning resources from Under Secretaries
and Designated DHS Officials.
4. Consult with Under Secretaries and Designated DHS Officials to
ensure that their policies and procedures incorporate the requirements
of this Directive.
5. Direct, as needed, the performance of environmental planning
activities within DHS components with particular emphasis on highly
sensitive programs or actions that may require the attention of the
senior executive levels of the Department.
6. Coordinate requests for environmental planning related
information received at the Departmental level among appropriate DHS
components or assign the request to the appropriate components for
resolution.
7. Approve new or revised administrative procedures proposed by DHS
components, including the delegation of authority to sign environmental
documents pursuant to the recommendations of the Director, Office of
Safety and Environmental Programs. Coast Guard, Federal Emergency
Management Agency, and Customs and Border Protection, are delegated
this authority when this directive goes into effect.
8. Revoke, as appropriate, delegations of authority to a DHS Under
Secretary or Designated Official.
D. The Director, Office of Safety and Environmental Programs
(DOSEP) is designated by the Secretary as DHS Environmental Planning
Program Manager and is responsible for establishing and directing the
Department's environmental planning program, and ensuring its
functional integration into DHS missions. The DOSEP will support the
CAS with advice and assistance in carrying out the responsibilities of
that office as set forth in the above paragraph. Such advice and
assistance will:
1. Advise the CAS, as needed, on all environmental planning matters
in the Department.
2. Develop, as needed, policy, guidance, or training to enable the
reliable, timely, and cost effective performance of environmental
planning throughout the Department to fulfill the Secretary's
objectives and other requirements of this Directive.
3. Evaluate for CAS, as requested, budget requests for
environmental planning resources.
4. Direct, as needed, the performance of environmental planning
activities within DHS components, with particular emphasis on
headquarters level programs or actions and those that have the interest
of the CAS.
5. Coordinate and respond to requests for environmental planning
related information received at the Departmental level among
appropriate DHS components or assign the request to the appropriate
Directorate for resolution.
6. Review environmental documents, public notices, and other
related external communications that require a Departmental-level
approval prior to release by the Proponent. This includes all draft,
final, and supplemental Environmental Impact Statements (EIS)
originating in the Department prior to filing with EPA, unless
otherwise delegated.
7. Evaluate new or substantively revised supplemental procedures
from DHS components for conformance with this Directive. DHS
components' supplemental procedures will only be recommended to CAS for
approval after they are evaluated by DOSEP, meet all necessary CEQ and
public review requirements, and incorporate all appropriate comments
and revisions.
8. Evaluate new or revised DHS component procedures for
environmental planning requirements promulgated under laws other than
NEPA to ensure appropriate consistency with existing policies or
procedures and potential for department-wide applicability.
9. Evaluate requests for delegation of authority from an Under
Secretary or a designated DHS Official to sign environmental documents.
Such delegation shall only be recommended for approval if the requestor
has both approved supplementary procedures and adequate staff resources
to fulfill the Secretary's objectives and the requirements of this
Directive. The
[[Page 16803]]
adequacy of staff resources will involve an evaluation of knowledge and
experience in fulfilling environmental planning requirements and
preparing NEPA analyses and documentation sufficient to meet the
Secretary's objectives. Requests for delegation of authority and
supplementary procedures may be evaluated concurrently.
10. Recommend revocation of a delegation of authority from an Under
Secretary or a designated DHS Official for inappropriate procedures or
inadequate staff resources to ensure full compliance with this
Directive or other environmental planning requirements.
11. Assist DHS components, as needed, in reviewing and assessing
the environmental impacts of proposed DHS actions covered by Executive
Order (E.O.) 12114.
12. Review and comment on EISs and NEPA analyses originating from
agencies outside of DHS relating to:
(a) Actions with national policy implications relating to DHS
missions;
(b) Legislation, regulations, and program proposals having a
potential national impact on a DHS mission, and,
(c) Actions with the potential to encroach upon DHS missions.
13. Coordinate requests from non-Departmental agencies regarding
cooperating agency status within DHS, as appropriate.
14. Act as the principal point of contact for DHS on environmental
issues brought before CEQ, the Office of Management and Budget, the
Advisory Council on Historic Preservation, U.S. Environmental
Protection Agency headquarters, and other federal agency headquarters.
This includes requests for alternative arrangements to comply with NEPA
and CEQ regulations.
15. Perform other functions as are specified in this Directive or
as are appropriate under NEPA, CEQ regulations, applicable Executive
Orders, other requirements concerning environmental matters.
E. The Office of General Counsel will:
1. Provide legal sufficiency review, when appropriate, for use of
categorical exclusions, draft, final, and supplemental Environmental
Assessments (EAs), Findings of No Significant Impact (FONSIs),
Environmental Impact Statements (EISs), and Records of Decision (RODs).
2. Advise Proponents (as defined in Appendix A, Glossary) in
consultation with the Environmental Planning Program Manager (EPPM),
whether a component's proposed action is subject to the procedural
requirements of NEPA.
3. Advise Proponents on compliance with NEPA, CEQ Regulations,
applicable Executive Orders, and other environmental planning
requirements.
4. Assist in establishing or revising Departmental or component's
NEPA procedures, including appropriate categorical exclusions (CATEX).
F. All Under Secretaries, Designated DHS Officials, and Heads of
Components will:
1. Fully integrate the requirements of this Directive into planning
for all applicable programs, activities, and operations. Ensure that
the planning, development, and execution of all their missions and
activities conform to the policy and procedures in this Directive.
2. Ensure that DHS Proponents take the lead in environmental
planning efforts and maintain an understanding of the potential
environmental impacts of their programs and projects.
3. Plan, program, and budget for the requirements of this
Directive.
4. Support outreach processes for environmental planning.
5. Coordinate with other DHS components on environmental issues
that affect them.
6. Prepare and circulate environmental documents for the
consideration of others when an action or policy area in question falls
under their jurisdiction as required by 40 CFR Part 1506.9.
7. Request the assistance of DOSEP in preparing the environmental
analysis for any actions covered by E.O. 12114, unless otherwise
delegated.
8. Propose to the CAS, for review and approval, new or revised
supplemental procedures for the implementation of this Directive. All
supplemental procedures will be consistent with the National
Environmental Policy Act, this Directive and the CEQ regulations.
(a) Proposals to establish, substantively revise, or delete CATEXs
are subject to DOSEP review, CEQ review, public comment, and
publication of a final version in the Federal Register before they can
be used.
(b) For those Under Secretaries and Designated DHS Officials with
delegated authority to sign environmental documents, preparation of
handbooks and other technical guidance regarding NEPA implementation do
not need CAS and CEQ approval.
9. Propose to the CAS any new or revised procedures for
environmental planning requirements promulgated pursuant to laws other
than NEPA to confirm appropriate consistency with existing department-
wide policies or procedures and to evaluate potential applicability to
other DHS components. Any new or revised procedures must be consistent
with existing department-wide policies or procedures.
10. Send all environmental documents and procedures via their
respective organizational hierarchy to the DOSEP for review, prior to
release to the public, unless otherwise delegated.
11. Components not listed in paragraph 5.C.7 may request from the
CAS a delegation of authority to sign environmental documents. The
request should include documentation demonstrating that the component
has adequate staff resources with knowledge and experience in preparing
NEPA analyses and documentation sufficient to ensure full compliance.
12. Ensure that all external communications on environmental
planning requirements that are controversial, highly visible,
classified, sensitive or related to matters with potential for
Department-wide implications are coordinated with the DOSEP and provide
DOSEP with a copy of all related formal communications.
13. Respond to requests for copies of environmental documents,
reports or other information related to the implementation of NEPA.
14. Designate an appropriate Environmental Planning Program Manager
(EPPM) and alternate in their respective components as a single point
of contact for coordination with DOSEP on relevant environmental
planning matters.
G. Environmental Planning Program Managers (EPPMs) will:
1. Act as a single point of contact for DOSEP on all environmental
planning matters.
2. Inform key officials within their respective components of
current developments in environmental policy and programs.
3. Coordinate environmental planning strategies for matters within
their respective component's purview.
4. Act to further their respective components compliance with the
requirements of NEPA, CEQ regulations, this Directive, applicable
Executive Orders, and other environmental requirements.
5. Identify discretionary activities within their respective
components and ensure that the requirements of this Directive are fully
integrated into those activities.
6. Work with Proponents in their respective components, as needed,
to fulfill the requirements of this Directive and other environmental
planning requirements. Consultation with Proponents will, at a minimum,
involve the following objectives:
[[Page 16804]]
(a) Ensure that appropriate environmental planning, including the
analyses and documentation required by NEPA, is completed before the
Proponent makes a decision that has adverse environmental effects or
limits the choices of alternatives to satisfy an objective, fix a
problem, or address a weakness.
(b) Plan, program, and budget to meet the requirements of this
Directive.
(c) Support the execution of the requirements of this Directive.
(d) Ensure that their respective DHS Proponents are cognizant of
the potential environmental impacts of their programs and projects.
(e) Monitor the preparation and review of environmental planning
efforts to ensure compliance with all applicable scheduling, scoping,
consultation, circulation, and public involvement requirements.
(f) Advocate and develop, as appropriate, agreements with federal,
tribal, and state regulatory and/or resource agencies concerning NEPA
and other environmental planning requirements.
(g) Coordinate with other DHS components on environmental issues
that affect them.
(h) Coordinate with DOSEP in preparing the environmental analysis
for any actions covered by E.O. 12114.
7. Propose changes in this Directive or their supplementary
procedures through the appropriate lines of authority to DOSEP.
8. Support outreach processes for environmental planning.
9. In consultation with the DOSEP, define appropriate environmental
training requirements for personnel within their respective components.
10. Coordinate with DOSEP on environmental issues to be brought
before CEQ, the Office of Management and Budget, the Advisory Council
on Historic Preservation, U.S. Environmental Protection Agency
headquarters, and other federal agency headquarters.
11. Coordinate requests from non-Departmental agencies regarding
cooperating agency status with DOSEP.
H. Program or Project Proponents will (in consultation with their
respective EPPM):
1. Ensure that appropriate environmental planning, including the
analyses and/or documentation required by NEPA is completed before a
decision is made that limits the choices of alternatives to satisfy an
objective, fix a problem, address a weakness, or develop a program.
2. Ensure that the program or project has adequate funding and
resources to complete appropriate environmental analysis and
documentation.
3. Ensure the quality of the analysis and the documentation
produced in the environmental planning process.
4. Perform the appropriate outreach and communication with federal,
state, tribal, local, and public interests.
5. Ensure that the project budget has sufficient resources to meet
all mitigation commitments.
6. Seek technical assistance from the DOSEP, as needed, through the
appropriate lines of authority to ensure compliance with NEPA.
6. Policy
A. Stewardship of the air, land, water, and cultural resources is
compatible with and complementary to the planning and execution of the
DHS mission. Environmental planning processes provide a systematic
means of evaluating and fulfilling this aspect of DHS responsibility.
DHS recognizes that when environmental stewardship responsibilities are
not managed effectively, there may be social, financial, and
administrative costs, as well as lost opportunities and potential for
lower quality mission outcomes. To effectively meet its environmental
stewardship responsibilities, DHS will integrate environmental planning
requirements into homeland security operational planning, program
development, and management methodologies consistent with homeland
security requirements, fiscal policies, and other considerations of
national policy.
B. DHS Proponents will have the lead role in the environmental
planning process. DHS Proponents will be cognizant of the impacts of
their decisions on cultural resources, soils, forests, rangelands,
water and air quality, fish, and wildlife, and other natural resources
in the context of terrestrial and aquatic ecosystems. DHS Proponents
will employ all practical means consistent with other considerations of
national policy to minimize or avoid adverse environmental consequences
and attain the goals and objectives stated in NEPA.
C. DHS Proponents will provide for adequate staff, funding, and
time to integrate environmental planning into DHS missions and to
perform appropriate NEPA analysis (in conformance with 40 CFR 1507.2)
for programs, plans, policies, projects, regulations, orders,
legislation or applications for permits, grants, or licenses. Should
mitigation be necessary to reduce the environmental effects of a DHS
proposed action, the Proponent will be responsible for providing the
costs of mitigation or ensuring that the applicant provides for
mitigation.
D. DHS Proponents will integrate the NEPA process with other DHS
planning and project decision making activities and other environmental
review requirements sufficiently early to:
1. Ensure that mission planning, program development, and project
decision making reflect the Secretary's objectives and the policies in
this Directive.
2. Ensure that no action moves forward for funding or approval
without the systematic and interdisciplinary examination of likely
environmental consequences according to the policy and procedures in
this Directive.
3. Balance environmental concerns with mission requirements,
technical requirements, and costs in the decision making processes to
ensure long-term sustainability of DHS operations.
4. Allow for appropriate communication, cooperation, and
collaboration between DHS, other government entities, the public, and
non-governmental entities as an integral part of the NEPA process.
E. DHS Proponents will emphasize quality analysis of the potential
for environmental effects among alternative courses of action to meet
mission needs and the development of strategies to minimize those
effects. Documentation required under NEPA will present the evaluation
of environmental effects and the development of the minimization
strategies. The depth of analysis and volume of documentation will be
proportionate to the nature and scope of the action, and to the
complexity and level of anticipated effects on important environmental
resources. Documentation is necessary to present results of the
analysis, but the objective is quality analysis to support DHS
decisions, not the production of documents.
F. DHS Proponent, in consultation with the EPPM and the Office of
General Counsel, will determine the level of NEPA analysis required for
the proposed action. DHS Proponents will complete their NEPA analysis
and review for each DHS proposed action before making a final decision
on whether to proceed with the proposed action. No action or portion of
an action that is the subject of an EA or EIS process will be taken
that limits reasonable alternatives, involves a conflict of resource
use, or has an adverse environmental effect until the ROD or FONSI has
been made public. No actions or portions of an action covered by a
CATEX that requires a Record of Environmental Consideration
[[Page 16805]]
(REC) will be taken until the REC is completed.
G. Laws other than NEPA that require DHS to obtain or confirm the
approval of other federal, tribal, state, or local government agencies
before taking actions that are subject to NEPA, will be integrated into
the NEPA process at the earliest possible stage and to the fullest
extent possible. However, compliance with other environmental laws does
not relieve the Proponent from completing an environmental planning
process, including appropriate compliance with NEPA. In addition,
compliance with NEPA does not relieve the Proponent from complying with
other environmental requirements.
7. Procedures
A. Appendix A contains specific procedures for the application of
environmental planning requirements to DHS consistent with the
Secretary's objectives and the policies in this Directive. Appendix A
also provides a glossary.
B. A DHS component with delegation of authority under Section 5.C.7
may also propose supplemental procedures for CAS approval. Supplemental
procedures specific to a DHS component will be effective upon approval
by CAS.
C. All supplemental procedures must be fully consistent with this
Directive.
D. DHS components may not use the CATEX expressly limited to
another DHS component or CATEX from any other federal agency.
E. The CAS may revoke all or part of a component's delegation and
any supplemental procedures. No component will be given approval to
implement its own supplemental procedures, unless they also have
received complete delegation authority.
F. Components may prepare handbooks or other technical guidance for
their personnel on how to apply these procedures to their programs.
G. Any questions or concerns regarding this Directive should be
addressed to the Director, Office of Safety and Environment.
Appendix A, Timely and Effective Environmental Planning in the
Department of Homeland Security
Introduction
This Appendix provides guidance for timely and effective
environmental planning and includes supplementary instructions for
implementing the NEPA process in DHS. The numbers in parentheses
signify the relevant citation in CEQ Regulations. DHS and its
components will use NEPA as a strategic planning tool, not as a
documentation exercise. DHS is committed to using all of the tools at
its disposal to ensure timely and effective environmental planning and
implementation of the NEPA process.
1.0 General Policies and Provisions
Timely and effective environmental planning involves a systematic
process to identify and evaluate the potential for significant
environmental effects from a proposed DHS action. Proponents of
programs and activities within DHS have a major role in this process
and are responsible for implementing the policies and provisions set
out in this section. This process and the guidance in this Directive
are designed to focus effort on those types of actions with the most
potential for significant environmental effects. The process involves
three levels of evaluation effort as shown in Figure 1: Categorical
exclusion, environmental assessment, and environmental impact
statement. These levels reflect the increasing potential for
significant environmental effects. It is expected that the majority of
proposed DHS actions will be able to be evaluated through CATEX or
environmental assessments. Fewer DHS actions are likely to require an
EIS, which is prepared for those proposals with the potential to
significantly impact natural resources and the human environment.
1.1 Up-Front Planning Activities
A. Continually assess environmental planning in DHS to improve its
effectiveness in supporting and enabling departmental missions.
B. Adapt environmental planning goals and requirements to
complement DHS mission requirements.
C. Fully integrate NEPA and other environmental planning goals and
requirements into program planning and decision-making processes and
formal direction, as appropriate, at all levels of the DHS
organization.
D. Ensure that environmental planning staffs are located within the
DHS organization where they can function as effective members of
interdisciplinary planning and project teams.
E. Enable effective environmental planning through appropriate
training, education, and interagency support relationships.
BILLING CODE 4410-10-P
[[Page 16806]]
[GRAPHIC] [TIFF OMITTED] TN04AP06.000
BILLING CODE 4410-10-C
1.2 Ongoing Administration
A. Ensure that appropriate environmental planning, including the
analyses and documentation required by NEPA, is completed before the
Proponent makes a decision that limits the choice of alternatives to
satisfy an objective, fix a problem, or address a weakness.
B. Integrate environmental and planning reviews concurrently,
rather than sequentially, with the NEPA process.
C. Use public involvement processes to limit the analysis of issues
to those that are important to the decision making at hand.
D. Share information with and coordinate with other federal,
tribal, state, and local agencies early in the planning process and
integrate planning responsibilities with other agencies and
governments.
E. Take into account the views of the surrounding community and
other interested members of the public during its planning and decision
making process.
F. Offer cooperating agency status, where appropriate, to other
federal, tribal, state, and local agencies that have
[[Page 16807]]
jurisdiction by law or special expertise, which means statutory
responsibility, agency mission or related program experience, with
respect to environmental issues.
G. Ensure the scientific integrity of all environmental impact
analyses, mitigation requirements, and monitoring requirements.
H. Make maximum use of programmatic analyses and tiering of
environmental planning efforts to provide relevant environmental
information at the appropriate program and project decision levels,
eliminate repetitive analyses and discussion, ensure proper
consideration of cumulative effects, and focus on issues that are
important to the decision being made.
I. In accordance with 40 CFR 1506.3, consider adopting relevant
existing environmental impact analyses, or any pertinent parts thereof,
whether prepared by DHS or another agency. Adopted environmental impact
analyses of others may be revised or supplemented as needed to serve
DHS purposes.
J. Incorporate material by reference to reduce unnecessary
paperwork without impeding public review. The referenced material must
be reasonably available for public review within the time allowed for
comment.
K. Update the list of CATEX to ensure that DHS environmental
planning resources remain focused on those activities with the most
potential for significant effects.
1.3 Follow Through--Monitoring and Mitigation (40 CFR 1505.3)
A. Practical mitigation measures (i.e., those that can be
reasonably accomplished within the scope of a proposed alternative, to
include offsite mitigation) should be identified to address the impacts
of the proposed action and alternatives. Any mitigation measures
selected by the Proponent will be clearly outlined in the FONSI or ROD
and will be included in the proposed budget for the project or made a
part of the approved application from external entities.
B. Use best management practices and existing environmental
management systems, to implement a project and monitor the predicted
environmental effects. Using adaptive management techniques, adapt the
implementation of a project as new information becomes available.
C. Budget for mitigation. The Proponent will ensure funding to
implement mitigation commitments or ensure that external applicants
provide for mitigation funding in their proposal prior to approval by
DHS.
D. Implement mitigation. Ensure that all mitigation commitments in
the ROD or FONSI are implemented.
E. Monitor Results. Monitoring of the expected environmental
effects from DHS projects, including appropriate indicators of
effectiveness, is an integral part of any mitigation system. The
Proponent is responsible for ensuring monitoring during mitigation,
where necessary, to ensure that the final decision justified in the ROD
or FONSI is implemented. For external applicants, the Proponent is
responsible for ensuring that the applicant provides for monitoring.
The Proponent is responsible for responding to inquiries from the
public or other agencies regarding the status of mitigation measures
adopted in the NEPA process.
1.4 Dispute Resolution
A. The DHS Dispute Resolution Process. During the environmental
planning process, a DHS Proponent and another federal agency may not
agree on significant issues or aspects of the process. DHS policy is to
seek to resolve these disputes at the lowest organizational level
possible. However, there are occasions when disputes cannot be resolved
at this level. Figure 2 provides a diagram of the full dispute
resolution process within DHS. Alternative Dispute Resolution, using
the Institute for Environmental Conflict Resolution (a federal agency
based in Tucson, Arizona) or another mediation service, is an option
that may be used at any stage of this dispute resolution process for
more significant disputes.
When significant disputes arise, it is important to maintain a
record of the positions and interests of all of the disputing parties,
as well as the eventual resolution of the dispute. The Proponent will
provide the other federal agency with written notification, using
certified mail or a comparable method, detailing the nature of the
disagreement. The Proponent will attempt to resolve the dispute within
30 working days of notification.
If dispute negotiations fail, the Proponent must notify the other
federal agency in writing that an agreement is unlikely and provide a
copy to the headquarters of the respective DHS component (where the
component does not have a separate headquarters, then the notification
must go to the Proponent's program office within their respective
Assistant Secretary's staff). From the date of that letter, the
headquarters of the DHS component will initiate 30 additional working
days of negotiations.
If after 30 working days, the headquarters of the DHS component has
not resolved the issue, it will be forwarded to the DEE. The DEE may
appoint a negotiating team and/or seek Council on Environmental Quality
(CEQ) support in resolving the issue.
B. The CEQ Referral Process (40 CFR Part 1504). The CEQ referral
process is available when an agency is of the opinion that there are
unacceptable environmental effects associated with another agency's
proposed actions. Upon receipt of information that another federal
agency intends to refer a DHS matter to CEQ, the DHS lead component
will immediately notify and consult with the DOSEP to notify the DEE
and determine how to proceed. In those instances where a DHS component
is of the opinion that another agency's proposed action that is being
analyzed in an EIS will result in unacceptable environmental effects,
the component should elevate the matter to the DOSEP and DEE at the
earliest possible time to determine how to proceed in accordance with
40 CFR part 1504.
BILLING CODE 4410-10-P
[[Page 16808]]
[GRAPHIC] [TIFF OMITTED] TN04AP06.001
BILLING CODE 4410-10-C
2.0 Intergovernmental Collaboration and Public Involvement
2.1 Purpose
Open communication, consistent with other federal requirements, is
DHS policy. The purpose of this policy is to build trust between DHS
and the communities it serves. Other organizations and citizens play an
important role in protection of resources and their communities.
Collaboration with other federal, tribal, state, and local agencies, as
well as non-governmental organizations (NGOs) and the general public is
an effective means to identify important issues to be considered in the
environmental planning process. In many cases, these parties have
expertise not available in DHS or they may have authorities and
obligations to protect specific resources or to approve or fund all or
a part of the proposal. Knowing these issues early in the environmental
planning process enables a focused effort on issues that are of most
interest to the public and importance to the relevant DHS decision.
Collaboration, through meaningful and regular dialogue with those
outside of DHS, can serve to avoid conflicts and facilitate resolution
when conflicts occur. Awareness and consideration of the needs and
requirements of other organizations and the general public,
[[Page 16809]]
consistent with mission requirements, will enhance the effectiveness of
DHS missions.
2.2 Coordination With Other Government Agencies, Tribes, States, and
the General Public
DHS policy is to seek out and coordinate with other federal
departments and agencies, tribal, state, and local governments, non-
governmental organizations, and the general public early in all
appropriate aspects of environmental planning, especially in an
environmental impact analysis process. In many cases, these
organizations have expertise not available in DHS or they may have
authorities and obligations to protect specific resources.
A. When DHS is the lead agency for an environmental planning
effort, it is responsible for the scope of the NEPA analysis and the
use of processes to coordinate with other government agencies, tribes,
states, and the general public to assist in defining that scope.
B. When another agency has expertise to analyze the potential
environmental effect of a DHS proposal, the Proponent will coordinate
with it early to ensure high quality and complete analysis.
C. DHS will coordinate draft environmental impact analyses with
appropriate federal, tribal, and state governments, as well as other
interested parties.
D. Among the various Federal agencies that can be involved in an
environmental planning effort, EPA has a special role. Section 309 of
the Clean Air Act provides the EPA Administrator with authority to,
among other things, review and comment in writing on the environmental
impact of any matter relating to the environment contained in any
authorized federal projects for construction and any major federal
agency action for which NEPA applies. At a minimum, DHS Proponents must
ensure that their EISs are appropriately coordinated with the EPA.
E. Proponents will make special effort to coordinate with affected
tribes. In particular, Executive Order 13175, entitled ``Consultation
and Coordination with Indian Tribal Governments'' directs all federal
departments to, among other things, ``strengthen the United States
government-to-government relationships with Indian tribes and establish
regular and meaningful consultation and collaboration with tribal
officials in the development of Federal policies that have tribal
implications * * *''
F. Obtaining the views of the surrounding community and other
interested parties during planning and decision making processes helps
proponents to focus the analysis to issues that are important to the
public or the decision making at hand and set the boundaries of the
environmental evaluation. Public involvement is a process that starts
early and continues throughout the planning and early stages of
conducting a NEPA analysis.
G. Scoping (40 CFR 1501.7) is a term for the process of
coordination with other government agencies, tribes, states, and the
general public that is required for EISs. DHS strongly encourages the
use of a process like scoping for EAs.
2.3 Lead Agencies (40 CFR 1501.5)
The lead agency in an environmental planning process has the
responsibility to define the scope and substance of the environmental
planning effort.
A. DHS will be the lead agency when a proposed action is clearly
within the province of DHS authority. Likewise, an Under Secre