*EDA Environmental Narrative Requirements*

**Appendix A:   Applicant Certification Clause**

# Revised June 2021. Please check EDA’s website before using this template to confirm that you are using the latest version. As of the date of this version, the current template can be found at the bottom of the “Programs” page at EDA.gov. 

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# Environmental Narrative Requirements

The National Environmental Policy Act (NEPA) requires Federal agencies to assess the potential environmental impacts associated with proposed federal actions, including financial assistance.  Applicants are encouraged to contact their designated Economic Development Representative or the applicable EDA Regional Environmental Officer with questions regarding this template and/or the appropriate level of documentation (please see the EDA website or the applicable Federal Funding Opportunity for contact information).  Resources of available information are listed in many of the sections. If you are using a locally saved copy of this template, please check EDA’s website to confirm this is the current version.

For further information regarding EDA’s obligations under NEPA, please refer to the regulations for implementing NEPA at 40 C.F.R. 1500-1508. The Council on Environmental Quality’s 2007 guidance document “A Citizen’s Guide to the NEPA” is another resource available online.  

Several issues discussed in the environmental narrative below may require consultation with other State or Federal agencies at a later date (for example, the State Historic Preservation Office, the U.S. Fish and Wildlife Service, or the National Oceanic and Atmospheric Administration’s (NOAA) National Marine Fisheries Service (NMFS)).  While EDA does not require that applicants complete such consultations before submitting an initial application, applicants should be aware that in the event their project is selected for further evaluation for funding, EDA may delegate these consultations to the applicant and expect them to be completed in an expeditious manner and prior to approval of an award.  

**Applicants must provide information on the following items in the environmental narrative.  For any area in which the applicant asserts that an item is not applicable to a project, provide an explanation.**

## PROJECT DESCRIPTION

### Beneficiaries

Identify any existing businesses or major developments that will benefit from the proposed project, and those that will expand or locate in the area because of the project.

### Proposed Construction

As an exhibit to this Narrative, provide a topographical map of the project area and a site map (with legend and north arrow) displaying the project location and boundaries, existing and proposed project components and location of all sites and/or companies benefitting from the proposed project.  The documents should be of sufficient clarity for adequate interpretation of the Applicant’s intentions.

Describe the project construction components in detailed, quantifiable terms.   Describe the project location, proposed construction activities (e.g., grading, trenching), and schedule. **It is sufficient to simply reference the Preliminary Engineering Report (PER) here if a PER containing this information has been submitted or will be submitted concurrently.** See the mock example below for the level of specificity expected by EDA:

*The City of ______________ is proposing to construct a 30-inch (in) water line which would be constructed within an existing 50-foot City of __________ right-of-way (ROW) and measure 1,220 linear feet (lf).  The project is located within Township 39N, Range 10E, Section 24 in the City of ________,  _______ County, [[[State]]].  The project would be constructed over a three-month period from April June 2011.  Construction of this project would entail trenching a 1 ft wide by 3 ft. deep ditch and installing the 30in. pipe within the existing ROW.  Total land disturbance will be 2.1 acres.*

*The construction staging area would be located entirely within the existing ROW.    Minor maintenance would occur during the operation of the waterline, but would not entail any ground disturbing activities.*

### Need and Purpose

Provide a brief summary of the underlying need and purpose of the proposal for EDA funding.

### Alternatives to the Proposed Project

Based in the Need and Purpose summary above, provide a detailed description of alternative actions that were considered during the project planning but were not selected (e.g., alternative locations, designs, scopes, other projects having similar benefits, and a “no project” alternative). Explain why this project/site was selected as the preferred alternative.  Provide detail on why other alternatives were rejected (e.g. did not meet the purpose and need of the project, implicated more environmental receptors, had greater climate impacts or were at greater risk to climate change than the proposed action).  If the selected project would impact wetlands or floodplains, please provide a detailed description of alternatives to those proposed impacts.  

## HISTORIC/ARCHEOLOGICAL RESOURCES

Identify any known historic/archeological resources within the project site(s) or area of potential effect that are either listed on the National Register of Historic Places or considered to be of local or State significance and perhaps eligible for listing on the National Register.  In many states, the State Historic Preservation Office (SHPO) maintains GIS databases of historic properties and cultural resources.  Delineate an Area of Potential Effect (APE) for the project.  The APE is the geographic area or areas within which a proposal may cause changes in the character or use of historic properties, which would include (but is not limited to) any new development or renovation by the beneficiary facilitated by the proposed EDA project. Discuss the potential impacts of the project on culturally significant resources and provide a determination as to whether there will be: no historical properties/cultural resources present; no historical properties/cultural resources adversely affected; or historical properties/cultural resources adversely affected. 

**Note that the applicant is not required to contact the SHPO until directed to do so by EDA**.  If comments from the SHPO have already been received, they should be attached along with copies of the information provided to the SHPO.  If you wish to initiate early consultation, please consult the website of the appropriate SHPO for instructions on required information.  

## AFFECTED ENVIRONMENT

For the resource areas identified below, indicate potential direct and indirect impacts from proposed project activities and specify proposed measures to mitigate probable impacts.  Direct impacts are caused by the proposed action and occur at the same time and place.  Indirect impacts are those that are caused by a proposed action, but that may occur later in time or farther removed in distance, relative to the primary impacts of the proposed action (40 C.F.R. Section 1508.8) Development induced by the proposed project would be an example of an indirect impact. 

### Affected Area

Describe the general project area, including topography, historic land usages, unique geological features, and economic history.  Provide site photographs if available.  Identify native vegetation and wildlife found in the project area or its immediate vicinity.  Describe the amount and type of vegetation in the project area and indicate the impact to vegetation if removed (e.g., 1.2 acres of early successional native hardwood forest). Identify any designated State and National Parks, National Wildlife Refuges, or National Game Preserves located on or in the vicinity of the proposed project activities. Identify any Wilderness Areas, as designated or proposed under the Wilderness Act, or wild or scenic rivers, as designated or proposed under the Wild and Scenic Rivers Act, or other lands protected under state or federal law that are located on or in the vicinity of the proposed project activities.

1. Please describe any direct effects 

2. Please describe any indirect effects

### Coastal Zones

Indicate whether the project is located within a designated coastal zone subject to the Coastal Zone Management Act.  Information on coastal zone boundaries is available on the NOAA’s website.  Identify any shorelines, beaches, dunes, or estuaries within or adjacent to the project site(s) and explain how the proposed project is consistent with the state’s Coastal Zone Management Plan. If state concurrence is required, identify the state’s Coastal Zone Management Agency.

### Wetlands

Identify any wetlands within or adjacent to the project site(s).  If available, provide an on-site wetland/waters delineation performed in accordance with the 1987 (or current version) USACE Wetland Delineation Manual, as amended. Provide any correspondence from USACE, including any jurisdictional determination or permit documents. 

1. Provide a determination of direct and indirect effects including the amount of jurisdictional waters affected by type (e.g. 1.1 acres of palustrine emergent wetlands would be impacted by the proposed project).  

2. If any wetlands would be impacted by the project, provide an analysis of alternatives to wetland impact in this section or in the Alternatives to the Project section above. 

3. Describe any mitigation plans here or in Section D below. 

Also indicate if there are any proposed overwater structures that could impact navigable waters as defined in 33 CFR part 329.

If wetlands, streams, or navigable waters may be impacted, it is recommended that Applicants contact USACE concerning any jurisdictional waters resources. 

### Floodplains

Please state whether the project is located within a mapped 100- or 500-year floodplain. Provide a FEMA floodplain map (with the map number and effective date) displaying the project location and boundaries, existing and proposed project components, and location of all sites and/or companies benefiting from the proposed project.  The document should be of sufficient clarity for adequate interpretation of the applicant’s intentions.  

Floodplain maps can be viewed and printed from FEMA’s website.  If FEMA floodplain maps do not exist in the project area, provide a letter from a Professional Engineer regarding the presence or absence of a 100-year floodplain.

i) Describe direct and indirect effects to 100-year floodplains, if any.

ii) If any 100-year floodplains would be impacted by the project, provide an analysis of alternatives to floodplain impact in this section or in the Alternatives to the Project section above.

iii) Indicate whether the Applicant’s community participates in the National Flood Insurance Program.

iv) Indicate if a critical action (e.g., emergency response facility, hospital, wastewater treatment plant) is being located within the 500-year floodplain.

### Climate Change

Identify any current or potential risks to the project due to climate change (e.g., flooding, wildfires, sea level rise, severe weather), utilizing federal resources, including the National Climate Assessment. Describe any steps taken in the planning and design of the project to mitigate those risks, including utilizing federal resources such as the U.S. Climate Resilience Toolkit. Identify any ways in which the project may contribute to future climate risks, such as by increasing flood risks, and any potential measures for mitigating those contributions. Describe any steps taken to reduce the project’s immediate and future carbon footprint (e.g., use of renewable building materials, incorporation of energy-efficient design features).

### 

### Endangered Species

Provide a list of all threatened, endangered, and candidate species located in or near the project area, including any proposed development by the beneficiary, and the immediate vicinity.  Identify these species’ potential or existing habitat, and critical habitat designations in the project area.  Identify the potential for direct or indirect impacts on these species.  Critical habitat designations, lists of protected species by county, and information on effect determinations are available on the FWS website. The FWS’ web-based Information, Planning, and Conservation System (IPaC) may also be useful for the early planning stage of a project. If an Effect Determination or Biological Assessment has been completed for any of the species listed, please provide.  Attach any correspondence with FWS that exists related to their proposal.  For projects with possible impacts to fisheries and marine/coastal species, provide any correspondence with NMFS.

### Land Use and Zoning

Describe the present formal zoning designation and current land use of the project site and adjacent land parcels.  The areas include: the site of construction activities, adjacent areas, and areas affected by the primary beneficiaries.  Land uses to be considered include, but are not limited to, industrial, commercial, residential, agriculture, recreational, woodlands, mines/quarries, and open spaces.  Please indicate whether the project is located entirely within a city limit.

Identify agriculture land parcels designated as “prime/unique agriculture lands” by the U.S. Department of Agriculture (USDA) under the Federal Farmlands Protection Act or a local equivalent.  Additional information may be found at the USDA’s Natural Resources Conservation Service website.

### Solid Waste Management

Indicate the types and quantities of solid wastes to be produced by the project facilities and primary beneficiary.  Describe local solid waste collection and disposal methods and the expected useful life of the disposal facility. Indicate if recycling or resource recovery programs are currently being used or will be used in the future.

### Hazardous or Toxic Substances

Describe any toxic, hazardous, or radioactive substances that will be utilized or produced by the proposed project facilities and primary beneficiaries.  Describe the manner in which these substances would be stored, used, or disposed.  Complete and sign one “Applicant Certification Clause” for each co-applicant (see Appendix A).  Indicate if hazardous or toxic substances have been or must be remediated prior to construction, demolition, or renovation.  If a recent Phase I or Phase II Environmental Site Assessment has been performed, please provide a copy of the executive summary (a full copy may be requested at a later date).

### Water Resources

Describe surface and underground water resources at or near the proposed project site(s) and any impacts of the project to these.  If groundwater will be used, is the aquifer in overdraft and /or adjudicated?  If there will be discharges to surface water, is the receiving surface water body listed on the U.S. Environmental Protection Agency’s (EPA) Section 303(d) list of impaired waters?  Is a National Pollution Discharge Elimination System (NPDES) permit required for any discharges to surface waters?  Indicate if the proposed project is located within an area mapped by the EPA as sole source aquifer recharge area (maps and further information are available on EPA’s website).  Describe any induced changes in local surface water runoff patterns, and the status of storm water discharge permit processes (if applicable).  

### Water Supply and Distribution System

Indicate the source, quality, and supply capacity of local domestic and industrial/commercial water resources, and the amount of water that project facilities and primary beneficiaries are expected to utilize.  Note whether the water that is being supplied is in compliance with the Safe Drinking Water Act, and if not, what steps are being taken to ensure compliance.

### Wastewater Collection and Treatment Facilities

Describe the wastewater treatment facilities available for processing the additional effluent including usage by the beneficiary(s). Indicate design capacities and current loading (both daily average and peak), and adequacy in terms of degree and type of treatment required.****Describe all domestic class or process wastewater or other discharges associated with the proposed project facilities and its primary beneficiaries, and the expected composition and quantities to be discharged either to a municipal system or to the local environment.  Indicate all discharges that will require on-site pre-treatment. Note whether the wastewater treatment plant is in violation of the Clean Water Act, and if so, what steps are being taken to ensure compliance.  If local treatment and sewer systems are or will be inadequate or overloaded, describe the steps being taken for necessary improvements and their completion dates.

### Environmental Justice (Executive Order 12898)

Describe whether the proposed project will result in disproportionate adverse human health or environmental impacts relative to minority and low income populations.  Sufficient detail should be provided to enable EDA to determine whether the project will comply with Executive Order 12898.

### Transportation (Streets, Traffic and Parking)

Briefly describe the local street/road system serving the project site(s) and describe any new traffic patterns that may arise because of the proposed project.  Indicate if land use in the vicinity, such as residential, hospital, school, or recreational, would be affected by these new traffic patterns. Indicate if any existing capacities of these transportation facilities would be exceeded as a direct or indirect result of this project implementation, particularly in terms of car and truck traffic, and what the new Level of Service designation would be.

### Air Quality

Indicate types and quantities of air emissions (including odors) to be produced by the proposed project facilities **and its primary beneficiaries,** and any measures proposed to mitigate adverse impacts.  Indicate the impact that the project would have on greenhouse gas emissions.  Is the proposed project site within an area classified as a “non-attainment” for any criteria pollutants?  If so, what are those pollutants?  Indicate any local topographical or meteorological conditions that hinder the dispersal of air emissions.

### Noise 

Would operation of project facilities or primary beneficiaries’ facilities increase local ambient noise levels?  If yes, indicate the estimated levels of increase, and the areas and sensitive receptors (e.g., residences, wildlife) to be affected. 

### Permits

Identify any Federal, State, or local permits of an environmental nature needed for the project (e.g., USACE, US Environmental Protection Agency (EPA), Coastal Zone Management/Shoreline Management, Air Quality, State Environmental Policy Act, NPDES) and the status of any such permits.  Attach copies of any such permits and all associated correspondence, including the permit applications.

### Public Notification/Controversy

Provide evidence of the community’s awareness of the project, such as newspaper articles or public notification and/or public meetings, as applicable.  If a formal public hearing has been held, attach a copy of the minutes. Fully describe any public controversy or objections which have been made concerning this proposed project and discuss steps taken to resolve such objections.

### Cumulative Effects

Please list projects (public and private, whether or not directly related to the proposed project described above) that have occurred or will occur in the past, present, and reasonably foreseeable future in and around the project area that could result in significant cumulative impacts when considered in aggregate with the proposed EDA project.  Cumulative impacts result from the incremental impacts of a proposed action when added to other past, present and reasonable foreseeable future actions (40 C.F.R. Section 1508.7). In other words, cumulative impacts can result from individually minor but collectively significant impacts.  Based on the direct and indirect impacts identified in Sections C1-18, identify which resources, ecosystems, and human communities are affected; and which effects on these resources are important from a cumulative effects perspective.

## MITIGATION

Describe methods to be employed to reduce impacts to any and all adverse impacts identified in Section C.  List all mitigation measures that would be implemented to minimize impacts to environmental resources from project implementation.

## 0. LIST OF ATTACHMENTS

The following checklist is a list of required and optional attachments to the Environmental Narrative as described in the sections above.  The items listed in the optional section may be required by EDA at a later date to complete the project review and selection process, so it is recommended that you provide them now if they are currently available.  While the documents listed below are the most frequently required for scoping determinations, EDA reserves the right to request additional items that are not listed below when necessary.

Applicants are not required to contact other governmental agencies for environmental or historical resources consultation until directed by EDA, though any interagency coordination letters that may be currently available should be provided.  **EDA expects that all Applicants whose projects are selected for further evaluation will proceed with consultations in an expeditious manner.  As such, Applicants should have the required information prepared for submission immediately upon notification of selection by EDA.**  If you determine prior to application that your project may affect environmental or historical resources, you may contact the appropriate Regional Environmental Officer to determine if early interagency consultation is appropriate.

Please refer to the applicable Federal Funding Opportunity for unique requirements for each individual grant competition and a list of documents required for submittal with the application.

Checklist of Optional Environmental Documents that should be submitted with Application**if available**(will expedite review and selection process):

· SHPO/THPO and Tribal leader comments and copy of submittals (see Section B)

· Site photographs (see Section C1)

· Coastal Zone consistency determination (see C2)

· Wetland delineation and/or Jurisdictional Determination (see C3)

· Preliminary wetland info (see C3)

· U.S. Army Corps of Engineers comments, Section 404 Permit, Section 10 Permit, and/or Water Quality Certification (401 approval) (see C3)

· Biological Assessment and/or survey for federally protected species (see C5)

· Correspondence with US Fish and Wildlife Service and/or National Marine Fisheries Service (see C5)

· Natural Resources Conservation Service determination of Prime Farmland, Form AD-1006, if applicable (see C6)

· Phase I and II Environmental Site Assessment (seeC8)

· Sole Source Aquifer review by US Environmental Protection Agency, if applicable (see C9)

· Other federal, state and local environmental permits (see C16)

· Copies of public notices, public hearing minutes, etc. (see C17)

*EDA Environmental Narrative Requirements*

2

The applicant represents and certifies that it has used due diligence to determine that the description of the project site described herein is accurate with respect to the presence or absence of contamination from toxic and hazardous substances.  The term “site” includes the entire scope of the project, including future phases of the project and all areas where construction will occur.

1. Is the site currently, or has it in the past 50 years, been used for any of the following operations or activities:

a. Generation of hazardous substances or waste?

		______  Yes  ______  No  

b. Treatment, storage (temporary or permanent), or disposal of solid or hazardous substances or waste?

	______  Yes  ______  No  

c. Storage of petroleum products?

	______  Yes  ______  No  

d. Used/waste oil storage or reclamation units?

	______  Yes  ______  No  

e. Research or testing laboratory?

	______  Yes  ______  No  

f. Ordinance research, testing, production, use, or storage?

	______  Yes  ______  No  

g. Chemical manufacturing or storage?

	______  Yes  ______  No  

h. Weapons or ammunition training, use, or testing?

	______  Yes  ______  No  

i. Iron works/foundry?

	______  Yes  ______  No  

j. Railroad yard?

	______  Yes  ______  No  

k. Industrial or manufacturing operation?

	______  Yes  ______  No

If any of the above operations ever occurred at the site, and if appropriate cleanup or other mitigation actions were performed in accordance with the local, State, and federal laws, please attach documentation of these actions.

2. Do wells draw from an underlying aquifer to provide the local domestic water supply?

	______  Yes  ______  No

3. Has a federal, State, or local regulatory authority ever conducted an environmental assessment, environmental impact statement, or a preliminary assessment/site inspection, or similar environmental surveyor inspection report at the site?  If yes, please list here and attach copies of these reports or results.

	______  Yes  ______  No

1) _______________________________________________________________________________

	2) _______________________________________________________________________________

	3) _______________________________________________________________________________

	4) _______________________________________________________________________________

	5) _______________________________________________________________________________

4. Have any environmental or OSHA citations or notices of violation been issued to a facility at the site? If yes, please attach copies.

		______  Yes  ______  No

5. Have any unauthorized releases of hazardous substances occurred at any facility at the site which resulted in notification of the EPA’s National Response Center?

		______  Yes  ______  No

6. Is any material containing asbestos or lead paint located at the site?  If yes, please attach information concerning State and federal regulatory compliance.

		______  Yes  ______  No

7. Is there any equipment (electrical transformers, etc.) containing polychlorinated biphenyls (PCB) on the site?  If yes, please attach a description of the equipment.

		______  Yes  ______  No

8. Are there underground or above ground storage tanks on the site?  If yes, please attach a detailed description, including the number of underground storage tanks on the site, whether the tanks have been inspected (or removed) and the results of such inspections.

		______  Yes  ______  No

9. Has the site been tested for radon?  If yes, please attach results.

		______  Yes  ______  No

10. Have there been, or are there now any environmental investigations by federal, State or local government agencies that could affect the site in question?  If yes, please attach available information. 

	______  Yes  ______   No

The applicant acknowledges that this certification regarding hazardous substances and/or waste is a material representation of fact upon which EDA relies when making and executing an award.  EDA reserves the right to terminate any award made in conjunction with the representations contained herein if, at any time during the useful life of the project, EDA becomes aware of the presence of hazardous materials or waste at the site, or that hazardous materials or waste have been inappropriately handled thereon.

Further, if it is determined at any time that the presence of hazardous materials or waste, or handling thereof, has been misrepresented, EDA may pursue other available legal remedies against the applicant.

__________________________________________________________________________________

Applicant’s Name

__________________________________________________________________________________

Name and Title of Applicant’s Authorized Representative

__________________________________________________________________________________

Signature of Applicant’s Authorized Representative				 	Date

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