&EPA
United States
Environmental Protection
Agency
Region 5
Water Division
230 South Dearborn Street
Chicago, Illinois, 60614 .
905185100
A Manual for Evaluating
Predicted and Actual
Impacts of Construction
Grants* Projects
Qualitative Impacts
Quantitative Impacts
C/3
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A MANUAL FOR EVALUATING
PREDICTED AND ACTUAL IMPACTS
OF CONSTRUCTION GRANTS PROJECTS
Contract Number 68-04-5017
Delivery Order No. 008
Prepared For:
United States Environmental
Protection Agency, Region V
230 South Dearborn Street
Chicago, Illinois 60604
Prepared By:
ESEI/EcolSciences
508 West Washington Street
South Bend, Indiana 46601
January, 1985
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Blank Page
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TABLE OF CONTENTS
PAGE
MONITORING & EVALUATION FLOWCHART Front Plate
I. INTRODUCTION 1-1
II. METHODOLOGY II-l
III. WATER QUALITY ISSUES III-l
IV. WETLAND ISSUES IV-1
V. FLOODPLAIN ISSUES V-l
VI. BIOTA ISSUES VI-1
VII. SOCIOECONOMIC ISSUES VII-1
\
VIII. AGRICULTURAL ISSUES VIII-1
IX. PHYSICAL ENVIRONMENT ISSUES IX-1
X. CULTURAL RESOURCE ISSUES X-l
XI. SOLID WASTE ISSUES XI-1
XII. ENERGY ISSUES XII-1
XIII. AIR QUALITY ISSUES XIII-1
XIV. INTERRELATED/OTHER ISSUES XIV-1
APPENDICES
A. DATA BASE REPORT A-l
B. DATA BASE MANAGEMENT B-l
C. ANNOTATED BIBLIOGRAPHY C-l
D. HOW TO PROVIDE INPUT FOR FUTURE REVISIONS D-l
i.
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Monitoring & Evaluation Flowchart
c
EPA Headquaters
Policies
Guidance
Directives
Promulgations
SMAP
1
Regional Monitoring &
Evaluation Coordination
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u
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(C
Decisions
Social
Economic
Geophysical
Indicators
Data Gathering
Quality
Control
Data Processing
Quantitative
Alternatives
1
Decisions
Air Quality
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Water Quality
Parameters
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CHAPTER I
INTRODUCTION
The promulgation of the National Environmental Policy Act (NEPA) in 1969
established a process by which federal agencies were required to assess the
environmental impacts of their actions. With the passage of P.L. 92-500 in
1972, also known as the Federal Water Pollution Control Act (FWPCA) and
amendments, a detailed facilities planning process was defined as part of the
Construction Grants program. The Environmental Protection Agency's environ-
mental review responsibilities of individual facilities plans are defined in
40 CFR Part 6 (Implementation of Procedures on the National Environmental
Policy Act). Additional policy and guidance documents have been issued which
provide technical guidance regarding the scope of EPA's environmental review
process.
Throughout the 1970's, environmental impact assessment methodologies were
refined, areas of concern expanded and environmental data bases accumulated.
Also, the intensiveness with which certain environmental issues were eval-
uated changed with the passage of specific federal legislation or require-
ments such as those relating to wetlands and floodplains. Secondary impacts,
those associated with the development stimulated by a Construction Grants
project (but not the project itself), became an important issue.
Beginning in 1978, EPA began delegation, a process by which many of the ad-
ministrative functions of the Construction Grants program were turned over to
State agencies. Although EPA established its role as the oversight agency of
the Construction Grants program, many of its direct environmental review
functions were delegated to the States. The Agency has always maintained
final NEPA authority to determine whether an Environmental Impact Statement
(EIS) or Finding of No Significant Impact (FNSI) should be prepared. How-
ever, in many cases where facilities plan review has been delegated, detailed
reviews are accomplished at the State level where a preliminary environmental
assessment (EA) is prepared and EPA's responsibility is carried out based
only upon its review of this often brief EA. Furthermore, the use of cate-
gorical exclusions and the elimination of Step 1 and 2 grants reflect the
evolution of EPA activities from direct scrutiny to oversight responsibili-
ties on Construction Grants projects.
As an oversight agency responsible for NEPA decisions, EPA must periodically
determine the effectiveness of the Construction Grants program and NEPA in
restoring the quality of the nations' waters and in protecting the environ-
ment. The primary purpose of this manual is to present an objective method-
ology for evaluating the accuracy of predicted environmental effects re-
sulting from Construction Grants projects. A methodology was designed such
that the accuracy of impacts predicted for a single project, group of pro-
jects or an entire program can be evaluated.
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A major result of this evaluation process will be to propose changes to the
existing environmental review process to increase the effectiveness and re-
sponsiveness to environmental issues. By fulfillment of this objective, it
is intended that EPA will increase the effectiveness of the NEPA process
through the coming decade. This manual has been developed by EPA, Region V;
however, the manual can be utilized for an analysis of completed Construction
Grants projects throughout the nation.
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CHAPTER II
METHODOLOGY
Introduction
A detailed methodology has been developed which determines the accuracy with
which planning and environmental review documents (NEPA documents) assessed
predicted environmental effects of Construction Grants projects. When the
term "NEPA documents" is used in this manual, it refers not only to the
Environmental Impact Statement (EIS), but also to the Environmental Informa-
tion Document (EID)/Environmental Assessment (EA), facilities plan, Draft
EIS, and other associated documents. Based upon the continued use of the
manual, it is EPA's intent to propose changes to the NEPA review process to
increase its effectiveness.
The process of environmental impact analysis is not an exact science. Levels
of uncertainty ranging from low to very high are associated with many of the
analytical steps. Thus, the term "accuracy", as it is used above and
throughout this document, must be defined in its most general sense.
A single methodology was developed to evaluate the entire spectrum of Con-
struction Grants projects. In general, evaluations are possible for three
types of situations: single project; aggregate of projects; and an entire
program. Specific components of the methodology include the use of: (1) a
simple set of procedures; (2) a standard set of issues for evaluations; (3)
systematic data retrieval; (4) uniform measurements; and (5) consistent docu-
mentation.
Effective use of this manual is predicated upon the identification and clear
definition of the program elements to be analyzed. This will provide the
reviewer with an additional level of understanding necessary for effective
utilization of the manual. If the definition of program elements is non-
specific or ambiguous, effective utilization of the manual is not likely.
Once the program elements have been identified, a simple procedure is pre-
sented in order that a sample of projects can be selected for application of
the methodology. An Evaluation Form (Figure I) has been developed to stan-
dardize documentation of the results of the evaluations. Another critical
aspect to the effective use of this manual is the ability to identify, gather
and manage data. Appendices A and B, Data Base Report and Data Base Manage-
ment, are included to assist the user in identifying readily available data
bases and to provide the user with a system for managing that data.
The majority of this manual consists of specific issue chapters. Each chap-
ter contains a specific methodology for evaluating one particular issue and
is presented in a uniform format which includes the following components:
introduction; data required; method; specific evaluation steps; and products
required. Appendix C presents an annotated bibliography in order to provide
the user with additional sources of information for evaluating specific en-
vironmental issues. Depending upon the evaluation goals, a few or several or
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all of the issue chapters may be used. The Interrelated/Other Issues chapter
must be included in all applications of this evaluation methodology.
Use of the manual will necessitate a combination of structured analysis with
qualified professional judgment; judgment that assumes a degree of experience
in impact assessment. Reliance upon judgment has been minimized to maintain
as much objectivity as possible. Documentation of judgmental decisions is
required within the methodology to insure an understanding of the subjective
factors influencing the evaluations.
Sample Identification
Prior to the implementation of the methodology, the reason for the analysis
should be briefly defined. The more accurate a definition, the easier it
will be to select a representative sample of projects to be evaluated. Items
such as issues, location and time span are valuable components of the defini-
tion. The common objective for every evaluation using this manual is to
answer the question: "How accurate were the impacts of a Construction Grants
project(s) predicted?" Several examples of program elements to be evaluated
might include:
0 An evaluation of all construction grants projects completed
per facility code within Region V between 1972 and 1984;
0 An evaluation of all projects completed within one state
such as Indiana;
0 An evaluation of the accuracy of predicting impacts to
wetlands and floodplains for all projects completed within
Region V;
0 An evaluation of the St. Cloud, Minnesota, project; and
0 An evaluation of all completed projects within Region V
only involving the construction of interceptors.
Once the reason for the analysis has been defined, a total list of projects
meeting those conditions must be identified. Sources of project identifica-
tion include EPA's Grants Information Control System (GIGS), regional person-
nel such as section chiefs and regional specialists; and permit records. For
several of the examples identified above, the following information was gen-
erated using these data sources:
0 Evaluation of all construction grants projects completed
per facility code within Region V between 1972 and 1984 = 693;
derived from GIGS;
0 Evaluation of completed projects affecting wetlands and
floodplains within Region V between 1972 and 1984 = 160 projects;
derived from GIGS and manual search of EPA Region V EIS Section "EA
Log" file in 1984.
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If the list of projects generated from the above sources is small, it may be
economically feasible to include all of the projects in the analysis. How-
ever, it will more often be the case that a large number of projects will be
identified as the example above illustrates. In this case, a second step is
required to generate a representative sample of the total set of projects
identified. Several sampling strategies exist to accomplish this goal.
Random sampling is the easiest method and should provide for very acceptable
results. However, if the reviewer has certain knowledge concerning specific
kinds of projects then a stratified sampling procedure may be in order.
Specific strata identified might correspond to location', size, cost and type
of project. The advantage of stratifying over random sampling is that a
smaller number of projects might be selected, but due to the efficiency of
this method, the accuracy of parameter estimates will be equivalent.
Generally, the reviewer should use a random sampling strategy, i.e., number
each project, then use a random number table to select the sample. The
sample size should be based on the reviewer's available time, budget, per-
sonnel resources, and the acceptable level of sampling error. If a more
complicated design is in order, the reviewer should consult with a statisti-
cian.
Specific Methodology
Specific methodologies have been developed to assess predicted and actual
impacts for 11 environmental issues. In addition, a chapter on Interrelated
Issues is included to assess unforeseen/unanticipated impacts and the effects
of mitigating measures. Each of the issue chapters (III-XIV) is arranged in
a uniform fashion to facilitate their use. The following sections are con-
tained in each of the issues chapters. General information is provided which
describes the intent of each section and an overview of the issue specific
methodology.
Introduction: An introduction precedes each issue chapter in order to pro-
vide a general technical overview of the subject.
Data Required: Specific data required for the evaluation of each issue is
included in this section. It is important to note that a significant amount
of this data were originally generated by engineering consulting firms and
not Federal or State agencies in the preparation of Facilities Plans and
environmental information documents. Each evaluation requires that uniform
information be available to identify the Construction Grants project. This
information should be retrieved from EPA's Grants Information Control System
(GIGS) and will insure proper identification of the project. Appendix A
describes numerous sources of computerized and manual data bases. A data
base management system is presented in Appendix B. These appendices should
be reviewed prior to the implementation of a project/program review. It also
is suggested that prior to undertaking any search for information, the re-
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viewer examine the Directory of Environmental Data Bases for Illinois,
Indiana, Michigan, Minnesota, Ohio, and Wisconsin (EPA, Region V, 1984).
Method: A general methodology for evaluating one specific issue is pre-
sented. Additional guidance is presented to assist with the integration of
quantitative information and judgmental factors.
Specific Evaluation Steps; Detailed steps to be followed for conducting
issue specific methodologies are provided. Each of the steps are linked to
facilitate completion of the Evaluation Form (Figure I). In general, the
specific methodologies are provided in a sequence of five logical steps.
Several of these steps may be combined in the issue chapters.
1. Identify Appropriate Data Base(s):
The reviewer must first determine which issues from the NEPA document
are to be evaluated. The Issues chapters (III through KIV) provide
guidance for the review of typical issues. The reviewer must be recep-
tive to unexpected, overlooked, or unpredicted impacts (Chapter XIV).
Data bases appropriate to these issues must be identified and located.
The relevant Issues chapter(s) and the Data Base Report (Appendix A)
provide guidance for this step. Generally, preference should be given
to EPA maintained data bases, then other machine readable files, and
finally, manual files. The preference for EPA-maintained data bases
relates to their being the most cost-effective and easy to access.
Also, the accuracy and the updating procedures are easily documented.
Other machine-readable files may involve user fees and are more labor
intensive to access. Manual files are substantially more labor inten-
sive to use and may require extensive searching to locate the file; how-
ever, there may be various project issues where this represents the best
data available. The selected data base(s) is entered in the Evaluation
Forms for each relevant issue.
2. Retrieve the Baseline Values for the Parameters:
A set of parameters are used to define each issue. Parameters must meet
two important criteria; they must be sensitive to the project activi-
ties, such that they will indicate the impacts of the project; and they
must be amenable to analysis, with baseline and available current data.
Each of the Issues chapters and the Data Base Report (Appendix A) pro-
vide guidance in the selection of parameters.
Once suitable parameters have been identified, the data base(s) will be
searched to locate the baseline values for these parameters*. The base-
line data must be taken as the most recent entry in the data base prior
to the publication date of the NEPA document, thus, insuring that the
proposed action does not influence the baseline. If the parameter is
subject to considerable natural variation, and if the study will use
statistical testing to evaluate the impact predictions, several data
points prior to the NEPA documents publication date must be retrieved.
Information logged on the Evaluation Form includes: parameters select-
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ed; baseline values; date of data; and the source of the NEPA docu-
ments.
3. Impact Predictions from the NEPA Document:
Generally, impact predictions are found in either the Impact Analysis
section or in the Alternatives Analysis section of the NEPA document.
The most important consideration in deriving the impact prediction is to
determine the original author's intended perception of the magnitude of
the impact(s) and the relative importance of the specific issue.
The prediction of impact will take one of three forms: quantitative
absolute, quantitative relative or qualitative. A quantitative absolute
prediction describes the value of the parameter at some future date, for
example:
"total phosphorous in the receiving water = 30 ppm after instal-
lation of project improvements,"
"service area population = 18,000 in year 1990,"
"300 acres of land reclaimed by sludge application in 1995."
A quantitative relative prediction describes the magnitude of the change
in the parameter expected by some future date, or the rate of change in
the parameter; for example:
"regional population will increase at a rate of about 15% per
annum."
A qualitative prediction describes the expected change in general terms,
without specifying the value or magnitude of the change, for example:
"downstream water quality will improve, during construction there
will be a slight increase in siltation."
Professional judgment is required to determine the quality of resource
data and to estimate magnitudes based on qualifiers. It is essential
that these judgments be fully documented including any assumptions
employed. If a particular issue is not addressed in the NEPA document,
the reviewer should assume, unless otherwise indicated, that the author
implied there would be no impact relevant to the issue.
In the case when "no impact" is predicted, it is understood that the
parameters describing the impact will change by zero units. Therefore,
if the values of parameters in question are compared before, after or
during the project, they would generally remain the same. Note that "no
significant impact" implies that some degree of impact may, in fact,
occur, but that the degree or magnitude of the impact attributable to
the project can be mitigated, if necessary, for environmentally accept-
able results.
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4. Retrieve the Current Values for the Parameters:
This step is a repetition of Step (2) except that the data to be re-
trieved are to be the most recent prior to the date of the evaluation
study and after the project has been constructed, not necessarily opera-
tional. It should be noted that short-term impacts that occur should
be included, but may be difficult to detect after the construction is
complete. It may be necessary to conduct field surveys in order to
obtain current values.
5. Evaluate the NEPA Predictions;
In this step the reviewer determines whether or not there is agreement
between predicted impacts and current values of the parameter meeting
the original author's statement of what impacts were expected. This
step is documented by a narrative statement along with the reviewer's
conclusions concerning the accuracy of the impact predictions in the
NEPA document. Results can be quantified (as a percentage) or quali-
fied in the narrative.
Products Required: The products required from the implementation of the
methodology include a fully completed Evaluation Form(s) and a narrative
statement which documents judgments and any other implications of the proce-
dures.
NEPA Review Process
It is the intent of this manual to enable EPA management personnel to propose
changes to the NEPA review process to increase its effectiveness. Changes to
the process will only become apparent after continued use of the manual
through a significant number of program evaluations representative of the
entire Construction Grants program within the United States. Recent changes
in the Construction Grants program which may have an impact on the effective-
ness of NEPA include the increased role of state agencies, the use of cate-
gorical exclusions from NEPA compliance requirements and the elimination of
Step 1 and 2 grants. As a result of the examination of NEPA effectiveness
future changes to the NEPA process might include minimal experience and edu-
cational requirements for NEPA reviewers; changes in federal/state responsi-
bilities; and changes to 40 CFR Part 6 (Implementation of Procedures on the
National Environmental Policy Act).
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EVALUATION FORM INSTRUCTIONS
1. Enter the project name.
2. Enter the Needs (facility) Number (32), NPDES (Permit) number (C2) , and
complete Grant Number to include Program Code (02), Grant Number (01),
Type (04),.Sequence (54), and Amendment (03). (GICS transaction numbers
are shown in parentheses.)
3. Enter the date of the NEPA document.
4. Check the document type. More than one type of document may be the sub-
ject of the review, e.g., amended EID's, EA's, etc.
5. Enter location in terms suitable to the issue(s) being evaluated, i.e.,
political jurisdiction for population, river basin and segment for sur-
face water quality. Include, if available, the latitude and longitude of
the vertices of a polygon defining the area concerned.
6. Enter the issue (e.g., socioeconomic) and parameter (e.g., population)
evaluated as identified in Chapters III through XIV.
7. Indicate the type of impact.
8. Provide a short description of the predicted impact as presented in the
NEPA document. Maximum length, 288 characters including blank spaces.
9. Enter the source of data used in the development of the NEPA document's
project baseline (#10).
10. Enter the date of the project baseline. Provide the baseline level of
the parameter (e.g., 1970 population, 12,000).
11. Provide the prediction of the parameter as projected or forecasted for
the end of the project life (include date) as expressed in the NEPA docu-
ment, (e.g., 1990 population, 14,500).
12. Based on the baseline data and predictions in #10 and #11, respectively,
extrapolate/interpolate the current or actual values of the parameter as
it should be at the time of study if the predicted impact is to be
reached by the end of the project life. (e.g. , 1970 baseline-population;
12,000, 1990 projected-population; 14,500, therefore, 1984 time-of-study
population should be 13,750), using a straight line interpolation.
Please note assumptions attributed for and against curved and/or straight
line projections.
13. Provide a brief description of the current level of the parameter based
on your evaluation as per the appropriate issue chapter.
14. Enter the title of the data base used or technique used to identify the
current level in #13.
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EVALUATION FORM INSTRUCTIONS
(Continued)
15. Provide your summary of the accuracy of the prediction. The first two
spaces should be the code described below.
NA = Not applicable/not an issue.
+1 = No significant difference or impact was in fact better
than expected or mitigated as planned.
-1 = Significant difference. This parameter should be examined
further. (Red flag.)
00 = Could not be evaluated.
16. Enter the date and title of the regulations governing this parameter
which were in effect during the baseline year. If the regulations have
changed, also fill in the date and title of today's regulations. Use
bibliographic format (author, title, publisher and date). If there is no
author, leave first six spaces blank. Use code of Federal Regulations
and/or Executive Order number where possible.
17. & 18. Initial and date form.
19. Enter the title of any narrative report or field investigation report.
20. Indicate where any narrative report is permanently filed (include data
base and file name, etc.), e.g., division, section, unit.
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1.
2.
3.
4.
5.
6.
7.
8.
Project Name |_
EVALUATION FORM
I I I I I I I I I I
Needs (Facility No.)
Grant No. I I I I I I
NPDES No.
Date of Document: Year | | | | Month | | j Day | | |
Type of Document: a. EIS j | b. EA | [ c. EID ] | d. Facilities Plan ) j
e. Negative Dec. [_| f. FNSI [_J
Location: (Latitude/Longitude)(degree/minute/second) or Political Jurisdiction:
I
-
-
N-
N-
N-
|
-
-
j
-
-
Pa
ra
W
W
W
meter:
_
-
-
__
-
-
N
N
N
-
-
_
-
-
_
-
-
W
W
W
Type of Impact: | | (1 = Quantitative) (2 = Qualitative)
Prediction: (limited to 288 alpha-numeric and blank character spaces)
9. Source of NEPA Document Data: I I I I I I I I I I I I
10. Baseline Conditions: Year | | | | (limited to 288 alpha-numeric and blank
character spaces)
11. Predicted for end of planning period: Year
J (limited to 288 alpha-numeric
and blank character spaces)
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EVALUATION FORM Page 2
12. Predicted for Current Year: Year |' | | | (limited to 288 alpha-numeric and blank
character spaces)
13. Actual Current Conditions: Year | | | | (limited to 288 alpha-numeric and blank
character spaces)
14. Data Base:
15. Summary: (Code | | | ) (limited to 360 alpha-numeric and blank character spaces)
16. Regulations in Effect:
A. Baseline: I I I I
Today: I I I I
B. Baseline: | | | |
Today: I I I I
C. Baseline: I I I |
Today: I I I I
17. Reviewer: | | | | 18. Date of Review: Year I | I | Month | | | Day
19. Title of Narrative Report: I I I I I I I I I I I I I I I I I I I I I I
20. Location of Narrative Report: | | | | | | | I I I I I I I I I I I I I I I I I I
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CHAPTER III
WATER QUALITY ISSUES
Introduction
The Water Pollution Control Act of 1972 redirected the Construction Grants
program in order to "restore the nation's waterways to fishable, swinunable
quality". Since this manual was developed to provide guidance in the assess-
ment of actual versus predicted impacts of Construction Grants projects, it
is appropriate that the foremost impact issue presented be water quality.
Water quality impacts of a Construction Grants project may occur during
building, as well as during operation of the facilities. They may affect
groundwater as well as surface water and may result directly from the con-
struction and operation of the project or indirectly from the development
which the project serves and/or allows to occur on previously undeveloped
land.
Water quality impacts resulting from Construction Grants projects are both
beneficial and adverse. Beneficial impacts are generally associated with the
operation of the facilities by elimination of the pollution sources and/or
improvement in the quality of existing effluent discharges to surface or
groundwater. Adverse impacts may be associated with the building and opera-
tion of the facilities or the use and development of land served by the
facilities. Examples of these are soil erosion and subsequent stream silta-
tion; replacement of natural vegetation with cultivated species or impervious
surfaces which change the quantity and quality of runoff and groundwater
recharge to local streams; and upsets or malfunctions of the facilities
caused by severe conditions or plant neglect resulting in the discharge of
excessive pollutant loadings.
The objectives of the Construction Grants program, the Water Pollution Con-
trol Act and the Clean Water Act are to effect a net beneficial impact on
water quality such that the fishable, swimmable use standards are met. Other
legislations including the Safe Drinking Water Act are concerned with pre-
serving and enhancing the quality of groundwater such that water is suitable
for human consumption.
The purpose of this chapter is to outline a method by which water quality
impacts predicted in the NEPA documents of one or more projects can be eval-
uated for accuracy against the actual impacts which have occurred. Thus, the
method is applicable only to completed Construction Grants projects upon
which NEPA documents were developed in the planning stages. Since impacts
from construction of facilities are largely mitigatable, short-term building
related impacts on water quality are not addressed. Long-term impacts due to
construction and operation of the plant or development served by the plant
are addressed in this chapter.
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Before proceeding further, the reviewer is cautioned that a very subtle dis-
tinction exists between the subject of this chapter and other related water
quality issues which are beyond the purview of this manual. For example, the
purpose of this chapter is not to determine whether the completed facilities
are in compliance with their operating permits. This is a function of the
State and the USEPA Compliance Sections and is done by evaluating reports of
plant effluent quality against the limitations set forth in the applicable
NDPES permits for a specific set of effluent parameters. Likewise, the pur-
pose is not to determine if the applicable stream or groundwater quality
standards are being achieved. This is a function of the state and the USEPA
Water Quality Surveillance Sections or Groundwater Sections and is carried
'out by evaluating sampling data against a set of state or Federal water qual-
ity standards.
The purpose of this chapter is to assess the accuracy of water quality im-
pacts predicted for Construction Grants projects in NEPA documents. This is
done by evaluating the predicted impacts on water quality against the actual
changes which occurred.
Since the impacts on groundwater, the circumstances under which they would
occur, and the methods used to assess groundwater quality are markedly dif-
ferent from those of surface waters; these two aspects of water quality will
be addressed separately throughout the remainder of this chapter.
SURFACE WATERS
Data Required
The prediction of impacts to surface water quality presented in NEPA docu-
ments will take any of three forms. A quantitative absolute prediction
states a specific value for some future time for each parameter used in the
assessment of impact. For example, "Following plant start-up and for the
remainder of the planning period, stream dissolved oxygen will meet or exceed
5.0 tag/1, except during some periods of rainfall or snowmelt". A quantita-
tive relative prediction states the impact in terms of the relative amount by
which a parameter is expected to change. For example, "Following plant con-
struction, the 100-year floodplain will be expanded by less than 1 percent".
Finally,'a qualitative prediction states the direction of impact (i.e., bene-
ficial, adverse or no impact), but does not attempt to define the magnitude
of change expected. For example, "Implementation of preferred alternative
will result in improved water quality in terms of higher dissolved oxygen and
lower pollutant concentrations".
The primary impacts on surface water quality from Construction Grants pro-
jects are defined in NEPA documents using specific chemical, physical, and
biological parameters. Since treatment plant design is based on the achieve-
ment of specific effluent limitations set forth in the NDPES permit, these
same or directly related parameters are generally used to describe the re-
sultant water quality impacts.
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In general, NEPA documents discuss long-term water quality impacts only in
relation to the impact of the operation of the proposed facilities. Since
this evaluation does not distinguish between impacts directly resulting from
plant operation and those long-term impacts caused by plant construction or
land use changes, a substantial margin of error between the predicted and the
actual is possible.
The predicted impacts to surface water quality should be derived from the
NEPA documents. If impacts are stated in quantitative relative or qualita-
tive terms, then the baseline upon which to relate the impact should also be
derived or determined. This baseline condition may take the form of a set of
"before project" water quality parameters, a set of "current upstream" water
quality parameters, or may be related to a critical or design low flow condi-
tion (e.g. , Q7/10).
If the prediction was based on a modeling effort, then the model baseline
water quality and the assumptions affecting impact prediction should be
understood. It may also be necessary to obtain the water quality data used
to support the model.
Since many Construction Grants projects involve the elimination of pollutant
sources over a large planning area, water quality data for affected waters
other than the project receiving water should be collected to assess impact.
Current or "after project" water quality data regarding the predicted impact
parameters must also be obtained. One of the most comprehensive sources of
such data is STORE!. The reviewer should request an inventory summary of
STORET data for the study area. The study area can be defined by a polygon
described in terms of latitude and longitude for each corner. The inventory
summary will identify all monitoring stations in the study area, the para-
meters monitored, the number of samples taken, the period of record, and some
summary statistics. Based on this, the reviewer can identify appropriate
stations, parameters, time frame, and other characteristics desired for a
full data retrieval.
Other sources of "before" and "after" project water quality data include
USGS, U.S. Fish and Wildlife, U.S. Forest Service, National Park Service,
various state departments associated with water resources, regional and local
planning agencies, and local water and sewerage departments. Data on pre-
dicted water quality impacts, however, can only be derived from the NEPA doc-
uments .
Method
The method consists of five basic steps: (1) determination of baseline
("before" project) water quality, (2) compilation of predicted impacts, (3)
determination of actual impacts based on current ("after" project) water
quality data, (4) determination of those impacts directly attributable to the
project as opposed to those attributable to other actions in the area, and
(5) assessment of the accuracy of impact prediction.
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The most crucial step in the method will be the comparison of actual impacts
with predicted impacts in the assessment of accuracy. The reviewer should be
aware that water quality data, particularly chemical, physical and biologi-
cal are generally obtained as grab samples or composite samples which repre-
sent conditions at a specific location and point in time. Water quality
characteristics- can and do change rapidly depending upon weather conditions,
location, season, time of day, temperature, and flow. The reviewer should
exercise caution to insure that data are reasonably comparable.
Specific Steps
For each water quality parameter used in the prediction of impacts, an eval-
uation form, as shown in Chapter II, should be completed.
1. Using the NEPA documents, define the predicted water quality impacts
of the project. Given the objectives of the Construction Grants pro-
gram, an enhancement of water quality should be predicted in all
cases. If possible, describe the predicted improvement in quantifi-
able terms such as absolute or relative concentrations of DO, BOD,
SS, nutrients, metals, organics, chlorophyll "a", or fecal coliform
bacteria. In any event, the conclusions of the NEPA document pre-
dictive technique should be reiterated. If modeling was used to
justify the project, the water quality response predicted by the
model should be described (e.g. , improved DO concentration, reduced
pollutant concentrations, reduced spatial or temporal extent of water
quality problems). If a loading analysis was used, summarize the
impact predicted for the loading reduction in terms of improved water
quality. If no analysis was used to justify the project but rather a
state policy (e.g, 3 to 1 dilution of effluent at Q7/10), obtain from
the document or calculate the expected parameter concentration for
the given critical flow condition.
2. From the NEPA documents or other appropriate sources, define the
baseline ("before" project) water quality of the planning area using
the same or comparable parameters as used in the prediction of
impacts. For chemical, physical and biological parameters, the
. reviewer should insure comparability to the predicted values relative
to flow, temperature, season, location, etc., as discussed above.
Compile the baseline water quality by location. Identify data and
parameters that indicate a water quality problem (e.g. , fish popula-
tion and stream classification) when compared to applicable stand-
ards. If possible, define the spatial and temporal extent of the
problems.
3. From STORET or other appropriate sources, determine the current or
"after" project water quality of the planning area using the same or
comparable parameters as used in the prediction of impacts. Again,
comparability of data must be evaluated by the reviewer.
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Compile the current water quality data by location.
4. Evaluate the accuracy of the NEPA water quality predictions by
comparing the predictions to the actual data. If the predictions
were made in terms of quantitative absolute values (QAV), the
difference between the predicted and actual values can be defined in
terms of a percentage accuracy as follows:
QAV: Actual Value =Comparative Value
Predicted Value
If the predictions were made in terms of quantitative relative
values (QRV), the difference between the predicted relative value and
the actual relative value can be defined in terms of a percentage
accuracy as follows:
QRV: Actual Value (Mean) to Actual Value (Mean) Comparative
Lowest Predicted Value Highest Predicted Value Range of Values
Finally, if the predictions were qualitative, the reviewer will be
required to make a professional judgment concerning the accuracy of
the prediction relative to the actual "after" project data.
In all cases, the final assessment of accuracy should be -tempered by the
reviewer's awareness of the relative margin of error or level of uncertainty
associated with the "before" and "after" project data employed. This is a
qualitative judgment on the part of the reviewer which requires a kind of
mental sensitivity analysis. The reviewer should attempt to answer in a
qualitative manner questions regarding the comparability of "before" and
"after" data, the accuracy of the sampling and analysis, the potential impact
of other non-project related pollutant sources, the existence of other data
which tends to either support or conflict with the reviewer's findings, etc,
From this exercise, the reviewer can formulate a professional judgment on the
level of uncertainty of the analysis. This should be expressed in terms of
low to very high. A low level of uncertainty would be a situation where
sampling locations, sampling technique, season and weather conditions, para-
meters tested, and laboratories were the same for the "before" and "after"
project data. A very high level of uncertainty might be indicatd where one
or all of these factors were different between the "before" and "after" pro-
ject data.
Products Required
Evaluation forms must be completed for each parameter/location to be used in
the assessment of predicted impact accuracy. A narrative explanation of-the
procedual steps taken in the evaluation, including all assumptions, judg-
ments and deviations made by the reviewer should also be prepared.
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GROUNDWATER
Data Required
The prediction of impacts to groundwater quality presented in the NEPA docu-
ments of Construction Grant projects may also take the form of quantitative
absolute, quantitative relative or qualitative predictions as defined under
Surface Water. Unlike surface water quality issues which are paramount in
virtually all Construction Grants NEPA documents, impacts to groundwater as
an issue, generally, only occur in cases where; 1) the project was justified
on the basis that a substantial groundwater pollution source (e.g., malfunc-
tioning on-site systems) would be eliminated, or 2) the potential for signi-
ficant adverse impact to groundwater quality exists (e.g. , wastewater or
sludge land application or sludge landfill).
The predicted impacts to groundwater should be derived from the NEPA docu-
ments. If impacts are stated in relative or qualitative terras, then the
baseline upon which to relate the impact should also be derived or deter-
mined. Baseline conditions may take the form of a "before" project ground-
water quality characterization based on well sampling in the project area or
may simply consist of quality characteristics "typical" for the aquifer.
If the prediction was based on a geohydrologic model, the model input data,
the baseline water quality and the assumptions affecting the model's pre-
dictive capabilities should be understood.
The primary impacts on groundwater quality from Construction Grants projects
are defined in terms of specific chemical, physical and biological para-
meters. Typically, local and state health departments routinely test new or
existing domestic wells for total coliform bacteria (TC) and possibly ni-
trates (N03) in some areas; thus, data from this source is generally
limited to these parameters. Where groundwater contamination or the poten-
tial for contamination exists, tests for several other constituents may have
been conducted to serve as a baseline for a monitoring program or to deter-
mine the existence of contamination. Constituents which .may be of concern in
Construction Grants projects include: BOD, COD, Total Nitrogen, Nitrate
Nitrogen, Total Phosphorus, Total Dissolved Solids, pH, Alkalinity, Sodium
Absorption Ratio (SAR), Total Coliform, various metals, cyanide, and organic
compounds.
The current or "after project" groundwater quality data regarding the pre-
dicted impact parameters must also be obtained by the reviewer. In projects
where groundwater quality is at risk, the best source of this information
would be from an on-going monitoring program associated with the operation of
the facilities. If no monitoring program has been conducted, requests should
be made from the county and state health departments and regional planning
agencies regarding any routine groundwater testing in the area or complaints
of contaminated wells. If contaminated well data does exist in health de-
partment files for the project's vicinity, a project related origin of the
contaminants or a project related impact of changing geohydrology must be
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documented before this data can be used to assess the accuracy of impact
analysis.
In projects where groundwater quality is expected to be enhanced, the best
source of data would be local and state health departments. Quantitative
data would require actual test results, while a qualitative impact might be
verified by comparing the annual numbers of contaminated wells discovered in
the project area for the "before" and'"after" project condition.
Method
As with surface water, the groundwater methodology consists of five basic
steps: (1) determination of baseline ("before" project) water quality, (2)
compilation of predicted impacts, (3) determination of the actual impacts
based on current ("after" project) groundwater quality data, (4) determina-
tion of those impacts directly attributable to the project as opposed to
those attributable to other actions in the area, and (5) assessment of the
accuracy of impact prediction.
The most crucial step in the method will be the comparison of actual impacts
to predicted impacts in the assessment of accuracy. The reviewer should be
aware that the travel time of constituents in groundwaters is slow and mixing
is not significant when compared to surface waters. A sample taken from a
well may reflect surface inputs from several years before sampling and may
not necessarily be associated with the operation of the facilities. Also,
groundwater flow dynamics and the factors which influence quality are much
less defined than for surface waters, thus, a substantial margin of error
between the predicted and actual impacts may exist. For this reason, on-
going groundwater monitoring programs are often required where there is a
risk of contamination from the operation of a project. Where quantitative
impacts are defined, the reviewer should insure that the "after" project data
are reasonably comparable to the baseline data in terms of location and
depth. Ideally, "before" and "after" samples from the same set of wells
should be evaluated.
Specific Steps
For each groundwater quality parameter used in the prediction of impacts, an
evaluation form, as shown in Chapter II, should be completed.
1. Using the NEPA documents, define the predicted groundwater quality im-
pacts of the project. These could range from substantial enhancement to
severe degradation. If possible, describe the predicted improvement in
quantifiable terms such as absolute or relative constituent concentra-
tions. The conclusions of the NEPA document predictive technique should
be reiterated. If modeling was used to predict the impacts, the water
quality response predicted by the model should be described. If a load-
ing analysis was used (e.g., nitrogen loadings for a land application
systems), summarize the predicted impact in terms of groundwater con-
stituent concentrations.
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2. From the NEPA documents or other appropriate sources, define the baseline
("before" project) groundwater quality of the project area using the same
or comparable parameters as used in the predictions of impacts. For
chemical, physical and biological parameters, the reviewer should insure
comparability to the predicted values relative, to well locations and
depth.
Compile the baseline groundwater quality data by location. Identify data
and parameters that can be used to indicate a groundwater impact.
3. From appropriate sources, determine the current or "after" project water
quality of the project area using the same or comparable parameters as
used in the prediction of impacts. Again, comparability of data must be
evaluated by the reviewer.
Compile the current groundwater quality data by location and depth.
4. Evaluate the accuracy of the NEPA groundwater quality predictions by com-
paring them to the actual data. If the predictions were made in terms of
quantitative absolute values (QAV), the difference between the predicted
and actual values can be defined in terms of a percentage accuracy as
follows:
QAV: Actual Value = Comparative Value
Predicted Value
If the predictions were made in terms of quantitative relative values
(QRV), the difference between the predicted range of relative values and
the actual relative value can be defined in terms of a percentage accura-
cy as follows:
QRV: Actual Value (Mean) to Actual Value (Mean) = Comparative
Lowest Predicted Value Highest Predicted Value Range of Values.
Finally, if the predictions were qualitative, the reviewer will be re-
quired to make a professional judgment concerning the accuracy of the
prediction relative to the actual "after" project data.
In all cases, the final assessment of accuracy should be tendered by the
reviewer's awareness of the relative margin of error or level of uncertainty
associated with the "before" and "after" project data employed. This is a
qualitative judgment on the part of the reviewer which requires a kind of
mental sensitivity analysis. The reviewer should attempt to answer in a
qualitative manner questions regarding the comparability of "before" and
"after" data, the accuracy of the sampling and analysis, the potential impact
of other non-project related pollutant sources, the existence of other data
which tends to either support or conflict with the reviewer's findings, etc.
From this exercise, the reviewer can formulate a professional judgment on the
level of uncertainty of the analysis. This should be expressed in terms of
low to very high. A low level of uncertainty would be a situation where
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sampling wells, technique, parameters tested, and laboratories were the same
for the "before" and "after" project data. A very high level of uncertainty
might be indicatd where one or all of these factors were different between
the "before" and "after" project data.
Products Required
Evaluation forms must be completed for each parameter/location to be used in
the assessment of predicted impact accuracy. A narrative explanation of the
procedual steps taken in the evaluation, including all assumptions, judg-
ments, and deviations made by the reviewer should also be prepared-.
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CHAPTER IV
WETLAND ISSUES
Introduction
Wetland areas are protected under several Federal statutes, an Executive
Order and various Agency regulations. The primary directive -was established
in Executive Order 11990, Protection of-Wetlands (42 FR 26961; May 25, 1977).
This order directs Federal agencies to insure that their actions do not dim-
inish, but rather restore, preserve, and enhance the natural and beneficial
values of wetlands. The order instructs Federal agencies to avoid new con-
struction in wetlands except where no practicable alternative is available.
In cases where such construction cannot be avoided, mitigative mesures must
be adopted and special public notice given. Because of this regulatory
emphasis and the environmental importance of these areas, it is essential to
monitor the impact of Construction Grants projects on wetlands.
The purpose of this chapter is to provide a method by which the reviewer can
evaluate the accuracy of predicted impacts on wetlands as addressed in NEPA
documents. It provides a method of comparing those parameters identified as
being the primary indicators of wetlands issues in a "before" and "after"
project context. In general, the wetlands issues will require the use of
manual data files. The data required will vary considerably, as the impacts
tend to be site-specific.
The primary impacts of Construction Grants projects on wetlands are loss of
wetland acreage in the project area and the degradation of wetlands caused by
increased siltation rates, changes in nutrient loadings or direct construc-
tion related activities (e.g. loss of vegetation, channelization, etc.).
Parameters which can be used to monitor direct impacts to wetlands may be
divided into two groups; 1) those which reflect direct changes in wetlands as
a whole, such as total acreage, alterations in shape, or changes in surface
or subsurface drainage patterns, and 2) those which reflect direct changes to
specific portions of the wetland, such as construction impacts on the extent
and location of vegetation (e.g., cutting or removal of wooded species for
pipeline routing).
Secondary impacts may also occur, including changes in wildlife populations,
aquatic species, encroachment, changes in groundwater recharge or discharge,
or groundwater quality. While the secondary impacts may dictate monitoring
for change, these evaluations are addressed in other more appropriate chap-
ters of this document. For example, encroachment is a growth related phenom-
enon and, therefore, would be addressed under the socioeconoraic chapter of
this document. Likewise, methodologies for determining the magnitude of
change in wildlife habitat, aquatic species, groundwater recharge, etc. are
discussed in their respective chapters.
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Other issues surrounding wetlands may include compliance with various Fed-
eral, state or local regulations, as well as applicable mitigating measures.
While the importance of these issues should not be downplayed, they are
separate issues not to be confused with primary or secondary impacts. Any
impacts resulting from regulatory issues will be reflected in the planning
process and mitigating measures.
It should be noted that the method does not provide the reviewer with a sys-
tem to predict wetlands impacts for a proposed project, but only for evalua-
ting the accuracy of NEPA impact predictions relative to the -actual impacts
of the completed project.
Data Required
The data required include those data elements from state and/or local agen-
cies or university studies which are pertinent to the site-specific predicted
impacts.
Specific data required will be maps or aerial photos of the wetland(s) before
and after the project. These maps/photos will be used to identify the boun-
daries of the wetlands, the total area (acreage) occupied by wetlands, drain-
age patterns, and the extent and location of vegetation within the wetlands.
These data may be -obtained through a number of sources and these will vary
from project to project. In order to assist the reviewer in data search ef-
forts, the following procedure is recommended for the procurement: of wetlands
data.
The reviewer should first examine the NEPA documents to identify original
data sources and determine their applicability for use in conjunction with
the methodology presented in this chapter. In many cases, the level of de-
tail presented in NEPA document figures may not provide enough detailed data
for analytical purposes. If NEPA document sources are insufficient, the fol-
lowing agencies and data sources should be contacted to determine if wetland
data are available.
0 USEPA EMSL (Environmental Monitoring and Support Laboratory).
° U.S. Fish & Wildlife Service and/or State DNR, Fish and Game
Departments - Wetlands maps developed as part of the National
Wetlands Survey.
0 USGS - Aerial photography summary record system, index to
aerial photography.
0 USGS and/or State DNR, Fish & Game Departments and/or State
EPA. Land use, land cover maps.
0 Local agencies such as the local Planning Commission, County
Engineer, District Offices of DNR, or Fish & Game or EPA.
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0 As a final resource, the reviewer may also utilize data presented
in the local SCS Soil Surveys.
"Before" and "after" project data should be obtained from the same source if
possible.
Method
The method consists of five basic steps; (1) determination of baseline ("be-
fore" project) conditions, (2) compilation of predicted impacts, (3) deter-
mination of actual impacts based on current ("after" project) data, (4)
determination of those impacts directly attributable to the project as op-
posed to those attributable to other actions in the area, and (5) assessment
of the accuracy of impact predictions. The -predicted impacts are derived
solely from the NEPA document(s) for the project. The predictions may take
any of three forms: quantitative absolute (or a statement of a specific
value of the parameter at some future date), quantitative relative (or a
statement of the relative amount by which the parameter is expected to
change) or qualitative (a statement which gives an indication of how the
parameter may change, without specifying the magnitude of the change). The
actual impacts are derived by comparing data which represents the "before"
and "after" project conditions. These data may be obtained from existing
data files, or from field studies. The comparison of the two sets of data,
the predictions and the actual impacts, and the evaluation of those results
is the crux of the method.
The most crucial step in the evaluation method is the derivation of the pre-
dicted impacts. The reviewer must exercise care to insure that the derived
impacts agree in spirit with the original author's intent as expressed in the
NEPA documents. This will often require that the reviewer exercise judgement
in interpreting the intent of qualifiers (such as slight, insignificant, sub-
stantial, etc.) commonly used in qualitative statements of predicted impacts.
The only exception is the use of "no impact" or "undetectable" in a qualita-
tive statement. "No impact" can always be taken as a quantitative relative
statement that the magnitude of the change is zero. Similarly, the reviewer
may reasonably infer that an "undetectable" impact is a quantitative relative
prediction of a change of zero magnitude.
Specific Steps
For each wetland issue parameter used in the prediction of impacts, an evalu-
ation form, as described in Chapter II, should be completed.
1. Using the NEPA documents, identify the counties and townships in which
impacts are expected to occur. Most wetlands data are amendable to re-
trieval on the basis of the township involved, so every reasonable effort
should be committed to determining the township(s) where the impacts will
IV-3
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occur. This information concerning location should be available in the
"Description of the Effects of the Proposed Action" or the "Description
of the Proposed Action" sections. In some cases, it will be in the
"Analysis of Alternatives" section. Describe the baseline "before" pro-
ject condition. Where NEPA document authors have omitted wetlands data,
the reviewer may be required to independently develop baseline as well
as post-project wetlands data.
2. Identify the predicted impacts. The NEPA document(s) must be reviewed to
determine exactly what the author(s) predicted. The statements will gen-
erally be either qualitative or "no impact" type statements. "No impact"
type statements are easily identified in NEPA documents and generally in-
clude a statement such as "wetlands will not be affected" or "no impacts
to the wetlands are anticipated", for example:
"Pursuant to 40 CFR Part 6, Appendix A - Statement of
Procedures on Floodplain Management and Wetlands Protection,
the Akron Composting Demonstration Project for the City of
Akron has been reviewed to determine what effects, if any,
will be caused by construction of the proposed composting
facility on a portion of the floodplain of the Cuyahoga River.
It was found that wetlands will not be affected by the proposed
project."
(Source: FNSI, Akron Ohio, Phase II Solids Handling Facility,
Summit, Ohio, August 1983)
Qualitative impacts describe the type of predicted change, but do not expand
on or define the specific or relative magnitude of the projected change.
"There will be an insignificant loss of wetlands and associated
terrestrial and aquatic biota as a result of berra construction along
the edge of the wetland.", or "A section of wooded species will be
removed from the southern portion of the wetland to accommodate
pipeline routing. The amount of vegetation removed, however, will
only be slight when compared to the total vegetation within the
wetland."
(Hypothetical)
Quantitative absolute predictions of wetlands impacts are easily recognized,
for example:
"0.5 acres of wetlands will be lost. This is a vernal pond with
no surface connection to the nearby, extensive backwater wetlands
[This example was paraphrased from a wetlands fill permit
application to a state DNR, for a residential development rather
than a. construction grants project.]
Quantitative absolute predictions would be expected to describe the acreage
of wetlands in the study area after the project improvements have been imple-
IV-4
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merited. Note chat wetlands may actually increase in some case such as where
wetlands are created to treat residual solids.
Quantitative relative would be similar to quantitative absolute except that,
rather than specifying a numerical value for the impact, it is described rel-
ative to another reference point. "The area will double" or "less than 10%
of the area would be affected", are examples of quantitative relative state-
ments. (Hypothetical)
3. Retrieve the wetlands data for the most recent date prior to the NEPA
documents and for the most recent date after the installation of the pro-
ject improvements. As previously discussed, the data collected will
depend upon the data available, but, in any event, will require maps or
aerial photos of the area which delineate the extent and boundaries of
the wetland(s). The boundaries can then be planimetered or measured by
a square count method to determine the area of individual and aggregate
wetlands in acres or other appropriate units of measurement. The extent,
configuration and drainage patterns of the wetlands can also be deter-
mined using this procedure. In order to determine construction or other
related impacts on the extent and location of vegetation, either aerial
photos or narrative descriptions of these features must be reviewed.
If post installation data cannot be found, a data collection field study
will probably be required. If data prior to the preparation of the NEPA
document cannot be found in appropriate state (e.g., DNR or equivalent)
or local agencies and are not in the affected environment section of the
NEPA document, the data should be obtained from remote sensing imagery
taken prior to the date of the NEPA document with the assistance of local
expertise (State DNR, Fish and Game, Forester; U.S. SCS, Ag. Extension
Service; University departments).
4. A comparison of the predicted impacts with the actual data will provide
an estimate of the accuracy of the prediction. This comparison; however,
must take into account the margin of error and level of precision which
can be obtained from the methods used. Examples of potential error in-
clude the accuracy of the planimeter (this is supplied by the manufac-
turer) , seasonal fluctuations in water levels and resulting boundary
definition of wetlands, scale of maps, and aerial photos and human error.
While this is not an exhaustive list of potential sources of error, it
does point out some factors which increase the level of uncertainty.
The reviewer should, to the extent possible, determine the degree of
accuracy inherent in all values used in the comparisons as this will
influence the reviewer's evaluation of the accuracy of the predictions.
If the statement of impact was qualitative, reviewer judgment will be
required to resolve the extent to which the actual data reflect the
degree of impact perceived by the NEPA document author(s) in the descrip-
tion of the anticipated impact. In some cases, it may not be possible to
determine the level of accuracy of predicted values and therefore, will
IV-5
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require a subjective judgement to develop a reasonable estimate of the
degree of accuracy which could be expected.
Products Required
Appropriate evaluation forms should be completed for each individual pre-
dicted impact•evaluated. A narrative explaining the procedural steps, in-
cluding justifications of any and all judgments involved, and a discussion of
the implications and results of the evaluation should be prepared.
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CHAPTER V
FLOODPLAIN ISSUES
Introduction
Floodplains are protected under several Federal statutues , an Executive Order
and various Agency regulations. The primary directive was established in
Executive Order 11988, Floodplain Management (42 FR 26951; May 25, 1977).
This order directs Federal agencies to insure that their actions do not dim-
inish, but rather restore, preserve, and enchange the natural and beneficial
values of wetlands and floodplains. The order instructs Federal agencies to
avoid new construction in floodplains except where no practicable alternative
is available. In cases where such construction cannot be avoided, mitigative
measures must be adopted and special public notice given. Because of this
regulatory emphasis and the environmental importance of these areas, it is
essential to monitor the impacts of Construction Grants projects on flood-
plains.
This chapter provides the reviewer with a method for assessing the accuracy
of NEPA predicted impacts on floodplains. Floodplain impacts occur when some
topographic change occurs in the floodprone area that, in turn, changes the
flood staging area, i.e., the river elevation and surface area covered by
floodwater in a river valley. Such impacts may result in damage to crops,
land and/or structures or may temporarily restrict or impair transportation
or certain land uses. The impact assessment may include, but is not limited
to, estimates of the number or extent of structures damaged, the dollar loss
to property and cropland, and/or the extent of disruption to traffic flow
(from flooded streets in floodplains). The environmental standard against
which impact is usually measured is the 100-year floodplain boundary.
The discussion of floodplain impacts in NEPA documents may indicate the loss
of floodplain acreage, but may not measure or predict any other impact from
the project unless flood hazard is a significant issue. This document may
state that mitigating measures will reduce anticipated floodplain impacts,
such as construction of a retaining wall, berra or a floodflow channel.
While direct impacts to floodplains are the subject of this chapter, direct
and indirect impacts may be identified with other environmental issues in-
cluding, but not limited to, biological resource values, cultural resource
values, and water resource values. The reviewer should check sections of the
NEPA document appropriate to these issues to determine whether any indirect
impacts to floodplains were predicted.
Data Required
Almost all of the data available for floodplains must be retrieved manually
on a local, state, or regional level.
V-l
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If a local government or urbanized area has applied for Federal flood in-
surance, floodplain maps may be available from Che Federal Emergency Manage-
ment Agency (FEMA) which operates the National Flood Insurance Program.
These Flood Insurance Rate Maps, based on detailed engineering studies (many
of which were done by the Array COE), indicate 100-year and 500-year flood
hazard areas. The maps are updated as necessary. They may be obtained
through EPA or the regional FEMA offices or the State DM library; first by
county, then by municipality.
If this map source is not available, USGS floodprone area maps may be ob-
tained by the 7-1/2 minute topographic quadrangle name from the State USGS
office or State geological survey. These maps provide engineering estimates
of the 100-year flood area and are updated periodically.
Historical flood data are available, but fractionalized. The State DNR (or
state water resource agency) may have historical profiles on past flood
events. The state USGS office maintains a computerized Peak Flow File, up-
dated annually, as well as scattered data on specific flood evemts. Local
flood history may be recorded on floods of smaller magnitude by the city,
county, or local planning agency (e.g., City or County Engineer or County
Drain Commissioner). The county USDA-SCS office may have technical flood
data if they have been involved in any local floodplain management studies.
In addition, a current land use or topographic map will be needed to identify
any changes or development in the floodplain since the NEPA document.
Method
The method consists of five basic steps; (1) determination of baseline
("before" project) condition, (2) compilation of predicted impacts, (3)
determination of actual impacts based on current ("after" project) data, (4)
determination of those impacts directly attributable to the project as op-
posed to those attributable to other actions in the area; and (5) assessment
of the accuracy of impact prediction.
The reviewer should locate the predicted impacts from the floodplain section,
or indirectly from related environmental issues, of the NEPA document(s). If
floodplain impacts have not been predicted, the reviewer will need to locate
basic floodplain data. The predictions may take one of three forms: 1)
quantitative absolute, 2) quantitative relative, or 3) qualitative.
A quantitative absolute impact measures the degree of impact at some future
date. As an example:
"Floodplains are protected from development by the HUD
Flood Insurance program which restricts further develop-
ment in communities accepting the assistance. All of
the local governments in the Study Area have been accepted
into the program, and as a result, no impact is anticipated."
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(Source: Environmental Analysis Report, Lehigh County and
Allentown, PA, 1976)
Another example:
"The results of this (100-year floodplain) analysis indicate
a stage increase at a cross section located at the pond site
of ...0.2 feet."
(Source: FNSI, Carver, Minnesota, 1982)
A quantitative relative impact describes the magnitude of change from the
baseline data of a 100-year floodplain boundary:
"These methods would eliminate less than 1% of
the available floodplain storage acres and are
not expected to alter flooding patterns."
(Source: SIS, Portage, WI, 1979)
In this instance, the reviewer needs to locate further data, specifically the
total floodplain acreage under discussion.
A qualitative impact suggests the direction of change, but not the magni-
tude:
"A portion of Site B is located within the Corps of
Engineers, year 2000, 100-year floodplain. This can
be mitigated by flood control measures and is con-
sidered insignificant from an environmental perspective."
(Source: South Canadian Wastewater Treatment Facility,
Oklahoma City, OK, 1982),
or
"While no floodplain maps are available, local floodplain
history suggests that any further construction in the
floodway will slightly increase the intensity of upstream
flooding."
(Hypothetical)
Specific Steps
1. Determine from the NEPA documents the baseline condition and predicted
impacts to floodplains by the project. If possible, define the impacts
in terms of acres (area) or acre-feet (volume) of floodplain lost due to
construction, or acres of floodplain expansion created by the project.
Impacts may also be defined in terms of a change in 100-year flood eleva-
tion.
2. Retrieval of actual impacts may not be possible unless a flood of 100-
year magnitude has occurred and has been documented since the project
V-3
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was implemented. If a 100-year flood event has occurred, collect new
data in terms of the predicted impacts (e.g., loss of cropland, loss of
historic site, etc.). Determine if a new or updated floodplain map has
been published since the pre-project data. If no floodplain data update
are available, the reviewer should document his or her audit
appropriately. If the city or county has kept records of smaller floods
of known magnitude, those data might be useful.
3. Evaluation. Several approaches are suggested to determine if predicted
impacts were accurate:
(a) Compare old and new floodplain maps (if both are available) to see
if there are any changes in flooding patterns. The reviewer must
carefully determine if any expansion of floodprone area was due to
the project (either primary or secondary impacts). When two maps
are being compared, it should be kept in mind that some margin of
error may be inherent when site anaylsis require multiple scales.
(b) If there is local flood history (pre- and post-project), determine
if flood intensity can be associated with the Construction Grants
project.
(c) If no 100-year flood events have occurred, and/or no new mapping or
smaller flood history has been recorded, then the minimum determina-
tion that can be made is to verify the physical/topographic predic-
tions made in the NEPA document. One example would be the examina-
tion of predicted impact areas on an updated land use or topographic
map.
Products Required
An evaluation form must be prepared for each predicted impact and for every
parameter discussed in the NEPA document. A narrative should accompany the
analysis which interprets the evaluation form.
V-4
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CHAPTER '/I
BIOTA ISSUES
Introduction
This chapter presents a method which allows the reviewer to assess the accu-
racy of NEPA impact predictions related to biota issues by comparing the
actual impacts with the predicted impacts. For the purposes of impact
assessment studies, biota are usually divided into three groups: (1) Terres-
trial (plants and wildlife), (2) Aquatic (phytoplankton or algae, benthic
invertebrates and fish) and (3) Rare, Threatened and Endangered species.
Within each group, the biota issues may include individual species,
populations, natural communities, critical habitats and/or ecosystems.
Impacts to aquatic and terrestrial biota (or their habitats) can stem from
the indirect consequence of changes in water quality (or flow), land use or
growth and development. Because of the connection with these other impact
areas, the reviewer should take care not to- identify these other impacts as
biotic impacts. For example, a biotic impact would be the predicted change
in aquatic species composition and not the reduction in nutrients to a lake
that affects species change. Another example of biotic impact is the des-
cription of the kind of terrestrial habitat to be destroyed and not the land
use impact of a certain number of acres of forest land to be lost. Impacts
to the aquatic and terrestrial biota of floodplain and wetland habitats are
included in this chapter,,
Rare, threatened, and endangered species are protected by Federal and state
law. Preservation of habitat is critical to the protection of a species.
Rather than estimating numbers of a species, these impacts are often pre-
dicted in terms of the potential loss (or enhancement) of critical habitat
.or specific conditions which are .crucial to the survival of a sensitive
species in the project area. For example, an impact may address the poten-
tial destruction of known breeding, spawning or nesting grounds, or the loss
of land area containing a recorded sighting of a rare plant species.-
Data Required
The data required should be derived from manual data files of Federal (U.S.
Fish and Wildlife Service - USFWS) and State (Department of Natural Resources
- DNR, Fish and Game, Department of Conservation) agencies and from local
authorities (typically a university or natural history museum). The reviewer
must collect updated information on the parameters presented in the NEPA doc-
ument (s). Typical data might include rare, threatened and endangered species
information, aquatic and terrestrial species lists, species ranges, popula-
lation densities and descriptions of natural communities and unique habi-
tats.
VI-1
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Although there have been proposals to computerize the Federally sponsored
data files for biota, these data are not generally available in machine read-
able form. The major stumbling blocks appear to be the lack of standarized
methods for data collection and the absence of any systematic surveys (except
for commercial timber resources).
There are potential sources of data on rare, threatened, and endangered
species. The U.S. Army Corps of Engineers (COE) maintains a computerized
system called the Sensitive Wildlife Information System (SWIS). Information
is organized by state and then by sensitive species. The system is operated
in conjunction with the USDA-SCS, USFWS, U.S. Forest Service and the Federal
Highway Administration. Also, the State of Michigan processes computerized
data on Federal and State endangered and threatened species, as well as prime
habitat and natural areas in its Michigan Natural Features Inventory, Post
Office Box 30028, Lansing, Michigan 48909. Numerous states publish books,
pamphlets, and lists of rare, threatened and endangered species. Other
states may have similar inventories available.
Method
The method consists of five basic steps; (1) determination of baseline ("be-
fore" project) conditions, (2) compilation of predicted impacts, (3) deter-
mination of actual impacts based on current ("after" project) data, (4)
determination of those impacts directly attributable to the project as op-
posed to those attributable to other actions in the area, and (5) assessment
of the accuracy of impact prediction.
The reviewer must derive the predicted impacts solely from the NEPA docu-
ment(s) and/or any supporting documents. Sometimes needed information, such
as species list, are not found in a NEPA decision document but can be located
in an appendix or other support document.
There is no standardized way in which to predict biotic impacts. In most
documents, the presentation of impacts was determined by the data available
at the time. In some cases, an extensive historical baseline may be avail-
able or, perhaps, a quantitative biological survey was done as part of the
planning. In other cases, a reviewer may find specific information regarding
certain species in the project area, e.g., mature hardwoods, game species for
fish and wildlife, nesting habitats of certain birds. These data may or may
not be quantified. In any case, the reviewer is likely to find predicted
impacts described qualitatively with respect to specific baseline data.
If there is no recorded data base for a project area, the document may pre-
sent a general discussion of what biota might be expected based upon an
observation of habitat. Predicted impacts are then qualitative based upon a
data base of professional conjecture. It is necessary, therefore, for the
reviewer to verify baseline data when qualitative impacts are presented in
order to further understand the origin or basis of the descriptive impact.
VI-2
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Basic data may have been altered, interpreted, or manipulated for project
use. For example, (1) from an aquatic species list, data on only one indi-
cator species may be discussed, such as the salmon, (2) a species list may be
reorganized to indicate pollution tolerant/intolerant species or (3) data on
number and kinds of species may be used to produce a diversity index or other
data used for a habitat index. Any of the above situations requires that the
reviewer uncover the method of data manipulation sufficiently in order to
collect the appropriate data updates to repeat the manipulation and under-
stand the limitations and/or assumptions inherent in the methodology. If
possible, it is also useful to understand the limitations of the biological
data base.
The predicted impacts may be quantitative absolute, quantitative relative or
qualitative. Quantitative absolute impacts predict the value of a parameter
at some future date. This includes the inference of "no impact" or "zero
change", for example:
"Following completion of construction activities, the
wildlife community in the vicinity of the proposed
WWTP would be expected to be very similar in composi-
tion to that of the preconstruction community."
(Source: Draft EIS Portage, WI, 1979)
The reviewer may reasonably infer that this means the change will not be dis-
tinquishable from normal season to season variation.
or
"No habitat known to support any designated threatened
or endangered species has been identified within the
planning area."
(Source: EA South Canadian Wastewater Treatment Facility,
OK, 1982)
Quantitative relative impacts predict the magnitude of change in a parameter
by some future date:
"Land requirements for the construction of WWTP
facilities may destroy nearly 10% of the known habitat
in the county for the endangered species Haliaeetus
leucocephalus, the bald eagle."
(Hypothetical)
Qualitative biota impacts are the most common and they predict the direction
-of change in a parameter without estimating the magnitude of that change:
"This (water quality) improvement will be accompanied
by a gradual return of desireable, pollution-sensitive
species to these streams."
(Source: EIS Oaks Wastewater Treatment Facility,
Montgomery Co., PA, 1975)
VI-3
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or
"This (removal of septic tank effluent) improvement
will reduce the build-up of high BOD sediments in
Lake Winnisquam and possibly result in the reduction
of the bluegreen algae blooms common during the
summer months."
(Source: EIS Winnipesaukee River Basin, NH, 1976)
or
"A few animals would perish."
(Source: Draft EIS Portage, WI, 1979)
or
"Related impacts of all alternatives on the Iowa
darter would therefore be expected to be insigni-
ficant."
(Source: Draft EIS Nettle Lake - Rural Lakes
Project, OH, 1981)
Specific Steps
1. Because the relevant parameters tend to be project-specific, the reviewer
must determine which parameters were used as indicators of biotic impact
in the NEPA document(s). The reviewer also needs to identify from the
NEPA document the geographic areas of potential indirect impact, includ-
ing bodies of water and terrestrial habitat.
2. Data concerning the identified parameters must be retrieved from the
governmental agencies (Federal or state) or local authorities previously
discussed. In collecting these data, the reviewer should obtain data
taken "after" .project completion to compare with pre-project data.
In the category of rare, threatened and endangered species, determine
from available data whether the species status is the same (e.g. , Is it
still on the list? Is it still threatened?). Verify what, if any, habi-
tat losses or gains have occurred, as well as sightings or counts. If no
post-project data are available, the reviewer must consider alternative
data collection. Before undertaking any field investigation, the poten-
tial benefits of the data to be collected must be weighed against the
costs of such a study (as well as evaluating the level' of confidence in
the baseline data). Local universities, nature groups, or planning com-
missions may have unpublished data or personal accounts that are usable.
VI-4
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Compare Che predicted impact and the actual impact to determine the accu-
racy of the prediction. For impacts which were quantified, the compara-
tive evaluation must take into account the margin of error and level of
uncertainty that were assumed in the original predicted impact. If
species numbers are being compared (density, diversity) there may be a
great deal of fluctuation in impacts because of seasonal variation, samp-
ling method, and simply the inherent variability in extracting a static
number from a dynamic living system. Supplementary data, such as a
series of data points over time (if available) may be helpful in inter-
preting a trend. If quantified impacts involve an estimation of acreage,
sources of error discussed in Chapters IV and V regarding the use of
measuring instruments are applicable here.
When the statement of impact is qualitative, reviewer judgment is
required to interpret the real differences, if any, between predicted and
actual impacts. If a qualitative impact, such the direction of a trend,
was predicted on quantitative data, the reviewer can use the baseline
data alongside the actual quantitative data to assess whether the trend
was accurately predicted.
If predicted impacts are qualitative and based on qualitative data (e.g.,
minimal predicted impact based upon species thought likely to be found in
area), it may be difficult to decide what actual data to retrieve. The
reviewer may choose to compare population changes in game species over
time as a way to assess the degree of impact. At a minimum, the reviewer
could verify the predicted acreage loss or extent of original habitat
alteration with the use of updated topographical or aerial maps.
Products Required
An evaluation form must be" completed for each parameter examined. In addi-
tion a narrative, which will allow the reader to retrace the analytical
steps, must accompany the forms.
VI-5
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Blank Page
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CHAPTER VII
SOCIOECONOMIC ISSUES
Introduction
The predominate socioeconotnic issues addressed in NEPA documents relating to
Construction Grants projects are: (1) population, (2) land use, (3) employ-
ment, (4) land or property values, (5) user charges as they relate to house-
hold income and (6) displacement and/or induced growth. Other issues may be
discussed. Likewise, some issue areas may not be discussed because of an
assumption (correct or incorrect) that there will be no impact.
Population issues are normally addressed by providing population forecasts
over time. Regulations require that forecasts at least cover the project
life. In most cases, this is assumed to be twenty years.
Population forecasts used in NEPA documents usually present the population at
5-10 year intervals. Often several forecasts are given, but one set of fore-
cast numbers should have been identified as the "design population or popula-
tion equivalent". They should not be confused with the planning area or ser-
vice area population since facilities may or may not be designed to serve the
entire planning area or service area population.
It should be noted that population projections in Construction Grants Facili-
ties Plans are not impact analyses, (as may be for NEPA documents written for
other types of public investment), but are baselines for the analysis of im-
pacts. As such the population projections may be the cause of inaccurate im-
pact assessments and are, therefore, addressed in this chapter.
Land use issues are much like population in that the predictions are the
baseline for impact predictions. The forecast landuse, if the project were
not built, is the baseline for the impact of the project on landuse. Care
should be taken when identifying the predicted impacts, not to confuse the
impact of the landuse forecast on the project design. Landuse forecasts are
used to develop interceptor routings, plant locations,_sludge disposal facil-
ities and other elements of the facilities plan.
Employment issues relate to impact analysis in several ways. The NEPA docu-
ment statements on employment must be carefully read in order to correctly
interpret what is being described. Regional planning agencies often use
employment as the major determinant of population forecasts. Other agencies
forecast employment as a result of predicted population growth. It should be
noted that neither of these situations forecast the impact of the project on
employment.
The issues surrounding land values relate to changes in land values near
wastewater facilities and relate to the changes in value of land because of a
VI I-1
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centralized sewer system. Both may be valid impacts, but are expressed dif-
ferently.
User charges and household income are tied together in impact analysis. A
given level of user charges in and of itself is not a problem. The predicted
user charge as related to current charges (adjusted for inflation) , and re-
lated household income are the issues. For this reason, user charges and
household income must be addressed together.
Also, displacement and induced growth issues are the major socioeconomic
issues of Construction Grants projects. Displacement is defined in two ways:
first, as the households which might be forced to relocate because of user
charges (as related to household income); second, as the commercial estab-
lishments and industrial facilities that would be displaced due to a combina-
tion of operating costs and wastewater treatment charges. Displacement may
also be caused by construction activities. Expansion of a treatment site,
acquisition of a land application site or construction of a pump station all
could cause displacement of residences, commercial buildings or industrial
facilities. Induced growth is the opposite of displacement. It is the
growth caused by the inclusion of sewer service or the expansion sewage
treatment capacity which is different in intensity and/or type of landuse
described by any approved landuse plans.
Data Required
1. Population. The indicator of population will be derived from the popula-
tion identified data in the United States census information. The census
data are available in two basic forms: census summary tape files (STF) and
printed documentation. The printed documentation is normally the most con-
venient and most readily accessible source. Table VII-1 provides a useful
reference chart for locating the appropriate printed census document based on
the size of the place affected by the NEPA project. Note that, while com-
plete data are available for places of 10,000 or more persons, some printed
data are not available for smaller places and no printed data are available
for places under 1,000 persons. In order to examine data for these small
places or to examine additional data which is not available in the printed
documentation, you must go to the STF files. These computer tape files con-
tain a much larger volume of data than is contained in the printed documenta-
tion. There are five STF files which present data in tabular form for dif-
ferent units of geography. For instance, the STF 1 file contains the 100%
count items (no census sample data) for all levels of geography down to the
census block. The STF 3 file will be of primary interest to NEPA project
evaluations. This file contains 150 tables for all census designated places
within a state and for census tracts and block groups within places. A
detailed listing of the table contents and the tape locations for the tables
can be found in the census publication, "Census of Population and Housing,
1980: Summary Tape File 3, Technical Documentation".
As noted above, the census STF files are rather difficult to work with. The
STF files are available for each state and for the United States as a whole.
VII-2
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TABLE VII-1
LOCATION FOR CENSUS DATA
Parameter
Persons
Households
Housing Units
Year Round Units
Vacant
Median Income
Median Housing Value
Employment
Census Table Number
1980
1960 & 70
1980
1960 & 70
1980
1960 & 70
1980
1960 & 70
1980
1960 & 70
1980
1960 & 70
1980
1960 & 70
1980
1960 & 70
SMSA's
GH-1
H-13
GP-29
H-16
GH-1
H-13
DH-54
H-13
GH-1 8
H-13
P-89
GSE-124
GH-20
H-10
GSE-121
•P-86
50,000+
GH-1
H-8
GP-29
H-16
GH-1
H-8
DH-54
H-8
GH-1 8
H-8
P-89
GSE-124
GH-20
H-10
GSE-121
P-86
10,000
50,000
GH-1
H-18
GP-36
H-16
GH-1
H-18
DH-54
H-18
GH-29
H-18
P-107
GSE-161
GH-31
H-20
GSE-159
P-104
2,500
10,000
GH-1
H-23
GB-39
H-16
GH-1
H-23
DH-54
H-23
GH-36
H-23
GSE-168
GH-37
H-24
GSE-167
P-118
1,000
2,500
GH-1
H-27
—
GH-1
H-27
DH-54
H-27
—
—
—
—
Counties
GH-1
H-60
GP-49
H-16
GH-1
H-60
•DH-54
H-60
GH-46
Jl-60
P-124
GSE-180
GH-45
H-61
GSE-177
P-122
H = 1970 Census of Housing, Housing Characteristics for States, Cities and Counties.
P = 1970 Census of Population, Characteristics of the Population.
GH = 1980 Census of Housing, General Housing Characteristics.
DH = 1980 Census of Housing, Detailed Housing Characteristics.
GSE = 1980 Census of Population, General Social & Economic Characteristics.
NOTE: These publications may be obtained from either (1) the local Census Bureau office,
(2) the state data center (each state has a designated center usually located in the state
capital or the major state university), (3) any library designated as a census data
depository, or (4) from the U.S. Government Printing office.
VII-3
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Many of the state files run more than one computer tape in length. A system
has been set up to facilitate access and easy use of the STF files. The EPA
computer facilities at Research Triangle Park in North Carolina has a soft-
ware system set up to extract the census data from these files. The system
is comprised of a complete set of STF 3 tapes, a computer program, STF/SAS
conversion and display system (SCADS), to extract and label data from the
tapes and place the data in a Statistical Analysis System (SAS) data file for
processing. The nature of the processing will depend upon the evaluation
project, but the SAS package of statistical and programming routines is
extremely comprehensive and flexible. Appendices A and B contain, a descrip-
tion of this data base and data management (SAS) system.
2. Growth. The indicator of growth is change in landuse. Since accurate
landuse information will not likely be available, an increase in number of
"housing units", as described by the census, can be included as an indicator.
An increase in the census identified "year round units" should be used as an
indicator of growth compensated by the conversion of seasonal housing. In-
formation from the operating entity as to the change in households served may
provide complementary indicators of growth. The reviewer must understand
geographic concepts used by the census, e.g., multi-jurisdictional growth.
comparisons are urban to rural and metropolitan to non-metropolitan, not
urban to metropolitan or rural to metropolitan.
3. Displacement. As an indicator of displacement, only documentation
directly linked to the Construction Grants program will be valid due to the
exogenous variables of migration patterns. Census data may be used for addi-
tional insight.
Displacement pressure is defined in NEPA documents as a function of user
charges and household income. "Median household income" from census data
should be used as the indicators of income, while the actual user charges
should be derived from the operating agency will be used.
4. Property Values/Land Values. The indicator of change in property values
and land values is reflected in "housing value" as defined by the census.
Local tax records may provide additional information concerning property and
land values. The .method and frequency of updating local records must be
understood if they are to be used to complement the census data.
5. Employment. The indicator of employment change will be the number of
employees as defined by the U.S. Census or Department of Labor.
It should be noted that census data for households, vacant housing units,
median income, median housing value and employment are not available in the
printed documentation for communities below 2,500.- In these instances', it is
often justifiable to use county values. Although the use of county data will
not provide the level of detail provided in larger communities, it can pro-
vide an indication of change for comparison with the predicted values, and
may be supplemented through discussions with local representatives.
VII-4
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Method
As discussed above, Che impacts or effects of a Construction Grants project
on the socioeconomic environment are related to changes in property/land
values, displacement/induced growth and income. Forecasts of population,
land use and employment are indicators of and baselines for the effects. It
is important to address the accuracy, the source, and the method of develop-
ing these baseline/indicators of socioeconoraic impacts since they provide
insights into the accuracy of impact predictions.
Population. The three methods of presenting population forecasts are as
described in Chapter II (quantitative absolute, quantitative relative and
qualitative). Examples of the three forms are as follows:
A quantitative absolute prediction forecasts the level of the parameter
at some specific time in the future. An example of such a prediction
follows:
"induced growth would be minimal under Alternatives 1 through 4.
Although more treatment capacity would be available under these
alternatives, it is unlikely that these facilities would induce
population growth above the projected level."
Population projections for the period 1975 to 2000 for the City of
Portage:
1975 1980 1990 2000
7,858 8,750 . 9,750 10,700
Source: Environmental Impact Statement, Portage, WI, 1975.
A quantitative relative prediction forecasts the level of a parameter
relative to a baseline:
"The landuse changes that the project will in part make possible
induces new residential development...some but not all of this pro-
jected growth (roughly a doubling of residential population) would
occur with existing sanitary sewerage policy, given the areas' geo-
graphy."
Source: FNSI, Clay Township, Hamilton County, IN, 1979.
A qualitative prediction provides a description of the net direction of
change in a parameter at a future date.
"The Facilities Plan Proposed Action...may accelerate the conversion
rate of seasonal to year-round housing units...."
Source: Environmental Impact Statement, Nettle Lake Area, Williams
County, OH, 1982.
VII-5
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Unfortunately, it is often the case that neither the quantitative nor the
qualitative predictions are backed up with supporting documentation such
as the source for either the prediction or the baseline population esti-
mate, and it is very uncommon for algorithms to be provided for the pro-
jected population figures.
Land Use. Each of the above forecasts/predictions also address landuse
changes either directly or indirectly. The Portage, WI EIS combines
population and induced population to imply that the landuse changes are
planned. The Hamilton County FNSI addresses landuse and population as
induced new residential development, and the Nettle Lake EIS addresses
land use changes via conversions of uses.
Employment. Employment forecast may or may not be included in NEPA docu-
ments. Often employment is only addressed as a component flow calcula-
tion. In large construction projects, the effort on construction indus-
try employment may be addressed. Likewise, the change in the number of
"operator" jobs may be addressed.
Land/Property Values. The external causes of changes in property and
land values dictate that only directional changes be forecast in nearly
all NEPA documents. Increases in land values are usually associated with
the desirability of new development to locate in areas served by central
sewers and/or the increased density allowed by central sewers. Decreased
land values are associated with the perceived blighting influence of
wastewater treatment and disposal facilities within close proximity to
residential development. As stated above, tax records may provide addi-
tional detail complementary to the census data.
Income/User Charges. User charges may be expressed in NEPA documents as
follows:
"....impacts of these costs are defined in terras of the percentage
of the populatio'n facing a significant financial burden. Applying
the threshold of 1.5% to this income results in a figure of $212;
or $102 more than the average annual homeowner cost of $110...."
EPA considers a project high-cost when the current guidelines are ex-
ceeded, however, the Agency will avoid labeling projects "expensive"
because when health or income is primarily identified with quality of
water resources, attitudes of best possible water quality typically re-
flect "necessity".
It should be noted that the relationship between user charges and house-
hold income became a guideline definitive criterion for the determination
of a high cost project in 1980. Since that time, the percentages used
and the income levels have changed. This does not, however, effect the
accuracy of the impact prediction, but rather may alter today's qualita-
tive judgment as to the severity of the impacts.
VII-6
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The impact and user charges must be identified to determine: 1) If cur-
rent charges are consistent with projected charges; and 2) The range of
variation in predicted/actual charges and median household income.
Displacement/Induced Growth. The causes of displacement and induced
growth can often be external to the study area of a facilities plan.
When- analyzing the actual impacts, one must keep in mind that what appear
to be an incorrect prediction of induced growth may be caused by a
national, regional, or local economic downturn or recession. Similarly,
displacement may be primarily the result of unemployment, energy short-
ages or social issues rather than high user charges. Initial analysis
should begin with the direct displacement due to building. The informa-
tion from the census provide insight as to the magnitude of change, but
will not provide an understanding as to the causes.
Specific Steps
1. Identify the counties and communities affected. This is done by review-
ing the introduction and/or affected environment sections of the NEPA
document which will delineate the counties and/or communities involved in
the study area. It may also be necessary to review the population sec-
tion of the document where specific population forecasts are given in
order to identify all involved communities. Often the population section
is the only section which identifies all of the communities within the
counties or service area and describes those communities only partially
served.
2. Retrieve the census information for the state. This will be retrieved
either from printed documentation or from census tapes. If census tapes
are to be used, the reviewer will need to establish contact with the EPA
computer facility. Contact should be made with the User Support Group.
They should provide the reviewer -with the necessary terminal set up pro-
cedures, accounting procedures, and with documentation on how to use the
facility.
3. Retrieve the user cost data. The user charges for the project must be
obtained from its operating agency. Average household user charges must
be obtained or calculated from the information supplied by the operators.
Be aware that one service area may have several rates or user charges per
type of service.
4. Identify the predicted impacts. The document being reviewed must be
examined to determine the predictions made. If the impact analysis gives
only qualitative impacts, then the alternative analysis section of the
NEPA document should be examined to determine if a quantitative predic-
tion was provided. The evaluation forms in Chapter II should be com-
pleted as appropriate to the type of predicted impact. The source of the
prediction should be identified since it will provide insight into the
factors responsible for an over or under estimation of impacts.
VII-7
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5. Conduct the evaluation. The comparison of the actual value of the para-
meter to the level predicted by the NEPA document will provide an esti-
mate of the accuracy of the prediction. For example, if the EIS speci-
fies a 1% growth rate for the population and uses a baseline population
estimate from the 1970 census, a predicted population for 1980 can read-
ily be calculated. Note this figure represents a linear projection from
the 1970 base along a growth rate of 17, per year from the 10 time points
between 1970 and 1980. The actual growth rate can be computed by taking
the 1970 figure and comparing it with the actual 1980 population. The
actual growth rate between 1970 and 1980, can then be calculated and may
be projected beyond 1980 to the limit of the project duration.. These two
rates of growth; one derived from the EIS; and the other derived from a
recalculation based on our new knowledge of the actual 1980 population,
are both fixed rates and, therefore, our population projections are both
projections from some known population base figure. The statistical
comparision could be based on determining how close the rates are to one
another (e.g., the rate based on the known 1980 population is 10% higher
than the EIS rate or show how the projected population figures differ
over time and compare" the projected figures at different time points,
such as the actual 1980 population is 10% higher than the EIS projected
population and the new 1990 projected figure is 15% larger than the EIS
projected figure). The key to each of these approaches is, of course,
the rate of growth and since the two rates are generated from actual
census population figures, the magnitude of their difference is the basis
for the comparison and statistical significance tests are not appro-
priate. The researcher should determine in advance what degree of accu-
racy (e.g., £ 10%) is acceptable for concluding that the initial popula-
tion projection was accurate. Caution is warranted because actual growth
rates are not typically straight line increases, even though in time, the
actual and final prediction value may be identical.
If a sample of projects is considered and a comparison of these projects
based on their population predictions is desired, then the use of a
paired T-test would be appropriate for comparing populations at two
points in time assuming that the projected population is correlated posi-
tively with the baseline figure. The T-test results will allow the
reviewer to conclude whether or not the mean difference in population
size between time 1 and time 2 is significantly different than zero for
the sample of projects. The reviewer must account for, in those exam-
ples, the standard error and confidence bounds of the census bureau's
data before determining the difference as significant. Also, the re-
viewer must realize that same percent differences in metropolitan popula-
tion counts have a dissimilar magnitude in small towns, e.g., a 10 per-
cent population increase/decrease in a town of 200 will be unlike a 10
percent increase/decrease in a metropolitan city of two million.
VII-8
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Another aspect of this analysis is an examination of other demographic
parameters in order to provide a profile of the socioeconomic makeup of
the place or places being studied. This analysis may provide insight
into the causes for the accurate or inaccurate nature of the EIS projec-
tions. For example, if there was a significant increase in the number of
year-round housing units or a significant decrease in the median house-
hold income, these changes may precipitate a change in the population
size. The direction of causality can be very ambiguous in these types of
analyses, but the outcome from generating a profile is a much better
understanding of the overall trends. Clearly, when dealing with small
area geography, a single event such as a plant closing or opening can
have a major impact on any population projection. Knowledge of these
events and general socioeconoraic trends can assist the reviewer in deter-
mining whether the EIS predictions were done poorly or whether external
factors or catastrophic events drastically changed the assumed project
parameters resulting in inaccurate predictions. The local chamber of
commerce is an additional data resource which might facilitate this
analysis.
Products Required
Appropriate evaluation tables must be completed for each predicted impact
evaluated. A narrative explaining the procedural steps, including justifica-
tions of any and all judgments involved, and a discussion of the implications
and results of the evaluation must be prepared. It is strongly suggested
that graphics be used in place of numerical and textual information whenever
possible. A graphic which is appropriate and well done will often convey
information at a glance rather than requiring pages of text or tables.
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CHAPTER VIII
AGRICULTURAL ISSUES
Introduction
This chapter provides the reviewer with a method for assessing the accuracy
of NEPA predicted agricultural impacts. The parameters used to indicate
impacts to agricultural land may include the amount of acreage currently in
agricultural use and farm-related data such as numbers of farms, average size
of farms or farm values. While farm-related data are not as valuable in re-
flecting impacts as data on acreage in agricultural use, they may be found in
the NEPA document. Since the updated 1979 regulations for implementing NEPA,
significant agricultural lands must now be identified in the preparation of
an EIS in accordance with EPA's Agricultural Lands Protection Policy. The
EPA policy, consistent with the United States Department of Agriculture's
(USDA) guidelines, officially recognizes seven agricultural land types (based
on a soil's capability for production): prime farmland, unique farmland,
additional farmland of statewide importance, additional farmland of local
importance, farmlands in or contiguous to Environmentally Sensitive Areas
(ESA's), farmlands of waste utilization importance, and farmlands with signi-
ficant capital investments in Best Management Practices (BMP's). (See 7 CFR
Part 657 for a mpre complete discussion of these terms.) If these designa-
tions have been identified at the county level by SCS, then impacts may be
estimated, for example, in terms of acres of prime farmland lost. If this
farmland designation system has not been used, then soil capability groups
(Class I - VIII) might be used to assess impacts to open land suitable for
farming. It is likely that early NEPA documents have not discussed these
special agricultural ratings and have only predicted impacts for land that is
currently in agricultural use - whatever its productive capability or design-
ation. The reviewer must be cognizant of this distinction.
Conversion of agricultural land to non-agricultural use is the primary ad-
verse impact of Construction Grants projects and is controlled by local and
regional land use planning through zoning ordinances and/or taxation rates.
Agricultural land impacts may also be estimated in NEPA documents(s) as the
rate of change in land use. - -
Data Required
The reviewer should collected from NEPA document(s) or other sources data on
soil capability groups and/or agricultural land designations (prime, unique,
etc.) on a county basis from the County Soil Conservation Service (USDA-SCS).
If required, county soil surveys include information, by soil type, on the
productive capability of soils (s'oil classes). The special agricultural land
designations may or may not have been identified by the SCS. These data are
available by distribution of soil types and not by legal boundaries or
platted land. For this information, the reviewer should obtain an updated
land use map from the area planning commission (or city, township, or county
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planning office). Additionally, one may also need to collect updates on the
rate of agricultural land change, from the local planning commission, if pre-
dicted impacts were based on rates of change.
Method
The method consists of five basic steps; (1) determination of baseline ("be-
fore" project) conditions, (2) compilation of predicted impacts, (3) deter-
mination of actual impacts based on current ("after" project) data, (4)
determination of those impacts directly attributable to the project as op-
posed to those attributable to other actions in the area, and (5) assessment
of the accuracy of impact prediction.
The reviewer should obtain the predicted impacts and possibly the baseline
data from the Affected Environment Section of the NEPA document. The impacts
may take one of three forms: quantitative absolute, quantitative relative or
qualitative. A quantitative absolute impact measures the amount of impact at
some future date:
"the construction of this line will open approximately 20
acres of prime farmland north of the alignment to potential
land use conversion.... If development of these 20 acres
would occur, the amount of prime farmland lost would not be
significant when compared with the total amount of prime
farmland in the county. In addition, these 20 acres com-
prise only 0.4% of the prime soil series in the planning
area."
(Source: FNSI Saline, MI, 1981)
A quantitative relative impact describes the magnitude of changes from base-
line values at some future date:
"Open land and agricultural land in the study area, summarized
in Table 10, contain primarily Class I and Class II soils for
farming. Nearly half of this acreage may be subject to second-
ary development pressures as a result of the proposed project."
(Hypothetical)
A qualitative impact suggests the direction of change, but not the magni-
tude:
"Some agricultural land is expected to be converted to resi-
dential use over the 20-year planning period. This will
occur in accordance with the Pittsfield Township Comprehen-
sive Plan which has made provisions for phasing of develop-
ment and protection of a majority of its agricultural land."
(Source: EA Muskingum County, South Zanesville, OH, 1983)
or
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"...urbanizing trends are evident on some of the prime
farmlands, particularly north of Portage around the Rt. 78
interchange and east of Portage near the intersection of
Routes 33, F and EE. No unique farmland would be involved."
(Source: EIS, Portage, WI, 1979)
Since a national agricultural goal is the preservation of land that has high
productive capacity, impact sections may only discuss local trends and pres-
sures toward agricultural land use conversion followed by a discussion of
local mechanisms for minimizing the loss of such lands. This would generally
fall under the category of qualitative impacts. Professional interpretation
would be needed to determine whether any agricultural land use conversion had
been project induced (either primary or secondary impact).
Specific Steps
1. Obtain predicted agricultural land impacts from the NEPA document(s) as
well as any other basic data that might provide factual information, such
as geographic location of the land involved. The Affected Environment
Chapter (or the inventory chapter in earlier documents) is the primary
location of this information.
2. Manual data retrieval will be necessary at a local or county level. Con-
tact the regional or county planning commission for updated information
on conversion of agricultural land to non-agricultural use. This infor-
mation may be direct data or may require map interpretation. Distinquish
between land use change that was attributable to the project and that
which was not. Local land use planners may assist in data interpretation
but final decisions on project-related growth are the responsibility of
the reviewer. Next, check SCS maps to determine the status or rating of
the converted agricultural land. Convert the information as necessary to
the form presented in the NEPA document, such as percent of total or
acres of prime agricultural land converted.
3. Actual impacts may be recorded as rates of change, as a specified number
of acres, or as a land use conversion trend.
4. If the predicted impact was qualitative, use updated information to ver-
ify the direction and intensity of the impact. Qualitative impacts of
agricultural land use conversion trends will require professional inter-
pretation. Local planners may provide insight on changes in the local
economy, land taxation rates and other factors that may be occurring
independently of project related growth which would alter trends in agri-
cultural land conversion.
Predicted quantitative impacts (absolute or relative) can be directly
compared with actual impacts. Interpretation of numbers may be necessary
since:
VIII-3
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1. inaccurate predictions may be more likely with secondary impacts
than with the land requirements for a specified use, such as a land
application site;
2. some minor inaccuracies (10-20%) are inherent in SCS maps and in
the engineering planning of land requirements for construction of
facilities, and
3. estimates of land use change or pressures for growth predicted
by the area plan commission may have been used, unchanged, in the
NEPA document.
The reviewer should be aware that other considerations may also exist for
a particular project.
Products Required
Evaluation forms should be prepared for each predicted impact and for every
parameter discussed in the NEPA document. A narrative should accompany the
analysis which interprets the evaluation forms.
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CHAPTER IX
PHYSICAL ENVIRONMENT ISSUES
Introduction
This chapter provides the reviewer with a method for assessing the accuracy
of NEPA predicted impacts on the physical environment of Construction Grants
projects. The physical environment includes the categories of climate, topo-
graphy, soils, and geology. None of the physical environment issues can be
addressed using machine processable data bases. This is due to the limited
availability of machine readable data bases for physical environment para-
meters, and to the site-specific nature of potential impacts.
Impacts related to the physical environment are project specific, thus, the
NEPA document should be carefully reviewed to determine what impacts were
addressed. Lack of impact analyses for any of the physical issues does not
preclude their existence. It is likely that in pre-1979 NEPA documents,
these physical environment issues were addressed only in a cursory manner.,
The reviewer should use this manual to assess the accuracy of impacts that
were predicted.
Many of the impacts to physical features are unavoidable and some are irre-
versible changes which were considered environmentally acceptable tradeoffs
in the planning of the proposed action. Some examples are (1) changes in
soil properties from cut and fill activities, (2) changes in topographic
features from grading activities, or (3) dedication of land to a particular
use, e.g., landfill, road right-of-way, or a WWTP site. A reviewer may find
additional information on the nature of the impacts in the mitigating
measures section of the NEPA document.
Climate. Long term changes in microclimate may result from certain projects
whose climatic impacts are of significant magnitude. An example of this may
be cooling towers of power plants emitting large amounts of water vapor. Ad-
verse impacts such as higher incidence of dense fog and street icing from
high humidity may occur. Primary indicators of climatic impacts might be
estimated as the quantity of water (vapor) to be emitted daily from a facil-
ity, e.g. , as increases in local relative humidity due to the burning of
solid waste.
An indirect indicator of this impact may be an increased number of traffic
accidents at that location; assuming provable causality. A predicted impact
such as this may be located in another section of the document, such as
transportation or secondary impacts. Climatic impacts (short and long-term)
resulting from dust generation are addressed in Chapter XIII, Air Quality
Issues.
Topography. Project impacts to topography result from short-term construc-
tion activities such as cut and fill (for sewers, roads, etc.) site prepara-
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tion (solids disposal site, WWTP site, or other facility site) and the gener-
ation and disposal of spoil material as well as long-term-impacts from final
site grading. These impacts may be quantified in terms of the quantity of
soil to be generated, the adequacy of the intended disposal site, the dimen-
sions (length, width, and depth) of cut and fill activities, the specific
acreage needed for construction of a facility or the percent slope not to be
exceeded in grading.
Impacts to topography might also be found within a discussion of aesthetics,
for example, the loss of a specific view or changes to the character of geo-
graphic area sufficient enough to change its appeal.
Soils. Project impacts to soils result from construction activities and can
change soil properties (chemical and textural). The parameter of soil dis-
ruption is probably inappropriate to an urban setting which may have already
been substantially altered. Such impacts are generally measured by the total
area affected. Impacts to soil properties from sludge or other solids are
addressed in Chapter XI, Solid Waste Issues.
Another impact issue is soil loss, or erosion, which may be addressed in a
mitigating impacts discussion as well as in a general impacts section of the
NEPA document(s). Erosion impacts may be short or long-term and are general-
ly estimated qualitatively or with a qualitative comparison to average annual
soil loss estimates from agricultural activities. Unless soil loss is a
major impact issue, impacts are usually not quantified because of the diffi-
culty in accurately estimating all of the variables in the Universal Soil
Loss Equation (USLE) of the Soil Conservation Service. Often in a project,
the identified areas of potential erosion impact have already been disturbed
(sometimes called man-made soils) and calculation of the USLE is made more
difficult. Another rationale for not quantifying soil loss is that erosion
should be minimized if mitigating measures are dutifully followed. Deter-
mining the accuracy of predicted impacts is difficult.at best since there is
no way to quantify actual erosion or soil loss versus a predicted quantified
soil loss estimate after the project has been constructed, unless an on-site
monitoring program is instituted prior to and maintained throughout the
planning period. This is rarely, if ever, the case. However, through the
personal observation of steep slopes and nearby streams, the reviewer may be
able to identify excessive erosion or siltation. In a project of significant
magnitude, (e.g., a land application project) preliminary measurements could
be made against which predicted and actual impacts would then be judged.
Data Required
Impacts to the physical environment are very site specific, thus, manual data
files are most applicable for the parameters or issues evaluated. Operation
and maintenance (O&M) records from a facility will contain data on atmos-
pheric emissions (e.g., water). Construction monitoring records (kept by
EPA) or records kept by the design or construction contractors may include
the quantity of fill used or spoil generated and its source or disposal loca-
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tion. The State or municipality involved can identify contractors not main-
tained in EPA records.
City or county engineering maps will indicate all areas of new sewers, roads,
and construction sites. Interviews with local SCS staff and updated land use
maps from the city or area plan commission will provide additional informa-
tion on surface feature changes. Post-project aerial photos or updated USGS
topographic maps of the study area may be used to detect changes in surface
drainage patterns.
Methods
The method consists of five basic steps; (1) determination of baseline ("be-
fore" project) conditions, (2) compilation of predicted impacts, (3) deter-
mination of actual impacts based on current ("after" project) data, (4)
determination of those impacts directly attributable to the project as op-
posed to those attributable to other actions in the area, and (5) assessment
of the accuracy of impact prediction. The predicted impacts are derived
solely from the NEPA document for the project. Each prediction will take one
of three possible forms: qualitative (a statement which gives an indication
of the direction of change in a parameter), quantitative relative (a state-
ment which describes the changes from baseline values at some future date) or
quantitative absolute (a statement which measures the amount of impact at
some future date). The actual impacts are derived from collecting post-pro-
ject information on the impact parameters. These data may come from existing
sources or from field studies when no other data source is available. The
two sets of impacts are compared and professionally interpreted.
A crucial step is the derivation of the predicted impacts. ' It is important
that the reviewer exercise professional judgment when interpreting qualita-
tive impacts, expressed as slight, minimal, insignificant, or substantial so
as to minimize misinterpretations of the author's intended perception of the
potential impact. An exception is the use of "no impact" or "undetectable"
in a qualitative impact. These phrases can always be translated as a quanti-
tative relative statement indicating that the magnitude of change is zero.
The absence of discussion of an issue in a NEPA document (e.g., soils, topo-
graphy, etc.) should not be autoraaticlly assumed to imply that there is no
impact or that it is of zero magnitude. Rather, the reviewer should be alert
to the possibility of unanticipated impacts which are addressed in Chapter
XIV.
Specific Steps
Information derived in the following steps should be entered onto the evalua-
tion forms described in Chapter II.
1. Using the NEPA document, identify the location and baseline character-
istics of the specific physical areas to which impacts are expected to
occur. This information should be located in the "Existing Conditions"
section, the "Description of the Proposed Action", or in the section on
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"Impacts of the Proposed Action". For these physical environment issues,
the reviewer needs the most site specific information available, and in
some cases, that information may be in the "Analysis of Alternatives"
section.
2. Identify the predicted impacts. The NEPA document must be reviewed to
determine exactly what the author predicted. It is common to find that
impacts to physical features are stated either qualitatively or as a
quantitative relative statement. For example:
"Site B is relatively flat and therefore adverse erosion loss
is not anticipated."
(Source: South Canadian Wastewater Treatment Facility, Oklahoma
City, OK, 1982)
or
"Soil erosion from construction activities are inevitable impacts
which can be somewhat mitigated by strict adhesion to the N.C.
Sedimentation Pollution Control Act of 1973 guidelines. These
guidelines specify that every construction activity must have an
approved sediment control plan."
(Source: 201 Facilities Plan for Wendell and Zebulon, North
Carolina, 1975)
Quantitative absolute predictions are rare.
"The excavation of tunneled sewers, cut and cover sewers and the
CSO control structure will create nearly 2.0 million cubic feet
(56,600 m^) of spoil. Disposal of this spoil in a haphazard,
uncontrolled manner will cause significant long term, adverse
impacts."
(Source: Detroit Segmented Facilities Plan, 1978)
In the preceding example, deletion of the word "nearly" would create a
quantitative absolute prediction.
3. Identify and then collect the appropriate data from manual sources as
discussed under the earlier section, Data Required. Make any current
quantifiable data compatible with the terms used in the NEPA document
(e.g., truckloads of spoil/day equals x ft.-Vday) for purposes of com-
parison. In retrieving data, the reviewer must collect the most recent
post-project data. If post-project data, such as SCS interviews, aerial
photos or updated topographic maps are not available, an on-site inspec-
tion will be required.
4. Compare the predicted impact and the actual impact to determine the
accuracy of the prediction. For impacts which were quantified, the com-
parative evaluation must take into account the margin of error and level
of accuracy that were assumed in the original predicted impact. Engi-
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neering estimates of construction activities made during the first phase
of planning may contain a margin of error between _+ 10-20%. SCS mapping
error on soils are also possible. The reviewer should also keep in mind,
if using a planiraeter to determine actual impact area, the accuracy of
the tool, the scale of the maps being used and, of course, human error.
When the statement of impact is qualitative, reviewer judgment will be
required to resolve the extent to which the predicted and the actual
impacts, each perceived by different people, agree with each other.
Almost all of the qualitative impacts predicted for physical features are
mitigated to some extent by measures recommended in the proposed plan.
In addition, many of these impacts were assessed as short terra and no
records may have been kept regarding their degree of severity for such a
short time. From a practical point of view, the reviewer may only be
able to assess those impacts to physical features which were severe
enough in nature to have become long term impacts on the land (severe
erosion, creation of wet spots from drainage pattern changes, etc.). In
a case where short term, minimal soil loss was predicted and the reviewer
observed (either by appropriate maps or first hand observation) long term
effects of erosion on the project site, an interpretation of the inac-
curacy of prediction would be required. Logical answers might be that
mitigating measures were not adhered to during construction or that the
qualitative estimate of erosion potential did not reflect the basic data
on slope, soil type, and climatic conditions.
Products Required
Appropriate evaluation forms must be completed for each individual predicted
impact evaluated. A narrative explaining the procedure steps, including
justification of any and all judgments involved, and discussion of the impli-
cations and results of the evaluation must be prepared.
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CHAPTER X
CULTURAL RESOURCE ISSUES
Introduction
This chapter provides the reviewer with a method for assessing the accuracy
of NEPA predicted impacts on cultural resoures. NEPA documents must identify
the presence of cultural resources (this includes architectural, historic and
archaeological resources) that are presently in or eligible for inclusion in
the National Register of Historic Places. Such properties must be identified
in the primary impact areas of a project. "Primary impact areas are those
where ground will be disturbed for the project, such as the plant site, pump-
ing station sites, access roads, and rights-of-way for interceptors. Areas
in which the wastewater treatment facilities will have direct visual, odor,
or aerosol effects may also be primary impact areas if they are likely to
contain cultural properties of a type which are susceptible to such impacts
and if the proposed project has been designed so as to be exposed to view or
will emit odors or aerosols." This quote and the guidance, which follows is
based on USEPA Region V 1984 draft revised guidance for archaeological and
historical preservation.
The NEPA document will contain evidence of consultation with the State His-
toric Preservation Officer (SHPO). The USEPA, in consultation with the SHPO,
makes recommendations on the need for a preliminary reconnaissance survey of
the area if a known or potential site would be affected by the proposed pro-
ject. A letter to this effect will be found in the facilities plan documen-
tation.
If the preliminary survey conducted by a qualified professional does occur,
results of the survey and further consultation between EPA or delegated State
and the SHPO will be documented. The survey results will conclude either (1)
no adverse effect is anticipated and project action may proceed or (2) an
adverse impact is anticipated and a survey is warranted.
To summarize the procedure, there are three situations that may arise when
dealing with a National Register property. ("Effects" and "impacts" as used
in 40 CFR 1508.8 are synonymous).
1. No effect. This addresses the usual or routine situation of no cul-
tural sites in primary impact areas of the project. The first let-
ter of documentation ("sign-off" letter) from the SHPO satisfies
this situation.
2. No adverse effect. This addresses the less than ideal situation
where any impacts which surface during construction can be miti-
gated. It also covers projects which may reveal unknown archaeolog-
ical artifacts that can be salvaged during project construction.
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3. Adverse effect. This addresses the least suitable situation where
adverse impacts are identified and cannot be acceptably mitigated.
A specific consultation procedure occurs involving the National
Advisory Council on Historic Preservation, USEPA, the SHPO, the
State Water Pollution Control Agency, and the grantee. This consul-
tation either results in an acceptable memorandum of agreement or
further procedures regulating the failure to avoid or mitigate
adverse effects.
Data Required
The reviewer must contact the SHPO to determine if any significant archaeo-
logical finds or any architectural/historic landmarks were discovered prior
to or during construction of the project. The reviewer must then determine
if the state maintains any follow-up records of NEPA projects, particularly
with reference to the implementation of mitigating measures.
A site visit may be necessary to document long-term mitigating measures to
cultural resource sites, properties, or buildings where no other source of
data are available. It may be useful to check with local authorities (uni-
versities, museums, historical societies) to document changes on or surround-
ing a site. Also, the reviewer may wish to contact the archaeologist or his-
torian involved in any of the evaluations, mitigation efforts, or recovery
operations.
Method
The method consists of five basic steps; (1) determination of baseline ("be-
fore" project) conditions, (2) compilation of predicted impacts, (3) deter-
mination of actual impacts based on current ("after" project) data, (4)
determination of those impacts directly attributable to the project as op-
posed to those attributable to other actions in the area, and (5) assessment
of the accuracy of impact prediction.
Impacts may take one of three forms: quantitative absolute, quantitative
relative or qualitative. A quantitative absolute impact measures the degree
of impact at some time in the future. Ideally, a Construction Grants pro-
ject will have been planned so as to avoid adverse impacts to cultural
resources or at least satisfactorily mitigate them. If in either of these
situations the concept of zero impact is inferred or expressed, the impact is
categorized as quantitative absolute:
"In addition, the State Historical Preservation Officer (SHPO)
concurs that the construction of wastewater treatment facilities
at the alternate sites or the expansion of facilities at the
existing site would result in no adverse effect to properties
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that are listed on or eligible for inclusion on the National
Register of Historic Places (By letter; Mr. Richard Erney, State
Historical Society of Wisconsin, to Mr. Charles Sutfin, USEPA,
14 April 1980).
(Source: Draft SIS, Portage, WI 1979)
A quantitative relative impact describes the magnitude of change in a para-
meter expected at some future data:
"As much as half of the scenic view from Fort Sumpter National
Park may be impaired after construction of the WWTP. Long-term
adverse impacts can be mitigated by construction of a vegetative
buffer to screen the plant from view."
(Hypothetical)
More typically in a NEPA document, cultural impacts are qualitative. That
is, they indicate the direction of an impact (adverse or beneficial) without
estimating the magnitude of that impact. Examples of qualitative impacts
are:
"The elimination of the existing WWTP would result in a
beneficial aesthetic (secondary) impact to these National
Register sites. The existing WWTP is in a direct line of
sight from these properties."
and
"The Old Indian Agency House would be impacted during both
the construction phase and operation phase. The aesthetic
and noise impacts during operation would detract from the
historical and architectural integrity of the Agency House
and would alter the National Register significance of the
site.... If this alternative was implemented, mitigative
measures would be taken, subsequent to SHPO and Advisory
Council consultation."
(Source: EIS, Portage, WI 1980)
Specific Steps
1. From the NEPA document(s), identify the predicted impacts to cultural
resources. Detailed statements of impact may be located in the SHPO
documentation in an appendix or support documents if they are not speci-
fically stated in the impact section of the main document. Also, a map
should be located which has all the properties or resources marked rela-
tive to the primary impact areas of the project. Where archaeological
sites are an issue, locations are deliberately kept vague in documents to
protect the site from potential vandalism. It is essential to check with
the SHPO and the USEPA project file/person to obtain more detail. Note
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where impacts are defined assuming specific mitigating measures will be
carried out.
2. Telephone calls for manual data collection is needed to verify the pre-
dicted impacts. Any records that exist which document implementation of
mitigating measures should be collected. Conduct site visits, as neces-
sary, to confirm that mitigating measures were carried out.
3. The reviewer can use quantified information from project records to com-
pare with quantitative impacts to determine the accuracy of the predicted
impact. Qualitative impacts, using terras such as slight, moderate,
severe, must be interpreted carefully by the reviewer. It may be useful
to seek advise from the SHPO in the interpretation of qualitative im-
pacts .
Products Required
An evaluation form must be prepared for each predicted impact in the NEPA
document. A- narrative should accompany the analysis which interprets the
evaluation procedure.
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CHAPTER XI
SOLID WASTE ISSUES*
Introduction
Environmental issues associated with solid waste may be associated with all
of the issues addressed in other chapters. Each of the issue areas in the
NEPA document should be reviewed to identify all impacts associated with
solid waste.
The volume of solid waste generated in a Construction Grants project depends
upon the volume of wastewater treated and the solids processing methods util-
ized. Both the quantity and the quality of processed solids affect the
method of disposal. An increase in the quantity of sludge will affect trans-
portion impacts - number of truckloads/day hauled. These impacts may be dis-
cussed under energy or cost sections in the NEPA document(s).
Site selection studies are commonly conducted to choose the most environmen-
tally suitable solids disposal site(s) from available land in the immediate
region. Disposal plans involving land application of sludge must address
potential impacts to on-site environmental aspects such as surface and
groundwater quality and human health, as well as -economic, social and politi-
cal factors. Guidelines and regulations exist that protect other features of
the environment from adverse impact, such as biota, floodplains, wetlands,
agricultural land and cultural resource sites, in the early planning stages
of the siting process. If any impacts are predicted or mitigating measures
recommended for these' issues, chapters of the Manual appropriate to these
issues should be implemented. Similar environmental issues are addressed
when choosing a landfill site for disposal of sludge or incinerator ash.
Some of these issues have been discussed under other chapters.
NEPA documents address the placement of construction debris or land applica-
tion of sludge on natural resources in or beyond a planning area. Conse-
quently, environmental issues including, but not limited to, placement of
overburden (spoil), leachate collection and treatment and monitoring of
groundwater wells are discussed among the solid waste issues.
Sludge quality imposes retrictions on the type of site chosen as well as the
rate of sludge application to the land. The cation exchange capacity (CEC)
of the soil is one of the factors which determine a soil's ability to accept
large amounts of sludge over time. Concentrations of cadmium and other toxic
compounds are indicators monitored in soils receiving sludge.
In the situation where a land application and/or landfill site is already in
use, solid waste impacts may assess the remaining capacity or "life" of the
site. These impacts may be estimated in terms of the proposed quantity of
sludge/ash to be received or as a percentage or increased rate of capacity
utilization of the disposal site.
* Waste does not infer unusable because spoil and sludge have market values.
The term "waste" simply refers to by-products.
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Many early NEPA documents may not have addressed solid waste impacts because
the existing system worked satisfactorily and because no guidelines or regu-
lations were in effect. For uniform application of this manual, one has to
assume that the author intended a statement of no impact by excluding the
solid waste section of a planning document. Planning documents should speci-
fically address solid waste disposal.
Data Required
The data required for this section include the NEPA predictions regarding
solid waste issues, current data from solids processing and solids disposal
sites operating and/or monitoring records. These data would include informa-
tion on the quantity and quality of solids generated (e.g, Ibs/day, tons/yr,
ppm Cd, ppb PCB). Data on the solids disposal site(s) can be retrieved man-
ually from site operating or monitoring records or from the state solid waste
management agency that monitors the site.
Method
The method consists of five basic steps; (1) determination of baseline ("be-
fore" project) conditions, (2) compilation of predicted impacts, (3) deter-
mination of actual impacts based on current ("after" project) data, (4)
determination of those impacts directly attributable to the project as op-
posed to those attributable to other actions in the area, and (5) assessment
of the accuracy of impact prediction. From the NEPA documents, the reviewer
must locate the predictions on the solids quantity and the solids quality
specific to the intended disposal method. The reviewer will also need to
know the proposed disposal plan. This information will be of help in identi-
fying appropriate impact issues (air quality, soil, energy, etc.) discussed
elsewhere in the document(s). Impacts of solid waste on the environment may
be found in the various NEPA impact sections or may be organized under a
single heading in the document. All sections will need to be searched for
solid waste impacts.
The impacts may take one of three forms: 1) quantitative absolute, 2) quan-
titative relative or 3) qualitative.
A quantitative absolute impact measures the degree of impact at some time in
the future:
"An estimated 750 Ibs/day dewatered sludge will be
generated at the new facility, at design capacity, and
transported to the county landfill. Assuming all other
inputs to the landfill remain constant, the additional
sludge load will reduce the projected life of the land-
fill by approximately three years."
(Hypothetical)
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or
"Based on sludge quality and current limits for cadmium
an PCBs, land application rates will average 5 tons/acre
dry solids. Having designed the land application pro-
gram within existing guidelines and following all recom-
mended mitigating measures, no adverse impacts are anti-
cipated. "
(Hypothetical)
A quantitative relative impact describes the magnitude of change in the para-
meter expected at some future date:
"An increase of no more than 20% more sludge per annum
will be generated from the proposed solids processing
program. Sludge hauling operations (truck traffic, vehicle
maintenance, capital and operating costs) will in-
crease up to about 20% per annum. No impact is anticipated
to land spreading facilities because adequate acreage
is available through the planning period."
(Hypothetical)
A qualitative impact suggests the direction change, but not the magnitude:
"Since the recommended land spreading application
rates are based on a balance of the nitrogen uptake
by the crop, the natural assimilative capacity of
soil is not exceeded, thus, significant adverse im-
pacts on groundwater quality are highly unlikely."
(Source: Municipal Sludge Land Disposal Feasibility
Study, Logansport, Indiana, 1979)
or
"By following the guidelines which have been proposed
for land spreading, it is highly unlikely that any
hazard to public health would occur with the land
spreading alternative. To ensure that guidelines are
met, a continuous monitoring program would be esta-
blished as part of the overall sludge management pro-
ject to accurately determine sludge quality and define
appropriate application rates. Thus, on a similar scale
of 1 to 5, the land spreading alternatives are rated a
5, virtually no hazard to public health."
(Source: Municipal Sludge Land Disposal Feasibility
Study, Logansport, Indiana, 1979).
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Specific Steps
1. In the NEPA document(s)., locate the predicted environmental impacts re-
lated to solids processing and disposal issues, either in a solid waste
section or as part of the overall impacts sections. If solid waste
impacts do not directly address environmental issues, determine if data
on the quantity and quality of solids are provided.
2. Retrieve from the facility operators data on the current solids quantity
and quality. If current data are needed on solids disposal sites, ob-
tain monitoring records from the operators or the state monitoring
agency.
3. In situations where a document did not provide specific impact assessment
(issue by issue) or only a qualitative assessment, the reviewer can com-
pare the predicted solids quantity and quality with the actual values on
solids quantity and quality. Make any adjustments (percentages, rate of
changes, etc.) necessary to the actual data to parallel the form of the
prediction. This comparison will only provide an indirect evaluation of
impact accuracy and assumes the predicted qualitative impacts were based
on the predicted estimates of solids quantity and quality. Reviewer
interpretation should include such factors as whether the predicted and
actual data represent the same operating numbers (average, design, or
peak production capacity) and normal engineering design margin of error
(10-20%).
4. For documents that provide specific solids impacts to air and/or water
quality, amount of land used, or energy consumption; for example, compare
with current operating or monitoring data to assess accuracy. The same
precautions apply in interpreting the accuracy of impact comparison as
discussed in item #3.
Products Required
An evaluation form must be prepared for each predicted impact and for every
solid waste parameter in the NEPA document. A narrative should accompany the
analysis which interprets the evaluation form.
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CHAPTER XII
ENERGY ISSUES
Introduction
Energy came to the forefront of environmental concern after the 1974 oil
embargo by the Organization of Petroleum Exporting Countries. Prior to 1974,
energy concerns in NEPA documents were often given only cursory examination
and were included as one of the many non-renewable resources. Modifications
to 40CFR6 have changed that emphasis. The criteria for the decision to pre-
pare an EIS includes "...deleterious changes in the availability or demand
for energy"; (40CFR6.506(a)(1)(vii)). Alternatives to be considered in NEPA
documents include "...appropriate energy reduction measures": (40CFR6.507-
( c)(5) (vii)). The discussion of environmental consequences include "...ener-
gy requirements and conservation potential..,": (40CFR1512.16(e)).
Early NEPA documents may not have a separate section on energy. Rather, they
may include any energy discussion in the section titled "Irreversible and
Irretrievable Commitment of Resources". Impacts in these discussions are
generally qualitative or qualitative relative (e.g., most to least energy
intensive). More recent documents may address energy in the environmental
consequences of alternatives where energy use may be quantified. The impacts
addressed in either the earlier or later documents are often limited to the
operation of the onsite facilities. It should be noted that energy is con-
sumed in the operation of facilities and by pump stations, sludge hauling and
landfill operations.
Where anaerobic disgestion is used, methane gas is a by-product. This may be
vented as waste gas or may be used to augment other fuel sources. Incinera-
tors may also be used to produce stream for use. Other alternative sources
such as solar (for heating water) or alcohol (for. combustion engine fuel) may
be used.
Other primary impacts include the use of energy during construction. Because
energy costs are included in the costs of construction, the energy require-
ments relating to construction may not be identified beyond the facilities
planning documents. Review the facilities plan documentation and GIGS to
obtain design data.
Secondary impacts associated with energy usage stem from changes in transpor-
tation volume and patterns, the development of residential, commercial and
industrial areas which determine the patterns of energy consumption, and the
associated air quality impacts resulting from the emission.
Data Required
The NEPA documents should be reviewed to obtain the baseline energy consump-
tion. In cases where no facilities existed during facilities planning base-
line energy consumption would be zero. Also, the reviewer should obtain the
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predicted impacts on energy consumption. In some cases, a net energy gain
may be realized where obsolete equipment is replaced by energy efficient
equipment. Current data regarding the NEPA energy issues should be obtained
from the operating entity(s). The treatment plant operations manager is the
source of the facilities energy usage. Where off-site operations are in-
cluded or where sludge may be disposed of by an independent contractor, the
operations manager should be sought to obtain additional data.
Specific Steps
1. Identify the predicted impacts. The NEPA document(s) must be reviewed to
first determine the regulatory environment under which the document was
prepared. Documents prepared prior to the November 6, 1979 regulations
for 40CFR6 may address energy only as one of the non-renewable resources.
Documents prepared after mid-1980, will likely address energy in a more
detailed manner in both the "Alternatives" section and the "Discussion of
Environmental Consequences". Most impact predictions will be quantita-
tive absolute, such as:
"Fox River Plant - 1,210 thousand kwh/year electricity,
2,465 million BTU/year fuel requirements..."
(Source: Fox River EIS)
Some energy inpacts may be relative, such as:
"new pump station will increase energy usage by
81,640 kwh/year."
(Hypothetical)
Qualitative impact predictions are seldom found without some quantifica-
tions elsewhere in the document. If a qualitative prediction is given,
it usually is in relation to a yet unproven technology such as:
"By upgrading the existing incinerators, autogenous
burning may be possible...substantial savings in
auxiliary energy will be realized...."
(Source: EIS, Detroit: Segmented Facilities Plan,
Detroit, MI, September 1976)
2. Retrieve operations data for the NEPA parameters addressed. It should be
realized .that the final design and construction may vary somewhat from
the planned facilities. The energy availability at the time may have
mandated a change from one fuel type to another. All predictions and
actual usage should be converted to equivalent units. The conversions
are as follows:
#2 fuel oil 120,000 BTU/gal
diesel fuel 140 ,000 BTU/gal
electric power 10,500 BTU/kwh
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natural gas .1,000 BTU/cuft
digester gas 600 BTU/cuft.
3. By comparing the predicted and actual energy consumption on tables as
discussed in Chapter II, the accuracy of impact predictions can be eval-
uated. One must consider any changes in the treatment process or sludge
disposal method that may have been necessitated after NEPA action. Since
energy consumption is directly related to flow, any assessment of accu-
racy should include the flow basis used whether actual or predicted.
Products Required
Evaluation forms must be completed for each individual predicted impact eval-
uated. A narrative explaining the procedural steps, including justifications
of any and all judgments involved, and discussion of the implications and
results of the evaluation must be prepared.
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CHAPTER XIII
AIR QUAL-ITY ISSUES
Introduction
The impacts of various projects on air quality are most often associated with
increased pollutants from point source emissions, area sources, or the direct
impacts of construction activities. Point source emissions from Construction
Grants facilities are generally evaluated in a regional context concerned
with the maintenance of national ambient air quality standards within the
boundaries of Air Quality Control Regions (AQCR) established by the states
and EPA. The impact of the project on the State Implementation Plan (SIP)
may also be an issue. In all cases, the concentration of various pollutants
for which ambient air quality standards have been set serve as a basis for
determining direct impacts.
The direct impacts of construction related activities are most often confined
to small localized areas and are of short-term duration. Examples of these
are dust generation or exhaust emissions from construction equipment. While
it is possible to monitor the levels of pollutants generated from these
activities at the site, such monitoring is not usually conducted.
Secondary impacts of increased air pollutant levels, such as acid rain, lower
crop yields caused by ozone destruction of leaves, increased rates of des-
truction of buildings from higher SC>2 levels, and increased incidence of
lung desease or health effects are also potential issues. However, the
routine evaluation of such impacts is generally not practiced in Construction
Grants NEPA documents due to their complexity and the cost of evaluation.
The objective of this chapter is to provide the reviewer with a method of
evaluating the accuracy of NEPA impact preductions of Construction Grants
projects regarding air quality issues 1 Using this method, the reviewer will
be able to compare the "before" and "after" project data for those parameters
identified as the primary indicators of air quality impacts. Most air qual-
ity issues will be addressed using one or both of two computerized data bases
maintained by the EPA's National Air Data Branch (NADB): Storage and
Retrieval of Aerometric Data (SAROAD) and the National Emissions Data System
(NEDS).
SAROAD contains aerometric data obtained from numerous ambient air quality
monitoring stations located throughout the States. Pollutant parameters mon-
itored at these stations are those for which the EPA has established National
Ambient Air Quality Standards (NAAQS). These are: total suspended particu-
lates (TSP), sulfur dioxide (802), nitrogen dioxide (NC^), carbon mono-
xide (CO), ozone (03), and lead (Pb). These stations are normally operated
at a local level, but the data obtained are, ultimately, sent to the State
EPA or the equivalent. The location of stations are based on a number of
criteria including; air pollution levels, population density, geography, and
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meteorological conditions. It is also important to note that not all para-
meters are monitored at each station and stations may be relocated from time
to time. The parameters to be monitored at each station and the need for
relocation depend upon local factors, therefore, it is imperative that the
reviewer obtain background information on the monitoring stations from the
State EPA or equivalent.
The NEDS data base contains information of specific point and area sources of
air pollution emissions. The type of pollutants monitored vary from station
(i.e. source) to station, and are based on the processes employed and pollu-
tants emitted from each individual source. For example, area sources are
often associated with transportation routes (e.g. , a major highway) of which
contaminants from exhaust emissions are the major pollutants. In this case,
the most common pollutants monitored would be those typical of these sources
such as CO, S02> NC>2, ^3. Pb, and hydrocarbons. However, a manufac-
turing facility may emit quite different pollutants and monitoring require-
ments and parameters for these facilities are tailored to fit each individual
facility. Much of the information in the NEDS data base is derived from
self-monitoring reports submitted by private companies to the State EPA or
equivalent.
Odors are also issues typically addressed in NEPA documents. The measurement
of odors, however, is very subjective and controversial. Since odors cannot
be measured directly, the reviewer must rely upon information documenting
odor complaints. This information can usually be obtained from the county
health department, the wastewater treatment plant, or the District or State
EPA or its equivalent.
Data Required
The data required depend, to some extent, on the type of project being eval-
uated. For those projects in which ambient air quality in general is a con-
cern, the SAROAD data base would supply the reviewer with the data required.
In addition to the raw data, the reviewer will also need to contact the State
EPA or equivalent to obtain background information on the location of sta-
tions and the pollutants monitored. Projects with issues centering on the
emissions from a stationary source will also require data from NEDS. The
reviewer may wish to use these two data bases in combination with one another
to identify and relate changes in regional air quality with emissions from
individual sources.
Information regarding odor complaints may be derived from sources which vary
from project to project. Contact the local health department, the District
EPA or equivalent, the State EPA or equivalent, or the facilities operators
(e.g., the wastewater treatment plant or landfill, etc.).
Impact predictions are obtained from the NEPA document.
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Method
The method consists of five basic steps; (1) determination of baseline ("be-
fore" project) air quality, (2) compilation of predicted impacts, (3) deter-
mination of actual impacts based on current ("after" project) data, (4)
determination of those impacts directly attributable to the project as
opposed to those attributable to other actions in the area, and (5) assess-
ment of the accuracy of impact prediction.
The statements of predicted impacts will take one of three forms, as follows:
quantitative absolute, quantitative relative, or qualitative. A quantitative
absolute prediction states the value of the parameter at some future date
(sulfur oxides = 80 ug/tP, or 0.08 ppra by 1990). Quantitative relative
predictions describe the change from base line values at some future date
(less than 10% increase over the planning period is expected). A prediction
that is qualitative suggests the direction of change, but not the magnitude
(construction would be expected to only slightly increase the local dust
levels).
For air quality issues, the magnitude of change may not be directly presented
in the statements themselves. For example: "An examination of the results
of the air dispersion analysis indicated that the impacts....will be minimal"
is written as a qualitative statement although the analysis probably produced
a quantitative prediction. This type of prediction is often found in the air
quality sections of NEPA documents. In almost all cases, the impacts are
summarized in qualitative terms regardless of the type of analysis used. The
entire NEPA document, especially appendices, may have to be reviewed to
retrieve the actual quantitative absolute predicted values. Similarly,
"significance" of the predicted impact is frequently determined by whether or
not the applicable standards (for ambient air quality) will be exceeded.
Air pollution does not follow defined regional, state, or local jurisdiction
boundaries, but may be influenced by sources many miles from the project
area. It is not always possible, therefore, to determine if identified
changes in pollutant levels are the direct result of the project. The re-
viewer must recognize this fact when evaluating the accuracy of predictions
presented in NEPA documents.
In the event that the NEPA document does not discuss air quality impacts, the
reviewer should assume that this implies either no impact or no significant
impact was anticipated. The difference between the "before" project or base-
line data and the most recent "after" project data can be compared to deter-
mine the validity of this implied prediction (i.e. no change in pollutant
parameters). If the reviewer discovers that the prediction was not met (e.g.
the concentration of pollutants have noticeably increased), the NEPA document
and associated planning documents should be reviewed to determine if informa-
tion contained in the documents may have lead to an alternate prediction. If
this type of information is not found, more detailed studies may be re-
quired.
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Specific Steps
Information obtained from these steps is to be complied using the evaluation
forms described in Chapter II.
1. Identify counties and applicable local areas affected. This involves a
review of the "Introduction" and "Affected Environment" sections of the
NEPA documents to delineate the area(s) for which impacts are predicted.
2. Identify the predicted impacts regarding ambient air quality standards or
other identified pollutants in the case of emission sources. The speci-
fic pollutant parameters will be based on the emphasis stressed in the
NEPA document. The "Impacts", "Affected Environment", and "Appendices"
sections of the project NEPA document(s) may have to be reviewed to
retrieve the results of the air quality analysis predictions as well as
the qualitative summary statement(s). If the most precise prediction is
"the standards will be met", then the standards themselves can be taken
as an limit boundary on the range of predicted values.
3. Retrieve ambient air quality data for the project area and the AQCR.
Specifically, data must be retrieved from SAROAD for monitoring stations
in and near the affected area and from NEDS for identified emission
sources. If pollutant loadings from point sources are predicted, the
NEDS data base will provide current emissions data for these sources.
Collect odor complaint data.
4. A comparison of the predicted impact to the current monitoring data will
provide the reviewer with a determination of the accuracy of the pre-
dicted impacts. For purely qualitative predictions, certain qualifiers
(such as slight, insignificant, moderate, substantial, significant) will
require subjective professional judgment by the reviewer. In order to
assess the potential impacts from other pollutant sources, the reviewer
should also contact the State EPA or equivalent to determine if any major
new sources have been constructed in the surrounding area since the base-
line year. Loadings of pollutants from new sources (determined from
NEDS) can be reviewed with respect to prevailing winds and other meteoro-
logical data to provide insights into the differences between actual and
predicted impacts. The magnitude of impacts from proposed or new
sources, however, cannot be quantified without extensive modeling.
Products Required
Evaluation forms must be completed for each prediction, and for each para-
meter to be evaluated. A narrative on the analysis including an interpretive
section discussing the evaluation forms must be prepared.
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CHAPTER XIV
INTERRELATED/OTHER ISSUES
UNFORESEEN/UNANTICIPATED IMPACTS
Introduction
In any project the potential exists for impacts to arise which were pre-
viously unforeseen. • This is not to say that the planners did not do an ade-
quate job or used faulty methods, but simply that certain factors cannot
always be taken into account or are not always known in the planning phase.
If, for example, the SHPO advises that a survey of the study area will not be
required, the applicant rightly assumes there is little possibility of dis-
rupting unknown archaeological materials. This assumption, however, does not
guarantee that artifacts will not be encountered during the construction
phase. Likewise, if protected open land along an interceptor route was to
remain undeveloped because of zoning policies, but the land was later found
to be extensively subdivided, it was probably because the planner assumed
zoning policies would not change over the planning period.
It must also be understood that NEPA documents are prepared based on Federal,
State and local regulations, policies, guidance documents and scientific
expertise appropriate and applicable to that period of time (when the term
NEPA documents is used in this manual, it refers not only to the EIS, but
also to the EID/EA, facilities plan, Draft EIS, and other associated docu-
ments). As time passes, the scientific base of knowledge, public concerns
and issues all change as do Federal, State and local regulations and poli-
cies. As the reviewer examines the NEPA planning documents, it may first
appear that certain issues or projections may have been overlooked or omitted
when, in fact, at that time, there may have been no particular policy requir-
ing such projections. Also, techniques may have not been available to assess
them. For example, EPA's Statement of Procedures on Floodplain Management
and Wetlands Protection was not formalized until 1979. Prior to that time,
1973, EPA had policies to examine wetlands and floodplain issues, and, there-
fore, they may have been addressed differently _in the NEPA planning docu-
ments.
A list of possible unforeseen or unpredicted impacts is presented below. The
reviewer should note that this is in no way an exhaustive listing. It is a
sample of ideas a reviewer can build upon. Each project is unique and may
result in additional and/or different impacts.
0 Increased or decreased recreational opportunities
due to changes in land use or wildlife habitat -
For example, creation of an artificial wetland at
the cost of low value wildlife habitat may result
in a predicted loss of small game hunting opportun-
ities for rabbit and squirrel but produce unantici-
XIV-1
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pated opportunities for waterfowl hunting and bird
watching.
0 The discovery of unknown valuable natural resources
including mineral resources - Although this is rare,
it nevertheless has been known to occur.
° Loss or contamination of drinking water
supplies caused by unforeseen hydrological
connections - For example, dewatering for
construction may lower groundwater tables.
This could cause shallow wells to run dry.
Homeowners utilizing shallow wells would
then be required to construct new wells
or find other sources of drinking water.
° Loss or gain of wetlands caused by unpredicted
hydrological connections resulting from construc-
tion activities.
0 Unforeseen tradeoffs - For example, a lake
area may be sewered to reduce or eliminate
blue-green algae blooms cause by septic
wastes. While blue-green algae populations
may be reduced, they may be replaced by
nuisance raacrophyte species.
° Municipal or sanitary district, entrepreneurship
of sludge is not realized causing operation,
maintenance and replacement constraints.
° Impacts caused by change orders or construction
decisions which are left to the discretion of
the contractor - If change orders are made to
include service to areas not previously included
in the service area, unpredicted impacts associated
with these changes can occur. Likewise, if impacts
are predicated on an assumed routing of interceptors
but the actual routing does not follow this
assumption, unpredicted impacts may occur.
Routing a pipeline through large salvageable
trees to gain salvage value vs. rerouting through
small saplings could be an example of these
impacts.
0 Cost overruns and faulty construction practices
are also impacts which are normally unforeseen -
These can result in major economic impacts from
the project. This is especially a concern if
the cost overruns which increase user charges are
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consistently due to certain construction activities by
particular offices or contractors.
0 Water quality impacts - The NEPA documents may
accurately predict growth along floodplains
or streams, but local land use changes could vary
zoning ordinances leading to new sources of
sedimentation or channelization, which are counter-
productive to the stream quality improvements
realized through wastewater treatment. The
reviewer should always consider potential indirect
impacts.
0 Cumulative impacts - Individual impacts may be
assessed correctly, e.g., as having no significant
impact, but when evaluated collectively, as in an
aggregate analysis of environmental issues, the
combined impacts may cause beneficial or adverse
impacts. Action in and beyond the study area or
the Construction Grants program could reflect
cumulative impacts, for example: the construction
of a WWTP may warrant the removal of a small por-
tion of a wildlife corridor, but while the magni-
tude of the change could be deemed insignificant
at the project land, it could, on a broader scope,
reflect intrusion into an isthmus-like food supply
migratory route.
There is also another group or type of unforeseen impacts which can be con-
sidered chronic but correctable. This type of impact is associated with
equipment and material failure or inadequate considerations for equipment
and/or operations. An example of equipment failure would be if a liner were
used for a landfill, and for the purposes of planning, it is assumed the
liner would remain intact and no leakage would occur. A failure of this
piece of equipment would result in unanticipated impacts which might become
serious if groundwater became contaminated. Similarly, planning documents
assume a WWTP will be operated to achieve their designed effluent require-
ments. If this does not occur, unanticipated impacts will result. These
could include increased operating costs, degradation of water quality, sludge
handling problems, etc.
As previously stated, these examples are not exhaustive and it is the re-
viewer's responsibility to identify impacts which may have been consistently
overlooked by the authors of the NEPA documents. This requires some degree
of expertise with impact prediction and environmental review. Only those
overlooked impacts which can be directly linked to the project should be
addressed. The reviewer should omit those impacts where a clear relationship
to the project cannot be established. It is not necessary for the reviewer
to absolutely quantify the degree of relationship between the impact and the
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project (e.g., 40% attributable to the project), but the relationship must be
established.
Data Required
Theoretically, there would be an infinite number of unanticipated impacts
covering an infinite number of issues. In order to limit the extent of this
examination to a manageable level, a regulatory basis has been chosen to
serve as a point of reference. The reviewer should use photos, maps, the
Code of Federal Regulations and Executive Orders to define issues which must
be examined. Textual data required are: 40 CFR Part 6, 40 CFR Parts
1500-1508, and any Executive Orders pertaining to environmental matters,
applicable to NEPA documents.
Method
Before the reviewer determines if any unanticipated impacts have occurred, a'
firm understanding of the baseline leading toward the predictions in the
study area should be gained. During the evaluation, the reviewer should also
be aware of the areas which are typically examined within current NEPA docu-
ments. The separation of procedures during the time of the baseline and cur-
rent procedures serves to perspectively focus the dual nature of the pre-
dicted/actual impact analysis. Once the initial evaluation is completed, the
reviewer should re-examine the NEPA document to determine the presence or
absence of unanticipated impacts.
Specific Steps
1. A review of the most current NEPA implementing regulations as promulgated
under 40 CFR Part 6 and 40CFR Parts 1500-1508 is necessary. Through this
evaluation, the reviewer should be able to develop a list of issues typi-
cally examined in NEPA documents. This list should be similar to the one
presented below which was developed from a review of 40 CFR Parts &.202
and 6.300.
Historic & Archaeological Resources
Wetlands
Floodplains
Agricultural Lands
Coastal Zone Management
Wild and Scenic Rivers
Fish and Wildlife
Rare, Threatened and Endangered Species
Hydrology
Geology
Noise
Air Quality
Biology
Socioeconomics
Energy
Land Use
Cultural Resources
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The list developed by the reviewer should be extensive. Once the list is
developed, it should be reviewed as one performs the tasks of each issue
chapter to remind the reviewer of the potential areas of unanticipated
impacts. Although all issues in the list may have been examined, the
reviewer of the NEPA document may find items to investigate based upon
current procedures of environmental analysis. While the investigation
may or may not disclose overlooked issues, every such examination, when
documented, helps refine the concepts of significant and no significant
impacts.
The reviewer should examine the NEPA documents and develop a list of
issues addressed in the documents. This is compared to the list of
issues from regulations and Executive Orders (as prepared above) to iden-
tify issues omitted or apparently addressed insufficiently in the NEPA
documents. A third list of omitted or insufficient issues should be pre-
pared. Issues addressed in the NEPA documents are examined as part of
the evaluation of actual vs. predicted impacts.
After identifying any issues which may have been omitted or were insuf-
ficiently addressed, the reviewer should determine if there was any
potential for impact. This can be done in-house, via telecommunications
and/or on a site visit. For example, if a document did not discuss
floodplains, the reviewer should determine if there are any floodplains
in the project area. This can be done by checking the maps first, then
if necessary, by contacting the Federal Emergency Management Agency or
the local agency responsible for Floodplain Insurance. The reviewer can
contact the agency and determine through a telephone interview, if any
100-year floodplains exist in the study area. If no floodplains exist,
then no unanticipated impacts could have occurred. The reviewer should
be sure to document his or her findings. (Telephone interviews, like all
crucial questions/answers in the evaluation process, should be tran-
scribed onto an evaluation form.) If the reviewer discovers floodplains
do exist, he or she should briefly explain the project to the agency
official and then ask if they have any knowledge of impacts which may
have occurred as a result of the project. The reviewer should be sure to
document their findings (be sure to obtain the telephone number, name and
title of the person interviewed). If the agency official has no knowl-
edge of any impacts, the reviewer may also want to contact other local
officials such as the Local Planning Agency, County Engineer, Mayor, etc.
to verify his or her findings. If necessary, the verification could be
made in a site visit. IN NO CASE SHOULD THE REVIEWER TRY TO PREDICT
IMPACTS WHICH MAY HAVE BEEN OMITTED FROM THE NEPA DOCUMENT. If all
agencies/officials contacted are unable to identify any impacts, and a
site visit for this particular issue is not warranted, the reviewer can
assume none have occurred. The reviewer should refer to EPA's Directory
of Environmental Data Bases for Illinois, Indiana, Michigan, Minnesota,
XIV-5
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Ohio and Wisconsin. This directory lists numerous information sources
for various environmental issues in Region V.
The reviewer may find that local expertise is not always available for a
particular issue. In these cases, the reviewer should try to interview a
local official with the greatest probability of having knowledge of a
particular issue. Local organizations with environmental concerns, such
as the Izaac Walton League, Sierra Club, Local Chapter of The National
Wildlife Federation, League of Women Voters, local or regional university
professors, etc., can also provide the reviewer with valuable insights
into unanticipated impacts.
Products Required
1. List of any unanticipated impacts which have been identified, including
a discussion of how the impact is related to the project. The impact
does not necessarily have to be quantified.
2. Documentation of all agency/source contacts including a summary of find-
ings; telephone numbers, names, titles, etc.
3. Any data sources upon which a determination of impact was made by a re-
viewer, agency, official, environmental representative, etc.
4. Current policies, guidelines, regulations, etc. used to determine whether
omitted issues were or were not applicable to the project period. Pre-
1977/78 projects may not have addressed floodplains and/or wetlands in
the manner prescribed by current guidelines. This may be due to changes
in EPA requirements since that time.
5. Evaluation forra(s).
MITIGATING MEASURES
Introduction
Mitigating Measures are those actions which are taken to reduce the degree or
severity of impacts normally associated with a particular action. Mitigating
measures can be classified into two groups based upon the permanency of the
mitigating measure. These are short-term mitigating measures and long-term
or permanent mitigating measures. Examples of short-term migitation measures
would be all activities for the abatement of erosion and sedimentation; the
control of fugitive emissions (e.g., dust) by wetting roads, the use of water
curtains, filters, etc.; the erection of temporary noise or visual barriers;
or timing construction activities with environmental conditions which mini-
mized impacts (e.g., stream crossings during low flow conditions). Long-terra
mitigation measures include permanent visual screens, the use of appropriate
treatment technologies (e.g., ozone vs. chlorine to reduce impacts to aquatic
species), monitoring programs, such as groundwater monitoring wells, restora-
XIV-6
-------
tion and landscaping, preCreatment, building design, up-to-date user charges,
etc.
It is extremely important that the reviewer determine if mitigating measures
have been carried out. However, the reviewer must also realize that it may
not always be possible to determine if short-term mitigation measures have
been followed. Temporary mitigation measures which have already been removed
will be unavailable for verification. The extent to which short-terra miti-
gation measures can be evaluated is dependant on the timing of construction
activities and other schedules as well as the timing of the NEPA evaluations.
These schedules may be described in the NEPA documents. Any long-term miti-
gation measures, social, economic or geophysical, should be verified. Site
visits will often be the preferred method of verification.
Data Required
The reviewer will need to examine the NEPA documents to determine all direct
and implied mitigation measures which were to be taken. Through site visits
or other means, the reviewer should determine the actual mitigation carried
out for the project(s) in question.
Method
The method for evaluating mitigation measures consists of two primary steps:
identification of recommended and required measures and verification of
actual mitigation measures. Mitigation measures are stated in terms of what
is to be done and/or the goal to be achieved. The reviewer will (1) verify
the mitigating measures taken and, in many cases, (2) determine if the goal
of the measure was met.
Specific Steps
1. The reviewer should examine the NEPA documents to determine the specific
mitigation measures which are required and/or recommended. This informa-
tion is generally in the "Affected Environment", "Environmental Conse-
quences", "Recommendations", or "Grant Conditions" sections of the NEPA
documents. Other chapters, however, should not be overlooked. The re-
viewer should also note those measures which are long-term or short-
term.
2. Next, the reviewer verifies the existence or non-existence of the pro-
posed/required mitigator(s). Only those impacts relative to the project
should be addressed.
"The treatment plant site will be surrounded by
existing and planted vegetation and mounds which
will serve as additional sound barriers."
(Source: EIS, Olentargy Environmental Control
Center, 1976, Delaware County, Ohio)
XIV-7
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Verification of the mitigators described is most easily accomplished through
a site visit. Although the reviewer, depending on the scope of the
evaluation study, may not choose to calculate the degree to which vegetation
and mounds buffer noise, he/she can see if vegetation has been planted or
mounds built and make a. qualitative statement based upon that observation.
Products Required
1. A list or description of verifiable mitigating measures from the NEPA
documents. This should also include objectives as provided in the docu-
ments.
2. Verification of the mitigation measures and a determination of how well
the mitigators served to accomplish the associated goal/objective as
appropriate.
3. Evaluation form(s).
XIV-8
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APPENDIX A
DATA BASE REPORT
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APPENDIX A
DATA BASE REPORT
Introduction
The objective of this Appendix is to present a list of computerized and man-
ual data bases which should be used with the Manual for Evaluating Predicted
and Actual Impacts of Construction Grants Projects. In general, the evalua-
tion of generic issues or programmatic evaluations is well suited to the use
of computerized data bases while reviews of individual projects are best
facilitated by the use of manual data files. An evaluation of data bases is
presented in Table A-l, which can be found at the end of this Appendix.
Computerized Data Bases
The initial step in analyzing data bases was to first address those data
bases and sources included in EPA's preliminary environmental data base re-
port prepared by WAPORA. (Directory of Environmental Data Bases for Illi-
nois, Indiana, Michigan, Minnesota, Ohio and Wisconsin 1984.) Data available
through Corps of Engineers, EPA's Monitoring Systems Laboratory, Fish and
Wildlife Service, were also addressed as well as a search of the Encyclopedia
of Information Systems and Services published by Gale Research Company (an
international guide to computer readable data bases, library and information
networks, and library management systems). Several critera were used to
evaluate each data base.
0 Is it machine readable? If a data base is not machine readable, the
cost of putting it into a computer base mode would be prohibitive.
0 Is it uniform throughout the region? If we are to compare projects
throughout the region with any degree of confidence, the information
used must be uniform.
°. Is there historic data? Since our analysis will most likely be with-
in the design life of the project, project life impacts will not be
able to be addressed directly and therefore deviations from the his-
toric pattern of change must be addressed.
° What is the confidence level in the updating procedures? If any com-
parison is to be valid or any methodology implemented, there must be
some confidence that the information will be updated accurately and
on a periodic basis.
Nearly 2,500 computer based data systems are currently available. Approxi-
mately 150 address natural and human environmental data relating to environ-
mental impact analysis. Of these, only three meet all of the above criteria
for generic project analysis. Even if the resources were available to EPA to
make other data systems compatible, the probable cost and the time required
A-i
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would be prohibitive when compared to the benefits derived. In addition, the
lack of sufficient historical data would continue to be the major data prob-
lem.
All three data bases meeting the previously described criteria are computer
based information systems which are currently maintained by federal agencies.
These include EPA's Grants Information Control System (GIGS) data base, U.S.
Census Summary Tape Files 3A, and EPA STORET system.
Grants Information Control System (GIGS)
The GIGS data are used primarily to provide information on a specific pro-
ject, including information in its design and construction. GIGS information
is essential in identifying separate projects and the data includes 30 ele-
ments as follows:
GIGS
Transaction No.
01
02
03
54
04
12
13
14
15
19B
20
23
24
25
32
33
45
92
98
99
B2
C2
D3
E6
F5
F6
Ml
N4
N5
N7
GIGS Data Element Name
Serial Number
Program Code Full Grant Identification
Amendment Designator Number
Sequence Number
Legislative Authority
Applicant Name
Applicant State Abbreviation
Applicant City Name
Project County Name
Cumulative EPA Funds Awarded
Project Description
Action Step Code
Action Step Date
Facility River Basin Code
Authority/Facility Number
Alternative System for Small Communities
Population Code
Percent Wastewater Treatment Construction Complete
Sludge Disposal Techniques/Design
Total Flow Capacity/Design
Grant # - Parent Project
Permit Number
Wastewater Management Technique/Design
Effluent Discharge/Design
BOD - Influent Design
BOD - Effluent Design
EID Review Code and Data
Final EIS Code and Date
Project Completion Code and Date
Funded Works and Operation Code and Date
A-2
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U.S. Census Summary Tape
The U.S. Census of Population and Housing Summary Tape Files 3A is used to
provide socio-economic information. Elements of data which can provide
useful information include:
Table # Description
1. Persons,
6. Housing Units Total,
10. Households,
11. Housing Units Year Round,
65. Employment by Industry,
140. Median Housing Value,
141. Median Household Income,
EPA STORET
STORET is a large-scale computerized STOrage RETrieval system for water pol-
lution measurement data collected from observation stations across the coun-
try. This data base was set up as a national repository of physical/chemical
water quality data for surface waters throughout the United States. As such,
STORET contains not only water quality data from those observation stations
which are monitored on a regular basis, but also from stations which are mon-
itored infrequently or even those for which information was collected on a
one time basis. Its water pollution data are derived from laboratory anal-
yses of water samples. The data are acquired from the USGS's National Water
Data System and from a variety of pollution abatement agencies at federal,
state, and local levels each with varying data needs. Because of the differ-
ing data needs from agency to agency and from station to station, the para-
meters analyzed at any one station vary accordingly.
Data Gaps in Computer Systems
Significant gaps currently exist in computerized data bases to facilitate
their total use in inplementation of this Manual. Current data bases which
met the four criteria were not found for the following parameters:
Soils
Topography
Geology
Plant & Animal Communities
Fish & Wildlife
Noise & Odors
Solid Waste
Energy Resources
Endangered Species Habitat
Rare Ecological Communities
Floodplains
Wetlands
Prime Farmlands
Steep Slopes
Land Use
Historical & Archaeological Sites
Recreation & Open Space
A-3
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Manual Data Bases
Since machine readable computerized data bases cannot meet all of the data
needs for NEPA evaluations, the reviewer will be required to locate and util-
ize manual data files. Some important sources which should initially be con-
sulted to locate manual data bases are listed on the following pages. For a
more detailed listing of sources, the reviewer is advised to examine the
Directory of Environmental Data Bases for Illinois, Indiana, Michigan,
Minnesota, Ohio and Wisconsin (WAPORA, 1984).
Data Gaps
There are data gaps in three major areas including noise, odor and aesthet-
ics. Noise and odor are subjective factors and are observer dependent im-
pacts.
While noise is a measurable phenomenon, unless noise measurements were made
prior to construction, the only analysis which can be done is in terms of
current noise levels. This will require field measurements.
A-4
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LIMITED SOURCES OF ENVIRONMENTAL 'DATA*
1. SOILS
State Soil Conservation Service Offices1
Soil Conservation Service (SCS)
U.S. Department of Agriculture
Post Office Box 2890
Washington, D.C. 20013
Telephone: 202/447-4543
2. TOPOGRAPHY
Areas east of the Mississippi
U.S. Geological Survey
Eastern Distribution Branch
1200 South Eads Street
Arlington, VA 22202
Telephone: 703/557-2751
Areas west of the Mississippi
U.S. Geological Survey
Western Distribution Branch
Box 25286, Federal Center
Denver, CO 80335
Entire United States
National Cartographic Information Center
507 National Center
Reston, VA 22092
Telephone: 703/860-6045
3. GEOLOGY '
U.S. Geological Survey
907 National Center
Reston, VA 22092
Telephone: 703/860-6517
State Geologic Survey Offices^
4. PLANT AND ANIMAL COMMUNITIES
U.S. Fish & Wildlife Service
Federal Building, Fort Snelling
Twin Cities, MN 55111
Telephone: 612/725-3500
For a detailed listing of sources in Region V, see the Directory of
Environmental Data Bases for Illinois, Indiana, Michigan, Minnesota,
Ohio and Wisconsin (WAPORA, 1984).
A-5
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5. SENSITIVE WILDLIFE INFORMATION SYSTEM (SWIS)
U.S. Army Corps of Engineers
Waterways Experimental Station
Post Office Box 631
Vicksburg, MS 39180
U.S. Forest Service
Region 9 - Eastern Region
633 West Wisconsin Avenue
Milwaukee, WI 53203
Telephone: 414/291-3693
State Sources
6. FISH AND WILDLIFE
(See Plant and Animal Communities)
7. NOISE AND ODORS
State EPAs or equivalent^
Local Health Departments
Facility Offices (e.g. wastewater treatment plants,
solid waste disposal facilities, etc.)
8. SOLID WASTE
State EPAs or equivalent4
Local Health Departments
County Engineer Offices
Local Planning Agencies^
9. ENERGY RESOURCES
Local Utility Companies
Facility Offices
10. ENDANGERED SPECIES HABITAT
(See Plant and Animal Communities)
11. RARE ECOLOGICAL COMMUNITIES
(See Plant and Animal Communities)
A-6
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12. FLOODPLAINS
Federal Emergency Management Agency
National Flood Insurance Program
Post Office Box 34222
Bethesda, MD 20817
Telephone: 800/638-6628 or 800/424-8872
NOAA Regional Coast Information Center (RCIC) Network
11400 Rockville Pike
Rockville, MD 20852
Telephone: 301/443-8137
13. WETLANDS
U.S. Fish & Wildlife Service
Federal Building, Fort Snelling
Twin Cities, MN 55111
Telephone: 612/725-3500
14. PRIME FARMLANDS
(See Soils)
15. STEEP SLOPES
(See Topography)
16. LAND USE
Regional Planning Commissions^
Soil Conservation Service
Inventory & Monitoring Division
U.S. Department of Agriculture
Post Office Box 2890
Washington, D.C. 20013
Telephone: 202/447-5424
17. HISTORICAL AND ARCHAEOLOGICAL SITES
U.S. Department of the Interior
National Park Service
440 G. Street N.W.
Washington, D.C. 20243
Telephone: 202/343-6401
State Historic Preservation Offices^
A-7
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18. RECREATION AND OPEN SPACES
National Park Service (NFS)
U.S. Department of the Interior
Midwest Regional Office
1709 North Jackson Street
Omaha, NE 68102
Bureau of Land Management
U.S. Department of the Interior
18th & C Streets, N.W.
Washington, D.C. 20240
Telephone: 202/343-5994
Regional Planning Agencies^
State Departments of Natural Resources
State Park Departments
^ USEPA, Directory of Environmental Databases for Illinois, Indiana,
Michigan, Minnesota, Ohio & Wisconsin, 1984. page 31.
2 Ibid, pages 27-28
3 Ibid, pages 52-60
4 Ibid, pages 34-35
5 Ibid, pages 70-84
6 Ibid, pages 87-88
A-S
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TABLE A-l
DATA BASE EVALUATION MATRIX
Title
0 MI Dept. of Natural
Resources
Wetlands Map
3 MI Natural
Features Inventory
0 WI Dept. of Natural
Resources
Endangered Res.
° Storage & Retrieval
for Water Quality
Data (STORET)
0 National Water Data
Storage & Retrieval
0 Planning Engineering
Data Mgmt. System
of Ohio
0 Wildlife Res. Unit
0 Resource Inv.
Soil Conservation
Service
0 WI Geo Survey
0 IN Geo Survey
0 MI Geo Survey
0 IL Consv. Dept.
0 OH Geo Survey
0 Fisheries DW MI Dept
of Nat. Resources
0 MI Wildlife E&T
0 MN Dept. of Natural
Resources Fisheries
0 MN Dept. of Natural
Resources Wildlife
0 IN Dept. of Natural
Resources
0 IL Div. of Planning
0 WI Dept. Local
Affairs
' Fish & Wildlife
Reference Service
0 MN State Soil Consv.
Service
0 IN State Soil Consv.
Service
Use-
able
Data
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
Machine!
Read-
able
No
No
Some
Yes
Yes
Yes
-
Yes
No
No
No
No
No
-
No
_-
No
Yes
Yes
No
—
No
No
Uniform
in
Region
MI
MN
WI
Yes
Yes
OH
—
Yes
WI
IN
MI
IL
OH
—
MI
—
MN
IN
IL
WI
—
MN.
IN
Historical
Data
No
No
N/A
1960 's
1960 's
No
—
1977
Varies
Varies
Varies
N/A
N/A
— ,
No
—
No
No
1980
Some
—
Some
Some
Adequate
Updating
No
Yes
Yes
Yes
Yes
Yes
5 years
No
No
No
Yes
Yes
Yes
—
Yes
Yes
Yes
Yes
—
Periodic
Periodic
Remarks
Wetlands map. partial
coverage
Fish, wildlife, hab.
not remotely acessible
includes STORET
ag vs urban landuse , flood
soil loss, veg,f loodprone
well data
well data
well data
historic sites
well logs
fish stocking
wetlands inventory
fish counts
wetlands mapping
endanger species collect.
wetlands inventory
farmland preservation
articles-fish & wildlife
prime ag land
past wetlands, croplands
A-9
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TABLE A-l
DATA BASE EVALUATION MATRIX
(Continued)
Title
0 OH Capabilities
Analyses Program
0 IL Department of
Commerce
0 MN Land Information
Center
0 Construction Grants
Evaluation and
Network Tracking
System
0 Grant Information
Control System
0 CACI Inc.
0 IL Floodplain
Repository
0 MI Info. Center
0 National Data
Planning Corp.
0 National Labor Ser.
0 Public Demographics,
Inc.
0 Sensitive Wildlife
Info. System
0 Soil Conversation
Service Soil Staff
0 Urban Decisions/NC
0 MI Metropolitan^
Info. Center
0 OH Dept. of Econ. &
Coram. Affairs
0 Census Tapes
0 Geographic Base File
Dual Independent
Map Coding
Use-
able
Data
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
No
No
Yes
Yes
No
Yes
Yes
Machine
Read-
able
Yes
Yes
Yes
Yes
Yes
Yes
—
Yes
Yes
—
Yes
—
—
Yes
Yes
—
Yes
Yes
Unif orn
in
Region
OH
IL
MN
Yes
Yes
Metro
—
MI
Yes
—
Yes
—
—
Yes
MI
—
Yes
Yes
Historical
Data
1973
1981
1969
Yes
Yes
1962
—
1980
1969
—
1981
—
—
1972
1981
—
Yes
N/A
Adequate
Updating
One time
Yes
1980
Yes
Yes
Census
—
Census
Census
—
Census
—
—
Census
Census
—
Census
N/A
Remarks
landuse,f loodplains , ag
land
industrial sites
forest wetlands, ag geo
county vs. basin
project data
census manipulation
index of studies
census manipulation
census manipulation
labor market experience
census manipulation
habitat mapping
maps soil suitability
file manipulation
census manipulation
area conversions
N/A = Not Applicable
= Data Not Uniform Among States
A-10
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APPENDIX B
DATA BASE MANAGEMENT
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APPENDIX B
DATA BASE MANAGEMENT
Introduction
Although the amount of data produced with each evaluation will vary as muli-
tiple evaluations are completed, a large amount of data will be assembled.
Unless a systematic approach to data management is used, the data will become
unwieldy. The purpose of this appendix is to: (1) provide the reviewer with
an understanding of the types of data which will need to be stored and re-
trieved; (2) explain the method of filing to be used; and (3) describe the
steps required to the reviewer to implement the system for a specific study.
Types of Data
Three types of data must be maintained in support of this manual. These in-
clude computerized data base files, manual data base files and the results of
the evaluation. The computerized data base files are Grants Information Con-
trol System (GIGS), the D.S. Census of Population and Housing Summary Tape
Files 3A (STF 3a), and EPA STORET. GIGS and STORET are updated by the USEPA
as data become available. The STF 3A are updated by the U.S. Department of
Commerce at ten-year intervals. Complete summary tape files have not been
available, historically, until two or three years after the census year. STF
3A are available at the time of this writing for the 1980 census and have
been purchased by the USEPA, Air Programs, Strategy & Air Standards Division
at Research Triangle Park, North Carolina.
While some manual data base files may be maintained by USEPA, others must be
retrieved from their source on an "as needed" basis. In both cases, the
files must be uniformly catalogued in order to allow the user to quickly find
the file for use. Likewise, once a file is obtained from another source, a
cataloguing system must already be in place in order to eliminate duplication
of data collection in future evaluations.
The evaluation results will produce two types of data; the evaluation forms
and the narrative discussions. The extent of the evaluation results is
dependent on the objectives of the specific evaluation and the issues asso-
ciated with the project.
Method of Cataloging
Computerized Data Base Files: The computer data base files will be in the
Statistical Analysis System (SAS) data sets. All data can be stored if com-
mon elements are included. (See Evaluation Form, Figure II.1). The common
elements within the GIGS file are state, county and local applicant names as
well as the Needs (or Facility) Number. All projects which are evaluated
must select a single or several common elements. STORET data are catalogued
(and retrieved) using the Needs Number, state, county, and river basin, and
B-l
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latitude and longitude designations. STF 3A can be catalogued by state,
county and place (city, village or township). If, for example, a SAS data
set is to require the merging of all three data bases, the common array (or
single) element(s) must assure linkage among the dissimilar files.
Manual Data Base Files: Data base files which are not computer based must
have a four level cataloguing system. Initially, the data base must be filed
by issue. The issues must conform to the issues which divide this manual
into chapters. The second level of cataloging is the parameters used as in-
dicators of impacts. The third level is to catalogue by state. Once the
state is identified, the only uniform indicator or geographic location is the
latitude and longitude. Effectively, both computerized and manual data bases
share common identifiers. An example of this system would be as follows:
CULTURAL RESOURCES ISSUES
Archeological Sites
Indiana
41°37' N, 87°30' W
Evaluation Results: The evaluation forms have been developed as computer in-
put forms. If they are filed in a computer, they will be retrievable via any
of the elements in the form, but files cannot be sorted beyond the year for
element #8 and elements #10 through #13. If the narrative report is not
entered in the computer, it should be catalogued via the Facilities Number
and Project Name. If it is a part of the computer's word processing element,
it can be catalogued via the same common elements of the computerized data
base files.
Specific Steps
Based upon a review of data to be managed, an approach for data base manage-
ment is presented. The following steps should be followed to implement this
system.
1. Set up filing system for the specific project. At the time of this writ-
ing, the computer based filing system has not been set up. When the
computer filing system is on line it will consist of a SAS manipulated
data set using a FORTRAN programmed system of prompts. Until the com-
puter filing system is on line a hard copy file for the project must be
set up using the catalogue system discussed above.
2. Set up File for the Evaluation Forms and Narrative Report. Prior to em-
barking on the actual evaluation, the file for the evaluation forms and
narrative report must be set up. The narrative report must contain the
identification elements discussed above.
B-2
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3. Insure that most recent census information is available. After the 1990
census, it will be necessary to obtain the 1990 STF 3A or the equiv-
alent.
4. Retrieve Computer Data Bases. After the issues are identified, the ap-
propriate computer data bases must be accessed and the information re-
trieved and filed for use in the evaluation.
5. Retrieve Manual Data Bases. The manual data bases which are required
must be retrieved for the evaluation. See the Appendix A, for sources.
6. File Results. Once the evaluation is complete, the results must be filed
properly to insure future retrieval.
7. Purge Files. Once the evaluation results are filed, the hard copies
(print-outs) of the STORE! and STF 3A data should be deleted. There is
no reason to keep such data when it can be retrieved from the original
computer files. Likewise, the information from STORET and STF 3A, which
is contained in the computerized project files, should be deleted since
it can be retrieved from STORET and STF 3A at any time in the future.
B-3
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APPENDIX C
ANNOTATED BIBLIOGRAPHY
-------
Blank Page
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APPENDIX C
ANNOTATED BIBLIOGRAPHY
Introduction
This annotated bibliography is provided as Appendix C to the Manual for
Evaluation of Predicted and Actual Environmental Impacts for Construction
Grants Projects in order to provide the user with additional sources of
information. It is anticipated that any review of NEPA documentation may
identify issues which have not been addressed by this manual or situations
which are unique to a specific project. This bibliography will provide the
reader with an identification of the documents and a brief abstract of their
content in order to allow the reader to understand how they might assist him
in his evaluation.
The bibliography is not meant to be an exhaustive listing of the literature
pertaining to environmental impact analysis, but rather those deemed to be
pertinent fay the writers of this Manual.
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Bascom, S.E., K.G. Cooper et.al., 1975. Secondary Impacts of Transportation
and Wastewater Investments, Council on Environmental Equality, Depart-
ment of Housing and Urban Development, and Environmental Protection
Agency, Washington, D.C.
A broad picture of the impact of public investment in transportation and
wastewater facilities is provided. Because most of the research at the time
of the writing of the document was in transportation facilities, that is its
emphasis. Much of the work done prior to 1975 included large modeling of
metropolitan areas and this is reflected in the body of the document.
Canter, L. 1979. Environmental Impact Statements on Municipal Wastewater
Programs. Information Resources Press. Washington, D.C.
A series of suggestions and recommendations for improving EIS's on wastewater
facilities was provided in this document. It first provided a substantive
review and analysis of draft and final EIS's on wastewater facilities plans,
identified their deficiencies, and strong points, and determined the degree to
which EPA was addressing critical issues in wastewater planning. The goal of
the document was to provide guidance in preparing better EIS's and thus
increase the effectiveness of wastewater management planning. The actual
projects for these EIS's were not analyzed nor were the after construction
impacts. Only the EIS document itself was examined. The document provides
good insight into what types of issues and how those issues were addressed in
a number of wastewater treatment environmental impact statements.
Christensen, K. 1976. Social Impacts of Land Development. Urban Institute
Washington, D.C.
This is one of five documents by the Urban Institute addressing the impacts
of land development. The report suggests an approach and data collection
procedures to enable planners to estimate the social impact of proposed land
development. It provides an insight into the relationship of land develop-
ment and social impacts such as recreational patterns and use, shopping
opportunities, pedestrian mobility, perceived quality of the national en-
vironment, safety and privacy, aesthetics and cultural values. It also pro-
vides a discussion of the approaches to estimating impacts which could be
used to verify impact analysis by field study.
Fitzpatrick, M. J. Wilson, et.al., 1971. Manual for Evaluating Secondary
Impacts of Waste Water Treatment Facilities, U.S. EPA, Washington, D.C.
The Manual provides procedures for assessing secondary impacts, including
both subjective and objective impact analyses. It is unique in that it pro-
vides more than one level of analysis in its description. The first level
approach as they describe it is an initial estimate; the second level
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approach is to provide a refinement of the judgemental findings; and the
third level is to project growth and allocate population and industrial acti-
vity. This document can provide the reviewer with an understanding of the
differences which he will find among NEPA documents.
Keyes, D. 1976. Land Development and the Natural Environment: Estimating
Impacts. Urban Institute, Washington, D.C.
Four areas of environmental impact from development are addressed. They are
air quality, water quality and quantity, wildlife and vegetation, and noise,
A brief discussion of landslides subsidence, earthquakes, agricultural land,
mineral deposits, and unique natural features is also provided. The various
methodological approaches for estimating impacts are addressed as well as the
measurements and indices for estimating impacts. This document has some
excellent information for a person entering the area of impact analysis. It
should provide that person with sufficient information to understand and
where expert experience is required and where the planner can do the impact
analysis.
Muller, T. 1977. Economic Impacts of Land Development. Urban Institute,
Washington, D.C.
The economic impact analysis in this report is limited to employment,
housing, and real property values. It not only addresses the issues well,
but also provides cause and effect analysis of the interaction among employ-
ment and other economic impacts. It provides an analysis of the methods for
estimating impacts and the data requirements for such analyses.
Muller, T. 1975. Fiscal Impacts of Land Development. Urban Institute,
Washington, D.C.
The fiscal impact analysis provided in this document is of much greater
detail than normally used in environmental impact analysis. The document was
designed for projecting cost revenue for new land development. The analysis
performed in the explanations can give the reader an understanding of the
interaction between development and the costs of government.
Schaenman, P., and T. Muller, 1976. Measuring Impacts of Land Development:
An Initial Approach. Urban Institute, Washington, D.C.
The overall approach addressed in this document provides the reader with a
source document for finding quantifiable impact measures for many areas. Al-
though originally developed for land development, most of the measures have
validity in any project requiring major public investment.
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Schaenman, P., 1978. Using an Impact Measurement System to Evaluate Land
Development. Urban Institute, Washington, D.C.
This document builds on Schaenman and Muller's "Measuring Impacts of Land
Development." It provides preferred measures for impact analysis; the fall
back measures of impact; and the basis for estimates. The impact measures
are for land development but are applicable to any public investment. If a.
new area of impact not covered by the Manual is identified, this is an ideal
source for developing additional methodological statements on evaluation of
predicted and actual impacts.
Urban Systems Research & Engineering. 1974. The Growth Shapers, Council on
Environmental Quality. Washington, D.C.
Growth Shapers is the primer for identifying the relationships within second-
ary impacts. It ties together all elements of infrastructure, investments,
and land use changes. It should be required reading for anyone addressing
secondary impacts for wastewater facilities.
Urban Systems Research & Engineering. 1974. Interceptor Sewers and Suburban
Sprawl. Council on Environmental Quality. Washington, D.C.
The impact of Construction Grants on Residential Land Use is the sub-title
of this study. It addresses the issues of how construction grants policy and
surburban sprawl are interrelated. It also provides recommendations to the
council on environmental quality, some of which were adopted after its pub-
lication. The objective of the study was to reduce the impact of interceptor
sewers rather than measure the impacts of interceptor sewers.
State of New Jersey, 1975. Secondary Impacts of Regional Sewerage Systems.
New Jersey Division of State and Regional Planning. Albany, NY
The most valuable element of this manual are the case studies which it pro-
vides to give an understanding of the causes of secondary impacts. It also
provides suggestions for regulatory controls.
WAPORA, 1980. Manual for Assessing Growth Related Impacts in Delaware
County, Ohio. EPA Region V, Chicago, IL.
This document provides a good comprehensive approach to monitor environ-
mental changes related to population growth. It emphazes the identification
of measurable prameters which best represent important features of the
regional environment.
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WAPORA, 1983. Directory of Environmental Data Bases for Illinois, Indiana,
Michigan, Minnesota, Ohio, and Wisconsin. EPA, Region V. Chicago, IL.
The directory provides a good source of information for one doing environ-
mental assessments within Region V of EPA. Every person preparing an en-
vironmental assessment or environmental impact statement should have a copy
of the directory as their initial source document for data libraries.
WAPORA, 1983a. Environmental'Review Manual for the Construction Grants
Program - Wisconsin Department of Natural Resources. U.S. EPA, 1983.
The Environmental Review Manual for each of the states should be available to
the reviewer when evaluating a NEPA document prepared after the publication
of the Environmental Review Manual. It provides the minimum requirements for
the evaluation of environmental impacts and allows the reviewer to understand
the guidelines provided to the preparer of the NEPA document. It also pro-
vides a list of contacts for information on various impact analyses in each
state.
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APPENDIX D
HOW TO PROVIDE INPUT FOR
FUTURE REVISIONS TO THIS MANUAL
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Provide comments to:
Laurence Adams-Walden, Project Monitor
United States Environmental Protection Agency
Region V
230 South Dearborn Street
Chicago, Illinois 60604
Telephone: (311) 886-0238
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