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Categorical Exclusion (CE) Training Class Presented by: Office of Environmental Services April 2-3, 2014.

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Presentation on theme: "Categorical Exclusion (CE) Training Class Presented by: Office of Environmental Services April 2-3, 2014."— Presentation transcript:

1 Categorical Exclusion (CE) Training Class Presented by: Office of Environmental Services April 2-3, 2014

2 Why Are You Here?  Pre-Qualification requirement  Increase project management awareness 2 Categorical Exclusion Training Class

3 Class Objectives  Understand the levels of CE classification  Understand Programmatic Categorical Exclusion Agreement between FHWA/ODOT/ORDC  Understand existing regulations and policies  Learn how to properly document and present the decision-making process for a project  Learn about upcoming changes to the CE process  Learn about the Online CE System 3 Categorical Exclusion Training Class

4 This Class is For You!  Ask Questions!!!  Share Experiences  Peer Interaction Encouraged 4 Categorical Exclusion Training Class

5 Introductions  Name  Company  Environmental /CE Experience  Class Expectations Thanks for coming! 5 Categorical Exclusion Training Class

6 Agenda  FHWA Perspective  Programmatic CE Agreement  Re-Evaluations  NEPA Disciplines/Online CE  Purpose & Need  Alternatives  Air & Noise  ESA  Cultural Resources  Ecological & Permits  Section 4(f) & Section 6(f)  Environmental Justice & Community Impacts 6 Categorical Exclusion Training Class

7 FHWA Perspective BIG PICTURE Why We Do What We Do! Categorical Exclusion Training Class

8 Law & Regulations  National Environmental Policy Act of 1969  40 CFR  Council on Environmental Quality (CEQ)  23 CFR  Federal Highway Adminstration (FHWA) 8 Categorical Exclusion Training Class

9 NEPA  Requires federal agencies within USDOT to assess and determine if a proposed action will result in significant environmental impacts  Established CEQ 9 Categorical Exclusion Training Class

10 Goal of NEPA  Identify and assess reasonable alternatives  Avoid or minimize adverse effects upon the human and natural environment 10 Categorical Exclusion Training Class

11 NEPA & CE Relationship  Documentation demonstrates specific conditions or criteria for a CE is satisfied  No individual or cumulative significant impact upon the human and/or natural environment  Per 23 CFR  Analysis is commensurate to a project’s potential for adverse impacts and controversy 11 Categorical Exclusion Training Class

12 NEPA & CE Relationship  Any project that creates SIGNIFICANT impacts cannot be considered for CE classification 12 Categorical Exclusion Training Class

13 CEQ & CE Relationship “…a category of actions which do not individually or cumulatively have a significant effect on the human environment and which have been found to have no such effect in procedures adopted by a Federal agency in implementation of these regulations and for which, therefore, neither an environmental assessment nor an environmental impact statement is required.” ~40 CFR ~ 13 Categorical Exclusion Training Class

14 FHWA Regulations  Title 23 - Highways  Part 771 – Environmental Impacts Classes of Action FHWA Categorical Exclusions 14 Categorical Exclusion Training Class

15 23 CFR (a)  Actions that meet 40 CFR  Do not require significant relocations  Based on past experience with similar actions, do not involve significant impacts to: Planned Growth or Land Use Natural Environmental Cultural and Recreational Properties Air, Noise, and Water Quality Travel Patterns 15 Categorical Exclusion Training Class

16 23 CFR (b)  Projects with unusual circumstances require appropriate environmental studies to determine if CE classification can be met  Significant environmental impacts  Substantial environmental controversy  Significant 4(f)/6(f) impacts  Inconsistencies with Federal, State, or local environmental laws, regulations or administrative determinations 16 Categorical Exclusion Training Class

17 23 CFR (c)  Actions that meet CE criteria per 40 CFR and 23 CFR (a)  Classified as Exempt projects in Ohio 17 Categorical Exclusion Training Class

18 23 CFR (d)  Actions that meet CE criteria per 40 CFR and 23 CFR (a)  CE Levels 1-4 in Ohio 18 Categorical Exclusion Training Class

19 FHWA Technical Advisory T6640.8A  Any action that meets the criteria of 23 CFR (a) may be classified as a CE  Even if it does not appear in (d)  Can be used as a guide to identify actions that may be processed as a CE  Must demonstrate that the proposed undertaking will not result in significant impacts 19 Categorical Exclusion Training Class

20 FHWA Policy Public Involvement is Essential!  Mitigates adverse impacts  Do not exclude any person from participating, due to handicap, age, race, color, sex, or national origin or to deny benefits of or be subject to discrimination under any Administration program or procedural activity required by or developed pursuant to this regulation 20 Categorical Exclusion Training Class

21 Public Involvement  Before action is taken, environmental information is made available to:  Public Officials  Stakeholders  Citizens 21 Categorical Exclusion Training Class

22 FHWA Policy Environmental Impacts & Related Procedures  Environmental coordinated as a single process  Alternatives evaluated and decisions made in the best interest of the public  Balances transportation needs with:  Social, Economic, and Environmental impacts  Environmental protection goals at the National, State and Local level 22 Categorical Exclusion Training Class

23 Ohio’s Programmatic CE Agreement Categorical Exclusion Training Class

24 Specifics  Between FHWA/ODOT/ORDC  Executed September 13, 2010  Supersedes previous processing agreements  Assures compliance with all applicable Federal environmental requirements  ODOT and ORDC act on behalf of FHWA  Includes oversight responsibilities through Compliance Reviews 24 Categorical Exclusion Training Class

25 Purpose  Provides a consistent documentation process  Legally defensible  Concise and easy process to follow  Reduces paperwork and processing time  Personnel with limited exposure to the NEPA process can easily provide proper information  Enables appropriate decisions to be made within bounds of the agreement 25 Categorical Exclusion Training Class

26 Five Levels  FHWA and ODOT have agreed to five levels of documentation for CE projects:  Exempt  Level 1  Level 2  Level 3  Level 4 26 Categorical Exclusion Training Class

27 Signature Authority  All CE Levels  District Environmental Coordinator (DEC)  ORDC Environmental Coordinator (EC)  CE Levels 2, 3, and 4  District Planning and Engineering Administrator  ORDC Executive Director  CE Levels 3 and 4  OES Policy Assistant Environmental Administrator (AEA) or OES Administrator  CE Level 4  FHWA 27 Categorical Exclusion Training Class

28 Exempt Project Types Categorical Exclusion Training Class

29 Definition  No documentation or further NEPA approval required  Meets the intent of 23 CFR (c)  Do not result in significant impacts to the human or natural environment  Standard stand-alone transportation activities 29 Categorical Exclusion Training Class

30 Exempt 1. Guardrail installation and replacement  Median cable barriers  No relocation of roadway ditches/backslopes 2. Replacement of existing or installation of new traffic signals  Flashing beacons, RR warning devices, ITS  No likelihood of contaminated materials 3. General pavement marking or “line painting” 30 Categorical Exclusion Training Class

31 Exempt 4. Herbicidal spraying 5. Mowing or brush removal/trimming projects 31 Categorical Exclusion Training Class

32 Exempt 6. Installation or maintenance of signs  Pavement markings, raised pavement markers  Traffic calming activities  New or replacement fencing  No likelihood of contaminated materials 7. Study type projects 32 Categorical Exclusion Training Class

33 Exempt 8. Bridges  Deck overlays and/or deck replacements  Superstructure Replacement  Maintenance Activities  Bridge Painting 33 Categorical Exclusion Training Class

34 Exempt 9. General highway maintenance  Filling potholes  Crack sealing, mill and resurfacing  Full pavement rehab  Joint grinding/milling, shoulder reconstruction  Minor slide stabilization/repair  Minor erosion control  Grading, parking lot pavement/repair  Access roadway pavement 34 Categorical Exclusion Training Class

35 Exempt 10. Disposal of excess ROW parcels  No presence of environmental resources  Environmental ROW Checklist 11. Improvements to existing ODOT/County maintenance facilities 12. Improvements to existing rest areas and/or weigh stations  Minor maintenance (mill and resurfacing)  Major construction may require a higher level of documentation 35 Categorical Exclusion Training Class

36 Exempt 13. Beautification or facility improvement projects  Landscaping  Curb and gutter replacement  Installation of park benches, decorative lighting 14. General permits to use or occupy highway ROW  Does not involve National Highway System  Does not involve limited access highways  No environmental impacts 36 Categorical Exclusion Training Class

37 Exempt 15. ODOT culvert maintenance or replacement and highway maintenance ditching activities  Culvert lining projects  Does not exceed 60” in diameter 37 Categorical Exclusion Training Class

38 Exempt 16. Construction of bicycle lanes and pedestrian walkways (no new disturbance)  Sidewalks, shared-use paths and facilities  Small passenger shelters  Alterations to facilities or vehicles for elderly and handicapped accessibility 17. Upgrade of existing tower lighting to new technologies that lessen impact of current system 38 Categorical Exclusion Training Class

39 Exempt 18. Approval of utility installations  Along or across transportation facilities  No drainage of wetlands will occur 19. Acquisition of scenic easements 20. Transportation corridor fringe parking facilities  Bus pull-ins and pull-outs  Park and ride lots, ridesharing activities 39 Categorical Exclusion Training Class

40 Exempt 21. Maintenance and/or replacement of existing noise wall panels and/or posts  Includes noise reduction alterations to existing publicly-owned buildings 22. Track and rail-bed maintenance activities and rail improvements 23. Bus and rail car rehabilitation 40 Categorical Exclusion Training Class

41 Exempt 24. Determination of payback under 23 USC 156  Property previously acquired with federal-aid participation 25. Transfer of federal lands pursuant to 23 USC 317  Subsequent action is not an FHWA action 26. Program administration, technical assistance activities, and operating assistance to transit authorities  Continue existing service or increase service 41 Categorical Exclusion Training Class

42 Exempt 27. Purchase and installation of operating or maintenance equipment  Located within transit facility  No significant impacts occur off site 28. Purchase and/or conversion of vehicles to alternative fuel  CNG, E-85, etc. 42 Categorical Exclusion Training Class

43 Not Exempt, When… Projects involve the following impacts:  New ROW acquisition  Scenic River Corridors  Waterway Permits  State/Federal Threatened & Endangered Species  Wetlands  Historic Properties or Historic Districts  Section 4(f)/6(f) Properties  Substantial Traffic Disruption  Minor Public Controversy (all issues addressed) 43 Categorical Exclusion Training Class

44 New C-List CEs Categorical Exclusion Training Class

45 MAP-21  Congress mandated certain actions be categorically excluded from requirements related to EA’s/EIS’s  Moving Ahead for Progress in the 21 st Century Act  Sections 1315, 1316, and Categorical Exclusion Training Class

46 FHWA Rulemaking  Amended 23 CFR (c) to add new CEs  (c)(9) Emergency repair projects  (c)(22) Projects within operational right-of-way  (c)(23) Projects with limited Federal funds  (c)(9) went into effect in February 2013 and (c)(22) and (c)(23) went into effect in February 2014  Rulemaking did not change procedural requirements for approval of projects  Environmental requirements under Federal and State statutes and regulations still apply e.g. Endangered Species Act, PI, EJ, etc. 46 Categorical Exclusion Training Class

47 Documentation The new CEs are considered to meet the c-list (undocumented CE) criteria, however…  FHWA required documentation to ensure a higher level of NEPA document is not warranted  No significant impacts will occur  No unusual circumstances exist  An Environmental Verification Form was developed for documentation purposes  Only for projects that meet new CE criteria 47 Categorical Exclusion Training Class

48 Level of Impacts The new CE’s cannot exceed the following thresholds:  Waterway Permits  Nationwide (NWP) or Regional General Permits (RGP)  May include Pre-Construction Notifications (PCNs)  Endangered Species  No Effect or May Effect, But Not Likely to Adversely Effect  100-year Floodplain  No substantial impacts 48 Categorical Exclusion Training Class

49 Level of Impacts  Section 4(f)/6(f)  No incorporation of land or conversion  No 4(f), No Use, or Exceptions (e.g. Temporary No Use ), and Maintenance or Temporary Non- Conforming Use  Cultural Resources  Minimal Potential to Cause Effect or No Historic Properties Affected 49 Categorical Exclusion Training Class

50 New CEs (c)(9) Transportation facilities damaged by an incident resulting in an emergency declared by the Governor of the State or a disaster or emergency declared by the President (c)(22) Projects that take place entirely within existing operational right-of-way (c)(23) Federally funded projects that receive less than $5,000,000 of Federal funds or with a total estimated cost of not more than $30,000,000 and Federal funds comprising less than 15 percent of the total estimated project cost 50 Categorical Exclusion Training Class

51 Level 1 Type Projects Categorical Exclusion Training Class

52 Definition  Minor or no significant impacts  No relocations  ODOT Districts/ORDC  Confirm undertaking meets Level 1 Criteria  Responsible for completing and filing CE Projects that DO NOT MEET Level 1 criteria will be processed at the next appropriate higher level 52 Categorical Exclusion Training Class

53 Level 1 1. Culvert and bridge replacement/reconstruction  No more than minimal additional right-of-way for grading and/or necessary channel work  Appropriate permits and coordination required 2. Modernization of a highway by resurfacing, restoration, rehabilitation and reconstruction 3. Modernization of a highway by the addition of turn lanes and/or addition of shoulders 53 Categorical Exclusion Training Class

54 Level 1 4. Environmental mitigation activities  Wetlands, streams, uplands, etc 5. Tower lighting and street lighting projects 6. Major reconstruction improvements  Existing rest areas and truck weigh stations 54 Categorical Exclusion Training Class

55 Level 1 7. Track and rail-bed improvements or acquisition 8. Installation of new fencing, signs, and small passenger shelters 9. Emergency repairs under 23 USC 125  Necessary work to restore travel  Repairs are made within 180 days of the event  Includes mine collapse, flooding, slips, etc 55 Categorical Exclusion Training Class

56 Level Joint or limited use of ROW  Minimal or no adverse social, economic or environmental impacts  Includes adverse impacts to highway safety 11. Approvals for changes in access control  Involves NHS (National Highway System) and limited access right-of-way 56 Categorical Exclusion Training Class

57 Level Acquisition of land for hardship or protective measures  Permitted only for a particular parcel or limited number of parcels  Action does not limit evaluation of alternatives that may be required in the NEPA process  NEPA process must be completed before proceeding 13.Installation of new noise walls and other new noise mitigation projects 57 Categorical Exclusion Training Class

58 Level Highway safety and truck escape ramps 15. Construction of bicycle lanes/pedestrian walkways, sidewalks, shared-use paths  Includes facilities and trailhead parking 16. ROW acquisition for bikeway/pedestrian facility  No construction 58 Categorical Exclusion Training Class

59 Level Beautification or facility improvement projects  Landscaping  Curb and gutter installation and replacement  ADA ramps/curb ramps  Installation of park benches, decorative lighting 59 Categorical Exclusion Training Class

60 Level Land donations to ODOT associated with ROW permits  Non-NHS/non-limited access ROW 19. Construction of alternative energy facilities  CNG, electrification, solar, fuel tank farms, wind turbines, etc. 20. Land reduction changes (“road diet”)  Traffic analysis is completed 60 Categorical Exclusion Training Class

61 Level Land acquisition by a public agency/public park entity for passive recreational use 22. Geotechnical activities  Grouting  Rock fall barriers  Rock fall netting  Drilled shafts and walls 61 Categorical Exclusion Training Class

62 Level Transportation corridor fringe parking facilities  Park-and-Ride lots  Ridesharing activities 24. Railroad projects that close at-grade crossings 25. Other project types  Must be approved by OES and/or FHWA 62 Categorical Exclusion Training Class

63 Not a Level 1, When… Projects involve two or more of the following impacts  Relocations  Section 106 “No Adverse Effect” finding  Programmatic or de minimis 4(f)  Section 106/4(f) on one site qualifies as a Level 1  Up to 3 acres of impacts to Cat 1 and 2 wetlands  Enough information to issue a wetland finding  Wetland/404 permit qualifies as Level 1 63 Categorical Exclusion Training Class

64 Not a Level 1, When… Continued from Previous Slide:  Scenic River corridor impacts  Individual 404/401  Substantial traffic disruption  Minor public controversy  All issues addressed  Endangered species 64 Categorical Exclusion Training Class

65 CE Level 2 & 3 Type Projects Categorical Exclusion Training Class

66 Definition  Involve a combination of impacts  Have higher thresholds based on context and intensity compared to a CE Level 1  Can include Exempt or CE Level 1 project types that are elevated based on impacts 66 Categorical Exclusion Training Class

67 Level 2 & Level 3 1. Addition of auxiliary lanes or through lanes  Parking, weaving, turning, climbing  Except for Interstate or “Interstate-look-alikes”  Major reconstruction on Interstates are considered on a case-by-case basis with OES 2. Bridge rehabilitation, reconstruction, or replacement 3. Realignments on new location  Not to exceed two miles in length 67 Categorical Exclusion Training Class

68 Level 2 & Level 3 4. Minor new highway facility on new location  Except for Interstates or “Interstate-look-alikes” 5. Modification of a non-interstate interchange or construction of a grade separation 68 Categorical Exclusion Training Class

69 Level 2 & Level 3 6. Construction of a new interchange  Except on Interstate or “Interstate-look-alikes” 7. Minor modification of an Interstate interchange  Can include, but not limited to: Addition/deletion of turn lanes Minor lane shifts Access to deceleration/acceleration ramps Major reconfiguration requires consultation with OES and/or FHWA 69 Categorical Exclusion Training Class

70 Level 2 & Level 3 8. New truck weigh stations or rest areas 9. Railroad/roadway grade separation to replace an at- grade crossing  Includes removal of existing grade separation structures 10. Rehabilitation, reconstruction or conversion of existing rail and bus buildings  Includes ancillary facilities  Minor amount of land needed  Not a substantial increase in number of users 70 Categorical Exclusion Training Class

71 Level 2 & Level Construction or conversion of rail storage and maintenance facilities on new location  In areas predominately used for industrial or transportation purposes  Not inconsistent with existing zoning  No significant noise impacts to community 71 Categorical Exclusion Training Class

72 Level 2 & Level New bus storage and maintenance facilities  In areas predominately used for industrial or transportation purposes  Not inconsistent with existing zoning  Roadway network can handle anticipated bus and support vehicle traffi c 72 Categorical Exclusion Training Class

73 Level 2 & Level New bus transfer facilities  Open areas consisting of: Passenger shelters Boarding areas Kiosks Related improvements  In commercial centers or high activity center  Adequate capacity for projected bus traffic 73 Categorical Exclusion Training Class

74 Level 2 & Level ODOT storage and maintenance facilities on new location  In areas predominately used for industrial or transportation purposes  Not inconsistent with existing zoning  No significant environmental impacts 74 Categorical Exclusion Training Class

75 Level 2 & Level Construction of bicycle, pedestrian lanes, paths or facilities 16. Other project types approved by OES and/or FHWA 75 Categorical Exclusion Training Class

76 Level 2’s Can Involve…  Minor right-of-way acquisition involving a maximum of two relocations  Context and intensity may require elevation to the appropriate higher level Does not result in significant impacts to the human and natural environment  Minor amounts of hazardous materials  Limited to petroleum related Underground Storage Tanks (USTs) and/or releases 76 Categorical Exclusion Training Class

77 Level 2’s Can Involve…  Up to 3 acres of impacts to Category 1 and 2 wetlands and/or up to 0.5 acres of Category 3  Enough information to issue a wetland finding must be included as documentation  Section 106 Impacts  No Phase III Archaeological recommendation  Documentation for consultation included in project files per 36 CFR Categorical Exclusion Training Class

78 Level 2’s Can Involve…  Programmatic or de minimis 4(f) impacts  Programmatic can be approved by OES  de minimis approved by FHWA  Minor public or agency controversy on environmental matters  No opposition from organized groups or agencies  No unresolved environmental coordination 78 Categorical Exclusion Training Class

79 Not a Level 2 When… Projects involve any of the following impacts:  New through lanes more than 1 mile in length  Interchange to replace an at-grade intersection  Coast Guard Permit  Individual 4(f)  Substantial floodplain impacts  Federal Threatened or Endangered Species  Impacts to critical habitats resulting in a BO  Disproportionately high or adverse impacts to Environmental Justice populations 79 Categorical Exclusion Training Class

80 Level 3’s Can Involve…  Right-of-way acquisition involving a maximum of eight relocations  Context and intensity may require elevation to the appropriate higher level Does not result in significant impacts to the human and natural environment  Section 106 impacts  Documentation of consultation included in project files per 36 CFR Categorical Exclusion Training Class

81 Level 3’s Can Involve…  Wetland impacts of 5 acres or less  Enough information to issue a wetland finding must be included in documentation  Programmatic or de minimis 4(f)  Programmatic has been approved by OES  de minimis has been approved by FHWA  Individual 4(f)  Draft CE provided to FHWA Categorical Exclusion Training Class 81

82 Level 3’s Can Involve…  Substantial public or agency controversy on environmental grounds  Involves strong opposition from organized groups or agencies  Documentation must demonstrate that concerns by all parties have been addressed Categorical Exclusion Training Class 82

83 Not a Level 3 When… Projects involve any of the following impacts:  Floodplains (substantial/significant)  Disproportionately high and adverse impacts to Environmental Justice populations Categorical Exclusion Training Class 83

84 CE Level 4 Project Types Categorical Exclusion Training Class

85 Definition  Must meet intent of 23 CFR (d)  Based on past experience with similar actions, do not involve significant environmental impacts  Includes projects with impacts not discussed in the PA or those with higher impacts than listed  Confirmation that criteria has been satisfied is made by OES and/or FHWA 85 Categorical Exclusion Training Class

86 CE Preparation Categorical Exclusion Training Class

87 Stand Alone Document  All impacts assessed for context and intensity  40 CFR  Briefly summarize supporting documents or studies for each specific discipline  Includes decision-making documents Section 4(f) Evaluations 404(b)(1) Alternative Analysis Section 106 Coordination 87 Categorical Exclusion Training Class

88 Preparation  Sufficient engineering is completed in the Preliminary Development Phase  Helps assess environmental impacts  Meets public involvement requirements  Assists in completing CE  Preliminary plans for Preferred Alternative are included in project file and designated Part of CE  Serves as basis to proceed with final design and evaluate final plans when environmental consultation review is performed 88 Categorical Exclusion Training Class

89 Online CE  Tabs Include:  Project File Upload all documents electronically  Document Level Series of questions are answered to determine if project is Exempt or is a higher level of CE  General  Purpose & Need  Alternatives  Resource Specific Tabs  Environmental Commitments  Review and Approval 89 Categorical Exclusion Training Class

90 Resource Remarks  Engineering decisions, in regards to detailed design, should consider impacts to environmental resources and associated consequences  Discuss analyses of resources and anticipated:  Impacts upon environmental resources  Public and agency involvement  Permits required  Avoidance or mitigation measures  Environmental Commitments 90 Categorical Exclusion Training Class

91 Resource Remarks  When impacts occur:  Provide explanation or narrative describing anticipated impacts  Include resources within study area not directly impacted  Contain an outline of how specific resource area was addressed  Agency correspondence/how issues resolved  Associated data and study materials are part of project file at the originating location 91 Categorical Exclusion Training Class

92 Re-Evaluations Categorical Exclusion Training Class

93 23 CFR  Re-evaluations are conducted when the project scope and/or project impacts have changed since environmental document was last approved  If document is an EIS and is more than three years old and/or it has been more than three years since the last major federal action was authorized  Final Design  Acquire a significant amount of right-of-way  Approval of plans, specifications, and estimates package This does NOT apply to CE or EA actions 93 Categorical Exclusion Training Class

94 FHWA Guidance  Re-evaluations intended to encompass same project limits as in original environmental document  Large projects phased for construction may not require a complete re-evaluation for entire project limits  For phased projects, re-evaluation addresses current status of the entire project but focus on current phase  Re-evaluations consider: What has happened on entire project to date (including prior construction phases) What will follow (future construction phases) What or how changes to the project or impacts will affect current phase (and potentially future phases if that information is known) 94 Categorical Exclusion Training Class

95 CEQ Guidance  If environmental studies are more than five years old, agency re-coordination and/or new studies may be necessary  40 CFR (c)(1)(i)  When significant changes occur environmental impacts must be addressed  Depending on complexity of re-evaluation, a narrative format or CE Form may be used  Same review, concurrence, and approval process Categorical Exclusion Training Class 95

96 Best Practices  Include when original document was approved and why a re-evaluation was required  If environmental studies were completed less than five years ago, cite the date of concurrence for each study conducted  If applicable, state when permits were obtained and when they will expire  Note that all original environmental commitments will be adhered to and list any new commitments that have been made as a result of the re-evaluation Categorical Exclusion Training Class 96

97 Environmental Consultation Form (ECF)  Completed by District Environmental Staff  Completed prior to plan submission for final processing and prior to contract sale  Determines whether conditions of the proposed project have changed  Confirms CE classification remains valid  Lists environmental commitments and disposition 97 Categorical Exclusion Training Class

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