TCG worked with the FEMA, the Department of Homeland Security (DHS), the White House Council on Environmental Quality (CEQ), and the Advisory Council on Historic Preservation (ACHP) to rescind and update FEMA’s NEPA procedures for overall improvements and for compliance with DHS Directive 023-01, Implementation of the National Environmental Policy Act, and Instruction Number 023-01-001-01, Instruction Manual on Implementation of the National Environmental Policy Act.

TCG assisted FEMA with strategic planning for the update and developed an approach for how to revise the procedures. On behalf of FEMA’s Office of Environmental Planning and Historic Preservation, TCG conducted a Gap Analysis between the DHS Directive and Instruction Manual and the draft FEMA Directive and EHP procedures to help them develop an approach for revising their NEPA implementing procedures. Our team then scoped the procedures, researched the requirements, drafted the procedures, and developed accompanying briefings and white papers for use by FEMA in vetting the procedures through their leadership.

The NEPA procedures work included coordinating with internal stakeholders; preparing communication materials such as handouts, email blasts, webinars, and presentations; and facilitating working group meetings. The project also involved the facilitation of an agency steering committee and working with program staff, environmental staff, and agency leadership along with the preparation of briefing materials for senior-level agency staff. TCG prepared interim and final drafts of the directive and manual (collectively, NEPA procedures) and supported FEMA with internal comment adjudication. The project resulted in a sound procedural document to present to the Department of Homeland Security and the Council on Environmental Quality.