Under contract to USACE RPEC in support of the customer, White Sands Missile Range, Chloeta prepared a Programmatic EA to evaluate the potential environmental effects associated with construction of 50 miles of new fence and maintenance of the White Sands Missile Range (WSMR) boundary markings. The construction of 50 miles of new fence and the maintenance of 100 miles of boundary fence and markings that covers an expansive and various terrain was a first for the installation.  

The installation initially planned to develop an EA for a smaller proposed boundary area and do subsequent EAs once more details were known of other potential boundary areas. Innovative thinking by the Chloeta team, based on past experience with programmatic NEPA documents, resulted in the development of a programmatic approach to provide the installation more flexibility once future exact locations of boundary fencing is proposed. This innovation also resulted in increased efficiencies by providing an overarching NEPA document that could be tiered off of, for example once WSMR identified exact locations and determined whether additional natural or cultural resource surveys would be needed.

As this work was scheduled to be performed in phases over several years, not all of the site-specific project details were known at the time of EA preparation but WSMR needed to complete the NEPA ASAP. Solution: The Chloeta team recommended a programmatic approach to allow the client maximum NEPA flexibility and save time. The programmatic approach supported the implementation of future construction and recurring and predictable fence repairs to proceed in a more efficient and standardized manner. Issue: Operational security issues regarding exact WSMR boundary locations. Solution: Worked closely with the client to ensure photos and project details met operational security requirements while including sufficient detail for analysis. Issue: Adjacent landowners/ranchers and public potential concern with change in access to WSMR. Solution: Ensured language in the EA detailed that authorized WSMR hunting would continue consistent with WSMR policy and provided details regarding one-way livestock gates to ensure safe passage. 

This project included coordination and communication of the Public Draft EA with 26 agencies demonstrating ability to consult with the regulatory community:  

● 5 neighboring city and county governments, 

● 6 state agencies including the New Mexico Environment Department, Department of Transportation, Department of Game & Fish, and State Land Office, 

● 3 U.S. Senators and U.S. Congress members, 

● 10 Federal agencies including U.S. Fish and Wildlife Service, U.S. Environmental Protection Agency, Holloman Air Force Base, Bureau of Land Management, and U.S. Army Garrison Fort Bliss.  

The Chloeta Team for this project proactively provided Tulsa and WSMR a programmatic solution to save time and money – and delivered the Draft EA approximately 4 months ahead of schedule, which ultimately enabled WSMR to initiate the actual activity on-schedule. By applying a keen understanding of the balance between security and transparency, Chloeta partnered with installation personnel to ensure operational security requirements were met while still providing the necessary level of information to support informed decision making and public notification.

The EA also included an analysis of biological resources and soil erosion completed by Chloeta, as well as Chloeta providing overall contract management. 

This EA was one of the first EAs to follow the 2020 revised CEQ NEPA regulations and the associated Army NEPA Policy Memorandum (dated 26 August 2020) regarding the scope, schedule, and length of the EA. This project is a good example of our team’s experience handling GIS data regarding installation security and ensuring only data and information that passes operational security (OPSEC) is shared.  

Also, the team overcame COVID-19 travel and site access limitations by remotely reviewing existing photos and previous NEPA documents, and communicating with WSMR staff to understand the diverse topography and challenges of the boundary security.