NEPA - Decision Documents and Implementation

Preparers

Leslie Brandt, US Forest Service Eastern Region and Northern Research Station, St. Paul, MN

Courtney Schultz, Assistant Professor, Colorado State University, Ft. Collins, CO

Background

In the decision and implementation stage of the NEPA process, a decision is made based on the analysis of the project alternatives, how well they meet the purpose and need for the project, and their environmental effects. Draft decision documents are prepared by the responsible official, and the public is given an opportunity to object to the proposed decision or activity prior to the final decision. If no objections are received, the decision is signed and implementation can begin. 

Decision Documents

It may be appropriate for the decision rationale in the decision document for an EA or EIS to include some indication of how climate change was considered in the decision. The responsible official can explain how climate change was considered given the scope of the project, the scope of the effects analysis, and how the effects were weighed along with the project’s objectives. Connections in the decision rationale can be made to agency-level strategies to respond to climate change.  Examples in the Forest Service include the Forest Service’s Strategic Plan and National Roadmap for Responding to Climate Change.

Examples where climate change is discussed in a decision document:

• Four-Forest Restoration Initiative, Coconino and Kaibab National Forests, Coconino County, Arizona (pages 4, 24, 27, 37)

Implementation

After the decision is made and implementation begins, some considerations may still be made related to climate change. For example, the timing of operations, such as timber treatments and prescribed fire, may also be adjusted due to seasonal shifts in ideal conditions from changes in climate. 

Monitoring and Evaluation

There are no uniform procedures for project-level climate change monitoring.  All forest plans under the 2012 planning regulations must include specific monitoring questions and indicators related to climate change. Decisions on what to monitor, and appropriate methods, will depend on the issues addressed in specific projects. Specific monitoring questions for a particular project can be developed using tools such as the adaptation workbook in Swanston and Janowiak (2012) and online. Some projects may take a long-term implementation and adaptive approach, committing to monitoring over time as part of their decisions. Where climate change may contribute to project success or cumulative effects, monitoring may be particularly relevant or may even be an integral part of the decision and plan for project implementation.