COFFIN, Circuit Judge.
In this appeal we consider the interaction of two federal statutes—the Federal Property and Administrative Services of Act of 1949 ("FPAS"), 40 U.S.C. §§ 471 et seq. and the National Environmental Policy Act of 1969 ("NEPA"), 42 U.S.C. §§ 4321 et seq. At issue are certain federally owned properties in Rhode Island,
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