Environmental Compliance 

Advanced Training

For the U.S. Department of Agriculture (USDA) Agricultural Marketing Service (AMS) 

Resilient Food Systems Infrastructure Program (RFSI)

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Learning Objectives

 Become familiar with the National Environmental Policy Act (NEPA) 

implementation process as well as RFSI Grant Program documentation 

requirements.

 Understand the RFSI grant application screening process required to achieve 

environmental compliance under NEPA as well as applicable Federal laws and 

regulations.

 Clearly identify USDA AMS, State/Territory, and applicant responsibilities in the 

RFSI Grant Program environmental screening process.

 Identify desktop tools available to facilitate site-specific environmental 

evaluation of RFSI Grant Program applications. 

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NEPA Documentation Review 

• CATEX – Categorical Exclusion (40 CFR Part 1501.4)

• EA – Environmental Assessment (40 CFR Part 1501.5)

• FONSI – Finding of No Significant Impact (40 CFR Part 1501.6)

• PEA – Programmatic Environmental Assessment 

 (45 CFR Part 900.207)

• EIS – Environmental Impact Statement (40 CFR Part 1502)

• ROD – Record of Decision (40 CFR Part 1505.2)

USDA NEPA 

Implementing 

Procedures are 

under development; 

CATEX cannot be 

utilized at this 

time.

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RFSI Programmatic Environmental Assessment (PEA) Scope

• Each grant application will be evaluated to determine if its potential environmental 

impacts have been addressed in the PEA. 

• Section 3.2 (Resources Considered with Detailed Analysis) finds no significant adverse 

impacts to the following environmental resource areas:

o Water Quality

o Socioeconomics and Environmental Justice

o Climate Change

• As per Section 3.1 (Resources Eliminated from Detailed Analysis), the PEA did not fully 

consider the following resources for further review at the programmatic level:

o Vegetation and Wildlife

o Cultural resources

o Coastal Barrier Resource and Coastal Zones

o Wild and Scenic Rivers and Nationwide Rivers 

Inventory

o Wilderness Areas and National Natural Landmarks

o Floodplains and Wetlands

o Soils and Other Important Land Resources

o Air Quality

o Noise

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State/Territory 

determines a 

subaward project 

is consistent with 

RFSI Program and 

submits proposal 

to AMS for 

approval. 

No

AMS notification to State/Territory of 

Administrative Review status. 

State/Territory notifies Applicant. 

State/Territories will eliminate 

subaward applications that are not 

consistent with RFSI Grant Program 

(they will not get forwarded to AMS). 

Yes Environmental Screening 

(State or Territory review of Applicant documentation)

Using the Environmental Pre-Screening Worksheet (AMSENV-A), States/Territories will review project detail and 

answer questions accordingly. Collect supporting 

documentation for answers, as necessary (ex. tax records, 

maps, details, etc.). 

States/Territories will notify the Applicant if more information 

is needed to complete Form AMS-ENV-A. A request for 

information may include an Applicant Questionnaire.

Based on Form AMS-ENV-A, the proposed project does not 

trigger extraordinary circumstances or require a site-specific 

review. The proposed actions are within the scope of the PEA. 

Yes

No

Further investigation is needed to demonstrate actions are within

scope of PEA and do not have significant impacts.

Using the Environmental Screening Worksheet (AMS-ENV-B), 

States/Territories will review project detail and answer questions 

according to each project. Collect supporting documentation for 

answers, as necessary. 

As with Form AMS-ENV-A, States/Territories notify the Applicant 

if information is needed to complete Form AMS-ENV-B. A 

request for information may include an Applicant Questionnaire.

NOTE: Multiple rounds of document requests, permit authorizations 

or regulatory agency consultation may be required to complete 

environmental analysis based on project complexity. All supporting 

documentation will be provided to AMS.

Based on Form AMS-ENV-B, there are no potentially significant 

environmental impacts or extraordinary circumstances. The 

Yes proposed actions are within the scope of the PEA. 

Environmental is Review Complete. 

AMS notifies State/Territory of Official approval. 

State/Territory includes completed forms and 

supplementary environmental documentation in 

the project application package provided to 

AMS. AMS will serve as the Responsible Federal 

Official (RFO) and provide final approval. 

No

This proposed action includes activities that do not fit within the scope of 

the PEA or has the potential to significantly impact a protected resource. 

A site-specific Environmental Assessment or an Environmental Impact 

Statement should be completed to provide further and more complete 

analysis of any adverse impacts and approval of the action must be delayed 

pending the outcome of the analysis. 

AMS will determine the appropriate level of NEPA documentation. 

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Roles and Responsibilities USDA AMS States and 

Territories 

Applicants

Complete an Applicant Environmental Questionnaire, when requested, to 

provide project details.

X

Complete an Environmental Pre-Screening Worksheet (AMS-ENV-A) up to 

Section 6, for the project. Include any supporting documentation.

X

Complete an Environmental Screening Worksheet (AMS-ENV-B) up to Section 

8, for the project, if necessary. Include any supporting documentation. 

X

Request any additional information from the applicant, if necessary to 

complete an environmental screening.

X

Obtain all necessary permits and authorizations (i.e., NHPA Section 106 and 

ESA Section 7 determinations, Clean Water Act permits, Clean Air Act permits, 

etc.) identified through the completion of AMS-ENV-B with support from State 

environmental agencies and USDA AMS. 

X X X

Approve AMS-ENV-A and AMS-ENV-B, determine the appropriate level of 

environmental review necessary to comply with NEPA, and provide written 

notification of authorization to proceed. 

X

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Applicant Environmental Questionnaire 

To facilitate the environmental review of project applications, States/Territories may ask 

applicants to complete a brief questionnaire to inform any potential environmental 

impacts resulting from the proposed project.

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Applicant Environmental Questionnaire (cont.)

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Environmental Screening Forms

• Environmental Pre-Screening Worksheet (AMS-ENV-A)

o Used to assess projects for their adherence with the limited, programmatic-level 

analysis within the PEA and determine the level of environmental review necessary.

• Environmental Screening Worksheet (AMS-ENV-B)

o Used to determine the potential for impacts not documented in the PEA and identify 

the level of additional environmental review required, if any.

o Section 3.1 of the PEA lists the resources that were eliminated from detailed analysis, 

including those that require a site-specific environmental review using Worksheet 

AMS-ENV-B. 

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Environmental Pre

-Screening 

Procedures (AMS-ENV-A)

• AMS-ENV-A serves as NEPA 

documentation for projects that fit 

within the scope of the PEA.

• Section 2 identifies extraordinary 

circumstances that may exist and 

require further site-specific 

screening.

• This form must be signed by the 

preparer (State/Territory) and 

Responsible Federal Official (USDA 

AMS). 

• AMS-ENV-A supports the 

preparation of AMS-ENV-B for 

projects that may be outside the 

scope of the PEA.

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Site

-Specific Environmental Review 

Procedures (AMS-ENV-B)

• AMS-ENV-B supports identification of 

environmental resource areas that may be 

impacted by the scope of the project.

• Section 2 identifies environmental resources 

that may require further analysis of potential 

impacts from the project.

• Section 3 identifies consultations and regulatory 

coordination that may be required to complete 

the environmental review for the project under 

NEPA. Applicable laws and regulations are 

identified. 

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Site

-Specific Environmental Review 

Procedures (AMS-ENV-B cont.)

• Section 6 identifies extraordinary 

circumstances that may be applicable to 

the project.

• Section 7 documents the NEPA compliance 

finding and if further review is necessary. 

The required level of NEPA documentation 

is identified with support from USDA AMS.

• States may need to contact internal or 

external resources and subject matter 

experts to complete the evaluation. 

• This form must be signed by the preparer 

(State/Territory) and Responsible Federal 

Official (USDA AMS).

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Consultations and Permits

• Based on the results of the Environmental Screening Worksheet 

(AMS-ENV-B), the environmental review may require consultations 

with Federal, State, or local government officials.

• Depending on the level of impact proposed for the project, applicants 

may also be required to obtain permits prior to project 

implementation.

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Consultations and Permits (cont.)

These are some Federal laws that could require applicants to initiate consultations or obtain permits/authorizations. 

National Historic 

Preservation Act

• Section 106 Consultation 

with SHPO

• Applicable to initial ground 

disturbing activities and 

structural improvements

Endangered Species 

Act

• Section 7 Consultation 

with USFWS or NOAA

• Incidental Take Permit

Clean Water Act

• Water Quality Certification

• National Pollutant 

Discharge Elimination 

System (NPDES) Permit

• Section 404 Permit

Clean Air Act

• Minor New Source Review 

(NSR) Permit

• Prevention of Significant 

Deterioration Permit

• Nonattainment NSR Permit

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Consultation Process Overview 

The States/Territories, in coordination with the applicants, will:

1. Identify resource(s), known constraints, or uncertainties. 

2. Identify the appropriate regulatory agency for consultation and internal 

resources/SMEs to support the effort.

3. Initiate agency consultation utilizing preferred communication channel

(consultation letters, email correspondence, online planning tools, etc.) 

and provide resource reports, as applicable. Tribal consultation would 

require signature by the USDA AMS RFO. 

4. Obtain concurrence on determination of effect. 

5. Return to NEPA documentation and incorporate any applicable 

mitigation, minimization, or avoidance measures. 

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Desktop Tools for Environmental Analysis

General

• EPA EnviroAtlas Interactive Map

• EPA NEPAssist

Climate Change

• CEQ Greenhouse Gas Estimating Tools

Environmental Justice

• CEQ Climate and Economic Justice Screening Tool

• EPA Environmental Justice Screening and Mapping 

Tool (EJSCREEN)

Air

• EPA CAA Permitting in Your Region

• EPA Nonattainment Areas for Criteria Pollutants 

(Greenbook)

Historic Preservation

• DOI National Natural Landmarks Directory

• DOI National Register of Historic Places Locations

• The National Conference of State Historic 

Preservation Officers Directory

• Tribal Directory Assessment Tool (TDAT)

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Desktop Tools for 

Environmental Analysis (cont.)

Water

• DOI Nationwide Rivers Inventory

• EPA Sole Source Aquifers

• FEMA National Flood Hazard Layer Viewer (NFHL)

• National Wild and Scenic Rivers System

• NOAA Coastal Zone Management Act Boundaries

Wildlife and Habitat

• NOAA Essential Fish Habitat Mapper

• USFWS Information for Planning and Consultation (IPaC)

• USDA Wilderness Areas

• USFWS Coastal Barrier Resources System Mapper

• USFWS National Wetlands Inventory

• USDA Web Soil Survey

Image from NEPAssist

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Common Requests for Information to Applicants

LOCATION ?

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RFSI Example: RFSI Application No. 202402 1). Based on Environmental PreScreening Worksheet (AMS-ENV-A), 

the State/Territory determined that 

the project may trigger extraordinary 

circumstances outside of the scope of 

the PEA and requires further 

investigation. 

2). State/Territory submits a 

request for information and 

Applicant Questionnaire, if not 

provided with application 

package, to the applicant. 

3). Using the Environmental Screening Worksheet (AMSENV-B), State/Territory reviews project detail provided. 

• 500- square feet of non-native vegetation (Black mustard 

and ornamentals) will be cleared adjacent to existing 

structures. 

• Ground disturbing activities will be limited to topsoil 

removal and the placement of gravel in preparation for a 

new freezer container. 

• Concurrence from the State Historic Preservation 

Office and tribal affiliates was obtained for a 

determination of no effect to historic resources. 

• All proposed improvements will be conducted entirely in 

upland areas. The nearest palustrine wetland is 350 feet 

away. 

4). Based on Form AMS-ENV-B, there are 

no potentially significant environmental 

impacts or extraordinary circumstances.

The proposed actions are within the 

scope of the PEA. 

The State/Territory provides AMS with the 

completed form for RFO approval.

ENVIRONMENTAL REVIEW IS COMPLETE 

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Thank You

For additional questions or training requests, please email: RFSI@usda.gov

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