Integrating environmental impact assessment with master planning: lessons from the US Army

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Abstract

The US National Environmental Policy Act (NEPA) requires agencies to consider environmental impacts in the early stages of planning and decision-making. Despite this mandate, agencies typically conduct EIA for projects, rather than for earlier and more strategic decisions, such as plans. This research investigated the extent to which a large federal agency, the US Army, has integrated NEPA analyses with master planning for their installations. Using in-depth case studies of 16 installations, we investigated how and why EIA was (or was not) integrated with planning, and identified the factors that promote or impede integration. Typically, integration has been regarded as concurrence, meaning that the EIA and planning processes are conducted together. Results of this research show, however, that integration can occur, even if the NEPA documents and master plans are not concurrently prepared. In this sense, integration can be viewed as the influence of the EIA process on agency planning and decision-making. Results also indicate that regulations are only one factor, and that several other factors influence the extent of integration, such as agency leadership and organizational incentives. Lessons from this study can help improve both the integration and the substantive implementation of EIA.

Introduction

The vision of US National Environmental Policy Act (NEPA) was that agencies could use EIA as a strategic planning tool, integrating environmental factors directly into policies and plans that influence subsequent projects.1 The NEPA implementing guidance reinforces that “agencies shall integrate the NEPA process with other planning at the earliest possible time to insure that planning and decisions reflect environmental values.”2 Studies on EIA effectiveness echo the need for agencies to apply EIA early in their decision-making process, which ultimately can help to fulfill the substantive promise of NEPA Clark and Canter, 1997, CEQ (Council of Environmental Quality), 1997.

Yet this vision has been blurred, and relatively few agencies have embraced NEPA for strategic planning. More commonly, agencies conduct EIA for projects, rather than for earlier strategic decisions, thus depriving NEPA of its substantive potential in planning. Consequently, NEPA has been criticized for being an exercise to justify decisions already made, resulting in major paperwork but only minor changes in projects. And even though EIA is widely regarded as a planning tool, agencies often keep it separate from their internal planning processes.

This “integration problem”—the lack of early integration between EIA and agency planning—is not just one of requirements, as NEPA is already required for plans and other strategic decisions3, and for proposals in early stages of decision-making.4 Rather, the problem is often one of implementation. Agencies may be reluctant to integrate EIA into early stages of decision-making for fear of delays, increased costs, liability, or that “microscopic detail will be expected, even when such depth of analysis is not possible that early in the proposal development stage” (CEQ, 1997: 12). In addition, because agencies retain considerable discretion in determining when NEPA should be applied,5 they often wait until the project is well defined and likely to survive the NEPA process. These reasons and others are provided in Table 1, which summarizes findings from the literature to explain the lack of integration.

On the other hand, some federal agencies have made progress toward integration of NEPA and planning, realizing that EIA “helps them to do their jobs” (CEQ, 1997: 12). In addition, the international experience in “strategic environmental assessment” (SEA) illustrates that agencies can and do integrate EIA with strategic planning (e.g., European Commission, 2001, Partidário, 2000, Partidário and Clark, 2000, Brown and Therivel, 1999, Sadler and Verheem, 1996, Therivel and Partidário, 1996). These studies suggest that early and effective integration depends not only on legal or procedural requirements, but also on organizational factors, and benefits perceived and realized.

This paper examines the efforts of the US Army to integrate EIA within the framework of master planning. In this context, “master planning” involves a systematic process for managing activities at Army installations. The outcome of this process is a document, a “Real Property Master Plan” that guides decision-making: it charts the strategy for achieving the installation commander's goals, supports the Army's vision for current and future missions, and coordinates functions and facilities at installations (US Army, 1993). The US Army has also established its own set of NEPA implementing regulations (US Army, 1988), AR 200-2, which is currently under revision (DoD, 2000). Both the current and revised versions stress the need for early incorporation of NEPA into planning.

This research investigated the issue of integration through two primary questions. (1) To what extent is EIA integrated with master planning at Army installations? (2) What are the factors that promote or impede such integration? To answer these questions, a case study analysis was conducted of Army installations that recently had prepared NEPA documentation on master planning or other land use planning activities. Each possible case was pursued, and 16 were identified that fulfilled the criteria of this research. The case study protocol involved analysis of NEPA documents on land use planning activities and interviews with more than 50 individuals, including those responsible for NEPA compliance and document preparation at Army installations, Army master planners, Army environmental policy staff, and Army NEPA legal advisors.

Initially, this research examined “integration” according to its traditional concept of concurrence: the synchronized preparation of the NEPA document and the master plan would indicate successful integration and, in contrast, the preparation of the NEPA document after the completion of the master plan would not. As this research proceeded, however, it revealed that elements of integration could occur, even if the NEPA document were prepared after the planning document, or even without a planning document. One reason is that agency planning can occur, even without a formal plan—and EIA can influence that planning process. Thus, this research extends the traditional concept of integration by including dimensions of the influence of the EIA process on the agency and its planning activities.

This paper proceeds as follows. Section 2 details Army regulations for both master planning and NEPA implementation, and summarizes Army reasons in support of early integration. Section 3 details the research approach and methods, which proceeded in four phases during the years 2000–2001. Section 4 presents the results, explaining the varying degrees of integration, and the factors that promote or impede NEPA integration with master planning at Army installations. This section also discusses the implications of the results, which can advance our understanding of integration and the effective implementation of EIA.

Section snippets

Installation master planning and plans

To provide an understanding of the planning process that is the subject of this research, this section briefly describes the Army Regulation (AR) 210-20 Master Planning For Army Installations (US Army, 1993). This regulation details a systematic planning process for installation level management, and the outcome of the process is the Real Property Master Plan (RPMP).

The master planning process and resulting RPMP are designed to “chart a long-term investment strategy for achieving the

Research approach and methods

This study investigated two primary issues: (1) the extent to which NEPA and master planning processes are integrated at Army installations, and (2) the factors that promote or impede such integration. The research progressed in four phases over two years (2000–2001), and each phase is detailed herein.

Phase One involved a review and analysis of Army NEPA and Master Planning regulations and the scholarly literature on NEPA integration with agency planning. This phase also included an initial

Extent of integration based on timing

For the initial purposes of this study, “integration” of EIA and agency planning was based on timing. A concurrent preparation of the installation master plan (the RPMP) and its required NEPA document (an EA or EIS) would indicate successful integration, and, in contrast, a NEPA document prepared after the master plan would not. This follows the concept that environmental documents prepared concurrently with the master plan can influence and modify strategic land use decisions, whereas

Conclusion

Timing alone cannot indicate the degree of integration between NEPA and installation land use planning. Other measures must be employed. This study extended the traditional concept of integration by examining the influence of EIA on the agency and its decision-making. Even though only one installation prepared a NEPA document concurrently with its master plan, other installations revealed ways that environmental factors are integrated into plans and planning, even without concurrent document

Acknowledgements

We thank Ron Webster and David Eady for their valuable comments throughout this study and on this paper. We are grateful to the very helpful comments from two reviewers. This research was supported in part by an appointment to the Student Environmental Management Participation Program at the US Army Environmental Center (USAEC) administered by the Oak Ridge Institute for Science and Education through an interagency agreement between the US Department of Energy and USAEC. This research also

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