NOAA Environmental Project Management Policy

1.1 In order to maintain uniformity throughout the National Oceanic and Atmospheric Administration's (NOAA) environmental compliance offices and to comply with applicable laws and regulations, the NOAA Environmental Compliance Staff (ECS) in headquarters will maintain a master project database which will include all environmental compliance projects required by NOAA facilities.

1.2 The NOAA master project database will include synoptic information and priority rankings for all NOAA environmental compliance projects. It will support the development of the environmental compliance portion of NOAA's budgets, spending plans, and annual financial statements.

1.3 Electronic methods will be used to maximum extent possible in maintaining, sharing, and transferring the master project database.

1.4 New and updated Federal agency FEDPLAN submissions are due at EPA Headquarters on September 1st of each year. NOAA is committed to providing a timely submission of its project data.

2.0 Definitions

2.1 Environmental cost estimates within NOAA will be determined using direct methods whenever possible, and through indirect methods when necessary.

2.1.1 Direct methods will be used according to the following order of preference:

Solicited estimates from reputable vendors or contractors for specific or grouped activities
Approved NOAA cost-estimating software (RACER or COSTPRO)
Detailed "bottom-up" estimates of the amount of labor, equipment, and materials and their associated unit costs.
Standardized published references (such as "Means").

2.1.2 Indirect methods rely on the expertise of the estimator and extrapolation from analogous data.

2.1.3 A simple statement will accompany the cost estimate stating why the particular technique used was considered preferable.

2.2 Discovery as used in this document shall be defined as the date that the government accepts the results of an observation, survey, audit, or inspection. Acceptance can be agreement with preliminary results as being indisputable. The receipt of a final survey, audit, or inspection report will always constitute discovery if the government has not previously agreed to preliminary results.

2.3 NOAA considers a project complete from an financial environmental liability perspective when the work has been completed and the receipt of contracted goods or services has been certified for payment.

2.4 Under Executive Order 12088, Federal agencies are required to submit environmental plans to the Environmental Protection Agency (EPA) which reviews and analyzes the plans and then forwards the analysis to the Office of Management and Budget. The process of submitting, reviewing, and analyzing agency plans is referred to as the FEDPLAN process (previously referred to as the A-106 process). The primary objective of FEDPLAN is to provide a mechanism for characterizing environmental activities, establishing priorities, and identifying the resources needed to sustain compliance with environmental requirements. At a minimum, NOAA prepares FEDPLAN forms for all projects contained in its master database, with the exception of any ship-related projects. Consistent with the practice of other Federal maritime agencies, ships are not considered facilities and are not reported in the FEDPLAN process. Projects which will be completed during the fiscal year and will not continue in to the next fiscal year need not have a FEDPLAN form prepared and submitted. Activities which occur on a regular basis such as training and waste disposal are not included on the master database and do not require submission of a FEDPLAN form.

3.0 Background

3.1 Discovery: NOAA environmental compliance projects are discovered by various means, including environmental site audits, environmental surveys, self inspections, external inspections, regulatory inspections, and informal observations. Regardless of how a project is identified, it is important that it be considered for inclusion in the NOAA master project database.

3.2 Prompt Corrective Action: Some environmental compliance projects either have no associated cost or can be corrected with available funding. Such projects should be completed promptly and do not require further action. However, many projects either cannot be funded immediately or must be funded from a source other than the facility at which the project exists. These projects must be documented and entered into the master project database, regardless of the funding source or the fiscal year of anticipated funding.

3.3 Examples:

3.3.1 Attachment 1 outlines the timing, actions, and products at each level of responsibility within NOAA necessary to support the master project database.

3.3.2 Attachment 2 presents an example of the NOAA process.

4.0 Procedures

4.1 Line Office Role:

4.1.1 The process begins with the completion of a "Project Prospectus Sheet" (see Attachment 3) by the Line Office representative (as designated). This form should be completed within 30 days of "discovery" of an unfunded environmental project. The Project Prospectus Sheet form is available on NOAA's environmental compliance web site.

4.1.2 The Line Office representative should estimate the cost of the project, indicate the rationale supporting the estimate, and include it on the Project Prospectus Sheet.

4.1.3 The Project Prospectus Sheet is submitted to the facility's Regional Environmental Compliance Officer (RECO).

4.2 RECO Role:

4.2.1 Within 30 days of receiving a Project Prospectus Sheet, a RECO will validate the project described as a legitimate environmental compliance project and insure that an appropriate cost estimate is attached to the project.

4.2.2 The RECO will determine if the project imposes a financial environmental liability on NOAA (see Attachment 4).

4.2.3 Project Prospectus Sheets, cost estimates, and other data pertinent to a particular facility's environmental compliance projects will be maintained by the RECO in project files. A form similar to the Project Validation Checklist (see Attachment 7) is recommended for attachment to the front cover of the file to track quarterly (see paragraph 4.5) and semiannual (see paragraph 4.6) reviews.

4.2.4 All projects determined to be financial environmental liabilities shall be subject to the criteria specified on the Environmental Project Liability Checklist (see Attachment 5). The checklist shall be completed by the RECO for each project and maintained with the data specific to that project. All financial environmental liability project files shall be distinctively marked to facilitate ease of identification.

4.2.5 All environmental project data will then be summarized and submitted by the RECO to the ECS headquarters (HQ) for inclusion in the master project list database.

4.2.6 Simultaneous with the development and submission of the Project Prospectus Sheet, the RECO will complete and submit a FEDPLAN form. NOAA uses its internal directions for "Agency A-106 Input Form, Federal Agency Environmental Management, Program Planning - Project Report" dated August 22, 1995, and revised August 5, 1996, for completing the FEDPLAN forms. Additional information is available in EPA 300-B-95-001, "Federal Agency Environmental Management Program Planning Guidance," dated October 1994.

4.3 Headquarters (HQ) Role:

4.3.1 HQ will maintain NOAA's master project database. Attachment 6 describes the contents of the project database.

4.3.2 HQ will validate project and FEDPLAN submissions by reviewing the submitted data for complete entry. The submitted project will be compared to other projects submitted for the same facility to ensure that it represents work not previously described.

4.3.3 HQ will assign project numbers to all validated submissions and update the master project database accordingly.

4.3.4 HQ will be responsible for coordinating complete reconciliation of the master project database and any lists, files, or other information held in the field, and for using the project data in supporting the annual budget submission

4.4 Exceptions:

4.4.1 Health or Safety Threats: If a "discovered" environmental project presents an immediate threat to the health or safety of individuals or to the environment, the process of Project Prospectus Sheet preparation, cost estimate preparation, project validation, and entry onto NOAA's master project list database shall be expedited such that the entire process is completed in less than 15 days.

4.4.2 End-of-Year Discoveries:

4.4.2.1 During the last 60 days of the fiscal year, any "discovery" of an unfunded environmental project shall be considered for its possible inclusion as a financial environmental liability.

4.4.2.2 If the project is determined to be a financial environmental liability, a cost estimate will be prepared to determine if it exceeds the NOAA threshold for accrual.

4.4.2.3 If the financial environmental liability exceeds the NOAA threshold for accrual, the process of Project Prospectus Sheet preparation, cost estimate preparation, project validation, and entry onto NOAA's master project list database shall be expedited such that any project qualifying for accrual on the annual NOAA Financial Statement prior to the last 15 days of the fiscal year shall be recognized and properly reported.

4.5 Quarterly Reviews:

4.5.1 Once a project has been included in NOAA's master project database of environmental projects, Line Office representatives should review those projects applicable to their facility on a quarterly basis. This review will validate that those projects are still required and that their scope remains accurately presented.

4.5.2 The appropriate RECO will coordinate and assist in this review and validation.

4.5.3 Each RECO will review and update the project list and FEDPLAN forms for all projects designated for his or her region of responsibility and forward the results of that review to HQ.

4.6 Semiannual Reviews:

4.6.1 On a semiannual basis, the RECOs will similarly review and validate the cost estimates and forward the results to HQ. For those estimates where there is no change, the RECO shall initial and date the verified cost estimate.

4.6.2 The project list validations of paragraphs 4.4.3 and 4.5.1 will become part of the HQ-coordinated master project database reconciliation discussed in paragraph 4.3.3.

4.7 Project Removal or Reduction:

4.7.1 A project is recommended for removal from the master project database when the work has been completed and the receipt of contracted goods or services has been certified for payment.

4.7.1.1 For financial environmental liabilities:

4.7.1.1.1 The RECO shall make this recommendation to headquarters immediately upon meeting the criteria of paragraph 4.7.1.

4.7.1.1.2 Recommendations for removal will be validated and completed within 7 days of receipt at HQ.

4.7.1.2 For other than financial environmental liabilities (completion, duplicate entry, overtaken by events, etc.), recommendations for removal will be made by the RECO, validated at HQ, and entered on the master project database no less than quarterly.

4.7.2 Large projects may be subject to payments for work progress and may extend over many months or even years. Although such projects are subject to the requirements of paragraph 4.7.1, the liability imposed by these projects must be reduced periodically to reflect the progress payments made.

4.7.2.1 For all environmental liabilities, progress payments shall be reported by the RECO semiannually (in conjunction with cost estimate verification, paragraph 4.6.1), validated at HQ, and entered on the master project database.

4.7.2.2 The reduction of an environmental project's liability to reflect progress payments shall be carefully coordinated with the servicing finance office to insure that liabilities are not double counted.

4.7.2.2.1 The original liability estimate for a given project number will be reduced by the sum of all accruals and disbursements related to that project number during the reporting period.

4.7.2.2.2 Only the difference between the original liability estimate and the total of the accruals or disbursements made shall be posted on NOAA's annual financial statements.

4.7.2.3 Although reduction of the liability associated with an environmental project prior to certification of successful completion by a regulating agency runs a risk that such certification will not be forthcoming, this risk is considered remote and not necessary for estimating.

4.8 Annual Processes:

4.8.1 At the end of each fiscal year, HQ will save and store the validated and updated master database as a separate file for historic reference.

4.8.2 Also at the end of each fiscal year, HQ will transfer those projects completed during the year to a separate database comprised only of completed environmental compliance projects.

4.8.3 The validated and updated master database, having had the completed projects removed, will form the initial master project database for the new fiscal year.

4.8.4 At the end of each fiscal year, HQ will provide a summary of NOAA's financial environmental liabilities to NOAA's Chief Financial Officer/Chief Administrative Officer. Any disclosures necessary to clarify the financial environmental liabilities will be coordinated by HQ.

4.8.5 The master database, as supplemented with information provided by the RECOs, will be used to generate NOAA's annual FEDPLAN submission.

4.9 Database Protocol:

4.9.1 The master project database maintained by HQ is the only authorized listing of NOAA environmental compliance projects.

4.9.2 Other specially tailored databases are permissible at the RECO or Line Office designee level, but they MUST match exactly the environmental projects contained on the master project database for that region or facility.

4.9.3 Any differences in project listings must be either reconciled for inclusion on or removal from the master project database, or removed from or added to the tailored data base.

4.10 Control: The point of contact for the NOAA environmental project management shall be the Deputy Chief, Environmental Compliance Staff.



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