3/S-/3
STUDENT TEXT FOR
PRINCIPLES OF ENVIRONMENTAL
IMPACT ASSESSMENT REVIEW
                July 1998
U.S. Environmental Protection Agency
Office of Federal Activities (MC 2251-A)
401 M Street, S.W.
Washington, D.C. 20460

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                       DEDICATION TO REVIEWERS
              To reviewers of proposed projects, policies, or programs.

     Who facilitate informed decision-making and follow up to help ensure that all
  opportunities for avoiding, minimizing, preventing, eliminating, reducing, restoring,
   and/or compensating for adverse environmental and socioeconomic impacts and
                     enhancing the environment are pursued.

    Who take steps to affect environmental impact assessment documents to provide
 information -which is complete, accurate, and to identify the significant environmental,
                           social and economic issues.

Who take steps to maintain the integrity of the environmental impact assessment process
by ensuring that the requirements of the environmental impact assessment process have
been met, and that the perspectives of affected stakeholders and interested parties have
                                been considered.

     Who bring to their jobs professionalism, objectivity, and a focused, systematic,
  interdisciplinary approach despite the strongly held views of those involved with the
                           project, policy or program.

  Who are resourceful in drawing upon multiple sources of information and disciplines
including knowing how to find relevant documents, networks of experts, and background
              information on the affected communities and environment.
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   Principles of Environmental Impact Assessment Review
                                ACKNOWLEDGMENTS

       This stand-alone text "Principles of Environmental Impact Assessment Review" and the
 associated Resource Manual and Facilitator's Manual constitute the materials for the international
 training course: "Principles of Environmental Impact Assessment Review".  We would like to
 acknowledge the many individuals who contributed to the evolution and unique focus of this material.

       First, we would like to acknowledge government officials in Mexico and Brazil who identified
 the need for further training to complement USEPA's first international course on "The Principles of
 Environmental Impact Assessment." They motivated the development of a sequel course by USEPA
 which in working with them has evolved from a potential course on "tools and techniques of
 environmental impact assessment" to its present form offering a unique perspective and previously
 unmet need to address "reviewers" of environmental impact assessment.  The comments of Mexican
 officials who participated in a pilot in Monterey, Mexico in September of 1996 helped to further direct
 the course to utilize actual environmental impact assessments as the basis for the course and to enhance
 the technical content of the material. The course will continue to be enriched over time as we strive
 together to best meet the needs of colleagues around the globe.

       We want to particularly acknowledge the contributions of Hector Pena of USEPA Region VI
 and Ed Yates, then of Region IX who facilitated the first pilot delivery in Monterey Mexico along with
 Mexican colleagues and who made key suggestions for improving the  course.  John Gerba and Arthur
 Totten in the Headquarters Office of Federal Activities served as project managers for this first phase of
 the course's development. Early work was funded by US AID through Pat Koshel and Cam Hill Macon
 of USEPA's Office of International Activities.

       Second, we acknowledge the team of experienced USEPA reviewers who spent many hours
 identifying the approaches they took to the job of the "reviewer," identifying what might be good "case
 studies", and serving as "guinea pigs" for two successive pilots of further course developments.
 Special thanks to the insightful comments of Patience Whitten, Tim Timmermann of Region I; Marie
 Tenet of Region II; Francesca di Cosmo, Danielle Algazi, and Regina Poeske of Region III; John
 Hamilton and Ernesto Perez of Region IV; Mike MacMullen and Chris Christienson of Region V;
 Hector Pena of Region VI; Dewayne Knott and Cathie Tortorici of Region VII; David Schaller, Cindy
 Cody, Steve Moores, Alicia Aalto, and Wes Wilson of Region VIII; David Mowday of Region IX; Joan
 Cabreza, Wayne Elson, and Rene Fuentes of Region X; Anne Miller, Deputy Director of Headquarters
 Office of Federal Activities (OF A),  Jim Serfis, of the NEPA Compliance  Division in OFA for his
 instructive suggestions on categorization of biological resources, Cheryl Wasserman Associate Director,
Headquarters OFA; and Gene Kersey, formerly of EPA Region VIII and now of the U.S. Department of
Agriculture.

       A note of thanks to Steven Moores whose imaginative illustrations during the August  1997 pilot
inspired the use of logos for the "roadmaps" and "tools and techniques" guides throughout the course,
                                             n
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   Principles of Environmental Impact Assessment Review
to Gene Kersey for providing the electronic versions of the logos and to Ron Slotkin who helped
develop the electronic version of my rendition of a road map to embellish a packaged "logo" for use in
the course.  Many thanks also to Ron Slotkin who helped develop the final graphic depiction of the EIA
process flowchart out of my early prototypes.

       Third, a special note of thanks to Arthur Totten who put together the accompanying Resource
Manual based upon the USEPA Sourcebook for environmental impact assessment and various USEPA
and World Bank guidance documents.  The Sourcebook, prepared in 1993, was the result of a contract
between the EPA Office of Federal Activities and Oak Ridge National Laboratory's Environmental
Sciences Division. Its development was overseen by a panel of worldwide experts representing most
aspects of environmental assessment. It contains a compilation of articles and collective experience in
the preparation of environmental  impact assessments.

       The interactive CD-ROM which is disseminated to participants as part of this training builds on
the sourcebook materials and original "Principles of Environmental Impact Assessment training course."
It was put together by a team from US EPA Region V and Purdue University using an actual case
example in Alaska to bring the materials to life.  We acknowledge this important contribution by Dale
Luecht, Robert Beltrain, Mike Bland and Alfred Krausse of USEPA Region V.

       The "Principles of Environmental Impact Assessment Review" text, Resource Manual and
Facilitator's Manual for the associated  training course was developed under the technical direction and
co-authorship of Cheryl Wasserman, Associate Director for Policy Analysis in USEPA's Office of
Federal Activities, Office of Enforcement and Compliance Assurance with the assistance of Science
Applications International Corporation (SAIC) Project Manager Kathleen Harrigan along with Kenneth
Pruitt, Gregg Mallon, Takisha Cannon under contract number 68-W7-0050 and technical  materials
developed by Susan Moore, Andrew Warner, and Kellie DuBay of SAIC under prior contract, 68-W2-
0026.

       Finally, I would like to acknowledge the commitment of William Dickerson, Director of the
Office of NEPA Compliance Division for continued support for the course development as testament to
our commitment  to those who have environmental impact assessment review jobs both within the
United States and around the world.
                           Cheryl Wasserman
                           USEPA, Manager for Domestic and International Capacity Building in
                           Environmental Impact Assessment
                                             in
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Principles of Environmental Impact Assessment Review
                                      IV
July 1998

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Principles of Environmental Impact Assessment Review
                            TABLE OF CONTENTS
DEDICATION TO REVIEWERS	 • • • • •	l

ACKNOWLEDGMENTS	fi

PREFACE	ix

1.     INTRODUCTION	 M

2.     THE ENVIRONMENTAL IMPACT ASSESSMENT PROCESS	2-1
       2.1    Decision to Proceed with Environmental Impact Assessment 	2-3
       2.2    Draft Environmental Impact Assessment Document	2-4
             2.2.1  Scoping to Identify Significant Issues 	2-4
             2.2.2  Documenting Purpose and Need	2-5
             2.2.3  Development of Alternatives	2-5
             2.2.4  Description of the Environmental Setting  	2-6
             2.2.5  Assessment of the Impacts of Alternatives	2-6
             2.2.6  Identification of Mitigation Approaches  	2-6
             2.2.7  Identification of the Preferred Alternative	2-7
             2.2.8  Review of the Draft Environmental Impact Assessment  	2-8
       2.3    Final Environmental Impact Assessment	2-8
       2.4    Decision-Making  	2-8
       2.5    Mitigation Plan	2'8
       2.6    Record of Decision	2-9
       2.7    Project Implementation	2-9
       2.8    Post-Decision Monitoring and Follow-up	2-9

 3.     REVIEWER'S ROLES AND RESPONSIBILITIES IN THE ENVIRONMENTAL
       IMPACT ASSESSMENT PROCESS  	3-1
       3.1    Introduction	3-1
       3.2    The Role of the Reviewer	3-1
             3.2.1   Reviewer as a Facilitator of the Environmental Impact Assessment
                    Decision-making Process 	3-1
             3.2.2  Different Contexts for the Reviewer's Role	3-4
             3.2.3  The Reviewer's Focus	•	3-7
             3.2.4  Four Types of Review Situations	3-8
       3.3    Reviewers and Review Teams	3-10
             3.3.1   Characteristics of a Good Reviewer	  3-10
             3.3.2   Expertise	  3"n
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 Principles of Environmental Impact Assessment Review
              3.3.3   Review Teams	  3_12
              3.3.4   Technical Experts	   3_13
              3.3.5   Preparation for the Reviewer Role in General	 3-13
       3.4    Reviewer's Role in Each Element of the Environmental Impact Assessment
              Process	3_14
              3.4.1   Decision to Proceed Activities:  Deciding Whether a Proposed
                     Project is Subject to Environmental Impact Assessment
                     Requirements  	     3-14
              3.4.2   Draft Environmental Impact Assessment Documents	3-16
                     3.4.2.1        Scoping: Environmental Impact Assessment
                                  Document Development	3-17
                     3.4.2.2        Involving Stakeholders and Other Interested Parties . . 3-20
                     3.4.2.3        Preparing Comments in the Draft EIA Roadmap  ....3-20
              3.4.3   Final Environmental Impact Assessment Documents	3-23
              3.4.4   The Role of the Reviewer in Decision-making	3-25
                     3.4.4.1        The Record of Decision	3-27
              3.4.5   The Role of the Reviewer in Post-Decision Monitoring
                     and Follow-up	3_29
       3.5     Communicating the Findings of the Review 	3_29
       3.6     Overcoming Obstacles to Effective Environmental Impact Assessment
              Reviews	            3_32

4. EVALUATION OF AN ENVIRONMENTAL IMPACT ASSESSMENT DOCUMENT  . 4-1
       4.1     Approaches to Review: Reading an Environmental Impact Assessment:
              What to Look for	4_j
       4.2    Purpose and Need  	     4.4
             4.2.1   Review of Purpose and Need  	   4.5
             4.2.2  Purpose  and Need Review Road Map	4-6
       4.3    Project Alternatives  	       4.7
             4.3.1   Review of Project Alternatives	4_g
       4.4    Description of the Environmental Setting	4_10
             4.4.1   Existing Physical-Chemical Environment	4-12
                    4.4.1.1        Air Resources 	4_12
                    4.4.1.2        Water Resources	4_14
                    4.4.1.3        Soils and Geology	4_16
             4.4.2  Existing Biological Conditions 	4_18
                   4.4.2.1       Wildlife and Vegetation	'.'.'.'.'.'.'.'.  4-19
                   4.4.2.2       Community and Habitat  Characterization .	4-22
                   4.4.2.3       Ecologically Significant Features  	4-24
             4.4.3  Waste Management and Pollution Prevention	4-27
             4.4.4  Socioeconomic Environment	4_2g
                   4.4.4.1       Land Use	4_29
                                         VI
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Principles of Environmental Impact Assessment Review
                    4.4.4.2       Population and Housing	4-29
                    4.4.4.3       Economic Activity . . .	4-30
                    4.4.4.4       Community Services and Public Finance	4-31
                    4.4.4.5       Transportation	4-32
                    4.4.4.6       Health and Safety	4-32
              4.4.5  Cultural Resources	4-33
              4.4.6  Reviewing the Description of the Environmental Setting Road Map  .4-34
       4.5    Potential Environmental Impacts .	4-35
              4.5.1  Methods of Analysis	4-37
                    4.5.1.1       Determination of Significance  	4-38
                    4.5.1.2       Cumulative Impacts	4-39
              4.5.2  Pollutant Generation, Transport, and Receptors	4-40
                    4.5.2.1       Air Resources 		4-40
                    4.5.2.2       Water Resources	4-42
                    4.5.2.3       Geological Resources	4-45
                    4.5.2.4       Biological Resources	4-46
              4.5.3  Habitat Alteration	4-46
                    4.5.3.1       Biological Resources	4-47
              4.5.4  Waste Management and Pollution Prevention	4-52
              4.5.5  Socioeconomic Impacts  	4-53
                    4.5.5.1       Land Use	4-54
                    4.5.5.2       Economic Activity	4-57
                    4.5.5.3       Population and Housing	 4-58
                    4.5.5.4       Community Services and Public Finance	4-59
                    4.5.5.5       Transportation	4-61
                    4.5.5.6       Health and Safety	4-62
                    4.5.5.7       Environmental Equity 	4-63
              4.5.6  Cultural Resources	4-63
              4.5.7  Assessment of Potential Environmental Impacts of Alternatives
                    and of Their Significance Road Map	4-64
       4.6    Mitigation and Monitoring Measures	4-68
              4.6.1  Hierarchy of Mitigation Measures	4-68
              4.6.2   Scope of Proposed Mitigation	4-69
              4.6.3   Review of Mitigation and Monitoring Measures Road Map	4-71
       4.7    Tools and Techniques for Environmental Impact Review 	4-73
                                           VII
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Principles of Environmental Impact Assessment Review
                      TABLE OF APPENDICES
APPENDIX A:   ENVIRONMENTAL IMPACT ASSESSMENT EVALUATION
             CHECKLIST	
     A-l
APPENDIX B:   ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGIES . . B-l

APPENDIX C-l:  ENVIRONMENTAL IMPACT ASSESSMENT TERM DEFINITIONS . C-l

APPENDIX C-2:  IDENTIFYING SIGNIFICANT ISSUES - EXAMPLES  	C-2

APPENDDC D:   CONTENTS OF SPECIFIC ENVIRONMENTAL IMPACT
             ASSESSMENT TOOLS	D-l

APPENDIXE:   ROAD MAPS 	E-l
                               Vlll
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Principles of Environmental Impact Assessment Review
                                      PREFACE

Reviewers of Environmental Impact Assessments (EIAs) play an essential role in helping EIA
analysis and documentation, as well as the entire EIA process, achieve its goals ~ enabling
decision makers to better integrate environmental, economic and social concerns for proposed
actions. Despite the importance of the function of the independent reviewer in this process, there
is little in the literature about approaches to the job or about how to do the job well. Most courses
and text material on EIA are geared to preparation of environmental impact assessments.  There is
a presumption that review of EIA is just the mirror image.  In developing this course we have
found that this is not the case.  We have canvassed experienced reviewers throughout the U.S.
with over 25 years of experience to develop some basic principles which would be applicable in
any setting.

The need for this text and course for reviewers actually grew out of USEPA's experience
delivering its predecessor course on the Principles of Environmental Impact Assessment.
The Principles of Environmental Impact Assessment vt&s one of the early environmental
management courses developed by the Agency for international use.  The "Principles" course was
developed in consultation with government officials and development banks around the world at
the request of environmental agencies in Central and Eastern Europe who were concerned about
the devastating effects of industrial operations on the environment and human health.  These
agencies were interested in preventing new environmental problems and strengthening public
participation in the environmental impact  assessment process. Since its delivery in Europe, the
Principles of Environmental Impact Assessment training course has been successfully delivered in
dozens of countries around the world and translated into many languages.

The Principles of Environmental Impact Assessment course is designed around well-established
international frameworks for environmental impact assessment.  In the course, participants are
encouraged to think about the reasons behind different elements of environmental impact
assessment. By allowing participants to reason and derive certain parts of the environmental
impact assessment process on their own, citizens, members of academic institutions, and policy-
makers complete the course with a deeper appreciation for the elements of environmental  impact
assessment.

Participants in Mexico and Brazil specifically requested more training on tools and methods for
conducting and preparing an actual environmental impact assessment. In response, EPA began to
develop such a course, but quickly realized that a one-week course was insufficient to make the
participants experts in subjects such as marine biology, air pollution and monitoring, or
environmental engineering.  Environmental impact assessment is interdisciplinary, and each
individual discipline can require lengthy course work and years of experience to master. Even if it
were possible to fit much of the  relevant technical information into a week-long course, EPA
decided that making the course too technical would miss other important needs of the
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 Principles of Environmental Impact Assessment Review
 participants, who wanted to do a better job of reviewing EIAs.

 This led EPA to focus instead on the special needs of the environmental impact assessment
 reviewer. Without being experts in all of the various disciplines, reviewers must be able to ask the
 right questions about the environmental impact assessment document and of the experts chosen to
 prepare it.  The reviewer should be able to pull together information from the various disciplines
 in a way that will aid decision-makers in the environmental impact assessment process. Most
 countries have adopted requirements for the EIA process to better plan for and avoid adverse and
 costly environmental impacts and, through status review and systematic assessment, to identify
 alternatives that may better mitigate environmental and social impacts.

 This text, as well as the course, presents technical information and review guidance at a sufficient
 level of detail to instruct individuals who review environmental impact assessment documents and
 who may not be experts in all fields.  The text emphasizes the process of environmental impact
 assessment review, as well as the substance that a reviewer can expect to find in environmental
 impact assessment documents.

 The text discusses the topics of how to be an effective reviewer in different review situations, and
 in different personal, legal, and institutional contexts. It presents "road maps" for the review of
 each part of an environmental impact assessment document.  It also  discusses tools and
 techniques available for the development of an environmental impact assessment and for the
 review of the document. Finally, another important part of this text and the course is helping
 reviewers discover what can go right and what can go wrong in the review process.

This text is one of several resource and training materials  developed by USEPA to build capacity
for effective EIA. It can be used as a stand-alone resource; it is also designed to accompany the
course Principles of Environmental Impact Assessment Review along -with a resource manual,
CD-ROMs and example EIAs.
                                                                              July 1998

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                                           Chapter 1 — Introduction to Guidance
               TABLE OF CONTENTS






1. INTRODUCTION	 1-1
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                                                         Chapter 1 — Introduction to Guidance
                       1.  INTRODUCTION

This text is designed to provide practical guidance to professionals who
expect to be involved in the review and evaluation of environmental
impact assessments. It is geared toward professionals who have a
working or academic background in environmental protection issues,
sciences or policies, but who may or may not have previous experience
reviewing and commenting on the results of environmental impact
assessments produced by others.  This text has been developed as a
companion to a four-day course on review of environmental impact
assessments (Principles of Environmental Impact Assessment Review).
It is meant to be applicable to a range of legal, institutional, and cultural
settings, and for use by reviewers in any country where environmental
impact assessments are conducted.

Generic terms are used in this text. The general term "environmental
impact assessment" refers to both a decision-making process and
document to assist in making informed decisions to better integrate
economic, environmental  and social concerns. It involves assessing the
environmental impact, broadly defined, of a proposed project or action
and its reasonable and feasible alternatives. The same process can also
apply to the evaluation of a proposed environmental program or policy.
The environmental impact assessment process starts with a decision
whether to proceed with the environmental impact assessment process.
This decision is based upon requirements of law and policy and other
criteria and usually involves some initial environmental impact
assessment to assess the potential for significant impact.  If the initial
environmental impact assessment review indicates that the threshold for
significant potential impacts has not been crossed, the results should be
summarized and documented and the proposed project allowed to
proceed to the implementation phase.  If the initial process identifies
significant potential impacts, a full environmental impact assessment
process is carried through and an environmental impact assessment
document must be prepared. National laws, policies, procedures and/or
criteria differ as to types of activities or impacts that are considered to be
significant for this purpose.

In accordance with internationally accepted principles, a draft
environmental impact assessment document presents the results of
assessments of the potential impacts of a proposed project and its
reasonable and feasible alternatives (project or other) on the natural and
human environments.  It should do so in a way that fosters better
informed decision-making by project proponents as well as by
government and the general public. Alternatives are simply different
approaches to the proposed project for achieving the same purpose and
need, or objectives, of the proposed project. An environmental impact
assessment document establishes a baseline description of the
environmental setting in which the proposed project is to be located, and
assesses the potential impacts of alternatives, including a no-action
•  Environmental Impact
   Assessment is both a
   document and a process.

•  EIA is usually required
   selectively where the process
   can have the most impact.
   — If no significant potential
     impacts are identified
     through the initial
     environmental impact
     assessment, most countries
     allow the project to
     proceed without formal
     EIA.
   - If significant potential
     impacts are identified by
     the initial EIA or the
     proposed action, covered
     by law or policy, is
     sufficient to trigger the EIA
     process, then an
     environmental impact
     assessment document is
     usually required.
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Chapter 1 - Introduction to Guidance
alternative, on that baseline.  This is done to compare and contrast the
beneficial and adverse impacts among alternatives in order to identify the
preferred alternative(s).  Depending on the characteristics and scale of a
proposed project, an environmental impact assessment may include
studies of the weather, vegetation and wildlife, seismic activity, human
health, employment and urban migration. In essence an environmental
impact assessment covers physical, biological, social, economic, and
cultural resources.

The environmental impact assessment process also includes stakeholder
views to solicit all relevant perspectives on the assessment of impacts
and consideration of alternatives.

Review of the environmental impact assessment document is conducted
by trained professionals independent of those who prepared the original
document. The purpose of an independent review process is to prepare
an unbiased evaluation of:  1) completeness and adequacy of the
environmental impact assessment document; 2) adherence to required
procedures for analysis, format, and stakeholder involvement; and 3)
environmental acceptability or conditions for environmental acceptance
of a preferred alternative, as well as to identify whether or not the
implementation of any other alternative—included or not included in the
document—would be more environmentally preferred than the one
selected by the project proponent or those responsible for preparing the
environmental impact assessment document.

This text is based upon internationally accepted frameworks and
principles of environmental impact assessment. Nevertheless,
environmental impact assessment processes and documents are different
in various countries. In the United States, for example, the
environmental impact assessment documents the environmental,
physical, social, and economic impacts of the proposed project and
project alternatives so decisions are based on a complete understanding
of their ramifications,  hi some other countries, the environmental impact
assessment covers only a single alternative.  Similarly, countries differ
widely in their requirements for stakeholder involvement. Some provide,
while others do not provide, the opportunity for public participation.

The remainder of this text is comprised of three chapters and five
appendices which focus on the environmental impact assessment process
and environmental impact assessment documents:
        The environmental impact assessment process
        The reviewer's responsibilities
        Review of each element in an environmental impact assessment
        document
        A detailed review checklist
        Other valuable reviewer resources.
July 1998
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                    Chapter 2 — Overview of the Environmental Impact Assessment Process
                   TABLE OF CONTENTS

2.   THE ENVIRONMENTAL IMPACT ASSESSMENT
    PROCESS	2-1
    2.1 Decision to Proceed with Environmental Impact
       Assessment	2-3
    2.2 Draft Environmental Impact Assessment Document  	2-4
       2.2.1   Scoping to Identify Significant Issues	2-4
       2.2.2   Documenting Purpose and Need 	2-5
       2.2.3   Development of Alternatives	 2-5
       2.2.4   Description of the Environmental Setting	2-6
       2.2.5   Assessment of the Impacts of Alternatives	2-6
       2.2.6   Identification of Mitigation Approaches	 2-6
       2.2.7   Identification of the Preferred Alternative	 2-7
       2.2.8   Review of the Draft Environmental Impact
              Assessment  			 2-8
    2.3 Final Environmental Impact Assessment	2-8
    2.4 Decision-Making			 2-8
    2.5 Mitigation Plan	2-8
    2.6 Record of Decision	2-9
    2.7 Project Implementation 	>	.,..,.	2-9
    2.8 Post-Decision Monitoring and Follow-up	2-9
                                            2-i
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                     Chapter 2 — Overview of the Environmental Impact Assessment Process
 2. THE ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

Environmental impact assessment is a process used in many countries to
ensure that environment-related factors are included in decision making
processes for projects that may affect the environment. The process is
also intended to ensure that there is an opportunity to avoid or mitigate
potentially adverse environmental impacts and to identify opportunities
for beneficial impacts. The process begins with the decision of whether
to proceed with an environmental impact assessment.  If potential
impacts may exceed acceptable impact thresholds, the process then
proceeds to documentation and analysis in draft and final environmental
impact assessment documents that are used to support decisions on
project alternatives, mitigation measures, and post-decision monitoring
and follow-up. An environmental impact assessment is a detailed,
systematic, objective, and reproducible assessment and comparison of
the proposed project and its reasonable and feasible alternatives. A
graphic representation of the environmental impact assessment process is
presented on the following page.

From a developer's point of view, a project begins in three stages:
design, detailed engineering and site preparation, and construction. An
environmental impact assessment should be initiated at project
conception before beginning detailed engineering or site preparation.
More and more industries and government agencies are beginning to
evaluate both the existing environmental setting and future
environmental impacts as part of project identification and design to
avoid costly environmental impacts and involve the affected public in
project design.

Public participation, including interested and affected parties. (i.e.,
stakeholders), and interagency consultation are critical to the success of
environmental impact assessment. In the United States and other
countries, the public and government agencies typically participate in
open meetings on the two types of major documents generated during the
environmental impact assessment:  1) initial environmental impact
assessment documents that indicate whether or not there is the potential
for significant impacts, and 2) draft and final environmental impact
assessment documents. Traditionally, the public has become involved
during review of draft environmental impact assessments. Public
involvement limited to the final environmental impact assessment
process has contributed to public opposition to proposed projects and
costly delays. As a result, initial public involvement is desirable during
the scoping phase of the preparation of a draft environmental impact
assessment to help identify significant issues, alternatives and sources of
information on the environmental setting. After completion of the draft
environmental impact assessment, public comments are solicited and
incorporated into the final environmental
•  The environmental impact
   assessment process includes:

   *• Decision to proceed with
     environmental impact
     assessment
   ป• Preparation of a draft
     environmental impact
     assessment
   ป• Preparation of a final
     environmental impact
     assessment and decision
     making
   ป• Post-decision monitoring
     and follow-up

• An environmental impact
   assessment should be initiated
   at the inception of a proposed
   project and prior to site
   preparation, while it is still
   possible to pursue alternative
   courses of action and prior to
   site preparation.
    Public Participation:  who to
    include...
    • Businesses
    • Local government
    • Citizens
    • Nongovernmental
      organizations

    ...and when to include them
    • During scoping phase to
      identify significant issues and
      alternatives.
    • During review of draft
      environmental impact
      assessment.
    • During review of final
      environmental impact
      assessment document.
    ป During selection of preferred
      alternative and mitigation
      measures.
    • During monitoring and follow
      up.
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                     Chapter 2 — Overview of the Environmental Impact Assessment Process
impact assessment. Public input also is considered during decision
making on the selection of the preferred alternative and mitigation
measures and should be considered in post-decision monitoring and
evaluation stages.

The remainder of this chapter briefly presents the environmental impact  '
assessment process, including the decision to proceed with an
environmental impact assessment, preparation of the draft and final
environmental impact assessments, and post-decision monitoring. Public
and government involvement are highlighted throughout the discussion.

2.1 DECISION TO PROCEED WITH ENVIRONMENTAL IMPACT
    ASSESSMENT

hi countries where government agencies are responsible for preparing
environmental impact assessments, such agencies must decide whether to
proceed with environmental impact assessments for proposed projects
that may pose a risk of significant environmental impacts. Not all
proposed projects have the potential for environmental impacts, and
those without this potential do not require a decision about whether to
proceed with environmental impact assessment. Proposed projects that
do carry the potential for environmental impacts initially undergo an
internal agency decision process to determine whether potential impacts
would be significant:

 • If the potential impacts are not significant, a report is prepared
    providing the results of the decision to proceed. This report is made
    available to the public and government agencies for review.
 • If the potential impacts are significant, an environmental impact
    assessment is often required.
             The Environmental Impact Assessment
                   Process in the United States

 In the United States, the decision to proceed process often includes a
 report called an Environmental Assessment Following public review
 and comment, if the determination is still that there is no significant
 impact, & "finding of no significant impact*' (FONSI) is issued,

 ai the United States,, the environmental impact assessment document
 is referred to as an ^environmental impact statement*' (BIS). After
 public review and comment, a "record of decision'3 (ROD) follows an
 environmental impact statement.
The initial step in the process typically includes analyses of
environmental conditions and the potential for significant environmental
impacts. This may include discussion on the presence of critical habitat
for an endangered species, important historical sites, or an active
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 Chapter 2 - Overview of the Environmental Impact Assessment Process
 earthquake fault, as well as other physical, hydrologic, biological, land
 use, access, economic, and air and water quality parameters.

 2.2 DRAFT ENVIRONMENTAL IMPACT ASSESSMENT DOCUMENT

 While the procedural and substantive activities involved in developing
 the draft environmental impact assessment vary by country, the following
 major elements of the environmental impact assessment preparation
 process are generally applicable: 1) scoping to identify all potential
 significant issues that the environmental impact assessment should
 address; 2) documenting the purpose and need; 3) development of
 alternatives; 4) describing the environmental setting; 5) assessment of
 the potential impacts of alternatives; 6) identification of mitigation
 approaches; 7) identification of the preferred alternative; and 8) review
 of the draft environmental impact assessment document.

 2.2.1  Scoping to Identify Significant Issues

 Scoping is the process used to identify significant issues and reasonable
 and feasible project alternatives and to help focus available resources on
 the assessment of those issues and alternatives. It should be remembered
 that an environmental impact assessment is not an opportunity to conduct
 unlimited academic or applied research. An environmental impact
 assessment should provide the best available answers to specific
 questions and should seek to do so in a cost-effective manner. Scoping
 meetings may be held internally, involving technical experts, or
 externally to obtain public input. The first step in the process is to
 develop information on the resource to be affected, a simple list of all
 potential concerns associated with the proposed project and any possible
 project alternatives. It is important to note that impacts are not
 quantified during scoping. When completed, the list is examined
 carefully to identify any potentially significant issues. The significance
 of issues is generally based on the geographical extent, duration,
 magnitude, and public perception of the impacts. Further information on
 determining the significance of environmental impacts is provided in
 Appendix C.

 Public participation is an important source of information about potential
 issues related to the proposed project. An important part of scoping is to
 identify all interested parties relevant to the process. Gaining the public's
 opinion early helps the project proponent avoid future conflict, hi the
 past, project proponents were concerned that public participation would
 slow project development.  The proponents attempted to push projects
 through the approval process with minimum public involvement. While
 this strategy was successful in some cases, it frequently failed because
without public participation, proponents often missed significant social
 and environmental issues.  Thus, both governments and project
proponents have found that it is very expensive to address significant
 issues after the proposed project has begun its detailed engineering phase
                      The draft environmental impact
                      assessment analysis and
                      documentation process:

                      1) Scoping to identify significant
                        issues
                      2) Documenting purpose and
                        need
                      3) Development of alternatives
                      4) Describing the environmental
                        setting
                      5) Assessment of potential
                        impacts of alternatives
                      6) Identification of mitigation
                        approaches
                      7) Identification of the preferred
                        alternative
                      8) Review of the draft
                        environmental impact
                     Why is scoping important?

                     • To focus available resources
                       in a cost-effective manner on
                       the most significant issues

                       If part of scoping, public
                       participation is an important
                       source of information about
                       potential issues related to the
                       proposed project
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                     Chapter 2 - Overview of the Environmental Impact Assessment Process
and have recognized the advantage of identifying issues as early as
possible in the proposed project's design phase.

2.2.2 Documenting Purpose and Need

Environmental impact assessment documents typically begin with an
introduction describing the purpose of, and need for, the proposed
project. The statement of purpose and need is important because it
provides the framework for identifying project alternatives.  For example,
a project to build a new highway may be proposed because the existing
highway is too narrow and cannot accommodate the volume of traffic.
The need for the project is a decrease in the amount of time drivers spend
in slow traffic.  The purpose, or goal to be met in addressing the need, is
to build a new highway of adequate width to accommodate projected
traffic flow in the future at sufficient travel speeds. The project
alternatives could include various locations for the proposed highway,
construction of additional mass transit capacity  to avoid building the
highway, designation of high occupancy vehicle (HOV) lanes, or a
combination of these alternatives.  All of these alternatives address the
need for the proposed project. Some of them address the purpose better
than others.  All reasonable alternatives that fulfill the purpose and need
should be evaluated in detail.  The more alternatives, the greater the
possibility of avoiding significant impacts.

Input on the purpose and need should be obtained from stakeholders,
including businesses, citizens, local government, and nongovernmental
organizations. This enables the project proponent to understand and
consider the priorities and concerns of the local  community and
government agencies early in the planning process, which could help to
avoid future delays.

2.2.3 Development of Alternatives

The environmental impact assessment may or may not contain a range of
alternatives developed to fulfill the purpose and need of the  proposed
project.  Some countries require a range of alternatives to be presented,
while others require that only the proposed project be presented.  Early in
the planning process, the project proponent usually identifies several
alternatives, including a proposed alternative. These alternatives are
sometimes subjected to an evaluation process to help identify and refine
additional reasonable alternatives.

Alternatives often involve different locations for the proposed project,
new or different technologies, and/or completely different approaches to
achieving project objectives. All reasonable alternatives should be
carried through the identification of mitigation approaches stage (see
Section 2.2.6). Thoroughly assessing a range of alternatives enables
project proponents, environmental impact assessment reviewers, and
decision makers to gain a complete understanding of the potential
impacts of the proposed project over the full spectrum of implementation
•  The purpose and need must be
   a clear, objective statement of
   the rationale for the proposed
   project
  The statement of purpose and
  need provides the framework
  for identifying project
  alternatives
  Example of an Alternative

  If a proposed project involves
  building a thermoelectric
  plant, alternative approaches
  to meeting energy needs might
  include demand-side
  management to reduce energy
  consumed by users, purchase
  of energy from other power
  plants, alternate sources of
  energy, and expansion of
  existing plants
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 scenarios and to refine the final preferred alternative with mitigation
 measures, if necessary.

 2.2.4 Description of the Environmental Setting

 After identifying the "region of concern," the project "applicant" or
 "environmental impact assessment preparer" (hereinafter collectively
 referred to as project proponent) describes the environmental setting in
 terms of physical-chemical, biological, socioeconomic, and cultural
 resources. The project proponent also includes any background
 information relevant to specific project concerns introduced during the
 scoping process. The descriptive information will be used as a baseline
 to project the potential impacts of the proposed project.

 2.2.5 Assessment of the Impacts of Alternatives

 The project proponent conducts a systematic and interdisciplinary
 analysis of implementing and operating each alternative, including the
 proposed project and no-action alternatives, to assess potential impacts
 on all resources of the future environmental setting in the region of
 concern.  The environmental impact assessment should include primary,
 secondary, and cumulative impacts.  The potential impacts will be used
 with the descriptive information to compare and contrast all alternatives.

 Once the potential impacts are identified, the project proponent or
 authorizing agency determines their significance through a combination
 of: 1) best professional judgment of an expert or group of experts; 2)
 quantitative thresholds of significance defined by law, regulation, or
 policy; or 3) the practice of an agency or the collective wisdom of a
 recognized group. In other settings, significance is determined through
 qualitative analysis by experts in relevant disciplines. Various factors
 are considered, including public health and safety, unique characteristics
 of the region of concern, degree of uncertain or unknown risks, and any
 project or impact controversy.

 The project proponent is usually required to compare and contrast the
 potential impacts of all alternatives, including the project proponent's
 original proposed project on the existing and future environments, in a
 summary table and may briefly summarize the comparisons, comment on
 important comparisons, or provide any insights in the text.  In addition,
 the proponent commonly identifies the preferred alternative(s) and the
 reasons for its/their selection.

 2.2.6 Identification of Mitigation Approaches

 To help ensure that the proposed project affects the environment as little
 as possible, the proponent typically identifies mitigation measures to
 address  all potential major environmental impacts. Mitigation measures
 should be defined for the proposed alternative as well as all other
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                     Chapter 2 — Overview of the Environmental Impact Assessment Process
alternatives. By doing so, a meaningful comparison among alternatives
is made possible.

The primary mitigation types can be classified as follows:

    •  Avoid or prevent impacts altogether by not taking a certain
       action or parts of an action

    •  Minimize impacts by limiting the degree or magnitude of the
       proposed project and its implementation

    •  Reduce or eliminate the impact over time by preservation and
       maintenance operations during the life of the proposed project

    •  Correct the impact by repairing, rehabilitating, or restoring the
       existing environment

    •  Compensate for the impact by replacing or providing substitute
       resources or environments.

These primary mitigation types are arranged above in descending order
of preferability. For example, avoiding or preventing an impact is
preferable to minimizing an impact, minimizing an impact is preferable
to reducing or eliminating an impact over time, and so on. This concept
is explored more fully in Chapter 4.

2.2.7 Identification of the Preferred Alternative

In environmental impact assessment processes that include alternatives to
the proposed project, the project proponent must often provide rationale
behind selection of the preferred alternative. Such rationale consists of a
comparison between all of the alternatives, including an explanation of
why the preferred alternative is superior to the others.  An alternative
may be selected as superior for any of the following reasons:

•  Meets the purpose and need for the proposed project more
    successfully than the other alternatives;
•  Meets the purpose and need of the proposed project as well as, or
    almost as well as, the other alternatives, while having less potential
    for significant environmental impacts than the other alternatives; and
•  Is comparable to other alternatives in terms of ability to meet the
    purpose and need and potential for environmental impacts, but would
    be less expensive.

These are simply three of the most common reasons for selection of a
preferred alternative. Project proponents may offer other rationales for
supporting a preferred alternative than those listed above.
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 2.2.8 Review of the Draft Environmental Impact Assessment

 The information generated during the assessment stage is the basis of the
 draft environmental impact assessment. After the draft environmental
 impact assessment is completed, a formal review is usually designated to
 allow public comment on the entire draft. If the proposed project is large
 or controversial, it may be appropriate to hold public meetings during the
 comment period.  These meetings are held to explain to the public the
 issues involved, answer any questions, and receive comments on the draft
 environmental impact assessment. It is at this stage of the environmental
 impact assessment preparation that the formal review—whose principles
 are the focus of this course—is undertaken.  In the United States, this
 review is done by an agency other than the agency responsible for its
 preparation or advocacy of the proposed project.

 2.3 FINAL ENVIRONMENTAL IMPACT ASSESSMENT

 To prepare the final environmental impact assessment, the project
 proponent should take into account each public comment and the
 comments of the independent reviewer that were received on the draft
 version. The project proponent includes both the comments and the
 responses in the final document (e.g., in an appendix) and revises the text
 of the document, if necessary, based on the comments.

 2.4 DECISION-MAKING

 The final decision on implementation of the proposed project is generally
 based upon the final environmental impact statement. The relationship
 between the reviewer and the decision maker will determine the level of
 influence the reviewer may have over the decision that is made.
 Conducting a detailed independent review, ensuring that the views of all
 interested parties have been  taken into account, and supporting the
 integrity of the process, are ways that the reviewer supports the decision
 making process.

 2.5 MITIGATION PLAN

 Once the preferred alternative has been selected, the project proponent
must specify a mitigation plan that will address all expected adverse
environmental impacts resulting from that alternative. The mitigation
plan should be a detailed description of the following things:

•  All  of the specific mitigation measures to be implemented
•  A feasibility assessment for all of the proposed measures
•  A schedule indicating when and where each mitigation measure will
   be implemented
•  A description of the costs of implementing the selected mitigation
   measures, and the sources of funding to cover those costs
•  Clear designation of the party(ies) responsible for implementing
   mitigation.
                                                                    Preparation of final
                                                                    environmental impact
                                                                    assessment:

                                                                    1)  hi an appendix, list all
                                                                      comments from the public and
                                                                      from the independent review
                                                                      agency
                                                                    2) Incorporate relevant
                                                                      comments and finalize the
                                                                      environmental impact
                                                                      assessment
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2.6 RECORD OF DECISION

A record of decision documents the result of an environmental impact
assessment.  It states what alternative has been selected by the project
proponent, what other alternatives were rejected and why, and what
mitigation measures will be implemented to address all projected adverse
environmental impacts. The reviewer's role is to take steps to help
ensure that the record of decision is accurate and complete. In other
words, the reviewer must read the record of decision to determine
whether it accurately describes the process that actually occurred, and
matches the findings in the final environmental impact assessment
document.

2.7 PROJECT IMPLEMENTATION

After a final environmental impact assessment document has been
reviewed, and the record of decision written, the proposed project may
proceed, as long as there are no permit requirements, enforcement actions
or other country-specific requirements that would prevent it from
proceeding.  Project implementation, if the proposed project involves
land development or the construction of a facility, typically consists of
four phases: site preparation, construction, operation, and mitigation.
The proposed project may also be programmatic in nature, and not
involve any construction or land modification directly attributable to the
project, such as the signing of a free-trade treaty. Regardless of the type
of proposed project, the reviewer's role consists primarily of post-
decision monitoring and follow-up, which are discussed below.

2.8 POST-DECISION MONITORING AND FOLLOW-UP

As soon as project implementation begins, three types of monitoring
become important in ensuring project success: (1) implementation
monitoring, (2) effectiveness monitoring, and (3) validation monitoring.
Implementation monitoring simply ensures that any mitigation measures
required are implemented. Effectiveness monitoring evaluates whether
the mitigation is working as expected.  Validation monitoring determines
the accuracy of the models and other tools that were used during the
environmental impact assessment process to identify potential
environmental impacts. Because this type of monitoring can be time-
consuming and expensive, it is important to focus on the evaluation of
models and tools related to potential environmental impacts of high
priority in the environmental  impact assessment.

The reviewer usually decides whether post-decision monitoring is
required depending on the circumstances of the project. If the potential
impacts were identified using new or unproven methodologies, for
example, the reviewer may require the proponent to validate the method
by monitoring the actual consequences of the project oh resources of
concern.  Similarly, if a mitigation technique is new or is applied in a new
Types of Monitoring:

1) Implementation monitoring
2) Effectiveness monitoring
3) Validation monitoring
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 Chapter 2 - Overview of the Environmental Impact Assessment Process
 setting, the reviewer may require the proponent to monitor its
 effectiveness. In addition, implementation monitoring to determine
 whether regulatory requirements (e.g., permits, enforcement conditions,
 discharge limitations) are being met may be set as a condition for
 approval.
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                                    Chapter 3 — Overview of the Reviewer's Responsibilities
                   TABLE OF CONTENTS

3.   REVIEWER'S ROLES AND RESPONSIBILITIES IN THE
    ENVIRONMENTAL IMPACT ASSESSMENT PROCESS ..  3-1
    3.1    Introduction	3-1
    3.2    The Role of the Reviewer 	3-1
           3.2.1    Reviewer as a Facilitator of the
                   Environmental Impact Assessment Decision-
                   making Process	3-1
           3.2.2    Different Contexts for the Reviewer's Role ..3-4
           3.2.3    The Reviewer's Focus  	3-7
           3.2.4    Four Types of Review Situations	3-8
    3.3    Reviewers and Review Teams	3-10
           3.3.1    Characteristics of a Good Reviewer	3-10
           3.3.2    Expertise	3-11
           3.3.3    Review Teams	3-12
           3.3.4    Technical Experts	3-13
           3.3.5    Preparation for the Reviewer Role in
                   General	3-13
    3.4    Reviewer's Role in Each Element of the
           Environmental Impact Assessment Process 	3-14
           3.4.1    Decision to Proceed Activities: Deciding
                   Whether a Proposed Project is Subject to
                   Environmental Impact Assessment
                   Requirements	3-14
           3.4.2    Draft Environmental Impact Assessment
                   Documents	3-16
                   3.4.2.1 Scoping: Environmental Impact
                          Assessment Document Development 3-17
                   3.4.2.2 Involving Stakeholders and Other
                          Interested Parties	3-20
                   3.4.2.3 Preparing Comments on the Draft
                          EIARoadMap	3-21
           3.4.3    Final Environmental Impact Assessment
                   Documents 	3-23
           3.4.4    The Role of the Reviewer in Decision-
                   making  	3-25
                   3.4.4.1 The Record of Decision  	3-27
           3.4.5    The Role of the Reviewer in Post-Decision
                   Monitoring and Follow-up	3-29
    3.5    Communicating the Findings of the Review	3-29
    3.6    Overcoming Obstacles to Effective Environmental
            Impact Assessment Reviews	3-32
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                                     Chapter 3 — Overview of the Reviewer's Responsibilities
  3. REVIEWER'S ROLES AND RESPONSIBILITIES IN THE
     ENVIRONMENTAL IMPACT ASSESSMENT PROCESS

3.1 INTRODUCTION

This chapter provides an overview of the different roles and
responsibilities of reviewers of environmental impact assessments.

Included in this chapter are discussions on the:
    role of the reviewer;
    reviewers and review teams: descriptions of key players;
    reviewer's role in each element of the environmental impact
    assessment process;
    communicating the findings of the review; and
    overcoming obstacles to effective environmental impact assessment
    review.
3,2 THE ROLE OF THE REVIEWER

3.2.1  Reviewer as a Facilitator of the Environmental Impact
      Assessment Decision-making Process

Environmental impact assessment has been defined in the previous
chapter as both a decision-making process and a document which
enables a decision-maker to:

•   Integrate regulatory, environmental, social, and economic
    considerations.
•   Eliminate, prevent, reduce, minimize or mitigate adverse
    environmental impacts resulting from a proposed project.

It does this by:

•   Ensuring consideration of both a proposed project and the range of
    reasonable alternatives that meet the overall purpose and need for
    actions which may have a significant impact on the environment,
    broadly defined;
•   Maximizing the breadth and inclusiveness of all relevant
    information, criteria, and parameters for decision-making through a
    systematic, interdisciplinary, reproducible and documented
    assessment; and
•   Providing for involvement of all key stakeholders.

Many government and financial institutions now require an
environmental impact assessment process and preparation of an
environmental impact assessment document that includes most of the
elements of the internationally accepted framework for environmental
impact assessment.  Associated with these requirements they have
  The term environmental
  impact assessment refers both
  to a decision-making process
  and a document
•  The independent reviewer:

   - May or may not have the
     authority to change aspects
     of the proposed project
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 Chapter 3 — Overview of the Reviewer's Responsibilities
 established the role of an "independent" reviewer within their
 organizations to help ensure that both substantive and procedural
 requirements are met. The public and various stakeholders conduct a
 review of an environmental impact assessment document during public
 participation or in response to notification and opportunities to review
 and comment on an environmental impact assessment or project
 proposal. For purposes of this text, the reviewer is an individual or a
 team led by an individual within an institution which requires
 environmental impact assessment in support of decision-making. The
 review function is usually, but not always, different from the decision-
 making function within such institutions. However, this is not always the
 case. For example, in instances in which the environmental impact
 assessment is used as a permit application, or is the basis for setting
 environmental conditions for construction, operation or financing of a
 facility, the reviewer may also be a "decision-maker" in regard to
 conditions  for project approval.  Even when the reviewer is not in a
 decision-making position, a good reviewer can nevertheless wield
 influence over the success and outcomes of the process and the
 environmental impacts of a proposed project.

 In most instances, having a distinct function for a "reviewer" of
 environmental impact assessment documents helps to:

    Overcome bias: Any project proponent will bring to the process
    certain biases or his or her own perspectives, however unintentional.
    A "reviewer" is someone who has greater "independence" and
    "objectivity"  because the reviewer is not associated directly with any
    particular outcome from the review. Obviously everyone brings the
    bias of his or her own perspectives, experiences,  and values, but this
    reviewer independence is based upon the reviewer's commitment to
    the systematic and interdisciplinary approach that is fundamental to
    environmental impact assessment.  Even within financial or
    government institutions, the reviewer role is often created as one
    which is separate from those who might be in positions to advocate
    for a particular project or proposal.

    Identify important information gaps and  reasonable alternatives that
    may have been overlooked: Everyone involved in the environmental
    impact assessment process is operating under constraints that
    influence the extent to which an assessment identifies, assesses, and
    resolves important issues and considers alternative courses of action.
    Shortcuts may be taken because of resource, information, and/or time
    constraints that may result in inadequate or total lack of information
    or exploration of alternatives or impacts  critical to sound decision-
    making. An "independent" reviewer who does not have a particular
    stake in the outcome may be in a better position to identify when
    further information is needed and reasonably obtainable.
                        Overcoming bias
                     •  Identify important information
                        gaps and alternatives
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                                   Chapter 3 — Overview of the Reviewer's Responsibilities
 Provide the decision-maker with environmental and related expertise:
 Often those in decision-making positions lack the necessary
 technical, economic, or related expertise to review an environmental
 impact assessment document to ensure the information presented is
 complete and accurate and that any preferred alternative and
 associated mitigation of environmental impacts present an
 environmentally (and socially) acceptable means of meeting the
 purpose and need for the action. A reviewer either brings to the
 review or coordinates the necessary expertise to make these
judgements.

 Distinguish significant from insignificant issues for decision-makers:
 The environmental impact assessment process often yields enormous
 quantities of data and many different and sometimes divergent views
 on desired outcomes. Whether serving or actually acting as a
 decision-maker, a reviewer typically plays an essential role in
 facilitating decisions whether to proceed and under what conditions.
 He or she does so by sorting through and identifying the most
 significant issues to the extent these are not clearly and
 systematically portrayed in the environmental impact assessment, hi
 addition, a good environmental impact assessment reviewer will be
 able to identify reasonable alternatives and/or ways to mitigate
unacceptable environmental impacts which may have been
overlooked in the process. This can provide both the project
proponent and the decision-maker with ways to resolve conflicts or
improve the outcome of the process. Finally, by assuring complete
and accurate information for the decision maker, and systematic
comparison of impacts associated with reasonable alternatives, the
reviewer can enhance the prospects for selection of a preferred
alternative which is environmentally sound. In this capacity, a
reviewer is a catalyst for improved decision-making and possible
development of creative ways to better integrate economic,
environmental and social objectives.

Ensure the integrity of the environmental impact assessment process
and document: The reviewer can assure that key stakeholder groups
are provided an opportunity to get involved in the process and have
their views known, if required, by providing an independent check on
how governmental or financial institution rules and procedures are
carried out. A reviewer also can try to ensure that environmental and
social concerns are seriously considered and addressed within the
process.  While the reviewer often is not in a position to actually
make a final decision about a proposed project, the reviewer can help
ensure at a minimum that all  of the relevant information was brought
before a decision-maker in a clear and systematic manner.

Bring perspective of all interests: A broad perspective from all those
with an interest in the outcome of the decision is an important aspect
of EIA. However, even when the public is provided an opportunity
Provide decision-maker with
valuable tools in the form of
environmental and related
professional experience
The reviewer can also help
decision-makers distinguish
between significant and
insignificant issues
The reviewer plays an
essential role in ensuring the
integrity of the environmental
impact assessment process
and document
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Chapter 3 - Overview of the Reviewer's Responsibilities
    to comment, there often are interests that are not expressed or are
    under-represented.  The reviewer can identify these interests and
    bring them into the process.
 In summary;  a reviewer facilitates the environmental impact
 assessment decision-making process which seeks to integrate
 environmental, economic and social concerns and eliminate,
 avoid, minimize, prevent, and/or mitigate adverse environmental
 impacts of a proposed project and its reasonable and feasible
 alternatives* Without the important role of the reviewer, the
 environmental impact assessment process can fail to meet its goals if
 the alternatives, assessment, and involvement of key stakeholders 1$
 deficient in some significant way. The presence of a reviewer can
 help to prevent the requirements for environmental impact
 assessment from being merely a paperwork exercise.
3.2.2 Different Contexts for the Reviewer's Role

A reviewer must understand the broader context within which he or she
conducts the review of an environmental impact assessment document or
gets involved in different stages of the process. These contexts are legal,
institutional, organizational, and personal.

Legal context: A reviewer must understand the legal basis for:
-   the environmental impact assessment process and documentation
    within his or her community, e.g., does it require identification of
    alternatives; is public participation mandatory or optional; what form
    does public participation take; who must be notified, and how?
-   legally binding requirements for environmental protection, and
    property rights, and
-   limitations on his or her own organization or other related
    organizations to define or establish binding conditions for mitigation
    of adverse environmental or social impacts.

Institutional context: There are several reasons why knowledge about
institutional settings is important for reviewers:

    Expertise: A reviewer must understand where to obtain relevant
    information and expertise within the various institutions within and
    outside of government.

    Perspective: In order to bring a broad interdisciplinary perspective
    to the review, a reviewer should be familiar with the various players
    and interests in a particular project proposal.

    Involvement:  Throughout this discussion, there is a preference for
    early involvement of the reviewer in the process, particularly at
                     •  Different contexts for the
                        reviewer's role:

                        - Legal
                        - Institutional
                        - Organizational
                        - Personal
                        Early involvement in the
                        environmental impact
                        assessment process is one of
                        the most important ways a
                        reviewer can help ensure the
                        integrity of the environmentail
                        impact assessment process
                        and document
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                                       Chapter 3 — Overview of the Reviewer's Responsibilities
    stages of initial environmental impact assessment and scoping, and
    for a reviewer to benefit from the results of public comment and
    participation if possible and to become a part of the process. The
    ability and opportunity to get involved at any stage in the process is a
    function of the institution within which the reviewer is situated as
    well as the approach of the individual reviewer.

    Support: To be effective, a reviewer needs to know the relative
    strengths and weaknesses of his own position as part of a specific
    institution. For example, a reviewer may have a position within an
    environmental ministry, department, or agency which has relatively
    weak authority compared to ministries which specifically advocate
    for economic sector development for the kind of project proposed. It
    would be advantageous to have good working relations with the staff
    of the stronger ministry and to establish good professional working
    relationships so that they better understand the benefits, support the
    results and perhaps even participate in reviews to make the results of
    review more effective.  Often these relationships are out of the
    control of an individual reviewer, but informal relationships can be
    invaluable. And, it may be necessary to provide even more support
    for any reviewer findings and recommendations if institutional
    support is generally lacking.

    Decision-making: A reviewer's comments and recommendations
    should have a direct influence on the information and options before
    a decision-maker. A part of that is a sound technical review of the
    completeness and adequacy of documentation, process, analysis, and
    considerations, and a second part of that is the ability to distinguish
    significant issues and to support clear decision-making on a
    preferred alternative and related mitigation.  Knowing who the
    decision-makers are and how decisions are made is invaluable in
    structuring communications and review to support it, whether that
    individual is different from or the same as the reviewer.

    Follow through: If a ministry or department responsible for
    reviewing environmental impact assessment documents is different
    from a ministry or department which has authority to ensure
    mitigation actions are carried out as proposed, it can be very
    important to communicate with all affected ministries to ensure that
    the basis for environmental impact assessment based decisions is
    sound.

Organizational context: Regardless of the institutional setting, a
reviewer sits within an organization with lines of authority and existing
decision-making processes and styles of communication, management
and decision-making. The organizational context will define how issues
are elevated  and resolved and who must make what decision and how.
Sometimes when issues or key concerns are raised early instead of very
late in a process,  approaches can be put into motion to help resolve them
   Reviewers should understand
   the strengths and weaknesses
   of their organization, and be
   prepared to use its strengths to
   benefit the environmental
   impact assessment process
•  Communication between
   reviewing agencies or
   ministries is very important to
   ensure proper follow-through
•  The organizational context
   determines how issues are
   elevated and resolved and who
   must make what decision
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Chapter 3 - Overview of the Reviewer's Responsibilities
rather than escalate the controversies.  Reviewers must be sensitive to
these unique circumstances within their own organizations. No one
responds well to surprises.

A reviewer also needs to know the priorities of the organization in
defining how to manage their own time and resources to any given
review. Most governmental agencies responsible for reviewing
environmental impact assessments often have several projects to review
during the same period of time. Because organizational budgets  and staff
time are limited, it is essential to focus time and effort on high priorities.
Every proposed project is different, and some should receive more
attention than others. It is up to each agency to determine its own
priorities and which environmental impact assessments to spend the bulk
of its resources on. Considerations each agency faces when setting
priorities in the context of environmental impact assessment review are
as follows:

•  Legal responsibilities to participate. What types of proposed
    projects are the agency required by law to review?  If some
    environmental impact assessments currently pending review must be
    reviewed, while others are optional, the agency should place  a higher
    priority on those it is required to review.
•  Severity of potential environmental impacts. When setting priorities
    between two or more environmental impact assessments, it is often
    prudent to place the highest priority on environmental impact
    assessments for proposed project(s) with the greatest potential for
    environmental or other harm.
•  Priority concerns of the agency. It is important to know the most
    significant environmental threats and priorities for the nation, region
    and/or locality.  Often agency priorities originate from legal
    responsibilities, which are also often related to protection of the
    environment, but sometimes there are other agency concerns that
    take precedence, such as the need to promote economic prosperity.
•  Available staff and travel resources. Sometimes an agency must set
    priorities based on scarcity of resources.  In such cases proposed
    projects that may be a priority concern of the agency are pushed
    aside in favor of proposed projects of lesser concern but a higher
    chance of actually getting reviewed.

It is essential that a reviewer have or develop an understanding of his or
her own organization's authorities, regulations, programs and levels of
authority and decision-making, and an appreciation for the limits of those
authorities. The range of authorities under which a reviewer may be
operating will in large part define the responsibilities of the reviewer.

Personal Context: The influence the reviewer has on decision-making
and outcomes can be influenced as much by the manner in which the job
is carried out as by explicit authority.  A reviewer can draw upon
different types of authority; that is, not only legal and institutional
                     •  A reviewer needs to know the
                        priorities of his or her
                        organization
                     •  Legal responsibilities
                        Severity of impacts
                        Priority concerns of the
                        agency
                        Available staff and travel
                        resources
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                                      Chapter 3 — Overview of the Reviewer's Responsibilities
authority, but also authority achieved through interpersonal and
communication skills and professional competence.

The reviewer not only brings expertise and experience, but also must
communicate, both orally and in writing, in an effective and convincing
manner; must "facilitate" other expertise, and public and internal
processes to ensure complete, thorough, accurate decision-making
documents; and may need to negotiate the scope, alternatives considered,
analysis prepared, data collected and/or alternative decided upon as well
as follow up actions. Such a range of possible activities places value on
judgement, perspective, logic, common sense and communication skills
as much as upon technical expertise.

3.2.3 The Reviewer's Focus

With all relevant contexts in mind, a reviewer must also focus his or her
review on the most important issues.  Environmental impact assessments
are often very large and contain extensive technical materials. Given
limited budgets and limited time, reviewers must focus on more
important issues, and give less attention to less important issues. In
essence, there are  six primary areas the reviewer of an environmental
impact assessment should focus on:

    1)   Completeness/Coverage: Whether all potentially significant
         environment types, impacts, data sources, and other necessary
         components of an environmental impact assessment were
         identified and evaluated for a complete range of reasonable and
         feasible  alternatives;
    2)   Significance: Whether all potentially significant issues were
         identified and addressed, and whether the issues that received
         the most attention;
    3)   Adequacy: Whether the analyses and data supporting the
         impact assessment are adequate;
    4)   Integrity: Whether there is internal logic and integrity in the
         environmental impact assessment document; whether the
         assumptions are consistent within the framework of the
         proposed project; whether the analytical approaches used and
         the conclusions drawn are valid; and whether the process was
         fair, e.g., open to all interests;
    5)   Accuracy: Whether the information, models, and assumptions
         used by a project proponent are accurate;  and
    6)   Influence: The degree to which the reviewer should and how to
         participate in, and influence, the environmental impact
         assessment and decision-making process.

By maintaining focus on these six areas, a reviewer can ensure that his or
her review stays on track and addresses  the key issues. It is important to
maintain this Reviewer's Focus throughout all stages of environmental
impact assessment review, from participation in decision to proceed
Reviewer Focus
-  Completeness/Coverage
-  Significance
-  Adequacy
-  Integrity
-  Accuracy
-  Influence
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 Chapter 3 — Overview of the Reviewer's Responsibilities
 activities to review of post-facility operation monitoring and mitigation.
 To help the reviewer maintain this focus, road maps that touch upon the
 six focus points are included throughout Chapter 4 in conjunction with
 descriptions of each part of a typical environmental impact assessment
 document. The reader is also encouraged to refer to the Reviewer's
 Focus list when reviewing environmental impact assessments in the
 future.

 3.2.4 Four Types  of Review Situations

 Regardless of the context in which a reviewer finds him or herself, the
 task of environmental impact assessment review is often complicated by
 a large workload and inadequate time and resources. For purposes of
 simplicity and to capture the range of situations reviewers find
 themselves in, we have described four types of review situations:

    •   "The solo  reviewer." Must carry out an isolated technical
         review without external assistance, and little context
         information.

    •   "The empowered reviewer." Builds his or her own informal
         networks and resources. Keeps up on environmental, economic
         and social  context information relevant to project and program
         reviews. Uses networks effectively. Knows where to find
         useful tools and techniques for review.

    •   "The lead reviewer." A manager of a team of associate
         reviewers within or outside of the reviewer's organization. The
         lead reviewer may have funding for experts or formal
         organizational links to experts upon which s/he can draw.
         Regardless, the lead reviewer needs interpersonal skills,
         managerial and communications ability to pull together the
         interdisciplinary team, and must provide a holistic perspective,
         and timely and concise advice.

    •   "The proactive reviewer." Gets involved up front in the
         process. He or she becomes involved before major design and
         planning decisions have been made by the project proponent.
         Early involvement is important in enabling the reviewer to
         influence the players involved in the process and quality of the
         environmental impact assessment document.  This can and
         must be done in a manner which does not compromise
         independence.  Any of the other reviewer situations can also
         include proactive elements.

It is important to recognize that the four reviewer situations presented
above may apply at any time to any reviewer throughout his or her career.
The same individual may serve as a lead reviewer at one time, a solo
reviewer the next, and a proactive or empowered reviewer at another
                         Solo Reviewer
                        Empowered Reviewer
                         Lead Reviewer
                        Proactive Reviewer
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                                      Chapter 3 - Overview of the Reviewer's Responsibilities
time.  For this reason, it is important to visualize all four reviewer
situations while reading this text — the characteristics of any one
situation may apply to a reviewer at present, or at some point in the
future, regardless of his or her current situation.
 One way to go about environmental impact assessment review in a
 proactive manner is to approach the initial review as a series of
 sequential steps. For example (adapted from Shipley Associates,
 1991. NEPA Executive Overview, Workshop Manual, p. 3-5):

 1) If the reviewer learns of a proposed project but does not know if
    an erivironmental impact assessment is planned, he or she should
    determine in a general sense whether a proposed project may be
    significant enough to have an environmental impact assessment
    If so,
 2) Contact the project proponent and a) Determine if theproponent
    planned to conduct an environmental impact assessment^ b) If not,
    inform that they may be required to, or c) If planned.; notify them
    that he or she will be involved in evaluating the environmental
    impact assessment,
 3} Take Steps to help ensure that both the project proponent and the
    reviewing agency will have sufficient time to analyze all
    documents and provide sufficient comments,
 4) Identify any government agencies (national and local) that should
    be included in the review, such as agencies responsible ibr issuing
    permits on the proposed project, or agencies that could help with
    the analysis,
 5) Develop a strategy to involve the public and any stakeholder
    groups in the environmental impact assessment process,
 6) Determine whether the reviewer's agency has the resources
    (including time, funding, personnel, and expertise) to conduct the
 .   assessment or whether to contract all or part of it to a company
    with sufficient resources,
 7) Select the interdisciplinary team leader and members ifthe agency
    will conduct the assessment and write the document
 Any of the four situations can be linked to decision making in various
 ways:

 •  Little relationship to decision making: hi some settings, a reviewer
    may only be asked to look for technical completeness and adequacy
    of an environmental impact assessment document with little apparent
    influence over decision-making or outcome;

 •  Direct linkage to decision making: hi some settings, the reviewer
    may be the decision-maker, while in others, the reviewer makes
    recommendations to the decision-maker.  The reviewer may also
Reviewers may or may not be
involved decision making.
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 Chapter 3 - Overview of the Reviewer's Responsibilities
     define permit conditions, mitigation requirements, or other
     conditions on the proposed project;

 •   Direct linkage to project follow through: hi some settings, the
     reviewer may be responsible for monitoring the environmental
     impacts of the proposed project during construction and after
     completion, or for monitoring compliance with mitigation plans.

 This will vary from country to country, and from institution to institution.
 In the United States, the U.S. Environmental Protection Agency (EPA)
 has been charged by Congress to review environmental impact
 assessments (called Environmental Impact Statements) prepared by other
 federal agencies to assess the environmental impacts and the adequacy of
 the analyses. The EPA provides comments which are made public to
 avoid or mitigate impacts and improve the rigor of the analyses and
 consideration of alternatives, but the ultimate decisions are made by the
 responsible federal agency. EPA does not have the legal authority to
 stop a proposed project because of objections about potential
 environmental impacts. Nevertheless, because EPA's comments are
 made public, and because citizens have a right to sue, EPA's reviews and
 ratings as to the adequacy of an environmental impact assessment
 document and the acceptability of the  environmental impacts associated
 with a proposed project have significant influence on the process. In
 contrast, Mexico and many other countries in Latin America and Europe
 empower the government agency responsible for reviewing the
 environmental impact assessment with the legal authority to directly
 approve the project, approve the project with conditions, or deny the
 project.

 3.3  REVIEWERS AND REVIEW TEAMS

 3.3.1 Characteristics of a Good Reviewer

 Some of the characteristics most useful in the review of a particular
 environmental impact assessment will depend on the specifics of the
 environmental impact assessment under review. However,
 generalizations  can be made about useful characteristics of reviewers of
 environmental impact assessments.

 It is  helpful to have a broad understanding of science, as well as personal
 capabilities and orientations which are discerning, professional, and
 systematic. A good reviewer combines basic technical knowledge with
 sound judgement, common sense, and  a logical thought process.

A good reviewer can:

 •  Develop and apply a broad understanding of environmental and
    social sciences and economics in identifying potentially relevant
                         In the U.S., the EPA does not
                         have the authority to approve
                         or disapprove a project due to
                         concerns about potential
                         environmental impacts. This
                         is done outside of the context
                         of the EIA within relevant
                         permits and other authorities
                         for project approval. In
                         contrast, many countries in
                         Latin America and Europe
                         empower the government
                         agency to disapprove
                         environmentally unacceptable
                         projects.
                         Characteristics of effective
                         reviewers:

                         - Knowledge
                         - Sound judgment
                         - Common sense
                         - Logical thought process
                        A good reviewer should
                        prepare for the job.
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                                      Chapter 3 - Overview of the Reviewer's Responsibilities
    issues and to discern the true significance and relative importance of
    these issues;

•   Develop and manage a formal or informal set of associate reviewers
    who are called upon to assist when their expertise is required;

•   Develop and manage an informal network of "experts" in a variety of
    fields who can answer specific questions that may arise during
    review of environmental impact assessments;

•   Establish a broad understanding of development and policy activities
    within the geographic area of concern;

•   Take steps to help ensure ready access to environmental impact
    assessments that may have been developed on similar projects, either
    within country or internationally;

•   Understand the context of each environmental impact assessment,
    including the key players, their perspectives, and the history of the
    proposed project; and

•   Negotiate: Creating a sound environmental impact assessment to
    facilitate decision-making and using the environmental impact
    assessment process to improve and have an impact on decision-
    making is a creative process of negotiation. In the vast majority of
    cases, a reviewer is bargaining for alternative mitigation measures.
    In those instances in which new alternatives should be considered
    (either because the purpose and need are not supported, or because
    the purpose and need are supported but the adverse impacts are
    significant even with mitigation and alternatives have been
    overlooked), to be most effective, the reviewer should be able to
    offer other alternatives.

3.3.2 Expertise

Many individuals approach the position of being a reviewer of an
environmental impact assessment concerned that they lack adequate
technical knowledge and expertise. However, a good reviewer need not
be an expert in all areas of review. It is helpful to be knowledgeable in at
least one technical discipline to understand the nature of how technical
disciplines, assumptions, selection of models, and analytical methods are
made to apply to a given circumstance, and to ask questions confidently
of technical analyses. It is not necessary for a reviewer to be an expert in
every discipline covered in an environmental impact assessment.

A reviewer should have a sufficiently rigorous technical background to
question the environmental impact assessment, as well as good general
knowledge of his/her agency's regulations and authorities. As noted
earlier, the lead reviewer in particular should be a generalist who is
A good reviewer need not be
an expert in all areas of review
 The lead reviewer should
 be a generalist
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 Chapter 3 - Overview of the Reviewer's Responsibilities
 knowledgeable about the environmental or other relevant fields and who
 can identify experts as needed. Generalists are often better lead
 reviewers than individuals with expertise in one narrow technical field
 because a reviewer who is an expert in only one field can have a
 perspective that is sometimes too narrowly focused on that field. This
 does not mean that an expert is necessarily an ineffective lead reviewer,
 but that effective lead reviewers also possess the skills of a generalist and
 facilitator.

 If a reviewer feels that he or she is lacking in a critical area of technical
 expertise, he or she can and should correct the area of deficiency. It is
 possible to develop technical skills in a variety of ways, ranging from
 formal academic training to careful review of technical literature and
 documents and communication with experts  in the field. It is particularly
 important to understand and develop credibility in communicating with
 others about technical issues related to prediction and measurement and
 ways to address environmental impacts. In general, a reviewer's
 professionalism is enhanced by demonstrating understanding of
 systematic approaches, regardless of the particular discipline used to gain
 that understanding.

 3.3.3 Review teams:

 Due to the interdisciplinary nature of potential impacts, environmental
 impact assessments can involve highly complex and technical
 information, drawing upon the natural sciences such as atmospheric
 science, forestry, geology, and hydrology, as well as social sciences such
 as economics, sociology, and archaeology. Few individuals possess this
 range of expertise and experience.  How then can a reviewer actually
 conduct a review for coverage, significance, adequacy, integrity,
 accuracy, and to determine his or her proper influence?

 An environmental impact assessment review team is often created to
 ensure that review is sufficiently interdisciplinary in knowledge, skills,
 and background to adequately and correctly review all aspects of the
 environmental impact assessment.

 The review team can be comprised of a combination of technical experts
 in specific disciplines, generalists who can maintain a sense of the "big
 picture," and facilitators working to ensure that the review is completed
 on-time and includes all relevant groups and individuals. Thus, if
 economic and historic issues are included in the environmental impact
 assessment, the team may have to include economists and historians.  It
 will almost certainly include environmental scientists, biologists and
 others from the natural sciences.

 The review team can consist solely of individuals from within a single
 agency, or it can include reviewers from other agencies, outside technical
 experts, and consultants or contractors.  The lead reviewer is responsible
                       •  Reviewers can remedy
                          deficiencies in technical
                          knowledge in a number of
                          ways
                         Few individuals possess
                         adequate knowledge in ALL
                         areas necessary for
                         environmental impact
                         assessment review.  A team
                         approach ensures that the
                         maximum amount of relevant
                         knowledge and skills are
                         brought to bear on an
                         environmental impact
                         assessment
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                                      Chapter 3 — Overview of the Reviewer's Responsibilities
for determining whether in-house technical expertise will be sufficient,
and for recruiting reviewers from other agencies or outside consultants if
gaps in the review team's time availability or expertise are identified.  In
addition, it is also often useful to include stakeholders and other
interested parties in the review of the environmental impact assessment
document. In the U.S., this inclusion is required by law.

Good lead reviewers in particular tend to have the following
characteristics:

•   A generalist or an individual who is able to identify and consider a
    broad range of issues (i.e., does not get too focused on a specific
    issuejs]);
•   Some understanding of technical issues in the environmental field;
    and
•   A good communicator, facilitator, and networker who can effectively
    draw upon the expertise of numerous colleagues or other individuals
    proficient in one or more technical.

3.3.4 Technical Experts

hi addition to lead and additional reviewers (including technical experts)
from within the agency formally responsible for reviewing an
environmental impact assessment, it is sometimes necessary to bring in
outside experts to review certain aspects of an environmental impact
assessment.  Such experts can be brought in for a short period oftime to
review a small part of an environmental impact assessment, or they can
be retained for the entire review period, depending on the review needs.
Outside experts can include researchers from academia, from other
government agencies, non-profit organizations, and consulting firms.
The use of technical experts is common and can be a valuable component
of environmental impact assessment review.

3.3.5 Preparing for the Reviewer Role in General

    It is helpful to do certain things to prepare for the job:
    •    Understand the legal, institutional and organizational context
         of the position;
    •    Obtain and thoroughly understand any applicable regulations,
         guidelines and policies;
    •    Read a few environmental impact assessments on a range of
         types of projects;
    •    Develop a broad understanding of the geology, geography,
         environmental features and quality issues, development patterns
         and pressures, and socio-economic and cultural features of the
         region;
    •    Identify sources of expertise, including reference materials,
         resident experts, academic institutions, and public and private
         resources;
Technical experts can be
brought into a review process
to review sections of an
environmental impact
assessment where their
expertise is necessary
Preparing for the reviewer
role
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 Chapter 3 — Overview of the Reviewer's Responsibilities
    •   Identify stakeholder groups, and public interest groups having
         expertise and interest in the environment and development; and
    •   Wherever possible, get to know others to turn to on a personal
         level, so subsequent inquiries or solicitations of advice may be
         more welcome and they may be more likely to be responsive to
         requests for assistance or advice.

3.4 REVIEWER'S ROLE IN EACH ELEMENT OF THE ENVIRONMENTAL
    IMPACT ASSESSMENT PROCESS

An environmental impact assessment will typically include
documentation of each stage of the environmental impact assessment
process.  Each stage raises different types of issues and opportunities for
the reviewer which will be highlighted below. The focus is on what a
reviewer's role might be if involved in that stage of the process. The
following stages are reviewed (see also the environmental impact
assessment flowchart in Chapter 2):

•  Decision to Proceed Activities to identify significant impacts and
    determine the need for an environmental impact  assessment;
•  Draft Environmental Impact Assessment;
•  Final Environmental Impact Assessment;
•  Decision-making: record of decision; and
•  Post-project approval monitoring.

To help keep reviewers "on track" during each stage of review, a set of
road maps have been created to accompany this text. To facilitate their
identification, road maps are boxed off from the rest of the text, and are
indicated by the icon located in the right-hand margin.

3.4.1  Decision to Proceed Activities: Deciding Whether a Proposed
      Project is Subject to Environmental Impact Assessment
      Requirements

One of the most important stages in the environmental impact
assessment process is the initial one: determining whether a proposed
project may have environmental impacts  potentially significant enough to
require a full environmental impact assessment. This determination is
made consistent with requirements of applicable environmental impact
assessment laws and procedures, which differ from country to country.
In some countries, the decision to proceed with an environmental impact
assessment is mandated even if the potential for significant
environmental impacts is relatively low.  In other countries, the potential
for significant environmental impacts must be high before an
environmental impact assessment is required. Laws and regulations may
also mandate environmental impact assessment for certain types of
impacts or affected environments, but not others. In  still other countries,
there are no requirements for environmental impact assessments at all.
In summary, initial and full environmental impact assessments are
                      • Each stage of an
                        environmental impact
                        assessment raises different
                        types of issues that the
                        reviewer has to deal with
                        The "Road Map" icon in this
                        text identifies guidelines to
                        keep the reviewer on track.
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                                      Chapter 3 — Overview of the Reviewer's Responsibilities
required under different circumstances in different countries. In addition,
countries that mandate environmental impact assessments differ
regarding the extent and type of assessment required for different types
of projects, potential environmental impacts, and affected environments.

During the decision to proceed stage, project proponents often conduct
an initial environmental impact assessment to determine whether the
potential for significant adverse environmental impacts is high enough to
require a full environmental impact assessment.  Alternatives may or may
not be identified or evaluated, depending on the legal or institutional
setting.                                                          ;

It is often difficult to distinguish the kind of assessment involved in an
initial environmental impact assessment from a full blown environmental
impact assessment.  Often the same information is relevant and the
distinctions come from the depth of assessment, generation of new
information, identification and systematic consideration of alternatives,
and public participation. However, these lines are often blurred. In
general, the initial environmental impact assessment is an internal
process, without the benefit of external comment.

Some of the following distinctions may or may not apply in individual
projects, different organizations and countries:
Reviewer's Role in Review of Initial and Fun
-Environmental Impact Assessments:
Initial Environmental Impact
Assessment
Usually internal to the organization
Scoping is done internally
Alternatives to proposed project
may or may not be included
May include proposed mitigation
to avoid significant impacts that
would trigger an environmental
impact assessment
Often does not include new
information gathering
Full Environmental Impact
Assessment
(based upon international framework
elements)
Includes external review and public
participation
Scoping involves the public and
interested parties
Alternatives, where required by law,
are always considered and
systematically assessed
Always includes mitigation plans
Often includes gathering new
information
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Chapter 3 - Overview of the Reviewer's Responsibilities
During the decision to proceed with an EIA, the role of the reviewer is to
determine:

•  Whether all potentially significant environmental and other impacts
    were correctly identified by the project proponent, or whether
    potential impacts were overlooked;
•  Whether information is sufficient to determine whether impacts
    identified are significant; and
•  Whether the magnitude of potential environmental or socio-economic
    impacts was assessed, and if so, whether it was assessed correctly,
    including whether the models, assumptions, and scenarios were
    valid.

After conducting an initial environmental impact assessment, a project
proponent may claim that the potential for significant adverse
environmental impacts is too low to warrant a full environmental impact
assessment.  If a reviewer is satisfied after conducting his or her review
of the initial environmental impact assessment document that claims of
no significant potential impacts are valid, he or she may simply agree and
cease involvement. However, if there is doubt as to whether the impacts
will be significant or not, a full environmental impact assessment may be
required of the project proponent or more information or data sought.  In
the United States, for example, there is a presumption that if information
is not sufficient to find the impacts are insignificant, then an
environmental impact assessment needs to be developed and the process
applied.

A reviewer who is either proactive, or who has oversight responsibility
for compliance with the requirements of environmental impact
assessment within an institution, would be more aggressive in seeking
out projects which require these decision to proceed activities and
working with the project proponents to establish clear steps for planning
and carrying out the initial assessment.

3.4.2 Draft Environmental Impact Assessment Documents

Drafts of environmental impact assessment documents are often
produced in order to provide an opportunity for reviewers and
stakeholders to evaluate a proposed project with substantial information
at their fingertips. This is required in most countries and institutional
settings (such as the U.S.), while in others it may be voluntary.  It is at
the time of review of a draft environmental impact assessment that a full
review of the proposed project's purpose and need, range of alternatives,
assessed environmental and socioeconomic impacts, suggested mitigation
measures and the selection of a preferred alternative can be fully
evaluated and critiqued.
                         If there is doubt as to whether
                         the environmental impacts of
                         a proposed project will be
                         significant, a full
                         environmental impact
                         assessment may be required
                         The preparation of draft
                         environmental impact
                         assessment documents is
                         required in some countries and
                         voluntary in others
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3.4.2.1   Scoping: Environmental Impact Assessment Document
         Development

While a reviewer must always try to preserve his or her independence and
objectivity, in general, it is advantageous for reviewers to become
involved as early as possible in the environmental impact assessment
process to ensure the best product for review and decision making.
However, the reality is that reviewers are often not involved in the
scoping process. They may not have learned of the proposed project
until later in the process, or they may have decided that sufficient
resources were lacking for participation. A  lack of involvement during
the scoping process is almost always less desirable compared to
involvement. In other words, the longer the assumptions, findings, and
alternatives present in an environmental impact assessment go
unquestioned and unchallenged, without critical and objective review,
the harder it is to convince the project proponent or others to alter them,
even if there are perfectly good reasons to do so.

To preserve independence and objectivity and avoid misunderstandings.
a reviewer must be careful to make it clear that early involvement in
scoping does not mean or guarantee that the reviewer will not have
comments to make later in the process or that the proposed project will
be acceptable as proposed. In fact, reviewers often make comments at
later stages in environmental impact assessment review, whether or not
they were involved in scoping.

hi some countries and circumstances, it may appear unlikely that
environmental agency officials who conduct environmental impact
assessment reviews will be allowed to engage in the scoping phase with
those of other ministries or departments or the private sector. This can
be true for political and organizational reasons, both historic and
interpersonal. There may be, however, opportunities either to convince
the key players of the potential benefits of early involvement, or to offer
an opportunity for an isolated experiment or pilot to gain more
institutional experience and acceptance of the idea. As noted earlier, this
course will not attempt to cover all potential differences between
environmental impact assessment processes in all countries and their
institutional settings. The point here is that it may be possible to
implement a more effective review than it may appear initially —
creativity and a positive attitude can sometimes accomplish as much as
technical expertise and rigor, particularly when the overwhelming
benefits of early involvement of the reviewer are conveyed to the project
proponents.

A concern that reviewers may have is whether early involvement may
lead to a lack of independence in subsequent review of the environmental
impact assessment product. As stressed earlier, it is critical for the
reviewer to remain professional and objective.
•  It is advantageous for
   reviewers to become involved
   as early as possible in the
   environmental impact
   assessment process
   A reviewer must make it clear
   that early involvement does
   not automatically imply
   agreement with the contents of
   the environmental impact
   assessment document
   Early involvement does not
   have to result in a lack of
   independence
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 Chapter 3 - Overview of the Reviewer's Responsibilities
 Experience has demonstrated that getting involved late in the process
 only makes it more difficult to do the job of the reviewer if the
 environmental impact assessment document is deficient. Any conflict
 early in the process associated with early reviewer involvement would
 usually be more than offset by the far more intractable conflicts that
 would have emerged when final findings are challenged.

 There are numerous benefits that accrue to the project proponent when
 reviewers are allowed to participate in scoping. Involvement in the
 scoping stage allows a reviewer to shape the assessment, including scope,
 purpose, alternatives and type of evaluation. Among the benefits of
 reviewer involvement in scoping, the reviewer can help:
    Explain the use of environmental impact assessment as a planning
    tool;
    Identify important environmental and other issues early;
    Help locate specific information or data related to the area of
    interest;
    Suggest others appropriate to involve in scoping process;
    Assist in ensuring an adequate range of alternatives is identified;
    Suggest specific alternatives to the proposed project that may avoid
    potential adverse impacts, including suggestions for an
    environmentally preferred alternative;
    Refer to publications, including guidelines and current research, that
    would be useful in analyzing the environmental impact of various
    alternatives;
    Identify mitigation measures that should be considered to reduce or
    substantially eliminate potential adverse impacts;
    Suggest specific assessment techniques and methodologies that
    might be used and those that may not be appropriate;
    Take steps to help ensure that time and/or resources are not wasted
    on trivial issues;
    Try to ensure that the environmental impact assessment is balanced
    and thorough. This will avoid delays that would arise later if the
    document is found to be significantly lacking; and
    Review to ensure that the required permits for the proposed project
    (e.g., wastewater discharge, waste disposal, building) are identified
    and discussed and input from the appropriate agencies is considered.
All of the above can benefit the project proponents, saving them time and
money, and potentially salvaging a proposed project that might have
otherwise been prevented by the reviewing agency in the end due to
unacceptable project components.  A reviewer who makes these benefits
clear before scoping has begun or early in the scoping phase may be able
to gain entry even in situations where reviewers normally are excluded.
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How to become involved in scoping:

•  Watch out for or take steps to help ensure receipt of formal
    announcements of projects;
•  Watch out for or try to ensure receipt of invitations to public
    meetings;
•  Watch out for news reports of planned activities;
•  Arrange for meetings with the contractor and the project proponent
    prior to preparation of an environmental impact assessment; and
•  Where possible, attend meetings with contractors and consultants
    throughout preparation of the environmental impact assessment.

Review of an Environmental Impact Assessment Document for
Adequacy of Scoping. After the Fact

Regardless of the degree to which scoping was carried out, the project
proponent should document what was done, and the extent to which
outside reviewers were involved. This is important information for
reviewers, because it provides background on the process that led to the
proposed project, and can help a reviewer determine whether scoping was
adequate.                                      ,....:.

Often a reviewer will not begin review of an environmental impact
assessment until  after the scoping phase has come to a close. In such a
case, how does he or she determine if the full range of issues were
addressed, or that a breadth of information and perspectives were
considered?  The reviewer should carefully review the environmental
impact assessment to determine the answers to the following questions:

•  Who was involved or consulted in the process of preparing the
    environmental impact assessment and how? Were the perspectives
    and concerns of any key stakeholders excluded?
•  Was an opportunity provided to solicit the views and assessments of
    important stakeholders that should have been involved?
•  What issues might have been raised, whether they were identified
    and addressed or not, by groups without an economic interest in the
    proposed project?  This is crucial given the importance of the
    environmental impact assessment process in providing public
    involvement in activities that will affect their futures; and
•  Within the bounds of appropriate professional conduct and
    neutrality, the reviewer might also:
    -   Suggest to the project proponent and environmental impact
        assessment preparer that they could involve a certain group in
        the process or solicit its concerns and ideas on alternatives, as
        well as how to avoid or mitigate potential environmental or
        other impacts; and
    -   Make sure that as many of the relevant stakeholders are
        involved as is possible by alerting concerned groups to the
        proposed project and suggesting they get involved.
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Chapter 3 - Overview of the Reviewer's Responsibilities
                  Road Map for Scoping Review

          Scoping was conducted and documented

          Potentially significant issues are identified for natural and
          human environments

          Insignificant issues identified and their dismissal justified

          Identified and considered the views of all interested and
          affected parties

          Sufficient detail provided to define the spatial and temporal
          scope

          Adequate geographic area considered for the scope

          Omissions are not related to significant issues

          Key issues are brought into focus
3.4.2.2   Involving Stakeholders and Other Interested Parties

Involving all stakeholders and providing for public participation is a key
element of environmental impact assessment and critical to decision-
making which seeks to integrate economic, social and environmental
concerns.  Some, but certainly not all, countries have adopted legal
requirements to involve all interested parties in the environmental impact
assessment process such as community leaders and groups, business
interests, other government agencies and non-profit organizations. It is
typically advantageous to involve these parties throughout the
environmental impact assessment process even without a legal
requirement to do so to ensure that adequate information is brought to
bear on all decisions made, and that potential problems are avoided.
Where there is public participation and comment, it provides a reviewer
with another means of critically reviewing the environmental impact
assessment. Reviewers should make every opportunity to obtain and
review these comments distinct from any formal environmental impact
assessment document if they are not included within it.

Outside involvement in environmental impact assessment review is not a
standard practice in  some countries. In other cases, even where outside
involvement is welcomed, some stakeholders will not have adequate
resources to effectively represent their group's interests. It is the
responsibility of the reviewer to take steps to help ensure that the views
                      •  Some, but not all, countries
                         have adopted legal
                         requirements to involve all
                         interested parties in the
                         environmental impact
                         assessment process
                      •  Outside involvement in
                         environmental impact
                         assessment review is not a
                         standard practice in some
                         countries
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                                       Chapter 3 — Overview of the Reviewer's Responsibilities
 of all relevant groups are fairly presented and considered in the decision-
 making process, including those groups that lack resources or a formal
 voice in the process. How is that done?  Some of the ways a reviewer
 might ensure these outside perspectives are considered include:

 •        Identify public participation requirements and expectations for
          involving certain stakeholders in early communications with
          the project proponent or its representatives if appropriate;
 •        Read local newspapers, newsletters from community groups,
          and other written materials that may provide information on
          community concerns and priorities;
 •        Attend meetings of local citizens' groups and other groups
          that involve people from the community;
 •        Post announcements of upcoming environmental impact
          assessment-related meetings that are open to outsiders, if
          appropriate to the reviewer's role;
 •        Use an informal network of organizations and individuals to
          provide added local or environmental perspective; and
 •        Think about who might have concerns and why when
          reviewing the description of scoping in environmental impact
          assessment documents and adopt the various perspectives of
          interested parties during review.

 Some or all of these may or may not be appropriate to a particular
 reviewer, and certainly mere  are more ways than those listed above.

 The benefits of communication with and involvement of all interested
 parties are so important that the expenditure of extra effort on their
 behalf is usually warranted. This is particularly true in the context of
 environmental impact assessment review because technical experts and
 other specialists can often overlook important facts or areas of
 investigation that local citizens and groups are more aware of because of
 their proximity to the potentially affected environment and their stake in
 the outcome.  By keeping the public and other stakeholders involved,
 there is a better chance that all important issues will receive adequate
 attention.

3.4.2.3 Preparing  Comments on a Draft EIA Road Map

Reviewer responsibilities differ from country to country, but a reviewer
should provide clear and concise comments on any draft environmental
impact assessments if presented for review. The reviewer may be called
upon to do one or more of several things with the draft:

•        Establish a schedule that allows time to consolidate and
         resolve any discrepancies in the comments provided by
         reviewers;
Technical experts and other
specialists often overlook
important areas of
investigation of which local
citizens and groups are aware
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•        Identify appropriate colleagues to provide input on the draft
         environmental impact assessment and send it out for formal
         review with a specified timetable for response; and
•        Draft a comment letter on the environmental impact
         assessment which provides a clear and concise description of
         the government agency's substantive and/or procedural
         concerns, if any, and recommendations for addressing the
         concerns. This letter might include the following:
         -      An evaluation of the adequacy of the supporting
                 information that was provided in the environmental
                 impact assessment;
         —      An evaluation of the completeness of the purpose and
                 need, alternatives, background information, impact
                 assessments, mitigation proposed and requirements or
                 suggestions for additional information needed, when
                 necessary;
         -      If a rating system is used, a rating of the potential
                 impact of the proposed project and the adequacy of
                 the analyses;
         -      Discussion of any concerns regarding the
                 methodologies in preparing the environmental impact
                 assessment (e.g., predictive models of pollutant
                 transport and fate, economic analysis and treatment of
                 unquantified environmental impacts, values, and
                 amenities);
         -      Additional information sources, including other
                 documents, studies, or onsite surveys to review;
         -      Possible mitigation measures to eliminate, prevent,
                 avoid, minimize, or reduce damage to the environment
                 or to protect, restore, and enhance the environment.
                 Suggestions should focus on mitigation measures that
                 will have a long-term effect, are technically feasible,
                 and are economically viable;
         -      Potential impacts that may lead to possible violations
                 of national environmental standards or that may
                 preclude or bias future issuance of environmental
                 permits; and
         -      Identification of an environmentally preferable
                 alternative, particularly if significant impact(s)
                 associated with the proposed project or preferred
                 alternative cannot be mitigated adequately or are less
                 desirable.  This may be a new alternative.
                 Alternatives, like mitigation measures, should be
                 reasonable and feasible.

It is important to realize that reviewers have resources to draw upon to
accomplish an effective review. One of the most important resources can
be the reviewer checklist presented in Appendix A. As the proceeding
discussion  makes clear, there are numerous components that must be
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                                      Chapter 3 — Overview of the Reviewer's Responsibilities
 kept in mind during review of draft environmental impact assessment
 documents. The same is true of final documents. The reviewer checklist
 was created to help ensure that the review is systemmatic and
 standardized across different types of projects. In addition to the
 checklist, Appendix B presents a matrix describing a wide range of
 environmental impact assessment methodologies; Appendix C-2
 presents a number of tools for identifying significant issues; and
 Appendix D presents tables of contents from two environmental impact
 assessment tools available to participants in the course Principles of
 Environmental Impact Assessment Review, a Resource Manual and a
 CD ROM, as well as  a summary of their content.
  Road Map for Draft Environmental Impact Assessment Review

  •      Establish a management approach:
                 Establish lead reviewer
                 Assign roles
                 Establish a schedule
                 Conduct Review

  •      Consolidate reviewers'comments:
                 Identify most significant issues
                 Determine the significance of each comment
                 Establish common threads
                 Resolve any discrepancies

  •      Draft a comment letter:
                 Maintain neutrality, objectivity and professionalism
                 Provide clear and concise comments

 _•	Anticipate and respond to public comment	.
3.4.3 Final Environmental Impact Assessment Documents

The same considerations listed for reviewing draft documents apply to
final environmental impact assessment documents. Responses to
comments on a draft document may be mandatory or voluntary.
Reviewers should always review the final environmental impact
assessment, even if they reviewed and commented on a draft, or even if
there were no objections to the draft. This is true for several reasons:

•        If there were no objections to drafts, the reviewer still needs to
         verify that nothing substantive changed between the draft and
         the final document, including the assumptions and predictive
         models utilized;
Reviewers should always
review the final environmental
impact assessment, even if
they had no comments on, or
objections to, earlier drafts
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•        The reviewer also needs to review the proponent's responses
         to comments submitted on the drafts; and
•        If there were objections to drafts, the reviewer needs to take
         steps to help ensure that they were addressed.

In most situations, the reviewer will develop comments on the final
environmental impact assessment as a matter of course. These
comments can focus on unresolved issues, particularly on the potential
impacts of the proposed project and the scope of review. Comments may
focus on issues raised in the comments on drafts, as well as on new
issues that either arose  since then or that the reviewer now identifies due
to new information.
                        Reviewers almost always
                        make comments on final
                        environmental impact
                        assessment documents
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                                      Chapter 3 - Overview of the Reviewer's Responsibilities
                       Road Map for Final
            Environmental Impact Assessment Review

          Establish a management approach

          Determine if basic assumptions and information are the same
          for draft and final

          Assess impacts of any changes on alternatives, impacts and
          proposed mitigation

          Verify that comments were acknowledged and addressed

          Review the relationship and consistency among responses to
          individual comments

          Consolidate comments and prepare the final comment letter

          Determine whether responses change fundamental reviewer
          findings:
                 Acceptability of environmental impact
                 Needed mitigation
                 Adequacy of environmental impact assessment
                 document and process
                 Who needs to be involved and consulted

          Decide projects to increase chance of correcting remaining
          deficiencies

          Anticipate use by decision maker

          Anticipate use to establish mitigation requirements

          If appropriate, prepare final comment letter.	
3.4.4 The Role of the Reviewer in Decision-making

As noted above, the reviewer may or may not be a decision-maker,
depending upon the organization or institutional setting. However,
decision-makers who are not the reviewers themselves often rely upon
the reviewers to provide a clear basis for decisions without having to
wade through significant amounts of information. The reviewer is
therefore a very important person for decision making, and can draw the
key elements from the document for not only project approval, but also
•  Decision-makers who are not
   reviewers often rely upon
   reviewers to sift through large
   amounts of information and
   provide them with the key
   information necessary to make
   decisions
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 conditions for proceeding. He or she can also suggest consideration of an
 alternative from within the range offered or a new alternative which may
 better resolve potential conflicts. In most cases, the preparation of an
 environmental impact assessment is mandated by legislation, by
 institutions, or encouraged by practice to ensure that all relevant
 environmental and socioeconomic factors are taken into account during
 the planning of policies, programs or projects, particularly projects with
 the potential to significantly affect the environment or society. The belief
 is that informed planning and decisions will result in a project that meets
 the purpose and need to the satisfaction of the project proponent, and
 does so with minimal negative environmental and socioeconomic
 impacts. Informed planning is also a cornerstone for sustainable
 development.

 The environmental impact assessment process is meant to be a tool for
 use in sound decision-making. It is not intended to be a "paperwork
 exercise" with no bearing on the decision-making process. The
 environmental impact assessment process should occur in conjunction
 with all aspects of a proposed project, from its conceptualization all the
 way through its completion and  beyond.

 Influencing the Decision-Making Process

 The approach in this text is to offer practical tips as well as theory
 concerning the realities of doing the job of environmental impact
 assessment review in a variety of settings. However, this approach
 fundamentally assumes there is some level of acceptance of the
 environmental impact assessment process by the involved parties.  This
 is not always the case. In the extreme, for example, it was once reported
 that country officials brought in new contractors when they did not like
 the information or outcomes reported in an environmental impact
 assessment simply because they contradicted the officials' desired
 outcome.  In that case, the reviewer was left only with the possibility of
 reviewing a poor product.  Such situations are rare but they do occur.
 These sorts of problems are not  explicitly addressed within this text.
 More common, and addressed here, is the situation in which resources for
 conducting a sound environmental impact assessment review are limited,
 and in which reviewers, while in a position to improve the assessment,
 must also learn to work with what is available.  They must also learn how
 to be in a better position to influence the development of a sound
 environmental impact assessment.

Maintaining Objectivity

 It is important for the reviewers of environmental impact assessments to
 be committed to long-term environmental and social health and stability.
 With this commitment, however, comes the risk of getting too personally
 involved. It is important to remain committed to the environmental
 impact assessment review process and not become either emotionally
                      • The environmental impact
                         assessment process is meant
                         to be a tool, not a "paperwork
                         exercise"
                      • Reviewers face different
                         constraints to their ability to
                         influence environmental
                         impact assessment
                         preparation in different
                         countries. Even if there are
                         many constraints, reviewers
                         can usually find ways to
                         influence the environmental
                         impact assessment process in
                         substantive ways
                          Reviewers must always
                          remain objective and
                          independent in their
                          reviews of environmental
                          impact assessment
                          documents
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                                       Chapter 3 - Overview of the Reviewer's Responsibilities
attached to a particular outcome or overly influenced or persuaded by an
interested party. To preserve independence and objectivity, a reviewer
should do two things:

•        Communicate clearly up-front that input from a reviewer is not
          tacit approval, and is not definitive; an independent review
          will follow, and the reviewer will be free to raise issues that
          may have been overlooked in the absence of all the
          information; and
•        Maintain neutrality and professionalism throughout the
          process.

Often the best approach is to continually reassert the reviewer's
neutrality to all parties.  The professionalism and neutrality of a reviewer
will help ensure a balanced, effective decision-making process. In fact,
the reviewer is often referred to as an "independent" reviewer, and that
independence and neutrality are important to supporting the decision-
making process.

3.4.4.1    The Record of Decision

A Record of Decision is the document that contains the reviewer's
decisions on project approval, denial, or conditional approval (if such
authority exists in a particular legal or institutional setting). The  term
Record of Decision may have different names in different countries, and
this particular term is used in this text as a simplification.

The Record of Decision is the final decision on the project by the
responsible agency or project proponent and may or may not be open for
public comment. Within the United States, for example, it is possible for
a member of the public to obtain a copy of a Record of Decision,
although it is not required to be publicly disseminated.

In some countries, project proponents are required to select and
implement the environmentally preferred alternative. In such settings, it
is important for the reviewer to check to make sure the Record of
Decision indicates selection of the environmentally-preferred alternative.
In other countries, like the United States, only the environmental
consequences of the proposed project must be considered during decision
making, whether or not the environmentally preferred alternative  is
selected.

A Record of Decision should contain the following:

•        A clear statement of which alternative was selected and a
          justification of why it was selected;
•        A summary of alternatives considered;
Often the best approach is to
continually reassert the
reviewer's neutrality to all
parties
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 •        A description of any conditions for approval (mitigation and
          continuing monitoring or other such requirements) that have
          been set;
 •        A discussion of concurrent regulations and laws and whether
          the proposed project will be in compliance with them;
 •        A demonstration that the environmental impacts of the chosen
          alternative were fully considered in the decision-making
          process;
 •        A demonstration that the benefits of the proposed project
          outweigh the adverse impacts of the proposed project; and
 •        A demonstration that implementation of the proposed project
          will be as environmentally acceptable as possible.

 A reviewer may or may not be the decision maker reviewing the Record
 of Decision. However, whether a reviewer requests an opportunity to
 comment on the Record of Decision is usually up to the discretion of the
 reviewer. The decision maker may in fact welcome positive comments
 on the Record of Decision as support for the proposed project, if they
 have been responsive to previous comments which were negative.
           Road Map for Record of Decision Preparation

          Re-state the purpose and need

          Support preferred alternative and justify
                 Meets purpose and need
                 Either preferred environmentally or meets purpose
                 and need better than other alternatives
                 Meets legal requirements
  •      Demonstrate all potentially adverse impacts from the selected
          alternative were fully considered

  •      Demonstrate benefits of proposed project outweigh adverse
          impacts

  •      Demonstrate that implementation of the proposed project will
          be environmentally acceptable

  •      Identify mitigation measures and continuing responsibilities.
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3.4.5 The Role of the Reviewer in Post-Decision Monitoring and
      Follow-up

In the case of proposed projects that will require significant mitigation
measures, the reviewer should review plans to follow up on the
implementation of mitigation after the environmental impact assessment
process is complete. For example, if the reviewer has sufficient
authority, he or she may require a monitoring plan. This can be an
effective way to ensure that the environmental impact assessment results
in a desirable outcome, and is not merely a paperwork exercise.
3.5
COMMUNICATING THE FINDINGS OF THE REVIEW
To effectively carry out the role of the reviewer, the reviewer must be
able to clearly communicate, both orally and in writing, the results of the
review in a clear and convincing manner.  The reviewer needs to
understand and consider the following potential audiences for
communications; some or all of these may be applicable depending upon
the procedures, institutional, organizational and personal contexts within
which the reviewer carries out his or her responsibilities:

•        Project proponent: about the requirements of the process,
         timetables, initial environmental impact assessment results,
         scoping, results of review of draft environmental impact
         assessment, final environmental impact assessment, and
         decisions made.
•        Public:  about opportunities for comment, solicitation of
         comment, about the proposed project, the potential impacts,
         and decisions made.
•        Decision-makers: about the proposed project, the potential
         impacts, the preferred alternative, proposed mitigation and
         related conditions for approval, responsibilities and roles for
         follow up, and coordination of review.
•        Internal review team and affected government agencies:
         about the issues requiring review and comment, and the
         timetable for comment.

The reviewer needs to think about how to get the most important points
on the table, and to put all points into context in terms the audience will
readily understand. The challenges to reviewers include:

•        How to be comprehensive and thorough without losing the
         target audience of the communication in a sea of detail. It is
         helpful to develop attachments, to categorize
         comments as to their significance, mandatory versus voluntary
         changes, etc. Another useful measure when submitting
         comments on an environmental impact assessment is to
         distinguish between comments that are advisory and those that
         are obligatory (e.g., regulatory or otherwise required). This
                                                              The reviewer can help ensure
                                                              that post-decision monitoring
                                                              follows the measures specified
                                                              in the environmental impact
                                                              assessment
                                                              The reviewer must be able to
                                                              communicate, both orally and
                                                              in writing, the results of the
                                                              review in a clear and
                                                              convincing manner
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          will make the job of setting priorities for areas of correction
          within the environmental impact assessment an easier one for
          the project proponent. It will also often diffuse conflict
          between the project proponent and reviewer by clearly
          identifying potentially controversial comments or
          recommendations as advisory rather than obligatory.

 •        How to communicate consequences of failure to consider
          certain alternatives, mitigation, and/or impacts, etc.

 ป        When to seek face-to-face versus written communications, and
          how often to communicate, hi some instances, a reviewer has
          an opportunity to discuss comments before they are formally
          sent. While needing to ensure that such opportunities do not
          compromise objectivity and independence, they can provide
          the project proponent with an opportunity to correct
          deficiencies before he or she may be publicly embarrassed.

  One way to avoid being compromised is to have the formal written
  comments ready and final before such a meeting. A face-to-face
  meeting at that point can serve to help ensure that the reviewer
  understood everything he or she read; and it helps identify actions that
  would resolve the reviewer's concerns. It becomes an excellent point
  of leverage for a reviewer and an opportunity to establish a responsive
  relationship with the project proponent.  Many experienced reviewers
  advocate early, frequent communications with the project proponent
  and all interested parties throughout the review process to ensure the
  best product for decision-making, but such opportunities are costly in
  time and effort and need to be balanced against other demands of the
  job. hi most instances,  the comment letter or rating should not be
  modified after meeting with the project proponent unless the reviewer
  obviously made an error in his or her reading of the draft document.

  Frequently a reviewer can improve communications and lower the level
  of controversy and degree to which the process is adversarial if
  comments can be offered early and project proponents are offered an
  opportunity to meet and discuss the issues  and arrive at new ways to
  mitigate or correct problems. While this is accomplished, the reviewer
  must try to ensure the integrity of his or her independent review. One
  effective step toward achieving this goal is to ensure that higher levels
  of authority above the reviewer are apprized of the comments  and
  approach so that unhappy project proponents cannot easily lobby the
  reviewer against the issuance of the comments by the agency.
  Depending upon the organization's culture, it may be possible to share
  comments with those at a higher level to gain support in advance and
  better insulate the reviewer from influence  or pressure by the project
  proponent who may not be pleased with the comments.
                      •   Frequent communication
                          with the project proponent
                          and all interested parties is
                          highly beneficial, but needs
                          to be balanced against other
                          demands of the job
                         Offering comments early to
                         the project proponent can
                         lower the level of controversy
                         in the environmental impact
                         assessment process by
                         allowing the proponent time to
                         address the reviewer's
                         concerns
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•        Who should the reviewer involve if he or she is in a position
         and role which requires communications with the public? It
         will be important in these instances to take steps to help
         ensure that no one feels left out or unfairly treated. When in
         doubt about a particular party, invite them to participate.

ป        What government officials should be involved, and when? It
         is particularly important to include agencies that are
         responsible for monitoring the type of project proposed in the
         environmental impact assessment. Such agencies should be
         provided ample time to review both the environmental impact
         assessment and all reviewer comments to ensure that the
         project proponent is made aware of any difficulties that may
         arise from a monitoring or enforcement nature once the
         proposed project moves forward.

>        Whether and to whom to distribute comments:  Every agency
         typically has its own unique system for distributing comments
         on environmental impact assessments. When comments are
         distributed, it is critical to try to ensure that all concerned
         parties receive copies of drafts of the environmental impact
         assessment and of the final environmental impact assessment,
         document as well as all comments on the draft and final
         environmental impact assessment.

ป        Who should receive comments on an environmental impact
         assessment? The following groups or individuals should
         receive comments, at a minimum:
         -      Local, state, and federal officials, especially any
                agencies or individuals in charge of monitoring or
                compliance, the consulting firms involved, the agency
                where the reviewer works, and any stakeholder groups
                such as citizens' groups in the areas likely to be
                affected;
         -      Those the reviewer wants to influence;
         -      Those who will follow-up and provide assistance or
                advice; and
         -      As many other relevant groups or individuals as
                possible (it may be useful to have a checklist of
                generic types of groups or individuals).

 A final note on distribution of comments: It may be possible and
 advisable to use communication of review results to effect change and
 mitigation. Depending on who receives comments, individuals,
 groups, or agencies with an interest in the proposed project may decide
 to become involved in ensuring the proposed project does not entail
 undue environmental or other impacts. This may serve to further the
 goals of the reviewing agency.
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             Road Map for the Communication Letter

          State bottom line including major recommendations up front
          and clearly

          Describe proposed project context

          If the purpose and need of the proposed project is in question,
          develop the link to the environmental concerns

          Distinguish what is mandatory, what is significant

          Provide a description of the substantive and/or procedural
          concerns

          Demonstrate sensitivity to interests and affected community

          Provide recommendations for addressing the concerns
3.6       OVERCOMING OBSTACLES TO EFFECTIVE
          ENVIRONMENTAL IMPACT ASSESSMENT REVIEWS

Some of the most common frustrations reviewers express when
reviewing environmental impact assessments are as follows:

•         There are too many environmental impact assessments to
          review at the same time given limited staff and financial
          resources;
•         The decision to pursue a particular alternative in an
          environmental impact assessment seems to already have been
          made by the time the reviewer learns of the proposed project;
          and
•         Comments from reviewers are ignored or under-valued, due to
          the influence of the project proponent.

There are often several options that can be pursued to overcome common
obstacles to effective environmental impact assessment review. It is rare
that all comments and recommendations from a reviewer are adopted
and/or influence the product and final outcome. However, a reviewer's
input can make a profound difference by persuading a project proponent
to make small incremental changes over time that are cumulatively
important.

Every country and institutional setting is different, and each presents
distinct challenges and opportunities. A reviewer who steadfastly
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maintains neutrality and commitment to the environmental impact
assessment process as taught in this course can make a difference.

Words to the wise: Creativity, patience, and a positive attitude can go a
long way toward achieving the goals of the environmental impact
assessment process. Any reviewer can evaluate the particular
circumstances surrounding environmental impact assessment review in
his or her country and institutional setting and identify opportunities for
change or creative use of existing resources.
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                                                         Chapter 4 — Evaluation of Each Element
                    TABLE OF CONTENTS

4. EVALUATION OF AN ENVIRONMENTAL IMPACT
    ASSESSMENT DOCUMENT  	  4-1
    4.1  Approaches to Review: Reading an Environmental
        Impact Assessment: What to Look for  	  4-1
    4.2  Purpose and Need 	  4-4
        4.2.1  Review of Purpose and Need	  4-5
        4.2.2  Purpose and Need Review Road Map	  4-6
    4.3  Project Alternatives	  4-7
        4.3.1  Review of Project Alternatives  	  4-8
        4.3.2  Alternatives Review Road Map	  4-10
    4.4  Description of the Environmental setting  	  4-10
        4.4.1  Existing Physical-Chemical Environment  	  4-12
              4.4.1.1 Air Resources	  4-12
              4.4.1.2 Water Resources 	  4-14
              4.4.1.3 Soils and Geology  	  4-16
        4.4.2  Existing Biological Conditions  	  4-18
              4.4.2.1 Wildlife and Vegetation 	  4-19
              4.4.2.2 Community and Habitat
                     Characterization	  4-22
              4.4.2.3 Ecologically Significant Features  	  4-24
        4.4.3  Waste Management and Pollution Prevention  . .  4-27
        4.4.4  Socioeconomic Environment	  4-28
              4.4.4.1 Land Use	  4-29
              4.4A.2 Population and Housing	  4-29
              4.4.4.3 Economic Activity  	  4-30
              4.4.4.4 Community Services and Public Finance  4-31
              4.4.4.5 Transportation	  4-32
              4.4.4.6 Health and Safety	  4-32
        4.4.5  Cultural Resources	  4-33
        4.4.6  Reviewing the Description of the
              Environmental Setting Road Map	  4-34
    4.5  Potential Environmental Impacts 	  4-35
        4.5.1  Methods of Analysis	  4-37
              4.5.1.1 Determination of Significance	  4-38
              4.5.1.2 Cumulative  Impacts	  4-39
        4.5.2  Pollutant Generation, Transport, and Receptors .  4-40
              4.5.2.1 Air Resources	  4-40
              4.5.2.2 Water Resources 	  4-42
              4.5.2.3 Geological Resources	  4-45
              4.5.2.4 Biological Resources 	  4-46
        4.5.3  Habitat Alteration	  4-46
              4.5.3.1 Biological Resources 	  4-47
        4.5.4  Waste Management  and Pollution Prevention  ..  4-52
        4.5.5  Socioeconomic Impacts	 .  4-53
              4.5.5.1 Land Use	  4-54
              4.5.5.2 Economic Activity	  4-57
              4.5.5.3 Population and Housing	  4-58
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 Chapter 4 - Evaluation of Each Element
               4.5.5.4 Community Services and Public
                      Finance  	  4-59
               4.5.5.5 Transportation	  4-61
               4.5.5.6 Health and Safety	  4-62
               4.5.5.7 Environmental Equity	  4-63
         4.5.6  Cultural Resources	  4-63
         4.5.7  Assessment of Potential Environmental
               Impacts of Alternatives and of Their
               Significance Road Map	  4-64
    4.6  Mitigation and Monitoring Measures	  4-68
         4.6.1  Hierarchy of Mitigation Measures	  4-68
         4.6.2  Scope of Proposed Mitigation	  4-69
         4.6.3  Review of Mitigation and Monitoring
               Measures Road Map	  4-71
    4.7  Tools and Techniques for Environmental Impact Assessment
         Review  	  4-73
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                                                         Chapter 4 - Evaluation of Each Element
    4. EVALUATION OF AN ENVIRONMENTAL IMPACT
                  ASSESSMENT DOCUMENT
 Environmental impact assessment documents should present the
 necessary background information and results of all assessments
 conducted to assess the relative environmental impacts associated with
 all reasonable and feasible alternatives to the proposed project. An
 environmental impact assessment typically proceeds from the purpose
 and need of the proposed project, project alternatives, and description
 of the environmental setting to the assessment of potential impacts. The
 document commonly concludes with a discussion of mitigation
 measures.

 This chapter discusses the contents of a comprehensive environmental
 impact assessment document and provides the reviewer with guidelines
 for its assessment.  The chapter follows the typical organization of an
 environmental impact assessment, and the reader should use these
 descriptions as a guide of what to look for in an environmental impact
 assessment. As in key sections of Chapter 3, at the end of each section
 in this chapter, the reader is presented with a road map to help guide
 review, indicated by the road map icon.

 4.1 APPROACHES TO REVIEW: READING AN ENVIRONMENTAL
    IMPACT ASSESSMENT: WHAT TO LOOK FOR

 Many of the specific steps that must be taken during the review of the
 elements of an environmental impact assessment are described
 throughout this document. Included in this chapter is guidance on how
 best to approach the analysis of an environmental impact assessment,
 and how to maximize the effectiveness of this analysis.

 In any review of any part of an environmental impact assessment
 document, the reviewer should keep in mind the six elements of the
 Reviewer's Focus presented in Chapter 3.  Namely, the reviewer should
 focus on:

            1)  Completeness/Coverage
            2)  Significance
            3)  Adequacy
            4)  Integrity
            5)  Accuracy
            6)  Influence

Throughout this chapter, the road maps for review of each element of
an environmental impact assessment document follow these six
elements of the Reviewer's Focus where relevant.

There are several different ways to approach the evaluation of an
environmental impact assessment, and all are appropriate to some
•  Typical structure of an
   environmental impact
   assessment document:

-  Purpose and need
-  Project alternatives
-  Description of environmental
   setting
-  Assessment of potential
   impacts
-  Mitigation measures
   Reviewer's Focus
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Chapter 4 - Evaluation of Each Element
degree or another depending upon the most effective approach within a
given country or institution, agency, and/or individual reviewer
situation. For example, the approach is different depending on the
reviewer's familiarity with the proposed project, and on his or her level
of experience. Each reviewer needs to find the approaches he or she is
most comfortable with for different types of projects.  This approach
will likely change over time as the reviewer gains more experience
evaluating environmental impact assessments and develops more
expertise in the various disciplines that contribute to environmental
impact assessment.

The following are some useful approaches to reading an environmental
impact assessment:

1)   Scan the document, then read it quickly to get a sense of what it is
     about. Think about:
     -  Flagging major issues: Identify them and determine if they
        were addressed.
     -  Spotting where help is needed:  Look at the Executive
        Summary and table of contents, spot key or significant issues
        and who might be called upon to assist in the review.

2)   Read the document several times (depending on time availability)
     to identify major issues and to  determine whether they were
     addressed. It would be less necessary to read an environmental
     impact assessment several times if the reviewer had been involved
     in the scoping process and other stages of the process. When
     conducting this more in-depth review, keep the following items in
     mind. Some of these methods are used in the review of the
     environmental impact assessment document, while others are
     useful components of managing the environmental impact
     assessment process.  These methods are not mutually exclusive,
     and individual reviewers should use the methods they are most
     comfortable with:

     -  Adequate inclusion of stakeholder views and concerns:
        Evaluate whether an adequate range of stakeholders was
        involved in the scoping and other processes. A reviewer should
        examine the list of people involved to determine if there was a
        scoping activity.  If a key group was absent from scoping, the
        reviewer should look particularly for the kinds of issues it
        would have raised.

     -  The train of logic:  Does the environmental impact assessment
        "make sense" in its internal logic from statement of purpose
        and need through impacts and consideration of alternatives and
        mitigation?  An environmental impact assessment that attempts
        to mask or downplay significant concerns often must make
        leaps in logic that such a review can help to identify. A
        reviewer should determine if environmental issues are clearly
                        Each reviewer needs to find
                        the approach to
                        environmental impact
                        assessment review he or she
                        is most comfortable with for
                        different types of projects
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                                                   Chapter 4 — Evaluation of Each Element
identified and whether there is a clear flow of information.  Is
there a basis for the conclusions drawn?

Logical application of technical knowledge/methods: Is the
rationale for the choice of models explicit, and consistent with
the facts in the situation? What was considered and rejected
and why? Were analytical methods and measures used? How
were the application of disciplines utilized?

Comparative Environmental Impact Assessments or
Guidelines: The reviewer can usefully compare the
environmental impact assessment to environmental impact
assessments on similar types of projects done elsewhere or EIA
guidance for similar projects. Among other things, this can
help identify issues that may have been overlooked.

Systematic approach: Walk through the environmental
impact assessment preparation steps/structure being
systematic and using checklists:  Use the structures for
preparation of an environmental impact assessment and
systematic checklists.  Identify different kinds of checklists and
their use.  Were the impacts addressed completely (e.g.,
pollution prevention, etc.)? A detailed checklist to guide the
review process is included in Appendix A of this document.  In
addition, there are several useful checklists and other sources of
information in the Resource Manual that accompanies the
Principles of Environmental Impact Assessment Review
course. Using these tools will enable a reviewer to determine if
the key steps and elements were executed properly by the
project proponent.

Support of decision-making: Is information understandably
displayed on alternatives and mitigation measures  so that
decisions can be made?
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Chapter 4 - Evaluation of Each Element
                     Road Map for Overall
       Environmental Impact Assessment Document Review

    •  Review Table of Contents and Executive Summary

    •  Scan and read the document several times                 *

    •  Take notes, write down questions

    •  Go through key environmental impact assessment elements
       -    Purpose and Need, Alternatives, Environmental Setting,
            Impact, Mitigation

    •  Use checklists where appropriate

    •  Review the logic and consistency of the document

    •  Use a systematic approach to identify areas where the
       assessment is:
       -    Incomplete, inadequate
       -    Significance unsupported/unclear/ignored
       -    Lacks integration

    •  Identify and adopt perspectives of all interested and affected
       parties

    •  Compare document to other environmental impact assessments

    •  Determine whether the document supports decision-making
4.2 PURPOSE AND NEED

The environmental impact assessment document should begin with an
introduction describing the purpose of, and need for, the proposed
project. An accurate description of the purpose and need is critical to a
full examination of possible alternatives and the selection of a preferred
alternative. The purpose and need must be a clear, objective statement
of the rationale for the proposed project.  The need for the proposed
project can simply be a specific problem that must be addressed, or an
available opportunity. For example, a problem may be flooding along a
river that affects the local community, and an opportunity may be to
attract tourists to an undeveloped coastal area.  The purpose  of the
proposed project describes the goals or objectives for meeting the need.
                       The purpose and need must
                       be a clear, objective
                       statement of the rationale for
                       the proposed project
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                                                           Chapter 4 - Evaluation of Each Element
The statement of purpose and need is important because it provides the
framework for identifying project alternatives. For example, a project
to build a new power plant may be proposed because the existing plant
is producing at full capacity and cannot meet projected growth in
demand for electricity.  The need for the proposed project is to provide
500 megawatts of electricity to meet the projected increase in demand.
The purpose, or goals to be met in addressing the need, is to minimize
the cost to consumers, improve air quality in an area that does not meet
current standards, and attract new industries. The project alternatives
could include various locations for the proposed new power plant,
implementation of conservation measures to avoid building the facility
(demand side management), different kinds of power (e.g., wind, solar),
different types of fuel (e.g., natural gas, oil, biomass), or a combination
of these alternatives and perhaps cogeneration.  All of these alternatives
address the need for the proposed project.  Some of them address the
purpose better than others.  All reasonable alternatives that fulfill the
purpose and need should be evaluated in detail. The more alternatives,
the greater the possibility of avoiding significant impacts.

A clear statement of purpose and need can further the goals of the
environmental impact assessment process in the following ways:

•  Provides basis for determining impacts
•  Provides basis for defining alternatives
•  Helps all parties to understand the  context of the action.

It is helpful to obtain input on the purpose and need of a proposed
project from stakeholders, including businesses, citizens, local
government, and nongovernmental organizations. This enables the
project proponent to understand and consider the priorities and concerns
of the local community and government agencies early in the planning
process, which could help to avoid future delays.

4.2.1  Review of Purpose and Need

The purpose and need for a proposed project are sometimes accepted as
"given," ignored, or under-emphasized in an environmental impact
assessment review. However, the reviewer should always review the
stated purpose and need of a proposed project. Such a review can find
either that the proposed purpose and need statement is a) adequately
described, b) adequately described but does not justify the proposed
project, c) adequately described but can be met by alternatives not
considered in the environmental impact assessment which may be
environmentally preferable, or d) is not supported in the document.
Proposed projects often take on a "life of their own" simply because
money has been made available. It is important to be aware of this.
The mere existence of funding for a project does not automatically
mean the proposed project is needed or is justifiable.
The statement of purpose and
need provides the framework
for identifying project
alternatives
The reviewer should always
review the stated purpose and
need of a proposed project.
It is important not to under-
emphasize this aspect of
environmental impact
assessment review
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 Chapter 4 - Evaluation of Each Element
 The realities of a reviewer commenting on purpose and need involve,
 first, the feet that it is often viewed to lie outside the actual or perceived
 expertise or role of a reviewer, and second, the fact that there are
 frequently powerful economic and/or political interests in a proposed
 project. Therefore, comments on purpose and need should be well
 founded to be taken seriously. The need to review and the time and
 effort required to review a proposed project's "purpose and need" are
 usually balanced against the potential for adverse environmental
 impacts of proposed project.  For example, it is most important to be
 confident in the purpose and need if potential environmental or other
 impacts are significant. On the other hand, if the purpose and need are
 weak, but the potential environmental or other impacts are insignificant,
 it may not make sense to spend large amounts of time and resources
 scrutinizing this aspect of the environmental impact assessment.

 A reviewer should ask for clarification from the project proponent if the
 purpose and need are vague or confusing. Other reviewers may also be
 consulted. When a reviewer is confident that the purpose and need
 merit a challenge, however, the reviewer should certainly offer one.  If a
 reviewer does not challenge the purpose and need of a poorly conceived
 project, the results of the environmental impact assessment process will
 be limited to mitigation measures, at best, when the issues may require
 more profound considerations. When offering a challenge to the
 purpose and need, it is important to also offer or take steps to help
 ensure there are viable alternatives  to the proposed project. Criticisms
 without alternatives are not well received, and often do not result in a
 constructive decision-making process.

 4.2.2  Purpose and Need  Review Road Map

 All of the preceding discussion on purpose and need can be summarized
 in the following road map for review of purpose and need. As a
 reviewer, you should focus on answering the following questions:
             Road Map for Purpose and Need Review

  •   Describes the purpose and need of the proposed project

  •   Demonstrates how purpose and need would be met by the
     proposed project

  •   Adequately describes the proposed project
     -  Maps project site, surrounding land use, and natural features
     -  Who and what would benefit; who and what would be affected
     -  Phases; site preparation, construction, operation, and closure
     -  Time frames, including when proposed project begins and
       ends
                      •  It is most important to
                         evaluate the purpose and
                         need if potential
                         environmental impacts
                         are significant
                     •  Road Map for Overall EIA
                        Document Review
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                                                           Chapter 4 - Evaluation of Each Element
4.3  PROJECT ALTERNATIVES

In most countries, a range of alternatives are evaluated to facilitate
identification of the most appropriate means of meeting the purpose and
need for a project.  Not all countries require the consideration of
alternatives. When required, or voluntarily included in an
environmental impact assessment, alternatives should include different
ways of achieving the purpose and need and alternate designs for the
proposed action. The environmental impact assessment should also
include the no-action alternative. This alternative provides a baseline of
existing and future environmental conditions without the proposed
project that can be used for comparison with the potential impacts of
the other alternatives. It also provides an opportunity to document the
beneficial and adverse effects of not addressing the need.  Finally, it
supports the decision-maker's choices of project approval or denial.

The "alternatives" section of the environmental impact assessment
describes all alternatives that were, or are, being considered. All
reasonable alternatives, those that meet the purpose and need, are
explained in detail.  Alternatives that were considered and rejected early
in the planning process are described briefly with the rationale for their
elimination. The rationale should have sufficient information to support
the decision not to proceed with the dismissed alternatives and sufficient
backup data to respond to any challenging questions or comments on
the draft environmental impact assessment.

The preliminary evaluation of alternatives should narrow the scope of
the environmental impact assessment to a reasonable set of alternatives.
The environmental impact assessment should focus on the most
feasible, cost effective and environmentally sensitive alternatives.  For
each alternative, the environmental impact assessment should include
(1) a balanced description, and (2) a discussion including the size and
location of facilities (or the project, if no facility is planned), land
requirements, operations and management requirements, auxiliary
structures, and construction schedules.

The benefits of evaluating alternatives include the  following:
     Selection of the best project design;
     Selection of the best project location;
     Most efficient use of resources;
     Avoidance of adverse impacts;
     Achievement of sustainable development goals only achievable
     through consideration of new ways of doing business.
When developing alternatives, it is beneficial for the project proponent
to solicit input from the public and government agencies. Including
these parties is an important technique for identifying potential issues
and problems with the proposed project or alternatives. The earlier any
   The environmental impact
   assessment should include a
   no-action alternative
   For each alternative, the
   environmental impact
   assessment should include:

   1) A balanced description
   2) Discussions of:
      -  Facility size and
         location (if applicable)
      -  Land requirements
      -  Operations and
         management
      -  Auxiliary structures
      -  Construction schedules
•  The earlier any problems are
   identified, the easier and less
   costly it is to address them
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  Chapter 4 - Evaluation of Each Element
  problems are identified, the easier and less costly it is for the project
  proponent and reviewer to address them.

  As part of the description of alternatives, the proponent's own initial
  evaluation to proceed with the proposed action should be explained to
  provide insight into the breadth and depth of alternatives considered and
  rejected or pursued for further study. A well-documented description of
  the preliminary evaluation processes explaining the process for
  shortening the list of alternatives can help determine whether a full
  range of alternatives was evaluated. Exploring and documenting a
  broad scope of alternatives is to the advantage of the project proponent.

  4.3.1 Review of Project Alternatives

  It is important that the environmental impact assessment include a
  sufficient number of alternatives to ensure an effective decision-making
 process.  The reviewer can question whether other alternatives should
 be included even after the scoping process has ended whether or not the
 reviewer was actually involved in scoping.

 The requirement to develop and analyze alternatives is not a boundless
 process of generating all possible alternatives.  There is an objective
 process for this aspect of the environmental impact assessment.
 Alternatives should be developed under the following considerations:

 •   Alternatives must meet the purpose and need for the proposed
     project.
 •   Alternatives should be reasonable, that is they should be
     practicable; it must be possible to carry them out. They must be
     feasible from logistical, technical and financial perspectives.

 For purposes of decision making, they can be presented as points along
 a continuous range of alternatives which, when systematically analyzed,
 provide a solid basis for decision-making.

 How Many Types and What Number of Alternatives are Adequate?

 How does a reviewer know how many alternatives there should be, and
 how well they were analyzed? It is important to keep in mind that
 environmental impact assessment is a tool for a decision-making
 process. Thus, a reasonable range of alternatives should have been
 identified and evaluated.  A single choice does not constitute a range of
 alternatives, because in such a case there is no decision, no decision-
 making, and no environmental impact assessment process.

 In reality a few or up to hundreds of alternatives may be necessary in a
 particular environmental impact assessment.  To determine whether a
 reasonable number of alternatives have been identified, the reviewer
must take into account time, geography, economics, environment and
 social impacts.  The alternatives should represent a range or points
                         Alternatives:

                         -  Must meet the purpose
                            and need
                         -  Should be reasonable and
                            practicable
                        Determining the correct
                        number and type of
                        alternatives
                        As little as one or two or as
                        many and hundreds of
                        alternatives may be
                        appropriate, depending on the
                        characteristics of the
                        proposed project
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                                                            Chapter 4 - Evaluation of Each Element
along a spectrum of options that offer real choices for the decision-
maker.

The No-Action Alternative

In countries where alternatives are required or commonly evaluated,
environmental impact assessments should always include a no-action
alternative.  Inclusion of the no-action alternative is important for
effective decision-making.  It provides an assessment of environmental
and other conditions absent the proposed project which can be used to
compare against the potential environmental impacts of the proposed
project, both beneficial and adverse.  The no-action alternative presents
expected fitture environmental conditions.  This can help reviewers
determine whether the anticipated deviation from the no-project state
will be acceptable.

Baseline environmental conditions are not the same as the no-action
alternative.  A baseline typically presents current environmental
conditions, but current conditions may change even in the absence of a
proposed project (for example, if a forest were projected to decline over*
time due to an insect infestation). It is important to identify both the
positive and negative potential environmental  impacts of a proposed
project throughout the life of the project, which requires anticipation of
changes in conditions that are not related to the proposed project.
Indeed, a proposed project may prove to be beneficial as  compared to
letting an existing situation deteriorate.

Balanced Assessment of Alternatives

Reviewers should determine whether each alternative was evaluated
adequately.  This implies that some alternatives may receive more
attention than others.  Often there are some alternatives that are
considered but not analyzed because they are clearly not viable. Of the
alternatives that are analyzed, each alternative should receive equal
analysis so that comparisons are meaningful.  Although equivalent
analyses are advisable, variation in analysis of alternatives is  common.
Reviewers should trust their own professional opinions and those of
associate reviewers; if an alternative seems to have been neglected
without just cause, it is reasonable and advisable to ask the project
proponent to revisit it in sufficient depth.
Environmental impact
assessments should always
include a no-action
alternative
Baseline environmental
conditions are not the same
thing as the no-action
alternative
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 Chapter 4 - Evaluation of Each Element
 4.3.2  Alternatives Review Road Map

 To summarize, when evaluating alternatives, the reviewer needs to ask,
 at a minimum:
               Road Map for Alternatives Review

 •  Considers the full range of alternatives to meet purpose and need
   -  No action
   -  Alternative sites, designs, controls
   -  Structural vs non-structural
   -  Reallocation of social costs and benefits
   -  Reasonable, feasible
   -  Reflective of the range of choices
   -  Meet the purpose and need of the proposed project

 •  Preferred alternative satisfies purpose and need better than
   alternatives with less environmental impact
4.4  DESCRIPTION OF THE ENVIRONMENTAL SETTING

The section of the environmental impact assessment document that
describes the environmental setting should identify and describe the
environmental setting, including the physical-chemical, biological, and
socioeconomic environments; aesthetics; and cultural resources.  The
description of the environmental setting must be complete and accurate
because it will serve as the baseline from which the impacts of the
proposed action are predicted.  The reviewer should refer back to the
scoping process of the environmental impact assessment to help ensure
that all substantial issues are addressed. The reviewer must identify all
substantial issues not covered in the environmental impact assessment.

The description of the environmental setting section should include only
the appropriate background information necessary to understand the
potential impacts of the project alternatives. The information should be
presented objectively.  The reviewer should take steps to help ensure
that each aspect of the environment that is likely to be affected by the
proposed project is adequately addressed.  The environmental impact
assessment should consider:

     •  Local ambient air quality conditions

     •  Location of seismic activity, flood plain, and other special
        geologic or hydrologic features within the vicinity of the
        proposed project

     •  Surface water and ground water quality and quantity
                         Description may include:

                         - Air resources
                         - Water resources
                         - Soils and geology
                         - Biological resources
                         - Waste management and
                           pollution prevention
                         - Socioeconomic setting
                         - Cultural resources
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                                                          Chapter 4 - Evaluation of Each Element
     •  Local biological communities and fish and wildlife habitats,
        including critical habitats of any rare, threatened, or
        endangered species

     •  Location of specially protected areas, including wildlife
        management areas, parks, wetlands, pristine lands or water
        bodies, or prime agricultural lands

     •  Renewable and nonrenewable resources

     •  Current and projected population, population density, and
        location of population in relation to the proposed project site

     •  Current and projected land use (within the proposed project
        area and region) and relevant land use regulations

     •  Local and regional patterns of energy demand and supply

     •  Local ambient noise levels

     •  Location of any properties with cultural heritage values within
        the vicinity of the proposed project

     •  Existing regulatory setting for each resource.

The description section should focus on the important issues. Only the
components likely to be affected need to be addressed in detail; others
should be summarized, consolidated, or referenced. Experience from
similar projects can be helpful in identifying the environmental
components that should be described.

When feasible, the environmental impact assessment should rely on
existing data to describe the environmental setting. If sufficient data
are not available to fill a particular need, various techniques can be
used to obtain the appropriate data. These techniques include field
surveys, checklists, topographic maps, and overlay mapping, including
those produced using geographic information systems (GIS).  The
Resource Manual that accompanies the Principles of Environmental
Impact Assessment Review course contains information on these types
of information sources.

To  effectively assess the potential impacts of a proposed project, the
reviewer must consider whether the project proponent has established
appropriate boundaries for the region of concern and time periods for
describing the baseline against which the potential impacts of the
proposed project will be compared. The region of concern is the
geographic area potentially affected by the proposed project.  The most
appropriate time period for assessing an impact is the point during
construction or operation that creates the greatest change in the present
environment. Different time periods and geographic boundaries are
 • Information sources:   .

   - Existing literature
   - Government agencies
•••••- Research organizations
   - : Field surveys
   - Topographic maps
   - Land use maps
   ^ Geographic information
      systems
   - Local specialists
   It is critical that the Region
   of Concern be clearly defined
   for each media, as well as
   time periods over which
   impacts are expected to occur
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 Chapter 4 - Evaluation of Each Element
 chosen for different impacts or parameters. For example, the
 boundaries of the region of concern are likely to be different for air and
 water. Projections of local employment may be compared for two
 different time periods—once during maximum temporary construction
 work force and later during full operation of the proposed project. The
 reviewer should make sure that the year(s) and area used for comparing
 the impacts are clearly indicated for each impact or parameter.

 The following sections describe factors that the reviewer should
 consider when evaluating the adequacy of the description of the
 environmental setting given in the environmental impact assessment.

 4.4.1 Existing Physical-Chemical Environment

 The physical-chemical environment comprises the air, water, and
 geological characteristics of the region of concern.  A complete
 understanding of the physical-chemical environment,  and the type of
 project proposed, helps the reviewer identify specific  issues to be
 investigated in the environmental impact assessment section that
 describes potential impacts. For example, the identification of frequent
 temperature inversions may require emphasis on the biological effects
 of gaseous emissions or a shortage of surface water in the project
 region may require that the few existing surface water bodies be
 considered critical habitats.

 4.4.LI Air Resources

 A wide variety of industrial operations have the potential to affect air
 resources.  These operations include activities at primary metal, pulp
 and paper, textile, and chemical manufacturing plants; power plants;
 and mining sites.  In addition, increases in air and automobile traffic
 frequently affect air quality.

 Air resources are described by the physical dynamic behavior of the
 lower atmosphere (parameters such as the seasonal distribution of wind
 velocity and the frequency and height of inversions) and by variations in
the concentrations of various gases and suspended matter. Wind
 velocity and the frequency of occurrence of inversions are influenced by
 specific local topographic features, particularly surrounding hills or
mountains. Air quality is described by the variations  in the
concentrations of pollutant gases and particulate matter in the lower
atmosphere. Both the physical dynamic behavior and air quality of the
lower atmosphere are needed to determine the impacts of proposed
project construction and operation on air quality.

The physical dynamic behavior of the lower atmosphere is largely
determined by the interaction of meteorological conditions and
topography. Therefore, the environmental impact assessment should
include a general discussion of climate within the region of concern that
includes the following factors:
                      •  Physical-Chemical
                         Environment:

                         -  Air resources
                         -  Water resources
                         -  Soils and geology
                      •  Air Resources:

                         -  Meteorological data
                         -  Ambient air quality
                         -  Sources of air pollution
                        Meteorological data:

                        - Temperature
                        - Wind
                        - Precipitation
                        - Humidity
                        - Atmospheric pressure
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                                                            Chapter 4 - Evaluation of Each Element
     •  Daily and seasonal ground-level temperature

     •  Wind characteristics at different heights and times (wind roses
        are particularly helpful and provide wind speed, direction,
        frequency, and stability characteristics of the atmosphere)

     •  Total monthly, seasonal, and annual precipitation and
        frequency of storms and their intensity, including both average
        and extreme events

     •  Evaporation

     •  Height, frequency, and persistence of inversions and
        atmospheric mixing characteristics

     •  Description of pattern(s) evident for days of significant
        pollution episodes.

In addition, information should be included on the frequency of local
climatic hazards, including tornadoes, high wind speeds, hurricanes,
and floods (see Section 4.4.1.2). Construction techniques and site
utilization may be affected by such climatic extremes. Meteorological
data are typically available from local weather service stations. Site
and area topography are generally determined from topographic maps
or field surveys.

Data on ambient air quality (e.g., concentrations of particulates,  carbon
monoxide [CO], hydrocarbons, ozone [03], and sulfur dioxide [SO2])
are required to predict the potential impacts during the construction and
operation of a proposed project. This information is usually available
from a local air pollution control agency. Using existing air quality as
the background, incremental increases in air pollution concentrations
can be predicted for comparison with various national and local
standards. Also, the proposed site's location relative to any protected or
sensitive areas (e.g., national parks) and any areas that are not meeting
applicable air quality standards should be provided.

The typical data sources for air quality are emission monitoring results
from individual facilities and ambient air quality monitoring results
reported by air pollution control districts. If these data are not
available and the project proponent or the reviewer thinks that they are
important, then air quality monitoring may be needed. At a minimum,
major facilities or stationary sources and their emissions should be
characterized, with daily variations in emissions by month, year,  and
peak season, for pollutants of concern.  In addition to information on
stationary sources, the environmental impact assessment should also
consider the effects of mobile sources on local air quality.

Projections of increases in emissions from both stationary and mobile
sources and estimates of long-term pollutant concentrations are
   Ambient air quality:

   -  Particulates
   -  Carbon Monoxide
   -  Hydrocarbons
   -  Ozone
   -  Sulfur dioxide
   -  Other pollutants of
      concern
•  Stationary sources of
   emissions:

   -  Power plants
   -  Industrial plants

•  Mobile sources of emissions

   -  Cars and trucks
   -  Airplanes
   -  Boats
   -  Trains
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Chapter 4 - Evaluation of Each Element
important for describing future air quality. The comparison of existing
air quality and expected trends with national and local air quality
standards will assist in assessing potential impacts of emissions
expected from the proposed project and in determining the need for air
pollution controls.

4.4.1.2 Water Resources

Water resources can be affected by almost any project and should be
considered when assessing potential environmental impacts of the
construction and operation of manufacturing, industrial, or processing
facilities, hazardous waste sites and landfills, tourism development,
electricity generation, port and harbor development, and many other
projects. Water resources can also be affected by infrastructure
projects, including transportation and sewage treatment, and natural
resource extraction projects, such as mining and forestry.  Potential
sources of impacts to  water resources from these types of projects
include:

     •  Withdrawal of freshwater from lakes, rivers, streams, or
        aquifers;

     •  Discharges of untreated or treated wastewaters;

     •  Deposition of pollutants from smoke stack and/or vehicle
        emissions;

     •  Storm water and agricultural runoff;

     •  Spills.

The reviewer should check to see whether information in the description
section of the environmental impact assessment describes surface water
bodies (i.e.,  streams, lakes, rivers, estuaries, and oceans), ground water
aquifers, and special aquatic areas located within the region of concern.
The descriptions should include maps of surface water bodies and
surface drainage patterns. In addition, they should describe current and
future uses of both surface water and ground water. Typical water
body uses include wildlife habitat, drinking water supply, industrial/
commercial  process water, agricultural irrigation water,  subsistence
uses (e.g., hunting, fishing), recreational uses (e.g., fishing, swimming),
and commercial fishing and biota harvesting (e.g., shellfish harvesting,
aquaculture). The use of surface waters (diversions, returns, and
reclamation) is critically important in locations where water resources
are scarce.

The environmental impact assessment also should describe current
water quality.  The description of water quality should include the
physical and chemical characteristics of surface water bodies that may
be affected by the proposed project.  Ambient conditions of
                         Water resources:

                         -  Source and location
                         -  Quality
                         -  Quantity
                         -  Uses
                      • Water quality information:

                        -  Dissolved oxygen
                        -  Temperature
                        -  Salinity
                        -  Suspended and dissolved
                            solids
                        -  Nutrients
                        -  Chemicals of concern
                        -  Biological contaminants
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                                                           Chapter 4 — Evaluation of Each Element
conventional parameters (e.g., dissolved oxygen, temperature, salinity,
suspended and dissolved solids, and nutrients), as well as
concentrations of any chemicals of concern, should be described for
both freshwater and marine water bodies.

In addition, descriptions of surface water bodies should include:

     •  Seasonal and historical maximum, minimum, and mean flows
        for rivers and streams;

     •  Water levels or stages and seasonal patterns of thermal
        stratification for lakes, ponds, and reservoirs;

     •  Circulation characteristics (e.g., tides, currents, thermocline,
        and thermohaline) for tidal rivers, lagoons, estuaries, and ocean
        waters;

     •  Biological resources (see Section 4.4.2);

     •  Fishing grounds;

     •  Aquaculture sites;

     •  Habitats.

In addition to the description of the physical and chemical
characteristics of surface water bodies, the environmental impact
assessment should describe existing pollutant sources, including:

     •  Industrial plants;

     •  Wastewater treatment plants;

     •  Untreated sewage from residential or industrial areas;

     •  Storm water and agricultural runoff.

Information should  include the locations of existing discharges and
actual data on pollutant loadings.  If actual loading data are not
available, they may be estimated based on information about the
sources of discharge.  An understanding of existing pollutant loads to
water bodies and the resultant ambient concentrations is required in
order to accurately predict future water quality and the impacts of the
proposed project.

A discussion of surface water resources should also include flooding
events.  The dates, levels, and peak discharges of previous floods
should be reported,  with the meteorological conditions that created
them. Historical data on flood levels support decisions on project siting
and design to avoid  flood damage.
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Chapter 4 - Evaluation of Each Element
In addition, the environmental impact assessment should describe
ground water resources. Descriptions of alluvial and bedrock aquifers
are necessary to determine the potential of project activities to
contaminate or deplete ground water reserves.  Projects are more likely
to affect ground water when the ground water table is near the land
surface, the proposed project is near a ground water recharge zone, or
the proposed project will withdraw ground water.  The depth to the
water table and the nature of overlying soils and geologic features are
important. The environmental impact assessment for projects that may
affect ground water resources should contain the following information:

     •  Ground water occurrence, including the locations and
        boundaries of aquifers;

     •  The aquifers' ability to transmit water (transmissivity);

     •  Ground water movement, including the direction and rate of
        flow;

     •  Location and rates of ground water recharge and discharge;

     •  Ground water quality (e.g., pH, total dissolved and suspended
        solids, salinity, and concentrations of specific contaminants of
        concern).

Site-specific ground water information is often obtained from regional
ground water maps or through a hydrogeologic field survey. These
surveys often rely on topographic maps to determine surface drainage
patterns, geological maps for soils and the sequence and thickness of
subsurface materials, and potentiometric surface maps and hydraulic
gradients for direction of ground water flow.

4.4.1.3 Soils and Geology

Construction, mining, forestry, agriculture, landfills, and coastal
development are some activities that affect soils and geologic
formations.  Conversely, underlying geologic structures can affect the
stability of various structures, including buildings, roads, bridges,
dams, and landfills. The environmental impact assessment should
include a detailed description of the surface topography and soil
composition over the region of concern. Soil maps and geological maps
indicating sequencing and thickness of subsurface materials are
commonly used. This section of the environmental impact assessment
should include information on the following parameters:

     •  Topography;

     •  Location and condition of joints, faults, fractures, and other
        potential weaknesses;
                        Key factors:

                        -  Depth to water table
                        -  Overlying soils
                        -  Geologic features
                      • Ground water quality:

                        -  pH
                        -  Solids
                        -  Salinity
                        -  Chemicals of concern
                        For the region of concern, title
                        environmental impact
                        assessment should include a
                        detailed description of:

                        -  Surface topography
                        -  Soils
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                                                            Chapter 4 — Evaluation of Each Element
     • Slope cuts and structural loads;

     • Landslide history;

     • Soil permeability;

     • Soil credibility;

     • Extent of weathering;

     • Depths to impervious layers;

     • Water table depth;

     • Ground water movement.

This information provides most of the baseline information necessary to
determine the risks of property damage and safety issues associated
with the proposed project.

The potential for erosion is an important consideration for certain sites,
including those in close proximity to water resources. The potential for
erosion depends on the following factors:

     • Local and regional topographic features, such as ridges, hills,
        mountains, coastlines, valleys, and stream banks;

     • Local soils characteristics and proposed slope changes;

     • Presence of riparian zone vegetation;

     • Precipitation patterns;

     • Water circulation patterns.

Meteorological data, topographical maps, and soil maps of the
proposed project area are typically sufficient to assess the potential for
erosion.

It is also important to consider the location of any limestone formations
or subsurface mining activity in the proposed project area, history of
subsidence in area, and planned uses for ground water (e.g.,  water
withdrawal). These factors will help assess the potential for land
subsidence. Information on the soils, subsoils,  and bedrock, as well as
knowledge of the proposed grading and compaction of the proposed
project, will facilitate assessment of the potential for excessive
settlement of foundation materials and related impacts.
 Erosion potential
Subsidence
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Geological features are important when paleontological sites and other
areas of scientific or educational value may be disturbed or overlain by
facility structures.

In regions that are seismically active, the description of the
environmental setting should include information necessary to assess
potential risks of damage and loss due to earthquakes and volcanoes.
Relevant information includes proximity to faults, the history of
earthquakes and volcanoes in the area, locations of epicenters,
magnitudes, and frequency of occurrence.

The environmental impact assessment should identify any mineral
resources, particularly those with economic value,  located in the region
of concern.  If such resources are present, the document should denote
the location of the deposits on a map of the proposed site and describe
the type(s) and quantities of the minerals. In addition, the document
should identify any mining claims or other present  or potential resource
development activities at or near the proposed site.  This information
will be useful in determining whether the presence  of mineral resources
may affect projected future land use or conflicts over the region of
concern.

4.4.2 Existing Biological Conditions

The description section of an environmental impact assessment should
contain a complete description of key biological elements, including the
identification and distribution of dominant, rare, and unique plant and
animal species within the region of concern. The description should
identify all officially recognized threatened or endangered species in the
region of concern. Data are typically reported using maps of the area
with overlays of vegetation types, floral and faunal species types, and,
when available, abundance lists. This information, in conjunction with
a consideration of ecological interrelationships, such as habitat and
food sources, provides the basis to determine whether the assessment
adequately considers potential impacts on the biological community.

Knowledge of both the types of plant communities in the general
proposed project area and the specific distribution  of vegetation within
the proposed site is necessary to assess the potential impact. The
presence of wildlife at a proposed site largely depends on the nature and
distribution of vegetation.  The environmental impact assessment
should emphasize species that are likely to be displaced by project
construction and operation, as well as any unique or rare species likely
to be in the region of concern.

There are a variety of ways that professionals approach review of the
description of biological resources in an environmental impact
assessment. While there is no single correct way to approach review of
a description of biological resources,  a three-part categorization is
presented in this text: 1) Wildlife and Vegetation; 2) Community and
Habitat Characterization; and 3) Ecologically Significant Features.
                         Seismic activity:

                         -  Proximity to faults
                         -  History of earthquakes and
                            volcanic eruptions:
                            -  Magnitude
                            -  Frequency
                         Mineral resources:

                         -  Locations of deposits
                         -  Type(s) and quantities of
                            minerals
                         -  Ownership of mining rights
                      •  Biological resources:

                         -  Aquatic communities
                         -  Wetland communities
                         -  Terrestrial communities
                         -  Ecological interrelation-
                            ships

                      •  Information sources:

                         -  Literature
                         -  Government agencies
                         -  Research organizations
                         -  Field surveys
                         -  Monitoring
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4.4.2.1 Wildlife and Vegetation

Often the most important information pertaining to existing biological
conditions in the description of the environmental setting refers to the
existing wildlife and vegetation.  Projects with the potential for
significant adverse impacts to wildlife and vegetation, particularly
threatened or endangered species, can often be highly controversial,
invoking public outcry and questions of law.  Reviewers of this section
of an environmental impact assessment should take extra care when
reviewing the description of existing wildlife and vegetation.  This will
also assist the reviewer in correctly assessing the importance of
potential impacts to existing wildlife and vegetation.

Species Composition

Species composition refers to the mix of biological species found in the
region of concern (the proposed project site and other potentially
affected areas).  It is common for environmental impact assessments to
include a list of the species found at the proposed project site, broken
down into various categories. To assist the reviewer in developing a
framework of information to guide review of information on species
composition, common and useful categories are presented below, along
with a number of examples of species that belong to each.

Aquatic Communities

The following categories should be used as a guide to assist the
reviewer in the evaluation of the adequacy of the environmental impact
assessment in describing the species composition of aquatic
communities:

     •  Flora

            Phytoplankton (e.g., diatoms, dinoflagellates, blue-green
            algae)
            Submerged vegetation (e.g., sea grasses, rooted aquatic
            plants, attached algae)
            Floating vegetation (e.g., water hyacinth, duckweed)
        Fauna
            Plankton (e.g., copepods, euphausiids)
            Benthic fauna (e.g., sea star, crab, caddisfly larvae,
            dobsonflies, polychaete worms, clams)
            Pelagic invertebrates (e.g., jellyfish, squid)
            Fishes (e.g., bass, salmon)
            Reptiles (e.g., turtles, snakes)
            Birds (e.g., ducks, geese, terns, gulls, cormorants)
            Mammals (e.g., beavers, sea lions, whales, otters).
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Chapter 4 - Evaluation of Each Element
Wetland Communities

The following categories can be used to assist the reviewer in
evaluating the adequacy of the environmental impact assessment in
describing existing flora and fauna in wetland communities:

     •  Flora

        -   Emergent vegetation (e.g., horsetails, sedges, rushes,
            mangroves)
        -   Submerged vegetation (e.g., freshwater grasses)
        -   Floating vegetation (e.g., water hyacinth, duckweed)

     •  Fauna

        -   Benthic fauna (e.g., brittle stars, crabs, caddisfly larvae,
            dobsonfly larvae, polychaete worms, clams, oysters)
        -   Insects and other invertebrates (e.g., mosquitos,
            butterflies, beetles, water striders)
        -   Fishes (e.g., bass, darters)
        -   Amphibians (e.g., frogs, toads, salamanders)
        -   Reptiles (e.g., turtles, water snakes)
        -   Birds (e.g., ducks, geese, songbirds, woodpeckers)
        -   Mammals (e.g., muskrats).

Terrestrial Communities

The following classifications can be used as a guide in assessing the
completeness of the description of the species composition of flora and
fauna in terrestrial communities:
        Flora
            Thalloid plants (e.g., lichens, mosses, algae)
            Herbaceous plants (e.g., wildflowers, ferns, grasses)
            Shrubs (e.g., rhododendron, creosote bush)
            Trees (e.g., palms, figs, pines).
        Fauna
            Insects and other invertebrates (e.g., beetles, flies)
            Amphibians (e.g., frogs, toads)
            Reptiles (e.g., turtles, snakes, lizards)
            Birds (e.g., songbirds, pheasants, hawks, eagles)
            Mammals (e.g., raccoons, moles, shrews, mice, lions,
            antilope, elephants, rats, leopards, monkeys, apes).
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                                                            Chapter 4 - Evaluation of Each Element
 Native Species Present

 In addition to lists of the dominant, rare, and unique biological species
 present at the proposed project site or region of concern, the reviewer
 should check to make sure the project proponent identified native
 species that are present. A species is considered native if it naturally
 evolved to occur at the proposed site, or at similar sites in the region.
 Native species are considered more valuable than non-native species,
 because they are often integral components in an ecosystem. Over time,
 particular species may influence site conditions, such as by changing
 soil acidity or by serving as a "keystone" species — one that a large
 number of other species depend on either directly or indirectly in the
 food chain. For this reason, it is important to clearly identify which
 native species are present.

 Exotics

 Unlike native species, exotic species have not evolved to occur at the
 proposed site or similar sites in the region.  Exotic species are often
 introduced by anthropogenic forces. Examples have included the Zebra
 Mussel introduced to the Great Lakes in North America via the ballast
 water of foreign ships, the Gypsy Moth caterpillar introduced to the
 U.S. northeast after escaping from a laboratory, and Africanized "killer
 bees" which have spread across much of South and Central America.
 Exotics are often of concern because they may displace native species.
 Exotic species sometimes have few or no local predators, allowing their
 populations to rapidly increase.  This can adversely affect the food
 supply, available nesting sites or other factors critical for the survival
 of native species.

 Exotic species  should be identified in any description of existing
 biological conditions. Attention should be paid to particularly invasive
 and damaging species in the ecosystems of concern. Also addressed
 should be factors that might lead to an increase  in the abundance of
 exotic species relative to native ones.  This  distinction will be necessary
 when reviewing the assessment of potential environmental impacts
 associated with the proposed project.

Rare and Threatened Species

 In the United States and many other countries, rare and threatened
 species are protected by law. In addition to laws that prevent direct
harm to such species, there are often prohibitions against indirect harm
through habitat modification or other forms of disturbance (e.g., noise).
In the United States, the Endangered Species Act distinguishes between
species that are "threatened" and those that are "endangered."
Endangered status invokes stricter legal obligations for protection than
threatened status. In addition, individual states may create their own
classifications and legal protections for rare or threatened species.  The
reviewer should be aware of all applicable national, state or regional,
and local laws and regulations pertaining to rare or threatened species.
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 The description of existing biological conditions should include a list
 and discussion of rare and threatened species present at the proposed
 site or in the region of concern. The reviewer should communicate
 early-on with the project proponent if this section of the description of
 existing biological conditions is incomplete, due to the fact that a
 misunderstanding or misrepresentation of existing rare or threatened
 species could lead to the proposed project being denied at a later stage
 of the process.

 4.4.2.2 Community and Habitat Characterization

 Community and habitat characterization involves looking at more than
 individual species or lists of species.  It involves identifying the broader
 community that supports individual species, and understanding the
 important features within that community, such as important physical
 features.

 Type of Communities Found in Area

 As in the previous section, community types are categorized into three
 headings: aquatic communities, wetland communities, and terrestrial
 communities.

 Aquatic Communities

 Aquatic environments range from freshwater streams to the pelagic
 regions of the oceans. These diverse environments provide habitats for
 a wide variety of plant and animal life.  When evaluating the
 completeness of an environmental impact assessment, the reviewer
 should help ensure that the description section properly identifies and
 describes the biological components of each aquatic community that
 might be affected by the proposed project. When reviewing the
 description of aquatic vegetation, the reviewer should check to
 determine whether areas in the vicinity and downstream from
 anticipated discharge locations are emphasized.  The first step is to
 make sure the document correctly identifies all the different aquatic
 environments within the region (e.g., streams, rivers, lakes, oceans).  A
 map indicating all surface water bodies in the region will help with this
 step.  Once the appropriate environments are verified, the reviewer
 should check to make sure that all organisms present are identified.
 Existing literature, biological monitoring, and field surveys are primary
 sources of data for identifying organisms.

 Wetland Communities

Wetlands form the transition between upland habitats and the waters of
 rivers, lakes, and  oceans. The hydrology of a wetland may be tidal or
non-tidal. In general,  tidal hydrology supports saltwater wetlands and
non-tidal supports freshwater wetlands. Wetlands may be permanently
inundated, temporarily inundated, or periodically saturated.
                         The environmental impact
                         assessment should clearly
                         identify any critical habitat
                         likely to be affected by the
                         proposed project and
                         describe in detail the life
                         history of those species that
                         depend on critical habitat
                         Aquatic communities:

                         -  Characteristics of flora
                            and fauna
                         -  Sensitivity
                         -  Life history
                         -  Abundance
                         -  Distribution
                         -  Diversity
                         -  Habitat types and
                            locations
                      •  Wetland communities:

                         -  Tidal
                         -  Non-tidal
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Major wetlands can be classified based on vegetation types into
emergent, scrub/shrub, and forested wetlands.  Vegetation in emergent
wetlands (also referred to as marshes) is dominated by grasses and
sedges usually associated with year-round standing water. Typical
forested wetland (i.e., swamp) vegetation includes a predominance of
tree species, such as mangroves in coastal areas, which are able to
survive and/or thrive in standing water for extended periods of time.
The scrub/shrub wetland is a mix of the emergent and forested
wetlands, consisting of vegetation typical of both. Particular species
that dominate each type of wetland vary, depending on geographic
location, soil saturation, and other environmental conditions.

Wetlands serve as critical habitat for a variety of plants and animals.
Tidal wetlands are especially important for estuarine and marine fish
and shellfish and certain waterfowl, shorebirds, and wading birds.
Non-tidal wetlands provide food sources for freshwater fish. In
addition, birds such as ducks and geese, feed, nest, and raise their
young in freshwater wetlands.  Both tidal and non-tidal wetlands serve
as spawning grounds and nurseries for a variety offish species.

Wetlands also play an important role in maintaining water quality and
moderating surges in water quantity. Wetlands slow the velocity of
water, reducing the erosional effects of tides, storm surges, and floods.
The reduced velocity also allows particulates to settle out of waters,
thereby improving water clarity. If toxic pollutants are bound to the
particulates, however, they can have a negative effect oh wetland
communities.

The environmental impact assessment should include a map delineating
wetlands and a list of flora and fauna species and abundances. Species
type and abundances are often identified through literature searches and
field surveys.
Terrestrial Communities

Terrestrial communities can be classified into general categories,
including desert, grassland, coniferous forest, and hardwood forest.
Each category provides habitat for unique plant and animal life.  Maps
of the region with overlays indicating dominant vegetation provide a
basis for the evaluation. Existing literature and field surveys conducted
by biologists with experience in identifying local flora and fauna may
provide specific information, including the various species present and
their abundances.

In different climates, different kinds of communities are climax
communities — those communities which have reached dynamic
equilibrium after a long period of community succession. It is
important that climax communities be identified to evaluate whether
adequate genetic resources are available for their preservation. Since it
•  Wetland community
   classifications:

   -  Emergent
   -  Scrub/shrub
   -  Forested
   The environmental impact
   assessment should include a
   map delineating wetlands and
   a list of flora and fauna
   species and abundances
ป  Examples of terrestrial
   communities

   -  Desert
   -  Grassland
   -  Coniferous forest
   -  Hardwood forest
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 Chapter 4 - Evaluation of Each Element
 often takes centuries to redevelop climax communities at a location,
 their loss is potentially significant.

 4.4.2.3 Ecologically Significant Features

 Support of Broader Ecosystems

 Often it is important to view a proposed project site as a part of an
 interconnected whole, rather than as an isolated island of land. Any
 given aquatic, wetland, or terrestrial site may have important influences
 on the biological resources of other sites. One example is a stop-over
 location in an avian flyway.  Certain locations serve as feeding, nesting,
 and breeding sites for migratory birds.  Although the birds that depend
 on the proposed site may spend much of their time in other locations
 during other seasons, maintenance of a particular site along the path of
 their migration in an undisturbed state may be critical for their health
 and survival. Such is the case in the United States for the Platt river in
 Nebraska, and for numerous other rivers, streams, and wetlands located
 within the various major flyways in Canada, the United States, and
 Mexico.

 Many animals hunt or feed over large areas.  Any change in the
 environment that prevents these animals from accessing any part of
 their home range has negative impacts on populations. Many
 threatened and endangered species in the United States have attained
 that status because of habitat loss or habitat fragmentation. The indigo
 snake in southern Florida is one such species.

 Biotic Interactions

 The environmental impact assessment should describe the key
 interrelations and dynamics within the different ecosystems identified in
 the region of concern. Although it is difficult to determine the extent to
 which plants and animals are interdependent at a given site, specific
 attention should be given to identifying predominant species and their
 trophic levels. A basic understanding of aquatic, wetland, and
 terrestrial food webs and the relationship among the various trophic
 levels of each of these ecosystem types forms the basis for predicting
 impacts to one trophic level based on changes occurring at other levels.
 For example, when examining the impacts from dredging activities to a
wetland marsh, one is most likely to first consider potential losses to
 resident benthic invertebrates resulting from burial and turbidity
 increases. Because the affected invertebrates serve as the primary food
 source for local fish species (which, in turn, are primary prey items for
shorebirds and mammals), significant decreases in invertebrates may
have far-reaching effects.
                         Ecologically significant
                         features include those that
                         support broader ecosystems,
                         important processes or
                         functions, and disturbance
                         regimes
                       • Habitat
                       • Limiting factors
                       • Food sources
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Important Process or Functions

A particular aquatic, wetland, or terrestrial area may perform important
functions that are not immediately apparent.  For example, during
periods of high rainfall, wetlands serve as natural retention basins for
increased  stream flow, absorbing high volumes of flow and gradually
releasing them, thereby helping to prevent flash flooding. Wetlands
also serve as natural filters, removing nutrients and toxics from polluted
water. Another example is a forest on steep slopes. In addition to all
the direct benefits provided by the forest, it also stabilizes slopes and
prevents erosion by shielding the mineral soil from wind and rain, and
by securing soil in place via  root systems.

It is important to recognize such important processes and functions
when reviewing the description of existing biological conditions.  To
ensure inclusion of this type  of information, the reviewer should check
to see if physical and biological conditions at the proposed project site
were studied or monitored over periods of time and during different
seasons. Certain important processes or functions are only apparent at
specific periods of time (e.g., during rainfall) or over long periods of
time (e.g., several seasons).

Disturbance Regimes

Any given site may be subject to natural or anthropogenic disturbances.
Natural disturbances (e.g., floods, fires) are those that occur regularly
or periodically and are a significant influence on the biological
conditions of the site. Anthropogenic disturbances may also play an
important part influencing biological conditions, whether by affecting
natural disturbances or by causing direct impacts (e.g., habitat
destruction).

Natural Disturbances

Two of the most common natural disturbances are fire and flooding.
Certain forests arid grasslands, for example, naturally experience fires
on a periodic basis. In ecosystems influenced by fire, species often
adapt to, or even require, the presence of fife.  For example, the seeds
of certain  tree species will not germinate until scarred by fire. Also,
certain forests rely upon fire to keep brush and other natural materials
from accumulating to dangerous levels.  In both of these cases, a
project that would result in a cessation of fire events would result in
significant changes to the biology of the system, including changes in
dominant species types and the potential for massive fires fed by an
over abundance of fuel.

Flooding patterns can also have important biological influences.  All
rivers overflow their banks under natural conditions, some on a regular
basis (e.g., each rainy season), and others less predictably. In certain
regions, these flooding events transport important waterborne nutrients
and sediments to surrounding land areas. Flood waters may also
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 Chapter 4 - Evaluation of Each Element
 replenish important watering holes and other water sources for wildlife.
 Understanding the processes at work in such a system is particularly
 important if a proposed project would alter a river channel or in any
 way block natural flooding.

 Project-induced Disturbances

 The effects of constructing and operating a proposed project may
 include the degradation or loss of habitat.  The extent of habitat
 disturbance depends on existing land use at the proposed site.  If the
 proposed project requires clearing and grading forested land or dredging
 a pristine water body, for example, the potential for habitat loss is
 greater than at sites where activities have already occurred.

 Adverse effects to critical species habitat, such as fish nursery
 grounds, breeding sites, or nesting areas, ultimately affects species and
 population survival.  Frequently, one particular life stage of a species
 requires a specific habitat (e.g., seagrass beds serve as nursery grounds
 for marine fish, and pristine, coldwater streams are required by some
 mayfly larva). Loss or degradation of these critical habitats may
 disrupt or destroy population regeneration. Thus, the environmental
 impact assessment should clearly identify any critical habitat likely to
 be affected by the proposed project and describe in detail the life history
 of those species that depend on critical habitat.

 Another consideration relevant to ecological interrelationships is habitat
 fragmentation. Even if a proposed project may not result in the
 complete destruction of a particular habitat, it may isolate parts of a
 previously continuous habitat.  Habitat fragmentation can lead to:

     •  Increase in mortality and inbreeding;

     •  Extinction of wide-ranging species (e.g., wolves, bears,
        manatees);

     •  Loss of area-sensitive species;

     •  Decrease in genetic diversity within rare species.

In addition, fragmentation of critical habitats will probably affect the
ability of a particular area to sustain plant and animal populations.
Such fragmentation can lead to displacement of individuals and/or
degradation or destruction of the remaining habitat.

Hydrologic Processes

Hydrologic processes refer to the  amount, location, and duration of
water flows to and through a given site. Hydrologic processes involve
both ground and surface water. Depending on geology and topography,
a particular location may serve as a basin receiving surface or ground
                          Habitat fragmentation
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                                                          Chapter 4 - Evaluation of Each Element
water (e.g., a lake or pond), a source of surface or ground water (e.g., a
mountain), or a combination of the two.

Hydrologic processes can be critical to biological resources. The
amount of water held or released by a particular site, and the duration
of capture or release, can have important influences on the biology of
the site and surrounding area.  Anadromous fish species may depend on
spring river flows to reach spawning sites. Biologically important
groundwater aquifers may depend on annual flooding of a certain
quantity to fully recharge.  Depth to groundwater may determine the
survival of both water tolerant and intolerant tree species.

The environmental impact assessment should include descriptions and
maps of hydrologic processes  important at the proposed site.  Such
information and maps should indicate depth to groundwater, maximum
and minimum annual and seasonal rainfall, the location of any surface
water bodies, including lakes,  ponds, rivers, and streams, and the flow
quantity and seasonality of rivers and streams.

4.4.3 Waste Management and Pollution Prevention

Almost all projects generate waste that must be managed in an
environmentally sound manner.  Characteristics and volumes of waste,
as well as waste management procedures and capacity, influence the
potential for significant environment impacts. Pollution prevention
policies play an important  role in projections of waste management
capacity.

The description of the environmental setting should describe existing
waste management procedures and facilities. Information on existing
wastes generated in the region of concern should describe the quantity
and characteristics of materials disposed of.  Descriptions of existing
waste management procedures should address current policies for
reducing the amount of waste generated and current techniques for
waste handling, storage, transportation., and disposal.

Typically, waste descriptions will include solid and liquid wastes and
discuss the sources of wastes, the quantities generated, and the
characteristics of the waste materials. Sources include industrial
processes, commercial establishments, and households.  The
characteristics of waste materials typically describe whether the
materials are explosive, corrosive, flammable, ignitable, or toxic. They
may also identify pollutants of concern and pollutant concentrations.

The preferred waste management measure is pollution prevention -
preventing the generation of waste in the first place through source
control and source reduction.  Pollution prevention measures not only
reduce operational impacts on the environment, but reduce the costs
associated with raw materials  and waste disposal.  Whenever possible,
the environmental impact assessment should include a discussion of
•  Waste information:

   -  Description of
      management practices
   -  Types of waste (liquid or
      solid)
   -  Toxic potential
   -  Quantities
   -  Location of disposal

•  Pollution prevention:

   -  Source control
   -  Source reduction
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 Chapter 4 - Evaluation of Each Element
 existing pollution prevention initiatives.  This should include
 identification of opportunities for source reduction, recycling, and waste
 exchange.

 Solid waste management may include disposal at landfills or
 incineration. In some areas, there are no existing provisions for waste
 management. The environmental impact assessment should address the
 adequacy of landfill construction and operation and whether the landfill
 has sufficient capacity to handle generated wastes. This information
 may include an estimate of the waste generated, the average wastes
 buried in the landfill per year, the unused capacity of the landfill, and a
 projection of when the landfill will reach its capacity.  Descriptions of
 incinerators should include the amount of wastes the facility can handle
 in a given timeframe, as well as an estimate of the capacity at which it
 generally operates.

 Liquid wastes may be discharged directly to a receiving water body or
 may be sent to a sewerage system. The environmental impact
 assessment should describe the characteristics of liquid wastes in order
 to determine whether treatment is necessary prior to release into the
 environment or sewerage system.

 4.4.4 Socioeconomic Environment

 The attributes of the socioeconomic environment include land use,
 population and housing, economic activity (including employment and
 income), community services and public finance, transportation, and
 health and safety. The anticipated significance of the potential impacts
 will determine the extent of the socioeconomic analysis. In other words,
 the level of detail and depth of discussion required in describing each
 socioeconomic attribute should increase as the significance of potential
 impacts increases.

 Each of the socioeconomic attributes should be defined within the
 region of concern.  Typically, two factors are used in determining the
 region of concern for socioeconomic resources.  The first is the
 residential distribution of the population to be affected by the proposed
 project, and the second is the degree of linkage among the economies of
 communities in the region. This linkage, based on both trade among
 industry sectors and household purchasing patterns within the region,
 determines the nature and magnitude of economic multiplier effects in
the region.  (Section 4.4.4.3 discusses this concept in detail.)  Taking
 into account these two factors, it is common for regions of concern to
be drawn along established jurisdictional boundaries, such as counties
in the United States, to facilitate data collection and provide
comparability of attribute conditions.

 In some socioeconomic analyses, the region of concern may vary for
each attribute. For example, health and safety may be an issue in the
local or immediate area and the region of concern might be a
                         Solid waste management:

                         -  Capacity per unit time
                         -  Volume capacity
                         -  Adequacy of design
                         -  Acceptable wastes
                      •  Socioeconomic issues:

                         -  Land use
                         -  Population and housing
                         -  Economic activity
                         -  Education
                         -  Community services and
                            public finance
                         -  Transportation
                         -  Health and safety
                        Appropriately delineating the
                        region of concern is critical
                        to ensure the accuracy of the
                        assessment
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                                                            Chapter 4 — Evaluation of Each Element
 1-kilometer radius from the proposed project site, while impacts on
 community services should be assessed throughout the entire
 community.  The region of concern for employment and economic
 activity could be evaluated at several levels, including local,
 community, and regional. In general, however, the region of concern
 for population and housing, economic activity, and community services
 and public finance should be consistent due to the interrelated nature of
 these attributes. In evaluating the appropriateness of the defined region
 of concern, it is necessary to keep in mind that an excessively large
 region of concern can waste analytical resources and dilute the
 significance of potential environmental impacts. An excessively small
 region of concern can inappropriately exclude portions of the
 environmental setting from consideration.

 4.4.4.1 Land Use

 The environmental impact assessment should include a description and
 map of present and future land uses of the region of concern. Various
 types of land use are possible including undeveloped, agricultural,
 industrial, commercial, residential, recreational, and conservation areas.
 The environmental impact assessment should emphasize land uses that
 pose potential conflicts with the proposed project, such as irreversible
 conversion of high quality agricultural land or mining in the proximity
 of residential areas, public facilities,  or protected areas.

 The land use section also should highlight existing land use or zoning
 laws and other adjacent or nearby proposed developments.  If
 applicable, official government policy, such as protection of high
 quality agricultural land, must be included.  In addition, the anticipated
 (and/or required) use of the land once project operations are completed
 is important.

 A proposed project can be evaluated on the basis of its consistency and
 conformance with an available local or regional planning agencies'
 "master" or "comprehensive" land use plans. A land use plan
 commonly details (1) existing land use, (2) future land use, and (3)
 applicable land use controls. If the existing plan is thorough and the
 responsible agency has the authority to ensure conformance to the plan,
the proposed project can be compared to the plan to help identify
potential impacts. If a land use plan  does not exist, the plan is
inadequate, or the responsible agency has little authority to enforce the
plan, the project proponent should have conducted a more thorough
assessment. In addition, in the latter  situation, the likelihood that
adverse effects can be controlled or mitigated is greatly reduced.

4.4.4.2 Population and Housing

A general discussion of the demographic and housing characteristics of
the region of concern should include the following data:

    • Current and historical total population (e.g., 1995, 1990,1980);
Land use types:

-  Undeveloped
-  Agricultural
-  Industrial
-  Commercial
-  Residential
-  Recreational
-  Conservation
Land use plans contain:

-  Existing land use
-  Future land use
-  Applicable land use
   controls
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Chapter 4 - Evaluation of Each Element
     •  Rate of population growth;

     •  Population density;

     •  Average household size;

     •  Number of available housing units;

     •  Occupancy and vacancy rates (owner-occupied versus rentals);

     •  Median home values and median rent.

For a more detailed presentation, the environmental impact assessment
can provide information on the age, sex, and ethnic composition of the
population, as well as data on educational attainment levels, residential
tenure, and population growth factors, such as birth, death, and
migration rates. The goal of this section should be to analyze shifts in
population and predict changes in community profile, neighborhood
composition, and housing demand.  Projections of baseline (i.e., without
the proposed project) demographic trends for the region of concern are
also necessary to determine the relative magnitude of assessed future
impacts.

Project-induced employment changes probably will affect the migration
rates associated with the region of concern. The permanent and
temporary relocation of households in response to employment
opportunities will create a demand on the housing market and a demand
for additional community services.  For this reason, an accurate
description of the baseline housing stock and public facilities and
services is critical in assessing the extent of potential migration
impacts.

It may also be important to identify special segments of the population,
such as indigenous and disadvantaged persons, to facilitate a discussion
of potential environmental equity issues. If the significance of potential
impacts dictates, the demographic and housing data presented in this
section should be in a disaggregated form so that they can be used to
assess whether the distribution of impacts across segments of the
population is equitable.

Indigenous population refers to native people with cultural and
economic ties to the geographic area in which they reside. These
populations are particularly vulnerable to environmental and
socioeconomic change. If indigenous populations are identified in the
region of concern, the description section of the environmental impact
assessment should include a detailed description of their distribution,
life style, livelihood and legal status.

4.4*4.3  Economic Activity

A representation of the economic well-being of the  region of concern
should rely on data regarding the gross output (total sales and receipts)
                      •  Additional population
                         information that can be
                         included:

                         -  Age
                         -  Sex
                         -  Ethnicity
                         -  Education
                         -  Residential tenure
                         -  Births and deaths
                         -  Migration rates
                         Environmental equity
                         Economic activity:

                         -  Gross output
                         -  Employment levels by
                            industry
                         -  Personal earnings and
                            income
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                                                          Chapter 4 - Evaluation of Each Element
of regional businesses, employment levels by industry, and personal
earnings and income.  The section should generally begin with an
identification of the "base" industries in the region. These would be the
industries that bring outside revenues to the region (e.g., by sales to
customers or other firms outside the region), which are then re-spent
(multiplied) within the region through business purchases and payroll
spending. The environmental impact assessment should also include
unique features of the business community, such as high seasonality of
trade, high outflow of profit, declining trade, or downtown
revitalization, if pertinent.

A description of current employment categories and unemployment
levels is required to provide the basis for determining the suitability and
capacity of the available labor pool for meeting potential project
demands. This section should present the following employment data:

     •  Total civilian labor force;

     •  Total employment and employment by industry;

     •  Unemployment rates and characteristics.

The characteristics of the unemployed population, if available, are
especially important if the proposed project is expected to generate
employment. If warranted by the nature of the potential impacts, the
employment data should be maintained in a disaggregated form to
facilitate assessment of the equity of changes in employment across
segments of the local population.  In addition, the environmental impact
assessment should present projections on anticipated trends in baseline
employment and unemployment to facilitate assessment of future
project-induced employment changes.

Darnings and income data provide a representation of the relative
wealth of the region of concern population.  Regional statistics, such as
median household income, per capita income, average earnings per job,
and percent of households below poverty level, help describe the general
financial well-being and solvency of the regional population compared
to the broader state or national population.  Baseline income and wage
data are also helpful in assessing the potential earnings impacts that
may be associated with project-induced employment changes.

4.4.4.4 Community Services and Public Finance

Community services include municipal water supply, sewerage, storm
drainage and flood control, waste management, power supply,
education, health care, police and fire protection,  parks and recreation,
churches, and libraries. The environmental impact assessment should
describe these services, including the agencies or organizations that
provide the services, the nature of the services provided, and the target
population receiving these services. Existing levels of use and
remaining capacity to accommodate growth should be included if
•  An environmental impact
   assessment should describe:

   -  Community services
   -  The agencies or organiza-
      tions who provide them
   -  The nature of services
   -  Target populations
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Chapter 4 - Evaluation of Each Element
potential project-induced impacts are expected to affect the demand for
such services. General data on community services could include:

     •  Utility providers and current levels of service;

     •  Public school districts, numbers and levels of schools, teacher-
        student ratios, and total school enrollments;

     •  Hospitals and clinics, bed capacity, and number of physicians
        and surgeons;

     •  Police and fire protection agencies, jurisdictions, and number of
        officers and firefighters;

     •  Total park acreage and number and type of recreation facilities.

The environmental impact assessment may include maps showing the
location of services within the region of concern and their respective
sphere of influence, or service and support areas.  Assessing the
quality, or adequacy of the services provided, and the ability of the
existing public facilities and services to accommodate additional users
is critical if there are significant potential impacts, such as substantial
population in-migration generated by project-related employment
increases.

The environmental impact assessment can describe public finance in the
region of concern based on historic revenues and expenditure levels,
changes in fund balances, and reserve bonding capacities. If project-
induced impacts are expected to significantly affect public finances, this
section should discuss each jurisdiction's governmental funds (e.g.,
general fund, special revenue funds, and, as applicable, capital projects
and debt service funds) and tax and non-tax sources of revenue.

4.4.4.5 Transportation

Transportation systems provide access to a facility for the import of
raw materials, export of final products, and the movement of staff and
service personnel.  The environmental impact assessment should
describe all relevant forms of transport that would be affected by the
proposed project. Road-based transport usually is crucial for all
facilities.  In addition, railways, airways, pipelines, and navigable
waterways may be important for some facilities. The environmental
impact assessment should present current traffic volumes, current
traffic capacity, the provision of public transportation, and an
assessment of the adequacy of the systems for meeting peak demands.
The environmental impact assessment should also highlight any
regional transportation plans and indicate whether they were followed.

4.4.4.6 Health and Safety

If the proposed project is likely to impose risks to the health and safety
of the local population, the environmental impact assessment should
describe any present health and safety issues. The description should
                         Significant population in-
                         migration may tax the ability
                         of existing public facilities
                         and services
                         Transportation routes:

                         -  Roads
                         -  Railways
                         -  Airways
                         -  Pipelines
                         -  Navigable waterways
                         The environmental impact
                         assessment should describe
                         any present health and safety
                         issues
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                                                            Chapter 4 — Evaluation of Each Element
 include statistics on industrial accidents in the local area; information
 on air, water, and radioactive emissions from existing and prior
 facilities and their effects on human health and the environment; and an
 analysis of present levels of noise and its impacts on people and
 wildlife.  The environmental impact assessment should also identify
 special populations or areas that are more likely to be exposed to
 adverse impacts (e.g., subsistence fishing populations using water
 bodies that probably will be affected by the proposed project).

 4.4.5  Cultural Resources

 Cultural resources include sites, structures, and remains of
 archeological, historical, religious, societal, or aesthetic value to local,
 national, or international interests. The location of any proposed
 project can result in irretrievable loss of cultural resources, both known
 and yet to be discovered.  Preservation and management of cultural
 resources is important for maintaining a culture's  sense of history and
 identity. It is also important for the information that can be gained
 from studying the consequences of past actions and applied to the
 solution of current problems.

 The description section should identify known cultural resources,
 including the location of the following kinds of sites in relation to the
 region of concern:

     •  Archeological sites (where human-made artifacts or other
        remains dating from prehistoric times are found);

     •  Paleontological sites (where bones, shells, and fossils of ancient
        plants or animals are found in soil or imbedded in rock
        formations);

     •  Historic sites (where significant events happened or where well-
        known people lived or worked);

     •  Sites of particular educational, religious, scientific, or cultural
        value.

Depending on the nature of the proposed project and the extent of land
disturbance involved, it may be appropriate to develop a cultural
resources sensitivity map. In addition to mapping known cultural
resources, the map should indicate areas of low, medium., and high
probability of containing undiscovered cultural resources. These
estimates are best made by archaeologists and anthropologists familiar
with the local environment and patterns of spatial distribution of
cultural resources (e.g., soil conditions, proximity  to water sources, and
other topographic features associated with previous archeological
finds).

Aesthetics involve the general visual, aural, and olfactory environment
(imagine the sensory differences among urban, industrial, agricultural,
 Cultural Resources

    -  Archeological
    -  Historical
    -  Religious
    -  Societal
    -  Aesthetic
   It may be appropriate to
   develop a cultural resources
   sensitivity map
Aesthetics
   -  Visual
   -  Aural
   -  Olfactory

In other words, items that are
seen, heard, or smelled
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Chapter 4 - Evaluation of Each Element
and forest environments). The description section should describe the
aesthetic characteristics of the environmental setting—items that are
seen, heard, and smelled in and around the proposed site—and their
emotional or psychological effect on people.  Descriptions (or pictures)
of views of the proposed site, unique features or features deemed of
special value, and public use and appreciation of the proposed site
provide information to facilitate the assessment of potential impacts.

4.4.6  Reviewing the Description of the Environmental Setting Road
      Map

It is clear from the preceding parts of this chapter that the description of
the environmental setting in an environmental impact assessment
document is both important and complex. It is important because it
establishes  a baseline against which potential impacts can be compared.
It is complex because both the natural and human environment are
composed of an almost limitless collection of interacting and
interdependent components.  The reviewer's focus, that is, reviewing
the coverage, significance, adequacy, integrity and accuracy of this
chapter of an environmental impact assessment document, and for
maintaining the appropriate level of influence over its preparation, is
critical to ensuring an effective and informed decision-making process.

To help ensure that the review is systematic and complete, and that the
reviewer maintains the reviewer's focus, the following road map was
created to guide review of the description of the environmental setting
chapter of an environmental impact assessment document. This road
map reflects a composite of all of the issues that were described in
section 4.4.
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                                                           Chapter 4 — Evaluation of Each Element
           Road Map for Environmental Setting Review

     All relevant types of natural and human environmental issues are
     addressed

     Affected area or community is adequately and accurately defined

     Adequately map impact area and surrounding features

     Baseline is established to measure impact

     Appropriate information and data documented and used
     appropriately

     Information links back to project description, purpose and need,
     alternatives?

     Levels of detail are appropriate to significance

     Information and data is of acceptable quality and relevance?

     Section is internally consistent
Addressing all of these issues and questions will help ensure that the
review is systematic and complete.  If there are many instances where
the description of the environmental setting does not meet the reviewer's
expectations set forth in the road map, the environmental setting chapter
is probably inadequate and will require further work. It is the
reviewer's job to point out such deficiencies to the project proponent.

Because descriptions of the environmental setting are often quite
complex, no one reviewer is likely to hold expertise in all necessary
areas for a fully adequate review. The reviewer should have the
confidence to ask questions of colleagues and outside experts when
needed.
4.5  POTENTIAL ENVIRONMENTAL IMPACTS

The primary objective of the "environmental impacts" section of
environmental impact assessment documents is to clearly and succinctly
present each potential impact, qualitatively and/or quantitatively.  The
environmental impacts section forms the scientific and analytical basis
for the comparison of alternatives and determination of relative
significance of impacts.  The reviewer should take steps to help ensure
that all impacts (including primary, secondary, and cumulative impacts)
that are potentially significant have been considered and discussed in
the environmental impact assessment. The environmental impacts
section should discuss the potential beneficial and adverse impacts of
Each potential impact should
be presented clearly and
succinctly
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Chapter 4 - Evaluation of Each Element
each alternative and their relative significance, including clear, technical
demonstrations of:

     • Primary impacts—A primary impact is direct and occurs at
       the same time and place as the action. Primary impacts are
       associated with the construction, operation, and/or maintenance
       of a facility or activity. They are generally visibly obvious and
       quantifiable;

     • 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;

     • Cumulative impacts—Cumulative impacts result from the
       incremental impact of a proposed action on a common resource
       when added to other past, present and reasonably foreseeable
       future actions.  These may include the collective effects of
       individually minor actions over a period of time, (e.g., the
       combined effect of wastewater discharge, dredging, and
       agricultural runoff on a small estuary, or several dams
       constructed throughout a single river basin);

     • Project compliance—Demonstrated compliance with national,
       state, and local environmental regulations and standards;

     • Possible conflicts —Identification of possible conflicts
       between the alternatives and the objectives of national,
       regional, state, and local land use plans, policies, and controls
       for the area concerned;

     • Irreversible and irretrievable commitment of resources
       —The irreversible and irretrievable commitments of resources
       (e.g., land, energy, natural resources associated with the
       proposed project should be summarized).

It is important for the reviewer to remember that major impacts can
occur to a variety of resources (i.e., physical-chemical, biological,
socioeconomic, aesthetic, and cultural resources).  Therefore, the
environmental impact assessment analysis needs to be conducted in a
comprehensive, step-by-step fashion, assuring that potential effects
have been considered for all resources described in the description of
the environmental setting section.

It is also critical that the reviewer remembers that environmental
impacts can occur during every stage  of a project, from initiation to
post-completion operation. Specifically, the reviewer should check to
make sure that impacts are assessed for the following project stages:
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                                                            Chapter 4 — Evaluation of Each Element
 •    Initial site preparation and construction;

 •    Facility operation;

 •    Post-facility operations, or site closure.

 These categories are, of course, merely three convenient headings for
 what is actually a spectrum.  The reviewer should take steps to help
 ensure that impacts are assessed for all project phases. Because each
 phase  may have several sub-phases (e.g., there may be several distinct
 phases during facility operation), there should be a careful assessment
 as to whether all potential impacts were assessed; long, medium, and
 short-term.

 4.5.1  Methods of Analysis

 The potential impacts of each alternative are identified by a systematic
 disciplinary and interdisciplinary examination of the consequences of
 implementing each alternative. While information may be gathered
 from field surveys, related environmental impact assessments, discharge
 applications, and other sources, the reviewer is responsible for
 evaluating the scientific and professional integrity of the information
 used in the environmental impact assessment. Therefore, the
 environmental impact assessment must clearly identify data sources,
 references, methodologies, and models used to analyze or predict
 results. Detailed methodologies or extensive data can be incorporated
 by reference if the source is readily obtainable.

 Specific methodologies may be available to identify, qualify, and
 quantify impacts for a variety of media.  For example, air quality
 impacts may be predicted using standard, approved models, if
 available.  A matrix describing models commonly used in
 environmental impact assessment is presented in Appendix B. These
 models use site-specific data for existing air quality and expected
 pollutant emissions from the proposed project, as well as the
 topographical and meteorological characteristics of the region of
 concern, to predict the transport and fate of pollutants. This is followed
 by an assessment of the effect of predicted pollutant levels on receptors,
 including humans and other biological resources, sensitive habitats, and
 cultural resources.

 The goal of the environmental impacts section is to quantify potential
 impacts to the physical-chemical, biological and socioeconomic
 environments including air quality, water quality, soils, biological
 resources, employment,  land use, and community services. The section
 should identify potential primary and secondary impacts under each
alternative, discuss the significance of potential impacts, and assess the
potential cumulative impacts.  The analysis  should identify and assess
potential impacts for all stages of the proposed action, including initial
site preparation and construction, facility operation, and, in some cases,
post-facility or site closure.
   The environmental impact
   assessment must clearly
   identify data sources,
   references, methodologies,
   and models used to analyze
   or predict results
•  The goal of the
   environmental impacts
   section of the environmental
   impact assessment is to
   quantify or describe potential
   impacts on:

   -  Air quality
   -  Water quality
   -  Soils
   -  Biological resources
   -  Employment
   -  Land use, and
   -  Community services
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4.5.1.1 Determination of Significance

Significance may be defined by law, regulation, policy, or practice of
an agency or through the collective wisdom of a recognized group (e.g.,
industry or trade association standards). Impact significance, however,
is often based on the professional judgment of an expert or group of
experts. The determination of significance must be based on clearly
defined criteria.

Significance can also be examined in terms of the context and intensity
of an action. Context relates to geographical scale—local, regional,
state, national, or global; intensity is defined by the severity of the
impact (e.g., the magnitude of deviation from background conditions,
the size of the area affected, the duration of the effect, and the overall
likelihood of occurrence). The potential for significant impacts is
greater in areas that are protected, unique, sensitive, or recognized by
government agencies (e.g., significant historical or cultural resources,
parks, prime farm lands, wetlands, wild and scenic rivers, or
ecologically critical areas). Other important factors include:

     •  Degree of controversy among experts of the impact;

     •  Degree of uncertain or unknown risks;

     •  Likelihood that a precedent will be set;

     •  Occurrence of cumulative impacts (especially if individual
        impacts are not viewed as significant);

     •  Degree to which cultural or historical sites may be affected;

     •  Degree to which significant scientific, cultural, or historical
        resources are lost;

     •  Degree to which commercially or recreationally valuable,
        threatened, or endangered species or their critical habitat is
        affected;

     •  The likelihood of violations of national, state, regional,  or local
        environmental law or requirements or, alternatively, the
        likelihood that appropriate standards applicable to the
        operation and various environmental media can be achieved.

Professional standards and design specifications are techniques  that can
be used to determine impact significance. Use of these techniques
consists of comparing project parameters to known professional
standards, such as effluent guidelines, to assess potential significance.
In addition, public opinion can be used to determine the qualitative
significance, or a specific impact.
                         Determination of significan.ce
                         must be based on clearly
                         defined criteria
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The threshold of significance is different for each impact, and the
parties judging significance need to explain the rationale for the
thresholds chosen.  Clear descriptions of threshold choices for
determining the significance provide the reviewer with a basis for
agreeing or disagreeing with the determination of significance based on
specific assumptions, criteria, or data.  Further guidance on determining
significance is presented in Appendix C.2 and in the Resource Manual
accompanying the course Principles  of Environmental Impact
Assessment Review.

4.5.1.2  Cumulative Impacts

Cumulative impacts result from the incremental impact of a proposed
action on a common resource when added to other past, present and
reasonably foreseeable future actions. These may include the collective
effects of individually minor actions over a period of time.  This
"accumulating" impact assessment approach is particularly instructive
when no single project is a major cause of a problem but contributes
incrementally to a growing problem.  It is important to recognize that
some projects act as catalysts for future growth and environmental
change in the region of concern.

If other projects are planned during the same timeframe as the proposed
action and in the same region of concern, they should be listed in the
environmental impact assessment and included in the cumulative
impacts analysis.  When assessing the potential for cumulative impacts,
the project proponent and reviewer should consider the following
factors:

     •  Temporal accumulations of impacts and whether perturbations
        are spaced adequately to allow the ecosystem to recover from
        the change;

     •  Spatial accumulation of impacts and whether there is sufficient
        distance between perturbations;

     •  Sources of impact, including primary and secondary effects of
        individual and multiple sources;

     •  Pathways of impact accumulation, such as additivity and
        synergism;

     •  Thresholds of impact, including linear and non-linear
        thresholds.

Cumulative impact analysis is hindered by the complexity of the
mechanisms of accumulating effects  and by limitations in understanding
ecosystem processes and responses to perturbations. There is no
standard method for assessing cumulative impacts. A combination of
analytical techniques and planning processes is frequently used to
assess and address potential cumulative impacts.  Appendix C.2 and
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 the Resource Manual for the course Principles of Environmental
 Impact Assessment Review describe some of these methods.

 4.5.2  Pollutant Generation, Transport, and Receptors

 Pollutant generation, transport, and fate can affect the air, water, soil,
 and biological resources in proximity to the proposed site. The
 pathway of pollutant transport and the ultimate fate of pollutants
 depend largely on the physical nature of the pollutant itself.
 Particulates and gases are typically transported by air but may deposit
 in surface waters or soils. Liquid pollutants (e.g., fuels, solvents) can
 volatilize into the air or be transported through soils, sediments, or
 aquatic media, such as ground water or surface streams.  Solid
 pollutants, including sediments and sand,  can be transported by winds
 or surface waters. The environmental impact assessment should
 thoroughly assess all potential pollutants, their pathways, and predicted
 receptors based on modeling or other information.

 4.5.2.1 Air Resources

 Site leveling and grading during construction results in large quantities
 of airborne dust particulates that may contain toxic constituents.  Dust
 particulates may settle on local vegetation or water bodies or may be
 ingested by biological organisms, including humans.  Emissions from
 construction equipment, such as bulldozers and graders, may also
 adversely affect biological resources.

 Impacts from facility operations are primarily associated with pollutant
 generation and transport and related effects to surrounding habitat.
 Typically, facilities cannot operate without obtaining environmental
 permits for air emissions, and most permits are issued only after it is
 determined that environmental impacts will be acceptably small.
 Effective implementation and enforcement of environmental
 requirements serve to minimize adverse impacts from project
 operations.

 Project operations affect air quality through atmospheric emissions of
 particulates, hydrocarbons, carbon monoxide, carbon dioxide, sulfur
 oxides, and nitrogen oxides.  Particulates result in a "dirty" or "dusty"
 atmosphere and accumulate on surfaces. Toxic chemicals also attach
 to particulates, resulting in potential human health impacts if inhaled.
 Accumulation of toxic chemicals on land surfaces can also cause
 environmental impacts.

Hydrocarbons and carbon dioxide are primarily responsible for the
 "greenhouse effect," because they impede the radiation of heat from the
 earth's surface back to outer space, increasing the temperature of the
atmosphere. Carbon monoxide is a known toxicant, which can cause
neurological and lung disorders, and even death. Sulfur oxides and
nitrogen oxides are "acid rain" constituents,  which can lower the pH of
natural water bodies and damage natural and human-made materials
                         The environmental impact
                         assessment should thoroughly
                         assess all potential
                         pollutants, their pathways,
                         and predicted receptors based
                         on modeling or other
                         information
                       Primary Effects

                       • Airborne dust and dust
                         accumulations on surfaces
                         adjacent to the proposed site

                       • Adverse health effects to
                         biological organisms
                         (including humans) caused
                         by inhalation of toxics

                       Secondary Effects

                       • Airborne transfer of
                         pollutants to distant soils and
                         surface waters

                       Cumulative Effects from
                       Facility Construction

                       • Greenhouse effect

                       • Acid, rain
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                                                           Chapter 4 - Evaluation of Each Element
and structures. Emissions can also produce offensive odors extending
throughout large areas in the vicinity of the proposed site.

Facility emission sources include diesel generators, vehicles traveling to
and from the proposed site, and pollutants specific to the facility's
industrial process. The environmental impact assessment should
address all potential emission sources and assess their cumulative
impact on the environment.       -.•.---..

Air quality impacts can be determined quantitatively by comparing
expected emissions with emission standards set by national, state, or
local governments and by comparing the expected ambient
concentrations of pollutants caused by facility emissions and other
sources with ambient concentration standards.  Monitoring  and
modeling are the two most common techniques used for air  quality
evaluations. Monitoring is often required to establish baseline ambient
concentrations for pollutants of concern prior to facility construction
and can be used to determine facility compliance after operations begin.
In addition, modeling is used to assess potential impacts from the
proposed project using mathematical simulations of dispersion. If air
quality models are used in the environmental impact assessment, the
reviewer should take steps to help ensure that the following  four major
input requirements were used during modeling:

    •  Emissions data;

    •  Stack information (e.g., stack height, diameter, temperature of
        exit gas, flow rate);

    •  Meteorological data (e.g., local wind speed, direction, and
        precipitation levels);

    •  Receptor coordinates and elevations.

    Critical Questions:

    • Will dust or air pollutants be generated from construction and
        site preparation activities?

       -   Does the environmental impact assessment identify
            emission sources and project emission rates and compare
            these rates to applicable national, state, and local
            standards and limitations (both emissions and air quality)?

       -    Does the environmental impact assessment compare
            predicted atmospheric levels with national, state, or local
            ambient standards?

    •  Does the environmental impact assessment identify emission
       sources and rates, including existing and known potential
Common Air Quality
Evaluation Techniques

•  Monitoring (to gauge pre-
   project ambient conditions
   and to track changes after
   project initiation)

•  Modeling (to predict project-
   related effects)
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Chapter 4 - Evaluation of Each Element
        sources in the vicinity not associated with the proposed site,
        and assess expected concentrations of pollutants in air?

     •  Are emission rates and resulting concentrations compared to
        applicable national, state, and local standards and limitations?

     •  Will facility operations result in noncompliance with air
        emission and ambient air quality standards?

     •  Have measures to control air emissions been addressed in the
        proposed project design? Will these measures be adequate?

     •  Does the environmental impact assessment describe stack
        emissions during operation and maintenance activities and
        compare these with existing national,  state, and local
        standards?

     •  Will stack emissions from the facility have deleterious effects
        on visibility and light scattering (i.e., cause smog); damage
        natural or human-made materials and structures (i.e., cause
        acid rain); or adversely affect human health, domestic animals,
        wildlife, or vegetation?

4.5.2.2 Water Resources

Construction activities can affect water resources depending on their
proximity to the proposed site. Settling of dust into water bodies
results in increased water turbidity. Vegetation removal and soil
compaction by construction machinery results in increased runoff
following rain events and greater volumes and velocity of water that
must be carried by local water bodies. This in turn may result in
sedimentation in receiving waters and adverse effects to aquatic
vegetation and other resident biological organisms, such as fish
populations. For example, elevated turbidity may reduce the amount of
available light, thereby decreasing photosynthetic rates of aquatic
vegetation, or may clog the gills offish with suspended particulates,
reducing respiratory function. In addition, increased sediment loads
frequently carry nutrients and toxic pollutants to receiving water
bodies.

A minor source of pollutants during the construction phase is oil or
other hazardous material that can leak or otherwise emanate from
construction equipment. These materials may leach into ground water
or be transported with runoff to local water bodies. Depending on their
concentration, these materials can cause toxic or bioaccumulative
effects to local biological resources.

Impacts to water range from water quality degradation caused by
discharges of toxic pollutants and excessive nutrients or oxygen
demanding substances to hydromodification impacts associated with
increased impervious area, soil exposure, and erosion.  Pollutants may
                      Primary Effects

                      •  Sediment loading of water
                         bodies adjacent to the
                         proposed site and associated
                         habitat alteration

                      •  Accumulation of toxics
                         within adjacent water bodies
                         resulting from site erosion
                         and runoff

                      ป  Increased water body
                         turbidity and decreased
                         photosynthetic rates for
                         aquatic vegetation

                      •  Burial of aquatic benthic
                         invertebrates

                      •  Clogging offish gills with
                         suspended particulates

                      •  Bioaccumulation by aquatic
                         organisms of toxic
                         constituents from eroded
                         sediments and airborne
                         particulates

                      •  Contamination of ground
                         water and/or surface water
                         from leaks or effluent
                         discharge
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                                                            Chapter 4 - Evaluation of Each Element
 enter surface waters from waste disposal to land, effluent discharges to
 water bodies, and precipitation runoff. Nutrients (nitrogen and
 phosphorus compounds) in water can lead to eutrophication—excess
 plant growth resulting in algal blooms, weed-choked water bodies, and
 fish kills. Excess nitrogen in drinking water causes human health
 problems, particularly to infants. Toxic contaminants result in acute
 and chronic toxicity to aquatic biota, as well as possible human health
 affects associated with ingestion of contaminated water and food. The
 temperature regimes of receiving waters may be changed through warm
 water effluents. Increases in ambient temperatures generally reduce
 biodiversity by limiting the abundance of cold water fish species or can
 lead to introductions of potential nuisance species.

 Potential water quality impacts can be determined by comparing
 effluent concentrations to relevant water quality standards or by
 predicting ambient concentrations and comparing these with water
 quality standards or acute/chronic toxicity levels. If particular
 contaminants are predicted to be more significant than others (i.e., large
 quantity or high toxicity), the environmental impact assessment should
 focus on the transport and ultimate fate of these pollutants. The
 environmental impact assessment should also consider the potential for
 contaminant bioaccumulation in the local food chain.  Modeling studies
 can also be used to assess concentrations of contaminants in receiving
 waters caused by process and storm water discharges or estimate
 concentrations of chemicals in aquatic biota resulting from the proposed
 action (e.g., fish uptake and food chain models). If water quality
 models are a component of the environmental impact assessment,
 specific inputs should include information on source input(s) (e.g.,
 effluent composition, concentration, and volume) and receiving water
 characteristics (e.g., currents, wind, flow rate, tidal range,
 stratification). The assessment should clearly state whether or not
model results have been tested or verified using range checks or other
 evaluation techniques.  Modeling exercises should include the impacts
of existing and planned sources, in addition to the proposed project and .
alternatives, and should be calibrated specifically for the system under
study.

     Critical Questions:

     • Does the assessment address the potential for water quality to
       be degraded by increased surface runoff (sediment and
       pollutant discharges), discarded or discharged construction
       materials and other chemicals, herbicides, wastewater, soil
       additives, disturbance of stream bed, or temperature increases
       due to increased turbidity or removal of vegetation?

       -   Does the assessment predict sediment loading and
            compare loadings and predicted in-stream concentrations
            of associated pollutants with existing national, state, and
            local water quality standards and criteria?
Secondary Effects

••• Modification of watershed
   drainage

•  Eutrophication or
   contamination of distant
   surface waters via site runoff

Cumulative Effects from Facility
Construction

•  Water quality degradation in
   excess of accepted standards
   due to multiple source loadings
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Chapter 4 - Evaluation of Each Element
       -   Does the document assess the potential effects to ground
            water quality from use or disposal of chemicals or
            nutrients? If ground water might be affected, does the
            assessment consider avoiding placement of contaminant
            sources over aquifer recharge areas?

       -   Will facility siting avoid direct contact with ground water
            during foundation work, tunneling, or construction of
            underground utilities?

       -   If the proposed project site is within an aquifer discharge
            area, will protective measures, such as liners and
            containment areas, be implemented?

       -   Is there a potential for increased overland flow, storm
            water runoff, flooding, stream bed sedimentation, or
            channel erosion due to increased runoff following
            proposed site preparation and construction activities?

            Does the construction plan limit the use of materials that
            can negatively affect the environment, particularly water
            resources?

            Is there a spill control/response plan that properly
            addresses spills of hazardous construction materials?

            Will hazardous materials be stored at the construction
            site?  If so, have provisions been identified to keep them in
            storage buildings located away from construction
            activities?  (Hazardous materials include petroleum
            products, fuels, solvents, paints, herbicides, and batteries.)

        Is there a potential for toxic pollutants and/or organic matter
        from waste disposal, effluent discharges, or precipitation runoff
        from storage areas to have deleterious effects on ground water
        or surface water?

        Does the assessment attempt to predict pollutant concentrations
        in ground waters and surface waters and compare results with
        existing national, state, and local water quality standards and
        criteria?

        Does the assessment discuss both short- and long-term impacts
        to the biological community caused by the discharge?

        Does the document assess receiving water temperature
        distributions around and below discharge locations and
        compare results with national, state, or local standards? If
        standards do not exist, does the environmental impact
        assessment assess the impact of temperature changes on the
        aquatic ecosystem?

        Would facility operation cause increased sedimentation and
        habitat destruction?
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                                                            Chapter 4 — Evaluation of Each Element
     •  Does the document assess aquatic habitats that might be
        affected by increased sedimentation or alteration of the existing
        flow patterns of water courses and assess the magnitude of the
        effect?

4.5,2.3 Geological Resources

The environmental impact assessment should assess the effects of site
construction on geological resources.  Construction activities include
leveling of hills, removal of rocks and soil, filling of valleys or
depressions, or other alterations to existing terrain. Modification of
geological resources can directly affect biological resources through
habitat loss. In addition, these alterations indirectly affect water
resources by changing local runoff patterns and other watershed
features.

During site preparation and construction, clear-cutting and removal of
ground vegetation typically results in soil erosion. Sediment loadings
from uncontrolled construction sites have been reported to be on the
order of 35 to 45  times greater than loadings from undisturbed
woodlands (typically less than 1 ton per year).  The extent of impacts to
geological resources depends on site geological/topographic features,
including slope, soil composition, and soil permeability, and whether or
not mitigative measures (e.g., use pf vegetative buffers to filter
sediments and sediment-bound pollutants) have been implemented.

The majority of impacts to  soils are expected to occur during site
preparation  and construction. After operations begin, however, the
potential for soil contamination is high due to spills in raw material/
product loading and unloading areas, materials storage areas, and
production areas. The potential for soil contamination is also high in
areas used for onsite waste storage or treatment facilities. Frequently,
land treatment units or landfills are used; sometimes waste materials are
stored in piles or drums.  Contaminant runoff or leachate from these
areas can percolate through soils to ground water. Soil contamination
can also occur from runoff of contaminant residues onto impervious
surfaces, such as  roads, parking lots, and runways.

Soil erosion and sedimentation may continue to occur after
construction. The extent of the problem depends on the effectiveness of
erosion control techniques used to stabilize the site after construction.

    Critical Questions:

    • Does the environmental impact assessment determine the
       potential for soil loss during construction and facility operation
       and discuss mitigation activities to reduce erosion?

    • Does the environmental impact assessment identify potential
       sources of soil contamination and describe feasible mitigation
       measures?
Potential Primary Effects

•  Soil contamination from leaks
   or spills

•  Loss of soil due to erosion

Potential Secondary Effects

•  Slope failure

•  Destabilization of shorelines

Potential Cumulative Effects

•  Desertification
   Soil impacts can occur both
   during facility construction
   and after, during facility
   operation
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Chapter 4 - Evaluation of Each Element
4.5.2.4 Biological Resources

During the project construction phase, biological resources may be
affected directly through loss of habitat, food resources, nesting areas,
or migration routes present within the region of concern or indirectly
through sediment loadings into nearby water bodies or pollutant
transfer to adjacent soils or surface waters resulting from site runoff.

As discussed in previous sections, facilities may discharge pollutants to
air, water, and soils. Contamination of local resources may result in
localized or widespread degradation of vegetative or wildlife habitat.

Sediment loadings potentially affect both terrestrial and aquatic
resources.  Sediment erosion results in loss of ground cover and
foraging ranges for terrestrial species. Sediment transport to local
water bodies causes burial of bottom dwelling organisms, reduced
dissolved oxygen levels, habitat alteration, and, depending on the
presence of toxics, bioaccumulative effects.

     Critical Questions:

     •  Does the environmental impact assessment consider potential
        losses of biological resources (especially rare and game species
        and/or critical habitat) known to exist within the region of
        concern?

     •  Have mitigative measures, such as vegetative buffers to prevent
        erosion, and spill response plans been included for the site
        construction phase?

     •  Does the environmental impact assessment address sediment
        transport impacts on aquatic resources during construction and
        operational phases?

     •  Does the environmental impact assessment describe effluent
        and emission concentrations and their potential toxic effects to
        vegetation and wildlife?

     •  Does the environmental impact assessment discuss potential
        bioaccumulative effects to biological resources from facility
        emissions and discharges?

4.5.3 Habitat Alteration

Habitat alteration is most evident during initial project construction
phases. Site preparation and construction can include some degree of
land leveling and soil compaction and the erection of production
facilities, raw material loading and unloading areas, raw material
storage areas, waste storage and disposal areas, and a transportation
system for moving materials from one area to another.  In the first stage
                       Secondary Effects

                       • Water quality degradation

                       • Modification of aquatic
                         habitat from erosion and
                         runoff

                       Cumulative Effects

                       • Bioaccumulation of toxics
                         resulting in ecological and
                         human health risks
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of construction activity, land is cleared and prepared for storing
building materials, transporting materials between the storage areas and
building sites, and preparing the building sites themselves.  For very
large facilities, stone crushing, concrete mixing, and other materials
processing facilities may also be built onsite. Facility operations affect
habitat primarily through pollutant generalization and transport. The
extent of impact depends, in large part, on the effectiveness of
restoration measures taken during the construction phase.

4.5.3.1 Biological Resources

The extent to which habitats are affected by proposed site clearing and
grading depends on the extent to which natural ecosystems were
disturbed previously.  Conversion of a wooded area results in greater
changes than conversion of a former industrial site. The habitats
associated with heavily vegetated areas are usually more densely
populated and diverse in species than those associated with previously
developed sites.

As described earlier, site construction activities may affect air, water,
or geological resources in proximity of the proposed site, all of which
may serve as habitat for a variety of organisms. Removal of native
vegetation during construction directly affects some species by
destroying their protective cover, food sources, or roosting, nesting, or
breeding sites.  Clear-cutting trees within the proposed site results in
reduced shading and may increase water temperatures within local
water bodies.  Over time, this could lead to reductions in dissolved
oxygen concentrations and adverse effects on aquatic resources.

Sediment erosion from the proposed site leads to deposition of
sediments on stream bottoms, altering the nature of the substrate and
changing stream bottom fauna from hard bottom or riffle communities
to soft bottom communities. If the stream bottom community changes,
the species offish inhabiting the stream will also change.  Depending on
previous site uses, sediment may be associated with toxic chemicals
that tend to adsorb to particles. If toxic components exist in dust or
sediment, the potential for bioaccumulative effects to  biological
organisms is greater.

The environmental impact assessment should assess the potential
damage or destruction of sensitive ecosystems from siting facilities in
close proximity. Improper siting with respect to slope and local
hydrology can affect sensitive areas by altering the local hydrological
regime, increasing runoff and erosion, and destabilizing slopes,  dunes,
or shorelines.

Even if natural habitats  are not destroyed completely by clearing and
grading, they may lose their value for some species because available
habitat is diminished. Some species require habitat of a particular
minimum size in order to survive. If the habitat is disrupted or
•  Maintaining a minimum
   habitat size is crucial to the
   survival of many species of
   animals, insects, and plants
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Chapter 4 - Evaluation of Each Element
otherwise reduced in size, for example, by construction of a road, the
size of the available habitat type may prevent continued species
survival, and individuals may leave the area or succumb.

In addition, the environmental impact assessment should describe noise
and disturbance impacts created by construction activities, such as
large trucks, bulldozers, and grading equipment, and their potential
effects on feeding, breeding, nesting, and other activities of local
species, even those inhabiting areas outside the region of concern.
Disturbance also may result in species leaving the area and subsequent
effects to local ecosystem dynamics,  in a manner similar to habitat
fragmentation.

     Critical Questions:

     •  Does the environmental impact assessment assess the potential
        effects of site preparation and construction activities on air,
        water, or geological resources?

        -   Is the proposed project designed to avoid or mitigate storm
            water impacts through the use of an infiltration field,
            retention basins, or other measures to reduce runoff?

        -   Does facility siting avoid steep slopes to prevent erosion
            or slope failures?  If the facility is sited on a slope, will
            erosion control measures, such as maintenance of
            vegetative cover, application of temporary soil covers
            (e.g., straw), and timing of construction activities to avoid
            heavy seasonal rainfall, be used to prevent erosion?

     •  Does the environmental impact assessment address the
        potential for construction and site preparation activities to alter
        critical habitats for wildlife, which could affect the local
        presence of such species?

        -   Does the environmental impact assessment quantify areas
            and locations of habitats and associated species that would
            be lost or adversely affected during site preparation and
            construction activities?

        -   Is the construction designed to cause the least possible
            disturbance to site vegetation (e.g., have attempts been
            made to preserve old-growth stands or  individual trees)?

        -   Does the construction plan provide for erosion and
            sediment control during and after construction?

        -   Will soil excavated from the site be reused, for example,
            as topsoil in landscaped areas?

        -   Will disturbed areas be revegetated following
            construction?

     •  Is there a potential for indirect  changes in habitats following
        construction and site preparation activities (e.g., increased
                      Additional potential impacts
                      on habitat

                      • Noise
                      • Physical disturbance of
                         nesting, breeding, or roosting
                         sites
                      Primary Impacts from Facility
                      Construction

                      • Loss of protective cover,
                         food sources, or roosting,
                         nesting, or breeding sites

                      • Reduced species abundance
                         and diversity

                      • Degradation of sensitive
                         ecosystems

                      • Alteration of aquatic bottom
                         habitat due to sediment
                         erosion and runoff

                      • Fragmentation or
                         simplification of habitat

                      • Species disturbance from
                         noise and other construction
                         activities
                       Secondary Impacts from
                       Facility Construction

                       •  Dissolved oxygen reductions
                          in surface waters

                       •  Invasion of exotic species

                       Cumulative Impacts from
                       Facility Construction

                       •  Bioaccumulation of toxics
                          resulting in potential
                          ecological and human health
                          risks.
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        erosion potential resulting in habitat disturbance through
        sedimentation in water bodies, disturbance of habitat and/or
        species from increased human access, modification of
        watershed)?

        -    Does the environmental impact assessment identify
             activities that would indirectly alter habitats and quantify,
             to the extent feasible, the areas that would be affected
             indirectly?

     •  Will the facility be sited at a maximum distance from sensitive
        areas, such as wildlife habitats, wetlands, floodplains,
        streambanks, coastlines, and protected preserves?

        -    Does the environmental impact assessment identify any
             sensitive habitats in the vicinity of the proposed site? If
             so, have all possible mitigative measures been considered
             (e.g., alternative site selection; site location away from
             streambanks/beds, floodplains, shorelines, and flood-prone
             areas) to avoid impacts to sensitive ecosystems?

        -    Will buffers, such as wetlands or forests, be used between
             the proposed development site and water bodies to
             minimize impacts to aquatic systems?

     •  If roads, pipelines, or bridges are planned as part of the
        construction, does the environmental impact assessment discuss
        taking advantage of existing corridors (e.g., roadways,
        transmission lines) to avoid disrupting additional habitat?

After construction is completed, impacts from facility operations are
related primarily to pollutant generation and transport.  Facility
operations can emit or discharge contaminants into air, water, or soils,
potentially causing environmental degradation and subsequent effects to
local biological resources. The following discussion highlights
potential impacts to biological resources  caused by facility emissions
and discharges  during operation phases.

Because construction removes much of the existing vegetative cover,
the environmental impact assessment should recognize that impacts to
local habitats may continue once facility  operations begin.  The impacts
associated with operational activities vary,  depending on the proposed
site, but can be particularly acute if environmentally sensitive or
ecologically important areas are affected. For most construction
projects, removed natural vegetation is not replaced onsite, either
because the area is rendered impervious or the land is disturbed to a
point that it will no longer support native vegetation. Often, the
replanting that does occur is done for aesthetic purposes; land is
converted to turf grass or ornamental landscaping plants are used.
While aesthetically attractive to humans, these non-native vegetative
covers do not offer the same level of environmental protection or
ecological value as natural vegetation.  Thus, the environmental impact
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 Chapter 4 - Evaluation of Each Element
 assessment should address the impacts caused by loss of native
 vegetation. Facility operations may also lead to increased access to
 remote areas, resulting in additional species disturbance.

 The absence or scarcity of vegetation removes or reduces the pollutant
 buffering capacity of the site, contributing to some of the following
 impacts:

     • Increased potential for water pollution because runoff volume
        and velocity will be increased and will enter water bodies
        directly without the filtering effects of vegetation;

     • Reductions in wildlife species number and abundance due to
        the loss of habitat and foraging grounds;

     • More severe weather conditions, including wider temperature
        fluctuations and stronger winds  generating dust

     • Increased noise levels caused by the loss of trees and other
        vegetative buffer areas.

 Wildlife impacts are primarily associated with changes that occur
 during site preparation and construction. However, many impacts are
 carried over into the operation phase and remain throughout the life of
 the facility. Habitat restoration is often impossible during operations
 because of irreversible damage done to soils and topography or the
 construction of buildings, roads, and storage areas.

 As described previously in this  section, the habitat loss associated with
 vegetation removal can have both primary and secondary effects.
 Primary impacts to species are expected if organisms depend on the
 removed vegetation for survival.  Secondary impacts include water
 quality degradation and stream  habitat damage resulting from erosion
 and runoff.

 All of these impacts affect the food supplies and living conditions of
 biological communities, ranging from the smallest microbes to large
 animals. Food sources may be destroyed, modified, or contaminated.
 Foraging, nesting, and breeding locations may be degraded or lost
 permanently. Living and breeding ranges may become fragmented or
 simplified, leaving areas too small or unstructured to support species.
 Exotic species may invade a region and out-compete resident species.
 Travel/migration routes may be altered by the activities and
 infrastructure involved in constructing and operating a new project. All
 of these conditions affect the composition, distribution, abundance,
 health, and vitality of resident species.
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Critical Questions:

     • Does the environmental impact assessment assess whether
       facility operations will permanently cause the loss or
       displacement of vegetation habitat and, therefore, floral species
       (rare, threatened, endangered, unique or unusual, or
       commercially valuable species, communities, or habitats)?

     • Does the environmental impact assessment identify critical
       vegetative habitats and associated species that will not be
       restored following facility construction?

     • Does the environmental impact assessment assess changes in
       local vegetative species composition, diversity, and abundances
       resulting from loss of specific types of habitats?

     • Does the environmental impact assessment address hazards to
       vegetation from air and water quality degradation?

     • Does the environmental impact assessment describe onsite or
       offsite compensation to replace vegetation loss?

     • Does the environmental impact assessment include a
       monitoring program to ensure effective implementation of
       mitigation measures?

     • Does the environmental impact assessment assess whether
       facility operations will cause permanent loss or displacement of
       wildlife habitat and, therefore, faunal species (rare, threatened,
       endangered, or game species)?

     • Does the environmental impact assessment identify critical
       habitats for wildlife and associated species that wUl be lost
       during construction and not replaced during facility operations?
       Rare, endangered, and commercially valuable species, as well
       as ecosystems, communities, and habitats should be included
       within the assessment.

     • Does the environmental impact assessment assess changes in
       local wildlife species composition, diversity, and abundances
       caused by human activity in the vicinity of the proposed
       project, including potential invasion by exotic species?

     • Will air, water, and soil quality degradation from toxics
       produced during operation and maintenance activities pose
       hazards to area fauna (resulting in death or reduced viability)?

     • Does the environmental impact assessment assess hazards to
       wildlife from air, water, and soil quality degradation?

     • Does the environmental impact assessment describe migration
       routes and movement corridors of sensitive species that may
       potentially be disturbed by facility operation?
Primary Effects from Facility
Operations

•  Degradation of habitat due to
   facility emissions and
   discharges

•  Species disturbance

•  Reductions in species
   abundance and diversity

•  Loss of ground cover, food
   resources, and breeding,
   roosting, or nesting habitat

Secondary Effects from
Facility Operations

•  Pollutant transfer to surface
   waters and associated aquatic
   organisms due to erosion and
   runoff

•  Modification of aquatic
   habitat following sediment
   loading

Cumulative Effects from
Facility Operations

•  Bioaccumulation of toxics
   resulting in potential
   ecological and human health
   risks
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      •  Will onsite or offsite compensation be used to mitigate loss of
         wildlife?

 4.5.4 Waste Management and Pollution Prevention

 Waste generation during project construction and operation can be a
 significant source of adverse environmental impact in the region of
 concern. Primary impacts result from contamination of air, soil, and
 water from improper waste storage, handling, transportation, and
 disposal. Secondary impacts may include placing a burden on the
 community's waste management capacity. Cumulative impacts can
 arise from long-term accumulation of toxic pollutants in the region and
 from the additive effect of multiple sources of wastes on the
 community's waste management capacity.

 A variety of waste management and pollution prevention measures can
 be implemented during the siting and construction phase to avoid or
 minimize adverse impacts. The environmental impact assessment
 should address these measures.  Selection of durable, long-lasting
 materials containing recycled or refurbished components reduces the
 overall volume of construction waste. Reuse or recycling of
 construction materials and natural resources, such as trees removed
 during construction, further reduces waste volumes.

 The environmental impact assessment also should address pollution
 prevention and waste management during the operational phase of the
 proposed project. The environmental impact assessment should include
 a description and estimate of project wastes and should address waste
 type, quantity, and toxic potential. Pollution prevention opportunities
 should be investigated by the project proponent. The environmental
 impact assessment should describe the proposed project waste
 management plan, including treatment, handling, and disposal. Each of
 these components should be designed to reduce the risk of accidental
 releases of toxics to the environment. In addition, onsite and offsite
 waste management techniques and disposal areas should be identified
 and their long-term capacity defined.

     Critical Questions:

     • Will the proposed project include the use of durable, long-
       lasting materials that will not need to be replaced frequently,
       reducing the amount of construction waste generated over time?

     • Does the construction plan include provisions for proper
       storage of construction materials to reduce the amount of waste
       caused by damage or exposure to the elements?

     • Will perishable materials, such as paints, be purchased
       incrementally to ensure reduced spoilage of unused materials?

     • Will the proposed construction project use materials containing
       recycled content when possible and in accordance with
                      Primarv impacts

                      • Contamination of air, soil, and
                         water from improper waste
                         storage, handling, and disposal

                      Secondary impacts

                      • Additional burden on
                         community waste management
                         capacity

                      Cumulative impacts

                      • Accumulation of toxic
                         pollutants
                      • Rapid consumption of
                         community waste management
                         capacity due to the additive
                         effect of multiple wastes
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       accepted standards? Examples of recycled content materials
       include concrete containing fly ash and thermal insulation
       composed of cellulose.

    • Does the environmental impact assessment describe a facility
       waste management plan with procedures for treatment,
       handling, and disposal?

    • Does the environmental impact assessment discuss projected
       facility waste characteristics?

    • Does the environmental impact assessment assess long-term
       waste disposal and disposal site capacities?

4.5.5  Socioeconomic Impacts

In addition to the environmental impacts described above, the
construction and operation of new projects, or the modification of
existing projects, may affect the local socioeconomic framework in a
variety of ways.  Elements of the socioeconomic impact analysis can
include (1) the compatibility of new land uses with existing land uses,
(2) issues associated with human and institutional resources and
impacts on community structure, and (3) effects on local economic
activity.  The elements are often interrelated in their response to a
particular action.  A project-induced change in employment demand, for
example, could lead to population movements into or out of a region
and, in turn, lead to changes in demand for housing and community
services.

The analysis of socioeconomic impacts should consider both impacts on
economic activity and on the community.  Economic activity can be
measured by changes in regional output, employment, and earnings, and
the community by changes in population, demand for housing and
community services, and effects on land use, transportation, and public
finance.  The impact analysis should estimate the potential social and
economic impacts expected to occur within the region of concern as a
result of implementation of the proposed project.

The socioeconomic impacts estimated in the analysis would be
generated by the proposed expenditures and employment associated
with the proposed project. The total socioeconomic impact includes
both primary and secondary impacts.  In general, the primary impacts
are the estimated changes in project revenues, employment, and payrolls
(employee earnings) that would occur during the construction and
operations phases (if applicable) of the proposed project.  Primary
impacts also include the resultant effects on regional population,
housing,  and community services associated with the change in
employment.

Secondary effects are the impacts on regional economic activity that
result from regional project-related purchases of goods and services
from local business and suppliers. Related impacts include the
Socioeconomic impacts

•  Compatibility of new land uses
   with existing land uses
• , Issues associated with human
   and institutional resources and
   impacts on community
   structure
•  Effects on local economic
  •activity
Changes in economic activity

•  Regional output
•  Employment
•  Earnings

Changes in the community
   Population
   Demand for housing and
   community services
   Land use
   Transportation
   Public finance
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  additional changes in regional economic activity that result from
  changes in the household spending of employees whose jobs are
  affected by either the change in employment at the proposed project or
  the change in employment at regional businesses that results from the
  secondary impacts to regional economic activity.

  4.5.5.1 Land Use

  The impact of the proposed project on land use depends on the
  adequacy of existing land use planning and control practices. These
  practices should include both a long-term comprehensive plan and
  effective implementation mechanisms.  To the extent the proposed
  project is consistent with the plan and addresses implementation of land
  use controls, then potential impacts may be low. If land use planning
  and control practices are inadequate or ignored, however, potential land
  use impacts from both the proposed project and possible encroachment
  activities caused by the proposed project can be significant.

 Project Construction

  Site preparation for the construction of new projects can disturb large
 areas of land and may change land use patterns in the area. Open
 spaces (agricultural land, forested areas, or other vacant land) are often
 used for these projects.  A new land use may not be compatible with, or
 easily returned to, its original state. In particular, industrial sites and
 infrastructure projects are not easily converted back to either forest,
 agricultural, or residential land. The construction sites for large
 projects in general are frequently considered temporary industrial land
 uses, regardless of the ultimate land use being developed. Once
 construction is initiated,  the options for converting the proposed site to
 other land uses become limited.

 Of particular importance is the potential for land use in the surrounding
 area to change as a result of construction activities. Housing usually is
 needed for the large construction crews required to build large facilities,
 and construction workers generally prefer to live near the work site.  If
 the proposed site is in a predominantly residential area, then housing
 will not necessarily be a problem (although housing values may change
 depending on their proximity to the proposed project). If the proposed
 site is far from a residential area, however, additional housing, often
 temporary structures, may develop in the immediate vicinity. In
 addition, small-scale commercial areas tend to develop around
 construction sites to provide food and services for workers and to
 provide construction support services.

     Critical Questions:

     •  Are adequate land use planning and control mechanisms in
        place and enforced?
                           Site preparation for the
                           construction of new projects
                           can disturb large areas of land
                           and may change land use
                           patterns in the area
                           Housing is usually needed for
                           the large construction crews
                           required to build large
                           facilities, and construction
                           workers generally prefer to live
                           near the work site
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    • Are the proposed project facilities and associated construction
       activities in conformance with the plan?

    • Will the construction and site preparation activities be
       compatible with the projected uses of adjacent, existing, or
       planned land uses?

    • Is the proposed site located in an area with existing or planned
       compatible activities or will the facility result in adverse
       aesthetic impacts or conflict with current or future residential,
       agricultural, or other land uses?

    • Does the environmental impact assessment identify the amount
       of existing or planned land use areas lost due to  site preparation
       and construction activities? Does the document describe
       expected changes in land use  on adjacent properties?

    • Does existing land availability, as determined by zoning and
       land use plans, conflict with proposed site preparation and
       construction activities?

    • Does the environmental impact assessment determine the extent
       to which site preparation and construction activities conflict
       with zoning requirements and existing or future  land uses?

Project Operation

Significant land use impacts can occur during the operational phase. A
potential major impact on land use is  the conversion of nearby land to
new uses stimulated by the proposed project. For example, industrial
projects may stimulate conversion of nearby land to related industrial
activities or residential use to meet the needs of an expanded labor
force. Tourism development projects, including  resort hotels,
frequently stimulate the development  of related facilities, such as
restaurants, shops, and other attractions.  The conversion of additional
land may not cause any adverse impacts if it is controlled through
effective planning. The environmental impact assessment should
discuss the potential for changes to existing land use patterns that might
be stimulated by the proposed project.  The potential environmental
impacts of additional land use changes  should be discussed as
cumulative impacts.

Given an appropriate local land use planning process and plan, the
assessment of the land use attribute of an environmental impact
assessment is driven by two evaluation criteria:  (1) conformance with
the land use plan and (2) compatibility with adjacent land uses. A third
criterion, "capacity," is more conveniently addressed under the
transportation and community services resources.

To the extent that a proposed project directly causes or indirectly
induces a land use that does not conform to the land use plan, there is
   A potential major impact on
   land use is the conversion of
   nearby land to new uses
   stimulated by the proposed
   project
Land use evaluation criteria

1) Conformance with the local
   land use plan
2) Compatibility with adjacent
   land uses
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  likely to be a significant adverse impact.  A determination of
  conformance may be made by comparing existing land use maps with
  the future land use plan and superimposing the land use changes
  associated with the alternative. In some cases, it will be necessary to
  evaluate more detailed categories of land use than the generic
  residential, commercial, industrial, agricultural, public use, and open
  space categories. For example, residential use is often categorized by 5
  to 10 density categories (dwelling units per acre), occupancy types
  (single-family or multi-family), and structural types (e.g., attached,
  detached, townhouse, apartment). Similarly, industrial land uses
  include a range of activities, from warehouses to light and heavy
  manufacturing facilities.  Commercial land uses are sometimes very
  difficult to evaluate for plan conformance because of the market
  justification of "pockets" of convenience retail activity.

  To the extent that the conformance criterion does not yield meaningful
  results, individual assessments of land use compatibility may be
  appropriate.  In these instances, it is important to incorporate as many
  of the local community's values into the assessment of compatibility as
  possible, except where there are overriding applicable public health
  considerations.  In many communities, "mixed" land use is an important
  positive aspect of urban living.  It is important to note that
  compatibility does not imply homogeneity.

      Critical Questions:

      •  Do primary and secondary long-term land use changes conform
        to the local land use plan?

      •  Does the environmental impact assessment address long-range,
        comprehensive land use impacts?  Are specific impacts
        addressed in the same timeframe as the local land use plan(s)
        (e.g., 10 to 20 years)?

     •  Do land use requirements for operation and maintenance
        activities (safe zone or buffer zones included) conflict with
        adjacent present or future land uses as planned by local,
        regional, and state agencies?

     •  Will induced growth around the facility change land use in
        ways that are counter to currently planned land uses for the
        area?

     •  Does the environmental impact assessment describe anticipated
        changes in nearby land use as a result of the facility?  Does  it
        evaluate potential conflicts that could occur during operations?

     •  Are land use controls adequate to prevent conversion of lands
        designated for protection by the government, such as prime
        agricultural, wildlife management or cultural heritage sites?

     •  Are local land use concerns and values used to develop land use
        compatibility criteria?
                            A determination of
                            conformance may be made by
                            comparing existing land use
                            maps with the future land use
                            plan and superimposing the
                            land use changes associated
                            with the alternative
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4.5.5.2 Economic Activity

The types of projects evaluated in environmental impact assessments
vary in terms of the potential socioeconomic impacts associated with
their implementation. The development of new facilities could generate
extensive changes in community structure stemming from changes in
population and employment patterns.  The construction of major
facilities requires a large, trained workforce that may not be available
locally and, therefore, would drive population in-migration.  Although
this potential influx of workers and their families may not be significant
in large and diverse communities, the entire economy of small
communities may be affected, including employment patterns,
population, and community resources.  If the proposed project also
requires a large operations workforce, the temporary changes
associated with the construction phase may become permanent.

Smaller projects, which may not be associated with large expenditures
or significant employment demands, would generate socioeconomic
impacts of a relatively smaller magnitude.  Therefore, the
environmental impact assessment would not analyze the impacts in as
much detail as for larger, more complex projects.  However, it is still
necessary for the analysis to quantify the primary impacts associated
with the proposed project and to assess the ability of the region of
concern to accommodate such a change.  It is important to note that
some projects (such as the closing of a large facility) may involve an
employment decline and subsequent potential out-migration and reduced
demand for housing and public services.  This discussion, however,
focuses on projects associated with increases, rather than decreases, in
economic activity.

The project proponent typically provides a description of the primary
economic impacts, including anticipated project expenditures,
employment, and payrolls. This project-related data should identify
employment and expenditure requirements during the construction and
operations phases of the proposed project.  Direct earnings (or payrolls)
can be estimated based on average wage and salary data.

The numerical relationship between the primary impacts in a region and
the total  impacts generated in the region is defined as a "multiplier."
For example, an employment multiplier of 2.5 in a given industry
indicates that for every job in that industry, an additional 1.5 jobs are
generated within the region.  Because different industries and
individuals purchase different mixes of goods and services and not all
of these goods and services may be available within a given region,
each industry generates a different amount of secondary (i.e;, primary
plus induced) impacts and, thus, will have a different multiplier.

For example, the construction and operation of a lumber mill may be
associated with a higher multiplier than the construction and operation
of a retail store. Construction of the mill may require greater
expenditures and more labor than the store. In addition, the lumber  mill
Socioeconomic impacts

•  Employment patterns
•  Population
•  Community resources
• Economic multipliers vary
   depending on project
   characteristics
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 may purchase more of its supplies locally than the retail store.  This
 would result in a higher secondary impact for the forest products
 activity.  In addition, the lower wages in the retail industry compared to
 the forest products industry could result in a lower induced impacts
 from the retail activity. In general, higher multipliers are associated
 with industries with the following attributes: greater revenues
 generated by sales to buyers outside the region, higher relative wage
 rates, and larger amounts of purchases made locally.

 The multipliers used in the analysis may be obtained from a variety of
 sources, including government agencies, financial institutions,
 universities, and other academic entities. The environmental impact
 assessment should disclose the source of the multipliers, justify the
 selection, and list the specific multipliers included.

 The selected multipliers are then applied to the primary impacts to
 provide estimated total employment and earnings impacts associated
 with the proposed project.  The number of potential in-migrant or out-
 migrant workers is often estimated according to a set of migration rate
 assumptions. These assumed rates of migration may be based on
 historical migration trends in the region or migration trends experienced
 in other regions where similar projects were implemented. In general,
 the higher the skill level and wage rate of the new positions and the
 smaller the existing available labor pool, the greater the likelihood of
 migration.

     Critical Questions:

     • Does the environmental impact assessment address changes in
        employment patterns associated with each phase of the
        proposed project?

     • Does the environmental impact assessment address the ability
        of the available labor pool to meet project-related employment
        needs?

     • Does the environmental impact assessment clearly identify the
        economic multipliers used in the analysis and their source?

     • Does the environmental impact assessment discuss the potential
        change in overall economic activity in the region?

4.5.5.3 Population and Housing

Changes in population following the construction and operation of a
new project are an important determinant of other potential
socioeconomic and environmental impacts. These population changes
have three key components:  (1) primary population impacts (relocation
of project workers and their families), (2) secondary population impacts
(relocation of workers and their dependents associated with project-
related expenditures in the region), and (3) natural increases (births
minus deaths) and non-project related migration.
                       Components of population
                       change

                       1) Primary population impacts
                       2) Secondary population impacts
                       3) Natural increases and non-
                          project-related migration
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The potential relocation of direct and indirect employees in response to
project construction and operation and the related increase in regional
economic activity are usually determined based on a set of assumed
migration rates, as discussed in the previous section. The number of
dependents expected to relocate with these workers may'be estimated
using average household size statistics gathered during preparation of
the description of the environmental setting section.

Population changes associated with the proposed project would result in
changes in housing demand. Housing demand impacts may be
estimated based on the number of estimated migrating workers,
assuming one housing unit for each migrating household. Expected
housing availability and the extent of potential impacts should be based
on recent housing market conditions, vacancy trends, and residential
construction activity.

As was mentioned earlier, indigenous populations are particularly
vulnerable to environmental and socioeconomic change. When
indigenous populations are identified in the region of concern, the
environmental impact assessment should assess impacts to the natural
resource base on which the population depends for its livelihood and to
the cultural fabric of the community.  Special development plans are
recommended to avoid or mitigate adverse impacts to indigenous
populations.

     Critical Questions:

     •  Does the environmental impact assessment address the
        relationship between employment increases and population in-
        migration?

     •  Does the environmental impact assessment identify deficiencies
        in available housing for the potential increased workforce and
        their families?

     •  Does the environmental impact assessment assess potential
        impacts to indigenous populations?

4.5.5.4 Community Services and Public Finance

The environmental impact assessment should assess the potential
impact of the construction and operation phases of the proposed project
on the capacity of the various utilities, transportation systems, and
other infrastructure and community services.  Potential impacts to local
community services are determined based on the change in the number
and composition of the population associated with the proposed project
and should be determined for the jurisdictions expected to have the
closest linkages to the proposed project and project-related personnel.
Housing demand

•  Estimate number of workers
   migrating to project area
•  Estimate available housing
•  Identify shortfall in housing (if
   any)
 • The environmental impact
   assessment should assess the
   potential of the proposed
   project to impact the capacity
   of the various utilities,
   transportation systems, and
   other infrastructure and
   community services
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 It is important that the impacts of the construction and operation phases
 are assessed separately because they can be very different. For
 example, the number of people required to operate the new facility may
 be much less than the number required for construction.  The in-
 migration of workers during the construction phase may be temporary,
 with temporary living quarters and support services provided by the
 builder (which would result in relatively few community impacts) or
 within the local communities (which could result in significant impacts
 depending on the size of the temporary workforce and current available
 capacity in the community).  After construction is completed, workers
 could leave the area and the additional housing and services developed
 to accommodate them would not be needed.

 Population changes associated with the operation phase, on the other
 hand,  are generally expected to be long-term or permanent. The
 changes in demand for housing and community services associated with
 these population changes tend to be given greater significance because
 they may permanently alter the structure of local communities and their
 resources. An environmental impact assessment typically will address
 the following impacts to community services:

     • Projected changes in public school enrollments and the effect
        on student-to-teacher ratios and school capacity

     • Expected changes in the demand for health care services

     • Estimated changes in demand for utilities and effects on current
        capacity.

 The potential effects on other public services can also be determined
 based  on the current levels of service and the expected change in the
 size of the population served.

 Local jurisdiction finances may be evaluated based on changes in
 historic revenues and expenditure levels, changes in fund balances, and
 reserve bonding capacities. Project-induced impacts on regional public
 finances should be analyzed, taking into account the expected increase
 in regional employment, the expected increase in population in each
jurisdiction (including school districts), the expected increase in
 business revenues and employee earnings, and potential changes in the
jurisdiction's property tax base.

     Critical Questions:

     •  Does the environmental impact assessment assess deficiencies
        in community services and infrastructure during project
        construction and operations?

     •  If additional support services are envisioned during the
        construction phase, what will happen to support services during
        the operation phase?
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     • Will there be a change in community structure during any
       phase of the proposed project? For example, would community
       life-style or stability be affected?

     • Does the environmental impact assessment assess any shortfalls
       in transportation capacity due to either primary or secondary
       impacts of the proposed project?

4.5.5.5 Transportation

Transportation impacts are generally characterized by (1) the extent to
which required transportation improvements are consistent with
applicable local transportation plans and (2) the level of service (LOS)
resulting from the assignment of project-induced travel demand to
various elements of the existing transportation system.

Consistency with local and regional transportation plans is very
important, because transportation systems are very capital intensive and
current funding is often applied to projects intended to meet travel
demand requirements 10 to 20 years in the future. As a result of long-
range transportation planning and capital investment, regional
transportation systems exert strong influence on private sector
locational and production decisions.  Proposed projects that do not
conform to such transportation plans or that require short-term "ad
hoc" changes to the planned system should generally be described as
having significant adverse impacts.

Even where conformance with the local and regional transportation
plan(s) exists, it is important to scrutinize the elements of the
transportation system that are likely to carry the bulk of the primary
and secondary transportation demand resulting from the proposed
project. Determinations of the level of service with and without the
proposed project and alternatives should be made for all affected public
thoroughfares and public transportation systems.

The LOS evaluation criterion provides for ratings ranging from "A"
(unrestricted free-flow) through "F"  (capacity exceeded, large queues,
and long delays).  In the United States, the threshold criterion for
acceptable performance is usually LOS D or E, and new capital
improvements are expected to attain LOS  C or better. For the larger
air, shipping, and rail facilities, there are often industry and port-
specific delay factors that translate into LOS equivalencies.

In addition to capacity issues, some projects may generate heavy
vehicle traffic (particularly during construction) that exceeds the weight
limits for affected roadways and bridges.  Such occurrences should
generally be mitigated fully because of public  safety implications.
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      Critical Questions:

      • Does the environmental impact assessment assess the extent to
        which the proposed project and alternatives are consistent with
        local and/or regional transportation plans?

      • Does the assessment assess changes in LOS resulting from the
        proposed project and alternatives?

      • Does the assessment assess the effect of heavy vehicle traffic
        on affected pavement and bridges?  Are significant adverse
        impacts to structural integrity and public safety fully
        mitigated?

 4.5.5.6 Health and Safety

 Impacts to health and safety vary among projects. For example, large
 and complex operations of new industrial facilities can pose threats to
 the health and safety of workers, the public, and the ecosystem in
 general. Health and safety issues tend to be more significant during
 operations, because they occur over an extended period. The three
 major health and safety concerns are industrial accidents, exposure to  .
 contaminants, and noise.

 Depending on the nature of the proposed project, hazardous or
 potentially dangerous materials may be used, produced, and/or stored
 onsite. Workers and the environment may be exposed to these materials
 through direct contact, exposure to fugitive dust and other air
 emissions, or spills. The potential for accidents at many facilities can
 be fairly high, if large quantities of raw material are used (and
 transported) around the facility and large volumes of waste are
 generated and must be handled during disposal. Noise is another
 challenging problem at some types of facilities.

 A health risk assessment may be appropriate to estimate the potential
 impacts of increased exposure to pollutants. A health risk assessment
 combines information on human exposure through air, water, and food
 with information on the toxicity of expected pollutants. The health risk
 assessment estimates increases in cancer rates and non-cancer health
 effects for the overall population in the area. It may be appropriate to
 calculate different health risks for different segments of the population,
 if there is  reason to believe exposure rates may be different. For
 example, subsistence fishing communities are at greater risk from
 consumption of contaminated fish than the general population.

     Critical Questions:

     •  Does the environmental impact assessment assess whether
        construction, operation, and maintenance activities present
        health and safety hazards to humans working or living at or
        near the proposed project site?
                        Major health and safety
                        concerns

                        1)  Industrial accidents
                        2)  Exposure to contaminants
                        3)  Noise
                          Health risk assessments should
                          assess human exposure
                          through:

                          -  Air
                          -  Food
                          -  Water
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     •  Does the environmental impact assessment assess the potential
        effects of facility noise levels on workers, local communities,
        and local fauna (e.g., are high frequency sounds emitted during
        facility operations that may disturb species sensitive to high
        frequencies, such as birds)?

     •  Does the environmental impact assessment assess the potential
        for long-term contaminant bioaccumulation within the food
        chain?

4.5.5.7 Environmental Equity

The socioeconomic analysis should address the nature of the
distribution of both beneficial and adverse impacts across different
segments of the population.  The analysis should identify specific
disadvantaged groups that may endure greater impacts than others (e.g.,
indigenous populations, migratory workers, minority groups, or specific
population segments based on age, sex, or poverty status).

     Critical Questions:                            ,

     •  Does the environmental impact assessment assess the equity of
        changes in employment patterns attributable to site preparation
        and construction activities?

     •  Does the environmental impact assessment assess the equity of
        community structural changes caused by project construction
        and operations?

4.5.6 Cultural Resources

Clearing and grading activities associated with project construction
may affect cultural resources with archeological, historical, religious,
societal, or aesthetic value. Site clearing activities may inadvertently
collapse or undermine the structural integrity of archeological sites or
uncover artifacts and historical sites. Even if these sites ,are preserved,
their historical or archeological significance can be damaged by
proximity to industrial or commercial activity.  The magnitude of
potential impacts varies according to the type of project, local climate,
settlement patterns, and capacity of the local government to enforce
protection of resources.                              ,   .  .

The environmental impact assessment should describe the potential
impacts on existing and undiscovered cultural resources.  The
description should include primary impacts (e.g., loss of subsurface
artifacts due to paving) and secondary impacts (e.g., generation of
smog due to increased commercial and residential traffic) associated
with project construction and operation.  It should also predict potential
cumulative impacts (e.g., the additive effects of increased business,
residence, and tourism on sensitive exposed structures over 10 or more
years).  If a resource cannot be avoided and remains at or near facility
Commonly disadvantaged
groups

•  Indigenous populations
•  Migratory workers
•  Minority groups
•  Specific population segments
   based on age, sex, or poverty
   status
Types of cultural resource sites
   Archeological
   Historical
   Religious
   Societal
   Aesthetic
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 Chapter 4 - Evaluation of Each Element
 operations, the environmental impact assessment should describe
 approaches for resource protection and mitigation.

     Critical Questions:

     • Does the environmental impact assessment assess any historical
        or cultural resources in close proximity to the proposed site
        following correspondence with appropriate authorities?

     • Is there a potential for historical or cultural resources on the
        proposed site to be disturbed, destroyed, or covered over by
        proposed site preparation and construction activities?

     • Does the environmental impact assessment discuss any
        mitigation measures necessary to preserve items of
        archeological, historical, or cultural interest (e.g., restoration of
        structural elements, rerouting of traffic, erosion control)?

     • Does the environmental impact assessment assess historical and
        cultural resources that could be reduced in value by the
        presence of the facility, even if impacts were mitigated?

     • Does the environmental impact assessment assess the extent to
        which construction operation and maintenance activities disrupt
        the aesthetic or sensory attributes of the proposed site?

     • Does the environmental impact assessment assess whether the
        facility components are designed with consideration given to
        human factors (e.g., religious, cultural, aesthetic values)?

     • Have all potential mitigative measures been assessed (e.g.,
        restoration of structural elements, rerouting of traffic, erosion
        control)?

4.5.7  Assessment of Potential Environmental Impacts of
       Alternatives and their Significance Road Map

The assessment of impacts is conducted several times during the
environmental impact assessment process.  It is performed during the
decision to proceed process to determine if the magnitude and nature of
potential impacts require that a full environmental impact assessment
be conducted, and again in developing the environmental impact
assessment document (both in draft and final) in response to comments.
It also is a part of reviewer communications and follow up monitoring
activities. How does a reviewer determine whether a project proponent
has accurately assessed the completeness, adequacy and significance of
an environmental or other impact? One way is to answer the following
questions, which form the road map for impact review:
                         The assessment of impacts is
                         prepared several times during
                         the environmental impact
                         assessment process
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                                                          Chapter 4 — Evaluation of Each Element
           Road Map for Environmental Impact Review

 •  All natural and human (socioeconomic) environmental impacts
    are identified

 •  Types of impacts include primary, secondary, and cumulative

 •  Detail on impacts is balanced among reasonable and feasible
    alternatives

 •  Both beneficial and adverse impacts are identified

 •  Potential impacts are identified for all phases of the proposed
    project

 •  Models, experts, and criteria accurately used to project the
    significance of impacts are valid for appropriate circumstances

 •  Data, information and key assumptions are representative,
    accurate, and current

 •  Appropriate criteria are used to characterize significance
In addition to this generalized list, the reviewer should carefully
examine all of the questions posed under the "Critical Questions" lists
in this section, which contain more detailed questions about each
component of environmental impact review.

Review of impacts can be divided into three headings:

1.   Completeness and Scope;
2.   Adequacy of the Assessment of the Magnitude of the Impacts; and
3.   Assessment of the Significance of the Impacts.

Completeness and scope: Review of the completeness of impacts that
are addressed and the scope of those that are considered worthy of
further analysis include:

     •   Using checklists and guidance documents for the particular
        type of proposed project;
     •   Comparing other environmental impact assessments on related
        projects;
     •   Assessing coverage in the environmental impact assessment of
        each phase of the proposed project including project design, site
        preparation, construction, installation, operation and closure
        and shutdown;
     •   Assessing coverage in the environmental impact assessment of
        all types of impacts: primary, secondary and cumulative;
     •   Viewing the proposed project from varied perspectives;
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 Chapter 4 - Evaluation of Each Element
     •  Reviewing maps and overviews of the area affected to
        determine if sensitive environments, resources, etc., have been
        overlooked;
     •  Using people networks and resource materials.
     •  Reviewing comments raised during scoping and whether they
        were addressed.

     Adequacy of the assessment of the magnitude of the impacts:  A
     reviewer must also examine the adequacy of the analysis. There
     are basically three types of approaches used:

     •  Extrapolation from current or past trends and conditions;
     •  Expert opinion;
     •  Predictive models.

        Reviewing extrapolations from past trends and conditions:
        Environmental impact assessments often base their assessments
        of potential future impacts on a continuation of past trends and
        conditions. In reviewing extrapolation, a reviewer should look
        for:
        -   Documentation of a rationale which justifies the validity of
            assumptions that existing or past conditions will continue
            into the future;
        -   Internal logic running throughout the environmental
            impact assessment and whether these assumptions are
            internally consistent;
        -   Whether expected changes in key assumptions are known
            to the reviewer or are obvious from the related impacts of
            the proposed project.

        Reviewing use of expert opinion:  Environmental impact
        assessments often rely upon the opinions and analyses of
        experts in the field. A reviewer will have his or her own
        experiences as  a professional and a reviewer, and must review
        critically the use of expert opinion regardless of the reviewer's
        expertise. The reviewer must carefully evaluate the
        environmental impact assessment document, as well as
        understand issues and concerns raised by other reviewers; this
        is the case even if the document or comments on the document
        are from an individual with more expertise in a particular area
        than the reviewer. This is critical, because mistakes can be
        made and people can be biased toward a particular outcome
        How is this accomplished in a professional and objective
        manner?

        To help identify whether an expert has applied their expertise
        appropriately or improperly, a reviewer can:
        —   Have equivalent technical expertise;
        —   Bring in an outside expert (e.g., a geologist) or have
            access to in-house expertise/consultants;
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                                                      Chapter 4 - Evaluation of Each Element
   -    Understand what expertise is and what it is not in this
        particular circumstance;
   -    Examine the use of internal quality control programs in
        the source agency or organization;
   -    Understand typical areas of concern, such as boundary
        conditions, appropriate use of models, etc.;
   -    Have and use a reference library.

   Reviewing the use of predictive models:
   -    Carefully examine the logic and internal consistency of
        basic assumptions, including the application of models and
        techniques that were used in the specific situation, and
        explore the logic and consistent use of assumptions used
        in evaluating project alternatives;
   -    Look for documentation that justifies the choice of one
        model over another;
   -    Look for boundary conditions which establish the
        credibility of the model for specific uses and whether those
        conditions are present in the current application;
   -    Look for key assumptions and whether they are internally
        consistent throughout the analysis or whether they are
        changed in any significant manner in order to use the
        model.

   Other bases for analysis:
   -    Did the impact assessment overlook an obvious source of
        information?
   -    Did the impact assessment assess impacts inconsistently,
        using some parameters or impacts for some alternatives
        and not for others?
   -    Did the impact assessment include both beneficial and
        adverse impacts?
   -    Did the impact assessment include quantification wherever
        possible?

Assessment of the significance of impacts: Review of the issue of
significance of impacts may include:

• Justification of findings of insignificant impact: whether they
   make sense;
• Comparison to regulatory limits;
• Level of controversy;
• Relative change in existing conditions;
• Cumulative impact analysis. This type of analysis is used to
   determine whether the cumulative impacts of the proposed
   project, when combined with existing environmental stressors
   unrelated to the proposed project, will together create
   significant impacts. For example, reviewers must consider the
   issue of biological carrying capacity in the affected geographic
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 Chapter 4 - Evaluation of Each Element
        area, and whether carrying capacity will be affected by primary
        or cumulative environmental impacts.

     There are several ways a reviewer can address the significance of
     potential environmental impacts when he or she feels it was not
     adequately addressed in an environmental impact assessment. The
     reviewer can:

     •  Evaluate the methodologies and rationales that were used for
        predicting impacts. Do they make logical sense? How do they
        compare to standard methodologies in common use in the
        scientific community?
     •  Compare the environmental impact assessment to other
        environmental impact assessments that were prepared for
        similar projects. Were potential impacts assessed in the same
        ways? Why or why not?
     •  Consult with technical experts either within or outside of the
        reviewer's agency who have expertise with the particular issue
        area in question.

See Appendix C.2 for further discussion on determining significance of
environmental impacts.

4.6  MITIGATION AND MONITORING MEASURES

Even with the best project siting and design, each of the alternatives to
a proposed project will have potential environmental impacts.  For all
adverse potential impacts, especially the significant impacts, the project
proponent must suggest mitigation measures.  Mitigation is
accomplished by refining the proposed project and alternatives during
siting, feasibility, and design processes.  The goal is to implement
projects with as few significant adverse impacts as possible.

In addition to proposing specific mitigation measures, some mechanism
for ensuring that mitigation measures are effective must be put into
place.  This can be achieved through appropriate monitoring measures
for each mitigation type.

4.6.1   Hierarchy of Mitigation Measures

Avoiding an impact altogether by not taking a certain action or parts of
an action should be the highest priority in an environmental  impact
assessment.  There are also other types of mitigation measures.
Mitigation measures are prioritized with "avoiding or preventing"
impacts as the most desirable mitigation measure and "compensating"
for a loss as the least desirable (but preferable to loss without
compensation).  In descending order of desirability, the primary
mitigation types can be classified as follows:
                       •  Avoiding an impact by not
                          taking a certain action or parts
                          of an action should be the first
                          consideration
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                                                           Chapter 4 - Evaluation of Each Element
     • Avoid or prevent impacts altogether by not taking a certain
       action or parts of an action

     • Minimize impacts by limiting the degree or magnitude of the
       action and its implementation

     • Reduce or eliminate the impact over time by preservation and
       maintenance operations during the life of the proposed project

     • Correct the impact by repairing, rehabilitating, or restoring the
       existing environment

     • Compensate for the impact by replacing or providing substitute
       resources or environments.

This hierarchy reinforces the objective of trying to avoid or minimize
potential impacts during project siting and design. The goal is to
identify a project and alternatives that meet the purpose and need, yet
do so with as little adverse environmental impact as possible, to carry
into the impact assessment process.

4.6.2  Scope of Proposed Mitigation

The environmental impact assessment should describe mitigation
measures for all  significant environmental and social impacts identified.
The following list highlights selected general mitigation measures:

     • Air Resources

       -    Implement an automobile inspection program to reduce
             impacts of increased traffic

             Site the facility so that prevailing winds carry emissions
             away from sensitive resources or population centers

             Install (and operate and maintain training) fabric filter
             collectors or electrostatic precipitators to reduce
             particulate emissions.

     • Water Resources

       -    Install and operate treatment systems so that discharges do
             not exceed the waste assimilation capacity of the receiving
             stream or sewage treatment plant

       -    Modify industrial processes to avoid generation of water
             pollution

             Maintain vegetative buffer areas along river banks and
             shorelines to protect water quality.

     •  Geologic Resources

        -    Revegetate cleared areas to protect soils
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 Chapter 4 - Evaluation of Each Element
         -   Avoid clearing steep slopes or highly erosional soil

         -   Limit the use of heavy machinery where soil compaction is
             a concern

      •  Biological Resources

             Develop land use plans to avoid incompatible use of
             sensitive areas such as floodplain, coastlines, wetlands,
             and conservation areas

             Maintain normal flow regime of aquatic and wetland
             systems by restricting channelization, preserving natural
             meanders, and limiting water diversions

         -   Replant areas  with a variety of native species to avoid
             introduction of exotic species and dominance of nuisance
             species.

      •  Waste Management

         -   Develop a materials management spill response plan

         -   Provide training to employees

         -   Implement a financial accountability plan to cover costs of
             remediation in the event of an industrial accident

         -   Implement a recycling and waste program.

      •  Socioeconomic Resources

         -   Include local communities in the project planning

         —   Provide job training for displaced workers

         -   Establish reasonable pricing policies for community
             services

        -   Develop an emergency response plan for industrial
             accidents.

     •  Cultural Resources

        -   Include local communities in the planning process

        -    Develop a plan for responding to chance archaeological
             finds during land clearing

        -    Develop cultural resource sensitivity maps delineating
             areas of high, medium, and low likelihood of containing
             cultural resources.
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                                                           Chapter 4 - Evaluation of Each Element
Each mitigation measure should be described in enough detail so that its
environmental consequences can be assessed and any residual impacts
clearly identified.

In addition to specific mitigation measures, an environmental impact
assessment document should propose appropriate monitoring plans to
measure the effectiveness of the mitigation measures. For example, if a
proposed project could potentially harm water quality in a lake, and a
mitigation measure consisting of a waste water treatment plant is
proposed, the quality of the water discharging from the plant to the lake
should be periodically monitored to ensure the lake is not being
adversely impacted.

In some countries, the reviewer may require specific mitigation
measures as a condition of project approval. In other countries,
opportunities for mitigation of environmental impacts are an important
consideration in determining the preferred project alternative.  The
preferred alternative typically reflects choices among tradeoffs. The
tradeoffs can include different processes, pollution control technologies,
costs, or other features.  The environmental impact assessment should
describe the process that led to, and the rationale for, ths selection of
the preferred alternative. The analysis should be deemed complete if:

     •  All reasonable alternatives were identified and evaluated;

     •  All potential impacts are identified and assessed for all
        alternatives;

     •  All possible refinements and modifications for environmental
        protection are incorporated in the alternatives;

     •  Any residual impacts and consequences of mitigating those
        impacts have been assessed.

4.6.3   Review of Mitigation and Monitoring Measures Road Map

The role of the reviewer is to assess whether proposed mitigation and
monitoring measures are complete and adequate.  The World Bank
Mitigation Tables that are included in the Resource Manual that is
associated with the Principles of Environmental Impact Assessment
Review text developed by EPA are a tool to support the assessment of
mitigation measures. In conducting this assessment, the reviewer
should ask the following questions, which serve as the road map for
mitigation and monitoring review:
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  Chapter 4 - Evaluation of Each Element
                  Road Map for Mitigation Review

   •  Specific mitigation measures are proposed

   •  All significant adverse impacts are addressed by the mitigation
      plan

   •  Measures are proposed for:
      -   All types of impacts
      -   All phases of the proposed project
      -   All environment types

   •  Preferred mitigation measures at the top of the mitigation type
      hierarchy are considered

   •  Mitigation measures are described in sufficient detail relative to
      the significance of impact

   •  Mitigation measures are:
      -  Technically and financially feasible with adequate financial
        and non-financial resources to implement the measures
      -  Socially and culturally acceptable

   •   Implementation plans include schedules and interim milestones
      and timing is consistent with other factors presented in the
      assessment of impact

   •   Responsible parties are identified and committed to
      implementation
 A reviewer must address the issues set forth in this road map when
 conducting mitigation and monitoring review. An environmental impact
 assessment document lacking any of the above components in its
 mitigation and monitoring section may be inadequate, and the reviewer
 should communicate this fact to the project proponent along with
 suggestions on how to correct the inadequacies.

 It is important to remember that, aside from avoiding an action,
 mitigation is often not an absolute prevention of all environmental
 impact. There is usually some impact, with mitigation implemented in
 order to lessen that impact. A law of diminishing returns often applies
 to mitigation, especially pollution reduction. It is often said that it is
 costlier to prevent the last 5 percent of pollution than the first 95
 percent combined. Emissions from coal fired power plants are an
 example.  It is relatively inexpensive to filter out the larger particulate
 matter before it escapes out of the stacks.  However, ensuring that there
 are zero emissions of sulfur oxides, nitrogen oxides, carbon monoxide
 and other pollutants can be astronomically expensive, if not impossible.
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                                                         Chapter 4 - Evaluation of Each Element
An effective reviewer will develop enough expertise, or know where to
find it, to determine how much is enough to ask of a project proponent
in terms of mitigation. If the purpose and need for a proposed project
are valid, and assessed environmental impacts are acceptable, a
reviewer should not expect the project proponent to implement
mitigation measures of such cost and difficulty as to prevent the
proposed project from moving forward. As in most areas of
environmental impact assessment review, a sense of balance is key.

4.7  Tools and Techniques for Environmental Impact Assessment
     Review

In addition to road maps for review mentioned throughout chapters 3
and 4, there are a variety of "tools and techniques" a reviewer can use
to aid his or her review. The following list of tools and techniques is
applicable to all elements of a typical environmental impact assessment
document and review process. They are also located in Appendix D,
along with an indication of where these tools can be found in the course
text and resource documents provided.
             Tools and Techniques for Environmental
                    Impact Assessment Review

    Information on legal and institutional requirements, policies, and
    guidance material

    Guidelines

    Road Maps

    Checklists

    Student texts

    Library                                   .    i

    Field reconnaissance

    Analytic and predictive models

    GIS maps and overlays

    Environmental impact assessments for similar projects,
    geographic area, etc.

    Consultation by colleagues/outsiders/experts/academia

    Reviewing other reviewer/public comments
                                              4-73
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 Chapter 4 - Evaluation of Each Element
 Reviewers are encouraged to use appropriate tools and techniques for
 each element of the environmental impact assessment document.
 Further information on these tools and techniques can be found in
 appendices A through E to this text, as well as in the Resource Manual,
 interactive CD-ROM, and case study EIAs  that accompany the course
 Principles of Environmental Impact Assessment Review.

 Now you are prepared for the important job of reviewer. We
 appreciate your comments on what is most useful to you and further
 ideas for best meeting the needs of environmental professionals in the
 field.
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           APPENDIX A

     ENVIRONMENTAL IMPACT
ASSESSMENT EVALUATION CHECKLIST

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-------
                                                                  Evaluation Checklist
                                     Introduction


There are many tools that a reviewer of environmental impact assessment documents can use to
help determine whether such documents are complete and adequate. Among the powerful tools
that can be used are checklists. Checklists can be valuable in the following ways:

•   They can help ensure that all key issues and elements have been considered;

•   They can be used by the project proponent and reviewer alike throughout all stages of the
    environmental impact assessment process;

•   They help ensure that the review process is systematic; and

•   They help make the review process more standardized across projects.

A comprehensive environmental impact assessment review checklist is presented in this appendix.
This checklist covers all elements of typical environmental impact assessment documents,
including:

Purpose and Need;

Project Alternatives;

Description of the Environmental Setting (both natural and socioeconomic);

Assessment of Potential Environmental Impacts; and

Mitigation and Monitoring Measures.

There are numerous checklist items under each of these headings. Because the environmental
impact assessment process is focused on preventing and minimizing impacts to the natural and
human (socioeconomic) environment, the majority of checklist items are located under
Description of the Environmental Setting and Assessment of Potential Environmental Impacts.

The checklist included in this Appendix can be a powerful tool for environmental impact
assessment reviewers, as well as project proponents and preparers of environmental impact
assessment documents. In addition to the checklist in this appendix, there are other relevant
checklists available to aid the review process. A number of other checklists are  included in the
Resource Manual accompanying the Principles of Environmental Impact Assessment Review
course. A list of the contents of the Resource Manual appear in Appendix D.
                                          A-l
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                                                               Evaluation Checklist
                 Environmental Impact Assessment Evaluation Checklist
Issue and Text Reference
PURPOSE AND NEED
1 . Clear description of underlying need for the
proposed project (p. 4-4)
2. Clear description of purpose of proposed project
0>.4-4)
3. Adequate description of the proposed project
(p. 4-4)
PROJECT ALTERNATIVES
1 . Consideration of all relevant alternative types.
(p. 4-7)
a. No Action
b. Alternative sites
c. Alternative designs
d. Alternative controls
e. Structural alternatives
f. Non-structural Alternatives
2. All alternatives satisfy the stated purpose and
need for the project, (p. 4-8)
3. Description of all alternative actions or projects
that were, or are, being considered, (p. 4-8)
a. Size and location of facilities
b. Land requirements
c. Operations and management requirements
d. Auxiliary structures
e. Construction schedules
4. Description of initial environmental impact
assessment processes and results (p. 4-7)
DESCRIPTION OF THE ENVIRONMENTAL
SETTING
1 . Region of Concern denned, including boundary
areas (p. 4-10)
2. Physical-Chemical Environment (p. 4-1 2)
a. Air Resources (p. 4-1 2)
1 ) meteorological data (e.g., temperature,
wind)
2) ambient air quality (e.g., particulates,
ozone)
3) stationary sources of emissions (e.g.,
power plants)
N/A



























Adequately
Covered



























Not'
Adequately
CoVerfid



























<
Comments



























July 1998
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                        Evaluation Checklist
Issue and Text Reference
4) mobile sources of emissions (e.g., cars
and trucks)
b. Water Resources (p. 4-14)
Surface Water:
1) location and type (e.g.,estuaries,
streams, lakes, and their position
relative to the site)
2) water quality information (e.g.,
dissolved oxygen, temperature,
nutrients)
3) existing pollutant sources (location and
amount of discharges)
4) future uses
5) discussion of flooding events
Ground Water:
6) description of key factors (e.g. , depth to
water table, overlying soils, geologic
features)
7) water quality information (e.g., pH,
solids)
c. Soils and Geology (p. 4-16)
1) topography
2) soil structure
3 ) ground water movement
4) erosion potential
5) subsidence
6) seismic activity (e.g., proximity to
faults, history of earthquakes and
volcanic eruptions)
7) mineral resources (e.g., locations of
deposits, types and quantities,
ownership of mining rights)
2. Biological Conditions
a. Wildlife and Vegetation (p. 4-18)
1 ) description and listing of aquatic,
wetland, and terrestrial flora and fauna
(e.g., species lists, abundances)
2) description and listing of native species
of wildlife and vegetation present
3) description and listing of particularly
invasive exotic species of wildlife and
vegetation
N/A







!







•






Adequately
Covered






















Not
Adequately
Covered






















Comments






















A-3
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                                                                 Evaluation Checklist
Issue and Text Reference
4) description and listing of rare and
threatened species
b. Community and Habitat Characterization
(p. 4-22)
1) maps and descriptions of the aquatic,
wetland, and terrestrial communities
found in and around the project site
c. Ecologically Significant Features (p. 4-24)
1 ) support of broader ecosystems by the
project site (e.g., if located along a
flyway or other biological corridor)
2) important ecological functions of the
project site (e.g., nutrient source
through flooding, storm water retention)
3) characterization of relevant disturbance
regimes, natural and project-induced
(e.g., floods, fire, potential impact of
logging)
4) description of hydrologic processes
(e.g., ground and surface water flows
and durations)
5) description of important biotic
interactions (e.g., interdependence of
plants and animals at the site and with
other sites)
4. Waste Management and Pollution Prevention
(p. 4-27)
a. Locations of expected waste disposal or
discharge
b. Description of waste management
techniques (e.g., treatment, storage,
transport, recycling)
c. Projected waste characteristics (e.g., types,
quantities, toxicity)
5. Socioeconomic Environment (p. 4-28)
a. Land Use (p. 4-29)
1) description of present and historic land
use
2) map of present and historic land use
b. Population and Housing (p. 4-29)
1) demographic information (e.g., average
household size, average age, age/sex
distributions, ethnic composition, and
community cohesion)
c. Economic Activity (p. 4-30)
N/A




















Adequately
Coveted




















Nat
Adequately
Covered




















Comments




















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                       Evaluation Checklist
Issue and Text Reference
1 ) description of present economic activity
(e.g., number and type of businesses,
annual revenues, ownership patterns)
2) description of unique features of
business community (e.g., high
seasonality of trade, high outflow of
profit, declining of trade, or downtown
revitalization)
3) consideration of interplay among
economic activity, capacity of public
services, and fiscal ability of community
to respond to capacity needs
d. Community Services and Public Finance
(p. 4-31)
1 ) description of existing public facilities
and services within vicinity of project,
including existing level of use and
remaining capacity to accommodate
growth
e. Transportation (p. 4-32)
1 ) description of all relevant forms of
transportation for facility
2) current traffic volumes
3) current traffic capacity
4) provision of public transportation
5) assessment of the adequacy of the
systems for meeting peak demands
during construction and operation
f. Health and Safety (p. 4-32)
1) description of present health and safety
issues (e.g., statistics on industrial
accidents, emissions data from prior and
existing facilities, present levels of
noise)
2) identification of special populations or
areas more likely to be exposed to
adverse impacts
6. Cultural Resources (p. 4-33)
a. Archaeological sites in relation to the
project
b. Paleontological sites in relation to the
project
c. Historic sites in relation to the project
d. Educational, religious, scientific, or cultural
sites in relation to the project
WA '



















Adequately
Covered



















Not
Adequately
Covered



















Comments



















A-5
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                                                                 Evaluation Checklist
Issue and Test Reference
ASSESSMENT OF POTENTIAL
ENVIRONMENTAL IMPACTS
The Environmental Impact Assessment discusses
primary, secondary, and cumulative impacts during
all stages, including initial site preparation and
construction; facility operation, and post-facility or
site closure for the following (p. 4-36):
1 . Pollutant Generation, Transport, and Receptors
(p. 4-40)
a. Air Resources (p. 4-40)
1 ) identification of emission sources and
project emission rates and comparison
to national, state, and local standards
and limitations
2) comparison of predicted atmospheric
levels with national, state, or local
ambient levels
3) description of stack emissions during
operation and maintenance activities
and comparison with existing national,
state, and local standards
4) identification of best mitigation
measures to avoid or minimize adverse
impacts
b. Water Resources (p. 4-42)
1 ) address potential for water quality to be
degraded by various factors
2) prediction of pollutant concentrations in
water bodies and comparison with
existing national, state, and local water
quality standards and criteria
3) identification of best mitigation
measures to avoid or minimize adverse
impacts
c. Geological Resources (p. 4-45)
1 ) determination of potential soil loss and
mitigation activities
2) identification of potential contamination
sources and mitigation measures
d. Biological Resources (p. 4-46)
1) consideration of potential losses of
biological resources within site
boundaries
2) description of effluent and emission
concentrations and their potential
effects to vegetation and wildlife
N?A


















Adequately
Covered


















Not
Adequately
Covered


















Comments


















July 1998
A-6

-------
                        Evaluation Checklist
Issue and Text Reference
3) discussion of bioaccumulative effects
from facility emissions and discharges
4) identification of best mitigation
measures to avoid or minimize adverse
impacts
2. Habitat Alteration (p. 4-46)
a. Biological Resources (p. 4-47)
1) address potential for construction and
site preparation activities to alter critical
habitats for wildlife
2) consideration of potential for secondary
changes in habitats following
construction and site preparation
activities
3) assessment of possible permanent loss
or displacement of vegetation habitat
due to operation
4) identification of changes in local
species composition, diversity, and
abundances resulting from loss of
specific habitats
5) identification of best mitigation
measures to avoid or minimize adverse
impacts
3 . Waste Management and Pollution Prevention
(p. 4-52)
a. description of facility waste management
plan with procedures for treatment,
handling, and disposal
b. discussion of projected facility waste
characteristics
c. identification of best mitigation measures
to avoid or minimize adverse impacts
4. Socioeconomic Impacts (p. 4-53)
a. Land Use (p. 4-54)
1) identification of the existing or planned
land use areas lost due to site
preparation and construction activities
2) determination of conflicting zoning
requirements and land uses with site
preparation and construction activities
3) description of anticipated changes in
near by land use as a result of the
facility and evaluation of conflicts that
could arise during operations
WA


















Adequately
Covered


















Not
Adequately
Covered


















Comments


















A-7
July 1998

-------
                                                                 Evaluation Checklist
Issue and. Text Reference
4) identification of best mitigation
measures to avoid or minimize adverse
impacts
b. Economic Activity (p. 4-57)
1) address changes in employment patterns
2) address ability of available labor pool to
meet project-related employment needs
3) identification of economic multipliers
used in analysis and their source
4) discussion of potential change in overall
economic activity in region
5) identification of best mitigation
measures to avoid or minimize adverse
impacts
c. Population and Housing (p. 4-58)
1 ) address the relationship between
employment increases and population
in-migration
2) identification of deficiencies in
available housing for the potential
increased workforce and their families
3) identification of best mitigation
measures to avoid or minimize adverse
impacts
d. Community Services and Public Finance
(p. 4-59)
1) identification of deficiencies in
community services and infrastructure
during project construction and
operation
2) identification of shortfalls in
transportation capacity due to either
primary or secondary impacts of the
project
3) identification of best mitigation
measures to avoid or minimize adverse
impacts
e. Transportation (p. 4-61)
1 ) assessment of proposed project's
consistency with local and/or regional
transportation plans
2) evaluation of changes in LOS
resulting from the proposed project
and alternatives
3) evaluation of the effect of heavy vehicle
traffic on affected pavement and bridges
N?A



















Adequately
Covered



















Not
Adequately
Covered:



















Comments



















July 1998
A-8

-------
                       Evaluation Checklist
Issue andTextReference
4) description of mitigation measures to
offset adverse impacts to structural
integrity and public safety
f. Health and Safety (p. 4-62)
1) evaluation of whether construction,
operation, and maintenance activities
present health and safely hazards to
humans working or living at or near the
project site
2) discussion of potential effects of facility
noise levels on workers, local
communities, and local flora and fauna
3) analysis of potential long-term
contaminant bioaccumulation within the
food chain
4) identification of best mitigation
measures to avoid or minimize adverse
impacts
g. Environmental Equity (p. 4-63)
1) determination of the equity of changes
in employment patterns attributable to
site preparation and construction
activities
2) determination of the equity of
community structure changes caused by
project construction and operation
3) identification of best mitigation
measures to avoid or minimize adverse
impacts
5. Cultural Resources (p. 4-63)
a. identification of any historical or cultural
resources in close proximity to the site
following correspondence with appropriate
authorities
b. discussion of mitigation measures necessary
to preserve items of archaeological,
historical, or cultural interest
c. determination of the extent to which
construction, operation, and maintenance
activities disrupt the aesthetic or sensory
attributes of the site
d. determination of whether the facility
components are designed with
consideration given to human factors
MITIGATION MEASURES
1 . Mitigation Measures (p. 4-68)
SB* "


•














Adequately
Covered

















Not
Adequately
Covered

















Comments

















A-9
July 1998

-------
                                                                 Evaluation Checklist
Issue and Text Reference
a. description of mitigation activities for all
significant impacts to both the natural and
human (socioeconomic) environments
b. description of mitigation measures with
adequate information to evaluate
environmental consequences and residual
impacts
c. identification of best mitigation measures to
avoid or minimize potential impacts during
all stages of the project, including siting
and design, facility operation, and post
facility closure.
d. support of the following types of mitigation
measures, in the following decreasing order
of preference:
- Avoidance or prevention
- Minimization
- Reduction or elimination over time
- Correction
- Compensation.
e. implementation plan (schedule) and criteria
for performance for all mitigation measures.
f. responsible entity assigned to carrying out
each mitigation measure.
g. measures are socially and culturally
acceptable.
h. adequate financial and non-financial
resources to implement the measures.
WA








Adequately
Covered








y&*
Adequately
Coveted








Comments








July 1998
A-10

-------
                  APPENDIX B
ENVIRONMENTAL IMPACT ASSESSMENT METHODOLOGIES

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                                    B-9
                                                           May 1998

-------

-------
                       C.1
ENVIRONMENTAL IMPACT ASSESSMENT TERM DEFINITIONS

-------

-------
                                                        Identifying Significant Issues
                 KEY CONCEPTS IN ENVIRONMENTAL IMPACT
                                  ASSESSMENT
ALTERNATIVES TO THE PROPOSED ACTION:  Alternatives are different means of
meeting the general purpose and need of a proposed action, 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

CUMULATIVE IMPACT: Cumulative impacts result from the incremental impact of a
proposed action on a common resource when added to other past, present and reasonably
foreseeable future actions.  These may include the collective affects of individually minor
actions over a period of time.

ENVIRONMENT IMPACT ASSESSMENT: 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 to help to mitigate
the adverse environmental impacts of activities related to projects, plans, programs or policies.
Involvement of the public and interested parties is important to obtaining complete information
on impacts and ensuring sound results.

IMPACT: A change in the environment brought about by implementation of a proposed
project or  alternative.

INITIAL ENVIRONMENTAL IMPACT ASSESSMENT:  Initial Environmental Impact
Assessments consider the significance of environmental impacts  in sufficient detail to make
one of two determinations:
       1) no significant impact is expected; or
       2) significant impacts are expected.

MITIGATION: Mitigation is a set of actions designed to reduce the undesirable impacts of a
proposed action on the affected environment in one or more of five categories (in order  of
desirability):
        •  Avoidance
        •  Minimization
        •  Rectification
        •  Reduction
        •  Compensation
                                       C-l-1
May 1998

-------
                                                          Identifying Significant Issues
 PREFERRED ALTERNATIVE: The preferred alternative is that alternative that 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

 PRIMARY IMPACT: A primary impact is direct and occurs at the same time and place as the
 action. Primary impacts are associated with the construction, operation, and/or maintenance
 of a facility or activity.  They are generally visibly obvious and quantifiable.

 PUBLIC PARTICIPATION:    Public participation is the involvement of citizens and citizens
 groups in the Environmental Impact Assessment process for the purpose of balancing any
 decision between policy makers and those who are affected by the policy.

 PURPOSE AND NEED:   The purpose and need of a proposed project is the justification for
 undertaking the action and may originate from legislation, administrative decisions, or private
 enterprise. It must be defined before the Environmental Impact Assessment process can
 proceed.

 SCOPING: The early, open, and documented process of considering the issues and choices of
 alternatives to be examined in the Environmental Impact Assessment for a particular action,
 policy, or program.  Scoping  includes:
        • determining the range of issues to be addressed,
        • determining the significance of these issues,
        • eliminating issues that are not significant,
        • securing participation of all technical experts and interested parties
        • assigning responsibilities for Environmental Impact Assessment preparation and
              review,
        • identifying other related planning decisions.

 SCREENING: The initial screening considers all possible impacts to the action, project,  or
 program.  It identifies whether significant impacts are expected or not.

 SECONDARY IMPACT:  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 impact alters the properties of a natural or man-
made resource in a way considered important. The importance is based on a  relative change to
an area, and the human perspective on the change.
                                        C-l-2
July 1998

-------
              APPENDIX C.2




IDENTIFYING SIGNIFICANT ISSUES - EXAMPLES

-------

-------
                                                         Identifying Significant Issues
                IDENTIFYING SIGNIFICANT ISSUES - EXAMPLES

There are several points in the Environmental Impact Assessment process where it is necessary
to distinguish significance from insignificance, such as in the decision of whether to proceed
with environmental impact assessment and during scoping. It is also necessary to make this
distinction when comparing impacts and alternatives and in selecting a preferred alternative
and its mitigation measures.  These are often difficult decisions to make especially where there
are no concrete standards to apply.  The text has been derived from several sources (listed
below) to provide examples on how decisions of significance have been made by 5 different
organizations with regard to 7 components of an environmental setting:

       A.    Physical Resources
       B.    Water Resources
       C.    Biological Resources
       D.    Hazardous Materials and Solid Waste Management
       E.    Cultural Resources and Aesthetics
       F.    Socioeconomic Resources
       G.    Land Use and Infrastructure.

The sources used in developing this material were:

       ฎ     U.S. Air Force. 1994. Preliminary Draft Eglin AFB Environmental Baseline
             Study Impacts Appendices.  Prepared by the Earth Technology Corporation,
             Colton, CA.

       9     Fittipaldi, J.J. and E.W. Novak. 1980.  Guidelines for Review of EA/EIS
             Documents.  Construction Engineering Research Laboratory Technical Report
             No. 92, United States Army Corps of Engineers.

       ซ     USEPA.   1995.  Principles for Review of Environmental Impact
             Assessments, Final Draft.

       •     USEPA.   1993.  Guidance for Writing Permits for the Use or Disposal
             of Sewage Sludge.

       •     Whitlow,  J. 1984.  Dictionary of Physical Geography. Penguin Books
             Ltd., Middlesex, England.
NOTE:  The information included in this appendix should be used as an EXAMPLE of
approaches used elsewhere and is not intended to provide guidelines to be applied to a
given project.
                                        C-2-1
July 1998

-------
                                                                 Identifying Significant Issues
 A.     Physical Resources

 Physical resources that may be affected by master planning and training activities include
 geology, soils, air,  noise, and visual and aesthetic resources. This section provides a general
 description of these resources and suggests factors to consider in assessing the potential
 impacts of project activities associated with these resources.

 Geology.  The geologic features of an area can both impact and be affected by project
 activities.  Geologic features include surface and subsurface formations like mineral reserves
 and fault lines.  Additional examples include unique surface formations with aesthetic value or
 fossils with paleontological1 value. A project can be affected by changes in geologic features
 such as seismic activity along fault lines or structural failure due to slope instability.  In
 addition, a project can have an impact on geologic resources by destroying features of
 aesthetic or scientific value or  by precluding access to mineral resources of economic value.
 Rank
 Significant Adverse
Contributing Factors

The activity results in irretrievable loss of important
mineral or paleontological resources.

The activity will destroy geological features of scientific,
educational and aesthetic interest.

The activity will change local drainage patterns.

The activity will locate  structures within a seismic impact
zone and the structures  are not designed to withstand
maximum recorded horizontal acceleration.2

The activity is subject to or is likely to contribute to
subsidence and subsidence is likely to cause loss of life or
property.

The activity will locate  structures in areas subject to slope
instability and slope failure3 is likely to result in loss of
          Paleontology is the science that uses fossil remains to study the life of past geological periods.
       n
          A seismic impact zone is an area in which the horizontal ground level acceleration of the rock within the
area has a 10% or greater probability of exceeding 0.10 gravity once every 250 years (40 CFR 503). The horizontal
acceleration is expressed as a percentage of the acceleration due to gravity (g), where g=9.8 m/sec2. Contact the USGS
for maps of faults and seismic impact zones.
         Slope failure is likely to occur when the applied stresses (e.g., structures) are greater than the strength of
                                            C-2-2
                                                      July 1998

-------
                                                               Identifying Significant Issues
                             life or property or have an adverse impact on water or
                             biological resources.

Adverse           ,   • ,     The activity is located within a seismic impact zone, but   ;     .>
                             structures are designed to withstand the maximum
                             recorded horizontal acceleration.

                      •      The activity is located in areas subject to slope instability,
                             but the proposed project has been designed to  minimize
                             the likelihood and/or impacts of slope failure.

                      •      The activity will reduce the extent of geological features
                             of scientific, educational,  and aesthetic interest.

                      •      The activity will create localized and temporary
                             construction related impacts.

No Impact            •      The activity does not include construction of structures in
                             seismic impact zones, on or near unstable slopes, in areas
                             subject to subsidence.

                      •      The activity will not occur in areas with surface
                             formations, mineral  resources, or paleontologic resources.

                      •      The activity does not involve extraction of subsurface
                             resources.

Soils. Soils are the thin layer of unconsolidated material  on the land surface.  Their properties
result from the interaction of underlying geology, topography, local climate,  microbial action,
and vegetation.  Soils can be altered by natural processes of weathering, water movement, and
biological activity; and by human activities such as tilling, grazing, construction, compaction,
and removal of vegetation.  Key soil properties to consider in an environmental assessment
include permeability4,  leachability5,  thickness, fertility, and erodibility.  Construction and
other activities on unsuitable soils can cause a variety of problems from ground water
contamination, erosion, sedimentation, landslides, and  irretrievable loss of prime farmland.
the underlying bedrock and regolith. Regolith is comprised of the layers of material overlying undecomposed bedrock.


       4 Permeability is the rate at which liquids (or gases) pass through rocks or soil. The permeability of a material
depends on its grain size, particle size, shape, and overall particle distribution.


       5 Leachability refers to the properties of the soil that influence dissolution and adsorption of chemicals.
                                            C-2-3
July 1998

-------
                                                               Identifying Significant Issues
 Rank
 Significant Adverse
Adverse
No Impact
 Contributing Factors

 The activity will locate structures in areas subject to slope
 instability and slope failure is likely to result in loss of life
 or property or have an adverse impact on water or
 biological resources.

 The activity results in erosion which would likely cause
 loss of sensitive species,  loss of sensitive habitat, loss of
 cultural resources, loss of infrastructure or facilities, or
 loss of human life.

 The activity results in sediment loading to stream courses
 which will result in exceedances of state or federal
 standards.

 The activity is likely to cause contamination of soil with
 toxic or hazardous chemicals.

 Chemical contamination of soil resources is likely to cause
 contamination of ground water or surface water
 resources.

 The activity results in irretrievable loss of prime
 farmland.

 The activity results in erosion which increases sediment
 loading to stream courses, but is not likely to result in
 exceedances of state or federal water quality standards or
 alteration of aquatic habitat.

 The activity is likely to cause short term erosion, but will
 not cause the loss of sensitive species, sensitive habitat,
 cultural resources,  infrastructure or human life.

 The activity is located in areas subject to slope instability,
 but the proposed project has been designed to minimize
 the likelihood and/or impacts  of slope failure.

 The activity results in no erosion or in short-term,
 localized erosion that does not result in increased loadings
to stream courses.

The activity does not have the potential to release
chemicals onto soils.
                                           C-2-4
                                                     July 1998

-------
                                                           Identifying Significant Issues
Air. Air resources may be affected by releases  of gases and particulates from stationary and
mobile sources.  Air quality is also influenced by meteorological conditions such as prevailing
wind, sunlight, and temperature inversions. A proposed project activity can act as a source
and/or a receptor of air pollutants.
Rank
Significant Adverse
 Adverse
Contributing Factors

The activity will introduce pollutants to the air that will
cause ambient air quality to exceed levels established by
the National Ambient Air Quality Standards (NAAQS) for
CO, SOx, NOx, lead, ozone, particulates

The activity will release air pollutants in levels that
exceed the National Emission Standards for Hazardous
Air Pollutants (NESHAP) for example beryllium,
mercury, arsenic, asbestos, benzene, radionuclides, and
vinyl chloride.

The activity will introduce NAAQS pollutants to an area
designated as a non-attainment area.

The activity will introduce pollutants to the air which in
combination with other sources will contribute to
exceedance of NAAQS.

The activity will introduce pollutants into indoor air that
exceeds OSHA exposure limits.

The activity is subject to New Source Performance
Standards (NSPS) and is not expected to comply with
NSPS upon commencement of operation.

Deposition of atmospheric pollutants (either directly to
surface water or to land) is likely to contribute to ambient
water quality problems (e.g., nutrient enrichment,
acidification, toxic accumulation).

The activity will introduce pollutants into indoor air,  but
will not exceed OSHA exposure  limits.

The activity will introduce NAAQS or NESHAP
pollutants, but will -not exceed limits either alone or in
conjunction with other sources.

The activity will result in temporary increase in ambient
concentrations of pollutants, but  will not violate NAAQS.
                                          C-2-5
                                                   July 1998

-------
                                                             Identifying Significant Issues
 No Impact
 The activity does not release pollutants into the air.
 Noise. Transportation (aircraft, marine, and land-based traffic) and construction activities are
 major sources of environmental noise.  Besides damaging hearing of humans, noise also
 interferes with communication, interrupts sleep, causes stress, and generally impacts the
 quality of life.  Noise can also have an adverse impact on domestic animals and wildlife.
 When considering the proposed project, it is important to determine if the proposed project
 will create unacceptable noise levels. The review should evaluate both non impulsive (e.g.,
 persistent traffic) and impulsive noise (sonic boom, explosion).  Note that the quantitative
 contributing factors provided below are based on the research summarized and policies applied
 in the Preliminary Draft Eglin AFB Environmental Baseline Study Impacts Appendices.
 Rank
 Significant Adverse
Adverse
 Contributing Factors

 The activity will expose populated areas to day-night
 noise levels (non-impulsive) of 75 decibels (dB) or
 greater.

 The activity will expose populated areas to c-weighted
 day-night noise level (CDNL) (i.e., impulsive sonic
 boom) 70 dB and greater.

 The activity (e.g., artillery, munitions, blasting) will
 expose populated areas to a single peak sound pressure
 level (dBP) greater or equal to 139 dBP.

 The activity will cause speech interference because indoor
 sound levels are expected to exceed 82 dB.

 The activity results in substantial likelihood of hearing
 loss because indoor sound levels (DNL) are above 84 dB.

 Noise levels associated with the activity are expected to
 cause domestic animals and wildlife injury, abandonment
 of habitat, or mortality.

 The activity will expose populated areas to day-night
 noise levels (non-impulsive) between 65 and 75 dB.

 The activity will expose populated areas to CDNL
 between 62 and 70 dB.

The activity (e.g., artillery, munitions, blasting) will
expose populated areas to a single peak sound pressure
level (dBP) greater between 115 and 138 dBP.
                                         C-2-6
                                                   July 1998

-------
                                                            Identifying Significant Issues
                     •     The activity will cause speech interference because indoor
                           sound levels are between 82 and 60 dB.

                     •     The activity creates a slight to moderate likelihood of
                           hearing loss when indoor sound levels (DNL) are between
                           75 and 80 dB.

                     •     The activity causes wildlife or domestic animals to display startle
                           effects, including fleeing the area, alteration in productivity,
                           reproduction, growth, or parenting behavior.

No Impact           •     The activity will expose populated areas to day-night
                           noise levels (non-impulsive) of 65 dB or less.

                     •     The activity will expose populated areas to CDNL 62 dB
                           or less.

                     •     The activity (e.g., artillery, munitions, blasting) will
                           expose populated areas to a single peak sound pressure
                           level (dBP) lower than or equal to 115 dBP.

                     •     The activity will cause speech interference resulting  from
                           indoor sound levels of 60 dB or less.

                     •     The activity is unlikely to cause hearing loss when indoor
                           sound levels are below 75 dB.

                     •     The activity is not likely to cause startle effects for
                           wildlife or domestic animals.
                                          C-2-7
July 1998

-------
                                                            Identifying Significant Issues
B.     Water Resources

 Watershed resources that may be affected include ground water, surface water and floodplains
(see Figure 6-3 of main text).  Evaluating water resources includes an assessment of impacts to
the physical, chemical and biological properties of the waterbody.  An assessment of an
activity's impact on water resources should consider primary, secondary, and cumulative
impacts. Following are examples of factors which contribute to an activity's classification as
significant adverse, adverse, or no impact to water resources.

Ground water. Ground water is water contained in a saturated zone at some depth below the
ground surface. When evaluating the proposed project activity, it is important to determine if
either the quantity or quality of ground water supplies will be affected.  Pollutants can be
introduced to ground water by seepage through soils and by injection through wells.  It is also
important to consider the interaction between surface water and ground water to identify the
potential for cross contamination.
Rank
Significant Adverse
 Contributing Factors

 The activity results in introduction of pollutants to potable
 ground water and is likely to cause ground water to
 exceed maximum contaminant level (MCL).

 The activity results in the introduction of pollutants to a
 ground water source that discharges to surface water and
 pollutants are likely to cause surface water to exceed
 ambient water quality standards (WQS).

 Introduction of pollutants to potable ground water will not
 exceed MCL, but will continue over life of project.

 Introduction of pollutants to potable or nonpotable ground
 water will contribute to exceedances of MCL and/or WQS
 in combination with other sources.

 Activity results in withdrawal of ground water, reduction
 of infiltration, or change in ground water flow direction
 such that it diminishes seepage or spring-water inflow into
 an ecologically significant habitat,  such as wetlands, or
 that results in modification of threatened or endangered
 species' habitat.

Withdrawal of ground water is likely to result in saltwater
intrusion to potable aquifer.
                                         C-2-8
                                                   July 1998

-------
                                                            Identifying Significant Issues
Adverse
No Impact
Introduction of pollutants to potable ground water is not
likely to cause ground water to exceed maximum
contaminant level (MCL).

Introduction of pollutants to ground water source that
discharges to surface water is not likely to cause surface
water to exceed ambient water quality standard (WQS).

Activity results in withdrawal of ground water, reduction
of infiltration, or change in ground water flow direction
that reduces or eliminates inflow to streams that are not
ecologically significant habitat.

Withdrawal of ground water or reduction in infiltration
that lowers the depth of the ground water table in
unconfined aquifers, but does not impact vegetation or
stream flow or result in saltwater intrusion.

Withdrawal of ground water results in a reduction of the
potentiometric surface (water-level elevations in wells
tapping a confined aquifer).

No introduction of pollutants to ground water.

No withdrawal of ground water.
                                         C-2-9
                                                   July 1998

-------
                                                             Identifying Significant Issues
Surface water. Surface water includes streams, rivers, ponds, lakes, wetlands, estuaries,
bays, and oceans.  When evaluating proposed project activities, it is important to consider
physical and chemical impacts.  Inputs that deteriorate water quality and impact aquatic life
include nutrients, heat, changes in pH, sediments, oxygen-consuming substances, in addition
to toxic compounds such as petroleum, PCBs, chlorinated pesticides, and heavy metals.
Sources of contamination to surface water include point source discharges, nonpoint source
runoff, marine vessels, and ground water. Changes in the volume or velocity of water in a
waterbody can erode stream banks, increase siltation/sedimentation, change salinity regimes,
and ultimately modify or destroy habitat.  Withdrawals from surface water bodies can reduce
instream flows below critical levels which are necessary to maintain riparian6 and instream
communities.
Rank
Significant Adverse  •
Contributing Factors

Activity results in introduction of pollutants (through
contaminated discharge, contaminated runoff, or dredging
of contaminated sediments) to surface water and is likely
to cause exceedance of state ambient water quality
standards, including chemical specific standards and
physical characteristics like turbidity, pH, dissolved
oxygen.

Activity results in discharge that exceeds National
Pollutant Discharge Elimination System (NPDES) permit
limitations.

Activity results in modification to flow volume or velocity
such that scouring occurs in the water body and is likely
to result in modification of stream channel, bottom
substrate, and/or bank stability.

Activity is likely to impede natural drainage patterns or
the direction of flow of surface water body.

Activity results in point or nonpoint source discharge of
sediments, nutrients, chemicals or other parameters that
result in modification or destruction of critical habitat of
threatened or  endangered species.
         Riparian refers to the area alongside the banks of a natural watercourse, usually a river or stream but
sometimes a lake or estuary.
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                                                            Identifying Significant Issues
Adverse
No Impact
Withdrawal of surface water or ground water that supplies
surface water results in disruption of riparian vegetation.

Introduction of pollutants, including sediment, that will
contribute to exceedance of ambient WQS in combination
with other sources.

Introduction of nutrients into a water body resulting in the
occurrence of algal blooms more frequently, for extended
time periods, or during critical intervals.

Withdrawal of surface water results in reduction of
sufficient flow to support sensitive habitats, threatened or
endangered species, or their habitats.

Activity results in introduction of pollutants (through
contaminated discharge,  contaminated  runoff, or  dredging
of contaminated sediments) to surface water, but
introduction is not likely to cause exceedance of ambient
WQS, including chemical specific standards and physical
characteristics like turbidity, pH, dissolved oxygen.

Pollutant discharges do not exceed NPDES permit
limitations.

Activity results in point or nonpoint source discharge of
sediments, nutrients, chemicals or other parameters that
result in modification or destruction of habitat of
indigenous species.

Influx of nutrients that results in periodic algal blooms.

Withdrawal of surface water results in reduction of flow,
but is not likely to impact riparian vegetation, aquatic life,
sensitive habitats, or threatened or  endangered species.

Activity does not result in introduction of pollutants or
withdrawal  of surface water.
                                          C-2-11
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                                                            Identifying Significant Issues
Floodplains.  Floodplains are the flat areas adjacent to the river's normal channel. These
areas accommodate flood flows resulting from rainfall and snowmelt.  Placing structures
within the floodplain can expose them to the impacts of flooding,  it can also reduce the
absorptive capacity of the floodplain and increase the volume and velocity of downstream
floodwaters. The 100-year floodplain is the area that is likely to be inundated during the  100-
year base flood.  A base flood is a flood that has a one percent chance of occurring in any
given year (i.e., a flood with a magnitude equaled once in 100 years). Restriction of the flow
of a base flood is defined as raising the flood levels by one foot or more due to the presence of
an obstruction7.
Rank
Significant Adverse   •
Adverse
No Impact
Contributing Factors

The activity results in placement of structures within the
100-year floodplain that are likely to incur significant
damage due to flooding.

The activity is displacing the absorptive capacity of the
floodplain such that it will restrict the flow of the 100-
year base flood and increase the potential for risk to life
or damage to downstream areas.

The activity is located within the 100-year floodplain, but
structures are not likely to sustain damage due to
flooding.

The activity does not displace the absorptive capacity of
the floodplain.

The activity is not located within the 100-year floodplain.
       7 This is the threshold used in EPA regulations governing the placement of landfills and sludge disposal units.
                                         C-2-12
                                                   July 1998

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                                                             Identifying Significant Issues
C.     Biological Resources

Biological resources that may be affected include vegetation, fish and wildlife, threatened and
endangered species, and habitat (see Figure 6-4 in main text). Assessing impacts to biological
resources requires knowledge of the types of plant and animal species present and their
distribution throughout the area, and an understanding of the relationships among  species,
populations, and habitat.  The evaluation should consider primary, secondary, and cumulative
impacts. Following are examples of factors which contribute to an activity's classification as
significant adverse, adverse, or no impact to biological resources.

Vegetation.  Vegetation provides food and shelter for fish and animals.  It also prevents
erosion and protects water quality. Some species of vegetation provide food or habitat during
critical life history stages of invertebrate and vertebrate species.  Impacts to vegetation result
from land clearing for construction and from disturbances associated with training activities.
Aquatic vegetation is impacted directly through water-based construction and indirectly
through increased sedimentation or pollutant loading from  land-based activities. Atmospheric
deposition can have adverse impacts on both terrestrial and aquatic vegetation. When
assessing the impacts of a proposed project on vegetation, it is important to consider the value
of the  vegetation in terms of ecosystem function, and its abundance and distribution.
Rank
Significant Adverse
Contributing Factors

The activity reduces, the diversity of terrestrial or aquatic
vegetation.

The activity reduces or eliminates native species or their
habitat.

The activity creates conditions conducive to proliferation
of non-native, invasive species.

The activity replaces native vegetation that served as food
source or habitat with vegetation that does not provide
food or habitat.

The activity is located in proximity to unique plant
populations or communities or isolated plant populations
of scientific interest.

The activity requires removal of vegetation which will
likely cause erosion and transport of sediment to
waterways, resulting in significant adverse impact to
water resources (see 6.3.2).

The activity involves introduction of pollutants, including
sediments and nutrients, to water bodies which may in
                                          C-2-13
                                                     July 1998

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                                                             Identifying Significant Issues
 Adverse
No Impact
 turn impact aquatic vegetation which serves as critical
 habitat for threatened or endangered species.

 The activity replaces native vegetation with non-native,
 but non-invasive species.

 The activity replaces native vegetation that served as food
 source or habitat with vegetation that provides food or
 habitat of lesser value.

 The activity removes vegetation which will likely cause
 erosion and transport of sediment to waterways, resulting
 in adverse impact to water resources (see section 6.3.2 in
 main text).

 The activity involves introduction of pollutants, including
 sediments and nutrients, to water bodies which may in
 turn impact aquatic vegetation which serves as habitat for
 indigenous species.

 The activity does not remove vegetation or is restricted to
 a previously developed area that has already been
 disturbed.
Fish and Wildlife.  Impacts to fish and wildlife can occur through numerous pathways
including destruction of habitat and food source, restriction of population movement due to
habitat fragmentation, alteration of community structure caused by changes in populations of
predator or prey species, and contamination through the introduction of pollutants to the
environment.  The sensitivity of a population to impact varies tremendously.  When assessing
the impact of the proposed project on fish and wildlife species it is important to consider
species abundance and distribution, position and function in the food chain, and habitat and
food source requirements throughout all life stages.  It is also important to consider both
resident and migratory species of fish and wildlife.
Rank
Significant Adverse  •
Contributing Factors

The activity will reduce or destroy food or habitat of
importance to terrestrial, riparian, or aquatic wildlife.

The activity eliminates fish spawning or wildlife breeding
areas.

The activity is located outside of the cantonment area,
within a migratory pathway, and proposed activities will
occur during migrations.
                                         C-2-14
                                                    July 1998

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                                                            Identifying Significant Issues
Adverse
No Impact
The activity eliminates a native population.

The activity will permanently (5 .years or longer) reduce
populations of fish or wildlife species by 50 percent.

The activity will impact specific species and will result in
alteration of community structure.

The activity will create favorable conditions for nuisance,
exotic, or pest species.

The activity will permanently (5 years of longer) reduce
populations of fish or wildlife by 15 to 50 percent.

The activity reduces the areal extent of fish spawning or
wildlife breeding areas, but does not eliminate them.

The activity results in temporary alteration of fish or
wildlife habitat, but not during critical stages of the
species' life cycle.

The activity is located outside of the cantonment area,
within a migratory pathway, but activities do not occur
during migrations.

The activity is located within the cantonment area and
does not disturb the habitat, food source,  or migratory
pathways of fish or!wildlife.
Threatened and Endangered Species.  Threatened or endangered species can be either plant
or animal.  A list of threatened and endangered species is published in the Code of Federal
Regulations at Title 50 Code of Federal Regulations Part 17.  To ensure the proposed project
will not impact threatened or endangered species' or their habitat, consultation with the Fish
and Wildlife Service is recommended.          :    .
Rank
Significant Adverse  •
 Contributing Factors

 Consultation with the Fish and Wildlife Service/National
 Marine Fisheries Service has determined that the activity,
 alone or in combination with other activities, is likely to
 jeopardize the continued existence of a species including
 individual members of the species or their habitat.
                                          C-2-15
                                                     July 1998

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                                                             Identifying Significant Issues
 Adverse
No Impact
 The activity is located in an area where threatened or
 endangered species are present and known to be sensitive
 to human activities.

 The activity will destroy critical habitat of threatened or
 endangered species.

 The activity fragments or encroaches over time on critical
 habitat of threatened or endangered species.

 The activity, alone or in combination with other activities,
 is likely to inhibit a species recovery.

 The activity is likely to directly or indirectly affect an
 individual of a threatened or endangered species, but not
 affect its recovery.

 The activity will result in temporary disturbance of habitat
 for threatened or endangered species.

 The activity is located in an area where threatened or
 endangered species are present, but they  are not sensitive
 to the actions associated with the construction of operation
 of the activity.

 There are no threatened or endangered species in the
 proximity of the activity.
Habitat. Habitat includes the biological community and the abiotic components within an
area. The biological community is comprised of microbes,  fungi, plants, and animals.  The
abiotic components consist of the geological features, soil, hydrology, climate,  and nutrient
cycles.  Habitat can be defined for an individual organism, a population, or an entire
biological community.  Maintenance of the habitat is essential to maintenance of the
community, population, and individual.  When assessing the impact of a proposed project on
habitat, it is important to consider the type and size of the habitat, the abundance and
distribution of similar habitat types in the local area, and the importance of the habitat to the
components of the biological community, including resident and migratory species.
Rank
Significant Adverse
Contributing Factors

The activity will destroy or damage rare or unique
ecosystems (e.g., coastlines, wetlands, deserts, old
growth forests, pristine areas, breeding or nesting
grounds).
                                         C-2-16
                                                    July 1998

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                                                            Identifying Significant Issues
Adverse
No Impact
The activity, alone or in combination with other activities,
will impact the integrity of an ecological system by
removing 75 to 100 percent of an ecological association
(e.g., meadow, forest, sandy beach, wetland, submerged
grass bed, reef).

The activity will disrupt the flow of resources (e.g.,
nutrients, water) to or from unique ecosystems.

The activity will cause or contribute to the introduction of
nuisance, invasive, or pest flora or fauna that may
displace native species and alter existing habitat.

The activity, alone or in combination with other activities,
will impact the integrity of an ecological system by
removing 25 to 75 percent of an ecological association
(e.g., meadow, forest, wetland, submerged grass bed,
reef).

The activity will exert a localized and temporary impact
on rare or unique ecosystems.

the activity is located within the cantonment area and will
not modify or otherwise encroach on natural habitat.

There are not  rare or unique  ecosystems located at or near
the proximity  of the activity
                                          C-2-17
                                                    July 1998

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                                                           Identifying Significant Issues
D.    Hazardous Materials and Solid Waste Management

The waste management resource group includes the management of hazardous materials, and
hazardous, non-hazardous, and solid wastes (see Figure 6-5 of main text). For definitions of
hazardous and non-hazardous waste categories, see Section 5.4 of main text.

Hazardous Materials and Waste.  When assessing the impact of an activity on the
management of hazardous material and/or hazardous and non-hazardous waste, it is important
to evaluate the usage and storage of hazardous material in addition to the storage and disposal
requirements for hazardous waste.
Rank
Significant Adverse
Adverse
No Impact
Contributing Factors

Permanent or temporary storage tanks at the activity site
are not equipped with leak detection mechanisms,
secondary containment systems, spill and overfill
protection, or other safety services.

Failure of hazardous materials or hazardous wastes
handling, storage, or disposal poses a threat to public
health and/or environmental media.

Accommodating the increased hazardous waste generated
will pose a significant cost.

The activity involves long-term generation, storage,
and/or disposal of large quantities of hazardous wastes.

The activity involves the long-term management of large
quantities of hazardous materials.

The activity requires the removal and disposal of
structural materials that contain hazardous materials (e.g.,
lead-based paints, asbestos).

Accommodating the increased waste generated will cause
a nominal increase in consumers cost of waste
management.

The activity requires the management of hazardous
materials.

The activity will not generate hazardous waste.
                                        C-2-18
                                                   July 1998

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                                                           Identifying Significant Issues
                    •     The activity will not require hazardous materials
                           management.

Solid Waste.  When assessing the impact of a proposed project on the generation of solid
waste, it is important to determine the volume and rate of waste generation and the capacity of
waste management, including recycling, and disposal systems.
Rank
Significant Adverse
Adverse
No Impact
Contributing Factors

Recyclable solid wastes generated by the activity will not
be recycled because the volume generated will exceed the
capacity of recycling operations.

Accommodating the increased solid waste generated will
cause a substantial increase in consumers cost of waste
management.

Storage and  handling of wastes increases the potential for
spills or leaks that may potentially contaminate soil,
ground water or surface water.

Solid waste volumes generated will reduce the life of
existing waste management and disposal operations.

Accommodating the increased waste generated will cause
a nominal increase in consumers cost of waste
management.

The activity will not increase the waste stream.
                                         C-2-19
                                                   July 1998

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                                                               Identifying Significant Issues
E.     Cultural Resources and Aesthetics

The resource group cultural resources and aesthetics addresses attributes that are considered
important to the local populations' sense of history and well-being. Cultural resources may be
historical buildings or landmarks, cemeteries, or other archaeological ruins; aesthetics refers
more to the visual quality of a site or region (see Figure 6-6 of main text). These resources
are primarily affected by the siting and construction of new buildings and infrastructure.
Sometimes they can be affected by changes in use of or access to resource areas.

Cultural Resources.  Cultural resources include archeological sites, historical sites, and other
cultural sites.  When assessing the potential impact of a proposed project on cultural resources,
it is important to consider proximity of the proposed project to the site, current use and access
to the site, and the potential to uncover previously unknown cultural resources.
Rank
Significant Adverse
Adverse
 Contributing Factors

 The activity will destroy an archeological, historical, or
 other cultural site that is listed on the National Register of
 Historic Places.

 The activity will permanently restrict public access to an
 archeological, historical, or other cultural site that is
 listed on the National Register of Historic Places.

 The activity will alter the landscape around an
 archeological, historical, or other cultural site and
 degrade the aesthetic value of its existing setting.

 The activity is located in an area where there is a high
 probability of finding artifacts of archeological, historical,
 or other cultural value and no plan exists for evaluating
 and recovering artifacts during the course of the proposed
 project.

 The activity will temporarily restrict public access to an
 archeological, historical, or other cultural site that is
 listed on the National Register of Historic Places.

 The activity will alter the landscape around an
 archeological, historical, or other cultural site, but
 measures are taken to protect the aesthetic value of its
 existing setting.

The activity  is located in an area where there is a high
probability of finding artifacts of archeological, historical,
or other cultural value, but a plan exists for evaluating
                                          C-2-20
                                                     July 1998

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                                                              Identifying Significant Issues
                            and recovering artifacts during the course of the proposed
                            project.

No Impact           •     The activity will not affect public access to an
                            archeological, historical, or other cultural site that is
                            listed on the National Register of Historic Places.

                     •     The activity will have no impact on the visual or audio
                            setting of an archeological, historical, or other cultural
                            site.

                     •     The activity is not located in the vicinity of an
                            archeological, historic, or other cultural site listed on the
                            National Register of Historic Places.

                     •     The activity is not located in an area where there is a high
                            probability of finding artifacts of archeological,  historical,
                            or other cultural value.

Visual and Aesthetic Values. Aesthetics,  in a broad sense, involve the general visual, audio,
and tactile environment and their emotional or psychological effect on people.
Visual/aesthetic resources refer to the structures, landscapes, and spaces of an area which
provide information for an individual to develop perceptions of the area. When considering a
proposed project or activity for development it is important to determine if it will adversely
affect the visual/aesthetic setting perceived by residents of the surrounding area.
Significant Adverse   •
Adverse
The activity will degrade the visual scene of the
surrounding area,  including interfering with natural
views, destroying  natural vegetative buffers, contributing
smoke, causing odors and noise, or discoloring water
bodies.

The activity will destroy, damage, or obscure scarce or
unique geological  features, landscapes, or other objects of
particular aesthetic Value.

The activity will deny accessibility to aesthetic resources,
including recreational access.

The activity will temporarily disrupt the visual scene of
the surrounding area, but will not disturb natural
vegetative buffers.

The activity will degrade the visual scene of the
surrounding area,  but architectural and landscaping
techniques are employed to minimize the impact.
                                           C-2-21
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                                                               Identifying Significant Issues
No Impact
The activity will limit accessibility to aesthetic resources,
including restricted recreational access.

The activity will not alter the visual or aesthetic character
of the area.
                                          C-2-22
                                                     July 1998

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                                                            Identifying Significant Issues
F.
       Socioeconomic Resources
This resource group includes population, housing, community facilities, and the economy.

Population.  An environmental assessment typically includes an assessment of potential
impacts of the proposed project on population demographics.  This information contributes to
the evaluation of the other elements of socioeconomic resources.  Important information
includes employment rates, migration rates, birth and death rates. When assessing impacts to
a local population it may be appropriate to describe changes in the age, sex, and ethnic
composition of the population, as well as educational attainment,  income,  and residential
stability (see Figure 6-7 of main text).
Rank
Significant Adverse
Adverse
                           Contributing Factors

                           Within the economic region of influence, the activity will
                           create or contribute to an excursion above or below the
                           existing forecasted pppulation by more than 5 percent.

                           The activity will cause a change in the population
                           demographics that could potentially disrupt employment
                           patterns or provision of services.

                           The activity will result in the dislocation of portions of the
                           local population due to loss of jobs or increases in
                           property values.

                           Within the economic region of influence, the activity will
                           create or contribute to an excursion above or below the
                           existing forecasted population by between 1 and 5
                           percent.

                           The activity will result in short term influx of workers.

                           Within the economic region of influence, the activity will
                           create or contribute to an excursion above or below the
                           existing forecasted population by less than 1  percent.

                     •     The activity does not require additional people to be
                           permanently or temporarily introduced to the area.

Housing. When assessing the potential impact of the proposed project on housing, it is
important to consider the availability of housing and the cost of housing relative to demand
and income.  It is also important to identify whether existing housing meets regulation
standards or if the proposed project has the potential to impact the value of residential
property.
No Impact
                                         C-2-23
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                                                            Identifying Significant Issues
Significant Adverse  •
Rank                       Contributing Factors

                            The activity will create a shortage of affordable housing
                            or will increase housing prices.

                     •      The activity results in housing that does not meet standards.

                     •      The activity will cause property values to decline.

                     •      The activity will adversely affect the availability of
                            mortgages or mortgage insurance.

                     •      The activity will cause forecasted vacancy rates to
                            increase or decrease by more than 5 percent.

Adverse             •      The activity will cause forecasted vacancy rates to
                            increase or decrease by  1 to 5 percent.

No Impact           •      The activity will not impact property values.

                     •      The activity will not require an influx  of new inhabitants
                            or relocation of existing ones, therefore the housing
                            resource is not impacted.

                     •      The activity will cause forecasted vacancy rates to
                            increase or decrease by less than 1 percent.

Community Services.  Community services refer to both pubic and private services on-post
and off-post that serve area residents.  Community services include primary, secondary and
adult education; health care; social services; police, fire and rescue; and recreational and
cultural activities. When evaluating a proposed project,  it is important to consider, existing
and projected capacity to provide services, current and future changes  in demand, and access
to community services.
Rank

Significant Adverse  •
                            Contributing Factors

                            Changes caused by the activity will result in a shortage of
                            community services.

                            Changes caused by the activity will result in long term
                            unused capacity of community services.

                            The activity provides redundant services and will result in
                            long term excess capacity for community services.
                                          C-2-24
                                                                                July 1998

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                                                           Identifying Significant Issues
                     •     The activity will require the number of service positions
                           for any category (e.g., teachers, fire, police) to increase
                           10 percent or more above forecasted levels.

Adverse             •     The activity will increase or decrease short-term demand
                           for community services.

                     •     The activity provides redundant services, but any unused
                           capacity is expected to be temporary.

                     •     The activity will require the number of service positions
                           for any category (e.g., teachers, fire, police) to increase
                           between 5 and 9 percent above forecasted levels.

No Impact           •     The activity does not impact demand for community
                           services.

                     •     The activity will require the number of service positions
                           for any category (e.g., teachers, fire, police) to increase
                           less than 4 percent above forecasted levels.

Economy. The effects of a proposed project on the economy depend on the size of the
project, in terms of project expenditure and employment, and the duration of the proposed
project.  In assessing the potential economic impacts of the proposed project, it is important to
quantify any primary impacts associated with the project and to evaluate the ability of the
region of concern to accommodate such changes. In general, a more rigorous assessment of
economic impacts is required for larger, more complex projects.
Rank
Significant Adverse   •
Contributing Factors

The activity will cause unemployment to increase by more
than 1 percent.

The activity will cause household income to decrease by
more than 1 percent.

The activity will reduce the bond rating of local
municipalities.

The multiplier effect of direct unemployment associated
with the activity will i dampen economic activity.

Reduced economic activity associated with the
unemployment caused by the activity will cause secondary
unemployment.
                                        C-2-25
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                                                          Identifying Significant Issues
Adverse
No Impact
The activity will cause a permanent reduction in military
personnel which will significantly reduce expenditures in
the local economy causing reduced economic growth and
secondary unemployment.

The activity will cause unemployment to increase by 0.5
to 1 percent.

The activity will cause household income to decrease by
0.5 to 1 percent.

The activity does not result in changes to employment or
income.
                                       C-2-26
                                                  July 1998

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                                                             Identifying Significant Issues
G.     Land Use and Infrastructure

The resource group infrastructure and land use includes utilities, transportation, and land use.
Land use plans address the integration of the built and natural environments and the human
activities occurring in a community.  In general, a community land use plan is implemented to
protect the health, safety and welfare of the population.  In recent years, land use plans have
been used to address protection of environmental resources and aesthetics.

Land Use.  When evaluating the proposed project, it is important to consider whether the
project is consistent with the designated land use and compatible with neighboring land uses.
If the proposed project is not appropriate for the designated land use then changes in the
proposed project or changes in zoning may be necessary.
Rank
Significant Adverse
Adverse
No Impact
Contributing Factors

The activity is inconsistent with a Master Plan and has the
potential to adversely affect the health, safety, and
welfare of the population or the quality of the
environment.

The activity creates a direct conflict among neighboring
land use activities, for example, residential areas and
range/training areas.

The activity will permanently destroy the existing land use
designation, for example, convert open space to
commercial facilities.

The activity is inconsistent with a Master Plan, but does
not have the potential to adversely affect the health,
safety, and welfare of the population or the quality of the
environment.

The activity requires a change in a local land use plan.

The activity requires a change in local zoning.

The activity is consistent with a  Master Plan.
Utilities. Utilities refer to the public services, such as electricity, water, and sanitation, that
are located in the area that serve and are used by residents and installation activities.  Utility
services that may be provided include: electricity, natural gas, potable water, sewage
collection and treatment, storm water collection, and trash collection and disposal. A key
consideration in assessing the impacts associated with a proposed project is to compare the
increased or decreased demand for public services with the unused capacity of the provider.
                                          C-2-27
                                                    July 1998

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                                                            Identifying Significant Issues
 Rank
 Significant Adverse
 Adverse
                            Contributing Factors

                            The activity will require utility services that are non-
                            existent.

                            The immediate and/or long term utility needs of the
                            activity have the potential to exceed the actual or
                            projected capacity of the utility to provide service,
                            without a major system modification such as additional
                            generation capacity.

                            The activity requires the acceleration of planned capacity
                            improvements by more than 5 years.

                            The activity is likely to increase immediate and/or long
                            term demand for service of one or more utilities beyond
                            current or projected capacity without minor system
                            modifications such as increasing capacity to existing
                            distribution systems or extending distribution systems.

                            The activity requires the acceleration of planned capacity
                            improvements by 1 to 5 years.

                            The activity does not affect demand for any utilities.

                     •      The immediate and/or long term increases in demand for
                            service are not expected to warrant any system
                            modification.

                     •      The activity requires the acceleration of planned capacity
                            improvements by less than one year.

Transportation. Transportation networks include road systems, railroads, waterway
transportation routes, and air transport.  Transportation services facilitate the movement of
people and goods. Transportation networks can have high social costs such as noise,  safety
hazards, and air pollution. The travel-ways can cause aesthetic problems and create physical
barriers to ground water movement and human and wildlife passage. When assessing potential
impact associated with transportation, it is important to consider (1)  the extent to which the
proposed project's transportation improvements are consistent with applicable local and
regional  transportation plans and (2) the level of service (LOS) resulting from the assignment
of project-induced travel demand to the existing transportation network.
 No Impact
Rank
                           Contributing Factors
                                         C-2-28
                                                                               July 1998

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                                                             Identifying Significant Issues
Significant Adverse
Adverse
No Impact
The activity requires transportation services and/or
infrastructure that are nonexistent and will need to be
constructed before construction of the proposed project.

The activity is likely to result in increased utilization of a
public road such that the level of service would decrease
to an unacceptable level, as defined in county or local
comprehensive plans.

The activity is likely to result in increased utilization of
railways, water shipping lanes, and air space beyond
existing or projected capacity.

The activity requires the acceleration of planned capacity
improvements by more than 5 years.

The activity requires development of new or significantly
expanded transportation services,  which will cause
cumulative impacts on air quality, water quality, and
biological resources.

The activity is likely to result in increased utilization of a
public road which may cause a decrease in the level of
service; but the level of service will remain equal to or
better than the level of service planned in county or local
comprehensive plans.

The activity is likely to result in increased utilization of
railways, water shipping lanes, and air space, but is not
projected to exceed existing or projected capacity.

The activity requires limited expanded transportation
services,  which are not projected  to increase impacts on
air quality, water  quality, and biological resources.

The activity requires the acceleration of planned capacity
improvements by  2 to 5 years.

The activity will not increase utilization of transportation
services.
Activity related increases in transportation services  are
not anticipated to  decrease the level of service projected  in
county or local  comprehensive plans.

The activity requires the acceleration of planned capacity
improvements by  1 year or less.
                                          C-2-29
                                                     July 1998

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                   Identifying Significant Issues
C-2-30
July 1998

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              APPENDIX D

         CONTENTS OF SPECIFIC
ENVIRONMENTAL IMPACT ASSESSMENT TOOLS

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                                                         Contents of Specific EIA Tools
                               EIA Tools — Introduction

Several tools and techniques for EIA reviewers are introduced in this student text. Many more
are available separately. To further assist EIA professionals, USEPA has developed the following
resource materials to compliment this text:

•   Resource Manual for Principles of Environmental Impact Assessment Review
    This Manual provides material referenced in the Principles course and student text, as well as
    material that is not covered in the course, such as  additional background on the EIA process,
    lists of available guidance documents from the World Bank and USEPA along with some
    excerpts and example documents, country specific laws and regulations, and a list of helpful
    Internet sites. Appendix D contains the table of contents for the Resource Manual which
    may change depending on the specific needs of the host country; and user.

•   Compact Disc(s): USEPA has produced two compact disks that are either available
    separately or combined into a single CD in version 4 issued in 1998. The two component
    programs are:

    - Environmental Impact Assessment Resource Guide (EARG): The EARG is an interactive
    program that allows participants to walk through information on the EIA process from
    project initiation to post-decision analysis.  The contents are listed in this appendix.

    - Environmental Impact Assessment Interactive Case Study: Chuitna, Alaska: This
    interactive CD-ROM enables the user to walk through the complete EIA process for a
    proposed project in Chuitna, Alaska and develop their own EIA. The CD-ROM covers the
    project's initiation, scoping, generation and analysis of alternatives, decision-making, and
    post-decision analysis. The notebook feature of the program is geared toward both self-study
    as well as an providing an ongoing tool. As an ongoing tool, the notebook feature of the
    program  enables the user to use the CD-ROM as a prompt to assist in the development or
    review of any EIA since they can be cleared and saved under different file names. An outline
    of the program's contents is listed in this appendix.

•   Principles of Environmental Impact Assessment text:  The Principles of Environmental
    Impact Assessment text and course was developed by USEPA to provide the basics of the
    EIA process, why each element is important,  and how one conducts the process and develops
    the EIA.  The course has been delivered in  over a dozen countries around the world to
    officials from government departments, non-governmental organizations, and others with the
    need to understand and implement the EIA process. This appendix contains a summary of
    the contents of the Principles of Environmental Impact Assessment.
                                          D-l
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                                                         Contents of Specific EIA Tools
 The CD-ROM(s), and Principles of Environmental Impact Assessment Review and guidelines
 described in this appendix are available from the United States Environmental Protection Agency.
 Contact:

           U.S. Environmental Protection Agency
           Office of Federal Activities
           MC2251-A
           401 M Street, Southwest
           Washington, DC 20460

 Reference the course Principles of Environmental Impact Assessment Review when inquiring.
July 1998
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                                                        Contents of Specific EIA Tools
                             RESOURCE MANUAL FOR
       PRINCIPLES OF ENVIRONMENTAL IMPACT ASSESSMENT REVIEW

                               TABLE OF CONTENTS
PREFACE	 .		M

ACRONYMS	  v/

SECTION 1 The Environmental Impact Assessment Process	  1-1
            1.1 Evolution of the Environmental Impact Assessment Process	1.1-1
            1.2 Overview of the Environmental Impact Assessment Process	1.2-1
            1.3 Project Initiation	1.3.1
                1.3.1 Purpose and Need	  1.3.1-1
                1.3.2 Statement of Underlying Need
                     Defines the Range of Alternatives	  1.3.2-1
                1.3.3 Techniques for Communicating with the Public	  1.3.3-1
                1.3.4 Identification of Issues	  1.3.1-1
                1.3.5 Generation of Alternatives  	  1.3.5-1
                1.3.6 Environmental Impact Checklists 	  1.3.6-1
            1.4 Decision to Proceed	,	1.4-1
            1.5 Draft/Final Environmental Impact Assessment Analysis and
                Documentation	1.5-1
                1.5.1 Scoping	  1.5.1-1
                1.5.2 CEQ Scoping Guidance	  1.5.2-1
                1.5.3 Defining the Scope of Alternatives in an Environmental
                     Impact Statement After Citizens Against Burlington ....  1.5.3-1
                1.5.4 Assessment	,	  1.5.4-1
                1.5.5 Sources of Environmental Data	  1.5.5-1
                1.5.6 Computer-Aided Environmental Assessment 	  1.5.6-1
                1.5.7 Impact Identification	  1.5.7-1
                1.5.8 Impact Analysis and Prediction  	  1.5.8-1
                1.5.9 Summary of Fate Models Used in Environmental
                     Assessment	  1.5.9-1
                1.5.10 Problems Associated with Amalgamation of Data	 1.5.10-1
                1.5.11 Geographic Information Systems	 1.5.11-1
                1.5.12 Determination of Significance  	 1.5.12-1
                1.5.13 Definitions for Describing Significance of Impacts .... 1.5.13-1
                1.5.14 Determining Impact Significance in Environmental
                      Impact Assessment	 1.5.14-1
                1.5.15 Mitigation	 1.5.15-1
                1.5.16 An Unreadable Environmental Impact Statement
                      is an Environmental Hazard	 1.5.16-1
                1.5.17 EPA Rating System Criteria for Draft Environmental
                                         D-3
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                                                         Contents of Specific EIA Tools
                       Impact Statements	 1.5.17-1
             1.6 Decision Making	1.6-1
                  1.6.1 Indices of Environmental Quality	 1.6.1-1
             1.7 Follow-Up	1.7-1
                  1.7.1 Negotiating a Monitoring Program	 1.7.1-1

 SECTION 2 Environmental Impact Assessment Methodologies and Evaluation
             Checklist  	 2-1
             2.1 Environmental Impact Assessment Methodologies 	2.1-1
             2.2 Environmental Impact Assessment Evaluation Checklist	2.2-1

 SECTION 3 World Bank Project Specific Impacts and Mitigation Measures	 3-1
             3.1 Industrial Impacts	3.1-1
             3.2 Project Specific Mitigation Measures World Bank Tables	3.2-1

 SECTION 4 Country Specific Laws / Background	 4-1

 SECTION 5 Relevant U.S. Environmental Protection Agency Guidance for
             Environmental Impact Assessment Reviewers 	 5-1
             List of Relevant U.S. Environmental Protection Agency Guidance
             5.1 Example 1: Ecological Impacts From Highway Development
             5.2 Example 2: Environmental Impact Assessment Guidelines for
                 Mining (Ore and Coal)

 SECTION 6 Glossary	 6-1

 SECTION 7 Environmental Impact Assessment Resources on the Internet  and
            Compact Disc	 7-1
July 1998
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                                                     Contents of Specific EIA Tools
                      COMPACT DISC: ENVIRONMENTAL
                    ASSESSMENT RESOURCE GUIDE (EARG)

                            OUTLINE OF CONTENTS
I. INTRODUCTION
      A. Acknowledgments                  ;
      B. EPA/Environmental Impact Assessment 'Workshop
      C. Acronyms
      D. Glossary

II. EA PROCESS EVOLUTION
      A. Policies, Plans & Programs
      B. Sustainability
      C. References

III. INITIATION
      A. Needs
          1. Environmental Information Packet
          2. Screening
          3. Interdisciplinary Teams
          4. Project Responsibilities
          5. Public Involvement Strategies
          6. Planning Records
      B. Tools
      C. Issues
          1. EA and Project Planning
          2. Coordination with Other Laws
      D. Linkages
      E. References
      F. Identification of Issues
          1. Needs
          2. Tools
          3. Issues
          4. Linkages
          5. References
                                       D-5
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                                                         Contents of Specific EIA Tools
 IV. SCOPING
       A. Needs
           1. Preliminary Project Information
           2. Early Planning
           3. Public Involvement
       B. Tools (Scoping meeting)
       C. Issues
       D. Linkages
       E. References

 V. GENERATION OF ALTERNATIVES
       A. Needs
       B. Tools
       C. Issues
       D. Linkages
       E. References
       F. Describing the Environmental Setting
           Geology, Topography, Soils, Groundwater Resources, Surface Water Resources,
           Terrestrial Communities, Aquatic Communities, Sensitive Areas, Air Quality, Land
           Use, Demography, Sound Levels, Infrastructure Services, Transportation, Cultural
           Resources, Project Economics.

 VI. ASSESSMENT
       A. Affected Environment
           1. Needs
           2. Tools
           3. Issues
           4. Linkages
           5. References
           6. General Site Information (12 items, most illustrated)
       B. Impact Identification
           1. Needs (17 illustrated items)
           2. Tools
               a. Site Visits
               b. Use of Checklists
               c. Checklist Example
               d. Matrix
               e. Networks
               f.  Other Tools (GIS)
           3. Issues
               a. Boundaries
               b. Predicting Impacts
               c. Assessing Cumulative Impacts
               d. Defined Endpoints
           4. Linkages
           5. References
July 1998
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                                                   Contents of Specific EIA Tools
C. Impact Analysis and Prediction
    1. Needs
    2. Tools                           ;
    3. Issues
    4. Linkages
    5. References
D. Determination of Significance
    1. Needs
    2. Tools
    3.Issues
    4. Linkages
    5. References
    6. Categories of Mitigation
        a. Avoidance
        b. Minimization
        c. Rectification
        d. Reduction
        e. Compensation
F. Documentation
    1. Needs
    2. Tools
    3. Issues
    4. Linkages
    5. References
    6. Environmental Impact Assessment Elements
G. Small Projects
    1. Small Project Environmental Impact Assessments
    2. Environmental Audits
H. World Bank Mitigation Tables
    Chapter 8: Agricultural and Rural Development, Rural Development, Agroindustry,
    Dams and Reservoirs, Fisheries, Flood Protection, Natural Forest Management,
    Plantation Development and Reforestation, Irrigation and Drainage, Livestock and
    Rangeland Management, Rural roads.,
    Chapter 9: Population, Health, Transport, Development, Water and Sewer, Roads
    and Highways, Inland Navigation, Ports and Harbors, Housing Projects, Solid Waste,
    Tourism, Wastewater.              :
    Chapter 10: Industrial Hazard Management, Electric Power Transmission, Oil and
    Gas Pipelines, Oil and Gas Development-Offshore and Onshore, Hydroelectric
    Projects, Thermoelectric Projects, Cement, Chemical and Petrochemical, Fertilizer,
    Food Processing, Iron and Steel, Nonferrous Metals, Petroleum Refining, Pulp, Paper
    and Timber, Mining and Mineral Resources.
                                   D-7
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                                                      Contents of Specific EIA Tools
 VII. DECISION-MAKING
       A. Needs
       B. Tools
       C. Issues
       D. Linkages
       E. References
       F. Alternatives (Matrix)

 VIIL POST-DECISION ANALYSIS
       A. Needs
       B. Tools
       C. Issues
       D. Linkages
July 1998
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                                                       Contents of Specific EIA Tools
                                 COMPACT DISC
        Environmental Impact Assessment CASE STUDY: CHUITNA, ALASKA

                             OUTLINE OF CONTENTS

A. INITIATION
       1. Project Orientation
       2. Simulated Flight Over Area                                   .      e
       3. Screening                                                    •-,ป
       4. Interdisciplinary Team
       5. Initiating Public Involvement                               ;
       6. Record-Keeping

B. SCOPING
       1. Introduction
       2. Identification of Issues
       3. Agency Involvement
       4. Public Involvement
       5. Responsiveness Summary
       6. Issues of Concern

C. GENERATION OF ALTERNATIVES
       1. Introduction
       2. Identification of Options
       3. Options Screening
       4. Identification of Alternatives

D. ASSESSMENT
       1. Introduction
       2. Description of Affected Environment
           a. Introduction
           b. Interdisciplinary Team
           c. Terrestrial Habitat Report
       3. Impact Identification
       4. Impact Analysis and Prediction
           Terrestrial Habitat Analysis
           a. Introduction
           b. Objective 1: Habitat Types
           c. Objective 2: Key Species
           d. Objective 3: Component Comparison
           e. Objective 4: Pre-mining/Post-Reclamation
           f. References
                                        D-9
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                                                         Contents of Specific EIA Tools
        5. Determination of Significance
            a. Introduction
            b. Criteria for Significance
            c. Magnitude/Likelihood
            d. Confidence in Prediction Values
            e. Assumptions/Limitations
        6. Mitigation
            a. Introduction
            b. Reclamation Plan
            c. Categories of Mitigation
            d. Terrestrial Habitat
            e. Test Your Knowledge
        7. Documentation

 E. DECISION-MAKING

        1. Introduction
        2. Review Proposed Tradeoffs
        3. Identify Preferred Alternative
        4. Comparing Housing/Airstrip Options
        5. Record of Decision
        6. Status of Report

 F. POST-DECISION ANALYSIS

        1. Introduction
       2. Important Impacts
       3. Categories of Mitigation
       4. Monitoring Requirements
July 1998
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                                                         Contents of Specific EIA Tools
                    "Principles of Environmental Impact Assessment"

                                  Document Overview

The US EPA has developed a course and associated student text entitled "Principles of
Environmental Impact Assessment" that provides additional information valuable to reviewers.
The Principles of Environmental Impact Assessment text was prepared to help individuals
responsible for environmental protection and impact assessment in different countries, regions,
and localities design and implement programs of environmental impact assessment 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 environmental impact assessment for anyone
involved in development, redevelopment, and remedial planning, including government
officials, nongovernment officials, industry and academic leaders, environmental scientists and
engineers, and private citizens.

The focus of the text is on the internationally accepted principles that underlie sound
environmental impact assessment programs rather than on the specific tools or measures of
impact assessment. However, references to texts or manuals that discuss the specific
application of methodologies are given in Chapter 13 of this text.  The text is not designed to
provide comprehensive technical guidance in the use of environmental impact assessment tools
such as air quality modeling, water quality modeling, ecological community analysis, risk
assessment, or fiscal analyses.  In this Principles of Environmental Impact Assessment, such
methodologies are summarized in terms of the types of approaches available for the assessment
of environmental impacts.

      This text provides the following:         ;

      •   A characterization of the nature and importance of an environmental impact
          assessment program.                ;
      •   A framework for designing and developing environmental impact assessment
          strategies and programs.
      •   Key considerations in the environmental impact assessment process.
      •   A synopsis of general methods for assessing environmental impacts.
      •   Guidance for the preparation of environmental impact assessment (environmental
          impact assessment) reports.
      •   Examples of existing environmental impact assessment programs and major
          environmental impact assessment issues.
      •   Options for incorporating various elements into  a specific environmental impact
          assessment program.
      •   A list of resources that provide further information.
                                        D-ll
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                           APPENDIX E
                           ROAD MAPS

The Road Maps that appear throughout the text in Chapters 3 and 4 are pulled
             together in this Appendix for ease of reference.

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                                                   Road Maps
         ROAD MAP FOR OVERALL
ENVIRONMENTAL IMPACT ASSESSMENT
            DOCUMENT REVIEW
Review Table of Contents and Executive Summary

Scan and read the document several times

Take notes, write down questions

Go through key environmental impact assessment elements
-     Purpose and Need, Alternatives, Environmental Setting, Impact,
      Mitigation

Use checklists where appropriate

Review the logic and consistency of the document

Use a systematic approach to identify areas where the assessment is:
      Incomplete, inadequate
-     Significance unsupported/unclear/ignored
-     Lacks integration

Identify and adopt perspectives of all interested and affected parties

Compare document to other environmental impact assessments

Determine whether the document supports decision-making
                       E-l
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                                                            Road Maps
          ROAD MAP FOR SCOPING REVIEW

•     Scoping was conducted and documented

•     Potentially significant issues are identified for natural and human
      environments

•     Insignificant issues identified and their dismissal justified

•     Identified and considered the views of all interested and affected
      parties

•     Sufficient detail provided to define the spatial and temporal scope

•     Adequate geographic area considered for the scope

•     Omissions are not related to significant issues

•     Key issues are brought into focus	
                               E-2
July 1998

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                                                     Road Maps
ROAD MAP FOR PURPOSE AND NEED AND
           ALTERNATIVES REVIEW

Describes the purpose and need of the proposed project

Demonstrates how purpose and need would be met by the proposed
project

Adequately describes the proposed project
      Maps project site, surrounding land use, and natural features
      Who and what would benefit; who and what would be affected
      Phases; site preparation, construction, operation, and closure
      Time frames, including when proposed project begins and ends

Considers the full range of alternatives to meet purpose and need
      No action
      Alternative sites, designs, controls
      Structural vs non-structural
      Reallocation of social costs and benefits
      Reasonable, feasible
      Reflective of the range of choices
      Meet the purpose and need of the proposed project

Preferred alternative satisfies purpose and need better than alternatives
with less environmental impact
                         E-3
July 1998

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                                                            Road Maps
ROAD MAP FOR ENVIRONMENTAL SETTING REVIEW

  •    All relevant types of natural and human environmental issues are
       addressed

  •    Affected area or community is adequately and accurately defined

  •    Adequately map impact area and surrounding features

  •    Baseline is established to measure impact

  •    Appropriate information and data documented and used appropriately

  •    Information links back to project description, purpose and need,
       alternatives?

  •    Levels of detail are appropriate to significance

  •    Information and data is of acceptable quality and relevance?

  •    Section is internally consistent
                               E-4
July 1998

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                                                           Road Maps
ROAD MAP FOR ENVIRONMENTAL IMPACT REVIEW

 •     All natural and human (socioeconomic) environmental impacts are
       identified

 •     Types of impacts include primary, secondary, and cumulative

 •     Detail on impacts is balanced among reasonable and feasible
       alternatives                ,

 ซ     Both beneficial and adverse impacts are identified

 •     Potential impacts are identified for all phases of the proposed project

 ซ     Models, experts, and criteria accurately used to project the significance
       of impacts are valid for appropriate circumstances

 ซ     Data, information and key assumptions are representative, accurate,
       and current

 •     Appropriate criteria are used to characterize significance
                               E-5
July 1998

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                                                       Road Maps
  ROAD MAP FOR MITIGATION REVIEW
 Specific mitigation measures are proposed

 All significant adverse impacts are addressed by the mitigation plan

 Measures are proposed for:
      All types of impacts
      All phases of the proposed project
      All environment types

 Preferred mitigation measures at the top of the mitigation type
 hierarchy are considered
Mitigation measures are described in sufficient detail relative to the
significance of impact

Mitigation measures are:
      Technically and financially feasible with adequate financial and
      non-financial resources to implement the measures
      Socially and culturally acceptable

Implementation plans include schedules and interim milestones and
timing is consistent with other factors presented in the assessment of
impact

Responsible parties are identified  and committed to implementation
                        E-6
July 1998

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                                                         Road Maps
ROAD MAP FOR DRAFT ENVIRONMENTAL IMPACT
                 ASSESSMENT REVIEW

  Establish a management approach:
       Establish lead reviewer
       Assign roles
       Establish a schedule
       Conduct Review

  Consolidate reviewers' comments:
       Identify most significant issues
       Determine the significance of each comment
       Establish common threads
       Resolve any discrepancies

  Draft a comment letter:
       Maintain neutrality, objectivity and professionalism
       Provide clear and concise comments

  Anticipate and Respond to Public Comment
                             E-7
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                                                         Road Maps
ROAD MAP FOR THE COMMUNICATION LETTER
State bottom line including major recommendations up front and clearly

Describe proposed project context

If the purpose and need of the proposed project is in question, develop the
link to the environmental concerns
Distinguish what is mandatory, what is significant

Provide a description of the substantive and/or procedural concerns

Demonstrate sensitivity to interests and affected community

Provide recommendations for addressing the concerns
                            E-8
July 1998

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                                                        Road Maps
                ROAD MAP FOR FINAL   .,
ENVIRONMENTAL IMPACT ASSESSMENT REVIEW

  Establish a management approach

 Determine if basic assumptions and information are the same for draft and
 final

 Assess impacts of any changes on alternatives, impacts and proposed
 mitigation

 Verify that comments were acknowledged and addressed

 Review the relationship and consistency among responses to individual
 comments

 Consolidate comments and prepare the final comment letter

 Determine whether responses change fundamental reviewer findings:
       Acceptability of environmental impact
       Needed mitigation
       Adequacy of environmental impact assessment document and process
       Who needs to be involved and consulted

 Decide actions to increase chance of correcting remaining deficiencies

 Anticipate use by decision maker

 Anticipate use to establish mitigation requirements

 If appropriate, prepare final comment letter	
                             E-9
July 1998

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                                                             Road Maps
ROAD MAP FOR RECORD OF DECISION PREPARATION

    Re-state the purpose and need

    Support preferred alternative and justify
          Meets purpose and need
          Either preferred environmentally or meets purpose and need better
          than other alternatives
          Meets legal requirements

    Demonstrate all potentially adverse impacts from the selected alternative
    were lully considered

    Demonstrate benefits of proposed action outweigh adverse impacts

    Demonstrate that implementation of the proposed project will be
    environmentally acceptable

    Identify mitigation and continuing responsibilities
                               E-10
July 1998

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