-2- <br />added to other past, present, and reasonably foreseeable future actions, is most likely significant, <br />given their overall imperiled status. Notwithstanding the proposed implementing procedures, a <br />programmatic NEPA document might be the most effective and efficient method for establishing <br />best management practices for individual projects, reducing the burden to individual applicants, <br />and addressing cumulative impacts. <br />Categorical Exclusions <br />The Department has identified 13 of the proposed categorical exclusions (A-6, A-7, A-8, A-9, A- <br />10, A-11, A-12, A-13, A-14 A-15, A-16, A-17, and A-19) as having the potential to significantly <br />affect wildlife and the biological environment. Given this potential, we want to underscore the <br />importance of our comments on FirstNet's procedural. guidance under Environmental Review <br />and Consultation Requirements for NEPA Reviews and its list of extraordinary circumstances in <br />Appendix D. <br />Environmental Review and Consultation Requirements for NEPA Reviews <br />To ensure there are no potentially significant impacts on birds from projects that may otherwise <br />be categorically excluded, the Department recommends including the Migratory Bird Treaty Act <br />and the Bald and Golden Eagle Protection Act to the list of requirements in this section. <br />Extraordinary Circumstances <br />To avoid potentially significant impacts on birds from projects that may otherwise be <br />categorically excluded, the Department recommends including species covered under the <br />Migratory Bird Treaty Act and the Bald and Golden Eagle Protection Act to the list of <br />environmentally sensitive resources. Additionally, adding important resources to migratory birds <br />such as sites in the Western Hemisphere Shorebird Reserve Network and Audubon Important <br />Bird Areas to the paragraph on areas having special designation or recognition would help ensure <br />their consideration when contemplating use of a categorical exclusion. <br />Developing the Purpose and Need <br />The Department recommends inclusion of language that would ensure consideration of all other <br />authorities to which NEPA is supplemental as opposed to simply the FirstNet mission. As <br />currently written, the procedures are limited to ensuring the purpose and need considers the <br />FirstNet mission. If strictly applied, this approach would severely limit the range of reasonable <br />alternatives, and likely preclude consideration of,more environmentally benign locations or. <br /> <br />construction prat ucc <br />Environmental Review Process., Apply XEPA Early in the Process, Where Action is by <br />Non-Federal Entity <br />The Department recommends that FirstNet be required to coordinate with federal agencies <br />having jurisdiction by law or special expertise on construction and lighting of its network of <br />towers. <br />