Proposal for Conducting “Program-Neutral” Environmental Assessments

For Arizona NRCS Programs

Fundamental Need and Purpose:

NRCS provides technical and financial assistance to facilitate the application of conservation practices to landowners and operators. Currently, Environmental Assessments are done programmatically at the national level. A more detailed assessment is needed to evaluate effects of those conservation practices applied in the varied resource areas and habitats of Arizona. Since many of the same practices are applied in the different programs that NRCS administers, a need exists to develop the assessments without regard to the program they are applied through.

Once completed, these EAs would serve as guiding NEPA documents for approximately 90% of all work NRCS field offices perform, regardless of what program the activity is conducted under. They could also serve as a tiering document for other more site-specific environmental assessments, as well as the environmental evaluations that must be conducted on all farm and ranch projects.

Environmental Assessments:

In order to adequately describe environmental effects, assessments would need be developed in geographic areas with similar natural resource conditions, concerns and trends. This paper proposes that the EAs be developed for Major Land Resource Areas (MLRA). There are eight such areas in Arizona; however, since MLRAs 36 and 42 are limited in size, they could easily be incorporated in the assessments for MLRAs 39 and 41, respectively. This would result in a total of six EAs to be completed.

Each EA would analyze effects from conservation practices commonly installed on farmland and rangeland in that area. There are approximately 65 practices installed state-wide that make up at least 90% of all field office conservation planning and application activity. Cumulative effects of installing resource management systems would also be considered.

Threatened and Endangered Species:

EAs will discuss effects on T&E species. Adverse effects, as well as beneficial, will be analyzed. Section 7 consultation with U.S. Fish and Wildlife Service would then be conducted. The intent would be to perform a “batched” consultation on those species identified in the EAs as being affected. We will consult only on those practices we determined to possibly effect T&E species or critical habitat. “No effect” determinations will not be consulted on. However, by consulting on beneficial effects to T&E species, we will legitimize the ranking process for several programs that give points to projects that benefit T&E species. Additionally, it will allow our planners to give an honest assessment of the value of their projects to T&E species without having to conduct additional consultation.

For those practices not covered by the EAs and batched consultation, an individual Section 7 consultation may be required, as determined by the environmental evaluation. Also, where NRCS personnel determine the effects to species goes beyond what was identified in the assessments, or where there are effects determined on T&E species not previously identified, Section 7 consultation will proceed as necessary.

Process:

1)Preliminary consultation will need to occur with USFWS to jointly agree on course of action and to set up further coordination meetings with appropriate staff.

2)Assemble NRCS team that will prescribe format for EAs and participate in the development thereof. (Smarik, Bemis, DeSimone, and Hemmer are possibilities.)

3)Obtain and/or develop necessary data for EAs. The FOTG and EQIP GPA proposals will serve as primary references.

4)If scoping is necessary, coordinate with Zones to schedule meetings.

5)Smarik/Bemis will coordinate and complete consultation with USFWS.

6)Publish FONSIs and/or NOI to prepare EISs.

Estimated Time and Staff Resources:

The amount of time to complete EAs will be directly related to available staff resources. The consultation process with USFWS is anticipated to take no less than 6 months. Total impact to staff resources for EAs and consultation is estimated to be 1.5 staff/years.

Attachments:

Arizona list of practices planned/installed under EQIP to date.

New Mexico NRCS sample EA for EQIP GPA

New Mexico instructions for completing EAs