Initiating a Preliminary Environmental Study for NEPA

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The National Environmental Protection Act (NEPA) requires agencies to consider the environmental impacts of any proposed action or project before a decision is made. Projects involving federal aid or permitting typically fall under the NEPA regulatory umbrella, including infrastructure development and resource management initiatives.

When a local or state agency is requesting federal aid, permits, or approvals for a local roadway or pedestrian facility enhancement project, the Local Public Agency (LPA) applies for a permit or funds from the federal agency. A state’s transportation department is the entity responsible for applying for infrastructure project federal funding or resources, typically from the Federal Highway Administration (FHWA) or another relevant agency.

In California, the California Department of Transportation (Caltrans) is responsible for the planning, design, construction, maintenance, and operation of California’s state highway system and other transportation-related projects. Caltrans also administers funding from FHWA and FTA for local roadway and pedestrian facility enhancement projects.

Preliminary Environmental Study (PES): The First Step in NEPA Compliance for local roadway and pedestrian enhancement projects

Caltrans utilizes a Preliminary Environmental Study (PES), found in Local Assistance Procedures Manual (LAPM) Form 6-A, to determine the appropriate level of environmental review required under NEPA. The purpose of the PES is to provide a basis for informed decision-making and to ensure that environmental considerations are integrated into the planning process from the onset. LPAs are required to address a variety of potential environmental impacts, assessing the risk level for each. A successful PES may include:

Initiating and Completing a PES Form

Following all information-gathering methods, the LPA completes the PES form, which must be submitted for local roadway and pedestrian facility enhancement projects seeking federal funding.

Filling out a PES form requires a thorough understanding of not only the proposed project, but also the potential environmental impacts, completed tests and analyses, and available mitigation opportunities. While the exact format and requirements may vary, completing the PES form generally entails:

  • Providing detailed project information

  • Identifying environmental resources

  • Assessing potential environmental impacts

  • Identifying mitigation measures

  • Describing public and agency coordinating efforts

  • Expertly reviewing documentation before form submittal

The PES form identifies 14 areas of environmental concern, further broken down into 36 questions regarding potential direct and indirect environmental effects. The areas of environmental concern include air and water quality, wildlife habitats, cultural resources, and socioeconomic factors.

PES Findings to Determine Level of Environmental Review and Mitigation

Depending on the findings of the PES, the LPA may be directed to proceed additional studies to inform the level of NEPA review required. Ultimately, Caltrans will determine whether the NEPA Compliance can be completed without any further review, or whether an Environmental Assessment (EA), or Environmental Impact Statement (EIS) will be required. Many local assistance projects are processed under a categorical exclusion, supported by technical studies.

Identifying, assessing, and addressing various environmental impacts for a proposed project is a complex process, but crucial in meeting our shared responsibility for public safety and environmental protection. Partnering with a third-party environmental consultation firm can take much of the burden off an agency’s shoulders and shift it to a team of experts.

FirstCarbon Solutions (FCS) is a robust team with decades of experience and skill in conducting thorough environmental assessments and identifying and addressing concerns, expediting your NEPA project approval process. The FCS team also has the resources to complete any necessary mitigation measures, making it a one-stop shop for development success.

FirstCarbon Solutions (FCS) comprises over 100 individuals offering due diligence, technical analysis, planning, environmental compliance, permitting, and mitigation/monitoring services for public and private projects. FCS has more than 30 years of experience navigating the complexities of NEPA and securing project approvals. Contact us for a free consultation to learn more about how we can help with your specific requirements. 

About the author

Mary Bean

Mary Bean thumbnail

Mary is FCS's Environmental Services Senior Vice President and has more than 24 years of experience managing the preparation of CEQA and NEPA documents in both the public and private sectors.
She is knowledgeable about a broad range of environmental topics, backed by her experience in the field, research, technical writing, and planning. She specializes in leading interdisciplinary teams in the preparation of technical studies that support environmental clearance at the local, State, and national levels. Her depth of experience allows her to be particularly effective in strategizing with clients about the most efficient approach to environmental review. In her 7 years with FCS, Mary has successfully led FCS’s services on more than 450 projects.

How we can help

In an ever-changing regulatory and sustainability environment, FCS understands the challenges you face. Our highly qualified environmental specialists, energy management consultants, and technical experts deliver integrated, industry-specific solutions that move your project forward—so that you can focus on what matters.