Tab O NEPA Documents.pdf

45 SW INRMP

Tab O, NEPA Documents

An Integrated Natural Resource Management Plan (INRMP) Environmental Assessment has been developed for the INRMP. A FONSI/FONPA has been signed indicating a finding of no significant environmental impact with INRMP actions. A Finding of No Practicable Alternative (FONPA) was incorporated into the FONSI and signed by AFSPC noting that habitat restoration work will occur in wetlands and floodplains but the long-term benefit is positive. Some natural resource project Air Force Form 813s are attached to this Tab for additional NEPA documentation.

As part of the NEPA process, Environmental projects should incorporate risk management. If projects aren‟t initiated through the AF Form 332 process, generally an AF Form 813 is developed that analyze environmental impacts to „Air Installation and Land Use Compatibility‟, „Air Quality‟, „Water Resources‟, „Safety and Occupational Health‟, „Hazardous Materials/Waste‟, „Biological Resources‟, „Cultural Resources‟, „Geology and Soils‟, and „Socioeconomics.‟ Analysis of these issues generally involves a form of risk management. The process of risk management is a “decision-making process to systematically evaluate possible courses of action, identify risks and benefits, and determine the best course of action for any given situation,” as defined in AFI 90-901, Operational Risk Management (ORM, April 2000). For example, a natural resource project to install osprey platforms should involve coordination of airspace/aircraft safety to ensure proper site location that will benefit the species while also preventing aircraft hazards.

The ORM principles should be applied to every project. The principles are: 1) accepting no unnecessary risk, 2) making risk decisions at the appropriate level,

3) accepting risk when the benefits outweigh the costs, and 4) integrating ORM into operations and planning at all levels. To determine the risk level, each project should be assessed such that the probability and severity of a realistic worst-case scenario are analyzed. In planning natural resource projects, the worst-case scenario is based on what repercussions are anticipated if the project does not happen. The project can also be assessed outside of the planning requirements (ACES) using ORM to determine what offsets can be devised to prevent the worst-case scenario.

Another example of a Natural Resource project ORM analysis:

SCRUB RESTORATION/PRESCRIBED FIRE (Land Management Units specified)

Mechanically treating specified land management units in preparation for prescribed fire; conducting the fire under prescription; supporting and tending the fire with various bulldozers, ATVs, water trucks, etc.; mopping up and assessing flare ups; finalizing restoration and characterizing quality.

45 SW INRMP

Tab O, NEPA Documents

Worst-case for planning: Scrub Restoration does not occur. Fines and violations if land is not managed per legal requirement to use prescribed fire to restore habitat for Federally protected Florida Scrub-jay. Likelihood for violations is high because of regulatory importance of habitat restoration for remaining populations of Florida Scrub-jays.

Worst-case for overall ORM: Fire rages out of control and causes infrastructure damage. The probability of this occurring isn‟t very high because the prescription is written based on wind direction, speeds, weather conditions, relative humidity, etc. If the weather isn‟t cooperating the day projected for the burn, it is classified as “out of prescription” and the burn is cancelled. The compartment is selected based on prevention of mission operation conflicts, smoke movement and worker safety, etc. Surveys are conducted prior to the mechanical treatment to prevent damage to nesting wildlife, burrowing animals and archeological resources. All personnel are trained to observe for fire “spot overs” and react quickly to douse any flames straying out of the restoration boundaries. Mop up occurs and hot flames are doused with water or dirt to reduce to smoldering debris. The area is monitored well after the burn to make sure flare ups are controlled and that any smoldering debris is still controllable.