ETCI’s The Environmental Blog

A bit of business: ETCI’s GSA-MAS Contract

Wed, 27 Jan 2010 14:35:27 -0800

As most of you know, we stopped publishing our corporate newsletter, OnTrack (and its electronic offspring, OnTrack OnLine), last December. We used that vehicle to alert readers to upcoming events, such as our annual environmental impact assessment course at Oklahoma State University, and other business-related topics in addition to commentary on current events. We believed that this blog could serve the latter purpose far more effectively, and serve the wider community who might not like to sign up for an email newsletter, but would happily click on an RSS feed using their own browser.

But a recent visit from our GSA auditor brought to our attention that many among even our long-term government clients are not using our GSA-MAS contract vehicle when they could, thus making more work for them, us, and our GSA auditor. So herewith, a bit of business.

Here’s the deal:

1. All of our NEPA Toolbox™ workshops and many of our other courses are available through our GSA contract at the push of a button by your contracting officer.
2. All of our custom-designed workshops can also be acquired through this contract.
3. Just visit our GSA page at http://www.envirotrain.com/gsacontractenvir.html and click on the GSA icon to be taken directly to GSA’s e-Buy web site, where you can order any of our training products.
4. On that same page, you can download our full-color catalog in pdf, including all course descriptions, example projects, and approved GSA price list.

Save yourself some effort, use the GSA contract!

As always, I welcome your comments and emails.

Cheers,

Leslie

Leslie E. Wildesen, Ph.D.
Co-founder and Managing Director
Environmental Training & Consulting International, Inc.

lew@envirotrain.com

http://www.envirotrain.com

Vanishing planets and snowfields...

Wed, 27 Jan 2010 00:00:00 -0800

Copenhagen and beyond...

Mon, 4 Jan 2010 11:25:06 -0800

You all know what happened, or didn’t happen, in Copenhagen last month. Above is a photo, courtesy of Google Earth, of the center of that wonderful (wonderful!) town.

Or, maybe not. Maybe you heard something, but didn’t bother to find out, and maybe you are mad, or happy, or puzzled, or in some other state not because of what happened or didn’t happen, but because of your profound state of ignorance of the actual outcomes.

As you probably know, I teach an environmental impact assessment class each year to undergraduate, graduate and sometimes professional-level students at Oklahoma State University. It lasts a week, and was originally designed for Environmental Science majors who need a taste of the real world prior to graduating and finding themselves immersed in it. We cover NEPA, National Historic Preservation Act, Endangered Species Act, and sustainability topics.

This year, after class on Thursday, one of the students asked if we could talk about climate change, because he had heard that the IPCC was just a bunch of bureaucrats, not really scientists at all, and he had heard about the hacked emails, and he had heard all kinds of things that caused him to doubt just about everything that was going on in Copenhagen.

He had “heard”? Excuse me? In the 21st century a college student didn’t get right on Google to go find out????

Well, I said, of course we can talk about it. And that night I spent the evening tracking down everything from the web casts from the Copenhagen meeting (winding down, it was the next-to-last-day) to the Flat Earth Society (yes, there is one, and yes, it’s as you imagine it would be). The next day, because of the magic of modern technology, we were able to go to all those web sites in real time on the projector in the classroom, and have our discussion. The web sites we visited are listed here, in no particular order:

http://www.ipcc.ch/index.htm IPCC home page

http://climatechangeskeptic.blogspot.com/ skeptic roundup site

http://nlquery.epa.gov/epasearch/epasearch?areaname=&areacontacts=http%3A%2F%2Fwww.epa.gov%2Fepahome%2Fcomments.htm&areasearchurl=&result_template=epafiles_default.xsl&action=filtersearch&filter=&typeofsearch=epa&querytext=global+warming EPA global warming search results 12-09

http://www.climatechangefacts.info/ variety of opinion/research results roundup site

http://www.alaska.net/~clund/e_djublonskopf/Flatearthsociety.htm Flat Earth Society

http://en.cop15.dk/ main climate change conference site

http://www1.cop15.meta-fusion.com/kongresse/cop15/templ/ovw.php?id_kongressmain=1&theme=cop15 climate summit webcast page direct

http://www.google.com/landing/cop15/ Al Gore’s visuals and other videos

So the short answer is, yes, of course the IPCC is a bunch of bureaucrats: it comprises representatives of governments, whose function is to make policy from the science provided by their scientists. The scientists’ credentials are spotless; the governments are, well, governments. Ours has not had a very good record, for example, even though our scientists have been doing studies and providing data for several decades now. But this is how the process was set up to work.

One thing this student did not understand was how things get done in the international arena. I described my service on the US TAG to the ISO 14001 committee during development of the international environmental management system standards in the 1990s: the US representative (and some others) went to the meetings; the scientists and managers developed the working papers, reviewed them in a kind of modified Delphi process, and ultimately reached consensus on wording that the US government could support, whereupon the USG representative met with his counterparts from other countries to develop a consensus on wording which everyone could support. Yes, science was an integral part of the process. No, perhaps none of the scientists was 100% happy with the final outcome. But guess what, that’s what the process was, and everyone bought into the process. And, because this is science, and because this is consensus process, there is always the opportunity to revisit any specific conclusions in a subsequent round of discussions.

The problem with the climate issues, of course, is that it is so expensive to fix. No one who has seen the news can doubt the ice is melting, the oceans are rising, the storms are getting more severe and more frequent, weather patterns are changing. We should be way beyond finger-pointing by now, and on to filling sandbags and moving infrastructure and figuring out how to grow food in new ways. Copenhagen didn’t quite achieve that, either, but we certainly are moving in the right direction, and finally the US is participating like a grown up in the process instead of ranting and raving and staying home. I for one think this is tremendous progress, although it should have happened 10 years earlier....

But, the next time you “hear” something, especially something that is disturbing, or that you think you don’t agree with, or that feels incomplete or biased, just go check it out for yourself. There is no excuse in the Information Age for remaining ignorant. So don’t!

As always, I welcome your comments and emails.

Cheers,

Leslie

Leslie E. Wildesen, Ph.D.
Co-founder and Managing Director
Environmental Training & Consulting International, Inc.

lew@envirotrain.com

http://www.envirotrain.com

No Environmental Picture Today....

Fri, 27 Nov 2009 14:30:22 -0800

No picture today, to protect the perpetrators.

I have just reviewed an Environmental Assessment that is over 200 pages long. The EA in question, for a construction project with 5 alternative locations, was prepared in 2003. It explains the purposes of NEPA, contains quotations from the CEQ regulations, describes agency requirements by quoting from the agency’s internal NEPA guidance, quotes EPA and FEMA (among other) guidelines for conducting various analyses, conflates description of affected environment with description of environmental consequences, and puts off the most useful studies -- soils, archaeology (remember, this is for a construction project!) -- for later!

The sad part is, the agency should have gotten a far better -- more concise, more precise, more useful -- product. They have extensive handbooks, guidelines, systems, samples, and training programs. They paid good money to a reputable consulting organization. The document makes good use of graphics. The writing is grammatically correct. The list of references cited is extensive. The preparers have solid credentials and experience. None of the construction sites are controversial.

What went (so seriously) wrong?

Here is where I take a page from my computer geek friends: R T F M! (consider that a shout) These initials stand for READ THE !@#$%^%^ MANUAL!

The Council on Environmental Quality has said for 30 years that EAs should be 10 to 15 pages long; that they represent a “concise” document that “briefly” serves to demonstrate that there are no “significant” impacts from a proposed action or its alternatives; and that a long EA often suggests that an EIS is needed.

How and where did professional practice go so far off track?

Some of my agency clients like to blame the lawyers: “our general counsel made us put this section in!” Some blame the consultants: “I couldn’t get them to take it out!” Some say they thought “X” was required (repeat: RTFM!). Some just throw up their hands and say, “this is what’s needed in the 21st century” (remember the “paperless office?”) Some think “training” is the answer, to which I respond, “of whom, and about what?”

Of course there is no single, or simple, answer. Lots of factors conspired to produce this debacle, including ignorant (not stupid!) agency managers, ignorant (not stupid, or even greedy) consultants, lawyers who have never done any environmental analysis, analysts who have never had to defend their work in court, a CEQ that has been missing in action for decades, and a decentralized compliance system which on the one hand provides a lot of agency flexibility and on the other hand creates a nightmare web of multiple and conflicting requirements. As someone who cut her teeth on linear projects back in the day, I’ve been struggling with that aspect of our environmental impact assessment system my whole career.

One approach to a solution is to take a page from some of our international colleagues, who have a two-tiered rather than a three-tiered system: projects are either exempted from further documentation after a preliminary review (similar to our Categorical Exclusion concept), or they are subjected to extensive analysis and documentation requirements (similar to our Environmental Impact Statement concept). The first tier (that is, the Categorical Exclusion process) provides the evidence that the second tier (the EIS) is not needed, thus substituting for our Environmental Assessment. The major difference, of course, is that in these two-tiered systems a central authority either at the state/province or national level makes the determination.

For agencies in the US that have land use planning requirements such a system could be designed to work in concert with their planning process. The plan would set out the framework for decision making, including criteria and thresholds, goals and guidelines, and projects that fell below the threshold and follow the guidelines would be exempt from further consideration until the next planning cycle calculated the cumulative effects of such projects and recalibrated the thresholds if necessary. Some of our land managing agencies have the potential of working this way now. Thus, agencies would “pre-consider” EA-type projects and develop time-delimited categories of actions which would not need further examination until the next planning cycle.

For construction (or construction permitting) agencies that often are responding to outside proponents’ requests for projects, the planning would have to be more collaborative and larger scale. Highways, pipelines, and buildings do not function in a vacuum; agencies at all scales and levels should cooperate and collaborate in defining goals, criteria, thresholds, and decision-making processes for a given planning horizon.

Then, of course, there is the not so tiny problem of some agencies not having planning processes. Many simply respond to requests, and have little or no control (or desire for control) over how projects they authorize interact with each other or with other projects going on in the same area. The independent permitting agencies, such as FERC and FCC often take this approach. This lack of foresight, and the inability to develop foresight, seems to be built in to our system, for better or worse. Couple this with an almost visceral distaste for anything smacking of central planning that seems to afflict a vocal part of our citizenry, and it seems these larger scale solutions may be doomed to fail. Please notice that I purposely use words like “seems” and “may” as the outcomes are by no means certain....

But perhaps there are smaller scale solutions at hand. While CEQ may not have been doing much lately to solve this problem except quote their regulations in memos (the Healthy Forest Act discussion comes to mind), the fact is that their regs have been remarkably stable and at no time over the past 30 years did they substitute “lengthy” or “elaborate” for “concise” and “brief” regarding EAs. Analysis tools such as Charles Eccleston’s 1985 set of “sufficiency questions” (which we adapted into our Sufficiency Protocol, downloadable from our web site) have been around for nearly 15 years. The training programs with which I am familiar (including ours, of course) consistently emphasize the need for careful environmental analysis and concise and precise documentation for Environmental Assessments. There seems to be no lack of information, for those who wish to use it.

I would add one other thing that I have found the be probably the most useful instruction in the environmental impact assessment practitioner’s toolkit, and it comes directly from the Council on Environmental Quality regs, 40 CFR 1501.7(a)(3): “Identify and eliminate from detailed study the issues which are not significant or which have been covered by prior environmental review.”

This is nothing but basic scoping instructions. NEPA 101. “Environmental impact assessment for dummies” material. Not rocket science. Even for rocket scientists.

Lately, this mantra has become my silver bullet (to mix up a few metaphors). In the EA under review here, it could easily have cut 150 pages of fluffy filler, useless bulk, “paid by the word” nonsense. And the soils and archaeology studies could have been conducted, their results included, and still the document would have come in at only about 10 pages per site location alternative (and only 35 pages more than is desirable!).

So let me say it louder: IDENTIFY AND ELIMINATE FROM DETAILED STUDY...

Or maybe you want it louder yet: IDENTIFY AND ELIMINATE FROM DETAILED STUDY....

What are the issues that will drive the agency’s decision? Talk about them. Don’t talk about the others. Which environmental effects will be the determining factor(s) in selecting an alternative location, or design, or scale, or construction season, or technology, for this project? Make sure they are described, but please don’t tell me about things that are not important. How will these environmental factors be applied to agency decision making, along with project costs, life-cycle considerations, proponent needs, and other non-environmental characteristics of the project? Make sure the connections are clear.

The EA should make very clear what the driving environmental issues really are, and how they will factor into the decision. It should examine and describe how they play out for all the alternatives under consideration, including No Action. It should contain sufficient information so that the decision maker and the public can feel confident the selected alternative won’t have any significant impacts so that an EIS is not required.

And that’s all. Everything else is appendix, file, or circular file material.

And whose job is it to make this happen? Of course, it is everyone’s job: the agency representative, the consultant, the reviewer, the contracting officer, the NEPA coordinator, the trainer, and the lawyer.

As consultants and trainers we certainly strive to do our part. How about you?

As always, I welcome your comments and emails.

Cheers,

Leslie

Leslie E. Wildesen, Ph.D.
Co-founder and Managing Director
Environmental Training & Consulting International, Inc.

lew@envirotrain.com

http://www.envirotrain.com

Let the Deniers Deny This!

Fri, 25 Sep 2009 11:33:17 -0700

Above is a satellite image of the dust storm that ate Sydney, Australia this week. It was the largest one in at least 70 years (some reports said “ever”), dumping much of the topsoil from the fertile regions of the outback (not such an oxymoron, think eastern Australian wine country) onto the opera house, bridges, roadways, buildings and dwellings of Australia’s largest city.

More dramatic photos (NOT color enhanced):

It is a good time for international discussions at the G-20. Let’s get on with preparing our infrastructure, agriculture, water distribution, energy networks, etc. for the big change. Or a series of little changes. But let’s stop arguing and get to doing something, OK?

That’s it for today. Enough said.

As always, I welcome your comments and emails.

Cheers,

Leslie

Leslie E. Wildesen, Ph.D.
Co-founder and Managing Director
Environmental Training & Consulting International, Inc.

lew@envirotrain.com

http://www.envirotrain.com