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Source: STANDARD HANDBOOK OF ENVIRONMENTAL ENGINEERING

CHAPTER 10

ENVIRONMENTAL ASSESSMENT
Lloyd V. Urban, Ph.D., P .E. R. K. Jain, Ph.D., P .E.

During the decision-making process and development of a project, the environmental engineer should incorporate considerations of the proposed actions on the total environment: air, water, and land. Also, the primary and secondary impacts on neighbors and the general public are important. In the United States, the National Environmental Policy Act (1) and subsequent regulations form the basis for environmental assessments (EAs) and environmental impact statements (EISs). An overview of the first twenty-five years of these regulations is included in this chapter. The environmental assessment process documents the awareness of the owner, designer, and public of the potential impacts resulting from the construction any new, modified, or expanded facilities. The documentation is concise, and the degree of detail varies with the size and location of the project. The outcome of the EA process will be a regulatory agency finding of no significant impact or a requirement for an EIS. An environmental impact statement documents in great detail real and potential direct and secondary impacts of the proposed project. Alternative evaluations and mitigation actions may be included. Public participation is key in the EA/EIS process.*

LEGISLATIVE REQUIREMENTS
The environmental assessment process is couched in federal law, with auxiliary requirements evolved through executive orders, regulations, agency response, state legal requirements, and other legal mechanisms. The principal federal legislation is the National Environmental Policy Act of 1969 (PL 91-190), typically referred to as NEPA (see Figure 10.1). When compared with most environmental legislation, NEPA has four distinguishing features (3). 1. NEPA is a policy act setting a course for public action and is not a regulatory statute. 2. NEPAs goals and principles are not self-enforcing but require action by Congress and the President. Observance of the policy intent is mandated by the environmental impact statement and is enforceable through the courts. 3. NEPA is integrative, crossing and affecting a broad range of public issueseconomic, demographic, ecological, aesthetic, and ethical. 4. NEPA is oriented toward the future by recognizing the worldwide and long-range character of environmental problems.
*Material for portions of this chapter has been drawn from Ref. 2. 10.1 Downloaded from Digital Engineering Library @ McGraw-Hill (www.digitalengineeringlibrary.com) Copyright 2004 The McGraw-Hill Companies. All rights reserved. Any use is subject to the Terms of Use as given at the website.

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PURPOSE Sec. 2. The purposes of this Act are: to declare a national policy which will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation; and to establish a Council on Environmental Quality. Title I Declaration of National Environmental Policy Sec. 101. (a) The Congress, recognizing the profound impact of mans activity on the interrelations of all components of the natural environment, particularly the profound influences of population growth, high-density urbanization, industrial expansion, resource exploitation, and new and expanding technological advances and recognizing further the critical importance of restoring and maintaining environmental quality to the overall welfare and development of man, declares that it is the continuing policy of the Federal Government, in cooperation with State and local governments, and other concerned public and private organizations, to use all practicable means and measures, including financial and technical assistance, in a manner calculated to foster and promote the general welfare, to create and maintain conditions under which man and nature can exist in productive harmony, and fulfill the social, economic, and other requirements of present and future generations of Americans. (b) In order to carry out the policy set forth in this Act, it is the continuing responsibility of the Federal Government to use all practicable means, consistent with other essential considerations of national policy, to improve and coordinate Federal plans, functions, programs, and resources to the end that the Nation may (1) fulfill the responsibilities of each generation as trustee of the environment for succeeding generations; (2) assure for all Americans safe, healthful, productive, and esthetically and culturally pleasing surroundings; (3) attain the widest range of beneficial uses of the environment without degradation, risk to health or safety, or other undesirable and unintended consequences; (4) preserve important historic, cultural, and natural aspects of our national heritage, and maintain, wherever possible, an environment which supports diversity and variety of individual choice; (5) achieve a balance between population and resource use which will permit high standards of living and a wide sharing of lifes amenities; and (6) enhance the quality of renewable resources and approach the maximum attainable recycling of depletable resources. (c) The Congress recognizes that each person should enjoy a healthful environment and that each person has a responsibility to contribute to the preservation and enhancement of the environment. Sec. 102. The Congress authorizes and directs that, to the fullest extent possible: (1) the policies, regulations, and public laws of the United States shall be interpreted and administrated in accordance with the policies set forth in this Act, and (2) all agencies of the Federal Government shall
FIGURE 10.1 The National Environmental Policy ActPublic Law 91-190 (as amended by PL 94-83).

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(A) utilize a systematic, interdisciplinary approach which will ensure the integrated use of the natural and social sciences and the environmental design arts in planning and in decision making which may have an impact on mans environment; (B) identify and develop methods and procedures, in consultation with the Council on Environmental Quality established by title II of this Act, which will ensure that presently unquantified environmental amenities and values may be given appropriate consideration in decision-making along with economic and technical considerations; (C) include in every recommendation or report on proposals for legislation and other major Federal actions significantly affecting the quality of the human environment, a detailed statement by the responsible official on (i) the environmental impact of the proposed action, (ii) any adverse environmental effects which cannot be avoided should the proposal be implemented, (iii) alternatives to the proposed action, (iv) the relationship between local short-term uses of mans environment and the maintenance and enhancement of long-term productivity, and (v) any irreversible and irretrievable commitments of resources which would be involved in the proposed action should it be implemented. Prior to making any detailed statement, the responsible Federal official shall consult with and obtain the comments of any Federal agency which has jurisdiction by law or special expertise with respect to any environmental impact involved. Copies of such statement and the comments and views of the appropriate Federal, State, and local agencies, which are authorized to develop and enforce environmental standards, shall be made available to the President, the Council on Environmental Quality and to the public as provided by section 552 of title 5, United States Code, and shall accompany the proposal through the existing agency review processes. (D) Any detailed statement required under subparagraph (C) after January 1, 1970, for any major Federal action funded under a program of grants to States shall not be deemed to be legally insufficient solely by reason of having been prepared by a State agency or official, if: (i) the State agency official has statewide jurisdiction and has the responsibility for such action, (ii) the responsible Federal official furnishes guidance and participates in such preparation. (iii) the responsible Federal official independently evaluates such statement prior to its approval and adoption, and (iv) after January 1,1976, the responsible Federal official provides early notification to, and solicits the views of, any other State or any Federal land management entity of any action or any alternative thereto which may have significant impacts upon such State or affected Federal land management entity and, if there is any disagreement on such impacts, prepared a written assessment of such impacts and views for incorporation into such detailed statement. The procedures in this subparagraph shall not relieve the Federal official of his responsibilities for the scope, objectivity, and content of the entire statement or of any other responsibility under this Act; and further, this subparagraph does not affect the legal sufficiency of statements prepared by State agencies with less than statewide jurisdiction. (E) study, develop, and describe appropriate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available resources;
FIGURE 10.1 The National Environmental Policy ActPublic Law 91-190 (as amended by PL 94-83) (continued).

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(F) recognize the worldwide and long-range character of environmental problems and, where consistent with the foreign policy of the United States, lend appropriate support to initiatives, resolutions, and programs designed to maximize international cooperation in anticipating and preventing a decline in the quality of mankinds world environment; (G) make available to States, counties, municipalities, institutions, and individuals, advice and information useful in restoring, maintaining and enhancing the quality of the environment; (H) initiate and utilize ecological information in the planning and development of resource-oriented projects; and (I) assist the Council on Environmental Quality established by title II of this Act. Sec. 103. All agencies of the Federal Government shall review their present statutory authority, administrative regulations, and current policies and procedures for the purpose of determining whether there are any deficiencies or inconsistencies therein which prohibit full compliance with the purposes and provisions of this Act and shall propose to the President not later than July 1, 1971, such measures as may be necessary to bring their authority and policies into conformity with the intent, purposes, and procedures set forth in this Act. Sec. 104. Nothing in Section 102 or 103 shall in any way affect the specific statutory obligations of any Federal agency (1) to comply with criteria or standards of environmental quality; (2) to coordinate or consult with any other Federal or State agency, or (3) to act, or refrain from acting contingent upon the recommendations or certification of any other Federal or State agency. Sec. 105. The policies and goals set forth in this Act are supplementary to those set forth in existing authorizations of Federal agencies. Title II Council on Environmental Quality Sec. 201. The President shall transmit to the Congress annually beginning July 1, 1970, an Environmental Quality Report (hereinafter referred to as the report) which shall set forth (1) the status and condition of the major natural, manmade, or altered environmental classes of the Nation, including, but not limited to, the air, the aquatic, including marine, estuarine, and fresh water, and the terrestrial environment, including, but not limited to, the forest dryland, wetland, range, urban, suburban, and rural environment; (2) current and foreseeable trends in the quality management and utilization of such environments and the effects of those trends on the social, economic, and other requirements of the Nation; (3) the adequacy of available natural resources for fulfilling human and economic requirements of the Nation in the light of expected population pressures; (4) a review of the programs and activities (including regulatory activities) of the Federal Government, the State and local governments, and nongovernmental entities or individuals, with particular reference to their effect on the environment and on the conservation, development and utilization of natural resources; and (5) a program for remedying the deficiencies of existing programs and activities, together with recommendations for legislation. Sec. 202. There is created in the Executive Office of the President a Council on Environmental Quality (hereinafter referred to as the Council). The Council shall be composed of three members who shall be appointed by the President to serve at his pleasure, by and with the advice and consent of the Senate. The President shall designate one of the members of the Council to serve as Chairman. Each member shall be a person who as a result of his training, experience, and attainments, is exceptionally well qualified to analyze and interpret environmental trends and information of all kinds; to appraise programs and activities of the Federal Government in the light of the policy set forth in Title I of this Act; to be conscious of and responsive to
FIGURE 10.1 The National Environmental Policy ActPublic Law 91-190 (as amended by PL 94-83) (continued).

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the scientific, economic, social, esthetic, and cultural needs and interests of the Nation; and to formulate and recommend national policies to promote the improvement of the quality of the environment. Sec. 203. The Council may employ such officers and employees as may be necessary to carry out its functions under this Act. In addition, the Council may employ and fix the compensation of such experts and consultants as may be necessary for the carrying out of its functions under this Act, in accordance with section 3109 of title 5, United States Code (but without regard to the last sentence thereof). Sec. 204. It shall be the duty and function of the Council (1) to assist and advise the President in the preparation of the Environmental Quality Report required by section 201; (2) to gather timely and authoritative information concerning the conditions and trends in the quality of the environment both current and prospective, to analyze and interpret such information for the purpose of determining whether such conditions and trends are interfering, or are likely to interfere, with the achievement of the policy set forth in title I of this Act, and to compile and submit to the President studies relating to such conditions and trends; (3) to review and appraise the various programs and activities of the Federal Government in the light of the policy set forth in title I of this Act for the purpose of determining the extent to which such programs and activities are contributing to the achievement of such policy, and to make recommendations to the President with respect thereto; (4) to develop and recommend to the President national policies to foster and promote the improvement of environmental quality to meet the conservation, social, economic, health, and other requirements and goals of the Nation; (5) to conduct investigations, studies, surveys, research, and analyses relating to ecological systems and environmental quality; (6) to document and define changes in the natural environment, including the plant and animal systems, and to accumulate necessary data and other information for a continuing analysis of these changes or trends and an interpretation of their underlying causes; (7) to report at least once each year to the President on the state and condition of the environment; and (8) to make and furnish such studies, reports thereon, and recommendations with respect to matters of policy and legislation as the President may request. Sec. 205. In exercising its powers, functions, and duties under this Act, the Council shall (1) consult with the Citizens Advisory Committee on Environmental Quality established by Executive Order numbered 11472, dated May 29, 1969, and with such representatives of science, industry, agriculture, labor, conservation organizations, State and local governments, and other groups as it deems advisable; and (2) utilize, to the fullest extent possible, the services, facilities, and information (including statistical information) of public and private agencies and organizations, and individuals in order that duplication of effort and expense may be avoided, thus assuring that the Councils activities will not unnecessarily overlap or conflict with similar activities authorized by law and performed by established agencies. Sec. 206. Members of the Council shall serve full time and the Chairman of the Council shall be compensated at the rate provided for Level II of the Executive Schedule Pay Rates (5 U.S.C. 5313). The other members of the Council shall be compensated at the rate provided for Level IV of the Executive Schedule Pay Rates (5 U.S.C. 5315). Sec. 207. There are authorized to be appropriated to carry out the provisions of this Act not to exceed $300,000 for fiscal year 1970, $700,000 for fiscal year 1971, and $1,000,000 for each fiscal year thereafter.
FIGURE 10.1 The National Environmental Policy ActPublic Law 91-190 (as amended by PL 94-83) (continued).

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National Environmental Policy Act The enactment of NEPA added a new dimension to the planning and decision-making process of federal and state agencies in the United States. NEPA requires federal agencies to assess the environmental impact of implementing their major programs and actions as early in the planning process as possible and, in all cases, prior to the undertaking of the project or the action (1). For those projects or actions that are either expected to have a significant effect on the quality of the human environment or are expected to be controversial on environmental grounds, the proponent agency is required to file a formal environmental impact statement (EIS) (1). This environmental assessment process (also referred to as the NEPA process) has had a profound effect on the way major projects with significant federal agency involvement are planned and implemented. In order to incorporate environmental concerns into the decision-making process, the environmental impact analysis of major undertakings is a logical first step. In the normal market exchange of goods and services, these environmental concerns cannot be, and are not, properly accounted for. Consequently, in the United States, provisions of NEPA were designed to create a vehicle for considering environmental amenities consistent with other national needs, such as economic development, in a systematic manner. This systematic procedure is called the environmental assessment process, and it is documented as an environmental assessment or an impact statement. Purpose. The main purposes of this legislation, as set forth in the act, are
To declare a national policy which will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation; and to establish a Council on Environmental Quality (1).

There are two titles under the Act: Title I, Declaration of National Environmental Policy, and Title II, Council on Environmental Quality (CEQ). Title I. Title I sets forth the national policy on restoration and protection of environmental quality. The relevant sections under this title are summarized as follows: Section 101. Requirements of Section 101 are of a substantive nature. Under this section, the federal government has a continuing responsibility consistent with other essential considerations of national policy to minimize adverse environmental impact and to preserve and enhance the environment as a result of implementing federal plans and programs. Section 102. Section 102 requirements are of a procedural nature. Under this section, the proponent federal agency is required to make a full and adequate analysis of all environmental effects of implementing its programs or actions. In Section 102(1), Congress directs that policies, regulations, and public laws shall be interpreted and administered in accordance with the policies of NEPA. Section 102(2) directs all federal agencies to follow a series of steps to ensure that the goals of the act will be met. The first requirement is found in Section 102(2)(A), where it is required that a systematic and interdisciplinary approach be used to ensure the integrated use of social, natural, and environmental sciences in planning and decision making. Section 102(2)(B) states that federal agencies shall, in consultation with CEQ, identify and develop procedures and methods such that presently unquantified environmental amenities and values may be given appropriate consideration in decision-making along with traditional economic and technical considerations. Section 102(2)(C) sets forth the requirements and guidelines for preparing environmental impact statements. This section requires all federal agencies to include in every recommendation or report on legislative

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proposals and other major federal actions significantly affecting the quality of the human environment, a detailed statement by the responsible official covering the following elements: 1. 2. 3. 4. The environmental impact of the proposed actions Any adverse environmental effects that cannot be avoided should the proposal be implemented The alternatives to the proposed action The relationship between local short-term uses of the environment and the maintenance and enhancement of long-term productivity 5. Any irreversible and irretrievable commitments of resources that would be involved in the proposed action should it be implemented Specific EIS format, coordination, and instructions for approval and review hierarchy are established by CEQ regulations (4) and each federal agency. Persons preparing an EIS should follow the instructions of the appropriate organization. Section 103. This section requires all federal agencies to review their regulations and procedures for the purpose of determining whether there are any deficiencies or inconsistencies therein which prohibit full compliance with the purposes and provisions of this Act and [they] shall propose to the President . . . such measures as may be necessary to bring their authority and policies into conformity with . . . this Act. Title II. Title II establishes the CEQ as an environmental advisory body for the executive office. In addition, the President is required to submit to the Congress an annual Environmental Quality Report. This yearly summary sets forth: (1) the status and condition of the major natural, man-made, or altered environmental classes of the nation; (2) current and foreseeable trends in the quality, management, and utilization of such environments and socioeconomic impacts of these trends; (3) the adequacy of available natural resources; (4) a review of the effect of governmental and nongovernmental activities on the environment and natural resources; and (5) a program for remedying the deficiencies and recommending appropriate legislation. The CEQ is composed of three members who are appointed by the President with the advice and consent of the Senate. The President designates one of the members of the CEQ to serve as chairman. In addition, the CEQ employs environmental lawyers, professional scientists, and other employees to carry out its functions as required under NEPA. Duties and functions of CEQ may be summarized as follows: 1. Assist and advise the President in the preparation of the Environmental Quality Report as required by NEPA 2. Gather, analyze, and interpret, on a timely basis, information concerning the conditions and trends in the quality of the environment, both current and prospective 3. Review and appraise the various programs and activities of the federal government in light of the policy of environmental protection and enhancement, as set forth under Title I of NEPA 4. Develop and recommend to the President national policies to foster and promote improvement of environmental quality to meet many goals of the nation 5. Conduct research and investigations related to ecological systems and environmental quality 6. Accumulate necessary data and other information for a continuing analysis of changes in the national environment and interpretation of the underlying causes 7. Report at least once a year to the President on the state and condition of the environment 8. Conduct such studies and furnish such reports and recommendations as the President may request A significant feature to note is that both the charter assigned and the responsibilities delegated to CEQ are quite extensive. However, although CEQ does not have any regulatory or policing responsibilities, it is highly influential in its advisory capacity.

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CEQ REGULATIONS AND ENVIRONMENTAL DOCUMENTS


In the United States, the CEQ is responsible for overseeing federal efforts to comply with NEPA. In 1970, the council issued guidelines for the preparation of EISs under Executive Order 11514 (1970). Until recently, the 1973 revised guidelines were in effect. But under Executive Order 11991, the President directed the CEQ to issue regulations to supersede the 1973 guidelines. Issued in 1977, the regulations became effective on July 30, 1979. In the executive order, the President directed that the regulations should be (5):
Designed to make the Environmental Impact Statement process more useful to decision-makers and the public and to reduce paperwork and the accumulation of extraneous background data, in order to emphasize the need to focus on real environmental issues and alternatives.

The new regulations were developed to achieve three principal goals: reduction of paperwork; reduction of delays; and, most importantly, production of better decisions which further the national policy to protect and enhance the quality of the human environment. These regulations are designed to ensure that the action-forcing procedures of Section 102(2) of NEPA are used by agencies to fulfill the requirement of the congressionally mandated policy set forth in Section 101 of the act. Since these regulations are applied uniformly to all federal agencies, this will minimize misinterpretation, redundancy, and misapplication. Also, time required to learn these regulations and review these documents will be minimized. Various documents required to comply with the NEPA process and CEQ regulations are described herein. Environmental Documents The CEQ regulations require that a number of environmental documents be prepared during the project planning and development process. These documents include the following (3): 1. 2. 3. 4. 5. 6. Notice of intent Environmental assessment Draft environmental impact statement Final environmental impact statement Finding of no significant impact Record of decision

This section will identify each of these documents and discuss briefly the differences among them. Notice of Intent. This refers to a notice that an EIS will be prepared and considered. This notice is published in the Federal Register, and all timing for document processing is tied to this publication date. This notice shall briefly 1. Describe the proposed action and possible alternatives 2. Describe the agencys proposed scoping process, including whether, when, and where any scoping meeting will be held 3. State the name and address of the person within the agency who can answer questions about the proposed action and the EIS Environmental Assessment. An environmental assessment is also referred to as an environmental impact assessment or EIA. This is a concise public document prepared by a federal agency that serves to

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1. Provide sufficient analysis for determining whether an EIS or a finding of no significant impact is needed 2. Aid in the agencys compliance with the NEPA when no EIS is necessary 3. Facilitate preparation of an EIS when one is necessary. Its format is similar to that of an EIS, except that its summary, lists of preparers, and appendix may be eliminated, and the level of detail required is less than that of the EIS. In the long run, it would be desirable to use the same general format for an EIA as is used for an EIS. Draft Environmental Impact Statement. The draft EIS (DEIS) is a detailed written statement required by Section 102(2)(C) of NEPA. The DEIS undergoes a formal review process outlined by CEQ regulations. Final Environmental Impact Statement. The final EIS is a detailed written statement as required by Section 102(2)(C) of NEPA, and it incorporates the results of a formal review of the draft EIS. Finding of No Significant Impact. This document, referred to as a FONSI, is prepared by a federal agency and briefly presents the reasons why an action, not otherwise excluded, will not have a significant effect on the human environment and for which an EIS, therefore, would not be prepared. It should include either the environmental assessment or its summary and other related environmental documents. The relationship between the documents discussed in the preceding sections is described in Figure 10.2.

FIGURE 10.2 EA/EIS and FONSI relationship.

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Record of Decision. At the time of its decision or, if appropriate, its recommendation to Congress, each agency should prepare a concise public record of decision. This record may be integrated into any other documentation that is prepared by the agency for a similar purpose. This record should include 1. A statement of what the decision was. 2. Identification of all alternatives considered by the agency in reaching its decision, including specification of alternatives that were considered environmentally preferable. An agency may discuss preferences among alternatives based on factors related to economic and technical considerations and to agency statutory missions. The agency should identify and discuss all such factors, including any other essential considerations of national policy that were balanced by the agency in making its decision; the agency should state how much these considerations entered into the decision-making process. 3. A statement of what practicable means to mitigate environmental damage under the selected alternatives were included in the implementation of the action. If some practicable mitigation techniques were not included, the reasons for their exclusion should be stated. A monitoring and enforcement program designed to carry out the mitigation techniques identified should be summarized. EIS Format and Content The CEQ has provided a streamlined standard format for all agencies to follow unless the agency has determined that there is a compelling reason to do otherwise. An outline for the CEQ-prescribed EIS format and content is provided in Figure 10.3. The following discussion outlines the content of each section. Cover Sheet. The cover sheet should not exceed one page. Information required for the cover sheet is outlined in Figure 10.3. An example cover sheet is also included in Figure 10.4. Summary. Each EIS is required to contain a summary that adequately and accurately summarizes the statement; it is suggested that the EIS format be used for organizing the summary. The summary should stress major conclusions, areas of controversy (including issues raised by agencies and the public), and the issues to be resolved (including the choice among alternatives). In order to stress and highlight these points, it might be desirable to cover these topics as distinct subsections of the summary. Table of Contents. Extra effort in organizing a table of contents can help the reviewers of the document considerably. All headings and subheadings should be identified with the appropriate page numbers. Lists of figures and tables with appropriate page numbers can also be included. While it is common practice to define each abbreviation, scientific notation, or Greek symbol used for the first time in the text, many readers reviewing or analyzing the document have difficulty with these abbreviations and symbols because they are not familiar with them. It is suggested that these items be listed and defined as an inclusion in the table of contents section. Purpose and Need. The ElS should contain a brief description of the need or requirement to which this action is responding. The purpose or objective for the action should relate directly to the need or requirement discussed. Alternatives, Including the Proposed Action. CEQ considers this section to be the heart of the ElS. Some information for this section may have to be prepared after other sections are completed (for example, Section 7). In fact, many parts of the EIS are interdependent, and the preparers may have to work on more than one section at a time and make changes as different sections are analyzed and completed. A general outline for this section is given in Figure 10.3. In describing the various alternatives consid-

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COVER SHEET

SUMMARY (NTE 15 pages). (NTE = not to exceed)

TABLE OF CONTENTS (suggest NTE 6 pages).

PURPOSE OF AND NEED FOR THE ACTION (sec 47, NTE 150 pages, 300 in special cases).

ALTERNATIVES INCLUDING THE PROPOSED ACTION

alternatives not under lead agency

AFFECTED ENVIRONMENT

ENVIRONMENTAL CONSEQUENCES

Native American

LIST OF PREPARERS (NTE 2 pages).

AGENCIES, ORGANIZATIONS, AND PERSONS TO WHOM COPIES SENT APPENDIX

INDEX

FIGURE 10.3 Outline for CEQ-prescribed EIS content.

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FIGURE 10.4 Example EIS cover sheet.

ered, all alternatives not under lead agency jurisdiction should also be discussed. Also, the alternative of no action is specifically required to be analyzed. Since those alternatives which are considered by the decision maker are supposed to be included in the EIS, there might be some difficulty in providing sufficient detail regarding an alternative which is not under the jurisdiction of the lead agency decision maker. Usually, there are many alternatives which are considered initially, but not explored vigorously. Reasons for eliminating such alternatives must be included. From the information developed in Section 7 (Environmental Consequences), environmental consequences of alternatives considered should be displayed in a comparative form. The purpose of this display is

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to sharply define the issues involved and to provide a clear basis for choosing among alternatives. The agency and public decision makers can quickly compare and analyze the alternatives from this comparative display. The agency can identify the preferred alternative or alternatives in this section unless another law prohibits the agency from expressing such a preference. Means to mitigate adverse environmental impacts can be included here; however, it would seem appropriate to include mitigation measures only for preferred alternatives. A summary of this information on mitigation measures must be included in the record of decision. Also, for mitigation measures to have any meaning, a plan and a framework for including these measures in the actual project or action must be developed. For the implementation of these regulations, the CEQ has required an analysis that should show how alternatives were considered and whether decisions based on these alternatives will or will not achieve the requirements of Sections 101 and 102(1) of NEPA and of other environmental laws and policies. Since the CEQ considers this section to be the heart of the EIS, it would be desirable to include this information here. Affected Environment. This section is what is commonly referred to as the environmental baseline. It is important to note that the baseline is not necessarily static. The affected environment, or the baseline, should be described succinctly, and the information included should be relevant to the impacts discussed. In the past, many EISs were prepared using verbose descriptions of the baseline; consequently, the CEQ has emphasized in its new regulations that this information be consolidated and, if necessary, other documents referenced in order to minimize EIS bulk. Environmental Consequences. This section forms the scientific and analytic basis for the comparison of alternatives included in the alternatives section. Environmental consequences or impacts to be considered should include direct, indirect, and induced impacts in the biological, physical, social, economic, and cultural environments. The discussion should include adverse environmental effects that cannot be avoided, relationships between short-term uses of the environment and the maintenance and enhancement of long-term productivity, and any irreversible or irretrievable commitments of resources that would be involved should the action be implemented. This section should not duplicate the discussion included in the alternative section. Environmental consequences resulting from the proposed action may be organized as shown in the outline (Figure 10.3). Any mitigation measures not fully covered in the discussion of alternatives may be further described here. List of Preparers. Names and qualifications (expertise, experience, professional disciplines) of persons who were primarily responsible for preparing the EIS or developing background papers or basic analysis components of the EIS should be included. Where possible, persons responsible for a particular analysis or section of the EIS should be so identified. This list of preparers will 1. Provide a basis for evaluating whether a systematic, interdisciplinary approach was used in preparing the EIS 2. Increase the accountability and professional responsibility of those who were, in fact, responsible for preparing any part of the EIS 3. Give due credit to and enhance the professional standing of the preparers Agencies, Organizations, and Persons to Whom Copies Are Sent. The list may serve as a check for both preparers and reviewers in determining the range and adequacy of assessment coordination and solicitation of comments. Index. Particularly for lengthy or complex statements, an index may facilitate the review and evaluation process. Since the indexing process can become a quite extensive undertaking, many preparers choose to omit this section in favor of expanded depth in the table of contents.

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Appendix. The appendix should not become a dumping ground for inclusion of irrelevant or unnecessary paperwork. Only the material that is prepared in support of the EIS and material substantiating analysis in the main body of the EIS should be included. It is often necessary to perform extensive computations to determine some impacts. It would be appropriate to include such analytic computations and the scientific basis for the computation in the appendix. Any material that is generally available in another document can be referenced and need not be included in the EIS. Among other things, the CEQ regulations differ in this regard from the old guidelines. The old guidelines required that the EIS document be an independent, complete document, and not require undue reference to other documents. Also, the appendix may be circulated with the EIS or be made available upon request. Processing Environmental Documents After an environmental document has been prepared, processing depends on the type of document and on specific agency requirements. General processing requirements are outlined as follows. Notice of Intent. This document should be published in the Federal Register as soon as practicable after the decision to prepare an EIS and before the scoping process. (Exception: When there is a lengthy period between the agencys decision to prepare an EIS and the time of actual preparation, the notice may be published at a reasonable time in advance of draft DEIS preparations.) Environmental Assessment. An EA is an intermediate document. If it is determined that no statement is required, then a FONSI results and the EA presents the substantiating evidence to support that conclusion. The EA or a summary is included in the FONSI. If a statement is required, the EA forms the basis for structuring the EIS. Draft ElS. Draft statements shall be filed with the EPA (Attention: Office of Federal Activities [A-104], 401 M Street SW, Washington, D.C. 20406). At the same time, they are transmitted to commenting agencies and made available to the public. EPA shall deliver one copy of each statement to the CEQ, thus satisfying the requirement of availability to the President. The EPA will publish a notice of this filing in the Federal Register and will review the document as described in a later section of this chapter. Office of Management and Budget Circular A-95, through a system of clearinghouses, provides a means of securing the views of state and local environmental agencies. After preparing a draft EIS and before preparing the final EIS, the agency should obtain comments from the following groups: Federal agencies that have jurisdiction by law or special expertise State and local agencies authorized to develop and enforce environmental standards Native American tribes, when the action affects them or their reservations Any agency that has requested the draft EIS The applicant, if the federal agency is issuing a lease, license, permit, or entitlement Public and conservation groups affected by or interested in the action Federal agencies with jurisdiction by law or special expertise with respect to any environmental impact involved are required to comment on the draft EIS. A federal agency or a cooperating agency may reply that it has no comment. In order to reduce unnecessary delays, agencies are required to provide their comments within the time period specified in the regulations. The sequence of processing activities for draft and final EIS documents is shown in Figure 10.5. Final EIS. The agency preparing the final EIS should assess and consider comments received on the draft statement both individually and collectively. The agency should take advantage of this input and make the

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agencies

FIGURE 10.5 EIS processing.

necessary changes. When the comments do not warrant further agency response, an explanation should be provided. All substantive comments received on the draft EIS should be attached to the final EIS. Voluminous comments may be summarized. If changes in response to the comments are minor, only the comments, responses, and changes made need to be circulated. In other words, there may be no need to rewrite the draft EIS; instead, the draft EIS, along with this supplement prepared in response to the comments received, would constitute the final EIS. The CEQ regulations require that the final EIS, together with comments and responses, or summaries thereof, be filed with the EPA, Office of Federal Activities, in Washington, D.C. The ElS should be made available to commenting agencies and the public at the same time it is filed with the EPA (see Figure 10.4). To comply with the requirements of making the EIS available to the President, the EPA again will deliver one copy of the statement to the CEQ. Finding of No Significant Impact. The agency should make this document available to the affected public upon request. In certain limited circumstances, which the agency may cover in its NEPA procedures, the agency should make this document available for public review (including state- and areawide clearinghouses) for 30 days before the action begins.

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Record of Decision. This document may be integrated into any other record prepared by the agency, including that required by OMB Circular A-95 (Revised), Part I, Section 6(c) and (d), and Part II, Section 5(b)(4). Specific documentation, processing, and other follow-up procedures may vary, but the record of decision must be made available to the public. Timing of Agency Action Each week, the EPA will publish a notice in the Federal Register of the EISs filed during the preceding week. The minimum time periods set forth by the CEQ should be calculated from the date of publication of this notice. No decision on the proposed action should be made or recorded by a federal agency except as follows: 1. Ninety days after publication of the notice for a draft EIS. 2. Thirty days after publication of the notice for a final EIS. However, there is an exception for those rulemaking actions where an agency may announce a preliminary decision at the same time an EIS is filed. In such cases there must be a real opportunity to alter the decision. This means that the period for appeal of the decision and the 30-day period required for the EIS process may be concurrent. An agency engaged in rulemaking under the Administrative Procedures Act or other statute for the purpose of protecting the public health or safety may waive this 30-day period. 3. The minimum 90 days required between the draft EIS and the final action (or recording of the decision) and the 30-day waiting period after the EIS may be concurrent. However, a minimum of 45 days must be provided for comments by other agencies and the public. 4. The lead agency may extend these prescribed time periods. The EPA may reduce the prescribed time periods at the request of the lead agency due to compelling reasons of national policy. Also, the EPA may extend the time periods at the request of other federal agencies (other than the lead agency) in consultation with the lead agency. The EPA is required to notify CEQ of any such extension or reduction of the time periods. There are some other restrictions as well, and these are further described in the CEQ regulations. Ordinarily, until an agency issues a record of decision, no action concerning the proposed action may be taken that would have an adverse environmental impact or limit the choice of reasonable alternatives.

PUBLIC PARTICIPATION
CEQ regulations state that agencies should make diligent efforts to involve the public in preparing and implementing their NEPA procedures. The council encourages federal agencies to use innovative techniques beyond the public hearing process to provide for effective public participation early in the planning stages of federal projects and actions. Presented in the CEQ regulations are many administrative techniques that federal agencies can use to obtain such participation (3). The extent of public involvement would naturally depend on the scope of the project. For example, in the case of an action with effects of national concern, notice should include publication in the Federal Register and notice by mail to national organizations reasonably expected to be interested in the action; in cases of actions having effects that are primarily of local concern, state- and areawide clearinghouses, as described in OMB Circular A-95, can be used. The notice of intent required in the CEQ regulations serves as an early warning or early notice system for informing the public of upcoming federal actions to which they may want to provide input. This is followed by the scoping process, which takes place early in the planning stages, into which input by federal, state,

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and local agencies and other interested persons can be provided. This input assists in determining the scope of significant issues to be addressed in the EIS. In addition, comments are specifically solicited by the federal agencies on a draft EIS, and these comments are carefully evaluated and considered in the decisionmaking process. This provides another positive vehicle for public participation. Effective Public Participation Effective public or community participation has been defined as occurring when a community acts with full information, equal access to decision-making institutions, and is able to implement its jointly articulated objectives (2). Based on this definition, several important requirements should be met to attain effective public participation. First, the public should have easy access to all project-related information. There is often considerable misinformation about the nature of most proposed projects, even when the withholding of information is not practiced deliberately. This lack of communication precludes effective citizen participation in many cases. Second, the community members must have access to the decision process. Allowing or encouraging community involvement in problem identification and discussion, without influence on the ultimate decision, is not very useful to the community or the agency. Third, for community participation to be effective, the input provided by the citizenry should result in a course of action consistent with the desires and needs of their fellow community members. The agency must have the power to act on behalf of the citizens, and the decisions must reflect the joint objectives of the agency and the community. The elements of an effective participation system are 1. Information exchange 2. Access to decision making 3. Implementation powers Various types of communication exchange provide the elements of an effective program. For a communication technique to function as a public participation tool, it must allow for citizens to become involved in decision making. This definition means that techniques that allow only one-way communication, such as newspaper articles, are not very useful. Newspaper articles may, however, be one prerequisite communication step in a public participation program that includes other forms of interaction with a well-informed public. A wide range of techniques contain some or all of the characteristics necessary for a public participation program. Public Information and Public Involvement Public information techniques and the level of public involvement vary depending upon the stage of development of the project, significance of the project to the public, and potential for environmental impacts. In the study initiation stage, public information techniques include 1. News releases, advertisements, and announcements through the news media 2. Mailings to individuals or groups 3. Information briefings to elected representatives and governmental agencies During the planning stages, information and involvement techniques include the notice of intent announcement followed by the scoping process as required by the CEQ regulations. These activities can be

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supplemented by brochures and information sheets on the project, and site visits and field trips for the interested groups. During the design stages of a construction project, and during final execution plan development of other types of projects and actions, the information techniques are more specific and are focused on the critical issues identified during the scoping process. Information and involvement techniques include 1. 2. 3. 4. Public hearings Public meetings Presentations to community groups Presentations to governmental agencies representing public interest in areas of their expertise or jurisdictional responsibility 5. Mailings to groups and individuals requesting specific information 6. Workshops and seminars 7. Focused meetings with public interest groups

Participation as a Group Member Because of the complexity of projects, reviewing and intelligently commenting on an EIS can be a difficult undertaking for an individual. Participation as a group member can provide the necessary knowledge base to comment meaningfully on an EIS and the necessary organizational strength to influence the agencys decision-making process (6). For technical aspects of the project, persons trained in the field should be consulted to assist the public interest group. General statements without proper scientific foundation are not likely to influence the agency or help the groups interests.

Benefits from an Effective Public Participation Program The catalog of reasons why decision making should not occur in a public forum, but should reside in a central locus, is extensive. Centralized decision making leads to more rapid, cost-effective, conclusive decisions, thus permitting effective and efficient leadership. The military is built on this mode of decision making. Congress is often perceived to act on issues lethargically, appearing to be inefficient and ineffective in comparison with the executive branch. However, this slow action has a distinct benefit; it provides an opportunity for diverse views to be accommodated. This perspective on the value of public participation suggests that decisions made on behalf of the public by centralized agencies can be substantially enhanced by providing channels for public input. There is a greater likelihood that more viable or innovative alternatives to a project will be identified by opening up the process to the public. Community members are well aware of their own resources, limitations (most often), and problems. The diverse perspectives of the communitys citizens provide input that could otherwise be obtained only through extensive fieldwork by the agency sponsoring the project. There is, further, the possibility that there might be a closer integration of planning and development with existing area planning efforts in which major input has already been made by the public. A community may be expected to react unfavorably when previous input to other pertinent plans is summarily disregarded by agency planners and decision makers. Active public involvement can also ensure that the final product, which the community helps to develop, will be successfully implemented. Implementation is much more likely where the community has taken an active concern in planning problems and has played an important role in generating and evaluating alternative solutions.

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ENVIRONMENTAL IMPACTS
An environmental impact may be defined as a change in one or more of various socioeconomic and biophysical characteristics of the environment. Environmental assessment is, therefore, a prediction of the probable changes which may resuIt from a proposed or impending action. The following discussion describes some of the considerations to be made in the projection of environmental impacts.

Impact Types With environmental impacts defined as changes in any component of the biophysical or socioeconomic environment, an impact may be positive, negative, or it may have both beneficial and detrimental aspects simultaneously. Impacts may be classified as direct, indirect, or cumulative. Direct Impacts. Direct impacts are caused by a specific action and occur at the same time and location as the action. As an example, erosion resulting from runoff from a newly cleared construction site is a direct impact. Direct impacts are also referred to as primary impacts. Indirect Impacts. Indirect impacts are caused by an action but are usually either (1) later in time or (2) further removed in distance. Indirect impacts, also called secondary impacts, may include growth-inducing effects and other effects related to induced changes in the pattern of land use, population density, or growth rate and related effects on air, water, and other natural systems including ecosystems. The adverse effects on the aquatic ecosystem caused by the erosion and soil loss described in the preceding paragraph are an example of an indirect impact. Cumulative impacts. A cumulative impact is one that results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency or person undertakes such other actions. Cumulative impacts might result from individually minor or innocuous actions which may be collectively significant when taking place over a long period of time. Reservoir siltation and ultimate reduction in storage volume resulting from the erosion described in the preceding paragraphs is an example of a cumulative impact.

Identification of Impacts The identification of environmental impacts is the essence of the environmental assessment process. In order for impact identification to be accomplished, it is necessary to follow a sequence of steps as outlined below 1. It is first necessary to develop a complete understanding of the proposed action incorporated in this portion of the analysis. A detailed description of what needs to be done or accomplished is required. What kinds of materials, workers, and/or resources are involved? Where will the action take place? When will the various activities associated with the project occur? 2. It is then necessary to gain a complete understanding of the affected environment. What resource factors in the biophysical and/or socioeconomic environments exist and are likely to be changed or affected by the action? 3. Finally, it is necessary to superimpose the proposed action on the affected environment and project possible impacts on the environmental characteristics, quantifying changes whenever possible and aggregating the impacts in order to prepare an environmental document describing the anticipated changes.

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Several methods have been developed that may be utilized to accomplish the analysis in a systematic fashion. These methodologies will be discussed in a later section. It should be noted that identification of environmental impact must be accomplished with the understanding that the environment is in a dynamic state. That is, changes are occurring in virtually all aspects of the environment on a continuing basis. It is the function of the environmental assessment process to consider only those changes or impacts that would be expected to result from the project. Measurement of Impact It is desirable to quantify impacts wherever possible. This may be accomplished through the use of instrumentation, data acquisition, application of models or other acceptable quantification techniques. In situations where quantitative measurements are not possible, impacts may be described through the use of qualitative measurements. Relative changes and general comparisons, based upon expert judgment, may be utilized in the absence of adequate measurable parameters. Aggregation Prior to reporting results of an environmental assessment in an environmental document, it is necessary to aggregate or combine the impacts identified with the various aspects of the proposed project. In this aggregation two problems normally occur. The first involves the wide range of environmental characteristics or resource factors that are utilized to describe the biophysical and socioeconomic environment. The traditional problem of comparing apples and alligators results. The second problem involves the need to aggregate impacts of various activities on a single resource factor. Finally, the combination of aggregative effects must be utilized to develop a comparative discussion for the decision-making process in the evaluation of different alternatives.

RESOURCE FACTORS
In order to facilitate the identification and description of impacts of the environment, it is useful to describe the environment in specific terms. Resource factors or attributes provide a mechanism for impact identification, measurement, and aggregation. In most assessment methodologies, an initial, basic list of environmental categories is utilized to develop an expanded list of detailed attributes that are specific and relevant to the proposed project and its alternatives in a given range of environmental settings. The discussion that follows provides a basic listing of formal resource factor categories and a higher level of attributes in each category. These listings may be expanded and/or reduced as particular circumstances warrant. Categories of Environmental Resource Factors Basic environmental resource factors include both biophysical and socioeconomic considerations. For convenience, the following discussion is broken into seven areas, with a short description of detailed attributes which may be considered in each category. The seven areas are 1. 2. 3. 4. Atmosphere Water Land Biological environment

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5. Sound 6. Human aspects 7. Economic aspects It needs to be emphasized that the listing is an example set. Other resource factors may be added depending on the complexity of the project and level of detail necessary for impact analysis. To make a list of attributes useful, it is desirable to further define them. For most of these attributes, a writeup covering the following items is available in Ref. 2: 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. 11. 12. Definition of the attribute Activities that affect the attribute Source of effect Variables to be measured How variables are measured Data sources for the attribute baseline information Skills and instruments required to collect the data Evaluation and interpretation of data Geographical and temporal limitations Mitigation of impacts Secondary effects Other comments and additional references

Atmosphere. Impacts to air quality frequently head the list of concerns associated with environmental assessment. This is particularly so when such impacts are visible and/or of a toxic nature, leading to potential health effects. Diffusion Factor. The diffusion factor is related to the structural aspects of the air environment. It reflects such components as vertical temperature structure, wind speed, stability, topography, and climatic conditions. An understanding of the diffusion factor is necessary in determining the extent to which air pollution can build up in a given region. Particulates. Particulates, one of the most prevalent air pollutants, exist in the form of individual particles suspended in the air. Ranging in size from 0.01 to 100 m, particulates can produce health effects, visibility problems, structural and material deterioration, and property value reductions. Sulfur Oxides. Generated primarily by the combustion of fossil fuels, sulfur oxides are usually a combination of sulfur dioxide, sulfur trioxide, sulfuric acid, and sulfurous acid. Undesirable results of sulfur oxides include health effects, increased corrosion of metals, plant injury, and production of acid rain. Hydrocarbons. Hydrocarbons include several organic compounds that are produced when petroleum fuels are burned. Automobile exhausts produce approximately one-half the hydrocarbons emitted to the atmosphere. Other hydrocarbons are produced from natural sources, such as decomposition of organic matter on land and in swamps and marshes. The primary concern associated with hydrocarbons lies in their role in the formation of photochemical oxidants and smog. Nitrogen Oxides. Nitrogen oxides are produced as a result of high-temperature combustion. In combination with hydrocarbons, they produce photochemical smog. Although direct health effects are uncertain, nitrogen oxides can affect vegetation, produce corrosion, and damage synthetic fibers and clothing. Furthermore, nitrogen oxides may contribute substantially to the acid rain problem. Carbon Monoxide. Carbon monoxide is produced by the incomplete combustion of carbonaceous materials in fuels, particularly in space heating and burning of refuse. Carbon monoxide is one of the most widely distributed and most commonly occurring air pollutants. Adverse health effects are related to carbon monoxide poisoning. However, vegetative or material effects usually are minimal. Photochemical Oxidants. Products of atmospheric reactions between hydrocarbons and nitrogen oxides

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which are initiated by sunlight are called photochemical oxidants. Ozone is a product of these reactions, as is peroxyacetyl nitrate (PAN). Although the toxicological potential of photochemical oxidants on animal and human receptors is uncertain, acute and chronic injury may occur to vegetation. Also, photochemical oxidants may lead to the deterioration of materials such as polymers and rubber. Hazardous Toxicants. The release of toxic substances such as elements or compounds of arsenic, asbestos, barium, chromium, lead, nickel, tungsten, radioactive wastes, mercury, and phenols may cause serious damage to the health and welfare of an exposed community. These materials can create serious health hazards and diseases of a chronic nature. Odors. Although most malodors are considered harmless, they may cause loss of personnel and community pride, loss of social and economic status, discomfort, nausea, loss of appetite, and insomnia. Water. The impacts on water quality, which are of particular importance in many projects, are of greatest concern when the results reduce the beneficial use or the aesthetic appeal of water supplies. Aquifer Safe Yield. The dependability of groundwater from a quantitative standpoint is dependent upon aquifer safe yield. This term relates the consumption rates to the recharge rates. If consumption is greater than recharge, the aquifer is, in effect, being minedan undesirable situation. Flow Variations. Changes in the velocity of flow and in discharge rates are important from both quantitative and qualitative standpoints. Nutrient transport, silt and sediment loading, and downstream effects on aquatic life may result from changes in upstream land use. Radioactivity. Since ionizing radiation is injurious when absorbed in living tissues in concentrations substantially above that present in natural background, it is necessary to prevent excessive levels of radiation from reaching any organism. Radioactive sources may include power development, industrial operations, medical laboratories, and material disposal. Suspended Solids. Suspended solids contained in water are those that are not in solution but which may be removed through laboratory filtration tests. Solids may be floating, settleable, or nonsettleable, and may contain organic or inert substances. Suspended solids may lead to undesirable aesthetic conditions, difficulties in water treatment and adverse impacts on fish and other aquatic life. Thermal Discharge. When water is released into an environment at temperatures much higher or lower than those of the ambient conditions, thermal pollution may result. Since water temperature is closely associated with physical, chemical, and biological conditions, the aquatic ecosystem may be significantly disrupted as a result of a thermal discharge. Acid and Alkali. Discharge of wastes which significantly alter the pH of the aquatic environment may be extremely damaging to aquatic life. Social and economic losses in terms of reduced productivity, declining recreational activity, and treatment costs necessary to correct pH-related problems may also result. Biochemical Oxygen Demand (BOD). BOD is an indirect measure of the amount of biological degradable organic material present in water. Dissolved oxygen will be depleted in the process of satisfying BOD requirements. As oxygen is utilized, water conditions become septic and other water quality and aesthetic problems result. Dissolved Oxygen (DO). DO is necessary in water to maintain aerobic conditions. Absence of DO leads to the development of anaerobic conditions with their associated odor and aesthetic problems. Adequate DO levels are necessary in surface waters to maintain growth of fish and other desirable aquatic life. Dissolved Solids. Total dissolved solids or TDS is the sum of carbonates, bicarbonates, chlorides, sulfates, phosphates, nitrates, and various salts of calcium, magnesium, sodium, potassium, and other substances. These salts in solution may alter the physical and chemical nature of water. High amounts of TDS are objectionable because of physiological effects, mineral tastes, or economic consequences. Nutrients. Nutrients are, in essence, fertilizers; they include forms of nitrogen and phosphorus which are responsible for eutrophication of water supplies. Eutrophic conditions are typified by dense algae growth, surface water scums, foul-smelling water, periods of anaerobic conditions, and fish kills. Many activities increase the supply of nutrients to natural waters.

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Toxic Compounds. Toxic compounds may occur in wastes containing heavy metals, organic chemicals, cyanides, sulfides, and pesticides. Adverse effects that can result include damage to aquatic life, reduction of beneficial use of water, and more and extensive treatment requirements. Aquatic Life. Aquatic life refers to the population of species which exists in a state of dynamic balance in water supplies. Since any pollution tends to upset this natural balance, changes in the many previously listed attributes will influence aquatic life. Fecal Coliforms. Fecal coliforms are single-celled bacteria found in the intestinal tracts of humans and other warm-blooded animals. Their presence in water is an indication of possible contamination by human wastes and, thus, that the water may contain bacteria, viruses, or other disease-causing organisms. Land. Most food and fiber resources come from the land; consequently, it must be used in a properly planned and controlled manner. Many activities affect the land resource and may preclude alternative uses. Erosion. Erosion is a process whereby soil particles are dislodged and transported to another location by wind or water action. Erosion may be highly destructive and render land unproductive and/or may pose a physical barrier to other activities. Water courses downslope from eroded areas may be adversely affected by excessive sediment loads. Areas subjected to erosive forces may become barren and aesthetically unappealing. Natural Hazards. Natural hazards are those occurrences, brought about by the forces of nature, that result in discomfort, injury, or death to humans; damage or destruction to physical structures; detrimental changes in physical character of the land, water, and air; or damage to plant and animal life in the affected area. Natural hazards include floods, earth slides, wildfires, and volcanos. Other hazards, such as earthquakes and hurricanes, may cause great personal and physical damage when they occur in areas of concentrated human activity. In some cases, the occurrence of these hazards may be accelerated through human activity, e.g., flooding. In other situations, the occurrence is unaffected by human activity; however, the degree of damage done may be dictated by the location and magnitude of population centers and other developments. Land Use Patterns. Land use patterns are natural or imposed configurations that result from spatial arrangement of the different uses of land at a given time. Historically, land use patterns evolve as a result of (1) changing economic considerations, (2) legal restrictions, such as zoning, and (3) changes in existing legal restrictions. Compatibility of use between one parcel of land and adjacent properties becomes a controlling issue. Biological Environment. The biological environment and its attributes can be utilized interchangeably with the concept of ecology and the ecosystem. Convincing evidence exists that species diversity in an ecosystem is closely related to the stability of that system. Greater species diversity indicates that the ecosystem is more able to resist disturbance and stress. Although humans have made progress in providing for their needs, the results are often accomplished at the expense of the total ecological balance of the environment. Since this balance is crucial to the long-term viability of human beings, species diversity must be maintained. Large Animals (Wild and Domestic). Large animals are those, both wild and domestic, that weigh typically more than 30 lb when fully grown. These populations may be affected by food supplies, cover, water, natural and artificial barriers, noise, and other activities. Predatory Birds. Birds of prey are flesh eaters that typically obtain their food by hunting, killing, and eating small animals, other birds, and fish. These birds are frequently impacted by loss of habitat, poisonings, or intrusion into or near nesting areas. Small Game. Small game includes both upland game birds and animals that typically weigh less than 30 lb as adults and which are hunted for sport. Many human activities result in habitat destruction or in other impacts to these animals. Fish and Shellfish. Fish are cold-blooded aquatic animals that obtain oxygen through a gill system and inhabit saltwater and freshwater bodies and streams. Shellfish are aquatic animals that have an exoskeleton

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shell. Since these species depend directly on water for some or all aspects of their existence, any activity which affects water quality and water level will impact on their well-being. Waterfowl. Waterfowl are birds that frequent and often swim in water, nest and raise their young near water, and obtain at least part of their food from aquatic plants, animals, and insects. Because they depend directly on water for all or some facets of their existence, activities which affect water quality and water level will also impact waterfowl. Field Crops. Field crops are those commercially cultivated for the primary purpose of providing food and clothing for humans or food for domestic livestock. Activities which impact field crops include those that alter land use and those which affect crop production, including the application of herbicides or other toxic materials. Natural Land Vegetation. Natural land vegetation is vegetation that uses soil as its growth medium and that is not the subject of extensive cultural practices. Included are plants, trees, shrubs, grasses, herbs, ferns, and lichens. Native vegetation is established through a series of successional stages. Successional change is slow, and disruption frequently results in the least-desirable plant types becoming the first to be reestablished. Aquatic Plants. Aquatic plants are those whose growth medium is primarily water, although they may be rooted in soil. They include free-floating plants, all surface and submerged rooted plants, and swamp and marsh vegetation whose roots are periodically or primarily submerged in water. Activities that cause changes in water level or water quality parameters have the greatest impact on aquatic plants. Sound. The level of sound is an important indicator of environmental quality. Noise has been defined as unwanted sound in the environment. Physiological Effects. Noise can affect physiology in three different ways. First, internal bodily systems may be affected; for example, extreme noises may constrict blood vessels, increase pulse and respiration rates, increase tension and fatigue, cause dizziness, and cause loss of balance. Second, the hearing threshold may be impacted with temporary or permanent hearing loss resulting. Third, sleep patterns may be disrupted, with resulting irritability and often irrational behavior. Psychological Effects. Noise exposure can have an impact on an individuals mental stability and psychological response. This response may be manifested with signs of increased annoyance, anxiety, or fear. Important variables of noise that result in psychological effects are its loudness, duration, and frequency content. Communication Effects. The presence of noise can adversely affect face-to-face conversation and telephone communication. Temporary interference or interruption can be annoying and occasionally harmful to personal well-being. Performance Effects. The presence of noise can affect the ability of a human to perform mechanical and mental tasks. This is manifested through increase in muscular tension, lapse in attention, diversion of attention, masking of needed auditory signals, and startle response to high-intensity noises. Human Aspects. This category refers to the way in which people interact with each other and the natural environment. These interactions are frequently complex and their analysis requires careful scrutiny of all activities and interrelationships. Life-styles. The social activities of humans often take on structural characteristics which eventually cause them to become organizations. The makeup of organizations may vary, depending upon the characteristics, interests, and objectives of the organizations population. The bases for these organizations might be ethnic, political, religious, or occupational. Changes in life-styles may be reflected by activities which affect employment, standards of living, community development, and recreational opportunity. Psychological Needs. Psychological needs of human beings are primarily those of emotional stability and security. Activities which affect these needs are essentially the same as those which impact life-styles. Physiological Systems. These systems include anything that is a part of a persons body or that plays a

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part in a bodily function. They include respiratory, circulatory, and digestive organs; skeletal and excretory systems; and all parts of the human body that contribute to its effective, efficient functioning. Any activity that can harm or threaten the efficient functioning of any part of the human body must be considered in light of its effect. Community Needs. A community requires many services including housing; water supply; sewage disposal; utilities, such as gas, electricity and telephone; recreational facilities; and police and fire protection. Any change or impact that occurs will depend primarily on the degree to which a population is affected by a proposed activity. Economic Aspects. In environmental impact analysis, the potential impact on the economic structure or changes resulting from project activities comes primarily from the direct effect of purchases of goods and services for project activities and from the indirect effects arising from goods and services purchased from payrolls. Effects may reflect impact on industrial and commercial activities, the local government, and the individual. Regional Economic Stability. Stability refers to a resistance to change in the ability of a regions economy to withstand severe fluctuations or to the speed and ease an economy demonstrates in returning to an equilibrium situation after receiving a shock. The more diverse an economy and the more closely related it is to growth areas of the national economy, the more stable it is likely to be. Public Sector Revenues and Expenditures. This attribute consists of the annual per capita revenues and expenditures of local and state governments and associated agencies in the region under study. Changes in this factor can be interpreted as a measure of a change in economic well-being of the public sector. Per Capita Consumption. The annual per capita personal consumption of goods and services by local citizens can be interpreted as a direct measure of personal economic well-being. Increases or decreases in local employment, industrial reduction or deletion, and construction all have the potential to affect per capita consumption. Environmentally Sensitive Areas Several resource factors are particularly important due to their tendency to elicit strong public reaction. When impacts occur in these areas, it is essential that an environmental assessment adequately addresses projected impacts due to all project alternatives. Furthermore, the assessment should contain a detailed discussion of mitigation measures which would be implemented should the project be undertaken. Human Health and Safety. Any activity that can adversely impact human health or increase the risk due to accidental exposure must be considered. There are many possible sources of impacts. These range from activities that might impair the safety of individuals when placed in a working environment to exposure to hazardous chemicals, gases, radiation, noise, or disease. Threatened Species. Formerly categorized as rare or endangered, threatened species include all forms of plants and animals whose rates of reproduction have declined to the point where their populations are so small they are in danger of disappearing. Lists of threatened animal species are published periodically by the Bureau of Sport Fisheries and Wildlife of the U.S. Department of the Interior. While animal species are the ones most often cited in the news media, there are many species of plants that also qualify as threatened. If any question exists as to the presence of a threatened species in the area of a project, knowledgeable wildlife biologists or botanists should be called on to verify their presence and to give a preliminary assessment of the impact of the activity on the population of this species. Nonrenewable Resources. Nonrenewable resource consumption is of particular interest since the consumption or utilization represents a commitment that is potentially irreversible or irretrievable. Fossil fuels,

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metals, many building materials, mineral resources, and other materials fall into this category. Impacts on nonrenewable resources may be minimized by economizing on resource requirements, development and use of substitutes, recycling, etc. Aesthetics. Impacts on aesthetics are those that are perceived through the senses: sight, taste, smell, hearing, and touch. Although aesthetic perceptions usually require the consideration of all senses simultaneously, visual perception is perhaps the most familiar of the areas. Generally speaking, any activity that will change the quality or distinguishable characteristic of the perceived environment can be considered as having an effect on aesthetics. Aesthetic considerations may be complex to evaluate because these perceptions are individual and values for definition become difficult to quantify. Cultural Resources. Cultural resources may include historic, archeological, and architectural resources, and may take the form of sites, artifacts, or properties. Other forms of cultural resources are associated with behavior patterns and may be associated with customs, traditions, and religious beliefs and practices.

ALTERNATIVES
The analysis of alternatives is an important consideration in the environmental assessment process. CEQ regulations, in fact, state that the required section on alternatives is the heart of the EIS. Types of Alternatives Specifically included in the alternatives to be considered are (1) the no action alternative, (2) all reasonable alternatives, (3) the agencys preferred alternative(s), if one or more exist, and (4) mitigation measures not discussed with the previous alternatives. No Action. Analysis of the no action alternative requires a projection of future environmental conditions without the proposed project; in other words, what will happen if nothing is done or if the decision is made to simply maintain the status quo. Reasonable Alternatives. The CEQ regulations call for agencies to rigorously explore and objectively evaluate all reasonable alternatives, and for alternatives that were eliminated from detailed study, briefly discuss reasons for their having been eliminated. Furthermore, the regulations state that reasonable alternatives not within the jurisdiction of the lead agency are to be included in the analysis (1). There is no clear definition of what constitutes reasonableness, although the courts have rendered various decisions that may be utilized in making a determination. Options may include alternatives in terms of routes, sites, timing or scheduling, objectives, and/or methods to accomplish a single objective. Possible exclusions are those alternatives too remote or speculative to be viable, or those unavailable in the proposed time frame. Where sheer guesswork would be necessary in the evaluation, such alternatives may be listed and the reason for lack of detailed analysis included. Preferred Alternatives. Although agencies are not to commit resources that would prejudice the selection of alternatives before making a final decision, the fact that, due to economic or other reasons, a preferred alternative may exist is recognized by the CEQ regulations. If such preference does indeed exist, it should be so stated. In this manner, the proposed action or preferred alternative can be more easily compared to the other alternatives prior to final decision making.

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Mitigation Measures. The minimization of adverse impacts (mitigation) often may be accomplished in a variety of ways. If appropriate mitigation measures are identified but have not already been included in the discussion of the proposed action or alternatives, special effort to include them as alternatives is required. Alternative Analysis Each alternative is to be analyzed for environmental impact. The CEQ regulations require that the statement should present the environmental impact of the proposal and the alternatives in comparative form, in order that the issues may be sharply defined and result in providing a clear basis for choice among options by the decision maker and the public (4). Although no format is specified, the requirement to present alternatives in comparative form frequently results in a matrix display of alternatives and summarized impacts, as shown in Figure 10.6.

ASSESSMENT PREPARATION AND REVIEW


The preparation and review of environmental assessments, impact statements, and other documents is accomplished through an interdisciplinary effort requiring the acquisition of background or baseline data and information and development of an accurate and complete definition of the scope of the proposed project. Then, utilizing a methodology to systematically relate activities of the proposed project and the alternatives to the affected environment, the potential impacts are identified and the indicated documentation is prepared. Finally, the documents are reviewed and disseminated for use in decision making. This section provides a brief overview of each of these basic components of the NEPA process. The Interdisciplinary Team As specified in the act, NEPA requires the utilization of an interdisciplinary approach. This means that due consideration must be given to all facets of the environmentbiophysical and socioeconomic. This is accomplished through the efforts of a group of individuals with expertise encompassing the entire range of resource factors previously discussed participating in the assessment study. Furthermore, these individuals must participate as team members, interacting and cross-communicating so that the result is interdisciplinary as opposed to multidisciplinary. As a general rule, group working sessions frequently become spirited; however, such exchange is often highly productive and becomes essential to the identification of indirect and cumulative impacts as is required in the analysis. Baseline Studies To establish the baseline requires a study of the environmental setting or location and conditions under which the proposed action is to take place. This may include the assembling of previously collected or secondary data, and when necessary, the acquisition of first-hand or primary data. The background studies should incorporate existing conditions, geographic characteristics, and temporal characteristics in such manner that the baseline information serves as a filtering mechanism, eliminating consideration of impacts unrelated to a specific area or site, and aiding in the quantification of impacts where the severity of impact would vary. Conditions Prior to the Activity. The nature of the impact is determined by the conditions of the environment prior to the activity. This information establishes the status of the attributes prior to the activity at the

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FIGURE 10.6 Matrix format for comparison of alternatives.

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project location. Because the measurement and analysis of environmental impact cannot take place without base data, identification of the characteristics of the baseline is critical. Geographic Characteristics. There may be significant differences in impact on attributes caused by a given activity in different areas. Geographic location is, therefore, one of the factors that affects the merit or relative importance of a particular attribute. For example, the impact of similar projects on water quality in an area with abundant water supplies versus the impact in an area with scarce water resources would differ significantly. The spatial dispersion of different activities introduces an element of difficulty when comparing the impact of one activity with another. Temporal Characteristics. Time may also pose problems for impact analysis. It is essential to ensure that all impacts are examined over the same projected time period. Furthermore, to adequately compare (or combine) activity impacts, it is necessary that the same time period (or periods) apply. Scoping The term scoping refers to a process of identification of the important issues that require full analysis and the separation of those issues from the less significant ones that do not require detailed study. It is necessary that the scoping process take place as soon as possible after an agency decides to prepare an EIS. Before completing the scoping process, the lead agency must publish a notice of intent. The scoping process also serves as a mechanism to identify other environmental review and consultation requirements and to allocate responsibilities among lead and cooperating agencies. Affected federal, state, and local agencies, any affected Native American tribe, the proponent of the action, and other interested persons must be invited to participate in the scoping process. In determining the scope of environmental impacts, the CEQ requires that agencies consider three types of actions, three types of alternatives, and three types of impacts (4). These include A. Actions (other than unconnected single actions) that may be 1. Connected actions, by which it is meant that they are closely related and therefore should be discussed in the same impact statement. Actions are connected if they a. Automatically trigger other actions that may require environmental impact statements b. Cannot or will not proceed unless other actions are taken previously or simultaneously, or c. Are interdependent parts of a larger action and depend on the larger action for their justification. 2. Cumulative actions, which when viewed with other proposed actions, have cumulatively significant impacts and should therefore be discussed in the same impact statement. 3. Similar actions, which when viewed with other reasonably foreseeable or proposed agency actions, have enough in common to provide a basis for evaluating their environmental consequences together, such as common timing or geography. An agency may wish to analyze these actions in the same impact statement. It should do so when the best way to assess adequately the combined impacts of similar actions or reasonable alternatives to such actions is to treat them in a single impact statement. B. Alternatives, which include 1. No action alternative 2. Other reasonable courses of action 3. Mitigation measures (not in the proposed action) C. Impacts, which may be 1. Direct 2. Indirect 3. Cumulative

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Assessment Methodologies Many methodologies have been developed which allow the user to respond in a substantive manner to CEQ requirements when preparing an EA/EIS. Presented in this section is a discussion of some of these impact assessment methodology types (2). Ad Hoc. These methodologies provide minimal guidance for impact assessment beyond suggesting broad areas of possible impacts; e.g., impacts on flora and fauna, lakes, and forests, rather than defining specific parameters to be investigated. Overlays. These methodologies rely on a set of maps of a project areas environmental characteristics (physical, social, ecological, and aesthetic). These maps are overlaid to produce a composite characterization of the regional environment. Impacts are identified by noting the impacted environmental characteristics within the project boundaries. Checklists. These methodologies present a specific list of environmental parameters to be investigated for possible impacts; they do not require establishing direct causeeffect links to project activities. They may or may not include guidelines for the measurement and interpretation of parametric data. Matrices. These methodologies incorporate a list of project activities with a checklist of potentially impacted environmental characteristics. The two lists are related in a matrix that identifies causeeffect relationships between specific activities and impacts. Matrix methodologies may either specify actions that impact certain environmental characteristics or may simply list the range of possible actions and characteristics in an open matrix that will be completed by the analyst. Networks. These methodologies work from a list of project activities to establish causeconditioneffect relationships. They are an attempt to recognize that a series of impacts may be triggered by a project action. These approaches generally define a set of possible networks and allow the user to identify impacts by selecting and tracing out the appropriate project actions. Combination Computer-Aided Methods. These methodologies, usually developed to assess large federal agency projects, use a combination of matrices, networks, analytical models, and a computer-aided systematic approach to: (1) identify activities associated with implementing major federal programs, (2) identify potential environmental impacts at different user levels, (3) provide guidance for abatement and mitigation techniques, (4) provide analytical models to establish causeeffect relationships to quantitatively determine potential environmental impacts, and (5) provide a methodology and a procedure to use this comprehensive information to respond to the requirements of environmental assessment documentation preparation. There is an extensive literature that discusses and describes various specific methodologies (2, 7).

Document Preparation Results of the impact analysis process are organized into one or more of the following documents: 1. 2. 3. 4. An environmental assessment (EA) A finding of no significant impact (FONSI) A draft environmental impact statement (DEIS) A final environmental impact statement (FEIS)

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FIGURE 10.7 Example impact summary sheet (6).

It may be useful to consider displaying the results in a way that makes it easy to comprehend total impact from a brief review. One suggested method for doing this is by displaying the impacts on a summary sheet, such as that shown in Figure 10.7. Details of the specific format for environmental impact analysis documentation are given by individual agency guidelines. These guidelines should be consulted and followed for each analysis. General comments included in the CEQ regulations regarding the preparation of EISs can be summarized as follows 1. 2. 3. 4. 5. 6. 7. 8. 9. 10. EISs should be analytic rather than encyclopedic. Impacts should be discussed in proportion to their significance. EISs should be concise. EISs should state how alternatives considered and decisions made, based on the EIS, will or will not achieve the requirements of Sections 101 and 102(1) of NEPA and other environmental laws and policies. Alternatives discussed should be limited to those that are expected to be considered by the agency decision maker. The agency should not commit resources prejudicing selection of alternatives before making a final decision. EISs should be a means of assessing the environmental impact of the proposed action, rather than a means of justifying decisions already made. A systematic and interdisciplinary approach should be used to prepare EISs. EISs should be written in plain language and appropriate graphics may be used so that decision makers and the public can readily understand the documents. Public participation should be actively sought during the scoping process and in the early planning stages of the project to identify significant issues.

Document Review The review of NEPA-related documents takes place at many different levels, for a variety of purposes, and from different perspectives, depending on the reviewers. Five typical review situations and three common areas of concern among the different types of review have been identified (2).

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Review Situations. Specific review situations include the following. Internal Review. Intraagency or in-house review whereby the document is examined for glaring errors, legal compliance, style, and technical content prior to public release is standard practice. Interagency Review. Before preparation of the final EIS, the draft statement must be sent to federal agencies. 1. Having jurisdiction by law or special expertise with respect to any environmental impact involved, or 2. That are authorized to develop and enforce environmental standards 3. In addition, the proponent agency is required to request comments of appropriate state and local agencies authorized to enforce environmental standards 4. Native American tribes when a reservation may be affected, and 5. Any agency making a request. EPA Review. Draft and final EIS documents are reviewed by the EPA. For draft statements, EPA considers the environmental impact of the action and the adequacy of the statement. Results of the review are published in the Federal Register. For final statements, EPA reviews the document with primary attention directed to substantive issues related to environmental impact assessment. Again, results are published in the Federal Register. Public Review. The lead agency must also request comments from the general public. Comments are usually solicited through published notices, public hearings, and contact with known interested conservation groups and individuals. Review for Decision Making. Finally, the EIS document is reviewed at the agency decision level, and utilized in preparing the record of decision. Types of Review. Three areas of concern are common to the diverse review situations outlined above. Administrative Compliance Review. This concern focuses on the document from the standpoint of compliance with NEPA, CEQ regulations, and specific agency document preparation and processing requirements. General Document Review. This aspect of review is concerned with clearness, completeness, and correctness. Technical Review. The third aspect is concerned with the technical accuracy and adequacy of the document. Several approaches for reviewing NEPA-related documents have been developed. Most utilize either an independent analysis or predetermined evaluation criteria to score or rate a document. Regardless of the approach taken, the overall review process is essential to the preparation of better documents, and ultimately better decisions.

NEPA AFTER 25 YEARS


Immediately after its enactment, NEPA began to alter the way federal agencies did business. Agencies, responding to NEPA, CEQ guidelines, and subsequent regulations, began developing an infrastructure to respond to the legal and procedural requirements. Legal actions, including landmark court cases, interpreted and further shaped the law. In the years immediately following the enactment of NEPA. the number of EISs filed reached over 2000 per year. That number declined to less that 400 per year in 1989, but appeals to have stabilized at approximately 500 per year in the 1990s. What is now known as the NEPA process has become a matter of routine, championed or respected by some, tolerated or criticized by others.

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On the occasion of the 25th anniversary of the act, the CEQ conducted a reflective study of NEPAs effectiveness and prospects for improvements. Participants in the study included representatives of the original framers of the act and individuals who drafted the CEQ regulations, along with some members of Congress, federal agencies with NEPA implementation experience, state and local agencies, and the public. In addition to evaluating strengths, the participants also considered the potential for improving the current implementation of NEPA, identifying areas . . . ripe for innovation, re-invention, and improvement (9) The study concluded that NEPA has been a success because it (1) causes agencies tv examine the environmental consequences of their actions before they make final decisions, and (2) provides a framework for collaboration between the agencies causing the actions and those who will be affected by the consequences (environmental, social, and economic impacts) of their decisions. The participants identified five elements critical to NEPA effectiveness and efficient implementation, and pointed out problem areas associated with each element. Strategic Planning The NEPA process provides a framework for integrating environmental concerns directly into agency internal planning, policies and programs at an early stage. Unfortunately, the process is often either initiated too late to be effective in agency planning and decision making or applied to individual projects instead of evaluating the programs that call for those projects. Agencies then encounter delays, incur increased costs or end up with fewer alternatives available for consideration, thereby denying NEPA its full strategic planning value. Public Information and Input NEPA significantly increased public information and input into agency decision making by opening opportunities for involvement. In many cases, agencies have actively solicited ideas and concerns from the public to improve the quality of projects and reduce adverse impacts on the environment. In others, the desired level of public involvement has not been achieved, with the result being a sense on the part of citizens of dissatisfaction, frustration, and distrust, sometimes leading to litigation. Interagency Coordination NEPA and many subsequent laws have required interagency coordination in an effort to reduce conflicts, reduce duplication of effort, and to improve the environmental planning process. When information is not shared or when processes are uncoordinated, agencies and often the public may be placed in adversarial positions leading to conflicts and delays. Problems are often initiated by conflicting or different timetables, requirements, and modes of public participation. Interdisciplinary, Place-based Approach to Decision Making NEPA calls for an interdisciplinary approach to planning and decision making. When agencies bring the full range of biophysical and socioeconomic factors affecting a single place into their management and planning processes, they are in a position to make better decisions with regard to the needs of the community and minimize adverse impacts on the environment. Difficulties include lack of quality environmental baseline data, lack of early participation by resource agencies, and costs and delays associated with data collection. New tools such as modern computers, internet communications, and geographic information systems hold considerable promise for improvements in this area.

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Monitoring and Adaptive Management Science-based and flexible management approaches are essential to the confirmation of predicted impacts. to ensure that mitigation measures are effective and to modify remediation or mitigation processes if necessary. By accepting more uncertainty in the environmental assessment process and adapting quickly to conditions actually encountered during the project operational phases, agencies may be able to decrease project startup time and reduce overall project costs. The CEQs goal is to use the experiences of the first 25 years to streamline and improve the NEPA process. By streamlining the process, the CEQ hopes to make it more efficient, to promote the integration of social, environmental, and economic factors into agency decision making, and to ensure openness in government. Additional information is available through its web site (www. whitehouse.gov/CEQ/).

REFERENCES
1. National Environmental Policy Act of 1969 (PL91-190; 83 Stat 852). 2. Jain, R. K., L. V. Urban, G. S. Stacey, and H. E. Balbach, Environmental Assessment, McGraw Hill, New York, 1993. 3. Caldwell, Lynton K., Beyond NEPA: Future Significance of the National Environmental Policy Act. Law Review, Vol 22, Number 1, Boston, Mass., 1998. 4. CEQ Regulations for Implementing Procedural Provisions of NEPA (43 FR 55978-56007), November 19, 1978. 5. Executive Order 11991, 42 FR 26967 (1977), amending Executive Order 11514 (1970). 6. Orloff, Neil, The Environmental Input Statement Process: A Guide for Citizen Action, Information Resources Press, Washington, D.C., 1978. 7. Canter, Larry W., Environmental Impact Assessment, McGraw-Hill, New York, 1977. 8. Jain, R. K., L. V. Urban, and A. J. Cerchione, Department of the Air Force Handbook for Environmental Impact Analysis, USAF/PREV Environmental Planning, Washington, D.C., June 1976. 9. The National Environmental Policy ActA Study of Its Effectiveness After Twenty-five Years. Council on Environmental Quality, Executive Office of the President, Washington, D.C., January 1997.

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