Environmental Review Support for EPA Solid Waste and Recycling Grant Program

The U.S. Environmental Protection Agency (EPA) approached ERG with an urgent need to conduct screening-level environmental reviews for 42 tribal solid waste and recycling infrastructure projects that would receive financial assistance under the Solid Waste Infrastructure for Recycling (SWIFR) Grant Program. ERG was tasked with reviewing the available project materials and providing a preliminary determination on the appropriate pathway for each project to fulfill National Environmental Policy Act (NEPA) requirements.

ERG began the effort by quickly coordinating with EPA to establish the review methodology and documentation requirements. The options for fulfilling NEPA requirements included applying a categorical exclusion (either from EPA’s NEPA procedures or adopted from U.S. Department of Energy NEPA procedures), preparing a project-specific environmental assessment (EA), or seeking coverage under the SWIFR Programmatic EA. For each of the 42 projects, ERG compiled a sortable spreadsheet with results that included a brief project description; a preliminary NEPA pathway determination with accompanying narrative explanation; and identification of non-construction activities that could proceed prior to completion of the NEPA review (e.g., research, planning, design, and outreach components). ERG submitted these results in batches so that EPA could review the deliverables and confirm they met expectations. ERG completed this review of 42 projects in just six business days after the initial request, and just four business days after receiving EPA clarification and confirmation of the methodology.