Written by Ravi Pathare, Staff Scientist, who works in BBJ Group's Real Estate and Transaction Support
The Illinois Department of Transportation (IDOT) Phase I Training on October 4th was an eye-opening, 7.5-hour day of bad coffee, a passable brisket sandwich and an in-depth explanation of the various aspects involved in the IDOT Phase I process. While the October 4th training was IDOT-focused, the National Environmental Policy Act (NEPA) process applies to many projects. NEPA applies to any federal action, which is any project that uses federal funds, requires a federal permit, or requires federal approval and/or oversight. It requires the plans to have a purpose and need for the project, evaluate alternatives, consider public input, make informed and documented decisions and disclose impacts to the public. With many consulting projects falling under the umbrella of federal action, it is important for consultants to understand what investigations and assessments are required to be NEPA-compliant. From an environmental perspective, this would include investigations and assessments of hazardous waste, wetlands, trees, noise and cultural resources.
As someone who previously had only a small amount of exposure to NEPA projects, it was interesting to learn what was included in a full NEPA review. On my first day with the BBJ Group Telecommunications team, I came across that then-mysterious acronym, NEPA. This came up specifically in regards to antenna collocations, where we conduct a pre-NEPA review to determine any adverse effects to the surrounding area caused by the proposed collocation. In most cases with collocations, we usually don’t even get to a formal NEPA review, as many of the collocations do not have any adverse effects on surrounding properties, and exemptions can be made for most of the rest.
It was after the Phase I Training that I learned that the pre-NEPA reviews would be classified as a Categorical Exclusion. Sometimes, however, considering a building’s historical significance, we complete Section 106 reviews, a historical review of the building and immediate area and a component of the National Historic Preservation Act (NHPA). It was interesting to learn that Section 106 reviews are just one small part of the entire NEPA process, and there is potentially so much more that could be involved, even with our antenna collocations.
The Phase I Training also broke down the three basic types of NEPA documents: Categorical Exclusion (CE), Environmental Assessment (EA), and Environmental Impact Statement (EIS). CEs are prepared when it is known that the project will result in no significant environmental impacts. For example, changing the size of a street sign would likely involve a CE. For example, changing the diameter of a stop sign from 4 feet to 5 isn’t going to have any serious environmental impacts. An EA would be completed when it is unsure whether or not the project will result in any environmental impacts, e.g. the widening of a roadway. Maybe there’s nothing of note, maybe there’s a rare tree along the roadway. An EIS would be completed when it’s known that the project will result in significant environmental impacts, such as the construction of a new interstate. Trees are going to be cut down, animals are going to be displaced, the whole nine yards. You’d be more surprised if there were somehow no environmental impacts.
Environmental aspects were only a small part of the full presentation, but understanding the connection between the environmental aspects of IDOT Phase I and the larger scope of IDOT projects was important in understanding why the numerous parts of the Phase I process take place, and when environmental consultants should get involved.
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