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Comprehensive Review of Environmental Policy Challenges in Project Planning and Implementation

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This chapter discusses common problem areas encountered in the environmental review process for project planning. It highlights key topics such as compliance with the Clean Water Act, Clean Air Act, and Endangered Species Act, focusing on the evaluation of alternative solutions, mitigation strategies, risk assessment, and documentation of scoping activities. Further, it addresses issues related to real estate, economic implications, and environmental justice, emphasizing the significance of thorough planning and alignment with federal interests to ensure successful project execution while addressing environmental concerns.

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Comprehensive Review of Environmental Policy Challenges in Project Planning and Implementation

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  1. Lessons Learned Common Environmentally Related Review Comments Chapter 8 Mod 1 HO # 27

  2. COMMON PROBLEM AREAS Analysis Process

  3. POLICY REVIEW KEY AREAS ANALYSIS Plan Selection Formulation Project Description Plan Implementation

  4. Common Policy Review Topics • Without and With-Project Conditions • Range of Alternatives • Separable Elements • Mitigation • Risk & Uncertainty • Measure All Effects • Economic • Real Estate • Legal • Sponsorship Issues • Policy Consistent

  5. Environmental Concerns ER 1105-2-100, App. C • Documentation of Scoping Activities and Environmental Compliance (summarize views, partial vs. full compliance) • Clean Water Act • Clean Air Act • F&W Coordination Act • Endangered Species Act • Historic Preservation Act • Environmental Justice

  6. Real Estate Concerns • Incomplete Real Estate Plan (See ER 405-1-12) • LERRD incorrect/incomplete • Recreation features not limited to project lands • Inadequate mapping • Trend toward more RE issues • Interest in lands (fee typically) • Land costs exceed 25% target of total project • Willing seller issues

  7. Purpose Specific • Flood & Coastal Storm Damage Reduction • Historical Damages • Future Development • Induced Flooding • Recreation • Public Access and Land Use (Coastal) • Monitoring • Mitigation vs. Restoration

  8. Purpose specific • Navigation • Construction/Dredging Windows • Beneficial use of Material • Disposal Areas • Mitigation

  9. Purpose specific • Ecosystem Restoration • Mitigation generally isn’t proposed/ provide justification • Cost-Shared Monitoring (1%, 5 years) and Adaptive Management (3%)- not research • Alignment with budget criteria- allows comparison nation-wide • (Woodley/DCW memos- 29 July 2005 & 30 March 2007 • Significance and Scarcity of Outputs • Nationally or Regionally significant? • Significance demonstrated by Institutional, Technical, and Public recognition • Environmental Operating Principles-#1, #2, #5.

  10. Other Environmental Concerns • Federal Interest • Is the Corps right for this effort vs. others? • Is it mission-related? • Mission Compatible • Is the proposal really aquatic ecosystem restoration? • Terrestrial restoration should be funded by others • Corps should not do enhancement or protection alone • Define a reasonable/ technically supportable outer limit, trend of using the 100-year flood plain isn’t appropriate • Public Access • (Open to all, if provided. Guidance is evolving)

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