EM CX role in the NEPA Integrator proves invaluable

Published Feb. 10, 2023

HUNTSVILLE, Ala. – The Environmental and Munitions Center of Expertise (EM CX) continues to provide quality guidance in ensuring adherence to the environmental regulations of the National Environmental Policy Act (NEPA) required for all Federal government projects.

The Council of Environmental Quality’s (CEQ) NEPA requirements consist of two analyses: Environmental Assessments (EA), which determine whether a federal project has the potential to cause significant environmental effects, and Environment Impact Statements (EIS), which determine whether a project will significantly affect the quality of the human environment. 

In 2016, the U.S. Army Installation Management Command (IMCOM) requested that USACE determine how it could assist in the execution of NEPA projects. In response to IMCOM’s requests, USACE established the NEPA Integrator team within the EM CX. This partnership between USACE EM CX and IMCOM serves as the central point for facilitating NEPA adherence and execution.

“The NEPA partnership is a one-stop shop for IMCOM to meet compliance nationwide and foster consistency. By doing so, we are able to free up IMCOM,” said Rebecca Latka, Biological Scientist at Huntsville Center.

The EM CX implements the NEPA program by serving as a liaison between agencies and providing regulatory guidance, this entity is known as the NEPA Integrator team. The NEPA Integrator team partners with districts to manage programs and project funding.

“The partnership provides product consistency. We advise on adherence to policy and then look to the other districts to execute,” said Mary Margaret Mangenot, EM CX Chief of Environmental Regulatory Compliance Division.

With a small Integrator team of four USACE employees within the EM CX, a key to success is teamwork, Mangenot added.

“We all have a role to play,” said Mangenot. Manroop Chawla, Environmental Biologist at the Construction Engineering Research Laboratory (CERL) adds “the EM CX team is great at effective and timely communication both with USACE headquarters and the Corps districts, to facilitate NEPA projects execution. We have open communication across the board with all organizations we support to help make this a successful program.”

“The partnership has evolved by incorporating lessons learned from the projects that are executed each year. An example would be development of templates for scope of work, EA, and EIS, thus reducing costs to the program,” adds Chawla.

Current NEPA projects include several EISs and EAs, and Programmatic EAs, including two EISs in Hawaii. One such project that the team is tackling is an environmental assessment of Pohakuloa, a 100,000-acre training parcel, a portion of which is leased to the Army by the state. 

The NEPA process could take two to three years to complete; however, Hawaii Environmental Protection Act (HEPA) requirements must also be met for the continued use of state land for military training. HEPA involves more stakeholders and adds complexity to the process.

As the EPA’s environmental regulations change, as do the NEPA requirements, and the team must adapt as needed. One such change was made in September 2020 and required a shift in the completion timeline for EAs. With the new regulations, the completion of the final report is now required within two years from the notice of intent, whereas they were previously given three to five years to complete.