Environmental Engineering Reference
In-Depth Information
in the programmatic EA as well as the listing of approximately 60 anticipated
future projects. Thus, when a project within the cantonment was in the
planning stage, even if it was not within the list of the 60 projects anticipated
at the time the programmatic EA was prepared, if it was similar in scale,
function, use, surrounding land use, etc., to one of the previously reviewed
or future anticipated projects, it would be covered by the programmatic EA
and associated mitigation requirements.
The programmatic EA analyzed the potential for environmental impacts
resulting from routine construction and maintenance activities to environ-
mental resources (e.g., endangered species, water quality, noise, cultural
resources) present within the developed portions of the base. The program-
matic EA first included a very thoughtful and carefully worded description
of the proposed action, such that it covered the full range of anticipated activi-
ties but was also consistent with the letter and intent of NEPA. The proposed
action was not to actually perform construction but rather to develop stan-
dardized operating practices for routine construction projects. The practices
were developed and evaluated by referencing the numerous previous EAs
and the extensive environmental management programs that had been insti-
tutionalized at Fort Campbell over the years. The programmatic EA pointed
out that through the successful and long history of the base's EA and envi-
ronmental management processes and project implementation, there was a
high level of assurance regarding compliance with applicable environmental
laws, regulations, and policies. The proposed action also included a require-
ment that each cantonment area project would require the submission of a
Record of Environmental Consideration to the Environmental Division for
review and an appropriate determination regarding NEPA compliance.
The next steps in the development of the programmatic EA followed the
CEQ NEPA guidelines as discussed in the previous chapters. The affected
environment for each of the environmental resources was described by
brief summaries taken from the numerous EAs previously prepared for
the cantonment area (the prior EAs were included by reference). Similarly,
the anticipated impacts on each resource area were briefly summarized
from the environmental impact analyses done for the previously prepared
EAs and standard practices developed as part of the environmental man-
agement plans. This analysis of impacts was not simply a prediction of
impacts but specific reflections of what had actually occurred from similar
past actions. For example, the potential impacts from fugitive fibers during
asbestos removal in buildings was addressed by referencing the history of
compliance and base-wide standard procedures to ensure compliance with
National Emissions Standards for Hazardous Air Pollutants regulations. The
programmatic EA also specified that each construction project shall abide by
the current Fort Campbell Storm Water Management Plan and provided a
list of commonly used best management practices for construction activities.
Similarly, storm water-related impacts were addressed by including in the
project description erosion and runoff control measures proven effective in
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