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Principles of
Environmental Impact Assessment
An International Training Course
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UPDATING AND ENRICHING THIS TEXT
This text will be periodically updated to include new environmental impact assessment
concepts and examples from countries around the world. Readers are encouraged to send
comments and ideas for the next edition to:
United States Environmental Protection Agency
Office of Federal Activities, MC-2251A
401 M Street, SW
Washington D.C. 20460
Ph: 1-202-564-2400
Fx: 1-202-564-0070
INTERNET: http://www.epa.gov/oeca/ofa
Edition: April, 1998
Principles of Environmental Impact Assessment
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ACKNOWLEDGEMENTS
This text is one of two documents that form the basis of a training course on Principles of
Environmental Impact Assessmen (ElA). The other is the Facilitator's Manual, which contains
the guidance, materials, and handouts required for facilitating the course. The text and course are
designed for policy makers from government, academia, public life, and environmental and industrial
organizations, broadly designed for use by anyone interested in an Environmental Impact
Assessment program, in any culture.
The course was prepared in 1991 by the U.S. Environmental Protection Agency (USEPA)
staff in Washington, D.C. Headquarters' Office of Federal Activities and USEPA's Region III
in Philadelphia, Pennsylvania, with assistance from Gannett Fleming, Inc. and EcolSciences. It
is based upon internationally accepted principles and frameworks as well as 25 years of experience
within USEPA implementing its EIA program, as well as the input from many colleagues around
the world. It was first developed in response to a request by Poland's Ministry of Environmental
Protection, Natural Resources and Forestry and subsequently revised for delivery at the request
of the Secretary of Social Development of Mexico (SEDESOL) with financial support from the
U.S. Agency for International Development. Modest revisions to the course materials were
designed by USEPA in response to comments of course facilitators from all EPA Regions and
participants from over a dozen countries over the past five years. These changes were completed
with the assistance of Science Applications International Corporation under EPA Contract No. 68-
W2-0026 in 1997.
Principles of Environmental Impact Assessment
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PRINCIPLES OF ENVIRONMENTAL IMPACT ASSESSMENT
TABLE OF CONTENTS
1. Introduction 1-1
What is the Purpose of This Text? 1-1
What is Environmental Impact Assessment (EIA)? 1-3
Why is EIA Important? 1-4
How May EIA Programs Evolve in Different Cultures and Countries? 1-5
2. Basis for EIAs 2-1
Introduction 2-1
Balanced Decisions 2-2
3. EIA Laws and Requirements 3-1
Introduction 3-1
Environmental Policies and Laws 3-3
Environmental Impact Assessment Regulations 3-3
Full Disclosure 3-3
Timing of EIAs 3-5
Time Limits on the EIA Process 3-5
Alternatives Analysis 3-6
The NEPA Example 3-9
4. Circumstances Requiring EIAs 4-1
Introduction 4-1
Scope of Effect 4-2
Significance of Effect on the Environment 4-2
Public Controversy 4-4
Legal and Financial Requirements 4-4
EIA Process in the United States 4-4
EIA Process in Europe 4-5
Categorical Exclusions 4-6
Initial Environmental Impact Assessments 4-8
5. Key Considerations in the EIA Process 5-1
Introduction 5-1
Purpose and Need 5-1
Public Participation 5-1
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TABLE OF CONTENTS
Scoping 5.3
Interdisciplinary Approaches 5.5
Alternatives to the Proposed Action . ,. . 5-6
Characterization of Impacts ......' 5-7
Primary and Secondary Impacts 5-7
Short Term and Long Term Impacts 5-8
Positive and Negative Impacts 5-10
Cumulative Impacts 5.10
Short-Term Uses and Long-Term Maintenance and Enhancement
of the Environment 5_11
Mitigation and Compensation 5_12
6. Key Steps in the EIA Process 6-1
Introduction g_l
Participants 5.3
Purpose and Need 5.3
Alternatives that Satisfy Purpose and Need 6-4
Screening Alternatives 5.4
Describing the Environmental Setting 6-5
Forecasting and Assessing Impacts 6-8
Biological Environment, Including Terrestrial and Aquatic Habitats 6-8
Water Environment 6-8
Air Environment 6-8
Noise Environment 6-9
Socioeconomic Environment 6-9
Cultural Environment 6-9
Mitigating Adverse Impacts 6-10
Identifying Preferred Alternatives 6-11
Documenting Results and Soliciting Comments 6-12
Decision 5.43
Monitoring and Follow-up 6-13
7. Methods for Forecasting and Assessing Impacts 7-1
Introduction 7_1
Environmental Impact Assessment Methodologies 7-2
Comparative Methodologies 7_H
Checklists 7_12
Matrices 1-Y1
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TABLE OF CONTENTS
8. Writing EIA Reports 8-1
Introduction 8-1
General Format • • • 8-1
Incorporation by Reference 8-5
Stages of Preparation 8-5
General Writing Suggestions 8-6
9. Reviewing and Evaluating EIA Reports 9-1
Introduction 9-1
Commenting 9-1
Inadequacies 9-2
Revisions/Supplemental Reports 9-5
The U.S. Section 309 Environmental Review Process 9-6
10. Building an Effective EIA Program 10-1
Introduction . . . 10-1
Selecting the Appropriate Elements 10-1
Streamlining the Process 10-2
Selecting the Interdisciplinary Team 10-4
Oversight of the EIA Program and Process 10-6
Data Management . 10-8
11. Assessments for Small Projects and Contaminated Sites 11-1
Introduction H-l
Small Project EIAs H-l
Environmental Site Assessments 11-10
12. Lessons Learned from Other EIA Programs 12-1
13. Information Sources 13-1
EPA Resources • 13-1
General References • 13-3
Bibliography of Technical References 13-5
14. Glossary 14-1
15. Model EIA Checklists for Scoping and Impact Assessment 15-1
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TABLE OF CONTENTS
LIST OF TABLES
Page
Table 1-1. The Importance of an Environmental Impact Assessment Program ......... 1-7
Table 2-1. Procedures to Encourage Public Participation in EIA Programs 2-3
Table 3-1. Basic Components of an Effective EIA Program 3-2
Table 3-2. Alternatives Analysis in the EIA Process 3-7
Table 3-3. Implementation of NEPA by CEQ in the United States 3-11
Table 5-1. Categories of Potential Secondary Impacts 5-9
Table 5-2. Categories of Mitigation 5_14
Table 7-1. Checklist of Potential Environmental Impacts of a
Transportation Project 7-14
Table 7-2. Optimum Pathway Matrix - Typical Format 7-18
Table 8-1. Summary Features of Major Components of an EIA Report 8-2
Table 9-1. General EIS Review Procedures and Responsibilities 9-9
Table 10-1. Data Management System Elements 10-10
Table 11-1. Representative Small-Project EIA Report Format 11-3
LIST OF FIGURES
Figure 6-1. The Environmental Impact Assessment Process 6-2
Figure 11-1. Environmental Site Assessment 11-14
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1
INTRODUCTION
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Introduction
1-1
1. INTRODUCTION
Many countries have taken positive actions to protect
environmental resources and public health from
environmental pollution and to restore and enhance the
quality of their natural environments. They have developed
or are developing legislative, procedural, and technical
strategies for assessing the potential environmental changes
caused by: 1) the development of new sites, 2) the
redevelopment of existing sites, 3) the remediation of
disturbed or contaminated sites, 4) use of natural resources,
and/or Significant new government policies and programs.
The common goal of these various environmental laws,
procedures, and regulations is to establish a substantive
environmental policy that protects natural resources,
environmental quality, and public and ecological health and
better integrates economic, social and environmental goals.
Integral to this goal are systematic procedures for
environmental impact assessment (El A).
Most strategies of EIA derive from statutory
requirements that must be addressed in planning for large
and small projects that could, if constructed and operated,
change the nature or quality of environmental resources,
both natural and man-made. An EIA program converts the
language and intent of fundamental environmental laws and
policies into a uniform set of procedural and technical
requirements that permit a systematic review of proposed
actions well before those actions are implemented. In this
regard, EIA is both an early warning process and a
continuing review process that protects sensitive
environmental resources from unwarranted or unanticipated
damage.
WHAT IS THE PURPOSE OF THIS TEXT?
This text has been prepared to help individuals
responsible for environmental protection and impact
assessment in different countries, regions, and localities
design and implement programs of EIA and to help others
participate in the process as reviewers and commentors. It
is intended to provide general and specific guidance in the
principles of EIA for anyone involved in development,
redevelopment, and remedial planning, including
Principles of Environmental Impact Assessment
EIA is an early warning system
and an on-going review
process.
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Introduction
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government officials, nongovernment officials, industry and
academic leaders, environmental scientists and engineers, and
private citizens.
This text is not designed to provide comprehensive
technical guidance in the use of EIA tools such as air quality
modeling, water quality modeling, ecological community
analysis, risk assessment, or fiscal analyses. Such
methodologies are summarized in this text in terms of the types
of approaches available for the assessment of environmental
impacts. In addition, references to texts or manuals that discuss
the specific application of such methodologies are given in
Chapter 13 of this text. The focus of this text, however, is on
the internationally accepted principles that underlie sound EIA
programs rather than on the specific tools or measures of impact
assessment.
This text provides the following:
• A characterization of the nature and importance
of an EIA program.
• A framework for designing and developing EIA
strategies and programs.
• Key considerations in the EIA process.
• A synopsis of general methods for predicting and
assessing environmental impacts.
• Guidance for the preparation of environmental
impact assessment (EIA) reports.
• Examples of existing EIA programs and major
EIA issues.
• Options for incorporating various elements into a
specific EIA program.
• A list of resources that provide further
information.
The successful implementation of EIA procedures
requires significant effort, forethought, and cooperation among
many responsible parties. The incorporation of EIA into
existing systems of land use planning, particularly incorporation
at the early stages of such planning, often entails modifications
of well-establiished procedures. Those modifications may be
modest or extensive, depending on the nature of prior planning
practices. Nevertheless, a reliable framework for designing and
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Introduction
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EIA is a problem-solving
approach to the decision-
making process.
The EIA process should be
systematic, reproducible and
interdisciplinary.
implementing EIA programs has emerged from the experiences
of several nations, including the United States, the United
Kingdom, France, Germany, Italy, Greece, the Netherlands, and
Canada. This text draws from those experiences and will be
updated periodically to enrich the value of the guidance it
provides.
WHAT IS EIA?
EIA is both a decision making process, and a document
that provides a systematic, reproducible, and interdisciplinary
evaluation of the potential effects of a proposed action and its
practical alternatives on the physical, biological, cultural, and
socioeconomic attributes of a particular geographical area.
EIA is often a key component in national, regional, or
local facilities planning and land use planning. The purpose is
to assure that important environmental resources are recognized
early in the planning process and protected through proper
planning and decision-making. The EIA analysis should be
systematic to assure that all feasible alternatives that would meet
the basic purpose and need of the proposal are considered and
compared, that relevant environmental resources are described
and evaluated, and that all measures that could protect those
resources are given full consideration in the planning process.
The EIA should be reproducible to permit independent
verification of the findings and conclusions presented in the EIA
document. The EIA should be interdisciplinary to ensure that
experts in the relevant physical, biological, cultural, and
socioeconomic disciplines contribute their expertise to the overall
assessment so that the evaluation of resources and impacts is
comprehensive and accurate.
As a decision-making process, EIA provides a means for
all stakeholders in an action to be heard and to participate in the
process of selection of alternatives and mitigation of adverse
impacts. It also brings before decision makers more alternative
courses of action that may better achieve several instead of just
one set of goals. Finally, it helps to identify actions needed to
prevent future environmental damage from future anticipated
impacts.
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Introduction
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EIA is the process and the
document.
Initial EIA is a preliminary
evaluation.
EIA improves planning and
decision-making.
The terminology used to describe the process of assessing
the potential environmental impacts of human actions is
somewhat variable from country to country. In this text, the
following conventions have been used:
• The phrase environmental impact assessment, or
EIA denotes the process as well as referring to the
document detailing the EIA process for a
particular action or class of actions. Decisions
include: 1) whether to evaluate impacts to the
environment of a proposed action and reasonable
alternatives, 2) whether to consider alternatives
and mitigation of adverse environmental impacts
and the results of analysis into account when
deciding upon the proposed action or its
reasonable alternatives^ and 3) how to involve
stakeholders in the process.
• The phrase initial environmental impact
assessment denotes an early stage of EIA wherein
a brief, preliminary evaluation of the types of
impacts resulting from an action are described.
WHY IS EIA IMPORTANT?
An effective EIA program brings multiple benefits to
society; several principal benefits are summarized in Table 1-1.
First, and most important, natural resources, environmental
quality, and public health are accorded appropriate degrees of
protection through a substantive environmental policy and an
effective EIA process. Second, the EIA document brings
together in a public document all relevant information on the
proposed action, the nature of the affected environment, and the
types of potential environmental impacts that might result from
implementation of the proposed alternatives to the action. Third,
the identification of finite resources and potential environmental
impacts at the earliest stages of project planning promotes the
selection of the most appropriate alternatives, pollution
prevention, and the use of best management practices and
technologies to reduce the magnitude of those environmental
impacts resulting from the action.
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Introduction
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HOW MAY EIA PROGRAMS EVOLVE
DIFFERENT CULTURES AND COUNTRIES?
IN
Anyone involved in designing an EIA program will
face certain fundamental issues: How should such a
program be initiated? What elements should be
emphasized? How can the full range of responsibilities be
handled with limited program resources? How should the
program evolve over time as the program moves to new
stages, and as policy-makers evaluate the success of
previous strategies? How can the program address
technological and economic developments that require new
assessment methodologies?
Each program must answer these questions based on
the resources and culture in place. This text provides a
broad range of possibilities for the different elements of an
EIA program. Policy-makers can select from these
possibilities to design or modify a program so that it best
serves the desired goals within the available resources.
The resources available to implement an EIA
program may limit the breadth and sophistication of the
program's initial application. Ideally, agencies and
individuals who are charged with preparing EIAs would be
well-trained and experienced before they engage in full-
scale assessments. Due to limited resources and/or program
priorities, many programs rely initially, if not
predominantly, on on-the-job training. The challenge for
every program is to make the most effective use of the
resources that are available. The approaches and
methodologies discussed in this text provide a broad base
from which individual EIA programs can be formulated.
Finally, the effectiveness of an EIA program
depends on the degree to which environmental quality is a
national, regional, and local priority. Adherence in
decision-making to a program of thorough EIA may lead to
difficult economic choices and environmental compromises.
Public and government concern for environmental quality
provide an important foundation for EIA programs as
without this commitment there is no guarantee that a sound
• Principles of Environmental Impact Assessment
EIA programs should be
developed from fundamental
approaches and methodologies.
National policy is an important
consideration in the
effectiveness of an EIA
program.
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Introduction
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environmental decision will result from having carried out
an EIA on several alternatives.
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Introduction
1-7
TABLE 1-1
THE IMPORTANCE OF AN EIA PROGRAM
Establishment of a Substantive Environmental Policy. An effective program of EIA
expresses the intent at the national, regional, or local level to establish a sound and
sustainable environmental policy for governmental and private decision-making.
Protection of Natural Resources, Environmental Quality, and Public Health. An
effective EIA program serves to identify, in advance, actions that could have significant
adverse effects on natural resources; on the quality of local, regional, or national
environment; and on human health and safety. In this regard, the EIA program is an
important preventive measure that reduces potential risks to the well-being of the natural
environment.
Full and Open Disclosure of All Environmental Consequences of a Proposed Action.
An effective program of EIA provides a standardized mechanism for documenting and
disclosing the full spectrum of effects of a proposed action. This disclosure encourages a
thorough examination of all actions that could affect the natural environment.
Objective Consideration of All Reasonable Alternatives. The heart of the EIA process
is the objective and'systematic comparison of reasonable alternatives to identify the least
environmentally damaging alternative that would meet the stated purpose and need of the
proposed action.
Establishment of a Uniform and Quantitative/Qualitative Basis for the Identification
and Characterization of All Relevant Environmental Impacts. The systematic steps
included in an effective EIA program provide technical guidance concerning the types of
environmental effects that should be evaluated, the range of technical methodologies that
might be used in those evaluations, and the types of techniques that can be used to predict
potential effects resulting from a proposed action.
Application of Best Management Practices to Minimize Unavoidable Impacts. Early
identification of effects potentially stemming from a proposed action can promote the use
of best management practices or innovative technological solutions to eliminate, reduce,
or mitigate significant adverse impacts.
Encouragement of Public Participation Throughout the EIA Process. Provisions for
public involvement through workshops, meetings, and hearings promote an open flow of
information and allow communities and citizens to make reasoned choices about the
benefits and risks of proposed actions. It also helps to identify alternatives which may not
have otherwise been considered which better serves to integrate economic, social and
environmental concerns.
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Introduction
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NOTES
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BASIS FOR EIAs
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Basis for EIAs
2-1
2. BASIS FOR EIAs
INTRODUCTION
Although EIA laws and regulations may differ from
country to country, many nations have included both formal
statements of environmental policy and a set of procedures
designed to integrate these policies into the planning
routines of government agencies and private developers. In
general, the procedures require the preparation of a formal
document that evaluates a proposed action, explores a
spectrum of viable alternatives, assesses the impacts of those
alternatives, and identifies measures to avoid or lessen the
severity of unwanted impacts. The information disclosed by
the EIA process can form the basis for a decision either to
approve or deny a proposed action, or to place conditions on
its implementation (Environmental Law Institute, 1991).
An EIA program will often require that
environmental specialists and planners consider a broader
range of alternative solutions and/or locations for proposed
actions than might have been considered in the absence of
such a program. An EIA program may also require that
potential impacts to environmental resources be evaluated in
detail, and that a preferred alternative be selected on
objective merits. This procedure for reviewing proposed
projects before they are implemented means that traditional
planning methods may have to be altered or adapted to
accommodate all of the EIA program requirements.
The aspects of traditional planning that are most
likely to be affected by the adoption of formal EIA
procedures are precisely those aspects that constitute the
core of an effective EIA program. These aspects are 1)
balanced decision-making and 2) public participation. In the
absence of an EIA program, decisions on development,
redevelopment, remedial actions or management of natural
resources can be made unilaterally, often by individuals or
organizations that have some degree of bias or preference
toward how the action should be oriented in location,
design, or both. Such unilateral decision-making provides
minimal information
'S'EPA • Principles of Environmental Impact Assessment
Traditional planning
approaches may need to be
expanded to include all the EIA
concepts.
An EIA program fosters
balanced decision-making and
public participation.
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Basis for El As
2-2
Balanced decisions consider
adverse and beneficial effects.
The no-action alternative is the
option of not carrying out an
action in any way.
The EIA docket is a record of
all the steps in the process.
about the planning process to the concerned public, and
eliminates the opportunity for public participation and comment
on the proposed action. An effective EIA program, conversely,
precludes unilateral decision-making by informing decision-
makers and involving the public. Single focus decision making
can often miss key opportunities for achieving greater benefit
and avoiding unforeseen costs.
BALANCED DECISIONS
A principal goal of the EIA process is to ensure, to the
greatest degree possible, that the undesirable environmental
effects of an action are kept to their practicable minimum. It
should be evident, however, that virtually any new development,
redevelopment, remedial action or resource use will alter some
attributes of the existing environment. A primary function of
EIA in the decision-making process is to ensure that decisions on
proposed actions are balanced, i.e., that the environmental
effects (both positive and negative) of an action are weighed
against the socioeconomic results of the action. The information
acquired and evaluated in the EIA process should thus be
organized and presented in a manner that facilitates balancing
these positive and negative factors. Moreover, the EIA process
should consider in comparative fashion several reasonable
alternatives that could meet the purpose and need of the proposed
action. These alternatives should include the option of not
carrying out an action in any way (the no-action alternative), and
describe objectively the reasoning for the preference of one
alternative over others.
The full and open disclosure goals of the EIA process
apply most emphatically to the aspect of balanced decision-
making. The administrative record, or docket, of the EIA
process should thoroughly document the steps taken throughout
the process to balance the factors incorporated into the final
decision on the proposed action. This would include records of
meetings, issues discussed at meetings, records of written and
oral comments from cooperating agencies and interested parties,
and full documentation of the various alternatives considered.
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TABLE2-1
PROCEDURES TO ENCOURAGE PUBLIC PARTICIPATION
IN EIA PROGRAMS
In the law-making and rule-making stages of EIA programs, publicize the adoption of
environmental laws and regulations. Emphasize the provisions that promote public
participation in the programs and publicize any changes to the laws and regulations.
Incorporate a provision into EIA regulations that requires an agency or private party to
publish in the public media a notice of intent to undertake an EIA and request for
public comment.
Invite public participation in the early planning stages of the project or program
planning through the use of scoping meetings.
Solicit assistance from the public in identifying project/program alternatives to be
studied and in comparing and screening reasonable alternatives.
Inform the public about significant issues and changes in proposed projects or
programs as such issues or changes arise.
Solicit assistance from the public, particularly from conservation groups and similar
organizations, in describing the ecological condition of the environments potentially
affected by the proposed project or program.
Anticipate potential conflicts and encourage early discussions of differences among
affected parties.
Incorporate provisions into EIA regulations that require a sufficient time to be set aside
for a period of public review and comment on the EIA report. Preferably, this would
occur at the stages where the draft and final EIA report are released.
Solicit comments from the public in formal public hearings, informal workshops, or
information sessions sponsored by the agency responsible for reviewing or preparing
the EIA.
Provide for responses to the comments in a final EIA document or a separate
document called a "responsiveness summary."
Use special facilitators or environmental mediators to enhance dialogue and
communications.
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NOTES
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EIA LAWS AND REQUIREMENTS
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EIA Laws and Requirements
3-1
3. EIA LAWS AND REQUIREMENTS
INTRODUCTION
The initial steps that should be taken to create an
effective EIA program are the establishment of
environmental policy and guidance documents followed by
law-making and rule-making steps that establish the
fundamental mechanisms for the EIA process. An
important goal of EIA laws and regulations is to improve
the quality of planning and decision-making by government
agencies, private organizations, and individuals.
In this text, a law refers to a statute passed by a
legislative body. A regulation, alternatively, refers to a
ruling that provides more detailed direction needed to
implement the law. A regulation is typically issued by a
government agency.
EIA laws and regulations require that parties prepare
an EIA document, follow certain procedures and consider
the environmental consequences of their actions or proposed
actions, and give substantive consideration to reasonable
alternatives that avoid or reduce adverse environmental
impacts. EIA laws and regulations are most effective when
they are linked to monitoring and follow up to any agreed
upon mitigation from to prevent environmental or other
adverse impacts. EIA laws and regulations can have the
added benefit of public participation and confidence in the
decision-making process through full disclosure provisions.
Finally, by setting "milestones" for various steps of EIAs,
the laws and regulations encourage the timely completion of
the decision-making process. Each component is discussed
further below and summarized in Table 3-1. For
comparative purposes, a synopsis of the United States'
National Environmental Policy Act (NEPA), which is the
EIA statute used in the United States, has also been added
at the end of this chapter.
EIA laws should be designed to
improve the quality of planning
and decision-making.
NEPA is the EIA statute in the
United States.
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EIA Laws and Requirements
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TABLE 3-1
BASIC COMPONENTS OF AN
EFFECTIVE EIA PROGRAM
The establishment by law of a substantive national environmental
policy that encompasses the concept of EIA.
The creation of EIA regulations and requirements that implement
environmental law in ways that are systematic, rigorous, and practical.
The establishment of a regulatory system ("agencies") for preparing
EIA's, or for coordinating, guiding and reviewing the preparation of
EIA's by others.
The identification and clarification of organizational roles and
responsibilities within the general framework of EIA regulations and
procedures.
The coordination of EIA preparation and review activities and
decision-making among government agencies, private developers,
environmental consultants, and the public.
The ongoing evaluation of the success of the program and holding
program personnel accountable for its success.
The encouragement of public participation in all aspects of the EIA
process.
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EIA Laws and Requirements
3-3
ENVIRONMENTAL POLICIES AND LAWS
The establishment of a substantive environmental
policy can provide a solid foundation upon which an EIA
program can be built. Such a policy can express the intent
and resolve of the government to protect and enhance the
natural environment as a means to safeguard the human
environment. An environmental policy at the national level
can establish the environmental standard and promote
consistency in environmental considerations at lower levels
of government.
The environmental policy can be formalized through
the adoption of laws or statutes at the national, regional, and
local levels of government. These environmental laws may
set forth broad general policies or may be directed at
specific environmental issues and responsibilities.
EIA REGULATIONS
Following the establishment of laws, the rule-making
process translates legislative intent into formal regulations,
requirements, and procedures that are to be followed.
These regulations may detail such requirements as the
circumstances requiring the preparation of an EIA, the
timing and content of the EIA, and reviewing and
commenting procedures for the EIA. These regulations may
also establish agencies with specific oversight, review, and
permitting authority. The regulations may also establish
requirements for the integration of public participation
throughout the EIA process. Typically, the rule-making
steps contain more specific information than do the laws; the
rules often contain details on the technical, analytical, and
procedural requirements for the program. After the laws
and rules necessary and sufficient to implement an EIA
program have been established, the decision-making process
- the heart of the EIA program - can commence.
FULL DISCLOSURE
The agency responsible for conducting the EIA for
a particular action should be required to maintain full
SVEPA • Principles of Environmental Impact Assessment
EIA policies clarify and express
the intent to protect the
environment.
Laws formalize policies.
Regulations provide detailed
requirements for implementing
laws.
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El A Laws and Requirements
3-4
Full documentation of the EIA
process is necessary.
Conflicting views often surface
when a draft EIA is released.
Did you have a sandwich for
lunch?
documentation of the EIA procedures followed. This planning
record, or docket, is evidence of the agency's compliance with
the EIA laws and regulations. If a document is lost or was never
prepared, the agency has no evidence of the efforts it took to
follow the EIA procedures. Some countries have laws
mandating that such planning records be made available to the
public for examination upon request.
At the point where the findings of the EIA have been
incorporated into a draft document, full disclosure and public
comment can be encouraged by circulating copies of the draft
EIA report to public institutions (e.g., libraries, local
government offices) as well as to interested governmental
agencies. Although procedures should be structured to
encourage mil disclosure and public participation throughout the
EIA process, in practice, it is often the disclosure of the draft
EIA document that generates the highest degree of public
scrutiny and comment on the proposed action.
It cannot be stressed too strongly that the EIA process for
any particular project should be documented fully and carefully.
This record serves as the "project memory" and is a record that
can be consulted should any aspect of the EIA process be called
into question. The need for such documentation can be
illustrated by an example from a major highway project that was
recently proposed in the northeastern United States. The EIA
report was legally challenged by several citizens groups on the
grounds that certain interpretations of impacts were changed
between the time the draft and final EIA reports were issued and
that the changes in interpretations were not fully documented.
A governmental official indicated in court testimony that certain
calculations had actually been performed and had been written
on the wrapping paper of the official's lunchtime sandwich. The
judge ordered the official to produce that wrapper and enter it
into evidence. In this case, the paper actually had been kept and
was duly produced and entered into the record. However, the
calculations that caused the interpretations of impacts to be
revised should have been formalized at the time they were
performed and entered into the public record for the project.
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TIMING OF EIAs
A fundamental goal of the EIA process is to
incorporate environmental considerations as part of the
decision-making process; therefore, agencies should
integrate the EIA process with other planning processes at
the earliest possible time. This will ensure that planning
and decisions reflect environmental values, avoid
unnecessary delays or procedural corrections later in the
planning process, and minimize potential conflicts. In
addition, design changes can be incorporated into the project
planning to avoid or reduce environmental impacts
identified by an EIA.
The project proponent, agency, non-governmental
organization, or team responsible for project planning
should not commit resources in a way that would prejudice
selection of alternatives before the EIA process is
completed. For example, a developer should not financially
invest in a particular action to the point that the developer
considers all other alternatives impractical because of that
investment. As another example, detailed planning for a
facility on a specific site may be required for a feasibility
study but the investment in time and money to obtain those
details should not be used as a claim that other alternatives
become less viable because of that investment. In this
regard, the EIA process should not be used to rationalize or
justify planning decisions made prior to application of the
EIA process.
TIME LIMITS ON THE EIA PROCESS
The implementation of a uniform process for
conducting an EIA should make the preparation of the
document and the decision-making process more efficient.
However, projects and programs differ in their complexity
and scope of potential impacts so the actual lengths of time
required for the preparation and review of EIAs for these
projects and programs are likely to vary. The time required
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Any statutory time limits should
be based on experience in
completing several EIAs.
Alternatives and the no-action
alternative.
Structural and non-structural
alternatives may meet the
purpose and need of the
project.
for an EIA can depend on such factors as the complexity of long-
term planning details and/or the acquisition of sufficient data.
Placing limits on the time allowed to prepare or review an EIA
without knowledge of the actual time required can result in an
inadequate or incomplete EIA process and EIA because of
unrealistic deadlines. Therefore, any statutory limits placed on
the length of time required to complete the preparation or review
of an EIA should be based on observations of the lengths of time
required to complete several actual EIAs. These EIAs should
have satisfied all EIA requirements and represented the spectrum
of proposed actions likely to be encountered in the future. Until
statutory limits can be finalized, initial guidelines for time limits
on one or more stages of the EIA process can be imposed to
ensure the process progresses toward completion.
ALTERNATIVES ANALYSIS
Alternatives are different means of meeting the general
purpose and need of a proposed project or program. The no-
action alternative is the option of not engaging in the proposed
project or the other "action" alternatives.
The EIA process as a decision-making tool operates
properly only if the assessment thoroughly considers a spectrum
of feasible alternatives that could reasonably achieve the
purposes and goals of a proposed action (Table 3-2). In this
way, the least environmentally damaging alternative that still
satisfies the purpose and need can be identified and selected. In
the absence of such feasible alternatives, the usefulness of the
EIA process is diminished greatly, yielding no more than a
cataloging of the environmental impacts of a specific project in
a particular location.
The identification and characterization of feasible
alternatives should be carried out as soon as possible after the
purpose and need are established; in this way, project planning
does not bias the assessment toward one alternative or another.
The alternatives analysis should include full consideration of
non-structural and structural alternatives that would satisfy the
purpose and need.
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; TABLE 3-2
ALTERNATIVES ANALYSIS IN THE EIA PROCESS
An EIA for a proposed action should consider a range of alternative means of
achieving the stated purpose and need of the action.
The range of alternatives should include the no-action alternative, the option of
not engaging in the proposed action or other action alternatives, or, in the case of
programs or policies, of not changing existing programs or policies.
All reasonable alternatives should be rigorously explored and objectively
evaluated in the EIA. Reasonable alternatives should include those that are viable
or feasible from a technical and economic standpoint, rather than only those
desirable from the standpoint of the project sponsor.
Alternatives can be screened to reduce their number so that a reasonable number of
alternatives that represents the complete array of viable alternatives can be
evaluated in detail.
Where the choice of no-action would result in predictable actions by others (e.g., if
not building a new roadway would create the need to redesign an existing
roadway), this consequence of the no-action alternative should be included in the
analysis.
Alternatives eliminated by objective screening from detailed study should be
identified, and the reasons for eliminating them should be documented.
All alternatives should be of equaU objective detail and given equal, objective
treatment in presentation such as displays and maps, throughout each stage of the
EIA process.
The EIA report should identify a preferred alternative and document the selection
criteria by which that alternative came to be preferred over other alternatives.
The decision-maker should consider all the alternatives discussed in an EIA
report, not just the preferred alternative.
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Alternatives include changes in
size, location, technology, or
planning.
Example:
Proposed Project:
Construction of a new drinking
water supply reservoir.
Range of alternatives that may
be considered:
• No action
• Water conservation
measures
• Installation of
groundwater wells
• Construction of a
desalination
system
Preferred Alternative.
In the identification of these alternatives, the no-action
alternative, which is the option of not to engage in the proposed
action or other action alternatives, should be retained as a
feasible option and given serious consideration in the subsequent
EIA steps. The no-action alternative serves as an objective
baseline against which the other alternatives can be measured.
When the environmental consequences of the other action
alternatives are weighed against their projected benefits, the no-
action alternative can sometimes be the preferred alternative and
the one selected.
The alternatives should offer legitimate and substantive
choices; siting a facility in one location or another of a large
tract of land may be an appropriate approach to reducing
environmental impacts, but generally constitutes only one
alternative way,, in the legitimate sense, of meeting the purpose
and need of the proposed action. The alternatives evaluated
should ideally provide the decision-makers with different
geographical locations for the action and with different technical
or planning solutions for achieving equivalent goals. For
example, if the purpose of a proposed action is to supply potable
water to a particular region, the alternatives analysis should not
be limited merely to a consideration of different sites for surface
water reservoirs. Rather, the alternatives analysis should also
consider the adoption of water conservation measures, the use of
groundwater aquifers, regional distribution systems, and
desalination of marine or brackish waters. This spectrum of
conceptual alternatives presents decision-makers with a balanced
set of structural and non-structural options that offer much more
than an alternative location for a particular type of water supply
facility.
As the EIA process for any particular action progresses,
the agency or party conducting the EIA can identify one or more
"preferred alternatives." A preferred alternative is generally
identified on the basis of its technical, environmental, and
economic merits, relative to the other project alternatives,
including the no-action alternative. A preferred alternative, once
identified, becomes a focal point for commentary by other
agencies and the public. The systematic comparison of
alternatives, including the no-action alternative, should be
carried throughout the documentation of the EIA process, treated
hi equivalent detail, and given equal weight, even when a agency
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preferred alternative has been identified. The selected
alternative is the alternative that is chosen for
implementation.
THE NEPA EXAMPLE
The environmental law that stipulates the need for
EIA need not necessarily be lengthy and detailed. In the
United States, the National Environmental Policy Act of
1969 (NEPA), which had enormous and far-reaching
influences on the way environmental impacts were
evaluated, was a model of brevity at five pages in length.
The major sections of NEPA encompassed the following:
• A congressional declaration of national
environmental policy.
• A directive to all federal agencies to use a
systematic, interdisciplinary EIA approach in
planning and decision-making, including the
preparation of an "environmental impact
statement" documenting in formalized
categories the EIA process and findings.
•-•'•••-. The creation of a Council on Environmental
Quality (CEQ), an independent government
agency, whose duties were to gather
information concerning conditions and trends
in the quality of the environment, review and
appraise the various programs of the federal
government, develop and recommend
national environmental policies, conduct
environmental investigations, and report at
least once per year on the state and condition
of the national environment.
• The authorization of federal funds for the
conduct of the activities authorized by the
Act.
The GEQ subsequently issued its NEPA guidelines
implementing the federal act. These regulations are much
more extensive and detailed than the act; the CEQ addressed
A five-page document contains
the statute for EIA in the
United States.
The NEPA statute addressed:
• National policy,
• Use of EIA in
government activities,
• Independent review
agency, and
• Funding.
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CEQ's regulations provided
details on how to implement
NEPA:
• Agency responsibilities
• Format of documents
• Timing
• Review process
agency responsibilities, the format of the EIA document
(called, in the United States, an environmental impact statement
or EIS), set the timing of various stages of EIA, and outlined the
review and decision-making processes that would follow any
assessment. The headings of the major sections of the CEQ
guidelines for implementation of NEPA are listed in Table 3-3.
In addition to the CEQ guidelines, federal agencies in the United
States have adopted their own sets of regulations that implement
NEPA and are consistent with the statute.
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TABLE 3-3
1MPOMENTATION OF NEPA BYCEQ1N
, UNITED STATES
PURPOSE, POLICY, AND MANDATE
Purpose
Policy
Mandate
Reducing Delay
Agency Authority
Reducing Paperwork
NEPA AND AGENCY PLANNING
Purpose
Apply NEPA Early in the Process
When to Prepare an EIA Document
Whether to Prepare an Environmental Impact Statement
Lead Agencies
Cooperating Agencies
Scoping
Time Limits
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TABLE 3-3
IMPLEMENTATIQN OF NEPA BY CEQ IN THE'
STATES
ENVIRONMENTAL IMPACT STATEMENT
Purpose
Implementation
Statutory Requirements of Statements
Major Federal Actions Requiring the Preparation of Environmental Impact
Statements
Timing
Interdisciplinary Preparation
Page Limits
Writing
Draft, Final, and Supplemental Statements
Recommended Format
Cover Sheet
Summary
Purpose and Need
Alternatives Including the Proposed Action
Affected Environment
Environmental Consequences
List of Preparers
Appendix
Circulation of the Environmental Impact Statement
Tiering
Incorporation by Reference
COMMENTING
Inviting Comments
Duty to Comment
Specificity of Comments
Response to Comments
PREDECISION REFERRALS TO CEQ OF PROPOSED FEDERAL ACTIONS
DETERMINED TO BE ENVIRONMENTALLY UNSATISFACTORY
Purpose
Criteria for Referral
Procedure for Referral and Response
NEPA AND AGENCY DECISIONMAKING
Agency Decisionmaking Procedures
Record of Decision in Cases Requiring Environmental Impact Statements
Implementing the Decision
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TABUE3-3
STATES
OTHER REQUIREMENTS OF NEPA
Limitations on Actions During NEPA Process
Elimination of Duplication with State and Local Procedures
Adoption
Combining Documents
Public Involvement
Further Guidance
Proposals for Legislation
Filing Requirements
Timing of Agency Action
Emergencies
Effective Date
AGENCY COMPLIANCE
Compliance
Agency Capability to Comply and Agency Procedures
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NOTF.S
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4. CIRCUMSTANCES REQUIRING EIAs
INTRODUCTION
The regulations implementing an EIA process should
include a set of standard procedures for identifying the
general or specific circumstances that require a full-scale
EIA. Those procedures should be capable of distinguishing
between proposed actions whose anticipated impacts are not
likely to be significant and those actions whose anticipated
impacts are likely to be significant.
An environmental impact is a change in the
environment brought about by implementation of a proposed
project, plan, program, policy or its alternative. A
significant environmental impact is, in general, an impact
that could alter the properties of a natural or man-made
resource in a way considered important. The significance
of an environmental impact is difficult to define more
explicitly in the abstract; significance of impact is generally
deduced or inferred from specific EIAs for specific actions.
As noted in Chapter 2, virtually every development,
redevelopment, remedial action, or resource use affects the
attributes of the existing environment; in fact, most actions
are explicitly taken to modify certain attributes to provide
particular socioeconomic benefits. However, some actions
are known to have, or anticipated to have, minimal impacts
on environmental resources, and subjecting such actions to
the full EIA process could be a misdirection of resources or
divert the attention of decision makers from more significant
issues. Therefore, the EIA process generally begins with an
initial consideration of whether or not the proposed action
should undergo a full EIA.
The actions that might be considered as subject to
EIA should include not only physical projects (i.e.,
construction of facilities), but also administrative policies,
plans, and programs that have the potential for significantly
affecting the quality of the environment.
Certain general types of projects (e.g., dams,
reservoirs, power plants, major roadways) can be assumed
• Principles of Environmental Impact Assessment
Environmental impacts and
significant environmental
impacts.
An EIA may be performed on
projects, policies, plans, and
programs.
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4-2
Scope of effect considers the
size of the area affected and the
length of time over which
impacts will occur.
from their nature or intent to generate significant environmental
impacts. Based on a knowledge of the types of actions in the
past that have required EIAs, a general framework for
determining which projects require EIAs can be established
under the broad categories of scope of effect, significance of
their effect on the human environment, controversial status in the
public view, or existing legal or financial requirements. These
broad categories are discussed individually below.
SCOPE OF EFFECT
This characterization refers to the extent of potential
impacts generated by a proposed action, mainly in the
geographic land area potentially affected, and the length of time
over which the impact will occur. The area also includes the
watersheds, airsheds, and ecosystems within which the project
is located. The defined area within which all potential effects,
impacts, features, and compensation efforts related to a proposal
and its alternatives would occur can be called the study area. As
noted above, reservoirs, logging operations, and power plants
generate effects over large geographic areas, entail major
construction, and continue to affect resources during the life of
their operation. Actions with similarly broad scopes of effects
might include solid waste landfills, airports, major roadways or
other linear facilities (electric, gas, water transmission lines),
and large industrial complexes. Similarly, a government policy
relevant to the construction of all solid waste landfills in a
country would have a broad scope of effect. The scope of
effects of these types of projects is reasonably well understood,
and EIA methodologies include detailed lists itemizing the
multiple impacts that such facilities might have on environmental
resources.
SIGNIFICANCE OF EFFECT ON THE
ENVIRONMENT
There are particular types of actions that, though of
somewhat more limited scope than in the sense discussed above,
have the potential to exert significant effects on the environment.
These potential effects may be related to the high sensitivity of
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4-3
the resources to disturbance, to the specific nature of the
impacts, to the potential duration of such impacts, or to
potential secondary and cumulative impacts. The principal
concern in these types of actions is that the environmental
effects could cause irrevocable losses of important natural
resources or irreversible effects on human health.
Highly sensitive environmental resources may be
certain natural environments such as major wetland
complexes (either inland or coastal), the floodplains of
major rivers, large tracts of prime agricultural land or
forestland, habitats with threatened species, or regions with
extensive and important cultural resources. In addition,
highly sensitive resources may be human resources; the
potential risk of an action may be a function of the number
of "sensitive receptors" in the affected area (sensitive
receptors here being such things as schools, potable water
supplies, recreational areas, and housing for the elderly).
Increased levels of air pollution, for example, are likely to
be more significant if the young, the old, or the ill - the
more sensitive human receptors - will be exposed.
The nature of the potential effects will affect the
EIA. Discharges of natural wastes (e.g., domestic sewage)
will produce undesirable changes in surface or groundwater
characteristics, but these changes are qualitatively different
from those potentially resulting from the release of a
synthetic chemical that is both hazardous and persistent.
The effects of the discharge of natural wastes are reversible,
at least in part, while contamination of surface or
groundwaters with hazardous and persistent chemical
compounds presents a significant problem over a longer
term. The significance of such effect should also be
considered in terms of time period. As the length of
exposure or the frequency of exposure increases, so will the
likelihood of adverse impacts.
Significance of Effects
• Sensitive resources
• Irreversible impacts
• Duration and frequency
of impact
• Secondary and
cumulative impacts
• Uniqueness of resources
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Public controversy over a
proposed action may be the
basis for deciding to proceed
with an EIA.
When does public controversy
arise?
EIA can be linked to the
permitting, licensing, or
financing of a proposed action.
PUBLIC CONTROVERSY
Public participation in the EIA process is, for most
proposed actions, accompanied by some degree of public
controversy - disagreement among public groups or concerned
individuals about the purpose, need, location, alternatives, or
impacts of the action. Such disagreement can contribute
constructively to the planning process if the adversarial positions
are not too extreme. Certain types of actions have historically
been particularly prone to arouse public controversy. Such
projects fall into the categories of major linear facilities such as
roadways, railways, transmission lines; reservoirs and dams; and
facilities generating, storing, handling, or processing hazardous
materials. Part of the controversy over major projects such as
these relates to the need for the acquisition of land from private
landowners; where private landownership is a firmly established
right or policy, taking land for a public facility may be
vigorously resisted. Occasionally, controversy will arise if the
project will cause a disruption to land use or commuting
patterns. Also, when a proposed action includes the involvement
of hazardous materials, particularly in populated areas, the
public discussions are likely to be controversial.
LEGAL AND FINANCIAL REQUIREMENTS
EIA Process in the United States
In the United States, the passage of NEPA in 1969
mandated the EIA process for all projects involving federal
actions, including the issuance of permits, licenses, and financial
assistance. In the years following NEPA, a number of states
enacted environmental policy acts mandating similar EIA
requirements for state-level projects, and many local
municipalities have followed this lead. As a result, an EIA in
some form is likely to be required by statute for many
development or redevelopment projects in the United States.
The governmental levels administering regulations and making
decisions on proposed actions may range from the level of the
local to the federal government. There is also a notable trend
toward project financiers requiring EIA to protect their financial
investments in properties and facilities. Once the underlying EIA
laws and regulations are in place, it is also entirely feasible
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for those laws and regulations to require the application of
the EIA process to subsequent, specifically-directed
environmental regulations. For example, an EIA law could
require a regulatory agency concerned with commercial
fishing to examine, through EIA procedures, the potential
impact of a change in the harvesting that it enforces.
Likewise, an agency responsible for establishing water
quality standards could be required to assess any potential
impacts that would result from changing these standards.
These "legislative EIAs" or "program EIAs" should address
purpose and need, alternatives, affected environment, and
risks and benefits — the same issues that would be
considered for a new development project.
EIA Process in Europe
In the past several years, an increasing number of
countries and multinational communities have enacted laws
and directives establishing EIA requirements for project
reviews. In 1985, the European Economic Community
issued a directive establishing minimum requirements for
EIA in all member countries. The United Nations
Environment Program adopted Goals and Principles of EIA
in 1987. In 1991, twenty-six nations of the United Nations
Economic Commission for Europe signed a Convention on
EIA in a Transboundary Context, requiring all signatory
nations to establish EIA procedures for transboundary
impacts. All Central and Eastern European countries except
for the Czech and Slovak Federal Republic signed the
convention (Environmental Law Institute, 1991).
EIA Process Internationally
Increasing emphasis on EIA is also being observed
by members of the international banking community. The
World Bank issued in 1989 an operational directive
requiring EIAs for certain categories of projects, while
multilateral development banks are working to incorporate
EIA procedures into their lending practices. The European
Bank for Reconstruction and Development (EBRD), created
in 1990 to fund the redevelopment of Central and Eastern
European economies, is likely to require EIA procedures to
further its goal of promoting "environmentally sound and
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EIA can also be linked to the
land use planning process.
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Some projects can be excluded
from the EIA process because
the type, or category, of activity
does not have significant
impacts.
Test 1 is based on experience
and the historical record.
sustainable development" in its economic activities
(Environmental Law Institute, 1991).
These actions at the national and international level describe a
clear trend in establishing a common basic requirement and
framework for evaluating proposed actions arid assessing
environmental impacts. As internatibmal financing agreements
and arrangements rise is geographical geographical scope and
economic importance, it appears clear that participating nations
will need a well-defined policy of EIA in order to engage fully
in these agreements.
CATEGORICAL EXCLUSIONS
All projects can benefit from some level of EIA, even
those on the level of individual businesses or facilities.
Triggering mechanisms for subjecting projects to EIA are
usually defined in the laws or regulations that create the EIA
process. In the United States, only those projects involving a
federal action undergo an EIA under the NEPA statute. Federal
actions are generally limited to project sponsors applying for
federal financial assistance, permits, or licenses. Other levels of
government may subject more and different kinds of projects to
assessment. When an assessment is required by two different
levels of government, requirements of .both are usually
incorporated into an assessment conducted at the level of
government with the riidre stringent regulation.
However, soine projects are so inconsequential that it
would be a waste 6f resources tfd require them to undergb a full
EIA; Therefore, the EIA process usually begins with a step for
determining whether on riot a project should undergo an
assessment at all. This step requires that a project meet 2 tests
before it can tie categorically excluded from the EIA process:
Test 1 - the project should be consistent with categories
of projects that have been determined not to have,
individually, cumulatively, over time, or in conjunction
with other projects in the same area, a significant effect
on the quality of the environment. Examples might be
the minor rehabilitation of an existing facility or the
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replacement of equipment. Such projects can be
placed in categories of projects that can be excluded
from EIA requirements if they can meet the criteria
under Test 2 below.
Test 2 - a project meeting the criteria for exemption
(Test 1) must not be located in or near areas that
might affect the protection of sensitive natural or
cultural(endangered species, historic sites, etc.). In
this case, exemption from EIA requirements would
not be appropriate. Similarly, a proposed program
or project might be characterized by a high level of
public controversy; such a project, though qualifying
for an exemption under Test 1, could benefit from
the full scrutiny and disclosure of the EIA process.
Categories of potentially exempted projects (Test 1)
are sometimes based on public policy. More often, they
result from experts' experience indicating that certain
categories of projects rarely result in adverse impacts to the
environment. Criteria for not granting an exclusion from
EIA (Test 2) are almost always due to public policy.
Even though a decision may be taken to exempt a
project from EIA based on the tests above, good practice
suggests that the affected public should be notified about
these projects. The value of the notice is that local
interested parties may know reasons, other than those
considered by the assessment team, why a particular project
should not qualify for exemption. It should also be noted
that, although this categorical exclusion step occurs in the
initial phases of the assessment process, in practice this step
involves consideration of the same factors as those used in
a full-scale EIA. Making effective determinations for
categorical exclusions requires a basic understanding of the
scope of the action, the sensitivity of the environment
potentially affected, and the general nature and magnitude
of potential environmental impacts.
The public should be notified of
a categorical exclusion.
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Initial EIAs consider
significance of impacts.
the
INITIAL EIAs
For the proposed actions that are not excluded from
further EIA by categorical exclusions, the majority will fall into
a category of assessments whose impacts are unknown. The
procedures for undertaking an EIA generally begin with an
initial EIA of the proposed action. The level of detail that is
required in the initial EIA must be sufficient to make one of two
determinations: 1) there will be no significant impact expected
to result, or 2) significant impacts are expected. If at any time
during the preparation of an initial EIA, information is
uncovered that would indicate the project could result in
significant environmental impacts, the initial EIA can be
immediately terminated (if it is a formal step in the procedure)
and a full EIA begun.
As experience in EIA is gained, proposed actions that
always have significant impacts associated with them in every
case (power plants, reservoirs and dams) should be identified
and categorized. Criteria that may be useful in identifying
significant actions include when a project:
• could impact directly on air and water quality,
piarticularly if there is a possibility that standards
may be exceeded or that degradation of high
quality conditions may occur;
• could adversely affect protected ecological
resources such as endangered species;
• could create undesirable indirect impacts such as
increased traffic or rapid urban growth;
• could cause release of toxic or hazardous
materials or generation of wastes;
• could, in combination with other activities, cause
adverse cumulative effects; or
• could create significant public controversy.
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5 KEY CONSIDERATIONS IN THE EIA PROCESS
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5-1
5. KEY CONSIDERATIONS IN THE EIA PROCESS
INTRODUCTION
When it is determined, through the EIA steps
discussed in Chapter 4, that a proposed action should
'undergo the EIA process, it is necessary to identify the
essential elements and particular issues that should be
incorporated into the process. By organizing the EIA
process from the start, a greater uniformity in style, content,
technical rigor, and specificity can be achieved. The
following considerations are key to the orderly conduct of
the EIA process.
PURPOSE AND NEED
The purpose and need of a proposed project is the
justification for undertaking the action. The purpose and
need may originate from legislation, from administrative
decisions, or from private enterprise. The need for the
action may be a policy that needs to be implemented or a
specific problem that needs to be addressed.
A clear description of the purpose of, and need for,
a particular action provides the perspective in which the
reasonableness of various alternatives can be evaluated over
a specified planning period. Without a clearly justified and
documented purpose and need, the project should not
proceed further.
PUBLIC PARTICIPATION
Public participation in the EIA process is a critical
component in achieving the open decision-making goal.
Public participation should begin in the earliest phases of
project planning and continue through the decision-making
process. Public involvement can be formalized by
scheduling public hearings and public information sessions,
creating public advisory and/or liaison groups, and
periodically distributing information concerning the status
of project planning. Public involvement in the EIA process
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Key Considerations in the EIA Process
gives communities and individuals a voice in issues that may
bear directly on their health, welfare, and quality of life.
An open flow of environmental information can foster
objective consideration of the full range of issues involved
in project planning and can allow communities and citizens
to make reasoned choices about the benefits and risks of
proposed actions.
The initial, day-to-day activities of an EIA are likely
to be carried out by the staff of an environmental agency or
other environmental specialists; the public may not be
involved at this level of the EIA. There are, however,
certain points in the EIA process where public participation
is readily achieved and may be most effective. These points
are: 1) the notification of an intent to undertake an EIA for
a proposed action, 2) the scoping of the EIA process, 3) the
issuance of a draft EIA report, if such a draft document is
circulated for public comment, 4) the issuance of the final
EIA report if circulated for comment, and 5) the decision.
A growing trend is to engage the public in follow up
monitoring of implementation of mitigation and post project
implementation environmental monitoring.
Public participation can also be encouraged by
establishing citizens' action committees that may include
groups of citizens representing various civic groups,
environmental interests, and business activities. These
committees can serve as a focal point or channel for public
participation efforts by distributing information about the
project and directing public comments to designated project
representatives. Ideally, the principal purpose of such
committees is to facilitate the objective collection or
dissemination of information relevant to the action rather
than to advocate or oppose a particular action or alternative.
Individuals or groups that are likely to possess
specialized knowledge about the affected environment should
be strongly encouraged to participate and provide input to
the EIA. Often, local conservation groups (e.g.,
birdwatchers, naturalists, watershed associations) have
detailed information about the distribution and abundance of
plant and animal species in their geographical area; such
• Principles of Environmental Impact Assessment
Public participation is critical
to open decision-making and
should begin as early as
possible in the EIA process.
Critical public participation
stages:
• Notice of intent
• Scoping
• Draft EIA report
• Final EIA report
• Decision
Citizens' action committees can
facilitate collection and
dissemination of information.
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Kev Considerations in the EIA Process
5-3
information has greater value in project planning and
comparison of alternatives if it is disclosed early in the EIA
process.
Because public participation is such an essential
component of the EIA process, a public participation
workplan should be prepared during initial project planning.
This workplan should describe how public participation will
be conducted, encouraged, and facilitated during the EIA
'process. The public participation workplan should include
a schedule of activities, staffing arrangements, budget
requirements, information distribution methods, and
identification of key points in the EIA process where public
participation will be emphasized. As the EIA process
proceeds, full documentation of the public participation
process, as well as the public's specific comments, should be
maintained. Table 2-1 summarizes several procedures that
can be followed to promote public participation throughout
the EIA process.
SCOPING
Scoping is the early, open process of considering the
issues and choices of alternatives to be examined in the EIA
of a particular action, policy, or program. Scoping helps
insure that real problems are identified early and studied
properly, that issues of no real concern do not consume
undue time and effort, and that the EIA report when made
public is balanced and thorough.
When a full EIA is required for a proposed action, it
is essential to plan the scope of the EIA study at the
beginning of the process. Many projects may involve a
substantial number of feasible alternatives and a wide
spectrum of potential impacts. In order to conduct the EIA
in an efficient and systematic manner, the scope of the issues
to be studied in detail can be derived and approved in the
beginning of the process. This early planning phase of the
EIA is often termed "scoping."
Early input from local
specialists may foster better
decisions.
What are the objectives of the
proposed action?
The public participation
workplan identifies tasks,
schedules, staffing, budget, and
methods to communicate with
the public.
Scoping focuses resources and
reduces paperwork.
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Scoping must occur early in the
EIA process.
Scoping is more than just
public involvement.
In the United States, scoping originated in response
to early applications of NEPA by federal agencies. In some
early environmental impact studies, great lengths were made
to study every conceivable impact, regardless of its
significance, and consequently enormous EIAs were
submitted in which critical issues were obscured by the
volume of details. Other environmental impact studies went
to the opposite extreme, presenting too little
information and analysis to be of use in the environmental
decision-making process. To remedy these problems, the
existing EIA regulations were supplemented to include a
requirement for all agencies to engage in scoping at the
beginning of the EIA process (Environmental Law Institute,
1991).
Scoping is used to determine the breadth of issues to
be addressed, to identify the significant issues related to a
proposed action, and to identify and eliminate from detailed
study the issues that are not significant or that have been
treated in prior EIAs. During scoping, the agency or
organization with principal oversight responsibilities over
the EIA process should assign the responsibility for
preparing the EIA to an appropriate agency or organization,
and should set forth a tentative schedule for planning and
decision-making.
Public participation should be initiated at the scoping
stage of the EIA process. This can be accomplished through
a public notice of intent to conduct an EIA for a specific
action. Such a notice of intent should include a description
of the proposal and describe how the public may participate
in the process. Early public involvement may lead to a
more detailed identification of sensitive environmental
resources and disclosure of issues of significant community
concern.
Scoping typically is conducted in a meeting or series
of meetings involving the project proponent, the public, and
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Kev Considerations in the EIA Process
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the responsible government agencies. The structure of the
meetings may vary depending on the nature and complexity
of the proposed action and on the number of interested
participants. Small-scale scoping meetings might be
conducted like business conferences, with participants
contributing in informal discussions of the issues. Large-
scale scoping meetings might require a more formal
atmosphere, like that of a public hearing, where interested
parties are afforded the opportunity to present testimony.
Other types of scoping meetings could include "workshops,"
with participants in small work groups exploring different
alternatives and designs. As is the case with all procedural
and analytical stages of the EIA process, documentation of
the scoping process should be systematic and thorough.
Once the details of the EIA approach to a particular action
are agreed upon, the agency or organization conducting the
EIA should prepare a 'work plan that addresses key
considerations in the EIA process. These key considerations
are discussed individually below.
INTERDISCIPLINARY APPROACHES
The scope of most EIAs is sufficiently broad to
require the contributions of a spectrum of technical and
scientific experts; for this reason, an interdisciplinary
approach will clearly provide the most valuable information
for decision-making. An EIA report for a major project will
commonly consider existing environmental conditions of,
and potential impacts on, surface water quality and aquatic
communities, groundwater quality and water supplies,
terrestrial vegetation and wildlife, air quality and human
health, geology, (including topography and soils),
infrastructure (transportation, demography,
socioeconomics), and cultural resources. A detailed
assessment of all of these systems requires the collaboration
of experts in these several fields. In some cases, additional
experts may have to be added to the interdisciplinary team
as the EIA progresses. The final EIA report can be written
by a smaller group of individuals having access to the
findings of the technical experts.
Scoping includes:
Participation by others
Determining issues to be
addressed in the EIA
Eliminating insignificant
issues
Assigning
responsibilities and
requirements for
preparation and review
Identifying other related
planning decisions
Don't forget to document the
scoping process.
The broad scope of the EIA
process requires the use of an
interdisciplinary team.
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Objectivity of the process rests
on the analysis of the
alternatives.
No-action alternative is the
baseline for comparison.
ALTERNATIVES TO THE PROPOSED ACTION
Alternatives are different means of meeting the general
purpose and need of a proposed action, project, or program.
The no-action alternative is the option of not engaging in the
proposed action or the other action alternatives and provides
the baseline against which the impacts of the action
alternatives are compared.
The identification, description, evaluation, and
comparison of alternative ways to meet the basic purpose
and need of a proposed action are crucial to the objectivity
of the EIA process. In most cases, the EIA team can
identify several alternatives that are reasonable, feasible, and
would achieve the stated needs of the action. In the absence
of an objective and thorough alternatives analysis, the EIA
process tends merely to affirm a chosen action and loses
power as a decision-making tool.
The thorough description of alternatives in an EIA
process facilitates their side-by-side comparison in terms of
their technical, environmental, and economic risks and
benefits. The alternatives analysis of an EIA should discuss
alternatives to a specific action, such as not proceeding with
the action, carrying out the action in a different location or
facility, or implementing a non-structural solution. It is
generally not sufficient to discuss only alternatives within an
action, such as using different designs or materials, or
changing the orientation of the facility slightly within the
project boundaries.
The alternatives considered should include the "no-
action" alternative the option of not carrying out any of the
action alternatives. The no-action alternative represents an
objective baseline against which the other alternatives can be
measured and may, in the final analysis, be the alternative
that is preferred.
• Principles of Environmental Impact Assessment
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CATEGORIZATION OF IMPACTS
Primary and Secondary Impacts
The primary impacts of an action are those effects that are
caused by the action and that generally occur at the same time
and place as the action. They are usually associated with the
construction, operation, maintenance of a facility or activity,
and are generally obvious and quantifiable.
Primary impacts can encompass such effects as:
• removal of significant amounts of prime or unique
agricultural lands from productive use.
• imposition on, or destruction of sensitive ecosystems,
including wetlands, forests, coastal areas, floodplains,
natural habitats, and the habitats of threatened or
endangered species.
• degradation of surface water quality due to erosion
during construction or due to excessive contaminant
loadings to surface water runoff and/or discharges.
• alteration of groundwater characteristics due to
construction, dewatering activities, or significant
withdrawals during operation.
• alteration or destruction of historical, archaeological,
geological, cultural, or recreational areas.
• displacement of households, businesses, and services.
• generation of increased concentrations of air
contaminants, and increased levels of environmental
sounds or odors.
• creation or aggravation of public health problems.
• direct violation during construction or operation of
national, regional, or local environmental and land use
statutes or regulations and plans imposed by such
statutes or regulations.
Primary impacts are direct
and occur at the same time
and place.
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Secondary impacts are indirect
and occur later in time or at a
different place.
Projects that expand
infrastructure often induce
development and have
secondary impacts.
Persistence and duration of
impacts should be
characterized.
Secondary impacts of an action are indirect or induced
changes in the environment, population, economic growth
and land use, and other environmental effects resulting from
these changes in land use, population, and economic growth.
In other words, secondary impacts span the potential effects
of additional changes that are likely to occur later in time or
at a different place as a result of the implementation of a
particular action.
Secondary impacts can include additional construction
and/or development, traffic increases, increased recreational
demand, and other types of off-site impacts generated by on-
site activities. Such induced changes may gradually
adversely affect the environment in the general vicinity of
the specific action. An EIA should include an analysis of
secondary impacts, and a demonstration that such impacts
satisfy, to the maximum extent possible, the applicable
environmental policies and standards. Secondary impact
analysis must include the likely geographic extent of induced
development, its relationship to the environmental master
planning for the region, an assessment of likely induced
point and non-point air and water quality impacts, and
evaluation of the induced development in terms of all
applicable resource and development policies.
In the United States, a secondary impact analysis was
mandated by regulation for certain categories of federally-
funded actions. These actions are, in general, those that
expand infrastructural elements that are considered to induce
development: water supply systems, highways, and
wastewater treatment systems. Table 5-1 lists the typical
categories of potential secondary environmental impacts that
should be addressed in EIAs.
Short and Long Term Impacts
Impacts can be short-term or long-term depending upon
the persistence or duration of the impacts. Identification of
short-term and long-term impacts is important because the
significance of any particular impact may be related to its
duration in the environment. The loss of grass or other low-
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5-9
TABLES-!
CATEGORIES OF POTJENTML SECONDARY IMPACTS
Environmental Media Impacts
• Surface and Groundwater Quality and Quantity
• Ambient Air Quality
• Ambient Noise Levels
• Waste Generation
Sensitive Environmental Area Impacts
• Wetlands
• Floodplains
• Coastal Zones
• Wildlife Habitats
Unique Area Impacts
• Parklands
• Wild and Scenic Rivers
• Areas of Historic, Architectural, Archaeological, or
Cultural Value
Secondary Economic Impacts
• Agricultural Land Availability
• Availability or Demand for Energy
• Property Values
Source: EPA, 1978
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Environmental impacts can
also be beneficial.
The sum of individual non-
significant impacts may be
significant.
lying herbaceous vegetation on a particular area might be
considered a short-term impact because the area may be easily
revegetated through seeding and mulching in a relatively short
period of time. The loss of a mature forest, however, can be
considered a long-term impact because of the time required to
reforest the area and for the trees to reach maturity.
Positive and Negative Impacts
Information on the potential environmental impacts of a
proposed action forms the technical basis for comparisons of
alternatives, including the no-action alternative. All
significant environmental effects, including beneficial effects,
should be addressed. Although the term "environmental
impact" has come to be interpreted in the negative sense,
many actions have significant positive effects that should be
clearly defined and discussed. This is particularly appropriate
for redevelopment or remedial actions whose specific purpose
and need is to remedy any undesirable condition.
Cumulative Impacts
Cumulative impacts are those environmental impacts that
result from the incremental impact of the proposed action on
a common resource when added to other past, present, and
reasonably foreseeable future actions. Cumulative
environmental impacts can occur from the collective effects of
individually minor actions over a period of time.
Circumstances generating cumulative impacts could
include:
• water quality impacts from an effluent discharge that
is combined with other point source discharges or
from non-point source runoff.
• air quality impacts that result from industrial or
commercial emissions operated in the same
geographical region.
• loss and/or fragmentation of environmentally sensitive
habitats (forests, wetlands, farmlands) resulting from
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Are all impacts additive?
Balanced decisions consider
policies, goals, and needs over
the long-term.
the construction of several independent residential or
commercial developments.
The assessment of cumulative impacts is difficult, in part
due to the speculative nature of the possible future actions,
and in part due to the complex interactions that need to be
evaluated when considering collective effects. The cumulative
impacts may be simply additive in their effects, but could
potentially interact in synergistic or antagonistic fashion.
Water and air quality modeling provide a means to study
effects of cumulative impacts.
The analysis of cumulative impacts can be particularly
complex when the cause-effect relationships are not strictly
additive (e.g., where the relationships are discontinuous or
non-linear). For example, an action that has a small impact
by itself may bring one or more key environmental attributes
to a threshold of irrevocable harm, with potentially serious
impacts to the affected ecosystems. A system in which an
incremental impact has a greater effect than the preceding
increment is non-linear. It can be important to factor this
non-linear aspect into an EIA because an assumption of
linearity would underestimate the real cumulative impact of an
action. Similarly, cumulative impacts could be
underestimated when various effects interact synergistically,
that is, when the aggregate of the effects is greater than the
simple sum of the effects.
SHORT-TERM USES AND LONG-TERM
MAINTENANCE AND ENHANCEMENT OF THE
ENVIRONMENT
The "balanced decision" aspect of the EIA process applies
not only to the evaluation of specific alternatives, but also to
the more general balancing of short-term uses of
environmental resources and the enhancement of such
resources over the long term. For example, there may be
national or regional environmental policies that set goals to
improve water and air quality; to preserve wetlands,
coastlines, and unfragmented forests; and to provide adequate
natural open spaces for the human population to enjoy. These
are broad policies directed at sustaining and enhancing
environmental resources through generations. The potential
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Mitigation reduces adverse
impacts.
Avoiding impacts is the most
preferable option.
Mitigation can take place
during planning, design, and
implementation.
environmental impacts of a proposed action, whose benefits
may address a short-term need (e.g., wastewater treatment,
increased industrial capacity, more efficient roadways) should
be evaluated for compliance with these long-term policies.
Economic comparisons of alternatives in the context of
national or regional goals can be very effective in
demonstrating which alternatives are most compatible with
long-term environmental goals such as levels of water or
energy conservation.
MITIGATION AND COMPENSATION
Mitigation is the purposeful implementation of decisions
or activities that are designed to reduce the undesirable
impacts of a proposed action on the affected environment.
Mitigation is a general concept that could include: 1)
avoiding impacts altogether by not taking a particular action,
2) minimizing impacts by limiting the magnitude of the
action, 3) restoring or repairing particular features of the
affected environment, 4) reducing impacts over time e.g. by
performing maintenance activities during the life of the
action, .and 5) compensating for impacts by providing
additions to or substitutes for the environment affected by the
action (Environmental Law Institute, 1991).
Note that these categories of mitigation approaches are
arranged in a hierarchical order of their desirability (Table 5-
2). In other words, it is more desirable to avoid impacts than
to have to restore the environment, or provide compensation
for impacts.
Undesirable environmental impacts that are identified
early in the EIA process can be avoided or minimized by
thoughtful modifications in the design of the proposed action.
The encroachment into sensitive environmental resources such
as wetlands, floodplains, or habitats for threatened and
endangered species can be avoided by changing the design or
layout if such resources are identified at an early stage of
planning and accorded the additional degree of protection
they warrant. For example, roadways that must cross wetland
areas can be aligned to cross the edge of wetlands so as
not to fragment them and disrupt their ecological and
Principles of Environmental Impact Assessment
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Key Considerations in the EIA Process
5-13
hydrological exchange; roadways that must pass through
wetland areas can also be designed with bridges or narrow
embankments to minimize the area of wetland filled in the
road crossing.
In a well-planned process, all reasonable means to avoid
and minimize impacts are incorporated into the alternatives
during the analysis of alternatives and project design.
Compensation for the remaining impacts is the final stage of
mitigation. A significant reduction in impacts can be achieved
by thoughtful use of the alternatives analysis and mitigation
options; it is through these means that the EIA process works
to prevent significant environmental impacts from occurring.
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TABLE 5-2
CATEGORIES OF MITIGATION
Avoidance:
Minimization:
Restoration:
Reduction:
Compensation:
Mitigation by not carrying out the proposed action. For example, if
the only area available for a regional airport happens to be an area of
extensive wetlands that would be filled during construction of the
airport, avoidance of the action might be the only reasonable way to
protect those wetlands.
Mitigation by scaling-down the magnitude of a project, reorienting
the layout of the project, or employing pollution prevention or
cleaner production technology and procedures that reduces the
factors generating the undesirable environmental impact. For example,
a wastewater treatment plant discharging to a river might be reduced in
treatment capacity, be oriented to avoid disturbances of wetlands and
floodplains at the facility site, and might employ advanced water quality
treatment techniques. Complete recycling of waste water could prevent
many of the adverse impacts due to water pollution.
Mitigation through the restoration of environments affected by the
action. For example, areas cleared for the installation of linear
facilities (pipelines, power lines) can be regraded after the facility is
installed, and then replanted with native vegetation.
Mitigation by taking control, prevention or maintenance steps during
the course of the action. For example, stormwater management
systems can be designed to trap sediments carried from developed areas
in stormwater runoff. Such stormwater systems are effective only if the
sediment traps are periodically cleaned.
Mitigation through the creation of environments similar to those
affected by an action. This step should only be considered after all
steps above have been completed. As a last resort, donation of land or
money for a regional program of habitat creation or enhancement could
be considered. Adverse impacts on the economics of small
communities can be "compensated" through special funds or payments.
Principles of Environmental Impact Assessment
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KEY STEPS IN THE EIA PROCESS
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6-1
6. KEY STEPS IN THE EIA PROCESS
INTRODUCTION
An EIA investigates, evaluates, and documents the
information that allows citizens and governmental agencies
to understand the risks and benefits of a proposed action and
its reasonable alternatives. This information is made
available to the individuals and organizations that will be
involved in the action, including environmental specialists,
the planners of the action, and the general public. The EIA
should consider all important information about the nature
of the proposed action, reasonable alternatives to the
proposed action including the no-action alternative, the
purpose of and need for that action, the environmental
setting in which the action is proposed, and a discussion of
anticipated environmental impacts. When completed, the
EIA report documenting the process becomes a primary
information source and a record of the EIA process. This
record becomes the decision document.
Experience in the United States and other countries
has shown that EIAs best serve these multiple purposes
when they are analytic rather than encyclopedic; that is,
when the information presented in the several EIA sections
is directly relevant to the risks and benefits of the proposed
action and its reasonable alternatives. This balance between
information content and relevance to the decision at hand is
a delicate one that is best approached by close adherence to
the general principles of scientific writing. The findings
and recommendations of the EIA should be supported by the
information and analyses contained in the document or, if
very voluminous, in documents incorporated by reference.
The logic of the steps in the impact assessment should be
clearly presented in a manner that will be understandable by
lay persons that review the report.
The basic framework of EIAs has been tested and
refined for several decades. The basic elements of that
framework are shown in Figure 6-1 and discussed in detail
below.
The EIA framework includes a
multi-step process that is
documented in the EIA report.
EIA documents should be
analytical.
Principles of Environmental Impact Assessment
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Key Steps in the EIA Process
6-2
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Kev Steos in the EIA Process
6-3
PARTICIPANTS
The EIA process requires the participation of several
groups: the agencies responsible for administering the EIA
regulations, representatives of the entity proposing the
action, scientific and engineering experts in relevant
disciplines, representatives from interested public
organizations, and the public at large. This combination of
participants is needed to achieve balance in the decision-
making process. The participants should be involved in the
process as early as possible and, through the scoping
process, should identify the key issues.
The report documenting the EIA process should
characterize the nature and extent of participation by
summarizing the participatory process and by identifying the
groups involved in such efforts. In addition, the
qualifications of the preparers should be presented early in
the document.
PURPOSE AND NEED
In organizing the EIA process, it is important to
articulate a clear definition of the purpose arid need for a
proposed action. In the absence of a clear perspective on
these aspects of an action, it would be difficult to identify
reasonable alternatives, balance the risks and benefits of an
action, and evaluate the reasonableness of the no-action
alternative. Where purpose and need are not clearly
justified and documented, the process should not proceed
further.
The report documenting the EIA process should
include a summary discussion and demonstration of the
need, or absence of need, for the proposed project. Where
the project entails new development, an analysis
demonstrating the inadequacy of existing development is
desirable. Where the project entails redevelopment or
remediation, an analysis demonstrating the benefits to be
gained from such actions should be clearly stated.
Principles of Environmental Impact Assessment
Who should participate in the
process?
Purpose and need must be
defined before the EIA process
can proceed.
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Key Steps in the EIA Process
6-4
Alternatives are compared with
respect to economics, policy,
technical feasibility, and
environmental impact.
Screening eliminates unfeasible
alternatives based on objective
criteria.
ALTERNATIVES THAT SATISFY PURPOSE AND
NEED
The alternatives section of the EIA report should include
a comparative analysis of feasible options that would meet the
stated purpose and need of the proposed action. The analysis of
alternatives should include consideration of the no-action
alternative. The feasible alternatives should be compared with
respect to capital and operating costs; direct, indirect, and
cumulative environmental impacts; physical, legal, or
institutional constraints; and compliance with regulatory
requirements. The reasons for rejecting any alternative should
be clearly stated, together with a summary of any significant
environmental benefits precluded by rejection of an alternative.
Alternatives often involve location, new or different
technologies, and/or alternative methods for accomplishing the
purpose and need. In a proposal to site an industrial facility, for
example, the alternatives analysis might identify several locations
or sites on which the facility could be constructed and operated.
The EIA process then should consider the range and magnitude
of environmental impacts that would occur at each location
should the facility be constructed there. The alternative of not
proceeding with the proposed action (the no-action alternative)
should also be accorded serious consideration and discussion.
SCREENING ALTERNATIVES
The initial screening of alternatives should be rigorous
and consider all possible means by which the purpose and need
of the action might be accomplished. This initial set of
alternatives will likely include some actions that are clearly
impractical, uneconomical, or environmentally unacceptable
based on objective screening criteria. It is important to
document the screening criteria and identify the class or types of
project that do not satisfy the criteria. Unreasonable alternatives
can be identified in an initial screening process, and eliminated
from detailed consideration in the full analysis of reasonable
alternatives. For some projects, this step may still leave an
unwieldy number of alternatives to evaluate in detail, in some
cases hundreds of alternatives. For these projects, it
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would be reasonable to reduce the number of alternatives to
a manageable few for detailed evaluation, using a more
refined or restrictive set of evaluation criteria. The use of
objective screening criteria enhances the reproducibility of
the results.
The number of alternatives carried forward for
detailed comparative evaluation and consideration should not
be arbitrarily set, but instead depend on the range of
practical alternatives available. The alternatives considered
in detail should be representative of the entire range of all
alternatives and should represent real alternatives to the
proposed action, not just modified versions of the preferred
alternative, However, the alternatives not considered
further should be documented in the EIA record, together
with the reasons why these particular alternatives were
screened from further evaluation.
DESCRIBING THE AFFECTED ENVIRONMENT
The description of the environmental setting sets
forth in detail the characteristics of the area in which the
proposed action would occur. This description should be of
the study area, which is a defined area within which all
effects, impacts, features, and potential compensation efforts
would occur from a proposed action and its alternatives.
The level of detail in this description of the study area
should be sufficient to convey to a reader or reviewer the
precise nature of the natural and human resources
potentially affected by the proposed action and alternatives.
This description also provides baseline data with which
environmental impacts can be predicted, and against which
the predicted impacts of the proposed action can be
compared.
The approach commonly adopted in treating this
aspect of EIA is the subdivision of the environmental setting
into a logical and hierarchical set of categories. The major
categories would likely include the following:
Geology - geological provinces, bedrock formations,
history of geological stability or instability.
Principles of Environmental Impact Assessment
How many alternatives should
be reviewed in detail?
The description of the
environmental setting defines
the study area and provides the
baseline for the impact analysis.
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Environmental Setting
• Geology
• Topography
• Soils
• Groundwater Resources
• Surface Water
Resources
• Terrestrial Communities
• Aquatic Communities
• Environmentally
Sensitive Area
• Air Quality
• Land Use
• Demography
• Sound Levels
• Socioeconomics
• Infrastructural Services
• Transportation
• Cultural Resources
• Project Economics
Topography - general topography of region, specific
topography of project area.
Soils - soils mapping, soil series properties, constraints
to development.
Groundwater Resources - nature of water-bearing
formations, recharge rates, sustainable safe yields,
locations and depths of existing wells, quality.
Surface Water Resources - drainage basins and
subbasins, named and unnamed water bodies and
watercourses, regulatory classification of water bodies,
flow regimes, water quality data and evaluation,
identification of existing permitted discharges to surface
waters.
Terrestrial Communities (botanical and zoological) -
spatial arrangement of vegetative community types,
vegetative species-abundance listings, wildlife species-
abundance listings, records of threatened and endangered
plant and animal species.
Aquatic Communities - nature of aquatic habitats,
species-abundance listings for aquatic macroinvertebrate
and fish communities, ecological indexing of community
data.
Environmentally Sensitive Areas - identification of
wetlands, floodplains, steep slopes, stands of mature
vegetation, aquifer recharge areas, areas of high water
table, areas of rock outcrop, prime agricultural lands,
and mines.
Air Quality - regional quality and trends, data from local
monitoring stations, reported exceedances of standards.
Land Use - existing patterns of land use in region,
regional planning for future use, zoning.
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Demography - censused or estimated population,
recent trends and projections for future population.
Sound Levels - existing sound levels, sources of
sound.
Socioeconomics (or Human Environment) -
economic and social structure of communities, tax
rates, characteristic types of development.
Infrastructural Services - nature and status of
human services such as police and fire protection,
hospitals, schools, utilities.
Transportation - layout and function of existing
roadways, railways, airports; existing and projected
capacities and demands.
Cultural Resources - location and characterization
of identified cultural resources (archaeological,
historical, cultural, landmark), potential for
unidentified resources to be present in project area.
Project Economics - comparative analysis of
proposed alternatives with present worth cost-
effective criteria, cost/benefit criteria, or other
methods.
The level of detail contained in the description of the
environmental setting will vary with the nature of the
proposed action and affected resources. Where an action
(and its anticipated effects) is compact and essentially
confined to a particular piece of property, it is generally
appropriate to describe all natural and man-made features of
the property and vicinity. This approach would be
appropriate in the EIA for a moderately-sized
industrial/commercial facility or for a residential
development. Where the action extends across several
regions or political subdivisions, as with a transmission line,
pipeline, or canal, the discussion of existing environments
may necessarily be less detailed in certain categories.
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Change of state is important in
forecasting impacts on the
biological environment.
Water quantity and quality
should be considered.
FORECASTED AND ASSESSING IMPACTS
Biological Environment, Including Terrestrial and
Aquatic Habitats - assessment of these natural features focuses
initially on the nature and distribution of existing habitats and
biotic communities, and the selective forces that have determined
these characteristics. The addition of new selective forces
related directly or indirectly to the proposed action should then
be considered. If the effects related to the proposed action are
likely to induce a "change of state" in one or more of the
affected habitats or biotic communities, the impact could be
considered significant. A change in state could be anticipated by
forecasting with ecological indices or habitat evaluation models;
for example, if the project could increase phosphorous levels in
a lake, the post-development trophic state of the lake can be
predicted. Likewise, if one or more habitats are likely to be
reduced significantly in size or habitat value, such an effect
might be deemed significant. The use of habitat evaluation
models can summarize present and future habitat values and can
quantify the degree of change likely to occur if the action were
implemented.
Water Environment - assessment of water resources
focuses on the identification of surface water and groundwater
resources, their existing quality and use, and the regulatory
standards applied to them. If water resources are to be used, the
capacity of the resource to accommodate this additional use
should be evaluated. Where water might be drawn from
subsurface aquifers and then, after use, discharged to surface
waters, the effects of this "diversion" of water from existing
hydrological cycles should be examined. The quality of water
might be altered by the proposed action from a wastewater
discharge. Water quality models can be run to forecast impacts,
and then future water quality should be compared to regulatory
standards and to the tolerances of organisms using the water
bodies as habitat.
Air Environment - assessment of the air environment
begins with the documentation of existing air quality, desirable
air quality, and prevailing regulatory standards. The potential
effects of the proposed action should be understood well enough
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to model the concentrations of important air-born
contaminants that would be expected if the action were
implemented. These anticipated concentrations can be
compared to regulatory standards and to standards or
guidelines for safe human exposure. Because the effects of
air quality changes are generally gauged in terms of the
affected human population, the determination of significance
in impacts may be more clearly discernible by human health
standards.
Noise Environment - assessment of the noise
environment is similar to that for air; the existing sound
levels can be compared to regulatory standards, guidelines,
health criteria, or some measures of acceptible levels and
the increases in sound levels, if any, can be gauged for
significance against these "standards". As with air
assessments, sound level assessments are generally
considered in the perspective of the human population
affected.
Socioeconomic Environment - assessment of
socioeconomic impacts should consider existing
demography, land values, income distribution, tax
schedules, and other related information about the structure
and function of the human communities affected by a
proposed action. The changes in these properties resulting
from implementation of the action can often be estimated as
monetary costs or benefits, resulting in a net gain or loss of
socioeconomic assets.
Cultural Environment - assessment of cultural
impacts focuses on the existence of recorded archaeological,
historic, or cultural resources potentially affected by the
proposed action. Where such resources have not been
formally described, literature and field studies may be
necessary to describe sufficiently the nature and extent of
such resources. The assessment of impacts should consider
the importance of cultural resources destroyed by the action
and the feasibility of recovering or conserving all or
portions of the resources.
Air models can forecast changes
in air quality.
Sound levels can be measured
in the field.
How will the action impact on
costs to the community?
Literature reviews and field
studies may aid in cataloging
cultural resources.
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MITIGATING ADVERSE IMPACTS
Mitigation in the EIA sense refers to measures taken to
eliminate or reduce undesirable effects that could result from a
proposed action. Mitigation may be required as a formal
component and a series of defined tasks in the approval of an
action, but mitigation as a philosophy can be invoked at any
stage of project planning.
In the United States, NEPA regulation 40 CFR 1508.20
defines mitigation as a hierarchical series of actions that include:
• avoiding the impact altogether by not taking a
certain action or parts of an action,
• minimizing impacts by limiting the degree or
magnitude of the action and its implementation,
• rectifying the impact by repairing, rehabilitating,
or restoring the affected environment,
• reducing or eliminating the impact over time by
preservation and maintenance operations during
the life of the action, and
• compensation for the impact by replacing or
providing substitute resources or environments.
The hierarchical nature of these mitigative categories is
a guide to project planning; during the initial phases of planning,
the action can be designed to avoid or minimize impacts to
sensitive resources through site selection and site layout.
Additionally, the plans for construction can include measures to
repair or restore affected areas and to maintain certain areas
during the life of the project. Compensation for the impact by
the substitution of resources or environments is the mitigative
measure of choice only if the preceding four categories of
mitigation do not adequately reduce the level of undesirable
impacts.
Mitigation by compensation can be accomplished by the
creation or enhancement of areas that are predicted to provide
equivalent resource value as the areas lost or disturbed by the
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proposed action. For example, if a wetlands area of low to
medium quality and value must be filled to accommodate a
project, an area of wetland can be created from upland
habitat. The specific techniques for this are reasonably well
understood (Hammer, 1989, 1992). However, a wetlands
constructed from uplands can seldom replace the functions
and values of a high quality and value wetlands; such
wetlands, given their difficulty to replace, should be more
stringently protected and if filled, should require greater
compensation than for low to medium value wetlands. In
the United States, regulatory agencies that administer
permitting procedures for such wetland disturbances often
require that the area of compensation be larger in area than
the area impacted. The rationale for this is that created
wetlands do not often achieve the same habitat value as do
natural wetlands, and value is lost over the time required for
compensated wetlands to reach full maturity.
IDENTIFYING PREFERRED ALTERNATIVES
The information on existing conditions and potential
environmental impacts that is collected in the EIA process
can ultimately lead to the identification of preferred
alternatives that can meet the needs and purposes of the
proposed action while simultaneously keeping undesirable
environmental impacts to a practicable minimum. The
identification of preferred alternatives meeting these criteria
should therefore be as analytically rigorous and objective as
is the documentation of conditions and impacts.
Several objective techniques for conducting analyses
to select the "best" alternative are described in Chapter 7.
In general, the relative merits of several alternatives are
often considered through three general perspectives: 1)
engineering feasibility and requirements, 2) economic
viability, and 3) environmental soundness. These general
perspectives can be used for orienting the initial screening
of alternatives and the final discussion of alternatives;
however, the identification of preferred alternatives should,
if possible, use more discriminating measures for comparing
the several options available to the decision-making body.
Principles of Environmental Impact Assessment
Compensation for adverse
impacts is less desirable than
avoiding the impacts altogether.
The selection of the preferred
alternative is an analytical and
objective process.
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The Three E's
Engineering
Economics
Environment
Engineering feasibility and requirements can be
quantitatively described in terms of facility requirements,
estimated costs to provide those required features, facility
construction and maintenance costs, and similar estimations that
are routinely carried out by businesses or site engineers when
new facilities are planned. The framework for these estimates
is well established in the industrial/commercial sector of
virtually every country.
Likewise, the economics of selecting one or another
alternative action can be well defined in monetary units well
understood by all persons and need to be determined for each
viable alternative. The estimation of economic costs, economic
benefits, changes in tax structures, infrastructural demands and
capacities, and employment opportunities that underlie such an
assessment are well understood and use commonly-accepted
techniques.
The environmental soundness of one or another
alternative is probably the most difficult aspect of the alternative
selection process to quantify. Projecting the risks and benefits
of proposed actions is possible, but these projections, estimated
as environmental changes, can only rarely be expressed in
economic units. Individuals and governments readily
acknowledge the intrinsic value of open spaces; of large tracts of
native vegetation; and of wetlands, coastlines, and diverse
wildlife communities. The balancing of losses of, or impacts to,
these environmental features is difficult to express in the same
terms as engineering requirements or economic benefits. The
techniques discussed in Chapter 7 describe various
methodologies that address this issue.
DOCUMENTING RESULTS AND SOLICITING
COMMENTS
The summary of results of the EIA process for a
particular proposed action and its alternatives should be compiled
in a formal document, the EIA. The EIA should summarize the
entire EIA process, from the notice of intent to prepare an EIA
and scoping to release of the EIA. Although public participation
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should be encouraged throughout the EIA process, the
stages in which the public most eagerly participates are
when EIA reports are released for comment. Ideally, the
EIA should be released for public comment two separate
times. The public comments received during the first
release of the document (draft EIA) should form the basis
for revisions to the next draft of the EIA (final EIA) in
which responses should provided to all comments received.
Comments received on the final EIA should be considered
when a decision on the choice of alternatives is made.
DECISION
The decision to adopt a particular alternative for
implementing a proposed action should be thoroughly
documented. The decision should be made with
consideration given to the comments received on the final
EIA. The decision made should be explained and justified
in light of the EIA and comments received. In the United
States, the formal decision document for a particular EIA is
either a Finding of No Significant Impact or a Record of
Decision, (ROD). This determination summarizes the EIA
process that led to the particular decision and includes all
conditions, such as compensation requirements, for
approval. The ROD should also be circulated for review.
MONITORING AND FOLLOW-UP
Once a proposed action has been approved through
the EIA process, the implementation of that action should be
periodically monitored for compliance with constraints set
as "conditions of approval." Such conditions might include
specific protective or mitigative measures, the monitoring of
discharges to air or water, the filing of periodic status
reports, or the performance of other activities to ensure that
the action does not have unanticipated impacts on
environmental resources.
The release of EIA reports is
when public participation is
greatest.
Decision documents describe the
outcome of the EIA process.
Can there be conditions of
approval?
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NOTES
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METHODS FOR FORECASTING AND
ASSESSING IMPACTS
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7. METHODS FOR FORECASTING AND
ASSESSING ENVIRONMENTAL IMPACTS
INTRODUCTION
The establishment of environmental laws and EIA
procedures in a variety of countries, and levels of
government in some of these countries, has catalyzed the
development or modification of many techniques for
assessing environmental impacts. The assessment of
impacts, however, still retains a high degree of subjectivity,
as evidenced by the spirited discussions that characterize
many public hearings on EIAs. Although the assessment of
the existing environmental conditions can be done with a
reasonably high degree of accuracy and precision, the
forecasting of impacts will continue to benefit from new
methodologies and refinements of existing techniques.
In developing a general approach to forecasting and
assessing environmental impacts, there are several
fundamental questions that must be asked early in the
planning process. They include:
• Are there sufficient predictive models and
site-specific data to support a quantitative
assessment of environmental impacts?
• Is there a quantitative threshold (e.g., a
standard or generally-accepted criterion) that
can be used to distinguish significant levels
of environmental impacts from all possible
levels of impacts?
• Are there quantitative/statistical
methodologies available for objectively
describing levels of impacts, or will
subjective scoring be used at one or more
stages of the assessment?
• Are there prior, related assessments that have
been conducted on similar actions?
Considerations in forecasting:
• Models
• Threshold levels
• Statistical methods
• Prior, related
assessments
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Absolute
methods.
vs. comparative
The ideal assessment circumstance would be where there
is a substantial base of data specific to the site or area being
evaluated, where there are well-tested predictive models that use
those categories of data, where there is general agreement among
professionals as to the level of environmental impact that would
be deemed "significant," where the need for subjective scoring
is minimal or absent, and where documentation of other similar
assessments is available. It is unlikely, however, that there will
be many situations where these ideal conditions will be satisfied,
and most EIAs require a substantial input of professional
judgement. In these situations, case studies of comparable
situations provide insight into the range and magnitude of
impacts.
Assessment methodologies generally can be separated into
two major subgroups: 1) those methodologies that use empirical
values to generate output that predicts future conditions (absolute
methods), and 2) those methodologies that use relative measures
to predict differences between two sets of conditions
(comparative methods).
ENVIRONMENTAL IMPACT ASSESSMENT
METHODOLOGIES
The number of specific methodologies that have been
developed to assess the environmental impacts of human actions
is substantial, too large to itemize in this document. The
methodologies, however, tend to fall into a manageable number
of general categories. Some of these are:
• Habitat Evaluation Methods - assessment of the
existing quality of various habitats can be standardized
through the derivation of a set of habitat evaluation
models that assign certain values (which may be binary,
incremental, or continuous) to certain environmental
conditions. These habitat evaluation methods may be
generalized for specific regional habitats, or may be
specific to particular species of concern. The U.S. Fish
and Wildlife Service has, with the help of expert
ecologists, produced many of these habitat evaluation
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methods, or "models," termed Habitat Evaluation
Procedure (HEP) models, and programmed these
models to be used interactively on microcomputers.
An investigator choosing to evaluate a particular
geographical area can select appropriate target
species from a master list, and use the habitat
requirements of these target species to generate a
sublisting of environmental variables that must be
analyzed or quantified. After these environmental
variables are measured or evaluated in field studies,
the habitat information can be entered into the
interactive program.
The HEP output reports each habitat type in terms of
its Habitat Suitability Index (HSI), scaled from 0.0
to 1.0. These HSIs are computed for each of the
target species and, as a weighted mean, for the total
area being evaluated. The investigator can also
examine intermediate model outputs and perform a
sensitivity analysis of the input variables. The HSIs
and the areas of the habitats can be combined by
simple multiplication to yield Habitat Units (HUs)
for each habitat category and for a series of
scenarios (target years) with varying combinations of
land use.
The HEP outputs can be used to assess
environmental impacts by comparing the HUs
available to each target species in pre-action and
several post-action scenarios. Additionally, if the
areas of certain habitats are to be created or
enhanced through mitigation, the effects of such
changes can be compared with the unmitigated
scenario.
Ecological Indices - ecological indices simplify
complex data sets to scales of 0-1 or 0-100 for
uniformity. The generation of indices from detailed
data sets can facilitate comparisons among existing
environments, and can, in certain cases, be used to
compare pre-development and post-development
conditions.
Biological models can assess the
suitability of habitats.
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Diversity is one measure of
ecological conditions.
Cause-effect relationships are
forecasted with mathematical
models.
An ecological index in common use in environmental
monitoring and assessment is the Shannon-Wiener
diversity index and used principally to describe the
taxonomic diversity of ecological communities. This
index describes the information content of any system as
defined by a Fano code (Shannon and Weaver, 1949).
The Shannon-Wiener index is easily computed from
listings of species commonly acquired during random
sampling of communities; moreover, the index can be
broken into various contributing subindices, and can be
applied hierarchically to several taxonomic levels
(Pielou, 1975). Other similar community diversity
indices include Simpson's index and Brillouin's index.
Simpson's index is based on joint probabilities and can be
used in the same context as the Shannon-Wiener index.
Brillouin's index is preferred when the community of
concern is totally censused rather than randomly
subsampled. All three of these indices use the taxonomic
representation of any group as its proportion of the total
number in the sample.
These community diversity indices can be applied not
only to taxonomic lists, but also to other analyses where
an aggregate can be separated into its components. For
example, information appropriate for habitat evaluation
models (i.e., where a large area is subdivided into
subareas of habitat types) can be evaluated by diversity
index models to describe the complexity of the existing
and future habitats.
Ott (1978) has published a discussion of the formulation
of environmental indices, including indices for air,
water, and quality of life.
Mathematical Modeling - in this approach to
environmental impact assessment, the principal cause-
effect relationships of a proposed action are described in
terms of mathematical functions and combined to yield a
mathematical model capable of predicting future
environmental conditions. Mathematical models come in
all degrees of complexity, from simple variations on
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mass balance equations (e.g., for estimating nitrate-
nitrogen in groundwater) to highly complex
multivariate systems. The mathematical functions
may be purely determined by existing conditions, or
may have strong random elements contributing to the
model output. Some models include statistical
routines for estimating error associated with model
outputs. Most commonly used mathematical models
for impact assessment have been adapted for
computers, in either batch or interactive modes.
A listing, though certainly a non-inclusive one, of
environmental effects that have been mathematically
modeled would include:
- Energy
- Thermal Plumes
- Noise
- Transportation
- Air Emissions
- Stormwater Runoff
- Pollutant Transport in Water
- Pollutant Transport in Soils
- Risk Assessment
- Ecological Risk Assessment
- Wasteload Allocations
Delphi Technique - this method uses the opinions of
knowledgeable experts and, through a repetitive
process, converges toward group consensus. The
technique originated by Rand Corporation in 1964
and has been used and tested in a wide variety of
applications and dimensions. The main attribute of
this technique is that is forces a group, typically an
expert panel, to think in a structured fashion and to
focus such thinking toward a common goal. The
technique commences with an initial survey, the
collective results of which are resubmitted to the
experts for a second round of comment. This
process of refinement continues until a group
consensus is reached on the issue being investigated.
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Methods for Forecasting and Assessing Environmental Impacts
7-6
How can experts be polled to
obtain objective assessments?
One example of an environmental assessment
methodology developed using the Delphi technique is the
National Sanitation Foundation Water Quality Index
(WQI) developed in the United States. The goal was to
derive a system for indexing key water quality variables
and integrating a small group of variables into an
indexing system. In this way, water quality data could
be used in a standardized system of rating that had use
for comparisons in space and time. The first step in
developing the WQI was the polling of 142 water quality
experts, who were asked to rate the importance of 35
water quality variables in describing the status of a water
body. One hundred and two opinions were returned in
this initial polling (a 72% return rate), and the collective
results were resubmitted to the participating experts for
additional comment. Eventually, the group opinion
converged on a "short list" of water quality variables that
were considered most important in describing the status
of a water body. These were dissolved oxygen
saturation, fecal coliform bacteria, pH, 5-day
biochemical oxygen demand (BOD5), nitrates,
phosphates, temperature (as a deviation from ambient
temperature), turbidity, and total solids. The polling also
allowed the experts to graphically portray their opinions
on how water quality changed with changes in the key
variables; the results of this polling were used to generate
graphs or rating curves relating the concentration of the
water quality variable to the quality of the water body on
a 0-100 scale. Finally, the polling of the experts allowed
the generation of variable weights that expressed the
relative importance of specific variables. For example,
dissolved oxygen saturation was considered more
important than total solids, and was accorded a greater
weight in index computation.
With the Delphi technique having provided the list of key
water quality variables, the relative weighting that should
be assigned to each variable, and the graphical
relationship between concentration and subjective water
for each variable, the WQI was created. The index,
which requires measurement of nine water quality
variables and a manual or computerized calculation of a
'S'EPA
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water quality index, has been used by various
regulatory and environmental organizations in the
United States. It should be noted that the reduction
of environmental data to index values, for water
quality or for other ecological attributes of a system,
should be done carefully because, by definition, the
data base is simplified enormously to generate the
index. The implications of certain index values
should be corroborated by other assessment
techniques. Also, any such assessment index should
be validated by field testing. Nonetheless, the use of
indices derived from the consensus of experts can
facilitate comparison of data from different
geographical areas or from different points in time.
Adaptation of Common Multivariate Statistical
Methods - the use of commonly accepted.statistical
methods can reduce one potentially troublesome
aspect of impact assessment - the reliance on
subjective judgements or scoring in comparing
different ecological conditions. Assessment by
opinion, even when those opinions are those of
experts on the specific issue, is difficult to
accomplish with limited resources, and is always
open to criticism. If there are sufficient and suitable
data available on particular environmental resources,
multivariate statistical routines can be used to group,
sort, and discriminate among general ecological
conditions. In some cases, these statistical
procedures can be used to quantify the predicted
magnitudes of environmental impact or even the
positive effects of mitigating measures. Multivariate
statistical methods often require the use of a
computer, and are performed by someone who is
extremely familiar with statistical analysis.
The types of multivariate statistical routines that can
be used include, but are not limited to, discriminant
analysis, case clustering, principal components
analysis, ordination, and canonical correlation.
These methods can isolate key variables that
differentiate among different sets of variables
(discriminant analysis), can be used to identify
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Multivariate Statistical
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Graphical Overlays
environments having similar collections of properties
(case clustering), can determine major axes along which
various environmental conditions or sets of variables can
be arranged and separated, and can arrange sets of
variables in a hierarchical manner (ordination, case
cluster). A primary advantage of these multivariate
statistical methods is that they use empirical values to
describe statistically significant similarities or
differences; the element of subjectivity inherent in
subjective scoring is drastically reduced.
An example of the use of multivariate statistical analysis
applied to an EIA can be drawn from a study directed
toward mitigating potential impacts to an estuarine fish
population resulting from the proposed filling of near-
shore habitats in a coastal river. Extensive trawl, water
quality, and bathymetric sampling generated an extensive
data base, from which the apparent habitat preferences of
the fish species was derived using case clustering and
discriminant analysis. The results of these analyses were
used to identify habitat conditions that could, in theory,
be changed to enhance the value of marginal habitats for
use by Ms fish species; in fact, by changing the inputs in
the analysis to the "enhanced values," it was possible to
estimate the degree of usage that the fish would make of
the enhanced habitats (Bell et a]., 1985). An extensive
review and discussion of the statistical analysis of
environmental impacts has been published by Green
(1979).
Graphical Overlays - this is a technique that has always
been extremely useful in identifying areas that have high
environmental sensitivity. The technique entails the
separate mapping of various critical environmental
features - wetlands, steep slopes, soils, floodplains,
bedrock outcrops, wildlife habitats, vegetative
communities, and cultural resources - at the same scale
as the project's site plan. The environmental features are
mapped on transparent plastic in different colors. The
several environmental maps can then be overlaid on the
project map to highlight the areas of highest
environmental sensitivity.
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Geographical Information Systems (GISs) - these
systems are essentially computerized graphical
overlays and interacting data files. Environmental
features are mapped, and the mapping digitized and
stored in the GIS data base. The mapped features
can be combined to produce computer-generated
displays of one or more environmental features in a
specified geographical area. If the GIS mapping is
conducted systematically, information acquired on
specific projects can be combined, and the GIS data
base becomes more detailed over time.
Simulation- simulation methodologies are generally
used to assess the probabilities of various classes of
events, or to forecast environmental changes from
existing general trends. Where environmental
properties have significant variation and constant
input values are not sufficiently descriptive,
simulation methods can be used to select input values
from a specified probability distribution into a
mathematical function. The function is solved
repetitively, and the distribution of output values
evaluated. The Monte Carlo simulation technique is
widely used in this manner.
For example, if a proposed water treatment plant
had a variable rate of discharge with variable
concentrations of a contaminant and variable
efficiencies in the removal of the contaminant, and
if each of these variables could be described by a
known probability distribution, Monte Carlo
simulation methods could be used to estimate how
frequently the concentration of the contaminant in
the discharge might exceed a particular value.
Monte Carlo simulation methods can also be used
where technical experts do not agree on the values of
correction factors to be used in assessing empirical
data. Such technical disagreements can lead to
different experts arriving at conclusions that are
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Simulation
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Risk Assessment
Cost-Benefit Analysis
orders of magnitude apart (as evidenced by recent
international discussions on the effect of the fires in the
Kuwait oilfields, global warming, and ozone depletion).
In a major environmental assessment recently conducted
on a proposed transportation project in the northeastern
United States, several experts independently analyzed
catch data from fisheries to estimate the proportion of the
population affected by the project. Those estimates,
which started with the same data set, ranged from 0.1 %
to 96%. The differences originated in the corrections
each expert made for efficiency of the sampling gear and
vertical distribution of the fish. Monte Carlo simulation
could have been used to generate probability functions
that would have been more realistic than the extreme
values generated by the contending experts. Presenting
a decision-maker with scientific testimony that the
proportion of a population potentially affected by an
action ranges from 0.1 to 96% is hardly conducive to
informed decision-making.
Risk Assessment - this refers to a category of analyses
by which the potential risk of harm to individuals,
communities, and ecosystems can be evaluated. The
general techniques include comparison of expected
conditions with prevailing environmental standards,
modeling of expected conditions and estimation of error
terms associated with model estimates, and Monte Carlo
simulation of the frequency of certain events under
expected conditions.
Cost-Benefit Analysis - this is a formalized accounting
of the anticipated costs and benefits of an action. The
cost-benefit analysis is of particular use when comparing
alternative forms of an action. The "costs" of an action
include, but are not limited to the economic costs, the
risks to long-term environmental quality and public
health, and the impacts to natural and man-made
resources. The benefits include monetary benefits, but
also extend to positive changes in the quality of life,
protection of sensitive environmental resources, and
long-term enhancements to human health and welfare.
Principles of Environmental Impact Assessment
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Methods for Forecasting and Assessing Environmental Impacts
7-11
COMPARATIVE METHODOLOGIES
The strong point of comparative assessment methods
is that the absolute values of environmental attributes need
not be quantified precisely. As long as a uniform treatment
of environmental variables is maintained, the assessment
should predict anticipated changes in environmental
conditions with reasonable accuracy, and in many cases it is
the description of the degree of change in environmental
condition mat is the principal goal of the impact assessment.
Comparative assessment is also of principal
importance in the evaluation of alternatives; for a fair and
full treatment of all reasonable alternatives, there must be
equivalency in descriptions of the potential environmental
impacts of each alternative. The checklist and matrix
methodologies described in the following sections are
examples of environmental assessment methodologies that
are appropriate for comparison of alternatives. The case
study approach can also be used. The proposed project can
be compared to similar projects that were previously
implemented.
A special case of comparative assessment of potential
environmental impacts is the so-called "worst-case
analysis." This was an analytical approach that resulted
from language in,the CEQ NEPA Regulations, which states
in 40 CFR 1502.22(b)(2) that "[F]or the purposes of this
section, 'reasonable foreseeable1 includes impacts which
have catastrophic consequences, even if their probability is
low, provided that the analysis of impacts is supported by
credible scientific evidence, is not based on pure conjecture,
and is within the rule of reason." This well-intentioned
mandate was rapidly exploited by EIA participants seeking
to cast a proposed action in the worst possible light, and
worst-case scenario-making showed some tendency to
exceed the "rule of reason" stipulated by the Council's
regulations. The worst-case analysis is useful as a
component in a spectrum of comparative analyses ranging
from the worst to the most likely case.
Comparative methods are based
on a uniform evaluation that is
not necessarily quantitative.
Principles of Environmental Impact Assessment
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Methods for Forecasting and Assessing Environmental Impacts
7-12
Checklists are commonly used
tools to identify impacts.
Matrices are widely used to
compare alternatives.
Model validation is a step necessary in the creation of
predictive models. The use of unvalidated predictive models in
impact assessment should be an approach used only when
validated models are unavailable or inappropriate. In one major
EIA for a highway project in the northeastern United States, an
unvalidated mathematical model was used to predict the
distribution of fish in a major estuary; the mathematical model,
which formed the technical basis for the findings of the EIA,
was later shown to converge on particular solutions with widely
varying sets of input data. This particular model was shown by
sensitivity analysis to be fundamentally flawed; expediency had
resulted in its use before adequate validation had been
performed.
CHECKLISTS
The use of checklists for identifying and, to a limited
extent, characterizing, environmental impacts, is very common
throughout existing EIA processes. A checklist forces the
assessment to consider a standardized set of activities or effects
for each proposed action, thus bringing uniformity to the
assessment process. Checklists can be used to determine
environmental impact thresholds, thus indicating whether a full-
scale EIA is needed for a particular project or whether a finding
of no significant impact could be issued.
In implementing NEPA, all United States federal
agencies prepared guidance documents demonstrating how their
procedures would conform with NEPA requirements. Many of
those agencies and their environmental consultants prepared
checklists that would be used for assessing all relevant aspects of
proposed actions in standardized format. An example of one
such checklist, adapted from that prepared by A.D. Little (1971)
for a proposed federal action is shown in Table 7-1.
MATRICES
Matrices are very likely the most popular and widely
used EIA methodology. One common application is in the
comparison of alternative actions. Alternative actions
(measures, projects, sites, designs) are listed as column
headings, while the rows are the criteria that should determine
'S'EPA • Principles of Environmental Impact Assessment
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Methods for Forecasting and Assessing Environmental Impacts
7-13
How many factors can you
consider?
Optimum is fewer than
the entire Leopold
Matrix which includes
8,800 different factors
Checklists can evolve into
matrices.
the choice of alternative. In each cell of the matrix, a conclusion
can be listed indicating whether the alternative action is likely to
have a positive or negative effect relative to the indicated
criterion. Very often, the conclusion is stated as a numerical
value or symbol indicating the level of intensity of the effect.
There is an opportunity, moreover, to apply relative weighting
to the various criteria when evaluating the completed matrix.
An early example of a comparative matrix with
provisions for weighting various criteria, adapted from Odum et
al.(1971) is shown in Table 1-2. This matrix was used in the
EIA process for a section of interstate highway in the
southeastern United States. A total of 56 factors were identified
and sorted into four general groups: economic and highway
engineering factors, environmental and land use considerations,
recreational considerations, and social and human considerations.
Data were evaluated for each of eight alternative highway
alignments. The data were scaled against the maximum value
occurring in the range of alternatives. Then, an interdisciplinary
team assigned relative weights (over a range of -20 to +50)
characterizing the initial and long-term effects of project
implementation on each individual factor. The weighted scores
were summed into a "relative impact" term characterizing each
alternative. The advantage of this technique is that an error term
can be calculated for each relative impact score, and the
technique can be repeated several times in a Monte Carlo
simulation to yield average scores adjusted for error.
The evolution of an EIA methodology from checklist to
matrix is intuitively and easily accomplished. A checklist can be
viewed as a single-column summary of a proposed action, with
only a coarse characterization of the nature and magnitude of
potential environmental impacts provided. An EIA matrix
provides a finer degree of impact characterization by associating
a set of columns (effects) with each row (environmental
attribute) of the matrix. The United States Geological Survey
matrix formulated by Leopold et al.(1971) (the "Leopold
Matrix") consists of 100 columns representing examples of
causative actions, and 88 rows representing environmental
components and characteristics. As a first step, the columns
SVEPA • Principles of Environmental Impact Assessment
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Methods for Forecasting and Assessing Environmental Impacts
7-14
CHECKLIST OF PO1
OFAT&
CATEGORY
I. Noise Impacts
A. Public Health
B. Land Use
n. Air Quality Impacts
A. Public Health
B. Land Use
m. Water Quality Impacts
A. Groundwater
1. Flow and water table
alteration
2. Interaction with surface
drainage
B. Surface Water
1. Shoreline and bottom
alteration
2. Effects of filling and
dredging
3. Drainage and flood
characteristics
C. Quality Aspects
1 . Effect of effluent loadings
2. Implication of other
actions, such as
a. Disturbance of
bentnic layers
b. Alteration of currents
c. Changes in flow
regime
d. Saline intrusion in
groundwater
3. Land use
4. Public health
IV. Soil Erosion Impacts
A. Economic and Land Use
B. Pollution and Siltation
V. Ecological Impacts
A. Flora
B. Fauna (other than humans)
'tAB"£&7-f5"''""
!ENTML"ENVIROIi
%Piw^vR*-(Ai*4"L«N iff
PLANNING, DESIGN
CENTAL IMPACT
IO3BCT
CONSTRUCTION
'S
OPERATION
Principles of Environmental Impact Assessment
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Methods for Forecasting and Assessing Environmental Impacts
7-15
TABLE 7-i
CHECKLIST OF POrflfiAL ENVmOKMENTAL IMPACTS
OF A TRAHSP0KTATI0H PROJECT
CATEGORY
VI. Economic Impacts
A. Land Use
1. In immediate vicinity of
project
2. In local jurisdiction
served
3. In region
B. Tax Base
1. Loss through
displacement
2. Gain through increased
values
C. Employment
1. Access to existing
opportunities
2. Creation of new jobs
3 . Displacement from jobs
D. Housing and Public Services
1 . Demand for new services
2. Alteration in existing
services
E. Income
F. Damage to economically-
valuable natural resources
VII. Sociopolitical Impacts
A. Damage to, or use of:
1. Cultural resources
2. Scientific resources
3. Historical resources
4. Recreational areas
B. Lifestyle and Activities
1. Increased mobility
2. Disruption of community .
C. Perception of cost/benefit by
different cohesive groups
1. Racial
2. Ethnic
3. Income class
D. Personal Safety
PLANNING, DESIGN
CONSTRUCTION
OPERATION
Principles of Environmental Impact Assessment
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Methods for Forecasting and Assessing Environmental Impacts
7-16
TABLE 7-1
CHECKLIST OF POTENTIAL ENVIRONMENTAL IMPACTS
OF A TRAN0POETATI0N PUdBCT
CATEGORY
VIII. Aesthetic and Visual Impacts
A. Scenic Resources
B. Urban Design
C. Noise
D. Air Quality
E. Water Quality
Source: A.D. Little, Inc. (1971)
PLANNING, DESIGN
CONSTRUCTION
OPERATION
• Principles of Environmental Impact Assessment
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Methods for Forecasting and Assessing Environmental Impacts
7-17
The Leopold Matrix assigns
numerical values for magnitude
and importance of impacts.
Graphical summaries of
matrices help to visually
illustrate the results.
that correspond with the nature of the proposed action are
checked off. Then, for each column that is marked, the cells
corresponding to environmental effects are examined. Two
scores (on a scale from 1 to 10) are listed in each cell, separated
by a slash (/); the first score represents the magnitude of the
possible impact, while the second score represents the
importance of the possible impact. Beneficial impacts are
indicated by a plus (+) sign. The interpretation of the matrix is
based on the professional judgement of those individuals
performing the El A.
Several variants of the Leopold Matrix have been
prepared; some of them have been adapted for computerized
analysis (Schlessinger and Hughes, 1972; LMS Engineers,
1985). These variants may also integrate the scores in groups of
cells to provide a quantitative and/or graphical summary of the
matrix scoring.
With the characterization of a particular action expanded
to two dimensions, comparison of several alternatives requires
the addition of a third dimension. This is readily accomplished
both conceptually and practically. The LMS Engineers
adaptation of the Leopold Matrix provides a graphical summary
(a bar histogram plot) of the anticipated impacts of a proposed
action. The Leopold Matrix analysis can be performed on
several alterative scenarios, yielding graphical summaries that
can be visually or mathematically compared. The three-
dimensional spreadsheet software programs now available also
lend themselves to the comparison of EIA matrices in three-
dimensional format.
Principles of Environmental Impact Assessment
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Methods for Forecasting and Assessing Environmental Impacts
7-18
O WMOM PATHWAY
COMPONENT
Land affected - pine forest
Land affected - mixed forest
Land affected - hardwood forest
Land affected - agricultural
Land affected - idle
Land affected - surface waters
Land affected - wetlands
Land affected - mined land
Land affected - urban
Water supplies affected
Unique areas
Streams crossed
Small abridgements
Major bridges - number across major water bodies
Major bridges - length of spans across water
bodies
Major bridges - number across other water bodies
Major bridges - length across other water bodies
Composite soil limitations
Maximum sedimentation effects possible
Minimum sedimentation effects achievable
Area to be paved
Area greatly affected by noise
Area somewhat affected by noise
Total system cost
Annual costs
Total excavation required (volume)
Annual road user costs
Benefit/cost ratio
Interstate highway mileage
Taxable land removed (area)
Public land removed (area)
Total family displacements
Nearby residences affected by noise
%nrf ^m* 7 "U&
ftfmXK »¥£*&&!
Relative Weight:
Initial Effects
' '*'~
.FORMAT
Relative Weight:
Long-term Effects
Classification
Principles of Environmental Impact Assessment
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Methods for Forecasting and Assessing Environmental Impacts
7-19
o^ruMim* pAi»w&o4£mi3£ - T^HCAI, roiMAi1
COMPONENT
Daytime residential activities somewhat affected
Daytime residential activities greatly affected
Nighttime residential activities somewhat affected
Nighttime residential activities greatly affected
Churches somewhat affected by noise
Churches greatly affected by noise
Schools somewhat affected by noise
Schools greatly affected by noise
Lives saved/route - short-term
Lives saved/route - long-term
Number of interchanges
Secondary growth impact - potential for
development
Secondary growth impact - suitability for
development
Secondary impact - water quality
Secondary impact - visual disturbance
Secondary impact - hunting and game
Secondary impact - natural character of area
Secondary impact - safe access
Impact on planned surface water supply pattern
Driving for pleasure
Composite noise effect - camping
Composite noise effect - picnicking
Recreational land loss - present lands
Recreational land loss - future lands
Source: Odumetal. (1971)
Relative Weight:
Initial Effects
Relative Weight-
Long-term Effects
Classification
Principles of Environmental Impact Assessment
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Methods for Forecasting and Assessing Environmental Impacts
7-20
NOTES
• Principles of Environmental Impact Assessment
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8
WRITING EIA REPORTS
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Writing EIA Reports
8-1
8. WRITING EIA REPORTS
INTRODUCTION
The EIA report documents the process of impact
assessment, serves as a primary information source for those
organizations and individuals reviewing and commenting on
the report, and presents in clear and objective manner
options to be considered in the decision-making process.
Clarity, objectivity, and conciseness in the report are of
paramount importance in the preparation of the EIA report.
To promote uniformity in the basic preparation of EIA
reports, the laws and regulations implementing the EIA
process should specify a basic format and recommend
general or specific styles for writing, indexing, referencing,
and illustrating to be followed.
GENERAL FORMAT
The general document format for EIA reports
recommended by the CEQ in the United States is as follows:
Cover Page
Summary
Table of Contents
Purpose and Need for Action
Alternatives including Proposed Action
Affected Environment
Environmental Consequences
Comments and Responses to Comments
List of Preparers
List of Agencies, Organizations, and Persons
to Whom Copies of the Report are Sent
Index
Appendices (if any)
Table 8-1 provides a summary discussion of each of these
major topics.
The EIA Report is;
• Clear
• Objective
• Concise
• Principles of Environmental Impact Assessment
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Writing E1A Reports
8-2
TABLE 8-1
SUMMARY FEATURES OF MAJOR COMPONENTS OF AN EIA REPORT
Cover Page
A single page listing the responsible agency and cooperating agencies; the title
of the proposed action and its location; the name, address, and telephone
number of a contact person, a designation of the report as draft or final, a one-
paragraph abstract of the EIA report, and the date by which comments must be
received.
Summary
A summary of the proposed action, preferably less than 15 pages in length, that
accurately and adequately describes the content of the EIA report. The
summary should stress the final conclusions, areas of controversy, and the
issues to be resolved.
Table of Contents
A list and page number index of the chapters, sections, and subsections in the
EIA report, including a list of tables and a list of figures.
Purpose and Need for Action
A brief statement of the purpose and need to which the agency is responding in
proposing the alternatives, including a description of the proposed action.
Alternatives Including Proposed Action
A presentation of the environmental impacts of the proposed action and all
reasonable alternatives in comparative form, exploring each alternative,
including the no-action alternative, and the reason why certain alternatives
were recommended or eliminated.
Affected Environment
A succinct description of the environment of the areas to be affected by the
alternatives under consideration. Data and analyses for any given subject area
should be commensurate with the importance of the impact in that subject area,
with less important material summarized or referenced.
Principles of Environmental Impact Assessment
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Writing EIA Reports
8-3
TABLE 8-1
OTtfMARY FEATURES OF MAJOR COMPONENTS OF AN EIA REPORT
Alternatives
Different means of meeting the basic purpose and need of a proposed action.
The alternatives should include a full and rigorous consideration of all
reasonable alternatives, including non-structural alternatives, that would satisfy
the purpose and need of the proposal. The goal is to identify the least
environmentally damaging alternative that satisfies the basic purpose and need
of the proposed action.
Environmental Consequences of the Alternatives
A discussion of the environmental impacts of the various alternatives being
considered, identifying any adverse environmental effects that cannot be
avoided if the action is implemented, all mitigation measures to be employed to
reduce the adverse effects, the relationship between short-term uses of the
environmental and the enhancement of long-term productivity, and any
irretrievable or irreversible commitments of resources that would occur if the
action were implemented as proposed.
Comments and Responses to Comments
A listing of the written comments submitted by reviewing governmental
agencies, public and private organizations, and interested individuals, and
comments submitted in public hearings on the project. The comments included
should be only those requiring a substantive response. The author of the
comment should be identified by name and address. Comments may be
paraphrased, and repetitive comments or questions may be listed once and
cross-referenced to multiple sources.
The responses to the comments should either follow the comment directly, or
reference the particular comment requiring any specific response. If the
response references material already contained in the EIA report, the pertinent
page number should be cited. The responses should address the substance of
the comments as directly as possible.
List of Preparers
A list of the names and a summary of the professional qualifications of persons
who were primarily responsible for the preparation of the EIA report or
significant background materials.
Principles of Environmental Impact Assessment
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Writing EIA Reports
8-4
TABLE 8-1
SUMMARY mAtWES OF MAJOR CQMPOITOTS OF
List of Agencies, Organizations, and Persons
to Whom Copies of the Report Are Sent
A list detailing the agencies, organizations, and persons that have been sent
copies of the EIA report, including the addresses of public repositories
(libraries, government offices) where the report is available for review.
Index
A listing of the major components of the EIA report by topic or issue, together
with page number references.
Appendices
Materials prepared in connection with an EIA report that substantiate analyses
fundamental to the report, that relate to the decision to be made, and that
should be circulated with the EIA report. Material incorporated by reference
is generally not included in these appendices.
• Principles of Environmental Impact Assessment
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Writing EIA Reports
8-5
INCORPORATION BY REFERENCE
EIA reports, as noted earlier, should be analytic
rather than encyclopedic, providing information necessary
and sufficient for reasoned decision-making. The EIA
report, therefore, should be a document of moderate size,
on the order of 100 pages. The bulk of the report can be
reduced by incorporation by reference; incorporated
material should be cited in the report and its content briefly
described. No material should be incorporated unless it is
reasonably available for inspection by potentially interested
persons within the time allowed for comment. Material that
is based on proprietary data that is itself not available for
review and comment should not be incorporated by
reference.
Tiering is another method used to reduce paperwork.
The term refers to the process of initially addressing a broad
topic in an EIA report and then analyzing a narrower, site-
specific project related to the broad topic. The purpose of
tiering is to eliminate repetitive discussions and focus on
relevant issues that are undergoing decision-making.
Materials typically incorporated by reference include
other EIA reports, research papers in the general technical
literature, technical background papers, data reports
prepared independently from the EIA, textbooks,
handbooks, other reference materials.
STAGES OF PREPARATION
EIA reports for major actions by national or regional
agencies are likely to generate substantial discussion among
reviewers, and may require modifications to components of
the proposed action before the action is considered
acceptable. The process of review and comment can be
expedited by circulating a draft EIA report to environmental
agencies and the public for review. The draft EIA should
be complete in form and content, so that all relevant
information about the proposed action is available for
review.
'SS'EPA • Principles of Environmental impact Assessment
Referring to other documents
by reference helps to make a
concise EIA.
A draft EIA is complete in form
and content.
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Writing EIA Reports
8-6
The final EIA should address
comments received on the draft
EIA.
Use graphs and charts
Following submission of comments from reviewers, the
EIA report can be revised to address substantive concerns and to
evaluate modifications in the proposed action. The revised
report can be re-issued in full as a final EIA report;
alternatively, a final EIA report that discusses only the changes
to the draft EIA report can be issued. This latter procedure may
save considerable time and resources by concentrating on
changes and incorporating by reference the sections of the draft
EIA that have not been modified in the course of review and
comment.
The final EIA report should also contain copies of letters
submitted in comment on the draft EIA, transcripts of public
hearings held on the draft EIA, and responses to substantive
comments. These responses may reference pertinent sections in
the EIA in answer to particular written or verbal questions.
GENERAL WRITING SUGGESTIONS
The EIA report must serve multiple functions, being
simultaneously a decision-making document, a technically
rigorous scientific analysis of potential environmental impacts,
a record of the EIA process and participants, and a source of
information for public citizens. Preparing a report that will
serve these different readerships requires careful consideration
of the ways in which information is presented. The following
items are useful guidelines to follow in preparing the EIA report.
• Use Visual Displays - visual displays of descriptions of
existing and future conditions, data sets, impact analyses,
alternatives comparison, and mitigation measures are
extremely effective in communicating information about
the proposed action. Maps and/or photographs should be
used to familiarize readers with the affected area.
Graphs, bar charts, pie diagrams, summary matrices, and
similar information summaries should be used where
possible. The visual displays can be briefly explained
and discussed in accompanying text.
• Principles of Environmental Impact Assessment
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Writing EIA Reports
8-7
Avoid Vague Generalities, Cliches, or
Professional Jargon - the findings and conclusions
of the report should be phrased in clear language
that can be understood by lay persons reading the
document. Where effects are understood, they
should be stated clearly and objectively; where
sophisticated analyses are performed, the summaries
of these analyses should explain the findings in
ordinary phrases.
Maintain Continuity Throughput the Report - the
EIA report, though likely to be highly technical and
lengthy, should "tell a story"; the sequence in which
information is introduced should have strong
continuity so that a review can follow the logic of
the assessments, analyses, and conclusions.
Review and Edit the Draft EIA Report for
Consistency in Style and Content - EIA reports are
likely to be drafted by interdisciplinary teams.
Differences in writing style could result in
contradictory statements or information in various
sections of the report. A thorough internal review
of the completed draft EIA report should be
conducted to identify and resolve such
contradictions, if present. Legitimate differences of
scientific opinion should not be omitted, but should
rather be included to provide decision-makers and
reviewers with these different assessments.
Conflicting statements based on technical errors in
data presentation or analysis should be resolved and
revised.
Present All Relevant Risks and Benefits
Objectively - the purpose of the EIA report is to
present to decision-makers relevant and objective
information about the alternative ways of meeting a
declared purpose and need. The risks and benefits
of alternatives reasonably available should be
presented without bias.
• Principles of Environmental Impact Assessment
Avoid Jargon
Try to tell a story!
Edit, Edit, Edit
Objective writing facilitates
non-biased decision-making.
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Writing EIA Reports
8-8
NOTES
'©'EPA
Principles of Environmental Impact Assessment
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REVIEWING AND EVALUATING
EIA REPORTS
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Reviewing and Evaluating EIA Reports
9-1
9. REVIEWING AND EVALUATING EIA REPORTS
INTRODUCTION
The various environmental agencies administering
EIA laws and regulations should review EIA reports and
submit comments in writing to the principal oversight
agency for the EIA being considered. If the laws and
regulations provide for the review of a draft EIA report,
review and comment on the completed draft can be
extremely constructive. The review should be concerned
with the completeness of the EIA report, the adequacy of
the information and analyses contained therein, and the
identification of significant impacts and appropriate
mitigative measures.
COMMENTING
The agency or entity that prepares an EIA document
should circulate for comment copies of the report to other
governmental agencies that have legal jurisdiction, special
expertise, or permitting and administrative responsibilities
for any aspect of the proposed action. Comments should
also be solicited from regional and local authorities,
organizations, and individuals that have requested to review
the EIA document. In the United States, such comments are
solicited upon the issuance of a draft report, thereby
allowing substantive changes to be made at this point in the
EIA process, if necessary.
Comments made by an agency, organization, or
individual on an EIA report should be as specific as possible
and may address either the adequacy of the report or the
merits of the alternatives discussed, or both. Comments that
identify inadequacies should include a description of the
additional information and/or analysis that would remedy
the inadequacy. Any comments or criticisms that are
directed toward the methodology used in the EIA should
include constructive suggestions about alternative
methodologies that might be used. If comments express
OEPA • Principles of Environmental Impact Assessment
Comments should be widely
solicited.
Specific comments are more
constructive than vague
generalities.
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Reviewing and Evaluating EIA Reports
9-2
How do you respond to the
comments?
Review the EIA for;
• Completeness
• Adequacy
• Merit
Completeness review.
Adequacy review.
reservations concerning the level of environmental impacts
resulting from the proposed action, those comments should
include specifics on the mitigation measures that would be
necessary to reduce the impacts to tolerable levels.
The preparer of the draft EIA report should assess and
consider comments both individually and collectively, and should
respond to such comments by 1) modifying one or more of the
various alternatives, including the proposed action, 2)
developing and evaluating alternatives not previously given
serious consideration, 3) supplementing or modifying the
analyses, 4) making factual corrections where errors are
acknowledged, or 5) explaining why certain comments do not
warrant any further responses. The substantive comments and
the written responses to those comments should be attached to
the final EIA report.
INADEQUACIES
A review of an EIA report may be structured to
incorporate three levels of review: 1) a review for completeness
to determine whether the report conforms with regulations
concerning format and content, 2) a review for adequacy to
determine whether the report provides adequate information on
the issues of concern, and 3) a review for merits to determine
whether the action should be approved as proposed.
The review for completeness is principally a baseline
administrative review, examining the EIA report for compliance
with the relevant regulations on format, style, and general
content, identifying deficiencies in these aspects of the EIA
report. If the report fails to pass the review for completeness,
further reviews will be delayed until the report is complete. If
the report passes the completeness review, it can be circulated
for more substantive examination in the review for adequacy.
The review for adequacy is directed toward determining
whether the EIA adequately sets forth the environmental impacts
of the proposed action and of the alternatives reasonably
available to the action. The USEPA adopted three categories
into which a draft EIA report can be classified (USEPA, 198.4);
these are:
• Principles of Environmental Impact Assessment
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Reviewing and Evaluating EIA Reports
9-3
1. Adequate - the draft EIA report adequately sets
forth, the environmental impact(s) of the preferred
alternative and those of the alternatives reasonably
available to the project or action. Nor further
analysis or data collection is necessary, but the
reviewer may suggest the addition of clarifying
language or information.
2. Insufficient Information - the draft EIA report
does not contain sufficient information to assess fully
the environmental impacts that should be avoided in
order to protect the environment, or the reviewer
has identified new and reasonably available
alternatives that are within the spectrum of
alternatives analyzed in the draft EIA report and that
could reduce the environmental impacts of the
proposal. The additional information, data,
analyses, or discussion so identified should be
included in the final EIA report.
3. Inadequate - the draft EIA report does not
adequately assess the potentially significant
environmental impacts of the action, or the reviewer
has identified new, reasonably available alternatives
that are outside the spectrum of alternatives analyzed
in the draft EIA report and that should be analyzed
in order to reduce potentially significant
environmental impacts. The additional information,
data, analyses, or discussions so identified are of
such a magnitude that they should have full public
review at a draft stage. This rating indicates a
determination that the draft EIA does not meet the
purposes of the environmental law, and thus should
be formally revised and made available for public
comment in a supplemental or revised draft EIA
report.
The third level review, the review for merit,
examines whether the draft EIA report has demonstrated
that the action as proposed has identified and avoided,
minimized, or mitigated significant environmental impacts
• Principles of Environmental Impact Assessment
Possible ratings for a review of
the adequacy of an EIA report:
• Adequate
• Insufficient information
• Inadequate
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Reviewing and Evaluating EIA Reports
9-4
Possible ratings for the Merit
review of an EIA report:
• Lack of objections
• Environmental concern
• Environmental
objections
• Environmentally
unsatisfactory
that should be avoided to protect environmental resources. This
is the most substantive level of review, where the review must
determine whether the content of the draft EIA report supports
the alternative preferred in the report's findings and conclusions.
While the reviews for completeness and adequacy essentially
determine whether the report surpasses minimum criteria, the
review for merit examines the accuracy and legitimacy of the
report's findings.
The USEPA assigns one of four ratings to draft EIA
reports (USEPA, 1984):
1. Lack of Objections - the review has not identified
any potential environmental impacts requiring substantive
changes to the preferred alternative. The review may
have disclosed opportunities for the application of
mitigation measures that could be accomplished with
relatively minor changes to the proposed actions.
2. Environmental Concern - the review has identified
environmental impacts that should be avoided in order to
protect fully certain environmental resources. Measures
to correct these concerns might require changes to the
preferred alternative, or the application of mitigation
measures that could reduce the level of environmental
impact.
3. Environmental Objections - the review has
identified significant environmental impacts that should
be avoided in order to protect environmental resources.
Corrective measures could require substantive changes to
the preferred alternative or consideration of some other
action alternative, including the no-action alternative or
a new alternative. The bases for environmental
objections could include circumstances where the action
might violate, or be inconsistent with, achievement or
maintenance of an environmental standard; where the
agency violates its own substantive environmental
requirements relating to jurisdiction or expertise; where
there is a violation of declared policy; where there are no
applicable standards, or where applicable standards will
not be violated, but there remains a potential for
significant environmental degradation that could be
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corrected by modification of the action or other
feasible alternatives; or where proceeding with the
proposed action would set a precedent for future
actions that collectively could result in significant
environmental impacts.
4. Environmentally Unsatisfactory - the review
has identified adverse environmental impacts that are
of sufficient magnitude to cause the agency to
believe that the proposed actions should not proceed
as proposed. The basis for an environmentally
unsatisfactory determination consists of identification
of environmentally objectionable impacts as defined
above, and in one or more of the following
conditions: the potential violation of, or
inconsistency with, an environmental standard is
substantive and/or will occur on a long-term basis;
there are no applicable standards, but the severity,
duration, or geographical scope of the impacts
associated with the proposed action warrant special
attention; or the potential environmental impacts
resulting from the proposed action are of national
importance because of the threat to national
environmental resources or to environmental
policies.
REVISIONS/SUPPLEMENTAL REPORTS
Revisions to the EIA report can be best
accommodated by circulating a complete draft or a
supplemental EIA report for review and comments. The
substantive changes deriving from agency and public
comments can be incorporated into either a complete,
revised final EIA report or can be documented in an
abbreviated final EIA report that incorporates the draft EIA
report by reference.
Where review of an EIA report discloses a topic area
that needs substantial supplementation, either through
further field studies or through further .analysis and
evaluation, the results of those further studies can be issued
SS'EPA • Principles of Environmental Impact Assessment
Supplemental EIA reports may
contain additional field studies
or responses to comments raised
on the draft EIA.
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in a supplemental EIA report that incorporates the main EIA
report by reference. The supplemental EIA report thus
would focus only on the few issues that were inadequately
dealt with in the main EIA report.
THE U.S. SECTION 309 ENVIRONMENTAL
REVIEW PROCESS
Section 309 of the United States' Clean Air Act
requires the EPA to review and comment in writing on the
environmental impact of any matter relating to EPA's duties
and responsibilities pursuant to the act or any other
provisions under the authority of EPA. These review
requirements apply to (1) legislation proposed by a Federal
agency; (2) newly authorized Federal projects for
construction and any major Federal action, or actions, other
than a project for construction; and (3) proposed regulations
published by any department or agency of the Federal
Government.
The objective of EPA's Section 309 Environmental
Review Process is to foster the goals of the NEPA process.
The process ensures that the EPA's environmental expertise,
as expressed in its comments on Federal actions and other
interagency liaison activity, is considered by agency
decision-makers.
EPA uses the 309 Review Process in conjunction
with other statutes (e.g., NEPA and CEQ implementing
regulations) to assist other federal agencies in integrating
sound and cost-effective environmental analysis into their
decision-making. EPA's policy is to identify
environmentally unsatisfactory proposals early in the
planning process, and negotiate with other agencies to
provide technical assistance to federal, state, regional, and
local governmental entities in the EIA process.
Pursuant to this objective, EPA has established
specific policies and detailed procedures for conducting
reviews of Federal actions that affect the quality of the
environment. These policies and procedures for carrying
out the Environmental Review Process assign specific
responsibilities and outline mechanisms for resolving
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problems that might arise in the review process (EPA,
1984). Table 10-1 presents a summary of the important
features of those Section 309 review procedures.
The policies and procedures established by EPA
stress several characteristics of the environmental review
process that are important for its effective functioning.
Among these are:
• The coordination of the environmental review
process among participating agencies at the early
stages of the assessment (e.g., scoping). This
interagency coordination promotes the production
of concise, well-reasoned decision documents that
identify project impacts, a range of project
alternatives, and mitigation measures that will
avoid or eliminate adverse effects on the
environment.
• The thorough understanding of agency policy,
procedures, hierarchy, language, and statutory
responsibilities. The agency's comments
resulting from environmental reviews should be
consolidated into one document consistent with
the agency's policies and regulatory language,
and reflective of the agency's authority and
responsibilities.
• An appreciation of the type and purpose of the
document being reviewed. For example, review
comments on a feasibility report should address
the general issues of project feasibility rather than
design-level specifics.
• The clear identification of whether conclusions
about a document's adequacy reflect mitigation.
A draft EIS might be rated inadequate because
the mitigation measures that are proposed to
minimize adverse impacts are only listed
generally, rather than being presented as firm
commitments with project-specific designs.
Subsequent agency reviews could be more
positive if more specific commitments to
mitigation are agreed upon; the basis for this
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change in the agency's position should have a
well-documented basis in that agency's record of
review comments.
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TABLE 94
GENERAL EIS REVIEW PROCEDURES AND RESPONSIBILITIES
(Eased on Section 309 of the U.S. Clean Air Act)
A. OBJECTIVE: The objective of the Environmental Revie^v Process is to foster the goals of the EIA process by
ensuring that the oversight agency's.environmental expertise, as expressed in its comments on national actions and
other interagency liaison activity, is considered by agency decision-makers.
B. STAFFING AND RESPONSIBILITIES: The Section 309 review process identifies a Review Coordinator, a
Principal Reviewer, and Associate Reviewers. The Review Coordinator is responsible for assuring that the review
is conducted in timely fashion and in compliance with all established procedures, consolidating comments from
other reviewers, and documenting and resolving any disagreements of inconsistencies between reviewers. The
Principal Reviewer is designated by the Review Coordinator to consolidate review comments and prepare a
comment letter. The Associate Reviewer is designated by the Principal Reviewer to provide technical and policy
advice in specific review areas.
C. PRE-EIS REVIEW ACTIVITIES: At this point in the process, the Review Coordinator should take steps to
establish and maintain general liaison with other agencies to assist in early identification of potential project
impacts, alternatives, mitigation measures, and assessment techniques; to participate in scoping meetings to identify
environmental issues, information gaps, reasonable alternatives, and mitigation measures; and to provide review
guidance as a cooperating agency (if the oversight agency is not the lead agency in the environmental review). All
agency responses and correspondence related to these activities should be made part of the official project file.
D. REVIEW OF DRAFT EIS: The Review Coordinator and Principal Reviewer are responsible for establishing
deadlines for receiving comments on the Draft EIS (DEIS); for rating the DEIS for adequacy according to an
established system; for consolidating comments on the DEIS with suggestions for additional information that is
needed (e.g., on mitigation, statutory authorities, alternatives, purpose and need); for distributing review comments
to other agencies; and for documenting all comment letters and correspondence as part of the official project file.
E. POST-DRAFT EIS FOLLOW-UP: The Review Coordinator should initiate consultation with other
participating agencies, particularly if the DEIS receives an "inadequate" rating. The Review Coordinator should
also prepare status reports on the resolution of these inadequacies, and document all consultations in the official
project file.
F. REVIEW OF FINAL EIS: This review should follow the general procedures of "D" above, concentrating on
consideration of the impacts of the project, any unresolved major issues, or additional mitigation measures needed.
If substantial new information is needed, a supplementary EIS may be requested. All comments and
correspondence should be documents in the official project file.
G. MONITORING AND FOLLOW-UP: After transmittal of comments on the Final EIS, the Review Coordinator
and/or Principal Reviewer should ensure that the record of decision incorporates all conditions agreed upon, that
appropriate agencies are informed of the oversight agency's position on the EIS, and that mitigation measures are
carried out. All comments and correspondence should be documented in the official project file.
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NOTES
Principles of Environmental Impact Assessment
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10 BUILDING AN EFFECTIVE EIA PROGRAM
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10. BUILDING AN EFFECTIVE EIA PROGRAM
INTRODUCTION
As countries and governmental subdivisions within
countries create or refine EIA programs, policymakers
should consider some of the major issues that have arisen in
the application of EIA procedures in the United States and
other countries. These basic issues are discussed in terms
of 1) selecting elements for the program, 2) testing the
program, and 3) overseeing the program.
SELECTING THE APPROPRIATE ELEMENTS
As noted several times in this document, the EIA
process is a method for facilitating the decision-making
process on issues that affect the environment. In this
regard, the specific EIA format adopted by any particular
country or region is, in part, a function of that area's
priorities. One can conceive of circumstances where
development and redevelopment is both a necessity and a
priority, while in other cases, development may be
considered less compelling. Whatever the necessity of
development may be, however, the EIA process should be
used to avoid affecting environmental resources more than
is absolutely necessary.
As a fundamental decision-making tool, the overall
purpose of EIA is to facilitate answering a fundamental
question. Should a proposed action be undertaken or not?
The process by which this fundamental question is answered
can be the full and complex EIA process or an abbreviated
adaptation of the full EIA process. Whatever adaptation of
EIA is adopted by a country, region, or local community
should be oriented toward answering this question through
a process open to public participation.
As has been discussed at several points in this text,
the decision of whether or not to undertake a particular
action is generally made at one of three points in the EIA.
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Mitigation is an essential
component and should be
emphasized even if a
streamlined approach is used.
Emergency Procedures
The selectivity of the screening, initial EIA, and EIA stages can
be intensified or relaxed, depending on other economic, politic,
and environmental factors. Relaxing the selectivity of screening
or EIA procedures would allow more actions to proceed without
a full EIA; intensifying such procedures would have the opposite
effect.
When, due to overriding economic or policy concerns, a
decision is made to relax and/or streamline the EIA process, the
mitigation aspect of EIA should be emphasized. Mitigation can
provide a substantial measure of environmental protection, even
when economic or policy circumstances dictate that certain
actions proceed in environmentally sensitive areas. Specifically,
the minimization, rectification, reduction, and compensation
categories of mitigation should be employed to protect or restore
environmental resources where avoidance or the disturbance of
such resources is not the preferred alternative.
In addition, it may be necessary to incorporate
procedures within an EIA program to provide for emergencies.
On occasion, it may be necessary to move forward with an
action that will have significant environmental impacts.
Procedures should be developed to identify notification
requirements, coordination steps, and how actions will be limited
only to those necessary to address immediate impacts.
STREAMLINING THE PROCESS
The experience in the United States with EIAs has
demonstrated that, in some circumstances, the process can
become very lengthy, extending over several years in some
highly-contested projects. The circumstances where this has
been most likely to occur are with 1) projects that are highly
controversial, 2) projects that require extensive site-specific data
collection to complete impact assessments, or 3) projects that
involve the issuance of one or more major environmental
permits. There are several approaches that can be used to
streamline the process to reduce the time between initiation and
completion of an EIA.
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Comprehensive Scoping - the scoping phase of the
EIA process should define clearly the information
needed to make a balanced decision on project
alternatives. Although it is impossible to anticipate
all issues that might arise during the course of an
EIA for any particular project, the general limits of
the work should be resolved during scoping, and a
firm schedule established for conducting the work.
For this reason, the parties participating in the
scoping should be prepared to cooperate to the
fullest extent on generating the scope of work for the
EIA process. For example, the scoping participants
should agree generally on the range of reasonable
alternatives and the type and extent of site-specific
data collection that should be undertaken. If one or
more important wildlife populations show seasonal
variations (e.g., migratory birds or fishes), the
number of seasons of data that will be necessary
should be agreed upon.
Program and Policy EIAs - as noted in Chapter 4,
program and policy EIAs evaluate the environmental
effects of programs or policies that, when
implemented, generate a number of similar projects.
Program and policy EIAs can help to streamline the
EIA process by resolving certain important
environmental issues in advance of specific project
proposals. Program and policy EIAs can define the
purpose and need for certain classes of actions,
compare alternative means of meeting those needs,
outline the spectrum of important environmental
issues that would be relevant within the reasonable
alternatives, and recommend particular patterns of
action. After the program or policy El A-has been
completed, reviewed, and adopted, the EIA process
for specific projects originating under that program
or policy can incorporate by reference the analyses
and findings of the program or policy EIA.
Generic EIAs - these EIAs, like program or policy
EIAs, encompass several possible site-specific
projects that have relevant similarities such as
Principles of Environmental Impact Assessment
Effective scoping aids in
streamlining the EIA process.
By using the EIA process for
programs and policies, certain
environmental issues can be
resolved in advance of specific
project EIAs.
Generic EIAs may contain
reference materials for site
specific EIAs.
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common timing, impacts, alternatives, methods of
implementation, or subject matter. A generic EIA identifies
factors to be evaluated, and methodologies for quantifying those
factors. Moreover, it may present reference materials that are
useful for evaluating the environmental impacts of site-specific
projects.
SELECTING THE INTERDISCIPLINARY TEAM
EIAs are often conducted by interdisciplinary teams of
ecologists, scientists, planners, and engineers to assess existing
conditions and potential environmental impacts. These teams
can be assembled from many sources such as government
agencies, universities, environmental interest groups, and
environmental consultants. The goal is to assemble a team of the
best available technical and scientific experts to evaluate the
environmental impacts of a proposed action and its alternatives,
particularly for those key issues identified in the scoping
process.
When these experts cannot be assembled from within the
organization preparing the EIA, then such expertise can be
sought from other organizations or from a well-qualified,
experienced environmental consultant. Consulting firms may
differ significantly in their capacity to assist in the EIA process.
The following points should be considered in the process of
selecting an environmental consultant:
• Make the Selection Process Competitive - the agency or
organization seeking to retain an environmental
consultant should inform several such consultants of the
services being sought, and solicit proposals from those
several firms. The solicitation in its formal form is often
termed a Request For Proposal or RFP.
• Request Details of the Firm's Qualifications - a firm
proposing to conduct EIA work should be able to
demonstrate that its personnel have the professional
qualifications to conduct EIAs.
• Request Details of the Firm's Experience with Related
EIAs - a firm proposing to conduct EIA work is more
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likely to produce a competent assessment on
schedule if mat firm has substantial prior experience
in such projects. Admittedly, when a new EIA
program is initiated in a country or region, the
number of experienced environmental consultants
may initially be limited, but prior experience is
nonetheless an asset to be evaluated in the selection
process.
• Have the Proposals Include a Detailed Work Plan
- the RFP to prospective consultants should include
a request for a detailed work plan for the specific
project. The work plan should provide a breakdown
of tasks and subtasks, a schedule of these tasks,
estimates of the level of effort needed for each task,
senior personnel that would be responsible for each
task and overall project coordination, and estimated
costs broken down by task and by type of cost (labor
or expense).
• Request a Discussion of the Availability of Key
Personnel - the RFP should ask for the names and
responsibilities of key personnel involved in the
EIA, and should require that the availability of such
personnel over the estimated schedule of the project
be specified.
• Request Information on Requisite Insurance - if
a professional firm is required by law to provide
insurance coverage to its personnel, or provide
professional liability insurance for its professional
work, the prospective consultant should be required
to produce evidence that its various insurance
coverages are adequate and in force or that the firm
has adequate financial resources in lieu of insurance.
The proposal submitted by the environmental
consultant is, if accepted, essentially a contract between the
consultant and the project developer. Thus, the RFP should
elicit written responses for all those items that will become
contract obligations for the consultant. Ambiguous RFPs
and incomplete proposals can lead to delays in the EIA
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process stemming from contractual rather than technical
difficulties.
OVERSIGHT OF THE EIA PROGRAM AND PROCESS
Oversight of the EIA process is necessary to ensure that
the intent of an EIA process is implemented in a fair and
equitable manner. Several processes are included in such
oversight.
• Establishing Uniform Procedural Requirements - One
agency must be relied upon to provide leadership for
establishing the basic procedural requirements and
guidelines for undertaking the basic components of the
EIA process. That agency's primary objective is to
establish ground rules to ensure uniform application of
legal EIA procedural requirements fashioned to minimize
adverse impacts from projects. It should also be
responsible for producing guidance documents, as
needed, to aid responsible parties in carrying out their
duties (e.g., clarifying requirements of the law, or
clarifying how the basic requirements may apply to new
assessment situations, or clarifying the nature and detail
required in a particular assessment).
This lead agency should also be responsible for gathering
information about the conditions and trends in
environmental quality, evaluating the programs of all
responsible parties in light of the goals established in
law, developing and promoting national policies to
improve environmental quality, and conducting studies,
surveys, research programs, and analyses relating to
ecosystems and environmental quality. Each year, an
annual report should be published to inform all
responsible parties and the general public about the status
of various environmental concerns, including the success,
or lack thereof, of the EIA process.
• Responsible Party Adaptation of the EIA Process -
Once established, the EIA process should be applied
uniformly across all program areas. This does not mean
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that the EIA process need be pursued apart from
other planning processes established under individual
program requirements. It only means that EIA's
should be prepared using a common format modified
to include all other project planning information
needed for an agency to reach its final decision. The
format should be such that decisions resulting in
adverse impacts to the environment will clearly
highlight the trade-offs being made between project
benefits and impacts. It should also allow for
presenting how project benefits outweigh impacts or
how other priorities override the environmental
concerns involved.
Independent Review of Projects - When many
entities are involved in an EIA process, there are
bound to be differences of opinion and interpretation
of the significance of impacts, including the
acceptability of permissible changes to elements of
the natural and man-made environment. For this
reason, several countries, including the United
States, have established an independent evaluation
process for all major projects (i.e., projects
determined to have significant impacts). Usually,
the same agency that establishes the basic EIA
guidelines is also charged with the independent
evaluation of major projects. The function of this
reviewing agency is twofold. First, it must review
individual project EIA documentation for adherence
to the minimum set of requirements for EIA,
including public notification and participation in the
process. Second, it must review for acceptability of
the impacts generated, including whether or not the
alternative chosen is the most appropriate in
minimizing adverse impacts to protected
environmental resources. The reviewing agency
should also have the responsibility for maintaining
files, available for public inspection, on all major
projects being evaluated, including brief descriptions
of the proposed action, how well the agency met the
requirements of the law, and how acceptable the
agency's action is in protecting or restoring
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environmental resources. In the United States, the CEQ
originally formulated the EIA requirements and provided an
independent evaluation of major project assessments. The
independent review is now conducted by the USEPA, with a
provision to refer unresolvable decisions to the CEQ.
DATA MANAGEMENT
An automated data management system can be a useful
tool for keeping track of the EIA process. Depending on the
EIA program that is developed, the system can be simple or
complex. If, for example, one agency or government
organization is responsible for the EIA program, then a data
management system could include all stages in the preparation,
writing, and review of the EIA document. On the other hand,
an organization that is responsible for reviewing EIA reports
may develop a data management system to keep track of the
review and comment process. Another advantage of this type of
system is that it can be used to document the decision-making
process, an important factor described in Chapter 6.
There are a number of aspects of the EIA program that
should be considered for inclusion in the automated data
management system, such as:
• Timeframes and responses to the EIA document review
process,
• Key steps in the public participation process,
• Milestones or requirements in the mitigation plan or
record of decision document, or
• Relationship to other permitting or planning activities.
At a minimum, the data management system should keep a
record of the titles of EIAs, and the date of initiation and
completion. In the United States, the USEPA uses a system
called the Environmental Review Tracking System to record and
track the various stages in the formalized EIA document review
process. This centralized system enables the USEPA to record
the principal reviewer of the document, the comments received,
and document the public's access to review comments.
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A data management system for an environmental review
process might comprise, as a minimum, the categories and data
elements on Table 10-1. This would establish a mechanism for
directly and routinely communicating dates and other
information related to EIA filing and review.
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TABLE 10-1
DATA MANAGEMENT
SYSTEM ELEMENTS
Category
Data Element/Code
File/Track EIA Documents
H (Heading). Identifies the time period in
which EIAs were filed with instructions on
receipt and nonreceipt of EIAs.
RF# (Reference Number). Assigned at the time
each EIA is received and used to track the EIA
in the filing system.
DF (Date Filed). Month, day, year the EIA was
received. Also, the date the document preparer
is required to complete distribution of EIA to
reviewers.
T (Title). Identifies the EIA filed.
AN (Amended Notice). Indicates previous EIA,
or if extended, withdrawn or corrected.
Designate by an * and provide an explanation.
Review Process
DD (Due Date). Month, day, year comments
are due to preparer.
PR (Principal Reviewer). Designates office
responsible for EIA review.
Public Access to Review Comments
ND (Note Date). Month, day, year that a
Notice appears advising public of availability of
comments on EIA. ND is also date EIA is
received for the review period. Day one of the
review period.
Publication of Unsatisfactory
Determinations
ND (Note Date). Month, day, year that a notice
appears advising public of unsatisfactory
determinations.
Principles of Environmental Impact Assessment
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ASSESSMENTS FOR SMALL PROJECTS AND
11 CONTAMINATED SITES
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11-1
11. ASSESSMENTS FOR SMALL PROJECTS AND
CONTAMINATED SITES
INTRODUCTION
Special environmental evaluations can be employed
for projects so small that a full, comprehensive EIA
document would not be warranted and for sites that are
being considered for development, sale, transfer, or
acquisition but that are potentially contaminated by
hazardous or toxic substances. These special evaluations are
discussed in the following sections.
SMALL-PROJECT EIAs
Although EIA laws, regulations, and programs of a
particular country are often initially implemented at the
national level, reflecting adoption of a national policy of
environmental protection, the principles of EIA can be
readily applied at the regional and local levels as well. In
the United States for example, many regional and local
governments have adopted EIA requirements that closely
parallel NEPA in format. Small projects can thus be
subjected to EIA requirements at the national, regional, and
local levels. Small projects are normally those having
impacts of small scale and scope and may therefore require
an environmental report that is less comprehensive and
extensive than a full-scale EIA. Such a report can often
take the form of an initial EIA. The use of simplified,
standardized forms are particularly effective for small
projects. In addition, a generic EIA can, in some cases, be
carried out for categories of projects with similar impacts.
Regardless of whether a report is prepared or a
checklist approach is used, an initial EIA should be as
comprehensive and extensive as required for the small
project to fully comply with all the provisions of the EIA
process. The efforts to identify and evaluate alternatives in
many cases can be reduced for small projects. Efforts to
Small project EIAs follow the
EIA framework.
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Small project EIA reports can
be based on checklists or
standardized formats.
avoid and minimize environmental impacts, however, should be
rigorous in all cases.
The proponent of a small project should notify the public
and begin the initial EIA as early in the planning phase as
practical. The person conducting the initial EIA is often separate
from the site engineer, requiring that the site engineer and the
EIA preparer coordinate their activities on the project. The EIA
preparer should examine the conceptual plan as early as possible
and make recommendations, if necessary, for design changes to
protect environmental resources.
The format of the initial EIA report should follow the
format specified in the regulation requiring the EIA process; if
a format is unspecified, the general format shown in Table 11-1
is generally applicable to small projects. The small-project EIA
should contain the following sections:
I. Plan and Description of Development - descriptions
of the preliminary site plan, including roadway access
and internal roadway configurations; local zoning and
land use in the vicinity of the project site; a plan for
water supply; a plan for wastewater disposal; a plan for
stormwater management; and a solid waste plan. These
project details are generally provided to the
environmental consultant by the project engineer, who
must configure the project to conform with local land use
regulations.
II. Inventory of Existing Environmental Conditions -
descriptions of local geology, soils, surface waters,
groundwater, vegetation, wildlife, sensitive
environmental features (wetlands, floodplains, steep
slopes, areas of high water table, areas of hydric soils,
areas with shallow depth to bedrock, areas with
exemplary stands of native vegetation, habitats for
endangered species), air quality, cultural and historic
resources, demography, socioeconomics, and traffic.
Much of the information needed in this inventory section
should be available from regional resource maps (e.g.,
geological mapping, soils mapping), topographic maps,
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11-3
, t f '' "* •"
TABLE 11-1
SEPRES&NT ATJVE SMAH^ROJECT EM REPOK11 FO»!
TABLE OF CONTENTS
EXECUTIVE SUMMARY
I. PLAN AND DESCRIPTION OF DEVELOPMENT
A. General Description and Project Need
B. Water Supply
C. Sewerage Facilities and Wastewater Management
D. Solid Waste Disposal
E. Drainage and Stormwater Management
F. Zoning
II. INVENTORY OF EXISTING ENVIRONMENTAL CONDITIONS . .
A. Air Quality
B. Water Quality
C. Water Supply
D. Hydrology \ . .
E. Geology ;
F. Soils and Properties Thereof
G. Sewerage Systems
H. Topography
I. Slopes
J. Vegetation
K. Wildlife Habitats
L. Aquatic Organisms
M. Critical Environmental Features . .
1. Wetlands
2. Critical Wildlife Habitat .
3. Stands of Mature Natural Vegetation
4. Floodways and Floodplains . . . .
5. Aquifer Recharge Areas
6. Areas of High Water Table
7. Bedrock Outcrops
8. Hydric, Acidic, or Highly Erodible Soils
9. Steep Slopes
10. Subsurface Workings
N. Noise Characteristics and Levels
O. Demography
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XX
; . . . XX
XX
XX
XX
oEPA • Principles of Environmental Impact Assessment
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TABLE 114
REPRESENTATIVE $MALI>R0£ECT E1A REPORT FORMAT
Q. Aesthetics XX
R. History/Archaeology , XX
S. Socioeconomics , XX
III. ASSESSMENT OF ENVIRONMENTAL IMPACTS OF PROJECT XX
A. Air Quality '. XX
B. Water Quality XX
C. Water Supply XX
D. Hydrology XX
E. Geology XX
F. Soils and Properties Thereof . XX
G. Sewerage Systems XX
H. Topography XX
I. Slopes XX
J. Vegetation XX
K. Wildlife Habitats , XX
L. Aquatic Organisms XX
M. Critical Environmental Features XX
1. Wetlands XX
2. Critical Wildlife Habitat XX
3. Stands of Mature Natural Vegetation XX
4. Floodways and Floodplains XX
5. Aquifer Recharge Areas XX
6. Areas of High Water Table , . . . XX
7. Bedrock Outcrops XX
8. Hydric, Acidic, or Highly Erodible Soils XX
9. Steep Slopes XX
10. Subsurface Workings XX
N. Noise Characteristics and Levels XX
O. Demography XX
P. Land Use XX
Q. Aesthetics , XX
R. History/Archaeology XX
S. Socioeconomics XX
IV. LISTING OF ADVERSE ENVIRONMENTAL IMPACTS XX
V. STEPS TO MINIMIZE ENVIRONMENTAL DAMAGE XX
VI. COMPARISON OF ALTERNATIVES XX
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TABLE 114
KEPKEPOTAUVE SMALL-PROJECT HA REPORT FORMAT
VII.
INFRASTRUCTURE XX
A. Sewerage
B. Drainage
C. Solid Waste Disposal
D. Air Pollution
E. Traffic
VIII.
LIST OF LICENSES, PERMITS AND OTHER
APPROVALS REQUIRED
REFERENCES
APPENDICES
XX
XX
XX
XX
XX
XX
Principles of Environmental Impact Assessment
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Small Project EIA Reports
• Plan and Description of
Development
• Inventory of Existing
Environmental
Conditions
• Assessment of
Environmental Impacts
• Listing of Adverse
Impacts
• Comparison of
Alternatives
• Mitigation
• Infrastructure Needs
* Licenses, Permit and
Approvals
regional lists of flora and fauna, and local zoning/land
use/demographic surveys.
III. Assessment of Potential Environmental Impacts of
Project - discussions of potential environmental impacts, both
short-term and long-term, that would result from constructing
the proposed project. The potential impacts should be discussed
in the ordered categories used in the inventory section ('B'
above), and the measures incorporated into the project design to
mitigate these potential impacts should also be discussed. Where
the potential for significant impacts exists, these discussions
should provide reasonably detailed information about the
anticipated level of impact and the measures taken to mitigate
such impacts. Where the potential for significant impacts is low,
the category can be treated in an abbreviated manner. For
example, if a site has a significant area of fioodplain, the EIA
section on impacts should discuss how the project has been
designed to minimize impacts to these sensitive environments; if
a site has no floodplains, a statement to that effect (verifiable
through mapping or modeling) is sufficient.
IV. Listing of Adverse Environmental Impacts - identification
of those environmental attributes that will be affected by the
project even after all mitigation measures are employed. A
development that clears forested land for residential or
commercial buildings clearly changes the character of that land,
reducing the area of forest and increasing the area of developed
land. The area of impervious surface will likely increase, and
stormwater runoff into surface waters will carry higher loadings
of nutrients and contaminants. Water supply demands may cause
groundwater levels to drop perceptibly. These adverse impacts
may result even though the developer has complied with all
pertinent design standards for site development; they are, in this
regard, unavoidable impacts that result from a decision to
proceed with development of a particular property.
V. Steps to Minimize Environmental Damage - discussion of
the various measures used to minimize environmental impacts,
both during construction on the site (short-term impacts) and
during operation of the facility constructed (long-term impacts).
Such measures could include erosion control through use of silt
fences or hay bales, stormwater management
• Principles .of Environmental Impact Assessment
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Assessments for Small Projects and Contaminated Sites
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through detention of surface runoff in basins, and
soil stabilization through mulching and planting of
disturbed areas.
VI. Comparison of Alternatives - identification of
alternative plans considered for site development,
including the no-action alternative. The discussion
of alternatives in a small-project EIA is usually less
extensive than that in a large-scale EIA because, in
a small-scale project, the developer generally has
few or no options in site location.
VII. Infrastructure - identification of the sewage
facilities, water supply, drainage, solid waste
disposal, air pollution, and traffic components of the
small project.
VIII. List of Licenses, Permits, and Other
Approvals Required - a listing of the various
approvals needed from governmental agencies
(local, regional, and possibly national environmental
agencies). The EIA report should, if possible,
describe the permitting authority, the permit needed,
and the status of the permit application.
References - a listing of books, reports, and other
technical references consulted during the preparation
of the EIA report.
Appendices - one or more appendices that contain
materials important to the review of the EIA report,
including pertinent correspondence from permitting
agencies, data reports central to conclusions about
environmental impacts, and materials describing the
qualifications and experience of the preparers of the
EIA report.
The schedule for the completion of a small-project
EIA should be substantially shorter than that for a
large project, taking a few weeks or a month to
prepare if the site engineering has been substantially
completed, the local resource mapping is available,
and numerous site-specific studies are not required.
• Principles of Environmental Impact Assessment
Alternatives are usually fewer
in number for small project
EIAs.
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Assessments for Small Projects and Contaminated Sites
11-8
Small project EIA review
should be based on
completeness, adequacy, and
merit.
The EIA report will be correspondingly shorter, with a typical
small-project report being about 75-100 pages in length.
Many of the smaller governmental units in the United
States (i.e., counties, townships) have cataloged the principal
environmental features within their boundaries in "Natural
Resource Inventories" (NRIs). These NRIs, if available, are
extremely helpful to a small-project EIA preparer. NRIs contain
many of the resource maps and lists from which the existing
environmental characteristics of the project site can be
characterized. NRIs also may provide quantitative data on water
quality, aquifer recharge rates, and air quality, and may specify
guidelines that describe the carrying capacity of the lands
affected by the proposed small project. For example, an NRI
prepared by a particular local government may recommend
certain values to be used when evaluating the safe sustained yield
of local groundwater aquifers, or the minimum land areas (lot
sizes) needed for safe operation of individual septic systems. In
the absence of compelling contrary evidence, the developer and
the developer's small-project EIA preparer should use the
carrying capacity values derived by the local government.
The review of small-project EIA reports is generally
carried out by local commissions, councils, or boards. The
reports should be evaluated on the same criteria as are large-
project EIAs: completeness, adequacy, and merit. Some local
governments have volunteer commissions (variously called
environmental commissions, conservation commissions, or
environmental management councils) that act as independent
reviewers for the local government, reporting comments and
recommendations on EIA reports and projects to the local
decision-making body. Some local governments also retain full-
time planners and/or planning staffs that can provide expert
comment and review at various stages of project designs. Most
local governments or their planning boards hold public hearings
on projects requiring their approval. At these hearings,
developers and the developers' small-project EIA preparers may
offer testimony, and comments are encouraged from citizens of
the community. In general, small projects evaluated at the local
level experience a great deal of public participation and review.
Also, negotiation usually plays a more important role in the
final design of projects at the local
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level, as the aims of the community are expressed through
the public hearing process.
The EIA review may extend to the regional
governmental body, which evaluates the project for
conformance with regional planning goals and regional
environmental standards (e.g., soil erosion, stormwater
management, roadway changes). The Appendix to this
document contains a checklist used by the state of New
York, United States, for use in scoping the environmental
issues that should be addressed in EIAs.
For certain categories of small projects or actions,
criteria have been established at the national, state, and local
levels of environmental regulation to permit such small
actions with a minimum of time and effort in EIA
procedures. Prime examples of this are the nationwide
permits issued by the U.S. Army Corps of Engineers (COE)
for certain projects or actions that disturb wetlands. Under
this system, a nationwide permit is issued covering small
wetland disturbances. Therefore, these small wetland
disturbances (e.g., wetland filling of one acre or less) can
be undertaken without site specific permits. In effect, the
regulatory agency has concluded in advance that such
actions will not generate significant adverse environmental
effects. It should be noted, however, that the COE went
through an EIA process and determined that there were no
significant impacts, (both individually and cumulatively)
from this approach. The only requirement is notifiying the
regulatory agency of the nature of the action and, providing
sufficient information to demonstrate that the action meets
the criteria for the nationwide permit.
These COE nationwide permits, and other small
projects (e.g., construction of small subdivisions, renovation
of existing structures) that have no site specific EIA
requirement, can be considered specific regulatory
exemptions or categorical exclusions. The significance and
timing of such categorical exclusions has been discussed
earlier in Chapter 4.
The checklist approach is useful
for small project EIAs.
Nationwide Permit Procedures.
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What are the differences
between EIAs for small projects
and large projects?
An environmental site
assessment is used to determine
the potential for existing
environmental contamination.
In summary, the EIA process for small projects works
well as a scaled-down version of the full-scale process and
framework described in this chapter for large projects. The
major differences are generally in the level of detail with which
environmental features and potential impacts are assessed, the
magnitude and duration of site-specific studies, the degree of
review given to the EIA report, and the governmental bodies
involved in the decision-making process.
ENVIRONMENTAL SITE ASSESSMENTS
A special type of EIA relates to assessing existing
conditions at a site where a proposed action is planned.
Environmental site assessments, also known as preacquisition
site assessments, are typically conducted to determine if a site is
contaminated by hazardous and/or toxic substances prior to the
development, sale, transfer, or acquisition of the property.
Hazardous substances may include chemicals, manufacturing
wastes, petroleum products, toxins, and so on. The site may
contain such materials because of, among other mechanisms,
past manufacturing activities, illegal "dumping," or subterranean
migration of contaminants through groundwater.
They are sometimes referred to as "Environmental
Audits", but are only a close relative since they do not involve
the traditional audit concept of comparing performance or
observation to pre-established conditions or criteria. These site
assessments may be conducted on behalf of any one of the
parties involved in a property transfer transaction, such as
investment bankers, attorneys, financial institutions, borrowers,
sellers, buyers, or insurers. These parties generally retain
experts to perform the assessments prior to closing a transaction.
The objective of a site assessment is to conduct a
preliminary evaluation of a site or property in order to identify
and assess the magnitude of any existing environmental hazards
and associated risks. Environmental hazards include soil and
groundwater contamination, leaking underground storage tanks,
asbestos, polychlorinated biphenyls (PCBs) and other materials
hazardous to human health and the environment. All properties
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Assessments for Small Projects and Contaminated Sites
11-11
and systems affecting the transaction, including the land,
buildings, plant and equipment, and neighboring properties,
should be evaluated as sources of potential concern. The
audit can also be used to establish baseline conditions prior
to development.
For parties involved in property transactions, the
results of these evaluations may be the difference between
a profitable and a bad investment. In case the audit
indicates no signs of environmental hazards, the transaction
can be closed by the parties with a higher degree of
confidence. If environmental hazards are found, then
corrective actions can be taken to remediate the problem.
Such an approach is likely to minimize health impacts and
save considerable costs in the future. An assessment or
environmental audit can offer liability protection against
unknown risks for an unsuspecting party involved in a
property transaction. The problems caused by
contamination can be very significant and create a
substantial financial risk for the site's owners over the long
term.
Environmental site assessments are typically
conducted in three or four phases depending on the time and
resources available. The scope of work for each phase
depends, in part, on the findings of the preceding phase. In
general the screening phase, or Prephase I, involves an
initial EIA based upon a general knowledge of the current
and past on-site activities. If there is evidence of prior
contamination or a reason to conclude that contamination
may have occurred, the investigation should proceed to
Phase I.
The tasks involved in Phase I of an audit include:
historical records search and review, site inspection and
visual survey, and preparation of a Phase I report. Phase I
activities generally involve a search and review of available
historical records related to manufacturing or disposal
activities, a review of historical aerial photographs, initial
site inspection, and visual survey of current materials
handling practices. The investigation is strictly nonintrusive
in nature and no sampling or analysis is performed on-site.
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Assessments for Small Projects and Contaminated Sites
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Phase n is an in-depth study
that involves Held sampling.
Phase III includes steps to
clean-up the site.
Conclusions of this phase are based upon any documentary
evidence, interviews with personnel knowledgeable about
recommendations for additional phases, and a description of the
limitations of the tasks performed.
If the historical records review and site reconnaissance
either provide evidence of or indicate the potential for
contamination on-site, an intrusive Phase II of the audit should
be performed to determine the nature and extent of
contamination. Phase II is an in-depth study that includes:
surface and subsurface exploration, multi-media sampling and
analysis, and if necessary, geophysical testing.
During Phase II, the actual sampling and analysis of the
various media of concern are performed at the site. The media
of concern that are tested may include soil, groundwater, and
air. Intrusive inspections may also be performed to assess the
potential for contamination in aboveground structures, utilities,
and underground sewer systems. Prior to initiating the Phase II
investigation a detailed work plan is developed that identifies the
specific sampling and analytical procedures that will be used. As
with the Phase I study, the Phase II report documents the
findings and limitations of the investigation.
If the results indicate that hazardous substances are
present at levels that may be dangerous to human health and the
environment, a Phase III investigation may be undertaken to
cleanup, or remediate, the site. This final phase is also known
as the clean-up or corrective action phase.
A typical scope of work under a Phase III investigation
includes:
• Remedial investigation - An in-depth field
investigation to document the nature and extent
of contamination.
• Feasibility study - An investigation of feasible
methods to remediate the site. The study
evaluates the technical and economic feasibility
of alternative clean-up methods. Computer
modeling or pilot testing of treatment
technologies may also be performed.
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Assessments for Small Projects and Contaminated Sites
11-13
• Remedial design - The preparation of
construction drawings and specifications
fbr the selected remedial action.
Figure 11-1 provides a graphical summary of the
various activities usually completed under each of the
assessment phases.
>syEPA • Principles of Environmental Impact Assessment
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Assessments for Small Projects and Contaminated Sites
11-14
O3
O)
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12
LESSONS LEARNED FROM OTHER EIA
PROGRAMS
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Lessons Learned from Other EIA Programs
12-1
12. LESSONS LEARNED FROM OTHER EIA
PROGRAMS
The creation and implementation of an EIA program
in any particular country, region, or local area will almost
certainly go through a period of adjustment, modification,
and refining as the program becomes a standard for project
.review. The experiences of countries that have had EIA
programs in place for several years or more can provide
some useful guidance in initiating a new EIA program. The
following listing of "lessons learned" may be helpful in this
regard. Many of these lessons are drawn directly from a
report prepared by the International Association for Impact
Assessment in 1996 with the Canadian Environmental
Assessment Agency (see Sadler).
• Two trends stand out in the advances made to date in
EIA process development and application. First is the
widespread establishment of EIA systems by many
developing countries and by countries in transition. Second
is the emergence in several industrialized nations of a
second-generating, integrated, strategic EIA process more
closely linked to national planning and decision-making
processes.
Three critical challenges to the contemporary practice of
EIA can be identified:
• sharpening EIA as a tool for sustainability
assurance, so as to provide guidance to the
larger process of decision making'
• ensuring the practical application of the
integrated, second-generation EIA, process,
particularly in the light of public sector
resource constraints and the lack of
consensus regarding sustainability criteria;
and
• quality control into the EIA process to help
bridge the gap between its practice and
potential.
• Principles of Environmental Impact Assessment
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Lessons Learned from Other EIA Programs
12-2
• A review of recent experience world-wide suggests
four necessary ingredients to the effective application of
EIA:
• appropriate timing in initiating the
assessment so that the proposal is reviewed
early enough to scope for development of
reasonable alternatives;
• clear, specific directions in the form of
terms of reference or guidelines covering
priority issues, timelines, and opportunities
for information and input at key decision-
making stages;
• quality information and products fostered by
compliance with procedural guidelines and
use of "good practices"; and
• receptivity of decision makers and
proponents to the results of the
environmental impact assessment, founded
on good communication and accountability.
• Project-level EIA remains a core mechanism for
identifying and mitigating adverse environmental
effects of development proposals. This process
typically addresses issues and impacts that are
complex, controversial and cross-cutting ~
transcending both jurisdictional and disciplinary
boundaries.
Despite the many methodological and administrative
advances in EIA over the past two decades, recent
experience in many countries confirms that there is still
considerable scope for strengthening the process.
Immediate and cost-effective measures could help improve
the process in four key areas: scoping, evaluation of
significance, review of environmental assessment reports,
and monitoring and follow-up.
• When full EIA requirements are adopted, the
number of EIAs conducted peaks soon after the
passage of the statute. In the United States, 1,949
Principles of Environmental Impact Assessment
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Lessons Learned from Other EIA Programs
12-3
EIAs were filed in 1971, the year following adoption of
NEPA. In following years, the numbers dropped
somewhat, with 1,371 in 1972, 1,148 in 1973, and 1,294
(estimated) in 1974 (Canter, 1977). The decline was
seen in all categories of EIAs.
The decline was seen in all categories of EIAs. The
cause of the decline could have been due to experience
gained in screening projects, the waning of the bottleneck
effect caused by a change in regulations, or the
elimination of projects that clearly caused significant
environmental impacts.
The EIA process becomes more efficient of as
environmental agencies gain experience in scoping and
reviewing EIAs, as environmental consultants become
experienced in formatting EIAs to avoid unnecessary
detail, as program and generic EIAs are produced, and
as EIA documents evolve toward incorporating more
material by reference.
Public participation in the EIA process tends to become
more extensive as citizens and citizens' groups become
more familiar with EIA laws and procedures, and as they
become more confident that their participation can affect
the review of proposed actions.
Inadequacies in EIAs tend to occur in certain topics:
analysis of a full range of alternatives, site-specific data,
secondary impacts, and cumulative impacts. In these
areas, the level of specificity is more likely to be
inadequate.
<&EPA
Principles of Environmental Impact Assessment
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13
INFORMATION SOURCES
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Information Sources
13-1
13. INFORMATION SOURCES
The sources listed in this chapter are provided for reference. The EPA documents can be
obtained from EPA via the Internet "www.epa.gov/oeca/ofa.htmr, by fax: 1-202-564-0070, or
by writing to USEPA, Office of Federal Activities, MC-2251-A, 401 M Street SW, Washington
D.C. 20460. Other reference materials can be obtained through publishers and libraries.
EPA Resource Materials: Materials most often requested from U.S. EPA are general publications
on the environmental assessment process, specific publications related to EIA for specific industries,
and information on the U.S. program. We also have responded to requests for Sample EIA's,
Sample EIA preparation contracts, Sample EIA law: NEPA and implementing regulations and
Description of the U.S. program.
Training Materials
• Student Text: Principles of Environmental (Impact) Assessment
• Student Text and Resource Manual: Principles of Environmental Review of
Environmental Impact Assessments (under development)
• CD-ROM with interactive EIA case study, resource materials and key USEPA
guidance documents for reviewers of EIA (under development)
Information on the NEPA and 309 review processes: EPA documents describing EPA's
responsibilities under NEPA and Section 309, and procedures for implementation are of general
interest to the public as they provide for opportunities for public participation. In particular, several
documents help to explain the process used to file Environmental Impact Statements and gain access
to them for public review and comment. These documents are distributed on in response to questions
about the process. Starred documents are currently available on the Internet as well:
- EPA Policy and Procedures for the Review of Federal Actions Impacting the
Environment (1995);
-Facts about the National Environmental Policy Act;
-Guidelines for Environmental Justice considerations in 309 Reviews *;
-EPA Voluntary NEPA Compliance Policy
-National Environmental Policy Act Review Procedures for EPA Facilities (1994)
-Cross-Cutting Environmental Laws: A Guide for Federal/State Project Officers (1991)
'S'EPA • Principles of Environmental Impact Assessment
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Information Sources
13-2
Guidance documents forEIS review/NEPA program implementation: issued principally
for use within U.S. EPA but also of interest to other Federal Agencies and to the public as
they define our expectations for complete and accurate Federal agency compliance with
NEPA.
Habitat Evaluation: Guidance for the Review of Environmental ImpactAssessment Documents
(19931
Grazing on Federal Lands: Background for NEPA Reviewers (1993")
Highway Development: Evaluation of Ecological Impacts (1993)
Guidance Memorandum Incorporating EPA's Pollution Prevention Strategy into the Environmental
Review Process (1993)
Pollution Prevention Environmental Impact Reduction Checklists for NEPA/309
Environmental Impact Assessment Guidelines for New Source Permits/Activity or Economic-Sector Guidance
For:
Fossil Fueled Steam Electric Generating Stations (1994)
Pulp and Paper and Timber Products (1994')
Petroleum Refineries and Coal Gasification Facilities (1994)
Mining (19941
Crude oil and Natural Gas Exploration Development and Production ("19921
Phosphate Fertilizer Manufacturing Facilities (19811
Non-Ferrous Smelters (19791
Leather Tanning & Finishing (19801
Iron & Steel Manufacturing Facilities (19801
Canned and Preserved Seafood Processing Facilities (19811
Mechanical Products Manufacturing Plants (19811
Phosphate Fertilizer Manufacturing Facilities (19811
Rubber Manufacturing Facilities (19811
Explosive Manufacturing Industry (19811
Non-Fertilizer Phosphate Manufacturing (19811
Non-Coal Mine Sites (1991)
General EA Guidance
Environmental Assessment Sourcebook, U.S. EPA (Sep. 1993) Text and Environmental Assessment
Resource Guide, CD-ROM (requires Windows™ V3.1), available Purdue University, The Farm
Building Plan Service, 1146 AGEN Building, West Lafayette, IN 47807-1146 or Dale Luecht, U.S.
EPA Region 5, 77 W. Jackson, S-14J, Chicago, EL 60604-3590: contains the U.S. EA Sourcebook
with selected reference materials from World Bank are included.
• Principles of Environmental Impact Assessment
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13-3
GENERAL REFERENCES
See the World Bank, United Nations Environment Program and U.S. Agency for International
Development (USAID) sources, with particularly excellent resources on women and children and
how to factor in gender differences.
The following technical journals contain information relating to EIA andEIA:
The Environmental Professional (the Official Journal of the National Association of Environmental
Professionals). Published in cooperation with the Department of Life Sciences, University of New
England, Biddeform, Maine, USA.
Environmental Monitoring and Assessment. Kluwer Academic Publishing Group, Dordrect,
Netherlands.
Journal of Environmental Management. Academic Press Limited, London, England.
Journal of Environmental Systems. Baywood Publishing Co., Inc., Amityville, New York, USA.
The following sources -were drawn on in preparation of this text:
AD. Little, Inc. 1971. Transportation and Environment: Synthesis for Action: Impact of National
Environmental Policy Act of 1969 on the Department of Transportation. Vol. I-III, prepared for
Office of the Secretary, Department of Transportation, July 1971.
Bell, D.M., K.A. Abood, R.A. Alevras, and G.R. McVoy. 1985. Analysis of habitat characterisitcs
and fisheries abundance characterisitics in habitat-loss mitigation planning. In: Brodtmann, N.V.,
Jr. (ed.), Second Water Quality and Wetlands Management Conference Proceedings, New Orleans,
LA, Oct. 24-25, 1985.
Burchell, R.W., and D. Listoken. 1975. The Environmental Impact Handbook. Center for Urban
Policy Research, Rutgers-The State University, New Brunswick, New Jersey, USA. 234 pp.
Canter, L.W. 1977. Environmental Impact Assessment. McGraw-Hill Book Company, New York,
New York, USA. 331pp.
Principles of Environmental Impact Assessment
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Environmental Law Institute. 1991. Environmental Impact Assessment: Integrating Environmental
Protection and Development Planning. Working paper prepared under the auspices of the
Environmental Law Institute's Law Drafting Assistance Project for Central and Eastern Europe,
Washington, D.C., USA. 62 pp. + appendices.
Erickson,P.A 1979. Environmental Impact Assessment: Principles and Applications. Academic
Press, New York, New York, USA. 395 pp.
Golden, J., R.P. Ouellette, S. Saari, and P.N. Cheremisinoff. 1979. Environmental Impact Data
Book. Ann Arbor Science Publishers Inc., Ann Arbor, Michigan, USA. 864 pp.
Green, R.H. 1979. Sampling Design and Statistical Methods for Environmental Biologists. Wiley,
New York, NY.
Hammer, D.A. 1989. Constructed Wetlands for Wastewater Treatment. Lewis Publishers, Inc.,
Chelsea, MI, USA. 831 pp.
Hammer, D.A. 1992. Creating Freshwater Wetlands. Lewis Publishers, Inc., Chelsea, Michigan,
USA. 298pp.
Leopold, L.B., E. Clarke, B.B. Hanshaw, and J.B. Balsley. 1971. A Procedure for Evaluating
Environmental Impact. United States Geological Survey Circular 645, United States Geological
Survey, Washington, D.C., USA.
LMS Engineers. A Generic Method for Quantitative Environmental Impact Assessment. LMS
Engineers, New York, USA.
Odum, E.P., et aL 1971. Optimum Pathway Matrix Analysis Approach to the Environmental
Decision-Making Process. Institute of Ecology, University of Georgia, Athens, GA.
Ott, W.R., 1978. Environmental Indices: Theory and Practice. Ann Arbor Science Publishers, Inc.,
Ann Arbor, Michigan, USA. 371 pp.
Pielou, E.G. 1975. Ecological Diversity. John Wiley & Sons, Inc., New York, New York, USA.
162 pp.
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Rau, J.G. and D.C. Wooten. 1980. Environmental Impact Analysis Handbook. McGraw-Hill Book
Company, New York, New York, USA. 615 pp.
Rosen, S.J. 1976. Manual for Environmental Impact Evaluation. Prentice Hall, Inc., Englewood
Cliffs, New Jersey, US A. 192pp.
Sadler, Barry. 1996. Environmental Assessment in a Changing World: Evaluating Practice to
Improve Performance. Canadian Environmental Assessment Agency and the Internaitonal
Association for Impact Assessment. Canada. 248 pp.
Schlessinger, B, and D. Daetz. 1973. A Conceptual Framework for Applying Environmental
Assessment Matrix Techniques. J. Environ. Sci. 16(4): 11-16.
Schlessinger, B., and R.A Huges. 1972. Environmental Assessment of Alternate Shipbuilding Sites.
Bechtel Corporation, San Francisco, CA.
Shannon, C.E., and W. Weaver. 1949. The Mathematical Theory of Communication. Univ. Illinois
Press, Urbana, IL. 177 pp.
BIBLIOGRAPHY OF TECHNICAL REFERENCES
This section contains sources of information for field sampling techniques, impact
analysis methods, and technical references for performing impact assessments in the following
areas: air quality, water quality, biology (aquatic and terrestrial biota), Wetlands, socio-
economics, agricultural land, and archaeological and cultural resources, field sampling
techniques and environmental impact anlayses.
Air Quality
Canter, L.W., "Air Pollution Impacts", Conference Proceedings, Bologna, Italy. 1989-1990.
This paper provides a methodology for the prediction and assessment of changes in
air quality due to project activities.
OEPA • Principles of Environmental Impact Assessment
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Information Sources
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Water Quality
Canter, Larry W., Water Resources Assessment - Methodology and Technology
Sourcebook. Ann Arbor Science Publishers, Inc. 1979.
This document reviews 254 references discussing EIA methods. The majority deal
with water resources assessment.
USEPA. Water Quality Assessment: A Screening Procedure for Toxics and Conventional
Pollutants in Surface and Groundwater - Parts I andII. EPA1600/6-85-002D.
Washington, D.C. United States Goverment Printing Office.
Biology (Aquatic and Terrestrial Biota)
Farmer, Adrian - Division of Ecological Sciences, Habitat Evaluation Procedures (HEP)
ESMJ02. United States Fish and Wildlife Service March, 1980.
This is a habitat-based evaluation methodology that outlines how concepts can be
implemented in a standardized procedure for conducting habitat evaluations in the
field.
Farmer, Adrian - Division of Ecological Sciences, Standards for the Development of
Habitat Suitability Index Models 103ESM. United States Fish and Wildlife Services.
April, 1981.
This document provides guidance and standards for the development of models or the
adaption of existing models to be used in determining Habitat Suitability Indices for
use with the HEP (102ESM).
Margules, C. and M.B. Usher. "Criteria Used in Assessing Wildlife Conservation
Potential: A Review," Biological Conservation. V21. 1981.
This article describes criteria used in assessing wildlife during a site investigation.
Principles of Environmental Impact Assessment
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Information Sources
13-7
USEPA. Risk Assessment Guidance for Super fund Volume II Environmental Evaluation
Manual. EPA 540/1-89/001. Washington, D.C.: United States Government Printing
Office. March 1989.
This document provides guidance for ecological assessment during site
investigations.
Ward, D.V., Biological Environmental Impact Studies - Theory and Methods - Modeling.
Wastewater Research Center, 1978.
This document uses mathematical models classified into four categories to perform
environmental impact studies. The models are used to develop interaction tables and
functional relationships.
Wetlands
Bunker, S. "The Maryland Critical Area Program: A Comprehensive Land Management
Approach." National Wetlands Newsletter 9. No. 1. January/February 1987.
Carpenter, J.M. and G.T. Farmer. Peat Mining: An Initial Assessment of Wetland
Impacts and Measures to Mitigate Adverse Effects. Washington, D.C.: United States
Environmental Protection Agency, 1981.
Kusler, J.A. Our National Wetland Heritage: A Protection Guidebook. Environmental
Law Institute, Washington, B.C. 1983.
Thibodeau, F.R., and B.D. Ostro. "Economic Analysis of Wetland Protection." Journal of
Environmental Management. Vol.12. 1981.
Principles of Environmental Impact Assessment
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Information Sources
13-8
Socio-Economics
Canter, L.W., Prediction and Assessment of Impacts on the Socio-Cultural - Economic
Environment. Conference Proceedings - Bangkok, Thailand. April, 1990.
This document outlines a systematic approach to identifying, quantifying, and
interpreting significance of changes on the socio-cultural - economic environment.
Yain, R.K., L.U. Urban, and G.S. Stacey. Environmental Impact Analysis: A New
Dimension in Decision Making. New York: Van Nostrand Reinhold. 1977.
This document reviews the input-output and economic based models used to perform
economic impact analysis.
United States Agency for International Development: See USAID literature on gender issues
in Environmental Impact Assessment.
United States Army Corps of Engineers, Oregon. Environmental Assessment Manual:
Columbia River and Tributaries. 1974.
This document contains an extensive explanation of economic impact assessment
methods and data sources.
Archaeological and Cultural Resources
King, Thomas F., Patricia Hickman, and Gary Berg, Anthropology in Historic
Preservation. New York: Academic Press, 1977.
This text presents methodologies used when evaluating a site for archaeological and
cultural resources.
Schiffer, Michael and George T. Gumerman, ed., Conservation Archaeology. New
York: Academic Press, 1977.
This text focuses on approaches used for archaeological conservation while
conducting site investigations.
Principles of Environmental Impact Assessment
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Information Sources
13-9
Field Sampling Techniques
Ford, Patrick J., et al, Characterization of Hazardous Waste Sites - A Methods Manual
Volume II Available Sampling Methods. EPA 600/4-89-076. Washington, D.C.: United
States Government Printing Office, December 1989.
This document is a compilation of sampling methods and materials suitable to
address most needs that arise during site investigations.
New Jersey Department of Environmental Protection and Energy, Field Sampling
Procedures Manual. February 1988.
This manual details the scope of field investigation related activities. From sampling
plan preparation through chain of custody procedures, the manual details the
handling requirements and offers a variety of collection techniques for samples of
various matrices.
United States Environmental Protection Agency, Conducting Remedial
Investigations/Feasibility Studies for CERCLA Municipal Landfill Sites. EPA540/P-91/001.
Washington, D.C.: United States Government Printing Office, February.
This document summarizes a field program for collecting data during site
investigations to be used to identify human health risk assessment, exposure
assessment, toxicity evaluation, and ecological risk assessment.
Environmental Impact Analyses
Canter, Larry W., "EIA Methodologies"Conference Proceedings, Bologna, Italy. 1989-1990.
This paper describes various methodologies for evaluating environmental impacts,
particularly those that could be useful in performing an EIS.
Principles of Environmental impact Assessment
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Information Sources
13-10
Environmental Resources, LTD, Methodologies. Scoping and Guidelines. Ministry of
Health and Environmental Protection, March 1981.
This document is a summary of a study conducted on 29 different methodologies. It
provides an overview of the use and purpose of an EIA methodology, and provides
examples of specific types of methodologies.
Shopley, J.B. and R.F. Fuggle, "A Comprehensive Review of Current Environmental
Impact Assessment Methods and Techniques," Journal of Environmental Management
18, No. 1, 1984.
This article identifies, defines, and evaluates a series of EIA approaches.
Vougias, S., "Training for Environmental Impact Assessment". University of
Thessaloniki, Greece.
This paper deals in general -with the methodology and practices for EIA, as well as
with the classification of the various tasks required and all the practical information
on methods and materials.
Warner, Maurice L., and Edward H. Preston, A Review of Environmental Impact Assessment
Methodologies. EPA-600/5-75-002. Washington, D.C.: United States Government Printing
Office, April 1975.
This document summarizes the EIA methodologies that can be used to evaluate
projects.
wEPA • Principles of Environmental Impact Assessment
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14
GLOSSARY
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Glossary
14-1
14. GLOSSARY
ACTION - An action is any policy, program, plan, or project that would affect the
environment.
ACTION ALTERNATIVE - An action alternative is one that would implement a plan,
program, or project, as differentiated from the "no action" alternative.
ADVERSE IMPACT - An adverse impact is an environmental effect that is considered
undesirable.
ALTERNATIVES TO THE PROPOSED ACTION- Alternatives are different means of
meeting the general purpose and need of a proposed action (project or program), including:
- not proceeding with the action
- carrying out the action in a different location or facility
- implementing a non-structural solution
- alternatives within an action, such as different designs or materials, are not usually
considered alternatives
ALTERNATIVES ANALYSIS - The alternatives analysis is the process of screening and
evaluating alternatives.
BENEFIT-COST ANALYSIS - Benefit-cost analysis is a method of comparing alternative
actions according to the relative costs (technical, environmental, and economic) incurred and
the relative benefits gained. The analysis incorporates discounting calculations to take into
account the time value of investments.
BEST MANAGEMENT PRACTICES - Best management practices are those methods or
techniques that effectively accomplish a certain purpose with the least environmental impact.
CONDITIONS OF APPROVAL - Conditions of approval are stipulations (e.g., mitigation
requirements, discharge standards) listed in the decision document, such as a Record of
Decision, that a project must meet for approval and implementation.
CUMULATIVE IMPACTS - Cumulative impacts result from the incremental impact of the
proposed action on a common resource when added to other impacts from past, present, and
reasonably foreseeable future actions. These may include the collective effects of individually
minor actions over a period of time.
DOCKET - The documentation of the EIA process for any given action.
ENDANGERED SPECIES - Endangered species is term for a species of plant or animal that
• Principles of Environmental Impact Assessment
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Glossary
14-2
is in danger of extinction throughout all or a significant portion of its range.
ENVIRONMENTAL IMPACT ASSESSMENT PROCESS - Environmental impact
assessment is the systematic, reproducible, and interdisciplinary consideration of the potential
effects of a proposed action and its reasonable alternatives on the physical, biological, cultural,
and socioeconomic attributes of a particular geographical area. It is a decision making process
designed to help integrate economic, social and environmental concerns and of mitigating the
adverse environmental impacts of activities related to projects, plans, programs or policies.
ENVIRONMENTAL IMPACT ASSESSMENT REPORT - an environmental impact
assessment is the report that documents the Environmental Impact Assessment process for a
particular action or class of actions.
ENVIRONMENTAL REPORT - an environmental report is a generic term for reports other
than Environmental Impact Assessments, initial EIAs, and environmental site audit reports.
ENVIRONMENTAL SITE ASSESSMENT- An environmental site assessment is a
preliminary evaluation of a site or property to identify and assess the magnitude of any
existing environmental hazards and associated risks.
FULL DISCLOSURE - Full disclosure is the maintenance of a complete and open record of
all relevant matters and procedures for any given action.
IMPACT - A change in the environment brought about by implementation of a project or
alternative.
INITIAL ENVIRONMENTAL IMPACT ASSESSMENT - An initial EIA is a report
containing a preliminary evaluation of the types of impacts that would result from an action.
An initial EIA can serve as a stand-alone document or the preliminary step that leads to the
preparation of an EIA.
IRRETRIEVABLE, IRREVERSIBLE IMPACT - An irretrievable, irreversible impact is an
environmental change that will persist for a long period of time and is resistant to remediation.
LEAD AGENCY - A lead agency is an agency responsible for preparing and issuing an EIA
for a proposed governmental action.
LEGISLATIVE EIA - A legislative EIA is an EIA report conducted on prospective legislation
that would affect the environment.
MAN-MADE RESOURCE - Man-made resources are those of historical, archaeological, or
cultural significance.
MITIGATION - Mitigation is the purposeful implementation of decisions or activities that are
Principles of Environmental Impact Assessment
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jCjtgssary
designed to reduce the undesirable impacts of a proposed action on the affected environment.
Mitigation is a general concept that could include 1) avoiding impacts altogether by not taking
a particular action, 2) minimizing impacts by limiting the magnitude of the action, 3) restoring
j'dr" repairing particular features of the affected environment, 4) reducing impacts over time by
performing maintenance activities during the life of the action, and 5) compensating for
impacts by providing additions to or substitutes for the environment affected by the action.
NATIONAL ENVIRONMENTAL POLICY ACT (NEPA) - NEPA is the environmental
assessment statute used in the United States.
NATURAL RESOURCES - Natural resources are features that have ecological, economic,
recreational, educational, or aesthetic value.
NO-ACTION ALTERNATIVE - The no-action alternative is the option of not engaging in
the proposed action, project, or program. It considers the potential long-range outcomes
resulting from no action.
NON-GOVERNMENTAL ORGANIZATION (NGO) - An NGO is a general term for
organizations outside of government agencies such as public organizations and environmental
interest groups.
OVERSIGHT AGENCY - The oversight agency is the governmental agency responsible for
administering the EIA statute.
PIGGYBACKING - Piggybacking is the combining of an EIA report with another project
planning document (e.g., land use plan) to reduce unnecessary paperwork and facilitate
environmental review of a project. The EIA report must, however, stand on its own as an
analytical document.
PREFERRED ALTERNATIVE - The preferred alternative is that alternative that a
particular decision maker believes best meets the purpose and need of the action, project, or
program while keeping environmental impacts to a practicable minimum. Selection often
considers three perspectives:
1) engineering feasibility and requirements
2) economic viability, and
3) environmental soundness
A preferred alternative is usually identified within a draft EIA to put commenters on notice as
to the decision that the decision-maker intends to make at the time public comment is sought to
better direct commenters attention to the analysis in the EIA.
PRIMARY IMPACTS - A primary impact is direct and occurs at the same time and place as
the action. Primary impacts are usually associated with the construction, operation, or
maintenance of a facility or activity, and are generally obvious and quantifiable.
PROPOSED ACTION - A proposed action is a policy, plan, program, or project that is
• Principles of Environmental Impact Assessment
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Glossary
14-4
offered for consideration in the EIA process.
PUBLIC PARTICIPATION - Public participation is the involvement of citizens and citizens
groups in the EIA process for the purpose of balancing any decision between policy makers
and those who are affected by the policy.
PUBLIC MEDIA - The public media (radio, newspapers, television) are the means by which
information is communicated to the citizens of a country, region, or locality.
PURPOSE AND NEED - The purpose and need of a project is the justification for
undertaking the action, and may originate from legislation, administrative decisions, or from
private enterprise. It must be defined before the EIA process can proceed.
RECORD OF DECISION (ROD) - The record of decision is the formal document approving
or disapproving the alternative selected by the EIA process.
REMEDIAL ACTION - Remediation is an activity whose purpose is the restoration of a
degraded environment to prior conditions.
SCOPING - Scoping is the early, open process of considering the issues and choices of
alternatives to be examined in the environmental impact assessment of a particular action,
policy, or program.
SCREENING - The initial screening considers all possible impacts to the action, project, or
program. It identifies whether significant impacts are expected or not.
SECONDARY IMPACTS - Secondary impacts occur later in time, or at a different place
from the initial action. These impacts are indirect or induced changes in the environment,
population, economic growth, and land use.
SIGNIFICANT IMPACT - A significant environmental impact is, in general, an impact that
could alter the properties of a natural or man-made resource in a way judged important by a
set of relative standards.
TIERING - The process of initially addressing a broad, general program, policy, or proposal
in a EIA report, and then analyzing a narrower, site-specific proposal related to the broad
program, plan, or policy in a subsequent EIA report. The purpose of tiering is to eliminate
repetitive discussions and focus on issues ripe for decisions at each level of environmental
review.
TRIGGERING MECHANISM - A triggering mechanism is a means of identify a key
property of an action that would cause that action to be treated in a particular way in the EIA
process.
• Principles of Environmental Impact Assessment
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Glossary
14-5
-raH^^
WORST-CASE ANALYSIS - A consideration, based on reasonable projection, of the worst
possible consequences of a proposed action, and generally understood to bellow * *'*-
probability/catastrophic impact event. The worst case analysis should also include
consideration of a spectrum of events of higher probability but less dramatic impact.
OEPA
Principles of Environmental Impact Assessment
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•* *, i
JStoss&iy-
qoit| B to
XS^EPA • Principles of Environmental Impact Assessment
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15
MODEL EIA CHECKLISTS
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Source: New York State Department of Environmental Conservation 1982 State
Environmental Quality Review Handbook.
Clteekl ist
introduction
The following checklist of topics is intended
as a starting point fee developing a detailed scope
for a project-specific Draft Environmental Impact
Statement. Typically, no one project-will, require a
discussion of all the topic areas contained- in this
document. Through the seeping process, this list ei
topics should be refuted to reflect issues unique to
the proposed project. Topic areas may be-deleted.
added* or elaborated upon, to arrive at the final
scoping.dacument. •
The purpose of the checklist format is to
Identify the baste topic areas for the Draft OS. This-
is accomplished by reviewing the list and placing a
check in .the box located to the left of those topics
which should .be discussed. 'The. model scoping
checklist can also be used as a worksheet, including
comments, suggestions* and identification of the'
particular example^) that are relevant to a detailed
discussion of the topic or issue that has been check*
ed. Conversely, those .topics which are not checked,
are issues not associated with the project, and may
be eliminated from discussion, in the Draft ESS.,
Minimum, requirements for any uraft CIS are
already checked for convenience; '•'..'•
The next step is to expand the list to include
or elaborate on those topics unique to the proposed.
project. A blank sheet is included at the end of the
checklist for such additional .information. •
. -The scoping process involves several steps in
addition to compiling a.list of topics. Scoping also
includes discussions en the quantity and quality of
information required'and the methods for obtaining
thatdatjfc : :
. MOTE: This checklist .was designed to be
used in conjunction with the section on scoping con-
tained in the SECR GuideHne-Qraft and Final £JS*s.
it is also important to emphasize that this checklist
should serve only as a medal to assist in the scoping
of a Draft E2S. It should net be used as a substitute
for actively scoping a Draft E3S for a .specific pro-
ject.
L Cover Sheet
. . All ElS's(Draft or FtnaOshall begin with a cove
sheet-that indicates:
A. Whether it is a draft or final statement
B. Name or other descriptrvsj title of the project
C Location (county and town, village or city) of
••';• the project . •-'*'
. Dv flame and address of the lead agency •which
required preparation of the* statement and
the name and telephone number of a person.
at the agency to be contacted for further, in-
formation : .
'"'£. .Mame and address of the preparers of any
. portion of the statement and a contact name
. and telephone; number .'
F. Date of acceptance of the Draft EfS . ,
G. In the case of a Draft £IS, the deadline date
by which comments.are due should be .in-
dicated
if. Table'of Contents'and Summary . :..
A table of contents and a brief summary are re-
wired for Draft and Final EJS*s exceeding 10 pages
n length. However. • one should, .include these
eatures in any size EJS to provide the review agency
ith easy reference to CIS topics.
: The summary should include: •
.Ai Brief description of the action
8.. Significant,.beneficial .and adverse impacts,
• -.(issues of controversy must be specified)
C Mitigation measures proposed
D. Alternatives considered
E. Matters to be decided (permits, approvals,
funding)
HI. Description of the {Proposed Action
. . Place a check in the Box to the left of those
topics to be included 1n the draft EiS.
D A. PROJECT PURPOSE AMD MEED
. 1. Background and history '• .
^Public heed for the project* and
municipality objectives based on adopted
community development plans
3. Objectives of the project sponsor
-------
b.) identification of present uses and
level of use of groundwater
examples:
—location of existing wells
—public/private water supply
—industrial uses
—agricultural uses
D 2. Surface water
allocation and description of sur-
face waters located on project
site or those that may be in*
ffuenced by the project
examples:
—seasonal variation
—quality
—classification according to
New York State Department of
Health
b.) identification of uses and level of
use of all surface waters
examples:
—public/private water supply
—industrial uses
—agricultural uses
—recreation
c.) description of enisling drainage
areas, patterns and channels
d.) discussion of potential for
flooding, siltation, erosion and
eutrophication of water sources
Q C AJR RESOURCES
O I. Climate
a.) discussion of seasonal variations
and extremes
examples:
—temperature
—humidity
—precipitation
—wind
Q 2. Air quality
a.) description of existing air quality
levels
examples:
—list the National and State Air
Quality Standards for the pro*
ject area and the compliance
status for each standard
b.) identification of existing sources
or pollutants-fixed or mobile
c.) identification of any sensitive
receptors in project area
examples:
—hospitals, schools, nursing
homes, parks
d.) description of existing monitor-
ing program (if applicable)
D D. TERRESTRIAL AMD AQOAT1C ECOLOGY
D 1. Vegetation
a.) list vegetation types on the pro*
ject site and within the surround*
ing area
b.) discussion of site vegetation
•characteristics
examples:
—species present and abundance
—age
—size
—distribution
—dominance
—community types
—unique, rare and endangered
species
—value as habitat for wildlife
—productivity
O 2. Rsh and Wildlife
a.) list of fish and wildlife species on
the project site and within sur-
rounding area, including
migratory and resident species
b.) discussion of fish and wildlife
population characteristics
examples:
—species present and abundance
—distribution
—dominance
—unique, rare and endangered
species
—productivity
D 3. Wetlands
a.) list wetland areas within or con*
tiguous to the project site
b.) discuss wetland characteristics
examples:
—acreage
—vegetative cover
—classification
—benefits of wetland such as
flood and erosion control,
recreation
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D . B. LOCATION
1. Establish, geographic boundaries of the
project (use of regional and local scale
maps is recommended)
2. Description of access to site
3. Description of existing zoning of propos-
ed site.
4. Other:
D C. DESIGM AND LAYOUT
1. Total site area
a.) proposed impervious surface area
(roofs, parking lots, roads)
b.) amount of land to be cleared
cjopen space
2. Structures
a.) gross leaseabte area (GLA), if ap-
plicable
b.) layout pf buildings (attached, enclos-
ed, separate)
c.)site plans and profile views
3. Parking
a.) pavement area
b.) number of spaces and layout
4. Other.
Q D. CONSTRUCTION AND OPERATION
I. Construction
a.) total construction period anticipated
b.) schedule of construction
c.) future potential development, on site
or on adjoining properties
d.) other:
2. Operation
a.) type of operation
b.) schedule of operation
c.) other:
E. CLOSURE AND POST CLOSURE PLANS
(for projects of planned limited life such as
landfills)
13 F. APPROVALS
I. Required changes or variances to the zon-
ing regulations
2. Other permit approval or funding re-
quirements
IV. Environmental Setting
Place a check in the box to the left of those
topics to be included in the Draft EIS.
Natural Resources
D A. GEOLOGY
O 1. Subsurface
a.) composition and thickness of
subsurface material
examples:
—depth to. and nature of, bed-
rock formations and imperme-
able layers
—occurrence of an extractive
mineral resource
—usefulness as construction
material
b.) earthquake potential
Q 2. Surface
a.) list of soil types
b.) discussion of soil characteristics
examples:
—physical properties (indication
of soils hydrological (infiltra-
tion) capabilities)
—engineering properties (soil
bearing capacity)
c.) distribution of soil types at pro-
ject she
d.) suitability for use
examples:
—agriculture
—recreation
—construction
—mining-
is.) other:
Q 3. Topography
a.) description of topography at pro-
ject site
examples:
—slopes
—prominent or unique features
b.) description of topography of sur-
rounding area
H B. WATER RESOURCES
O 1. Groundwater
a.)location and* description of
aquifers and recharge areas
examples:
—depth to water table
—seasonal variation
—quality
—quantity
—flow
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Human Resources
D A. TRANSPORTATION
Q 1. Transportation services
a.) description of the size, capacity
and condition of services
examples:
—roads, canals, railroads,
bridges
—parking facilities
—traffic control
b.) description of current level of use
of services
examples:
—ajn. and p.m. peak hour traffic
'flow '
—vehicle mix
—sources of existing traffic
volume
D 2. Public transportation
a.) description .of the current
availability of service
b.) description of present level of
use
D 3. Pedestrian environment
D 4. Other
O B. LAUD USE AND ZOI1U1C
O 1. Existing land use and zoning
a.) description of the existing land
use of the project site and the
surrounding area
examples:
—commercial
—residential
—agricultural
—business
—retail
—industrial
—vacant
b.) description of the existing zoning
of site and surrounding area
D 2. Land use plans
a.) description of any land use plans
or master plans which include
project site and surrounding area
b.) discussion of future development
trends or pressures
D 3. Otjien
Q C COMMCJMITY SERVICES (for this section in-
elude a list of existing facilities and a discus*
sion of existing levels of usage and pro*
jected future needs)
O 1. Educational faciiilies
O 2. Police protection
Q 3. Fire protection
D 4. Health care facilities
D 5. Social services
O 6. Recreational facilities
O 7. Utilities
O 8. Other:
0. DEMOGRAPHY
Q' 1. Population characteristics
a.) discussion of the existing popula-
tion parameters
examples:
—distribution
—density
—household size and composi-
tion •
b.) discussion of projections for
population growth
D 2. Other
Q £. CULTURAL RESOURCES
Q 1. Visual resources
a.) description of the physical
character of the community
example:
—urban vs. rural
b.) description of natural areas of
significant scenic value
c.) identification of structures of
significant architectural design
O 2. Historic and archaeological
resources
a.) location and description of
historic areas or structures listed
on State or national Register or
designated by the community
b.) identification of sites having
potential significant ar-
chaeological value
-------
Q --3. Hoise
a.) identification of existing level of
noise in the community
b. identification of major source* of
noise
examples:
—airports
—major highways
—industrial/commercial
facili-
ties
Q.4. Othen
V. Significant Environmental Impacts
Identify those aspects of the environmental set-
ting in Section IV that may be adversely or
beneficially affected by the proposed action and re-
quire discussion.
VI. Mitigation Measures to Minimize Environmen-
tal Impact
.Describe measures to reduce or avoid potential
adverse impacts identified in Section V. lite follow-
ing is a brief listing of typical measures used for
some of the major areas of impact.
natural Resources
D A. GEOLOGY
1. Subsurface
a.) use excavated material for land
reclamation
b.)use facility wastes (ash, sludge)
for land reclamation
c.) othen
2. Surface
a.) use tcpsoii stockpiled during
Construction for restoration and.
-landscaping
b.) minimize disturbance of non-
construction sites
c.) design and implement soil ero-
sion control plan
djothen
3. Topography
a.) avoid construction on areas of
steep slope
b.) design adequate soil erosion
•devices to protect areas of steep
slope
c.) othen
.D B. WATER RESOURCES
1. Groundwater
a.) design adequate system of treat
ment for stormwater runoff prior
to recharge of groundwater
b.) maintain permeable areas on the
site
c.) institute a program for monitor-
ing water quality in adjacent
wells
d.) other
2. Surface water
a.) ensure, use of soil erosion control
techniques during construction
and'operation to avoid siltation
.examples:
—hay bales
—temporary restoration of
vegetation to disturbed areas
—landscaping
b.) design adequate stormwater con-
trol system
c.) restrict use of salt or sand for
road and parking area snow
removal
d.) avoid direct discharges to surface
water resources
e.) othen
0 C AIR RESOURCES
1.. Air quality
a.) assure proper construction prac-
tices.
examples:
—fugitive dust control
—proper operation and
maintenance of construction
.equipment
b.) design traffic improvements to
reduce congestion and vehicle
delay
c.) install and ensure the proper
operation of emission control
devices
d.) initiate a program for monitoring
of air quality
e.) othen
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D D, TERRESTRIAL AMD AQUATIC ECOLOGY
1. Vegetation
a.) restrict clearing to only those
areas necessary
b.) preserve part of site as a natural
area
c.) after construction, landscape site
with naturally occurring vegeta-
tion.
d.) purchase open space at another
location and dedicate to local
government or conservation
organization
e.) other
2. Fish and Wildlife
a.) provide adequate habitat (shelter
and food) for remaining wildlife
species
b.) schedule construction to avoid
sensitive periods of fish and
wildlife life cycles
c.) other:
Human Resources
D A. TRANSPORTATION
1. Transportation services
a.) design adequate and safe access
to project site to handle pro*
jected traffic flow
b.) install adequate traffic control
devices.
c.) optimize use of parking areas
d.) encourage car pooling and opera*
tion of facility during non-peak
traffic times
e.) design special routing and
restricted hours for delivery truck
traffic
f.) other:
2. Public transportation
a.) adjust public transportation
routes and schedules to service
the facility
b.) encourage use of public transpcr-
tation by using incentive pro*
grams for employees or by sell*
ing tickets in facility
c.) other:
D B. LAND USE AND ZONING
1. Existing land use and zoning
a.) design project to comply with ex-
isting (and use plans
b.) design functional and visually ap-
pealing facility to set standard
and precedent for future
surrounding land use
c.) other:
Q C. COMMUNITY SERVICES
I. Police protection
a.) minimize local police protection
responsibilities' by providing
private security force
b.) provide security systems, alarms
for facility
c.) provide equipment, funds or ser-
vices directly to the community
d.) other
2. Fire protection
a.) use construction materials that
minimize fire hazards
b.) incorporate sprinkler and alarm
systems into building design
c.) provide equipment, funds or ser-
vices directly to the community
d.) other:
3. Utilities
a.) install utility services
underground
b.) incorporate, water saving fixtures
into facility design
c.) incorporate energy-saving
measures into facility design
d.) other
D D. CULTURAL RESOURCES
1. Visual resources
a.) design exterior of structure to
physically blend with existing
surroundings
b.) minimize visual impact through
thoughtful and innovative design
of lighting and signs (consider
height, size, intensity, glare arid
hours of lighting operation)
c.) design landscaping to be visually
pleasing and to serve as a buffer
between surrounding land uses,
parking areas, operational equip-
ment and facilities
d.) other
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2. Historic and archaeologic resources
a.) allow historical and ar-
chaeological officials access to
the project site during excavation
b.) devote space within project site
to a display of historical and ar-
chaeological artifacts of local in-
terest
c.) preserve architecturally signifi-
cant structures and make a
photographic and statistical
record of those that must be
destroyed
d.) other
3. Noise
a.) schedule construction/operation
to occur during "normal
business" hours minimizing
noise Impact during sensitive
times (early morning, night)
b.) assure adherence to construction
noise standards
c.) design berms and landscaping to
block and absorb noise
d.) other:
VII. Adverse Environmental Effects that Cannot
be Avoided if the Project Is Implemented
.Identify those adverse environmental effects in
Section V that can be expected to occur regardless
of the mitigation measures considered in .Section
VI.
VIII. Alternatives
This section contains categories of alternatives
with examples. Discussion of each alternative
should be at a level sufficient to permit a com-
parative assessment of costs, benefits and en-
vironmental risks for each alternative. It is not ac-
ceptable to make simple assertions .that a particular
alternative is or is not feasible. Identify those
categories of alternatives which should be included
in the E3S by placing a check in the box located to
the left of the topic.
D A. ALTERNATIVE DESIGN AND
TECHNOLOGIES
1. Site layout
a.) density and location of structures
b.) location of access routes, park-
ing and- utility routes
2. Orientation
a.) compatibility with slope and
drainage patterns
b.)site size and setback re-
quirements
3. Technology
a.) pollution control equipment
b.)innoyative vs. proven
technologies
4. Mix of activities
a.) addition of businesses which
would affect the operational
nature of the facility
D B. ALTERNATIVE SITES
1. Limiting factors
a.) availability of land
b.) suitability of alternate site to ac-
comodate design requirements
c.) availability of utilities
d.) suitable market area
e.) compatibility with local zoning
and master plan
f.) compatibility with regional ob-
jectives
g.) accessibility of site to transporta-
tion routes and the service
population
D C ALTERNATIVE SIZE
1. Increase or decrease project size to
minimize possible impacts
2. Increase or decrease project size to
correspond .to- market and com-
munity needs
Q D. ALTERNATIVE CONSTRUCTION/OPERA-
Tion SCHEDULING
1. Commence construction at a dif-
ferent time
2. Phase construction/operation
3. Restrict construction/operation
work schedule
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D E. ALTERNATIVE LAND USE
1.. Suitability of site for other uses
a.) other types of commercial uses
b.) other types of industry
c.) different types of housing
d.) other:
2. Public vs. private use
D F. MO ACTION .
1. Impacts of no action
a.) effect on public need
b.) effect on private developers'need
c.) beneficial or adverse, en-
vironmental impacts
D G. OTHER:
IX. Irreversible and Irretrievable Commitment of
Resources ,' • ; . •
Identify those natural and human resources listed
in Section IV that wilt be consumed, converted or
made unavailable for future use.
X. Growth Inducing Aspects
Describe in this section the potential growth
aspects the proposed project may have. Listed
below are examples of topics that are typically af-
fected by the growth induced by a project.
D A. POPULATION
1. Increases in business and 'resident
population due to the creation or
relocation of business
2. Increases in resident population due
to the construction of housing
D B. SUPPORT FACILITIES
•1. • Businesses created to serve the in-
creased population
2. Service industries created to supply
new facility
D C. DEVELOPMENT POTENTIAL
I. Introduction or improvement of in-
frastructure (roads, waste disposal.
sewers, water) to service proposed
project ' . •
2. Creation of further growth potential
by construction of improved in-
frastructure
D D. OTHER:
XI. Effects on the Use and Conservation of Energy
Resources
Identify the energy sources to be used, an-
ticipated levels of consumption and ways to reduce
energy consumption. The examples listed below are
typical issues to be considered when addressing this
topic.
Q A. PROPOSED ENERGY SOURCES AND
ALTERNATIVES
D B. ANTICIPATED SHORT-TERM/LONG-TERM
LEVELS OF ENERGY CONSUMPTION
D C. INDIRECT EFFECTS ON ENERGY CON-
SUMPTION
1. Increased dependence on
automobile use
2. Increased levels of traffic due to pro-
posed project
D D. ENERGY CONSERVATION MEASURES
1. Design methods to reduce fuel use
for heating, cooling, and lighting
a.) conventional technology
examples:
. —insulation
—thermopane windows
—use of low wattage lights
b.) innovative technology
examples:
—heat pumps
—solar panels
—wind energy
—use of waste heat from an in-
dustrial plant
c.) efficient layout
examples:
—orientation of structures in
relation to summer and winter
sunlight
—clustering of structures to
maximize common walls
—shortening of utility runs
—shared insulation and heating
2. Indirect energy benefits
a.) location and design of facility to
accomodate mass transit
b.) use of shuttle buses
c.) location of facility 'to minimize
- travel distance
D E. OTHER:
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XII. Appendices
Following is a list of materials typically used in
support of the EiS.
A. List of underlying studies, reports and infor
(nation considered and relied on in preparing state-
ment
, B. List all .federal, state, regional, or local agen
cies. organizations, consultants and private persons
| consulted in preparing the statement
C Technical exhibits (if any) at a legible scale
O. Relevant correspondence regarding the pro-
1 jects may be included (required in the Final EIS)
Additional Draft EIS Scoping Topics
| Indicate any additional topics for discussion in the
Draft EiS. Attach additional sheets if necessary.
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