Event ID: 2840280
Event Started: 2/23/2016 1:45:55 PM ET
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Getting started with our conservation webinar I and the national technology specialist for the NRCS used national technology support Center in our moderator today also located at our center is Don Riley. On is our environmental compliance -- you may begin.

Thank you and hello and welcome to today's webinar entitled NRCS and environmental evaluation series number 11 , appropriate use of categorical exclusions. I am happy that you have taken time to join us today for this, the 11th installment of the environmental evaluation series. If you are unable to some review the previous webinars in the series I encourage you to review the recordings as they are intended to provide a comprehensive overview of the NRCS process. We'll make an attempt to answer questions at the end of today's presentation. Please feel free to type your questions as we go through the subject matter over the next hour or so. Today's webinar as the title suggests is focused on the appropriate use of the numerous USDA and NRCS specific categorical exclusions. Our goal is that you, the participant, we'll learn how to use this categorical exclusions for national environment policy act compliance progressively subject matter our presenter today will provide background information on them and why categorical exclusions argues, discuss specifics of the various categorical exclusions and provide examples of projects to which they might apply. Speaking of our presenter, I am very happy to introduce Karen Fullen to you today. Karen is the ecologist at the West national technology support Center in Portland Oregon. She has been on the staff there in the regional office since 2014. Prior to joining this intercession was state biologist in Idaho where she had state-level environmental compliance duties. In addition she has spent time as a soil conservationist and what went team biologist so she brings much experience and brought suspect is perspective to the subject. I have found her to be an excellent resource and I am sure you will as well. With that I turn the presentation over to you, Karen.

Thank you very much for that lovely introduction and today everyone. We had numerous requests from the states to do this webinar and wanted to do it because we find that many of you seem uncertain how to use the CatEx and hesitant to use them. I know that like me, many of you were taught to adhere to the national programmatic document and you continue to do that. The categorical exclusions are often a better way to documents that NRCS is complying with NEPA and I hope you understand that after we talk about the legal foundations, policy and procedures, and documentation requirements for NRCS to use the CatEx. As mentioned we will be going over each one and giving a few examples of where they might apply.

Before I really delve into this, I want you to know that there is no on standard abbreviation for the term categorical exclusion. Different agencies use different terms, some say CE, some say CX and there are all different ways to spell CatEx. Our national compliance handbook uses CE so that is what is on most of the slides throughout the presentation, but I preferred the pronounceable CatEx so that is what you will hear me say . It is all the same thing.

Categorical exclusion is defined in the code of federal regulations or CFR title 40 of the CFR part 1500 through 1508 contains the Council on environmental quality regulations for implementing the national environmental policy act or NEPA. The Council on environmental quality called CEQ for short was established under the NEPA statute and consists of a small group of people in the executive office of the president who work with federal agencies to develop their environmental policies. The CEQ regulations allow for the use of CatEx to -- a categorical exclusion means the category of actions which do not individually or cumulatively have a significant effect on the human environment and which have been found to have no such effect in procedures adopted by a federal agency and implementation of these regulations and for which therefore neither an environmental assessment nor an environmental impact statement is required. NRCS actions requiring NEPA requirements include federal -- compatible uses on easements, among others. After determining there is a federal action, NRCS should comply with NEPA by first determining if there are categorical exclusions that apply to the proposed actions. Is no CatEx applies then in a or EIS is needed.

In addition to the CEQ regulations legal authority for NRCS to use a certain CatEx is in title VII of the CFR. The CEQ regulations require federal agencies use to adopt their own procedures to implement NEPA. USDA and NRCS posted so by developing their own speculations that supplement the CEQ regulations. In this regulations both USDA and in RCS -- EIS. CEQ reviews and approves agencies NEPA regulations including their CatExes. Agencies must show the category of action should be excluded. That usually means there have already been a series of EA's prepared that analyze the environmental effects of those actions and that resulted in findings of the significant impact. CatExes are normally found in an agencies NEPA regulations in one agencies CatEx cannot be used by another agency. Best NRCS can only use its own or USDA CatExes and cannot use a CatEx established by another agency, even another USDA agency such as forest service or FSA.

Agency CatExes and NEPA regulations are established a public process with a review period allowing interested agencies and the general public to submit comment for the agencies to consider. In a summary, CEQ regulations allow agencies to use CatExes and those used by NRCS were developed a public process approved by CEQ and published in NRCS and USDA regulations. Those three sets of regulations give NRCS but legal authority to use the CatExes discussed today.

As mentioned earlier, federal agencies comply with NEPA but first determining if there is a CatEx that applies to the action agency is proposing to take if no CatEx applies in EA or EIS is needed. NRCS documents compliant with NEPA with the responsible federal officials complete section Q through letter S on form. Know that the finding that a proposed action is categorically excluded is possible for the finding that a proposed action has been sufficiently analyzed in an existing NEPA document. This is because a CatEx is the first option for NEPA compliance that [ Inaudible ] should consider. In the event of a legal challenge to in NRCS action a document finding that a CatEx complies is more legally defensible than a finding that an action has been sufficiently analyzed in one of our national programmatic NEPA documents. We'll talk more about documenting this finding in the reasons it is more likely to be sensible at the end of the presentation today.

Policy on the NRCS compliance with NEPA and other environmental laws and requirements is provided in title 190 part 410 of the general manual. Part 410.6 he tells policy on the use of categorical exclusions. The national environmental compliance handbook contains detailed information on how to use CatExes in subpart D, 16.46 as well as much a lot of other guidance on how to comply with NEPA, other environmental laws and agency policy. NRCS planners and partner staff document environmental evaluations only NRCS EPA 52 are required to know the policy and use the NECH. If you are not familiar with those go to the directives and find them and become familiar.

There are two basic requirements that must be met in order to use a CatEx. First, the proposed action must fit within the category of actions that have been categorically excluded in the NRCS or USDA published NEPA procedures and meets the criteria to use the CatEx. And there can be no extraordinary circumstances that may result in a significant adverse effects that cannot be mitigated. We'll talk about the criteria to use CatExes in a minute the first let's review the extraordinary circumstances.

The factors that may lead to a determination of extraordinary circumstances are the same factors used to make a determination of significant. Eight factors in -- must be reviewed to determine whether a proposed NRCS action meets the criteria for no extraordinary circumstances to ensure that an action is eligible for a CatEx. But for a moment at the next to the last significant factor on this slide. Will the preferred alternative likely have significant adverse effect on any of the special environmental concerns I wanted to point out to you that the mere presence of special environmental concerns such as endangered species habitat or cultural resources in the planning area does not automatically mean that you cannot use the CatEx. They CatEx may not be used if there are or could be significant adverse impacts to protected resources that cannot be mitigated. Consultation under the Endangered Species Act for state or tribal historical preservation officers should be completed before a determination of significance or extraordinary circumstances is made.

This'll be a good time to point out then that the CatExes are only used to comply with NEPA. They did not eliminate compliance of other environmental laws like the Endangered Species Act, national historic preservation act, Clean Water Act , state and local laws protecting the environment, etc.

You cannot use a CatEx is an action without a CatEx are included in the preferred alternative. Or action will have, as we just discussed, significant adverse impact the impacts that cannot be mitigated, the call extraordinary circumstances.

You also cannot split up in action into smaller component parts to avoid the need for in EA or EIS. And thinking about whether actions are connected or not, think about whether they trigger other actions, cannot proceed unless other actions are taken previously or simultaneously, or depend on other actions to justify their existence. In other words, they do not have independent utility. For example, NRCS typically would not provide financial assistance for an irrigation system if there were no sources of irrigation water to connected to. The water well or the diversion structure to divert surface water would be connected to an irrigation system.

In our regulations on CatExes, NRCS established six overarching criteria that we call sideboards that apply to all of the CatExes. All of these must be met to meet any of the CatExes. The rationale section of the CPA 52 should explain which of these sideboards listed on this slide in the next apply and how the project meets them. You can disregard sideboards that do not apply to the preferred alternative question. For example, is the action does not involve work in streams, then do not address whether the action is based on natural stream dynamics and processes. And said, simply include a statement that the sideboard does not apply.

Note that one sideboard requirement is that NRCS conservation practice standards are followed. Recipients of grants program funds like those NRCS administers under the regional conservation partnership program are encouraged but not required to use the conservation practice standards. If they do not in EA or EIS will likely be needed for that are CCP agreement.

Here are the original soil conservation service CatExes from our very first NEPA regulations published in 1979. If you don't know, NRCS prior to 1994 was known as the soil conservation service. These are still in effect today, but rarely if ever did that apply to the type of work that field offices do today. Back in 1979, NRCS. Providing financial assistance to implement conservation practices agreed to under today's conservation programs in Farmville. These generally do not apply to those types of practices.

Here is the list of seven USDA CatExes. I wanted you to see all seven. I apologize for the number of words on this screen, but I wanted to specifically call your attention to number three and number six. Those are in bold. Number three, inventories, research activities and studies such as resource inventories and 14 and a collection with such actions are clearly limited in context and intensity. This CatEx is often used for conservation innovation grant agreements and program contracts where interim practices are planned. The national programmatic NEPA document analyze the impacts of conservation practices with something called a network effects diagram, interim practices do not have network effects diagrams developed yet. We are studying those practices, testing the technology to see if we want to make it a permanent part of our field office [ Inaudible ]. It would be incorrect programmatic national document when you have interim practices plan. This CatEx is the only one that might apply.

Number six, activities which are advisory and consultative other agencies in public and private entities is often used for contracts funding development of a conservation activity plan or cap, funding a contract with the development of a cat is a federal action subject to NEPA, but the plan itself is not , is not going to have any effect on the environment. We can't control what the land owner does with that plan unless until they come back to us and apply for equal or some other program to implement that plan. For the contracted just funds the CHP we often use USDA CatEx.

Now we're going to delve into the list of 21 CatExes that we have had available to us since 2009 and that too often apply to program contracts that field offices are funding with individual producers.

CatEx number one you can see a good example of where CatExes may have their own specific criteria embedded within them. In addition to the over arching sideboards that we went over. CatEx number one includes a specific criteria that the vegetation planted cannot include noxious weeds or invasive plants and the planting is done on disturbed sites for the purpose of restoring or maintaining ecological functions and services. You are encouraged to interprets the CatExes broadly, however. For example, plantings here would not necessarily have to restore and maintain every possible function or service of the ecological site it provides. This CatEx should be used for most of our vegetative planting practices.

CatExes number two and number three are related and dealt with the restoration of hydrology. They would often be used for floodplain or wetland restoration projects, removing dikes and associated [ Inaudible ] plugging and filling excavating drainage dishes to allow hydrology. By the way, in a CatEx gives examples using words like such as an including, it does not mean that your proposed action has to be one of those things. Like a culvert pipe, valve gate or fencing listed here under CatEx number two. Those are just examples to help you decide if the CatEx applies to your proposed action.

CatEx number four, repairing or replacing existing culverts, great stabilization, and water control structures and other small structures that were damaged by natural disasters could be used for many emergency watershed protection program projects and when replacing or repairing damaged structures on wetland reserve easements.

CE number five is another that is applicable to wetland and floodplain restoration projects.

CE number six is one that we don't use a lot, but we can and have used it, removing or relocating structures in the 100 year floodplain or within the area of a dam, this is appropriate for emergency watershed protections and some of our watershed projects. And can also be used for relocation of animal feeding operations out of the floodplains.

CatEx number seven, removing storm debris and sediment involving a natural disaster. Here is another when the were primarily be used in emergency watershed protection program product -- projects.

CatEx number eight, stabilizing stream banks and associated structures to reduce erosion through bioengineering techniques following a national natural disaster. This also be used under [ Inaudible ] and equip projects. Any stabilization project that uses bioengineering techniques. Note that you can use natural and synthetic support materials such as rocks, riprap and Geo textiles in concert with living and nonliving plant materials those not engineering techniques however a project that use only riprap without -- recall from the sideboard that in order to CatEx in action in streams, the work must be based on principles of natural stream dynamics and processes.

CE number nine in 10 are preparing maintenance on existing structures or improvements on construction, constructing small structures or improvements for the restoration of wetland repairing and instream or native habitat. These would apply to many of the things we do on rangeland, peninsulas, water developments, watering facilities for livestock, getting or trying to get the livestock out of the stream I could manage how long livestock hang out in the stream.

My personal favorite, CatEx 11, restoring an ecosystem, official wildlife habitat, biotic immunity or population of living resources to a determinable pre-impact condition. -- Wildlife program, other wildlife projects. Is helpful to have ecological site descriptions or other descriptions or photographs of plant communities that existed before an impact and that impacts could be cultivation, livestock grazing or natural disturbance such as fire or flooding.

CE number 12 and number 13 number 12 is repairing or maintenance of existing constructive -- passageways so aquatic organism passage would be the practice standard associated with that. Number 13 installing, repairing, maintaining or installing the screens on existing structures. For example, irrigation diversions. Things to protect --.

Number 14 through 17 we're going to talk about here over the next few slides. They are especially useful for our watershed rehabilitation projects and some may also apply to EWB or some equip projects. All of them have a CE specific criteria intimate. The work will be confined to the existing footprints and no major change in reservoir or downstream operations will result.

CatEx number 50, repairing or improving spillways could be used for some rehab projects and also to repair or improve pond that were originally constructed to [ Inaudible ] standards.

Repairing embankment slope failures on structures may also be used to repair ponds

Number 17 this is one that I see quite a bit, this is describing the work that is done quite a bit in many of the watershed rehab projects that I've seen increasing the freeboard of an existing dam or dike and again I will call your attention to the CE specific criteria for the purpose is to ensure during extreme events flows are confined to the spillways so that the damp does not overtop which may result in catastrophic failure and elevating the top of the dam will not result in an increase to labor strength levels. Again work will be confined to the existing dam and abutment areas. If you need a large area somewhere else of site, outside of the dam, and abutment area or you need a large stage meant there's staging area, this is probably not going to be able to use these CatExes. -- And you should definitely talk to my counterpart there at the center, David Huffington. If you are thinking one of these CatExes may apply to your watershed Project.

CatEx number 18 is related to number six but instead of moving structures out of the floodplains, here we are modifying them to prevent flood damages. Damages such as elevating structures or ceiling basis.

We are winding down to the last three that have broad applicability to many projects, so hang in there with me. We are almost through with them all. CatEx number 19 is interesting, and I interpreted it to nearly for a long time so I will tell you how it should read. Undertaking minor agricultural practices, to maintain and restore ecological conditions in floodplains after a natural disaster or number two, on Lance impacted by human alteration. Cultivation, livestock grazing, forest stand improvement activities, just about all of the management practices that people use to produce food, said, fiber, 4-H could be considered in impacts of a human alteration impact. Any minor agricultural practices taken on just about any agricultural lands, plant producing, food feed, fiber, 4-H could be CatEx under this one.

And finally, number 20 and number 21, soil erosion, soil conservation and water conservation. Number 20 would apply to many of our practices that reduce erosion, great stabilization, sediment basis, terraces, grass waterways, filter strips, conservation crop rotation, cover crops, reduce tillage practices. Just a few examples. 21, a few examples include minor irrigation land leveling, irrigation water conveyance, in irrigation water control structures, irrigation systems, irrigation water management, for example.

We made it through all of them. Let's go back to how we document one or more of these CatExes. Back in the day, back before 2009 when we got the 21 CatExes that we just read through, field office staff instructed to use the national programmatic EA to document NEPA compliance as long as there were no extraordinary circumstances. Otherwise, in the a or EIS would have been needed for each individual program contract. The NRCS national programmatic NEPA documents only analyze impact and a broad national scale using those network effects diagrams for the conservation practice standards that I mentioned earlier. In the Emmett event of a legal challenge the analysis, the broad analysis in those national NEPA documents would not be as legally defensible as using a CatEx. NEPA requires a site-specific evaluation of impacts and those national programmatic documents don't give you that. The NRCS environmental evaluation that you do us part as planning and document on the 52 form, but does give you the site-specific impacts, but it by itself is not a NEPA document. There are three ways that agencies can comply with NEPA. Is a categorical exclusion applies or in EA or EIS is needed by the way, there should only ever be one box checked in section 2 of the form. It is an either/or situation. You cannot CatEx part of the action and save the rest of the action is covered in and EA.

In the example shown on this and the previous slide, the RSO checked the box, box number two that the action is categorically excluded and then they choose the appropriate CatExes from the drop-down menu in the section our and write a little narrative statement about how the sideboards are meant under the rationale the findings documentation and finally sign and date in section F.

To sum it all up with a single slide, if one or more CatExes describe all the practices and activities to be implemented under the preferred alternative and there are no extraordinary circumstances that cannot be mitigated and all of the applicable criteria and sideboards are immense, then you should use the CatEx and not adhere to the national programmatic EA. With that I'll be happy to take questions.

Okay. Thank you, Karen for going through that we do have a few questions that pop 10. Some are somewhat general and will maybe hit those first. Specifically, I think maybe some folks got on a little late so I will let you answer just a quick just as a quick summary the question came in are these CatExes NRCS specific or USDA? If you can quickly say again for those who joined late which once apply.

We went over all of the CatExes that NRCS can use which include those published in the NRCS NEPA regulations and those in the USDA NEPA regulations. Any USDA agency can use the USDA CatExes, but otherwise agencies cannot use each other's CatExes. They have to use their own that are in their own NEPA regulations.

Great, and then just a clarification that someone had asked and the answer is yes, but if you want to expand on its, they were asking did they hear you say that the use of NRCS practice standards was impact of sideboards for the use of categorical exclusions? The answer is yes and I didn't know if you want to expand on that answer at all.

I don't think it needs any expansion. Yes, that is one of the sideboards and those sideboards apply to any CatEx that we use.

Now some specific questions and this is one that has been discussed a number of times and maybe you could just take us second or two to clarify and the asking specifically about caps and should the USDA categorical exclusion be used for all caps

You now, that's something that the responsible federal official has to determine for each individual action. I am not a responsible federal official, I can only advise you so yes, the USDA CatEx for -- will make a back four activities which are advisory and consultative, so there is an NRC is action to fund the account, providing funding is a federal action subject to NEPA so we had to document how we are -- any effect on the environment. That one is generally advised to apply to the CAT. The the AP plan itself is advisory and consultative to the land owner. We can control but the land owner does what does once they receive it from the technical service provider. We hope that they will later come to us and apply for program funding to implement the recommended practices in the CIP but until that happens, when that happens then we will have to do another CPA 52 for that action of funding implementation of the CAP. There are multiple steps involved with conservation activity plans because first there is a program contract funds CAP and then there is a second program contract usually for implementation.

There are several questions I'm going to take the liberty to answer if you don't mind concerning natural disasters and the term had been used for a number of allegorical exclusions and folks are questioning what would constitute a natural disaster if you go to the DWP language it says that the program helps remove threats to life and property that remain in the watershed in the aftermath of natural disasters including but not limited to floods, fires, windstorms, ice storms, hurricanes, typhoons, tornadoes, earthquakes, volcanic actions, slides and droughts. That gives you a general idea of what is meant when you hear the term natural disaster from the manual. If you want to add anything to that, Karen.

I would say that again they should be interpreted broadly. It doesn't say it has to be a presidentially declared disaster or estate declared disaster. Sometimes, for instance, the CatEx for stabilizing stream tanks. We can use that one a lot's. A lot of times there are just as there is localized flooding that does not rise to the level of having in DWP project or being some sort of officially declared disaster. It just took out the landowners stream bank maybe a few neighboring landowners. As long as there has been some sort of flood event, fire, windstorm that you could point to and say this caused that damage and now you're going to fix it I would say that CatEx applies.

Okay. Another fairly broad question, and it just basically is asking what would be the process for adding a new CatEx to the list and how would NRCS go about that? That is a good question, because we are starting -- we have started the process and the way we did it was to go through CatExes that other agencies are using and pick out those that we thought would be applicable to NRCS actions. Now we have to find the documentation that support that they should be a CatEx for the actions had to have been analyzed in environmental assessments that resulted in findings of no significant impact. We have to put all that documentation together and's of course there will be some internal NRCS review and then they will be reviewed by the Council on environmental quality, CEQ and is CEQ approves that will be published in the NRCS NEPA regulations. It is a long and involved process. It does not happen quickly.

Okay. A couple of CE specific questions, specific to it says could you use categorical exclusion number one categorical exclusion number 14 say a forage and biomass planting of a grass such as Bermuda grass?

The CE specific criteria there says it does not include noxious weeds or invasive plants. If Bermuda grass, first of all you should take your states noxious weed list. If it is a state or federally or County listed noxious weed then I would say no. It is known to be invasive. I am from California originally and it certainly invaded all of my flower and shrub that's a very vigorously. If you can justify how in your area it is not invasive say you could.

Okay.

You always have to be ready to defend your decision, be ready to give reasons for the decisions you've made.

A question came in here and it was one of the more key points, I think, and maybe is worth reiterating. The individual is asking about choosing and Jason choosing option number two versus option number three were making you're finding and obviously this webinar is focused on the use of categorical exclusions, and if you just want to take maybe 30 seconds to once again reiterate the significance of the categorical exclusions as compared to those other NEPA documents.

The NEPA statutes, the NEPA law requires a site specific analysis of the environmental impact of the federal action. To determine if it is significant in environmental impact statement is required. If you are not sure if it is significant in environmental assessment is required. The NRCS actions have been broadly analyze at the national programmatic document, it was seen as a way to save people in the field from having to write in EA or EIS for every single program contract that we funds. We could not possibly find hundreds and thousands of them that we do every year is providing a NEPA document for each individual contract. But, those broad programmatic national documents did not provide site-specific analysis that NEPA requires. The evaluation that you do us part of planning and document the 52, that requires a site-specific analysis that a CPA 52 form is not in EA or EIS. Is not recognized under the NEPA statutes. However a categorical exclusion is recognized in the NEPA regulations published by CEQ. It is a legitimate way, an alternative way to comply with NEPA out doing a site-specific EA or EIS.

A follow-up to that in just to give you an option to reiterate is the question is, is there any benefit to the RSO to selecting options if they apply?

There is a benefit, and in fact it is wrong. Either in action, the entire action is categorically excluded from the need for an EA or EIS quarter and EIS or EA is needed. You should never check more than one bottle. -- On box.

A question here comes back to something you've already mentioned, but we would throw it out there again just for discussion, and it comes back to interpreting these categorical exclusions broadly, and specifically to see -- CE number nine an example of a small structure.

I would say a small structure is anything smaller than a dam. That is my personal opinion. I think that most of the structures we do our small-ish, it is usually individual landowner scale, it is not something that could potentially impact an entire community. You might look at job classes, engineering job classes, if it is a structured that needs approval at the state office level or beyond, maybe it is not small. Interpret them probably, because they are more defensible, legally defensible than those national programmatic's would be.

That same philosophy would apply to 19 we're talking about minor practices which you discuss, correct next

Exactly. Be ready to defense that it is minor or small, but if you can do that then fine, use transit.

All right. I'm trying to look through here. There is -- on dealing specifically with a CAP SS sent a forestry CAP result in a forest -- categorical exclusion number three be applicable as well as categorical exclusion number six?

Yes. You could use the one for inventory as well. That would cover actually having a person walks to the forest and collect inventory data or whatever small environmental impact there might be from that.

You can use more than one for an action but you cannot use a CatEx and in EA or EIS.

Okay. I think that gets us through the questions that I am seeing that we can answer ends -- and that does it. I want to thank you for taking the time to prepare and pulling this information together and being able to answer some of these questions for the listeners out there and for everybody else out there is dialing in, you see there the contact information for those of us that if you have additional questions that you can feel free to contact us of course I am Don Riley in the ease of have Roslyn more acting in the central. Our find the center Karen presented today, and then of course David Ethington down in Arkansas. Karen, again thank you so much for your time and your preparation. With that, Holly, I turned back over to you.

Okay. Thank you Karen and Donna for making the presentation, we think our participants for joining us today. We had more than 300 people join today's webinar. To provide your feedback about the webinar and if you selected to earn CE use please return to your open browser window to continue the process offered by step two and this concludes our webinar presentation today. Thank you.

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