Federal agencies are being asked to evolve.
Their NEPA processes usually aren’t.
That’s where things start to break down.
Grant programs are designed to respond to real community needs. The mission of a federal agency may stay the same, but how that mission is carried out can look very different depending on the communities it is serving. Because of that, the types of projects needed to achieve that mission shift over time. As those programs evolve, the environmental review process does not always keep pace.
We saw this firsthand working with the Northern Border Regional Commission (NBRC).
NBRC’s mission is to support economic development across the Northeast, particularly in low-income and rural communities. The way that support takes shape varies across the region, but it also changes over time. Economies evolve. The needs of communities shift. What made sense to fund ten years ago often does not reflect what those communities need today.
As NBRC’s grant programs adapted to meet those changing needs, the types of projects they funded began to shift as well. More recently, that has included greater investment in forest economy projects tied to regional resources. NBRC was doing exactly what it should be doing as a federal funding agency, evolving its programs to stay aligned with its mission. But the environmental review framework in place was not keeping pace, making it more difficult to process those projects efficiently and in a way that was fully aligned with how they were intended to be reviewed.
The question became: how do you evolve a grant program without letting environmental compliance slow everything down?
Because that is where good projects get stuck.
At The Clark Group, we understand that NEPA has historically been a fixed process. But recent changes have created a real opportunity. As of 2023, federal agencies can adopt another agency’s categorical exclusions for their own actions when done appropriately.
That shift matters.
It creates a way for agencies to align their environmental review process with the work they are actually funding, instead of forcing new types of projects through a framework that was not built for them.
For NBRC, that meant looking at how similar projects were already being reviewed by the U.S. Forest Service and identifying where those approaches aligned.
This is where we stepped in.
As NBRC’s environmental compliance advisor, we worked with them to identify a path forward that aligned with both their evolving programs and their NEPA obligations. Rather than pushing these projects through longer environmental reviews that were not proportionate to their impacts, we showed how categorical exclusions used by the Forest Service could be appropriately applied to NBRC’s projects.
From there, we worked alongside NBRC to apply those categories in a way that fit their programs, ensuring they were used consistently, appropriately, and in line with how they are intended to function.
It is not a copy and paste exercise. It requires understanding how those categories are used in practice and tailoring them so they fit the agency’s specific programs and types of projects.
When done well, the result is straightforward.
Projects that do not have significant environmental effects can move forward efficiently, without being pushed into unnecessary levels of analysis. Agencies can keep their programs aligned with real community needs without slowing down the delivery of funding.
For NBRC, that meant being able to move projects forward that aligned with their mission, without unnecessary delays.
And that is really the point.
When environmental compliance is aligned with the work being funded, it does not slow things down. It supports better decisions and allows agencies to deliver funding where it is needed, when it is needed.
There is a way to do both.
And when it is done right, NEPA becomes part of the solution, not the bottleneck.
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About The Clark Group
For more than 25 years, The Clark Group has led environmental compliance efforts for federally funded projects across the United States. In addition to preparing environmental documentation and coordinating federal, state, and local consultations, we have developed NEPA procedures and guidance for federal agencies. Our experience spans both implementation and policy development, giving us a practical understanding of how environmental review works in real-world project settings.