Negotiating the NEPA Maze: It Really Is Rocket Science Start.

Negotiating the Negotiating the NEPA Maze: NEPA Maze:

It Really It Really IsIs Rocket Rocket ScienceScience

Start

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ContentsContents

I. NEPA Process Overview: Who, What, Where, When, and Why?

II. NEPA Documentation: An Interactive Look

III. Helpful Resources

NEPA Process Overview:NEPA Process Overview:

Who, What, Where, Who, What, Where, When, and Why?When, and Why?

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What is NEPA?What is NEPA?

National Environmental Policy Act National Environmental Policy Act (NEPA) is our basic national charter (NEPA) is our basic national charter for protection of the environmentfor protection of the environment

Two basic objectivesTwo basic objectives– Provide full disclosure and consider Provide full disclosure and consider

consequences of proposed Federal actionsconsequences of proposed Federal actions– Ensure that environmental information is Ensure that environmental information is

available to Agency decision makers and available to Agency decision makers and the public before decisions are madethe public before decisions are made

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What Does NEPA Require?What Does NEPA Require?

Federal Agencies mustFederal Agencies must– Consider environmental values in Consider environmental values in

planning before action is takenplanning before action is taken– Consider alternatives to proposed actionConsider alternatives to proposed action– Incorporate environmental Incorporate environmental

considerations with technical and considerations with technical and economic factors into decisionseconomic factors into decisions

– Make environmental information Make environmental information available to public available to public

– Prepare thorough and clear statements Prepare thorough and clear statements to assess environmental impactsto assess environmental impacts


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Why Does NEPA Why Does NEPA Apply to Licensing Actions?Apply to Licensing Actions?

Licensing launches, reentries, and Licensing launches, reentries, and launch and reentry sites is launch and reentry sites is

considered a considered a Federal action and is Federal action and is therefore subject therefore subject to the requirements of to the requirements of NEPANEPA

AST is responsible for analyzing AST is responsible for analyzing environmental impacts associated environmental impacts associated with licensed launcheswith licensed launches

AST’s responsibilities under NEPA AST’s responsibilities under NEPA are outlined in are outlined in FAA Order 1050.1DFAA Order 1050.1D


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How Does NEPA How Does NEPA Affect Licensing Process?Affect Licensing Process?Environmental determination, i.e., Finding of No Environmental determination, i.e., Finding of No

Significant Impact (FONSI) or Record of Significant Impact (FONSI) or Record of Decision (ROD) must be made before Decision (ROD) must be made before

license license can be issuedcan be issuedChanges to operations that impact the Changes to operations that impact the

environment must be evaluated in separate environment must be evaluated in separate documentationdocumentation

NEPA process can be used to document NEPA process can be used to document compliance with other statutory and compliance with other statutory and international requirementsinternational requirements

No action can be taken (e.g., start No action can be taken (e.g., start construction) until ROD or FONSI isconstruction) until ROD or FONSI isissuedissued


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Who Prepares NEPA Who Prepares NEPA Documentation?Documentation?

Federal agency undertaking Federal agency undertaking program, program, project, plan, regulation, or project, plan, regulation, or licensing/ licensing/ permitting activity is permitting activity is responsible responsible

Agencies may use contractors to Agencies may use contractors to prepare environmental prepare environmental

documentation; documentation; however, document however, document is submitted by the is submitted by the Agency to the Agency to the Environmental Environmental Protection Agency (EPA)Protection Agency (EPA)

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What Types of What Types of NEPA Documentation Exist?NEPA Documentation Exist?

Categorical ExclusionCategorical Exclusion - action that - action that normally does not, individually or normally does not, individually or cumulatively, have significant impact on cumulatively, have significant impact on quality of the human environmentquality of the human environment

Environmental Assessment (EA)Environmental Assessment (EA) - - analysis of proposed action and reasonable analysis of proposed action and reasonable

alternatives (including no action) that alternatives (including no action) that could could result in preparation of Environmental result in preparation of Environmental

Impact Statement (EIS) or FONSIImpact Statement (EIS) or FONSIFONSIFONSI - outcome of EA that documents - outcome of EA that documents no no

significant impact requiring the significant impact requiring the preparation of preparation of an EISan EIS


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What Types of NEPA What Types of NEPA Documentation Exist Documentation Exist

(continued)?(continued)?

EIS EIS - detailed analysis of - detailed analysis of environmental consequences of environmental consequences of proposed action and reasonable proposed action and reasonable alternatives (including no action), alternatives (including no action), cumulative impacts, and mitigation cumulative impacts, and mitigation

actionsactions

RODROD - concise summary of EIS, - concise summary of EIS, alternative selected and reasons for alternative selected and reasons for

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What are AST’s What are AST’s Responsibilities under NEPA?Responsibilities under NEPA?

Assist license applicant in identifying Assist license applicant in identifying potentially significant impacts potentially significant impacts

Review environmental information Review environmental information submitted by applicant submitted by applicant

Prepare NEPA documentation, Prepare NEPA documentation, conduct conduct scoping, coordination, and scoping, coordination, and public reviewpublic review

Respond to public comments Respond to public comments received received during the comment period during the comment period

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What Steps What Steps Should Applicant Take?Should Applicant Take?

Early in the process the applicant Early in the process the applicant shouldshould– Consult AST on level and scope of environmental Consult AST on level and scope of environmental

documentation neededdocumentation needed– Conduct preliminary studies to determine impact of Conduct preliminary studies to determine impact of

proposed action and identify reasonable proposed action and identify reasonable alternatives alternatives

– Submit applications for all permits or approvalsSubmit applications for all permits or approvals– Notify AST of other Federal, Tribal, regional, state or Notify AST of other Federal, Tribal, regional, state or

local requirements that may applylocal requirements that may apply– Notify AST of private citizens and groups interested Notify AST of private citizens and groups interested

in proposed actionin proposed actionContact AST’s environmental specialistsContact AST’s environmental specialistsfor guidance for guidance


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When Should NEPA When Should NEPA be Initiated?be Initiated?

Early in planning process - before Early in planning process - before decisions are made and actions are decisions are made and actions are takentaken

Prevents prematurely limiting Prevents prematurely limiting choice of reasonable choice of reasonable alternativesalternatives

Early application of NEPA Early application of NEPA may prevent subsequent may prevent subsequent schedule slipsschedule slips

Applicant should Applicant should contact AST contact AST early early in process to initiate in process to initiate NEPA reviewNEPA review

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PagePage

NEPA DocumentationNEPA Documentation

An Interactive LookAn Interactive Look


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NEP

A P

rocess

NEP

A P

rocess

Proposed Action

Categorical Exclusion1

Environmental Assessment

Further NEPA

Analysis Required

Notice of Intent

Scoping Process

Draft Environmental Impact Statement

EPA’s Notice of Availability

Public Review (45 days minimum)

Final Environmental Impact Statement

EPA’s Notice of Availability4

Record of Decision

Public Hearing

No Further Documentation2

Finding of No Significant Impact

Proceed with Project

Known Significant Impact

Yes

No Significant

Impact3

Yes

1 – If no extraordinary circumstances

2 – FAA may document categorical exclusions

3 – Or mitigated below level of significance

4 – Publication of FEIS in Federal Register for minimum 30 day public review

Minimum 30 day waiting

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Other NEPA Other NEPA Topics of InterestTopics of Interest

Supplemental NEPA Documentation

TieringEnvironmental Monitoring

Written Reevaluation


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Proposed Action and Proposed Action and AlternativesAlternatives

Describes range of alternatives Describes range of alternatives including including proposed action and no actionproposed action and no action

Reasonable alternatives may include Reasonable alternatives may include but but are not limited toare not limited to

– Launch facility locations,Launch facility locations,– Configuration of the launch facility, Configuration of the launch facility, – Extent of launch facility operations,Extent of launch facility operations,– Types of launch vehicles, andTypes of launch vehicles, and– Range of launch trajectoriesRange of launch trajectories


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Developing Proposed Developing Proposed Action and AlternativesAction and Alternatives

To assist applicants in identifying To assist applicants in identifying proposed action and alternatives, proposed action and alternatives, consider consider the following questionsthe following questions

1.1. Where is your preferred site?Where is your preferred site?2.2. Have you identified alternative sites?Have you identified alternative sites?3.3. What is your proposed launch manifest?What is your proposed launch manifest?4.4. Have you considered using a different Have you considered using a different

number of flights?number of flights?5.5. Have you identified a preferred configuration Have you identified a preferred configuration

for the site?for the site?6.6. Have you considered any alternative site Have you considered any alternative site

configurations?configurations?


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Developing Proposed Action Developing Proposed Action and Alternatives (continued)and Alternatives (continued)

7.7. Have you identified a preferred Have you identified a preferred family or class of vehicle(s)?family or class of vehicle(s)?

8.8. Have you identified an alternative Have you identified an alternative family or class of vehicle(s)?family or class of vehicle(s)?

9.9. Have you identified a preferred Have you identified a preferred trajectory for launch(es)?trajectory for launch(es)?

10.10. Have you identified an alternative Have you identified an alternative trajectory for launch(es)?trajectory for launch(es)?

Answering these questions Answering these questions helps helps define the proposed define the proposed action action

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Written for actions which in the Written for actions which in the agency’s experience do not individually agency’s experience do not individually or or cumulatively have a significant cumulatively have a significant impact impact on the environment and do not on the environment and do not require require preparation of an EA or EISpreparation of an EA or EIS

Actions that are routineActions that are routineNormally excluded actions may require Normally excluded actions may require

more extensive review if more extensive review if potential potential exists for public controversyexists for public controversy

AST’s categorical exclusions are AST’s categorical exclusions are listed in listed in FAAFAA Order 1050.1DOrder 1050.1D

Categorical ExclusionCategorical Exclusion


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Environmental Environmental Assessment (EA)Assessment (EA)

Defined as concise document thatDefined as concise document that– Provides analysis to determine if EIS is necessaryProvides analysis to determine if EIS is necessary– Serves as the Agency’s compliance with NEPA Serves as the Agency’s compliance with NEPA

when EIS is not necessarywhen EIS is not necessary– Facilitates preparation of EIS when necessaryFacilitates preparation of EIS when necessary

Addresses environmental effects that are Addresses environmental effects that are not anticipated to cause significant not anticipated to cause significant impacts impacts when no categorical exclusion existswhen no categorical exclusion exists

Evaluates actions that have potential Evaluates actions that have potential effects that can be mitigated to less than effects that can be mitigated to less than significant levelssignificant levels


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EA ContinuedEA Continued

Less detailed than an EIS but must Less detailed than an EIS but must address similar elements includingaddress similar elements including

– Description of proposed actionDescription of proposed action– Purpose and need for actionPurpose and need for action– Alternatives including no actionAlternatives including no action– Description of affected environmentDescription of affected environment– Consequences of proposed action and Consequences of proposed action and

alternativesalternatives– Cumulative and long-term environmental Cumulative and long-term environmental

effectseffects– Degree of controversyDegree of controversy– Mitigation measures (if appropriate)Mitigation measures (if appropriate)


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EA ContinuedEA Continued

Determines whether there will be Determines whether there will be significant impacts from the significant impacts from the

proposed proposed actionaction

EA process ends in Finding of No EA process ends in Finding of No Significant Impact (action Significant Impact (action

may may proceed) or preparation of EISproceed) or preparation of EIS

EA process generally takes 6-12 EA process generally takes 6-12 months, but depending on months, but depending on

complexity complexity can take much longercan take much longer


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Finding of No Finding of No Significant Impact (FONSI)Significant Impact (FONSI)

Decision document which follows Decision document which follows completion of an EA and completion of an EA and

states states Agency’s determination of no Agency’s determination of no significant impactsignificant impact

Subject to 30-day review and Subject to 30-day review and comment by public if proposed action comment by public if proposed action

isis– An issue of national concernAn issue of national concern– Similar to actions which require an EISSimilar to actions which require an EIS– An unprecedented actionAn unprecedented action


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Notice of Intent (NOI)Notice of Intent (NOI)

FAA publishes NOI after making FAA publishes NOI after making decision to prepare EISdecision to prepare EIS

Initiates public scoping and EIS Initiates public scoping and EIS processprocess

Invites comments on scope of EISInvites comments on scope of EISIncludes date, time, and location Includes date, time, and location

of any planned public of any planned public scoping scoping meetingsmeetings

Identifies Identifies lead agencylead agency and any and any cooperating agenciescooperating agencies


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Lead Agency ResponsibilityLead Agency Responsibility

Responsible for facts, opinions, and Responsible for facts, opinions, and judgments upon which final judgments upon which final environmental determination is basedenvironmental determination is based

Performs independent review of Performs independent review of information provided by applicantinformation provided by applicant

Approves contractor for EIS process Approves contractor for EIS process and develops third party contracting and develops third party contracting mechanism see 40 CFR § 1506.5(c) mechanism see 40 CFR § 1506.5(c) and FAA Order 1050.1D paragraph 52 and FAA Order 1050.1D paragraph 52


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Cooperating Agency Cooperating Agency ResponsibilityResponsibility

Participate in the NEPA process at Participate in the NEPA process at the request of the lead the request of the lead

agency agency

Participate in the scoping processParticipate in the scoping process

Assume responsibility for Assume responsibility for preparing preparing portions of NEPA portions of NEPA analysis at the analysis at the lead agency’s requestlead agency’s request

Provide staff and funding to Provide staff and funding to participate in the NEPA processparticipate in the NEPA process


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Scoping ProcessScoping ProcessIf an EIS is required, scoping is If an EIS is required, scoping is

conducted toconducted to– Solicit public opinion and opinions of other agenciesSolicit public opinion and opinions of other agencies– Determine potentially significant impacts to be Determine potentially significant impacts to be

analyzed in detailanalyzed in detail– Identify and eliminate from study non-significant Identify and eliminate from study non-significant

issuesissues– Allocate assignments for preparing EIS among Allocate assignments for preparing EIS among

participating agenciesparticipating agencies– Identify environmental review and consultation Identify environmental review and consultation

requirementsrequirements– Develop a schedule for Develop a schedule for

preparing EISpreparing EIS


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Environmental Impact Environmental Impact Statement (EIS)Statement (EIS)

Prepared when a proposed action may Prepared when a proposed action may result in significant impacts result in significant impacts

Should be analytical and concise Should be analytical and concise with a level of analysis commensurate with a level of analysis commensurate with the potential with the potential for impact for impact

EIS process generally takes 12-18 EIS process generally takes 12-18 months but can take much longer if months but can take much longer if controversial issues or complex controversial issues or complex analysis are involved analysis are involved


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EIS ContinuedEIS ContinuedAn EIS should containAn EIS should contain

– Cover sheet Cover sheet – SummarySummary – Table of contents Table of contents – Purpose of and need for action Purpose of and need for action – Alternatives including proposed action Alternatives including proposed action – Affected environmentAffected environment– Environmental consequencesEnvironmental consequences– List ofList of preparers preparers– List of agencies, organizations, and persons to whoList of agencies, organizations, and persons to who

m copies of document are sentm copies of document are sent (Distribution List) (Distribution List)

– IndexIndex– AppendicesAppendices


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Cover Sheet, Cover Sheet, Summary, Table of ContentsSummary, Table of Contents

Cover sheetCover sheet – summarizes – summarizes proposed proposed action, agency point of action, agency point of contact, contact, abstract, and date by which abstract, and date by which comments comments must be receivedmust be received

SummarySummary – summarizes EIS analysis – summarizes EIS analysis stressing conclusions and stressing conclusions and

areas of areas of controversycontroversy

Table of contentsTable of contents – lists sections of – lists sections of document, figures, and tablesdocument, figures, and tables


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Purpose of and Purpose of and Need for ActionNeed for Action

Outlines the purpose and need Outlines the purpose and need which which FAA is addressing by FAA is addressing by proposing proposing alternatives and alternatives and proposed actionproposed action

Defines parameters for a Defines parameters for a reasonable reasonable range of alternativesrange of alternatives

Forms framework for remainder Forms framework for remainder of of document including document including evaluation of evaluation of alternativesalternatives


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Alternatives Including Alternatives Including Proposed ActionProposed Action

Describes range of alternatives Describes range of alternatives including proposed action and no including proposed action and no actionaction

This section shouldThis section should– Define the issuesDefine the issues– Inform the public Inform the public – Provide basis for choice among options,Provide basis for choice among options,– Explore and evaluate alternativesExplore and evaluate alternatives– Discuss reasons why some alternatives Discuss reasons why some alternatives

were eliminated from further studywere eliminated from further study


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Affected EnvironmentAffected Environment

Baseline description of proposed site Baseline description of proposed site and alternative sitesand alternative sites

Considers issues includingConsiders issues including– Air qualityAir quality - Water quality- Water quality– Land useLand use - Noise- Noise– Biological resourcesBiological resources - Geology/soils- Geology/soils– Cultural resourcesCultural resources - -

Health/safety Health/safety – Socioeconomic issuesSocioeconomic issues - Airspace- Airspace– Environmental justiceEnvironmental justice


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Environmental Environmental ConsequencesConsequences

Analyzes impacts resulting from Analyzes impacts resulting from development and operation development and operation

of launch of launch site and launch activitiessite and launch activitiesAddresses resources and issues Addresses resources and issues

discussed in the affected discussed in the affected environment environment sectionsection

Evaluates direct and indirect, Evaluates direct and indirect, cumulative, and beneficial cumulative, and beneficial

impacts impacts Mitigation measuresMitigation measures must also be must also be

consideredconsideredBack


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Mitigation MeasuresMitigation Measures

Means by which adverse project Means by which adverse project impacts can be diminished or impacts can be diminished or eliminatedeliminated

Steps in mitigation planningSteps in mitigation planning1.1. Identify impacts and determine which can Identify impacts and determine which can

be eliminated or reducedbe eliminated or reduced2.2. Select mitigation measures based on Select mitigation measures based on

consultation with agencies and affected consultation with agencies and affected partiesparties

3.3. Implement mitigation measuresImplement mitigation measures4.4. Monitor and report on effectiveness of Monitor and report on effectiveness of

measuresmeasures


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List of Preparers and List of Preparers and Distribution ListDistribution List

List of PreparersList of Preparers – list of – list of names names and qualifications of and qualifications of persons who persons who were primarily were primarily responsible for responsible for preparing the EISpreparing the EIS

Distribution ListDistribution List – list of – list of persons persons or agencies to whom or agencies to whom copies of the copies of the document were document were providedprovided


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Index and AppendicesIndex and Appendices

IndexIndex – Should have a level of – Should have a level of detail detail sufficient to focus on topics sufficient to focus on topics of of interestinterest

AppendixAppendix – items may include – items may include– Material prepared in connection with EISMaterial prepared in connection with EIS– Material to substantiate analysis in EISMaterial to substantiate analysis in EIS– Analysis relevant to facilitate decision Analysis relevant to facilitate decision

makingmaking


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Draft EISDraft EIS

Circulate Draft EIS and provide Circulate Draft EIS and provide copies to cooperating agencies and copies to cooperating agencies and

Federal, state, or local Federal, state, or local agencies agencies authorized to enforce authorized to enforce environmental environmental standardsstandards

Request comments from agenciesRequest comments from agencies

Address, consider, and include or Address, consider, and include or summarize summarize

comments in the Final comments in the Final EIS EIS


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Notice of Availability (NOA)Notice of Availability (NOA)Draft and Final EISs must be filed Draft and Final EISs must be filed

with EPA’s Office of Federal with EPA’s Office of Federal ActivitiesActivitiesEPA files NOAs in Federal Register EPA files NOAs in Federal Register

weeklyweeklyEPA’s filing starts public review period EPA’s filing starts public review period

for Draft EIS and waiting period for Draft EIS and waiting period for for Final EISFinal EIS

No decision can be made until 90 days No decision can be made until 90 days after publication of NOA for Draft after publication of NOA for Draft

EIS EIS or until 30 days after publication or until 30 days after publication of of NOA for Final EISNOA for Final EIS


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Public ReviewPublic Review

Comments are solicited fromComments are solicited from– Federal agencies with jurisdictionFederal agencies with jurisdiction– Appropriate state and local agenciesAppropriate state and local agencies– Potentially affected Indian tribesPotentially affected Indian tribes– Any agency that requested copies of Any agency that requested copies of

documentdocument– ApplicantApplicant– PublicPublic– Interested public organizationsInterested public organizations


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Public Hearing ProceduresPublic Hearing Procedures

AST sponsors public meetings or AST sponsors public meetings or hearings hearings when appropriate or required when appropriate or required by statuteby statute

Criteria for meetings includeCriteria for meetings include– Substantial environmental controversy over Substantial environmental controversy over

proposed action or interest in holding proposed action or interest in holding meetingmeeting

– Request for hearing by Request for hearing by another agency with another agency with jurisdiction over actionjurisdiction over action

Hearing held no earlier Hearing held no earlier than 15 days after draft is releasedthan 15 days after draft is released


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Final EISFinal EIS

Must consider comments both Must consider comments both individually and individually and

cumulativelycumulatively

Responses to comments Responses to comments raised raised during public review during public review must be must be included in the Final EISincluded in the Final EIS

Comments may be received Comments may be received on on the Final EISthe Final EIS


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Record of Decision (ROD)Record of Decision (ROD)

Public record of a decision Public record of a decision indicating final approval indicating final approval

of a of a proposed action proposed action

Identifies all alternatives Identifies all alternatives considered by Agencyconsidered by Agency

States whether means to States whether means to minimize environmental minimize environmental harm were adoptedharm were adopted

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What Happens Next?What Happens Next?

Following release of ROD, 30-Following release of ROD, 30-day day waiting/cooling off waiting/cooling off period starts period starts before action can before action can proceedproceed

Agency open to possible legal Agency open to possible legal actionaction

Applicants for AST license Applicants for AST license must must still meet other still meet other requirements to requirements to obtain license obtain license

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Supplemental NEPA Supplemental NEPA DocumentationDocumentation

Prepare supplements to draft Prepare supplements to draft or or final EISs if substantive final EISs if substantive changes changes are made to the are made to the proposed actionproposed action

Prepare, approve, circulate, Prepare, approve, circulate, and and file in the same manner file in the same manner as draft as draft or final EISs but scoping or final EISs but scoping is not is not requiredrequired Back


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TieringTiering

Agencies are encouraged to Agencies are encouraged to tier tier to eliminate repetitive to eliminate repetitive discussions discussions of issuesof issues

After Programmatic or other After Programmatic or other broad EIS has been broad EIS has been

prepared prepared subsequent EA subsequent EA or EIS only or EIS only needs needs to to summarize issues previously summarize issues previously discusseddiscussed


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Written Written ReevaluationReevaluation

AST exercises judgment to AST exercises judgment to determine determine when this is appropriatewhen this is appropriate

May be appropriate whenMay be appropriate when– Proposed action conforms to plans or Proposed action conforms to plans or

projects for which prior EISs or FONSIs projects for which prior EISs or FONSIs have been filedhave been filed

– Data and analyses in previous EISs or Data and analyses in previous EISs or FONSIs are substantially validFONSIs are substantially valid

– All conditions and requirements of prior All conditions and requirements of prior approval have been or will be met in the approval have been or will be met in the current actioncurrent action


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Environmental Environmental MonitoringMonitoring

FAA may require environmental FAA may require environmental monitoring as part of the licensemonitoring as part of the license

Monitoring may include pre- and Monitoring may include pre- and post-launch observation post-launch observation

for for species of concern, species of concern, surface surface water sampling, water sampling, vegetation vegetation surveys, and other surveys, and other actions as actions as appropriate appropriate


Helpful ResourcesHelpful Resources

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Guidelines DocumentGuidelines Document

Aids applicants in Aids applicants in understanding understanding FAA’s policies FAA’s policies and proceduresand procedures

Guidelines are intended to be Guidelines are intended to be used in conjunction used in conjunction

with with FAAFAA Order 1050.1DOrder 1050.1D, , NEPA, and other NEPA, and other environmental environmental laws laws

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Programmatic EIS Programmatic EIS

Programmatic EIS for LicensingProgrammatic EIS for LicensingLaunchesLaunches

Addresses environmental impacts of Addresses environmental impacts of licensing launches and two alternativeslicensing launches and two alternatives

Three categories of impacts Three categories of impacts consideredconsidered

– Atmospheric Atmospheric – Noise Noise – Other environmental effects Other environmental effects

Considers possible mitigation measuresConsiders possible mitigation measures

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Other Environmental Other Environmental RegulationsRegulations

Many environmental regulations and Many environmental regulations and executive orders may apply to executive orders may apply to

actionsactions– E.O. 12114 - Environmental Effects Abroad of Major E.O. 12114 - Environmental Effects Abroad of Major

Federal ActionsFederal Actions– Endangered Species ActEndangered Species Act– Federal Coastal Zone Management ActFederal Coastal Zone Management Act– Marine Mammal Protection ActMarine Mammal Protection Act– Clean Air ActClean Air Act– E.O. 11990 - Protection of WetlandsE.O. 11990 - Protection of Wetlands– National Historic Preservation ActNational Historic Preservation Act

For a more extensive list refer to For a more extensive list refer to Appendix Appendix E of the Guidelines DocumentE of the Guidelines Document

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AST StaffAST Staff

For more information or to discuss For more information or to discuss a a particular proposed project particular proposed project please please contactcontact

– Michon Washington Michon Washington (202) 267-9305(202) [email protected]@FAA.gov

– Doug GrahamDoug Graham(202) 267-8568(202) [email protected]@FAA.gov

Visit AST’s Website: Visit AST’s Website: http://ast.faa.govhttp://ast.faa.gov

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