NEPA Feasibility Study Talking Points

· The purpose of the study was to analyze whether there is room for improvement in the agency’s overall approach to performing activities related to compliance with the National Environmental Policy Act (NEPA). This study identified areas of NEPA implementation that can be improved through efficiencies in personnel staffing, organizational structure, communications, technology application, and procedures.

· Much of the information collected and analyzed in this study can be used to identify ways NEPA performance can be improved upon, both from a quality and from an efficiency perspective.

· The Chief supports the findings that were presented in the study:

o Due to the complexity of NEPA and associated legal compliance issues, there is no consistent view of the “NEPA process”. The lack of objective quality standards and performance measures for NEPA documents hampers the identification of effective and efficient practices.

o NEPA-related activities are often carried out in partnership with other federal agencies, tribes, and other entities. Where these relationships are impaired, the accomplishment of NEPA-related activities suffers.

o Disparity in training, skill levels and employee development, and inconsistent availability of qualified employees were identified as issues.

o The report notes large discrepancies in budget and types of resource allocations For NEPA activities. Some units no longer have adequate budgets and/or personnel to staff interdisciplinary teams.

o Large variations across the agency in approaches to accomplishing NEPA related activities increases the difficulty of achieving and maintaining consistent, high-quality results.

o The high degree of “fragmentation” (a variety of distinctly different job duties in a single position) results in inconsistent skill levels, shifting work priorities, missed deadlines, and/or inefficient approaches.

o People assigned to NEPA teams participate on unplanned details, most notably on all-hazard detail. These interruptions to NEPA projects can cause timeliness and/or quality to suffer.

o It is currently very difficult to track the actual cost of performing NEPA.

· The “To Be” organization described in the Feasibility Study Report is merely conceptual, as stated in the report. Further data collection and analysis will be done before any realignment is proposed.

· There are no position reduction “targets”.

· The Chief has not issued a decision on the business process by which NEPA will be further analyzed to address these issues but a decision is expected soon. Business Process Reengineering is being considered. Public private competition under Circular A-76 was ruled out prior to the Omnibus legislation prohibiting spending on competitive sourcing related activities.