NEPA Compliance
IEc is frequently called on to develop and deliver complex National Environmental Policy Act (NEPA) evaluations for a wide variety of agencies. We have extensive experience conducting NEPA reviews under tight timelines for complex subjects. Clients seek out IEc for support on challenging rulemakings and program actions that involve a high level of public scrutiny and evaluation. We have conducted NEPA evaluations for some of the largest regional and national environmental management issues in recent years, including programmatic evaluations of Deepwater Horizon oil spill restoration efforts, management of coal mining alongside streams, and large dam removals. IEc has experience in all aspects of the NEPA process, including public meeting support, public comment analysis and responses, and maintenance of the decision file. We regularly work with multi-agency and stakeholder groups to manage and address diverse perspectives and objectives.
IEc has more than 15 years of experience developing complex Environmental Impact Statements (EIS). Selected work includes assisting NOAA, DOI, and the State of Florida in evaluating the environmental and economic impacts of distributing the $8 billion natural resource damages settlement from the Deepwater Horizon spill, including assistance in development of two Programmatic EIS and more than 10 separate NEPA Environmental Assessments to date. IEc also supported NOAA in its development of Environmental Impact Statements for elements of the Atlantic Large Whale Take Reduction Plan.
IEc is a leader in the field of regulatory benefit-cost and cost-effectiveness analysis, as well as socioeconomic impacts assessment, under NEPA. Under separate contracts to the U.S. Army Corps of Engineers (USACE) and the Bonneville Power Administration, we supported the two agencies in developing a large-scale EIS of alternatives to the operations and management of 14 federal dams on the Columbia and Snake Rivers for the Columbia River System. For USACE and the Louisiana Coastal Protection and Restoration Authority, IEc recently evaluated the socioeconomic impacts of the $1.5 billion Mid-Barataria Sediment Diversion project as part of a third-party EIS, which evaluated alternatives that would divert water and sediments from the Mississippi River to restore degraded marsh habitats. We also supported USACE in its Economic Data Update for the Long Island Sound Dredged Material Management Plan. All of these efforts helped decision-makers to better quantify the tradeoffs between environmental improvements and potential economic costs.
IEc is frequently called on to develop environmental justice assessments in support of NEPA reviews. We have conducted these assessments in a variety of contexts. For example, for the Department of Energy’s Bonneville Power Administration, IEc evaluated the potential environmental justice impacts of alternatives for the operations and management of 14 federal dams on the Columbia and Snake Rivers. IEc also recently evaluated the socioeconomic and environmental justice impacts of the $1.5 billion Mid-Barataria Sediment Diversion project, which would divert water and sediments from the Mississippi River to restore degraded marsh habitats. For the Bureau of Ocean Energy Management, IEc supported efforts to develop agency-wide best practices for environmental justice analyses conducted under NEPA.
As part of our work, IEc regularly manages multi-agency and stakeholder groups to manage and address often diverse perspectives and objectives. IEc facilitates public meetings both in person and virtually. We are currently supporting the U.S. Coast Guard in its development of a Programmatic EIS for a large rulemaking effort. For this effort, IEc developed meeting materials, including fact sheets, a virtual and in-person meeting presentation, and posters. IEc facilitated a set of four public meetings along the Atlantic Coast of the U.S., one of which was virtual. IEc also recently facilitated a set of virtual public meetings for USACE in Louisiana to discuss the Mid-Barataria sediment diversion project EIS and to take public comments. We also facilitated a public meeting in Oklahoma related to a federal rulemaking and regulatory impact analysis that we conducted. As part of Deepwater Horizon support efforts, IEc worked with a large group of Trustees, including representatives from DOI, NOAA, U.S. Department of Agriculture (USDA), U.S. Environmental Protection Agency (EPA), and five states, to develop a comprehensive strategy that outlined the types of restoration projects negotiated with the responsible party under early and long-term restoration frameworks, including multiple iterations of drafts that incorporated Trustee comments. We facilitated a series of over 40 early restoration public meetings across the Gulf of Mexico region, and more recently have facilitated in-person and virtual public meetings for individual EAs.
IEc assists clients with support for managing public comments, including organization, analysis, and response. We have managed public comment compilation, analysis, and response processes for many high-profile federal rulemakings. IEc has experience managing many thousands of comments: examples include the Columbia River System Operations EIS, which received over 95,000 comments; the Office of Surface Mining Protection Reclamation and Enforcement’s Stream Protection Rule, which received nearly 100,000 public comments; and several actions by the Bureau of Land Management that received over 250,000 comments.
IEc has conducted a wide variety of projects that required careful and detailed administrative recordkeeping, providing us with extensive experience preparing, maintaining, and evaluating project administrative records (ARs) and repositories as well as helping trustees develop publicly available ARs. IEc’s strategy is to proactively design approaches for effective document management in advance of requests for materials. As a result, we respond to requests quickly and effectively, allowing our clients maximum time to conduct their own internal document review. In coordination with attorneys from relevant agencies, IEc has developed guidance for technical staff describing the types of documents and records that should be kept or that can be disposed of. Because requirements for complying with information requests can vary, we supplement our trainings with specific guidance from client attorneys. Our experience assisting trustees in defending settlements using an AR provides us with unique insights into the types of materials (and structure) required of such databases.
IEc has been involved in several efforts supporting EPA’s Office of Policy in preparing documents that would help its staff meet NEPA and other obligations. In particular, we assisted the NEPA Compliance Division in the development of a six-module training course for EPA staff to become familiar with EPA’s roles and responsibilities under NEPA and section 309 of the Clean Air Act. In addition to the teaching modules, the course included a student handbook, resource materials, homework, and a final exam. IEc helped deliver the course virtually, after which we worked with EPA staff to refine the materials and assist in translating the course into online asynchronous modules.
Project Examples
![Dam on the Columbia River](https://hgt3b6.p3cdn1.secureserver.net/wp-content/uploads/Columbia-River-NEPA-project.jpg?time=1725552260)
Columbia River System Operations, Pacific Northwest
U.S. Army Corps of Engineers, Bonneville Power Administration![Whale](https://hgt3b6.p3cdn1.secureserver.net/wp-content/uploads/4b-whale-sized.jpg?time=1725552260)