The Council on Environmental Quality (CEQ)’s guidance states that when substantiating a new or revised categorical exclusion (CATEX), agencies may draw on several sources of supporting information. These sources include the experiences and opinions of professional staff; assessments of the environmental effects of previously implemented agency actions; and benchmarking other agencies’ experiences.

In November 2017, TCG led a training class for BLM and other DOI components on how to develop and substantiate categorical exclusions to improve the efficiency of DOI NEPA compliance, particularly in response to Executive Order 13807: “Establishing discipline and Accountability in the Environmental Review and Permitting Process for Infrastructure Projects”, and DOI Secretarial Order 3355: Streamlining NEPA Reviews and Implementation of EO 13807. 

The training course consisted of both presentations and facilitation of discussion among participants.  The course content included an overview of the requirements for establishing and implementing Categorical Exclusions from the CEQ regulations, instruction on how to develop the language for new categorical exclusions and how to substantiate the CATEX list through an administrative record including benchmarking, professional experience, and previously implemented actions, and instruction on the process including consultation with CEQ, federal register requirements and public comment.  In addition to administrative CATEX lists, the course also covered legislative categorical exclusions and methods for agencies such as the BLM and Forest Service to collaborate on the establishment and use of CATEXs for similar projects.