United States
Environmental Pr
Agency
Pectoral Activities
(A-107)
EPA 300-8-93-007
September 1993
Sourcebook For The
Environmental Assessment (EA)
I N I T I A T I O N
purpose & need
environmental information
issues
interim alternatives
no known
impacts
impacts
unknown
significant
impacts
SCREENING
EXCLUSIONS
* existing information
* categories
* criteria
DECISIONMAKING
* issue EA decision
document
* notify public
INITIAL EA
* public/government
views
* tentative issues
* other alternatives
EXCLUDED
FROM EA?
SIGNIFICANT
IMPACTS ?
Independent
Review
'completeness
* adequacy
! REALM OF
I*—PUBLIC
PARTICIPATION
DETAILED EA
* public/government
notification
* interdisciplinary
team
* scoping meetings
* significant issues
* other alternatives
DRAFT EIA
* potential impacts
of alternatives
* proposed mitigation
* public/govt. review
and comment
FINAL EIA
preferred
altemative(s)
address draft EIA
comments & new
issues/information
ACCEPTABLE
No X.IMPACTS?
Yes
implement
project
POST DECISION ANALYSIS
monitoring
project modification
application to future actions
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SOURCEBOOK FOR THE
ENVIRONMENTAL ASSESSMENT (EA) PROCESS
EPA Contract No. DW 89935209-01-0
September 1993
Submitted to:
John Cerba
U. S. Environmental Protection Agency
Office of Federal Activities
401 M Street, SW
Washington, DC 20460
Submitted by:
Lorene L. Sigal
Environmental Sciences Division
Oak Ridge National Laboratory
Oak Ridge, TN 37831-6036
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11
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SOURCEBOOK FOR THE ENVIRONMENTAL ASSESSMENT (EA) PROCESS
TABLE OF CONTENTS
PREFACE
ACRONYMS
PART A: INTRODUCTION
Chapter 1. EVOLUTION OF ENVIRONMENTAL ASSESSMENT ... 1-1
Attachment
l.A Emerging Issues - Sustainable Development
PART B: THE ENVIRONMENTAL ASSESSMENT PROCESS
Attachment
Environmental Assessment Process
Chapter 2. INITIATION 2-1
2.1 Identification of Issues 2-13
22 Generation of Alternatives 2-17
Attachments
2.A Defining the Purpose of and Need for a Proposed Action
2.B Environmental Impact Checklists
2.C The Interdisciplinary EA Team
2.D Planning Records
Chapter 3. SCOPING 3-1
Attachment
3.A CEQ Memorandum: Scoping Guidance
Chapter 4. ASSESSMENT 4-1
4.1 Affected Environments 4-3
Attachment
4.A Sources of Environmental Data
111
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Impact Identification 4-15
Attachments
4.B Computer-Aided Environmental Assessment
43 Impact Analysis and Prediction 4-29
Professional judgement 4-31
Expert systems 4-32
Analog studies 4-33
Impact matrices 4-33
Field and laboratory tests and experiments 4-35
Predictive models 4-36
Specialized analysis and prediction methods 4-42
Habitat evaluation procedures (HEP)
Geographic information systems (CIS)
Ecological risk assessment
Human health risk assessment
Economic-demographic assessment models
Attachments
4.C Summary of Fate Models Used in Environmental Assessment
4.D Problems Associated with Amalgamation of Data
4.E A Case Study for a Geographic Information System
4.4 Determination of Significance 4-63
Attachments
4.F Definitions for Describing Significance of Impacts
4.G Determining Impact Significance in EIA: A Review of
24 Methodologies
4.5 Mitigation 4-71
Attachment
4.H Mitigation Measures
4.6 Documentation 4-79
Attachments
4.1 An unreadable EIS is an Environmental Hazard
4J The U.S. EPA Rating System Criteria for Review
of Draft EISs
IV
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Chapter 5. DECISIONMAKING 5-1
Attachment
5.A Indices of Environmental Quality
Chapter 6. POST-DECISION ANALYSIS AND FOLLOW-UP 6-1
Attachment
6.A Negotiating a Monitoring Program
PART C: CASE STUDIES
Case Study Outline
Listing of Case Studies
Case Study on the Application of EIA Methodologies to the
Phoenix Pulp Mill Project hi Thailand
PART D: SELECTED ENVIRONMENTAL LAWS AND REGULATIONS
Facts About the National Environmental Policy Act
CEQ Regulations for Implementing NEPA
CEQ 40 Most Asked Questions Concerning the NEPA
Regulations
Summaries of Related Environmental Laws
States with Environmental Policy Acts
States with Limited Environmental Review Requirements
Established by Statute, Executive Order, or Other
Administrative Directives
PART E: GLOSSARY
PART F: COMPUTER SOFTWARE SUPPLEMENT FOR THE
ENVIRONMENTAL ASSESSMENT RESOURCE GUIDE
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vi
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PREFACE
The United States (U.S.) Environmental Protection Agency (EPA) is
increasingly being asked for information on the environmental assessment process
(EA) by foreign governments, states, localities and others. This reflects U. S.
experience in this area, the increasing number of EPA programs (e.g., the State
Revolving Fund) which have encouraged states to have expertise in carrying out
EA, and a worldwide interest in the EA process. The Office of Federal
Activities, which has responsibility for environmental assessment in EPA under
the National Environmental Policy Act (NEPA), decided to develop a sourcebook
on EA in order to meet this increased demand for information.
Li the sourcebook, EA is used in its broadest sense, that is, as a formal
but flexible process (not just a document) for examining proposed activities early
in planning for their potential to impact the environment. The term
environmental impact assessment (EIA) is .used to describe the documentation
resulting from the EA process.
The goals of EA are the same regardless of the level of decisionmaking
(i.e., project, program or policy). These include the following:
better decisionmaking,
public involvement,
analysis of viable alternatives,
prediction of impacts,
mitigation of impacts, and
follow-up or monitoring and feedback.
A timely interactive EA can:
• minimize adverse impacts on the environment,
• reduce delays in project development,
• reduce cost of the selected alternative,
• promote interagency as well as public involvement and
cooperation, and
• promote community acceptance.
Although the sourcebook reflects the U. S. experience in implementing
NEPA (and some major international variations) the EA process is applicable to
any group charged with the responsibility of providing adequate environmental
information to decisionmakers for projects and programs that may directly or
indirectly impact the environment. These include private applicants or other non-
government entities who are required to provide information or reports to
government for grants or permits; proponents of projects and managers and
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decisionmakers who are responsible for integrating EA with early planning and
the decisionmaking process; and proponents of projects and consultants who are
responsible for preparation of EA documents. In addition, the sourcebook may
be used by reviewers of environmental documents and decisionmakers to evaluate
if environmental effects and values are appropriately identified and presented so
that they can be integrated with economic and technical analyses. The
sourcebook also includes specific and technical direction in certain areas,
particularly document preparation. For these reasons, it is also valuable as a
training guide for new employees. However, it is important that users realize that
the sourcebook is a guide only and does not address all of the complexities or
questions raised by the EA process.
Because the generic elements of the EA process are emphasized, the
sourcebook is of use to federal, state, tribal and local agencies, foreign countries,
and non-governmental organizations. However, in the U.S., NEPA applies only
to federal activities including financial assistance, grants, and permitting. In
contrast to other countries, the costs of EA in the U.S. are usually borne by the
sponsoring federal agency.
The focus of this sourcebook is generally on EA for project-level decisions
because in practice this is where agencies expend most of their EA resources.
Historically, there is less experience with the application of EA to policy-and
program-level decisionmaking. In theory, however, the EA process is applicable
to any level of decisionmaking although the methodologies and the data for broad
spectrum analyses are often lacking. Nevertheless, interest is growing in EA of
policies as governments realize that their policy-level decisions require assessment
of global and international environmental issues (e.g., sustainable development,
global warming, biodiversity).
The sourcebook is organized around the major activities that are required
for successful EA. These include: initiation, scoping, assessment, decision
making, and post-decision analysis. In each of these sections there is a
description of the activity followed by subsections that describe the needs, tools,
issues, linkages, and references:
• The needs subsections highlight planning, information/data, and
resources;
• The tools subsections describe methods and techniques that have
proven useful;
• The issues subsections identify important points and concerns and
areas where conceptual and analytical uncertainties exist;
• The linkages subsections call attention to the connectedness of EA
activities;
viu
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• The references subsections provide citations to published
information found to be particularly useful.
In addition, there are attachments to each section. These attachments provide
information that is often not readily available, particularly to those in foreign
countries or those just starting EA programs.
The topics addressed in the sourcebook are mostly broad in scope and
inclusive of only some of the many aspects of EA; however, they represent the
important aspects of the impact assessment process. It is important for users of
the sourcebook to remember that the level of EA should reflect the magnitude of
the proposed activity; its potential for environmental impact; and the prevailing
environmental policy, regulatory structure, and institutional capabilities.
In the U.S., during the EA process, other environmental review and
consultation requirements (e.g., endangered and threatened species, historic and
cultural resources) are frequently integrated with the requirements of NEPA.
This reduces duplicative effort and the potential for delays. The requirements of
such related laws are not addressed in this sourcebook, but brief summaries of the
laws are included in Part D. Also included in Part D are the Council on
Environmental Quality (CEQ) Regulations for Implementing the Procedural
Provisions of the National Environmental Policy Act, the CEQ responses to the
forty most asked questions concerning the NEPA regulations, and state
requirements for environmental assessment.
The sourcebook is planned to be an easy-to-use reference manual, hence
there are some overlaps and repetitions. Its format is designed to facilitate
frequent updating or additions of new material. Part F is a computer software
supplement to this sourcebook. Comments are invited from users on ways that
the sourcebook can better meet their needs.
As required, permission to use copyrighted materials has been received
from the following publishers: Academic Press (Attachments 4.G, 4.H); Elsevier
Science Publishing Company, Inc. (Attachments 4.B, 4.D, 5.A, and Figure
4.3-3); Environmental Law (Attachment 2.A); Environmental Law Institute
(Attachment 2.A); International Association for Impact Assessment (Attachment
6. A); Lewis Publishers (Attachment 4.C, Figure 4.3-2); National Association of
Environmental Professionals (Attachments l.A, 4.E, 4.1); Shipley Associates
(Attachment 2.C); The World Bank (Attachment 2.B, computer discs); Tycooly
Publishing (Part C); and Unwin Hyman, Ltd. (Figure 4.3-4).
IX
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Acknowledgments
The sourcebook is the result of a contract between the EPA Office of
Federal Activities and Oak Ridge National Laboratory Environmental Sciences
Division. Experts representing most aspects of environmental assessment
participated in a workshop on December 11-12, 1991 at Oak Ridge National
Laboratory to plan the format and content of the sourcebook. We thank all of
those participants, who are listed below, for their ideas, suggestions, and
continued interest in the project.
Ronald E. Bass
Jones & Stokes Associates, Inc.
2600V Street
Suite 100
Sacramento, CA 95818-1914
Robert S. Boulden
Environment Canada
15th Floor, Place Vincent Massey
Ottawa, Ontario
Canada K1A OH3
Robert G. Connelly
Federal Environmental Assessment Review Office
13th Floor, Fontaine Bldg.
200 Sacre-Coeur Bldv.
Hull, Quebec
K1A OH3
Robert Goodland
Environment Dept., Room S-5035
The World Bank
1818 H Street, NW
Washington, DC 20433
Dale W. Lucent
U.S. Environmental Protection Agency
Region V
77 West Jackson Boulevard (WCP-15J)
Chicago, IL 60604
Karen Raymond
Environmental Resourced Limited
Eaton House
Wallbook Court
North Hinksey Lane
Oxford OX2 OQS
Barry Sadler
Canadian Environmental Assessment Research
Council
1631 Barksdale Drive
Victoria, B.C. Canada
V8N5A8
Gordon E. Beanlands
Dalhousi University School for Resources and
Environmental studies
1318 Robie Street
Halifax, Novia Scotia
B3H3E2
Larry W. Canter
Environmental and Groundwatcr List.
University of Oklahoma
200 Felgar Street, Room 127
Norman, OK 73019
John Gcrba
U.S. Environmental Protection Agency
A-104
401 M Street, SW
Washington, DC 20460
F. Larry Leistritz
Department of Agricultural Economics
North Dakota State University
Fargo, ND 58105
Joe Montgomery
U.S. Environmental Protection Agency
A-104
401 M Street, SW
Washington, DC 20460
Robert M. Reed
Oak Ridge National Laboratory
Building 4500N, Mail Stop 6200
P.O. Box 2008
Oak Ridge, TN 37831-6200
Dean L. Shumway
FERC
825 North Capitol Street, NE (810 UCP)
Room 1027
Washington, DC 20426
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Lorene L. Sigal
Oak Ridge National Laboratory
Building 1505, Mail Stop 6036
P.O. Box 2008
Oak Ridge, TN 37831-6036
Glenn Suter
Oak Ridge National Laboratory
Building 1505, Mail Stop 6038
P.O. Box 2008
Oak Ridge, TN 37831-6038
Rob A. A. Verheem
AIAT 174222 XI B.2
Rue de Laloi
B1049 Brussels, Belgium
Henyk Weitzenfeld
Pan American Center for Human Ecology and
Health
Apartado Postal 37-473
06696 Mexico DS
Mexico
Rhey M. Solomon
Environmental Coordination Staff
USDA Forest
P.O. Box 96090
Washington, DC 20090^090
Robert Turnbull
Center for Environmental Management and
Planning
23 St. Machar Drive
Aberdeen AB2 1RY
Scotland, UK
Ron Webster
Department of the Army
Construction Engineering Research Lab
P.O. Box 9005
Champaign, IL 61826-9005
Lee Wilson
Lee Wilson and Associates, Inc.
P.O. Box 931
Santa Fe, NM 87504
XI
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Xll
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ACRONYMS
AHPA Archeological and Historic Preservation Act
BLM Bureau of Land Management (U.S.)
CBA coat-benefit analysis
CBRA Coastal Barrier Resources Act
CBRS Coastal Barrier Resources System
CEQ Council on Environmental Quality
CFR Code of Federal Regulations
COE Corps of Engineers (U.S. Army)
CZMA Coastal Zone Management Act
DOE U.S. Department of Energy
e.g. for example
EA environmental assessment (process)
EC European Communities
ECE United Nations Economic Commission for Europe
EEC European Economic Community
EIA environmental impact assessment (document)
EIS environmental impact statement
EO Executive Order
EPA Environmental Protection Agency
ESA Endangered Species Act
et al. and others
et seq. and the following ones
FEARO Federal Environmental Assessment Review Office (Canada)
FEMA Federal Emergency Management Agency (U.S.; for Flood Hazard Boundary Maps)
FGDC Federal Geographic Data Committee
FNSI finding of no significant impact
FPPA Farmland Protection Policy Act
FR Federal Register
FWCA Fish and Wildlife Coordination Act
FWS Fish and Wildlife Service (U.S.)
CIS geographic information system
HEP habitat evaluation procedure
HUD Department of Housing and Urban Development (U.S.)
i.e. that is
NEPA National Environmental Policy Act
NGO non-governmental organization
NHPA National Historic Preservation Act
P.L. Public Law
PDA post-decision analysis
ROD record of decision
SCS Soil Conservation Service (U.S.)
SEA strategic environmental assessment
U.S. DOI United States Department of Interior
U.S. United States
U.S.C. United States Code
USGS U.S. Geological Survey
WA Wilderness Act
WSRA Wild and Scenic Rivers Act
Xlll
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XIV
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PART A
INTRODUCTION
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PART A
INTRODUCTION
A-l
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A-2
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CHAPTER 1
EVOLUTION OF ENVIRONMENTAL ASSESSMENT
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CHAPTER 1
EVOLUTION OF ENVIRONMENTAL ASSESSMENT
In response to a growing awareness of environmental issues in the United
States in the 1960s, the public called on Congress to enact an environmental
policy with comprehensive goals that transcended the separate pollution and
resource management laws of the time. The product of this growing
environmental consciousness was the National Environmental Policy Act (NEPA),
passed by Congress on December 22, 1969 and signed into law on January 1,
1970 (Part D). The statute is the foundation for consideration of environmental
factors in federal decisionmaldng. Moreover, it provides for citizen involvement
and the opportunity for environmental litigation (Bear 1989).
NEPA ushered in a new era of environmental awareness in the United
States by requiring federal agencies to include environmental considerations early
in their plans and activities. And it created the environmental impact statement
for assessing the likely effects (both beneficial and adverse) of projects with
significant environmental impacts that agencies intend to build, finance, or
permit. NEPA also provided the interested and affected public with one of its
most important tools — the right to bring a case to court. Litigation during the
late 1960s and 1970s established that noneconomic interests (i.e., aesthetic,
conservational, recreational) were sufficient to establish "standing to sue". Over
time, NEPA litigation has declined because there are fewer threshold issues and
federal agencies have largely institutionalized NEPA and the results of the early
landmark cases in their implementing regulations. Although the effectiveness of
NEPA is often questioned, there is growing recognition that NEPA has made a
significant difference in federal agency decisionmaking (Wandesford-Smith and
Kerbavaz 1988).
In the more than two decades since the passage of NEPA, nations around
the world, international lending agencies, and multilateral development assistance
organizations have initiated similar requirements for assessing and managing
impacts upon the environment of their development activities (see Chapters 10 -
14,16 and 17 of Wathern 1988). Nevertheless, in Europe and elsewhere, the EA
process is essentially reactive (i.e., applied after a decision is made).
Requirements for EA, if any, are found in existing statutes and regulations written
to address pollution control, safety, and land-use planning. It was not until
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publication in 1985 of the Commission of the European Communities' directive
on EIA for projects that, at least for the member countries, a proactive approach
to environmental assessment was mandated. However, the directive only
specifies binding policy objectives; the means for implementing the conditions of
the directive are left to each member country. Thus, a wide range of approaches
have been adopted (Wathem 1988), mostly set within the context of existing
national planning law.
Historically, the emphasis in EA has been on project-level activities in
spite of the fact that EA legislation in some countries (e.g., United States, The
Netherlands, Canada) includes application to policies, plans, and programs.
However, there is growing recognition that EA should reach beyond projects to
broader governmental initiatives. In the United States, there is evidence that the
government is applying EA to programmatic decisions (e.g., the Department of
Army programmatic EIS for the Chemical Stockpile Disposal Program; the
Department of Energy (DOE) programmatic EIS for the Nuclear Weapons
Complex Reconfiguration; and the DOE programmatic EIS for Environmental
Restoration and Waste Management). Following programmatic decisionmaking,
more focused documents are prepared for specific projects within a program.
The secondary documents are tiered to the programmatic document; they do not
duplicate material found in the programmatic document but summarize such
information and incorporate it by reference.
In Europe, interest in EA for policies, plans, and programs is increasing
(Therivel et al. 1992). Under the auspices of the Senior Advisors on
Environmental and Water Problems of the United Nations Economic Commission
for Europe (ECE) and the sponsorship of the United States Environmental
Protection Agency, an international task force studied the application of the
principles of EA to policies, plans, and programs. The task force agreed that the
principles of EA as applied to projects are appropriate for policies, plans, and
programs (ECE 1992). These include early initiation of assessment, scoping,
independent review, public participation, formal documentation, use in
decisionmaking, and post-decision analysis. However, the task force recognized
that timing and confidentiality might limit public involvement, independent
review, and scoping for policy-level decisionmaking. In order to enhance the
quality of information used in EA for policies, plans, and programs, the task
force agreed that efforts should be pursued to adapt and develop methodologies
and databases to promote exchange of information gained from ongoing
experiences. In addition, the Commission of the European Communities is
currently working on a new directive for strategic environmental assessment
(SEA), as it is called, for policies, plans, and programs.
An EA system is easiest to apply within a single jurisdiction. However,
there is an increasing need to extend EA to environmental issues that are regional,
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international, and sometimes global in scope. Burton et al. (1983) identify two
classes of problems associated with international EA:
• the action takes place in one or a few adjacent countries but the
impacts can be widespread (e.g., acid rain, nuclear power); and
• the action takes place in many countries and the impacts may be
distributed globally (e.g., stratospheric ozone depletion, CO2 -
induced climate change).
In the first case, conventional EA may be appropriate. For the second,
new procedures are needed that address state sovereignty, acceptable
administrative procedures for EA at the international level, and the determination
of significance. The 1991ECE Convention on Environmental Impact Assessment
in a Transboundary Context (signed by 28 countries, including the U.S., and the
European Community) obliges signatories to assess the environmental impacts of
certain listed activities likely to cause significant adverse transboundary effects.
Members are currently working on issues associated with transboundary EA
among which are: identification of parameters to determine which activities
require EA; criteria for determining the significance of transboundary impacts;
and standardization of methods for prediction of environmental impacts.
Obviously, the nature of EA will differ at the various levels of
decisionmaking. At the policy level, EA will be more general and less certain.
There will be difficulties associated with availability and/or existence of
information for assessment and less precise predictions about the consequences
of change. Nevertheless, these are not seen as insurmountable problems, because
decisionmakers may have lower expectations regarding precision at the policy
level (Wathern 1988). The longer lead time associated with policy development
should allow feedback between data generation and impact prediction, so that the
environmental effects of policies can be more precisely described and the impacts
more narrowly defined over time (Wathern 1988).
Currently with the growing interest in policy-level EA, there is increasing
recognition that EA should be used to assess the net contribution of a project,
program, or policy to sustainable development (Jacobs and Sadler 1990). The
1987 report of the Brundtland Commission, Our Common Future, sounded an
urgent call for global environmental strategies for achieving sustainable
development based on identification of long-term environmental issues and
definition of appropriate efforts to protect and enhance the environment. It went
on to state that "The ability to choose policy paths that are sustainable requires
that the ecological dimensions of policy be considered at the same time as the
economic, trade, energy, agricultural, industrial, and other dimensions—on the
same agendas and in "the same national and international institutions."
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A strong case can be made for the use of EA to push decisionmakers
along the path of sustainability (Attachment l.A). There is a clear indication that
environmental advisors working in bilateral and multilateral agencies see the
potential for modification of existing EA practices to encompass social impact
assessment, participatory appraisal procedures, and environmental economics.
However, moving from conventional EA to a wider more comprehensive
approach encompassing environmental/biological, social and economic elements
on an equal basis for developed and developing countries will require time,
cooperation, and agreement within and among governments. It has been
suggested that EA procedures be developed for issues. For example, focusing on
a selected key problem with significant social and economic dimensions as well
as environmental implications such as hydropower dams with their associated
irrigation schemes, displaced people and refuges. Such an issue - based strategy
facilitates an interactive approach, building on lessons learned, and provides a
means to test and demonstrate the utility of a modified approach to EA.
The World Bank summarizes the basic operational principles of
sustainability as output and input rules:
• output guide. Waste emissions from a project should be within the
assimilative capacity of the local environment to absorb without
unacceptable degradation of its future waste absorptive capacity or
other important services.
• input guide. Harvest rates of renewable resources should be
within the regenerative capacity of the natural system that produces
them. Depletion rates of nonrenewable resources should be equal
to the rate at which renewable substitutes are developed by human
invention and investment.
Although not addressed directly, the concept of sustainability has been
applied to carrying capacity studies in some 20 EAs prepared for World Bank
projects (e.g., for rangeland and power projects; Attachment l.A). For most
animal species, carrying capacity is defined as the maximum population that can
be supported indefinitely in a given habitat without permanently impairing the
productivity of the ecosystem(s) upon which that population is dependent (Rees
1988). For human society, regional carrying capacity can be defined as the
maximum rate of resource consumption and waste discharge that can be sustained
indefinitely in a defined planning region without progressively impairing
bioproductivity and ecological integrity. Carpenter (1990) presents some practical
problems in measuring sustainability and describes ongoing studies that could lead
to better measurement of sustainability (Attachment l.A).
Rees (1988) notes that while the notion of carrying capacity is
conceptually simple, various factors make it difficult to put into practice (e.g.,
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interregional trade lessens the importer's concern for understanding the carrying
capacity of the exporter; cumulative demands for consumption and production
must be assessed). Nevertheless, he suggests four initial steps in recreating EA
to serve a viable role in sustainable development. They are as follows:
• Extend the scope of EA-like activities to cover the full range of
ecologically and socially relevant public and private sector
proposals and actions.
• Create a variety of institutional frameworks for EA adapted to the
increased diversity of initiatives and activities to be assessed.
These mechanisms should be equitable, reduce conflict of interest,
and promote political accountability.
• Develop methods for EA that reflect the discontinuous temporal
and spatial dynamics and the resilient properties of ecosystems.
This requires a balance between predicting the known and adapting
socially and politically to the uncertain and unknown in the natural
world.
• Implement the foregoing as part of a broader planning and
decision-making framework (e.g., community development
planning, regional planning) that effectively recognizes ecological
functions as limiting factors.
It is also recognized that indicators (i.e., measures) are needed for analysis
of sustainability and to guide policymakers in their evaluation of environmental
quality (Attachment l.A). Such indicators will be vital in the development and
monitoring of national sustainable development plans. Consider economic
planning without GNP or social planning without life expectancy and rates of
fertility, yet environmental planning has no comparable measures. New
indicators are needed to enable the integration of environmental, economic and
social concerns for sustainable development planning.
A mandate for sustainability in environmental planning is found in Section
101 of NEPA (Part D). It states that the ". . . Federal Government . . . will
foster and promote the general welfare, to create and maintain conditions under
which man and nature can exist in productive harmony, and fulfill the social,
economic, and other requirements of present and future generations of
Americans." Furthermore, the regulations that implement NEPA require analyses
that address the tenets of sustainability (e.g., the relationship between short-term
uses of man's environment and the maintenance and enhancement of long-term
productivity, and any irreversible or irretrievable commitments of resources).
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The challenge for the future is in how well we use the tools we have to fulfill our
responsibilities as trustees of the environment for succeeding generations.
REFERENCES
Bear, D. 1989. NEPA at 19: a primer on an "old" law with solutions to new
problems. Environmental Law Reporter 19 ERL 10060—10069.
Carpenter, R. A. 1990. Biophysical measurement of sustainable development.
The Environmental Professional 12:356-359.
Economic Commission for Europe (ECE). 1992. Application of Environmental
Impact Assessment Principles to Policies, Plans and Programmes.
ECE/ENVWA/27. United Nations, New York.
Jacobs, P. and B. Sadler (editors). 1990. Sustainable Development and
Environmental Assessment: Perspectives on Planning for a Common
Future. Canadian Environmental Assessment Research Council, 13th
Floor, Fontaine Building, 200 Sacre"-Couer Blvd., Hull, Quebec. K1A
OH3.
Rees, W. E. 1988. A role for environmental assessment in achieving sustainable
development. Environmental Impact Assessment Review 8:273-291.
Rees, W. E. 1990. Economics, ecology, and the role of environmental
assessment in achieving sustainable development. In: Sustainable
Development and Environmental Assessment: Perspectives on Planning
for a Common Future (eds., P. Jacobs and B. Sadler), Canadian
Environmental Assessment Research Council, 13th Floor, Fontaine
Building, 200 Sacr6-Couer Blvd., Hull, Quebec. K1A OH3.
Therivel, R., E. Wilson, S. Thompson, D. Kearney, and D. Pritchard. 1992.
Strategic Environmental Assessment. Earthscan Publications Ltd.,
London. 181 pp.
Wandesforde-Smith, G. and J. Kerbavaz. 1988. The co-evolution of politics and
policy: elections, enterpreneurship and EIA in the United States. In:
Environmental Impact Assessment (ed., P. Wathern), Unwin Hyman,
Boston.
Wathern, P. 1988. The EIA directive of the European Community. In:
Environmental Impact Assessment (ed., P. Wathern), Unwin Hyman,
Boston.
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Westman, W. E. 1985. Ecology, Impact Assessment, and Environmental
Planning. John Wiley & Sons, New York. 532 pp.
World Commission on Environment and Development. 1987. Our Common
Future. Oxford University Press, New York. 400 pp.
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ATTACHMENT l.A
EMERGING ISSUES - SUSTAINABLE DEVELOPMENT
• Introduction: Emerging issues - Sustainable development
• Sustainability and Environmental Assessment. (Source: Goodland, R., and H. Daly.
1992. Three steps toward global environmental Sustainability. World Development
2:64-71)
• Carpenter, R. A. 1990. Biophysical Measurement of Sustainable Development. The
Environmental Professional 12:356-359.
References listed below (not attached) are found in the Abstracts and Invited Papers of
the Twelfth Annual Meeting of the International Association for Impact Assessment,
"Industrial and Third World Environmental Assessment: The Urgent Transition to
Sustainability". August 19-22, 1992. The World Bank, Washington, D.C.
— Mikesell, R. F. Environmental assessment and Sustainability at the project and
program level.
— Dalai-Clayton, B. Modified EIA and indicators of Sustainability: first steps
toward Sustainability analysis.
— Goodland, R., H. Daly, and S. El Serafy. The urgent need for environmental
assessment and environmental accounting for Sustainability.
l.A-1
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l.A-2
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Introduction: Emerging Issues • Sustainable Development
It is well recognized that environmental indicators of sustainability are needed to capture
trends in ways that policymakers and others can grasp immediately (Mikesell 1992, Dalai-
Clayton 1992, Goodland et al. 1992). Such indicators would be tools in assessment of
sustainability and monitoring of national sustainable development plans; guide policymakers in
their evaluation of environmental quality; and enable integration of environmental, economic and
social concerns for sustainable development planning. The relative merits of multiple
environmental indicators and a single or "collapsed" indicator are being debated. Nevertheless,
there is general agreement that indicators must be simple, practical, and based on data that are
readily available in common data sources.
The following tables [excerpted from Dalai - Clayton (1992)] show suggested quantitative
(Table l.A-1) and qualitative (Table l.A-2) environmental and economic indicators of
development. It is suggested (Dalai-Clayton 1992) that the qualitative indicators of sustainability
are 1) targets for sustainability and less post-hoc than the quantitative indicators, and 2) more
conducive to participatory monitoring by citizen groups. On the other hand, they are probably
less useful for integrating changes in the natural resource base in gross national product
accounts. The utility of indicators is yet to be tested and it may be that some combination of
qualitative and quantitative measures will provide the needed insight to environmental
sustainability.
Researchers are also actively evaluating the application of sustainability criteria at various
levels of decisionmaking (i.e., policy, program, and project) and various spheres of interest
(i.e., global, national, regional and local) (Goodland and Daly 1992).
In addition to debate on what are the appropriate indicators for sustainable development,
Carpenter (1990; see attached) discusses uncertainties associated with biophysical measurement
and the lack of understanding of ecosystem processes that hamper planning for environmental
sustainability. Such uncertainties (e.g., natural variation, succession, reversibility, threshold
values) often result in arbitrary management strategies that either overconserve or overexploit
natural resources. Nevertheless, Carpenter (1990) sees sustainable development as an
experiment, with incremental advances, midcourse correction, and a constant supply of
monitoring data.
l.A-3
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Table l.A-1. Some Indicators of Sustainable Development.
(Excerpt from Dalai-Clayton 1992)
THE USE OF ENERGY AND MATERIAL
Per capita resources consumption, for • given standard of living, ii dropping-
The proportion of non-renewable energy uaage in primary production ia diminiabing, while renewable source*, such as solar or human
energy, are increasing: and sectors using non-renewable forms of energy are investing significantly to develop and apply technologies
that will use renewable forms.
Passenger kilometers travelled by public transport are increasing in proportion to those travelled by private motorized transport.
There is a progressive increase in both official incentives to use renewable energy and disincentives to use nonienewable forms.
There is an increasingly free flow of technology, especially to poor countries.
ECOLOGICAL PROCESSES & BIOLOGICAL WEALTH
Development activities seek to maintain ecological processes (soil fertility, waste assimilation, and water and nutrient cycling) and not
to exceed the capacity of these processes.
Development increasingly depends upon and conserves a growing range of genetic material, not only the different species but the
varieties within species.
Renewable resources are increasingly used and harvested at rates within their capacity for renewal.
More and more areas of high value for their irreplaceable environmental services are not only being set aside, but are being effectively
managed, with secure funding.
POLICY, ECONOMICS & INSTITUTIONS
Economies - especially those that depend upon high-volume natural resources data - are diversifying, especially towards high-value
information and service industries.
There are growing numbers of formal mechanisms to integrate environmental and development concerns, and to insert environmental
values in prevailing systems of economic policy, planning and accounting.
More accurate and representative economic indicators are being introduced to measure sustainable development, so that the currently
dominant concerns of consumption, savings, investment and government expenditures are increasingly joined by measures of natural
resources productivity and scarcity.
More methods are being introduced for valuing use by future generations, for comparing such use to today's needs and for making
equitable trade-offs between generations.
Flows of resources to and from a given country are increasingly stable and equitable, and do not result in severe net depletion of the
national resource base.
Both the incidence and the effects of 'boom and bust* are diminishing.
There are both regulatory measures that ensure that resource limits are not exceeded, '«nd enabling measures that encourage voluntary
improvements in technology to make more sustainable use of resources within those limits.
Environmental monitoring is regularly and effectively carried out, and both policies and operations are adjusted to suit.
Military budgets are decreasing in relation to budgets for work to ensure environmental security and sustainable development.
l.A-4
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Table l.A-1. continued
SOCIETY & CULTURE
The notion of resource limits, and the need for sustainability in production and livelihood systems, is increasingly
prevalent in a society's values, embodied in its constitutions and inherent in its education systems.
The community is becoming more diverse in terms of skills and enterprises, and yet remains coherent as a community.
There is a growing body of commonly held knowledge and available technology for maintaining a good quality of life
through sustainable activities.
There is a tendency towards full employment, good job security and household stability.
Increasing numbers of people have access to land adequate for sustaining good nutrition and shelter for their families
and/or sdequate, reliable incomes to pay for these necessities.
The costs and benefits of resource use and environmental conservation are more equitably distributed: consumers
increasingly choose to pay for goods and services that are resource-efficient and minimize environmental degradation.
Conflicts over land and resource rights are diminishing.
People who once relied upon unsustainable activities for their livelihood are being supported in their transition to
sustainable activities.
Development is increasing people's control over their lives, the range of choices open to them and the knowledge to
make the right choices: it is compatible with the culture and values of the people affected by it, and contributes to
community identity.
(Source: Holmberg, J., S. Bass, and L. Timberlake. 1991. Defending the Future: A Guide to Sustainable Development.
Earthscan Publications Ltd., London)
l.A-5
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Table l.A-2. Some Environmental and Economic Indicators of Development. (Excerpt from Dalai-Clayton 1992)
Countries
Algeria
Botswana
BracD
Chma
Costa Rica
FttDCO
Haiti
India
f---..!,^
swfamtSM
Mexico
Ntfcni
Peru
DataaMhJ*
KWaUMiv
Ssu.Anbk
Sier. Leone
Spun
Sweden
Thailand
USA
Zimbabwe
1985-90
Popuhtioa
Oiuwlh Rite
(*)
3.12
3.51
2.07
1.39
2.64
0.36
1.88
2.0S
1.52
2.20
3.43
2.51
3.40
3.96
2.49
0.38
(0.03)
1.53
0.82
3.15
1985-89
GNP Growth
Rate(»)
1.7
11.4
3.9
7.9
4.6
3.2
(0.6)
5.8
5.3
0.9
2.9
(0.2)
(0.4)
1.5
2.3
5.3
2.4
10.2
3.3
3.6
1991
nil in mi
Development
Index {•)
0.490
0.524
0.759
0.614
0.876
0.971
0.296
0.308
0.761
0.838
0.242
0.644
0.213
0.697
0.048
0.951
0.982
0.713
0.976
0.413
1989
Energy
Consumption (bj
(gifajoulesper
capita)
27
X
23
24
15
116
2
8
25
49
6
15
1
186
2
73
149
19
297
20
1988
CttfoOU
Emissions {c]
(metric tarn
per capita)
0.7
0.4
0.4
0.6
0.2
1.6
0.0
0.2
0.6
1.0
0.1
0.3
0.0
3.5
0.0
1.3
1.8
0.3
5.3
0.5
Mid-19801
Prodm liuo of
Hazardous
Wartes[d]
(metric toot)
X
X
X
X
X
2.000.000
X
36.000.000
X
X
X
X
X
X
X
1.700.000
500.000
X
265.000.000
X
Annual Rate of
P*fftr***ftfiiffi [cj
(boctftfo)
40,000(1}
20,ooo[q
1.380.000
X
42.000
X
2.000
48,000(n
2.000
595.000
300.000
270,000
3.000
X
6.000
X
X
158.000
159.000(1]
X
1989
Hi in*. J i J
FTOBCVBQ
ARM (X of
oountiy)
0.2
17.7
2.4
0.8
12.0
8.2
0.3
4.4
0.0
2.9
l.i
4.3
10.5
0.4
1.4
5.1
4.1
9.1
8.6
7.1
1990
Water Use
(Xof
available
wpply)
16
1
1
16
1
18
0
18
4
15
1
15
2
106
0
24
2
18
19
5
Sou EronoQ
(metric torn
per bectttcper
y«)
X
X
X
X
X
X
X
7S[g]
36(h]
X
1«M
15
X
X
X
X
X
X
10(hJ
sow
I
o>
Note*: X • Not available. 0 » Zero or ten tan half (he unit of measure.
[•] The Human Development Index, contracted by the UNDP, combines, in one number. • nteuun of ecooamic, education*], tod health deprivmtiaa. Countries above 0.8 ire considered to h«ve hifh humtn
development; 0.5 to 0.8, medium development; «nd below 0.5. low development
[b] Energy consumption include* traditional fuels.
[c] Fujurei include carbon from energy consumption and other industrialized sources.
[d] Hazardous wastes are not defined consistently from country to country.
[e] An fifura are from the Food and Af ricultuial Organization of the United Nations for the 1980s, except the following countries, which come f
Amazon only); Costa Rica. 1973-89; India, 1983-87; and Thailand, 1985-88.
[f] These figures include open and closed forests; all omen are for closed forests only.
[gj Figures are for seriously affected ciuplaul only.
[h] Figures are for total cropland.
ationali
i for the yean indicated: Brazil. 1990 (legs!
(Source: Mathews. J. T, and D. B. Tunttall. 1991. Moving Toward Eco-Development Generating Environmentalhformatknfor Deckionmaken. Issues and Ideas Paper. World Resources Institute, Washington. D.C.;
using dan from the United Nations, World Bank. World Conservation Monitoimg Centre. World Resources Institute)
-------
Sustainability and Environmental Assessment. (Source: Goodland, R., and H.
Daly. 1992. Three steps toward global environmental Sustainability.) World
Development 2:64-71.
Although Sustainability has not been an explicitly defined criterion in EA, a review of
some twenty EAs done for World Bank projects revealed some practical ways in which the
concept has been applied. For example, in the Uganda Livestock Services Project the EA
advocated a carrying capacity study for the rangelands to determine how many cattle could be
grazed on the land without reducing the land's capacity to support grazing next year. The main
focus of the project was to eliminate the tsetse fly. In a sense the land had been protected from
physical degradation by the infestation which had reduced human presence. With the eradication
of the tsetse fly human pressure on the land would increase, and the danger of that pressure
reaching an unsustainable level was recognized. A study to establish the carrying capacity of
the rangelands is a first step in avoiding unsustainable overgrazing. A further study comparing
the capacity of the land to support game versus the capacity to support cattle was also
recommended along with a study of the market for game meat as a substitute for cattle meat.
Also needed of course are institutions and laws that insure that ranchers will not exceed that
capacity.
Although the concept of carrying capacity has long been associated with cattle ranching,
it is also applicable more generally. For example, in the Java (Suralaya) Thermal Power
Project, a 1980 EA established that the site could accommodate up to 3,100 MW of generating
capacity. Presumably this reflects environmental limits although the recent EA did not specify
how the 1980 EA arrived at that figure. Nevertheless that approximate figure was respected in
the current expansion of the Suralaya generating station. It is not clear whether the limiting
factor was air quality, cooling water capacity, capacity to dispose of ash, or what. But some
regional environmental factor limits the carrying capacity for coal-fired power plants, just as
either rainfall, sunlight, or soil nutrients may limit the growth of grass and thus the number of
cattle that can sustainably be grazed on the rangelands in Uganda. The concept of environmental
carrying capacity logically applies to coal-fired power plants as much as to cattle.
The concept was extended one step further to apply to industrial development in general
in the case of the Dahanu Thermal Power Station in India. It was recognized that induced
industrial development around the new power station would overwhelm the environmental
protection features of the project itself. To avoid exceeding the local environmental carrying
capacity for industrial activity in general, part of the surrounding area was declared as an
"industrial exclusion zone."
The point of these examples is to show that the above discussion of theoretical input and
output guides based on regenerative and assimilative capacities is not impractical abstract theory,
but is in fact actually being approximated in rather imaginative ways by project designers even
in the absence of guidelines. But Sustainability is too critical to be dealt with in ad hoc fashion,
l.A-7
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however imaginatively. As emphasized at the beginning of this discussion sustainability is not
optional - it is not just one more value to be traded off against others - it is a mandate in the
absence of which measured income is not true income and measured rates of return on projects
are misleading. To carry out his mandate we must advance sustainability from a vague, but
important, concept to a set of operational guidelines.
l.A-8
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356
COMMENTARY
BIOPHYSICAL MEASUREMENT OF SUSTAINABLE
DEVELOPMENT
Richard A. Carpenter
Environment and Policy Institute
Abstract. Sustainability is now an accepted constraint on economic development. Biophysical measurements of the condition of the
environment are the essential first step in determining whether a given use or exploitive practice is sustainable. Uncertainties in these
measurements and lack of understanding of ecosystem processes hamper the guidance of economic planners and managers. It is especially
difficult to detect and predict the shift to unacceptable degradation in a highly productive managed ecosystem, such as intensive agriculture
or forestry. Opportunities for improved measurement are to be found hi new approaches such as restoration ecology, long-term ecological
research, and the concept of keystone species. Economic development enterprises, including international aid agencies, can afford to support
research and monitoring to reduce uncertainties about ecological sustainability. An adequate future supply of food and other products of
renewable natural systems will depend on more reliable measurement of sustainable development
INTRODUCTION
Reliance on conventional economics is often blamed for
policies and practices leading to unsustainable use of re-
sources (World Commission on Environment and Develop-
ment, 1987;Goodland, 1989; Daly, 1990; Asian Development
Bank, 1990). The implication is that sustainable economic
development cannot be achieved at the expense of the envi-
ronment (Shearman, 1990). Substantial efforts are underway
to improve economic theory and analyses, including the
valuation of environmental externalities for inclusion in
benefit-cost calculations (Carpenter and Dixon, 1985) and
the addition of changes in the natural resource base in gross
national product accounts (Ahmad et al., 1989). The mon-
etary values used derive from biophysical measurements of
the status and trends in natural systems. These quantifications
comprise the initial step in ascertaining whether a develop-
ment activity is ecologically sustainable. The answer may be
obvious with no special measurement skills needed if one
observes advancing deserts, deep gullies, algal blooms, or
salt-crusted soils. Similarly, if natural systems simply are left
alone, it is reasonable to predict that they will sustain them-
selves (although not without changing). The more important
and difficult task, however, is to intensify the productivity
Richard A. Carpenter is a research associate in the Environment and
Policy Institute, East-West Center, Honolulu, HI 96848. He was the
first Chief of the Environmental Policy Division of the Congressional
Research Service. Library of Congress, where he contributed to the
formulation, passage, and implementation of the National Envi-
ronmental Policy Act. In 1972, he became Executive Director of the
Commission on Natural Resources of the National Research Council,
National Academy of Sciences. Since 1977, he has worked
collaboratively at the East-West Center with specialists from Asian
and Pacific developing countries on planning and supervising a
continuing series of studies on environmental impact and risk
assessment
from natural resources, pressing against thresholds and limits
of degradation, striving for that maximum output for the
present which does not jeopardize the ability to continue the
same productivity in the future.
Science cannot detect dependably, much less predict, the
transition from intensive, but sustainable,' use to unacceptable
degradation. Further, the expectations of scientific certainty
by other actors in the development business (particularly
decisionmakers) probably are far more than can be delivered.
A World Bank report (Ahmad et al., 1989) states:
We believe that environmental accounting in physi-
cal terms is essential, particularly as this would cover
collecting data that indicate the direction and rate of
change in the quantity or quality of a resource. At the
same time, we recognize that 'monetization,' to the •
extent possible, is important as well....
Recognizing this mismatch of capabilities with expectations
and doing something about it must be a part of any attempt to
operationalize sustainable development
Uncertainties about natural systems have at least four conse-
quences on attempts to achieve sustainable development
• First, it may be difficult to tell whether a given use pattern
is sustainable, simply because the natural variations are
so great that the effects or noneffects of human interven-
tion cannot be detected. If, as is commonly encountered,
the precision of measurement is < 0.5, i.e., the standard
deviation is more than twice the difference between the
true population mean and the sample mean, then the
number of measurements required for the conventional,
or prudent, 90-95% confidence in the ability to discrimi-
nate becomes large, costly, and perhaps impractical to
obtain (Mar et al., 1987). The signal is lost in the noise.
THE ENVIRONMENTAL PROFESSIONAL Volume 12 pp. 356-3591990.
Printed in the USA. AD rights reserved.
0191-5398/90 $3.00+ .00
Copyright C National Association of Environmental Professionals
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MEASUREMENT OF SUSTAINABLE DEVELOPMENT
357
• Second, uncertainties can be used as an excuse for arbi-
trary resource management strategies that are either
overconserving or overexploiting. To environmentalists,
it is intuitive that uncertainty recommends more cautious,
even if more expensive, environmental protection. To
development advocates, uncertainty about the future
environment justifies going ahead to capture obvious
short-term economic gains.
• Third, thresholds are postulated to exist in some natural
systems beyond which catastrophes or irreversible degra-
dation occur (e.g., extinction of species, contamination of
groundwater, loss of soil A-horizon). The uncertainty
about threshold values may rule out development options
which otherwise are economically attractive.
• Fourth, since ecological and economic calculations of
sustainability assume "stationarity," or continuity of fun-
damental environmental conditions, the likelihood of
baseline changes such as climate warming, and the uncer-
tainties about their degree, or even direction, are substan-
tial additional problems for the development analysts and
decisionmakers.
If a society is averse to risk, all of these adverse effects of
uncertainty are increased. Batie (1989) notes that while
econometrics assumes that nature is predictable, the ecologi-
cal sciences admit the impossibility of prediction in many
situations. She describes some of the "belief system" of
sustainable development whose advocates: l)perceive that
the biosphere imposes limits on economic growth, 2)express
a lack of faith in either science or technology as leading to
human betterment, and 3)are extremely averse to environ-
mental risks.
The economic losses associated with erring on the safe side
(or compensating for uncertainties) when striving for
sustainability may be large. In attempts to design and operate
sustainable development systems, the economic optimum
may be missed by a wide margin. However, it is not just fine-
tuning which is in question, but the very real possibility of not
being able to tell whether a system is sustainable. Large
investments by industry, government, and international aid
agencies are at stake. Therefore, the presumed value of
reducing uncertainties should be sufficient to generate sub-
stantial support for research and monitoring, including the
development of indicators of unsustainability.
EVIDENCE OF CURRENT INADEQUACIES
The following examples of practical problems in measuring
sustainability document my thesis.
• The quantification problem is often manageable for single
stresses on well-defined resources, such as forests or
aquifers, but numerical measures are much more difficult
to obtain for characteristics of holistic systems, such as
resilience,robustnesstorstability(Munn, 1989). Cocklin
(1989) asks:
Most simply, how do we in fact measure whether
a system is sustainable or not? ...It will almosl
certainly prove impossible to define any single
measure of sustainability atageneral-system level.
This implies, then, that individual components
will need to be measured separately.
How to combine different measures in order for manag-
ers to make trade-offs and compare development alterna-
tives becomes a major problem.
• The "Safe Minimum Standard" advocated by Ciriacy-
Wantrup (1968) seeks to minimize the chances of catas-
trophe to the environment by making a social decision to
pay a premium of protection costs or foregone produc-
tion, but only if the premium is not "too large"—a value
judgement In practice, this would require confident
prediction of conditions that bring about worst-case con-
sequences, such as species extinction. Furthermore, in
the case of extinction, there are large uncertainties about
the characteristics of plants and animals that eventually
might prove useful to society (Bishop, 1978).
• The conservation of biological diversity is attracting
general public support and commitment of funds. At the
same time, scientific understanding about disruption
from exotic species, critical-link species in food webs,
and habitat vs. species preservation is changing rapidly.
Westman (1990) notes that some of our current poli^
toward biological conservation appear to be basecW
concepts that no longer are widely accepted in the eco-
logical community.
• For some time, fisheries have been managed for maxi-
mum sustainable yield, but the impact on harvest from
changes elsewhere in die larger system upon which.the
fish depend can be devastating. Bardach (1990) noted
the fluctuations in sardine fisheries of the Southeastern
Mediterranean after the As wan High Dam was built The
Nile stopped delivering nutrients to the sea and the
fisheries collapsed, only to revive somewhat later when
expansion of irrigated agriculture, also made possible by
the dam, again provided some nutrients. A similar
example is the crash of shrimp populations in the Eastern
Arabian Sea due to an increase in salinity of coastal
waters, because dams on the Indus River greatly reduced
freshwater flows. Prediction of the timing and magnitude
of such chains of events is usually imprecise.
• Development projects based on growing vegetation, such
as pastures or fuelwood plantations, usually are not
allowed to achieve a mature equilibrium condition; rather,
these systems are manipulated constantly to stay at an
early succession^ stage, where primary productivity of
biomass is greatest Establishing the conditions fa
sustainability in such a dynamic process is much n(~
difficult than with systems that are in the climax
(Harper et al., 1987).
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358
CARPENTER
• Field measurements and laboratory analytical results
concerning natural systems in developing countries are
notoriously uncertain, due to natural variation and errors
in collection, analysis, and interpretation (Blaikie and
Brookfield, 1987). A recent repon of the Asian Develop-
ment Bank (1990) concludes:
The lack of quantitative environmental informa-
tion comparable with the statistics available re-
garding economic parameters is a major obstacle
to integrated economic-cum-environmental plan-
ning. Statistical information on the environment is
scarce, often inaccurate, seldom comparable from
country to country, and rarely available in a time
series covering a sufficient number of years to
indicate trends in a reliable way.
Statistically reliable data simply are not widely available
for such fundamental factors as soil erosion, nutrient
transport, and vegetative productivity (Carpenter, 1989).
Ludwig (1985) observes that while the results of water
analyses reported in developing countries may appear
adequate at first glance, all too often they actually contain
numerous errors and omissions and scarcely give a com-
petent picture of the water quality.
• Hydrologists have studied the Pearl Harbor aquifer on
Oahu, Hawaii, for decades, yet recently decided to reduce
the amount of water removed by 13% because of uncer-
tainty about recharge rates and the fear of saltwater
intrusion (Hufschmidt, 1990).
• The inability to predict accurately the assimilative capac-
ity of water bodies for organic matter, a so-called free
service of nature, has led to the zero-discharge concept in
the United States Water Quality Act, thus requiring more
expense for sewage treatment and control of nonpoint
sources. The value of the renewable resource of assimi-
lation is ignored.
• If the rate of soil building by natural processes (weather-
ing of rock and accumulation of detritus) is greater or
equal to the erosion rate in a given farming system, then
the practice could be said to be sustainable. Neither rate
can be measured with sufficient accuracy, however, to
allow certainty in specifying a tolerable amount of ero-
sion (Crosson, 1985).
PROMISING RESEARCH
There are lines of investigation now underway which could
lead to better measurement of sustainability. These research
approaches could be expedited with increased funding from
development interests which are feeling the imposition of a
sustainability constraint on their activities.
• Most fertile parts of the world are used to support dense
or expanding human populations. Highly productive.
intensive, high-input agricultural systems are essential to
provide adequate food in the future. Otherwise, marginal
lands would have to be brought under cultivation, and
such lands are not capable of being fanned sustainably.
However, the intensive systems are also suspect; for
example, salinization and waterlogging follow excessive
irrigation, nitrate fertilizer applied to crops leaches into
drinking water supply aquifers, and dependence on
chemical pesticides results in resistant strains of insects
(York, 1988). Much of the research work at the centers
of the Consultative Group on International Agricultural
Research (CG1AR) is on the feasibility of agricultural
sustainability.
Promoting sustainable development includes the trans-
formation of currently degraded and unsustainable sys-
tems into a productive sustainable state, but not necessar-
ily the same as before degradation. For example, careful
research has provided practical means of restoring lakes
which have been damaged severely due to pollution by
sewage, sedimentation, or lowered water level, and whose
damage is irreversible by natural recovery mechanisms.
The research involves die entire system of the lake and
the surrounding drainage basin. Such measures are called
"redevelopment" by Bjork (1988).
Keystone species are those which play a central role in
controlling or determining the relative abundance of
other species in an ecosystem. More knowledge of these
important plants and animals would allow conservation
efforts to be concentrated on their role in, for example,
sustained yield management of game species (Westman,
1990). Moreover, the expected global warming will
bring stress and breakdown to currently sustainable sys-
tems and the health of keystone species could be a key
indicator of such changes.
The actual length of time that a given practice may be
sustainable is difficult to predict, because of long-term
time lags between human manipulations and ecological
responses (Magnuson, 1990). These time lags, some-
times decades long, separate cause and effect and make
them difficult to correlate. They may result in costly
mistakes by managers of renewable resources. Long-
term ecological research is beginning to bring some
understanding of these delayed, but profound, changes.
So far, such research is mostly in the temperate zone, and
extension to the tropics will be necessary to assist the
developing countries there.
The sustainability of an ecosystem often is correlated
with the extent of habitat. A minimum viable population
(MVP) is that number of some species that has a high
probability of survival. For example, in tree species,
population sizes decrease with decreasing area, and the
risk of extinction due to chance genetic, demographic, or
environmental events increases. Although few precise
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MEASUREMENT OF SUSTAINABLE DEVELOPMENT
359
estimates of MVP are available, future research should
allow useful predictions from such relationships
(Edgerton, 1990).
• The Environmental Monitoring and Assessment Pro-
gram of the U.S. Environmental Protection Agency fol-
lows the effects of regulating pollution on the condition
of the environment. To accomplish this task, indicators
of status and change that can be monitored efficiently and
continuously are being developed (Hunsaker era/., 1990).
CONCLUSION
Development generally is regarded as acceptable only if it is
sustainable socially, economically, and ecologically. In
particular, the exploitation of renewable natural resources
should not result unknowingly in their degradation. Imple-
mentation of this sustainability constraint requires, and pre-
sumes, a reasonable certainty about the condition of natural
systems under varying degrees of stress.
There is consensus in the environmental science literature
that this capability for reliable biophysical measurement is
inadequate to meet the expectations of resource managers.
Further, there is insufficient awareness of the inherent uncer-
tainties attending descriptions and predictions of natural
systems. Despite this management information gap, eco-
nomic development in a crowded world must proceed with
intensified production from forests, fisheries, range lands,
farms, and wildlife. Technological inputs to less exploited
sites will increase. Damaged ecosystems will be restored.
Investments and risks are enormous, but the health and
quality of life for billions of persons depend on successful
sustainable development.
A second consensus from the environmental science com-
munity is that opportunities for improved measurement and
prediction are at hand. Research approaches and monitoring
techniques which promise practical guidance for development
planners are evolving. This work now is funded primarily by
pollution control agencies. The sponsorship of environmental
science research by development authorities has, so far, been
restricted largely to "Green Revolution" agriculture. The
analysis presented here justifies a much broader and more
direct support, in order to avoid costly mistakes and to
increase confidence in decisionmaking. Sustainable devel-
opment can be considered as an experiment, with incremental
advances, midcourse correction, and a constant supply of
monitoring data on the condition of the environment as well
as its productivity. The payoff for improving biophysical
measurements could, in fact, be the achievement of
sustainability.
REFERENCES
Ahmad. YJ.. S. El-Serafy, and E.Lutz,eds. 1989. Environmental
Accounting for Sustainable Development. The World Bank,
Washington, DC.
Asian Development Bank. 1990. Economic Policies for S
able Development Asian Development Bank, Manila, p.
Bardach, John. 1990. Sustainable Development of Fisheries.
Presented at Globe 90, Vancouver. BC. Match.
Batie, Sandra S. 1989. Sustainable Development: Challenges to the
Profession of Agricultural Economics. American Journal of Ag-
ricultural Economics 71(5). December.
Bishop, R.C. 1978. Endangered Species and Uncertainty: The
Economics of a Safe Minimum Standard. American Journal of
Agricultural Economics 60(1): 10-18.
Bjork, Sven. 1988. Redevelopment of Lake Ecosystems: A Case
Study Approach. Ambio 17(2).
Blaikie, P.M., and H. Brookfield. 1987. Land Degradation and
Society. Methuen, London and New York.
Carpenter, RA. 1989. Do We Know What We Are Talking About?
Land Degradation and Rehabilitation 1:1-3.
Carpenter, R.A., and J.A.Dixon. 1985. Ecology Meets Economics:
A Guide to Sustainable Development. Environment 27(5): 6-11,
27-32.
Ciriacy-Wantrup.S.V. 1968. Resource Conservation, 3rd Edition.
University of California Press, Berkeley.
Cocklin, C.R. 1989. Methodological Problems in Evaluating
Sustainability. Environmental Conservation 16(4). Winter.
Crosson, P. 1985. Impact of Erosion on Land Productivity and
Water Quality in the United States. In Soil Erosion and Conser-
vation, S.A. El-Swaify, W.C. Moldenhauer, and A. Lo, eds. Soil
Conservation Society of America, Ankeny, LA.
Daly, H.E 1990. Toward Some Operational Principles of Sustain-
able Development Ecological Economics (2): 1-6.
Edgerton, S.A., FLR. Smith, R.A. Carpenter, T.A. Siddiqi, S.G.
Olive, C.P.B. Claudio, V.T. Covello, DJ. Fingleton, K.G. Kim.
andB.A.Wilcox. 1990. Priority Topics in the Study of En
mental Risk in Developing Countries: Report on a W<
Held at the East-West Center, August 1988. Risk Analysis 1
Goodland,RJA. 1989. Environmental Sustainability in Economic
Development: A Comment Land Degradation and Rehabilita-
tion (l):3ll-322.
Harper, D.E., D.B. Botkin, R.A. Carpenter, and B.W. Mar. 1987.
Applying Ecology to Land Management in Southeast Asia.
Occasional Paper No. 2. East-West Environment and Policy
Institute, Honolulu.
Hufschmidt, M. 1990. Personal communication. Consultant
Environment and Policy Institute. East-West Center. Honolulu.
July 2.
Hunsaker, C., D. Carpenter, and J. Messer. 1990. Ecological
Indicators for Regional Monitoring. Bulletin of the Ecological
Society of America 71(3): 165-172.
Ludwig, H.F. 1985. Exercise in Checking Validity and Reliability of
Typical Water Quality Analysis for a Natural Water. The NEB
Newsletter (Bangkok). No. 19. September.
Magnuson, JJ. 1990. Long Term Ecological Research and the
Invisible Present Bioscience 40(7).
Mar. B.W., W.S. Miner, R.N. Palmer, and R.A. Carpenter. 1987.
Cost-Effective Data Acquisition. Workshop Report No. 1. East-
West Center, Honolulu.
Munn. RJL 1989. Towards Sustainable Development: An Environ-
mental Perspective. Development 1989:2-3, Journal of SID: 70-
80.
Shearman, R. 1990. The Meaning and Ethics of Sustainability.
Environmental Management 14(1): 1-8.
Westman, WJL 1990. Managing for Biodiversity: Unresolved
Science and Policy Questions. Bioscience 40( 1): 26-36.
World Commission on Environment and Development 1987.
Common Future. Oxford University Press, Oxford, UK.
York, E.T.. Jr. 1988. Improving Sustainability with Agriculti
Research. Environment 30(9). November/
tu^r
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PARTB
THE EA PROCESS
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PARTB
THE ENVIRONMENTAL ASSESSMENT PROCESS
B-l
-------
B-2
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THE ENVIRONMENTAL ASSESSMENT PROCESS
The Environmental Assessment (EA) process includes a variety of
activities aimed at providing information to decisionmakers to ensure that
environmental considerations are a part of decisionmaking (Figure B-l). The
scope of these activities will vary depending on the nature of the proposed action,
its potential for impacts to the environment, public interest, and the
decisionmaking culture of any given industry or government. Nevertheless, there
are some basic elements that are recognized as generally essential to successful
EA. These include:
• Initiation (including identification of issues and generation of
alternatives)
• Scoping
• Assessment
• Decisionmaking
• Post-Decision Analysis
During initiation, which is generally an internal process occurring early
in project formulation, the proponent evaluates the purpose and need for the
proposed action and the required level of EA review and documentation (e.g., in
the U.S., categorical exclusion, environmental assessment, or environmental
impact statement). Predetermined lists, a screening procedure, or a combination
of these approaches can be used to determine the potential impacts of a proposed
action. Tentative issues and alternatives are identified during initiation.
Once a decision is made that EA is necessary for a proposed action, a
team is assembled and the formal scoping process begins. This process usually
includes consultation within and between governmental departments and public
and government participation in one or more scoping meetings. The purpose of
scoping is to identify reasonable alternatives and issues and concerns related to
the proposed action; provide early identification of areas (including data gathering
and research) that will need attention for evaluation of their significance; and
facilitate consideration of alternatives and mitigation. Scoping is an ongoing
process, but it is most effective and useful when begun early in the planning
process.
Following the formal part of the scoping process, the proponent decides
what must be considered in the analysis and assessment part of the EA process
and what can be eliminated. These early decisions should be documented. Based
on guidance from the proponent, an interdisciplinary team divides the analytic and
B-3
-------
I N I T I A T I O N
* purpose & need
* environmental information
* issues
* interim alternatives
no known
impacts
impacts
unknown
significant
impacts
SCREENING
EXCLUSIONS
* existing information
* categories
* criteria
SIGNIFICANT
IMPACTS ?
Yes
None or
mi or mitigation
DECISIONMAKING
issue EA decision
document
notify public
Implement
project
INITIAL EA
* public/government
views
* tentative issues
* other alternatives
independent
Review
'completeness
* adequacy
REALM OF
f—PUBLfC
PARTICIPATION
DETAILED EA
* public/government
notification
* interdisciplinary
team
* scoping meetings
* significant issues
* other alternatives
DRAFT EIA
* potential impacts
of alternatives
* proposed mitigation
* public/govt. review
and comment
FINAL EIA
preferred
altemative(s)
address draft EIA
comments & new
issues/information
No
Yes
POST DECISION ANALYSIS
* monitoring
* project modification
* application to future actions
Figure B-1 The Environmental Assessment Process
B-4
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writing responsibilities and draft and final EA documentation is prepared. For
purposes of this sourcebook, an environmental impact assessment (EIA) is the
report that documents the detailed EA process. Draft EIAs for proposed actions
with potential for significant impacts to the human environment should generally
be circulated for review and comment to the public, non-governmental
organizations, and government agencies, as appropriate. In the U.S., expert
agency comments and public scrutiny are essential to implementing NEPA.
Following review of comments, the EA team prepares final documentation which
the proponent makes available to all interested and affected entities.
Decisionmaking for major proposed actions follows internal and public
review and distribution of the EIA. The result of the decision process is
formalized by publication of a "record of decision" or a determination that
identifies the alternatives considered, which of them are environmentally
preferable, the one chosen to be implemented, and any mitigation measures to
reduce or eliminate adverse effects of unavoidable environmental impacts. It also
may discuss preferences among alternatives based on economic and technical
considerations and statutory constraints. An EIA is written to inform ultimate
decisionmakers about the consequences of their choice but decisions are also
made during the EA process that influence the choice of alternatives and other
aspects of the proposed action (e.g., design and mitigation measures). In
practice, the overall influence of an EIA on ultimate decisionmaking is unknown
(Culhane et al. 1987) but there is little doubt that EA influences decisions
resulting in changes to proposals and environmental management conditions
(Hollick 1986). The lack of EA or an inadequate EIA, particularly for major or
controversial actions, can result in time consuming and costly litigation that can
cause modification, delay, or cancellation of projects.
Post-decision analysis (PDA) is increasingly being recognized as an
important element of EA (ECE 1990). Ideally, PDA encompasses evaluation of
scientific and technical issues and procedural and administrative matters during
and after implementation of a proposed action. The nature of PDA studies
depends on the proposed action, but often includes compliance monitoring studies
required by regulatory agencies, baseline monitoring (prior to construction and
operation), environmental effects monitoring, and mitigation monitoring. The
information provided by the PDA studies not only allows for -project
modifications if needed but also results in a better understanding of impact
predictions and the effectiveness of mitigation measures which can be applied to
future activities of the same type.
B-5
-------
REFERENCES
Culhane, P. J., H. P. Friesema, and J. A. Beecher. 1987. Forecasts and
Environmental Decisionmaking. Westview Press. 306 pages
Economic Commission for Europe (ECE). 1990. Post-Project Analysis in
Environmental Impact Assessment. ECE/ENVWA/11. United Nations,
New York. 54 pages.
Hollick, M. 1986. Environmental impact assessment: an international
evaluation. Environmental Management 10:157-178.
B-6
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ATTACHMENT TO PART B
THE ENVIRONMENTAL ASSESSMENT PROCESS
• Environmental Assessment. (Source: U.S. Environmental Protection
Agency. EPA/600/M-91/037 March 1992)
B-7
-------
B-8
-------
&EPA
United States Office of Reseg Band Office of International Office of Enforcement
Environmental Protect™ Development^^ Activities Washington DC 20460
Washington. DC 20460 Washington, DC 20460
am
Environmental
Assessment
-------
EFA Technical Information Packages
This brochure is pan of a series of information packages prepared by the United States Environmental Protection Agency (EPA). Aimed
at the international community, the packages focus on key environmental and public health issues being investigated by EPA. The products
highlighted within these packages provide a sound technical basis for decisions regarding the development of environmental policy, abatement
activities, and pollution prevention. By pooling expertise in the areas of environmental science and technology, significant progress can be
anticipated to ensure a habitable environment for all nations.
Environmental Impact Assessments presents information on the components, applicability and benefits of the environmental assessment
process. Brochures and associated support material are available on the following topics:
• Ensuring Safe Drinking Water....EPA/600/M-91/012
• Mining Waste Management EPA/600/M-91/027
• Pesticide Waste Disposal EPA/600/M-91/028
• Air Quality Management EPA/600/M-91/029
• Solid Waste Disposal EPA/600/M-91/030
• Hazardous Waste Management ..EPA/600/M-91/031
• Small Community Wastewater
Systems EPA/600/M-91/032
• Water Quality EPA/600/M-91/033
• Risk Assessment EPA/600/M-91/034
• Pesticide Usage Guidelines EPA/600/M-91/035
• Pollution Prevention EPA/600/M-91/036
• Environmental Impact
Assessments EPA/600/M-91/037
• EPA Information Sources EPA/600/M-91/038
• Environmental Management ...EPA/600/M-91/039
Each complete Technical Information Package (TIP) consists of a cover brochure as well as all of the documents highlighted within the
body of the brochure. Generally, the cover brochures contain a section discussing the environmental issue, associated health and environmental
effects, guidelines, sampling and analytical methods, as well as treatment and disposal technologies. Following this section, a bibliography is
provided to identify other important sources and documents in the field. An attempt has been made to provide references that are readily available
in technical libraries. Finally, a number of EPA contacts followed by some additional resources are listed to facilitate consultation and technical
assistance. Document ordering information is provided on page 8.
FRONT COVER: Construction of the Stonewall Jackson Dam in West Virginia.
Photo courtesy of the U.S. Arniy Corps of Engineer*.
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IVHronmental Assessment
Process
Key Concepts
Environmental Assessment (EA) Pro-
cess1: This generic term denotes a multifaceted
decision-making process. The process is struc-
tured to anticipate, analyze and disclose the
consequences associated with proposed activi-
ties2 with respect to established public policies
for protecting and enhancing the natural and
man-made environment.
Terms associated with the EA process
include:
Assessment: An "assessment" is any docu-
mentation describing the consequences associ-
ated with a project and the means by which the
estimates were derived.
Environmental Assessment: An "EA" is
a document containing information in suffi-
cient detail to determine whether a project's
environmental consequences will fall above or
below thresholds considered to pose signifi-
cant adverse impact to the environment.3
Environmental Impact Assessment: An
"EIA" is a document containing an assessment
of environmental consequences for projects
known, or expected, to exceed thresholds of
significant adverse impact to the environment.4
The overall purpose for undertaking an
environmental assessment is to seek ways to
avoid or minimize adverse effects of a pro-
posed project to ti^pitent practicable, and the
maintenance, restoration or enhancement of
environmental quality as much as possible.
Notes:
'"Environmental Review" (ER) process is
the legal term used in the United States (U.S.).
2 "Proposed activities" subject to assess-
ment are not limited to physical projects, but
may also include plans, programs, policies and
even legislation or regulations if it is deter-
mined that their implementation, directly or
indirectly, could cause potentially significant
environmental impacts to occur. The term
"project" is used genetically hereafter for any
or all of these categories.
3 In the U.S., EAs are coupled with a
decision document termed a "Finding of No
Significant Impact."
4 In the U.S., EIAs consist of an "Environ-
mental Impact Statement" (the "assessment")
coupled with a decision document termed a
"Record of Decision."
Support documents:
• Facts About The National Environmental
Policy Act, September 1989, Council on Envi-
ronmental Quality and U.S. EPA.
The Benefits of an EA
Process
An EA process is essentially an early
warning process. The primary objectives of an
EA process are to alert all interested parties to:
the purposes and potential negati^phnpacts
associated with a proposed project; and alterna-
tives that optimize positive outcomes while
minimizing undesirable effects. The earlier it is
initiated the greater the benefits it will provide.
Proposed projects start with an initial plan-
ning/design stage, followed by detailed plan-
ning/engineering, and ends in implementation
or construction. The review for potential envi-
ronmental impacts should be coupled with the
early phases of initial planning and design. If
unacceptable impacts are anticipated, changes
can be made during early project planning to
minimize them less expensively than would be
required once engineering or construction work
has begun. In some cases, environmentally
preferable alternatives may be identified. There-
fore, the effectiveness of an EA process is
dependent on the following two conditions:
first, that the process is an integral part of the
plan of action, begun early in the budgeting
cycle before irrevocable commitments of re-
sources have been made; and second, that it is
linked to the decision-making processes in-
volving location and design studies.
An EA process can greatly influence where
and how a project or activity is sited, the size of
facilities to be built, the technologies employed,
and the area a project is to serve or otherwise
affect. Location analysis can help to avoid
areas of environmental importance, such as
critical habitats of endangered species and
highly productive farmland. It can also help to
avoid potential catastrophic situations such as
diverting developments from areas that are
-------
frequently flooded or potentially hazardous to
life and property in other ways.
If critical or sensitive resources or loca-
tions cannot entirely be avoided, comparative
analysis of alternatives can help identify op-
tions that minimize irreparable damage. Simi-
larly, analysis of alternative technologies can
identify cost-effective solutions that reduce
discharges of air and water pollutants as well as
providing collateral savings to the public in
terms of reduced maintenance and health costs.
Finally the analyses of an EA can influence the
extent of project service areas, thereby allow-
ing local communities to exercise control over
land-usage and urban growth incompatible with
preserving environmental amenities.
Establishing the Framework
Assigning responsibilities5: There are
several approaches for constructing a frame-
work. They require the following questions to
be answered: who will be responsible for (1)
preparing the basic format and other assess-
ment requirements to be followed; (2) prepar-
ing assessment documents on individual
projects; (3) making the final decisions based
on project assessments; and (4) evaluating the
adequacy of assessments and decisions that
flow from them.
For example, a single agency can be des-
ignated to be responsible for all four tasks. The
benefit to this approach is that it might produce
the greatest uniformity of EA application and,
incidentally, may preclude the need for evalu-
ating the adequacy of individual assessments.
A drawback to this model is that this approach
would be the least effective in convincing other
agencies about the benefits of the EA process.
Another approach would be to spread the
responsibilities for the four tasks among as
many agencies as possible. This model would
enable the responsibility for the actual produc-
tion of assessments to be assigned to every
agency having jurisdiction over activities af-
fecting development. However this approach
would require an independent agency for con-
ducting task four. In the long run, this model
could maximize government-wide regard for
environmental principles.
There are several other combinations that
could be established in between. The most
common approach is to require each agency to
produce and issue assessments on all projects
within their jurisdiction and make final deci-
sions on them, and rely on another agency to
undertake the tasks of establishing basic re-
quirements and evaluating the adequacy of
assessments.
Note:
5 The discussion in this and other sections
assumes that the process is being conducted by
a governmental agency.
Applicability of Projects to
Assessment
All projects can benefit from EA even on
an individual business level. On a governmen-
tal level, triggering mechanisms for subjecting
projects to EA are usually defined in the law
creating the process. For example, the Ameri-
can federal process requires only projects in-
volving a "federal action" to undergo an EA.
Federal actions are generally limited to project
sponsors applying for federal financial assis-
tance, a permit or license. Different levels of
government may subject different kinds of
projects to assessment. When an assessment is
required by two different levels of government,
requirements of both are usually incorporated
into an assessment conducted at the highest
level of government.
However, some project actions are so in-
consequential that it would be a waste of re-
sources to require them to undergo an EA.
Therefore, the EA process usually begins with
an initial step for determining whether or not a
project should undergo an assessment at all.
To be exempted from the EA process, a
project must meet two tests:
Test 1 - the project should be consistent
with categories of projects that have been deter-
mined not to individually, cumulatively over
time, or in conjunction with other projects in
the same area, have a significant effect on the
quality of the environment (e.g., minor reha-
bilitation of existing facilities or replacement
of equipment); however,
Test 2 - a project meeting the criteria for
exemption (test 1) must not be located in or near
areas that might affect the protection of sensi-
tive natural or cultural resources (e.g., endan-
gered species, historic sites, etc.).
-------
igories of potentially excluded projects
(test 1) are sometimes based on criteria result-
ing from public policy. More often they result
from agency experience indicating that certain
project categories rarely result in adverse im-
pacts to the environment. Criteria for not grant-
ing an exclusion from EA (test 2) are almost
always due to public policy.
Even though, based on the tests above, a
decision is made to exclude a project from EA,
good practice suggests that the affected public
should be notified about these projects as with
any other type of assessment. The value of the
notice is that local interested parties may know
reasons other than those considered by the
assessment team, why a particular project should
not qualify for exemption.
Experience gained on the federal level in
the U.S. indicates that approximately 10-15%
of projects covered by the EA process are
categorically excluded from further assessment
Determining the
Appropriate Level of
Assessment
For project actions not excluded from fur-
ther assessment, the majority of project actions
will fall into a category of assessment whose
impacts are unknown. The procedures for un-
dertaking an EA generally begin with an ex-
amination of the proposed action to whatever
level of detail is required in order to make one
of two determinations: either there will be no
significant impact expected to result; or, there
will be significant nl^acts. If at any time during
the preparation of an EA information is uncov-
ered that would indicate the project could im-
pact the environment in a significant way, the
EA can be immediately terminated and a full-
scale EIA begun.
As experience in EA is gained, project
actions that have significant impacts associated
with them in every case (e.g., power plants,
reservoirs and dams) should be identified and
categorized. Criteria that may be useful in iden-
tifying significant project actions include when
a project (1) impacts directly on air and water
quality, particularly if there is a possibility that
standards may be exceeded or degradation of
high quality conditions may occur, (2) ad-
versely affects protected ecological resources,
such as endangered species; (3) creates unde-
sirable secondary impacts, such as increased
traffic or rapid urban growth; (4) causes release
of toxic or hazardous materials or generation of
wastes; and (5) in combination with other ac-
tivities causes adverse cumulative effects.
A majority of project actions result in
findings that do not significantly affect the
environment, or are easily changed to avoid
any undesirable impacts. Only a small percent-
age of all project actions will require a detailed
EIA.
Components of an EA
Process
There is not a precise and uniform meth-
odology for EIA. There are, however, four
components, each having a core set of activi-
ties, that are generally characteristic^TEIA as
it is practiced throughout much of the world.
These four basic components are infinitely
adaptable to fit unique environmental, political
or cultural conditions. EIA is very much an
evolving process, reflecting both the growth in
environmental knowledge and increasing ex-
perience.
The four basic components to an EIA
process, regardless of the complexity of the
evaluation to be undertaken, include (1) Sur-
veying and Information Gathering - describing
the existing environmental/social setting and
identifying the project's potential benefits and
adverse impacts; (2) Alternatives Generation
and Forecasting - identifying alternatives and
projecting the future environmental and social
setting by anticipating the consequences of
each alternative; (3) Screening - comparing and
contrasting the short and long-term effects of
each alternative for acceptability of change
they cause; and (4) Communicating - informing
the affected and interested public about the
rationale for selecting a "preferred alternative"
and soliciting input. There is a fifth component
that is not a formal part of an assessment pro-
cess but is very much related to it. This is: (5)
Monitoring - ensuring that a project is carried
out as approved.
Component 1 - Surveying and Informa-
tion Gathering: project needs and objectives
and general solutions are defined; surveys are
conducted to collect data descriptive of the
existing environmental setting (base line data);
meetings with affected and interested parties
-------
are held to identify the environmental issues
that need to be addressed (scoping process);
and, the nature and intensity of current trends
causing changes to the setting are identified.
Governmental agencieshavingjurisdictionover
areas that may be affected by the project as well
as other groups having special knowledge and
information pertinent to the project should be
identified and invited to participate in this and
succeeding steps. These activities can be best
handled by creating an inter-disciplinary team
early in this step to work on producing an
integrated assessment involving all five steps.
Component 2 - Generating Alternatives
and Forecasting: First agreement on a set of
viable alternatives is reached. Then a "no-
action" forecast is made to determine what the
future environmental setting might look like
without the project being undertaken. Next,
modifications to the initial forecast are made to
determine the beneficial or negative effects that
each alternative under consideration might pro-
duce. This step should, if feasible, also take into
account: scenarios that identify "areas of un-
certainty" for projects expected to have detri-
mental effects to various segments of the envi-
ronment; and, should also identify cumulative
affects caused by long-term phased projects
and/or from other developments in the project
area.
Component 3 - Screening: The beneficial
and adverse short- and long-term impacts of
each alternative should be compared and con-
trasted, and summarized in a way to facilitate
discussion and evaluation by the affected pub-
lic and other interested parties. As a part of this
step, the limits of acceptable change and risk
should also be identified and explained. The
results of this step will be a draft EA document
that summarizes the alternatives studied and,
whenever possible, identifies the preferred al-
ternative and the reasons for its selection.
Component 4 - Communicating: there
are numerous benefits to inviting the affected
public and other interested parties to comment
on all aspects of an assessment, especially on
the draft EA. The two principal benefits are that
it produces better informed judgements and
creates a better climate for public acceptance of
a proposed project. Their active participation
helps in clarifying the options available and to
disclose additional appropriate issues. New is-
sues raised by the public that have not been
addressed in the draft EA document should be
resolved and included within a final EA docu-
ment. Whenever necessary, a mitigation plan
should be worked out with all interested par-
ties. Finally, a decision document for the public
record is prepared focusing on the reasons for
the selection of the alternative to be built.
Component 5 - Monitoring: This is some-
times considered as one of the major compo-
nents of an EIA process. In reality, monitoring
is generally undertaken during, and following,
the implementation or construction of a project.
An entity having legal capacity to enforce com-
pliance of restrictions that may have been im-
posed on the project should be given responsi-
bility for seeing that mitigation measures, when
appropriate, are implemented, and environmen-
tal safeguards are enforced.
Support documents:
• Scoping Guidance, Memorandum of the
Council on Environmental Quality, issued April
30,1981.
The Substance and Content
of Assessments
An E A process is an umbrella under which
concerns for the protection of impacted natural
and cultural resources can be weighed against
the benefits derived from the project Each
individual project will raise different issues.
One project may require diverse expertise in
many socio-economic, ecological and cultural
disciplines. Another may have only narrow
concerns involving only one or two disciplines.
To address this problem, checklists have been
developed to quickly assess which potential
areas of impact will, or may, be involved.
Project managers should consider probable
consequences in the following areas (although
this is not intended to be an exhaustive list):
• Human health concerns include the iden-
tification and minimization of undesirable re-
leases of: paniculate or hazardous substances
to the air, nutrients or hazardous substances to
surface water, and solid wastes or hazardqj
O^L
-------
subSMces (e.g., pesticides) to soils and ground-
water. Assessments should also examine dis-
posal methods for unavoidable contaminants
so that environmental problems are not trans-
ferred among media. Although the concerns in
this area focus on human health, measures
taken to prevent contamination of drinking
water or waters used for recreation, for ex-
ample, also will benefit ecological concerns
such as fish and wildlife habitats.
• OtherSocio-Economicconcernsinclude
avoiding: the displacement of residents;
unaffordable user fees to build, operate and
maintain projects; adverse effects on property
values and land-use zoning including the uses
or misuses of lands in floodplains; overloading
community services; and, problems stemming
from induced growth in general, including trans-
portation costs and mobility.
• Ecological concerns vary widely among
geographic and climatological regions of a coun-
try or the world. On a national scale, major
areas of concern include protection of endan-
gered species of plant and animal life and their
aquatic and terrestrial habitats, preservation of
wild and scenic rivers and national parks, and
otherresourcesconsidered "critical" (e.g., prime
farmland, wetlands, barrier islands and wilder-
ness areas). On a more local level, additional
concerns (e.g., preservation of farmlands that
produce specialty crops, areas other than prime
agricultural land, land of importance to local
economies or that which provides open-space
relief from otherwise^Thbroken development)
may need to be considered.
• Cultural concerns include identifying
and determining the worthiness of preserving
the artifacts of early cultures and historic settle-
ments (e.g., tools, utensils, furnishings, build-
ings and other structures). Where and when it
becomes impossible to preserve items which
have been designated as official historic land-
marks, or otherwise considered significant by
interested parties, then an effort should be made
for experts to study the site and document its
attributes and significance prior to its loss by
construction activities.
Support documents:
• Cross-Cutting Environmental Laws: A
Guide for Federal/State Project Officers, Janu-
ary 1991, Office of Federal Activities, U.S.
EPA.
(2 model checklists)
• EPA Reviewers Checklist and Guidance
for EPA Regional Oversight of State National
Environmental Policy Act Delegation.
Oversight of the EA Process
Oversight of the EA process is necessary
to ensure that the intent of an EA process is
implemented in a fair and equitable manner.
Establishing Uniform Procedural
Requirements
One agency must be relied upon to pro-
vide leadership for establishing the basic pro-
cedural requirements and guidelines for under-
taking the basic components of the EA process.
Its primary objective is to establish ground
rules to ensure uniform application of legal EIA
procedural requirements fashioned to minimize
adverse impacts from projects. It should also be
responsible for producing guidance documents,
as needed, to aid responsible parties in carrying
out their duties such as: clarifying requirements
of the law; or clarifying how the basic require-
ments may apply to new assessment situations.
The lead agency should also be respon-
sible for gathering information on the condi-
tions and trends in environmental quality; evalu-
ating the programs of all responsible parties in
light of the goals established in law; developing
and promoting national policies to improve
environmental quality; and conducting studies,
surveys, research and analyses relating to eco-
systems and environmental quality. Each year
an annual report should be published to inform
all responsible parties and the general public on
the status of various environmental concerns
including the success, or lack thereof, of the E A
process.
Responsible Party Adaptation of the EA
Process
Once established, the EA process should
be applied uniformly across all program areas.
-------
This does not mean that the EA process need to
be pursued apart from planning processes es-
tablished under individual program require-
ments. It only means that agencies should pre-
pare EAs and EIAs using a common format
modified to include all other project planning
information needed for an agency to reach its
final decision. The format should be such that
decisions that result in adverse impact to the
environment will clearly highlight the trade-
offs being made between project benefits and
impacts. It should also allow for presenting
how project benefits outweigh impacts, or, how
other priorities may override the environmen-
tal ones involved.
Independent Review of Projects
When many agencies are involved in an
E A process, there are bound to be differences of
opinion on interpreting the significance of im-
pacts, including the acceptability of permis-
sible change to elements of the natural and
man-made environment. For this reason sev-
eral countries, including the U.S., have estab-
lished an independent evaluation process for all
"major" projects (e.g., projects determined to
have "significant" impacts). Usually the same
agency that establishes the original EIA guide-
lines isalsocharged with the independentevalu-
ation of major projects.6 The function of this
reviewing agency is twofold. First it must re-
view individual project EA documentation for
adherence to the minimum set of requirements
for EIA including public notification and par-
ticipation in the process. Second it must review
for acceptability of the impacts caused, includ-
ing whether or not the alternative chosen is the
most appropriate in minimizing adverse im-
pacts to protected environmental resources.
The reviewing agency should also have the
responsibility for maintaining a file, available
to public inspection, on all major projects evalu-
ated, including a brief description of the action,
how well the agency met the requirements of
the law and how acceptable the agency's action
is in protecting and restoring environmental
resources.
Note:
6 In the U.S. the Council on Environmental
Quality originally produced the original re-
quirements andprovided the independent evalu-
ation of major project assessments. The inde-
pendent review is now carried out by the Envi-
ronmental Protection Agency.
Attachments:
Sect 1502.10, Recommended format, Regula-
tions for Implementing the Provisions of the
NEPA, Council on Environmental Quality,
1980.
Additional References
• Application of Environmental Impact As-
sessment: Highways & Dams, United Nations
Economic Commission for Europe, Environ-
mental Series ECE/ENV/50.
National Environmental Policy Act [NEPA] of
1969,42 U.S.C. 4321 etseq.
Executive Orders 11514 and 77997; Council
on Environmental Quality Regulations Imple-
menting NEPA, November 29, 1978 (43 FR
55978).
Environmental Impact Assessment: Theory and
Practice, Ed. by Peter Wathern, Unwin Hyman,
1988.
Evaluation of EPA's £75 Program for Waste-
water Treatment Facilities, November 1980,
Office of Federal Activities, U.S. EPA.
Procedures for Implementing the Requirements
of the Council on Environmental Quality on
The National Environmental Policy Act, 40
CFR Part 6, U.S. EPA.
Environmental Impact Assessment, Larry W.
Canter,McGraw-Hill Book Co., 1977.
Environmental Impact Assessment, Proponent
Sponsored Engineer Corps Training, U.S. Corps
of Engineers, CE Training Management Div.,
1991.
-------
J^HMB^
,
Environmental AsKssment Contact List
Technical Area
Basic Principles & Processes
Cultural Assessments
Current Issues
Ecological Assessments
Methods for Identifying & Forecasting Impacts
Policy & Plan Assessment
Post Assessment Effectiveness
Public Participation
Recommended Formats & Evaluating Documentation
U.S. Experience
U.S. National Environmental Policy Act (NEPA)
Contact
John Gerba
Bob Hargrove
William Dickerson
Heinz Mueller
Larry Canter
Joseph Montgomery
Gene Wojcik
David Ketchum
Anne N. Miller
Nicholas C. Yoast
Dinah Bear
FAX Number
202-260-0129
212-264-6693
202-260-0129
404-257-5206
405-325-7596
202-260-0129
312-886-0168
202-205-1708
202-260-0129
202-887-0689
202-395-3744
Training Contacts
The following U.S. federal government agencies provide open enrollment workshops:
CE Registrar
U.S. Army Corps of Engineers
Engineering Division, Huntsville
ATTN: CECND-TD-RG
Huntsville, AL 35807-4302
Group Leader for Training and Support
Environmental Coordination Staff
Forest Service
U.S. Department of Agriculture
P.O. Box 96090
Washington, D.C. 20090-6090
-------
Ordering Technical Documents
The EPA documents mentioned in the Technical Information Package brochures can be ordered at no charge (while supplies are available)
from the Center for Environmental Research Information (CERI). Once the CERI inventory is exhausted, clients will be directed to the National
Technical Information Service (NTIS) where documents may be purchased. Orders can be placed by mail, phone, or FAX. To order documents,
have the document number or the EXACT title ready. The journal articles listed in the Additional References section may be ordered from the U.S.
National Focal Point of INFOTERRA.
, RESEARCH INFORMATION (CERI)
U.S. EPA, P.O. BOX 19963
CINCINNATI, OH 45219-0963
513-569-7562 PHONE 989-296-(US EPA UD) TELEX
513-569-7566 FAX
NEEDED TO ORDER: EPA document number or the EXACT title.
INFOTERRA U.S. NATIONAL FOCAL POINT
U.S. EPA
401MST..S.W., PM211A
WASHINGTON, DC 20460
202-260-5917 PHONE (23) 4979995 TELEX
202-260-3923 FAX
NEEDED TO ORDER: Name of journal, volume number, and page numbers.
NATIONAL TECHNICAL INFORMATION SERVICE (NTIS)
5285 PORT ROYAL ROAD
SPRINGFIELD, VA 22161
703-487-4650 PHONE
703-321-8547 FAX
NEEDED TO ORDER: EPA document number, NTIS number,
or EXACT title.
8
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CHAPTER 2
INITIATION
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CHAPTER 2
INITIATION
Initiation is generally an internal agency process preceding interagency and
public involvement that defines the purpose and need for the proposed activity,
generates tentative alternatives, and determines the appropriate level of
environmental review and documentation (e.g. in the U.S., categorical exclusion,
environmental assessment or environmental impact statement). Predetermined
lists, a screening procedure or a combination of these approaches can be used to
determine the potential impacts of a proposed action. Management commitment
to and support of the EA process must be established early in the planning
process and continue throughout the process in order for EA to influence
decisionmaking. Although proposals are generated by government
decisionmakers, government and public applicants for permits or funding, court
orders, and legislative commands, the proponent (i.e., the agency) has the
responsibility for developing an interdisciplinary approach to EA that is integrated
with planning and decisionmaking.
NEEDS
The initiation phase requires a clearly stated proposal, succinct statements
of purpose and need (Attachment 2. A), environmental information for screening
to determine the appropriate level of EA, formation of an EA team, and
determination of responsibility for coordination, record keeping and public
involvement.
• Environmental Information. The EA process begins when a
proposal is sufficiently well-developed that an environmental
information packet can be prepared. The proponent (agency,
applicant, grantee, or permitee as the case may be) assembles the
packet, generally from existing information and comparison to
similar activities. (Activities that can be categorically excluded
from detailed EA rarely require information beyond that found in
existing sources; activities mat require EA may require additional
or new information.) The information is used by the proponent to
determine the level of EA required for a proposed activity and also
it can be used as the basis for public information for scoping.
2-1
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The packet should describe the potential environmental
impacts of the proposed action and be of sufficient scope that it
can be used to determine if and how the proposal should be
pursued. At the initiation stage, knowledge and understanding of
the EA requirements and procedures, management support, good
communication, sufficient information, and logic are required.
Above all, the content and extent of the environmental
information, and all subsequent EA documentation, must be in
proportion to the environmental issues and to the relative
importance of those issues to decisionmaking. A checklist may be
helpful at this stage to identify basic issues related to proposed
projects (Attachment 2.B).
To the extent possible and as relevant to the proposed activity, the
environmental information packet should include
discussion/description of the following items:
- Need for the proposed activity
The proposed activity
— description of the proposed activity in appropriate detail
- current management or other activities in the area
- known potential impacts of the proposed activity
- important elements of the existing environment (physical,
biological, and social characteristics)
— known public use/interest in the area
- reasons for bounding the study area
- possible concerns
Purpose (objectives) of the proposed activity
Decisions to be made
— reference to any higher-level policy or planning or
existing environmental documents that might influence
the decisions to be made
Preliminary alternatives to the proposed action
— including the no-action alternative (which provides the
baseline information for assessment)
Anticipated level of EA documentation including rationale
Activities to be considered in the EA (scope)
— connected, cumulative, or similar activities
— mitigation measures
Environmental laws
— associated review, consultation, or permit requirements
- Federal, state, or local government agencies with jurisdiction
by law or expertise
2-2
-------
- names of agencies and point of contact with addresses
and telephone numbers
— tentative roles of agencies
- formal/informal agreements needed and responsible
persons
Background information documents (e.g., prefeasibility
studies, environmental studies)
- Schedule
- EA milestones, comment periods, and approval dates
— proposed implementation dates
- role of the decisionmaker in the assessment process and
the review of EA documentation
- Budget
- Responsibility
- proponent point-of-contact (oversight)
- team leader
team members
- other expertise as needed
— editing, graphics
- Public involvement
— proposed public involvement strategy
- known affected or interested persons, agencies,
organizations
Screening. Once the environmental information is available, the
proposed activity can be reviewed in order to determine the
appropriate level of environmental assessment. This internal
procedure is often referred to as "screening".
There are two approaches to screening, categorical and
discretionary, and most EA requirements [e.g., the CEQ
regulations implementing NEPA (Part D) and the EC Directive on
EIA, 85/337/EEC (1985)] provide for a combination of
approaches.
- Under the categorical approach, the proposed activity is
compared to predetermined lists of specific categories of
activities that 1) can be excluded from EA or will 2) always
be subject to EA. Often the applicability of the exclusion list
is determined by eligibility criteria (e.g., if the proposed
activity has the potential to affect a valued wetland or other
sensitive area, it will be subject to EA even if it is on the
exclusion list). The categorical approach reduces uncertainty
2-3
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and delay in determining which proposed activities will be
subject to detailed EA.
- Under the discretionary approach, if the proposed activity
cannot be categorically excluded, the proponent decides on the
appropriate level of EA. An (EA) document is prepared to
assess the environmental significance of the proposed activity.
- If it is determined that the proposed activity may
significantly affect the quality of the human environment,
then a full environmental assessment is required, starting
with the scoping process and culminating in an
environmental impact assessment (EIA) that documents
for the decisionmaker the information needed to decide
between the proposed activity or one of its alternatives.
- If it is determined that the proposed activity will not
significantly affect the quality of the human environment
and/or that potentially less significant impacts can be
easily mitigated, then the proponent prepares a brief
document that explains why the project will not
significantly affect the environment, and if applicable,
describes the mitigation measures.
Public involvement in the EA process usually begins when the
decision is made that an EIA is required.
Interdisciplinary EA Teams. When the screening process results
in a decision that an EIA is required, the proponent is responsible
for preparation of the document. Quality EA and documentation
is dependent on an experienced EA team leader with a general
understanding of all of the issues and an interdisciplinary team of
technical and scientific specialists chosen to match the issues
associated with the proposed action and its alternatives (Canter
1991). The U.S. CEQ regulations require this interdisciplinary
approach (Part D). Furthermore, the regulations require that the
professional qualifications of the team members (i.e., their
expertise, experience, and professional disciplines) be included in
an EIA.
Teams are assembled from staff members, other government
agencies or are hired consultants [e.g., non-governmental
organizations (NGOs), universities]. Occasionally, team
membership can only be determined after completion of the
scoping process. Generally, three types of members are selected:
2-4
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a team leader, who is responsible for the overall analysis,
document preparation, and coordination with the proponent's
point-of-contact;
- the core team members, who are responsible for analysis of
specific issues; and
- extended team members, who provide information as needed.
The team is responsible for thorough and correct analyses that
provide a basis for decisionmaking by the proponent. A team is
most likely to produce a competent assessment when it has a
thorough understanding of the EA process and prior experience
with similar environmental and project issues. Attachment 2.C
outlines the characteristics and responsibilities of an EA team
leader, the team members, and the extended team members.
Proponent Responsibilities. Successful EA depends not only on
adequate environmental information and technical expertise, but
also on good planning, management-support, and coordination with
the decisionmaker. The proponent must provide the team with:
- a clear and concise statement of work including the expected
technical and procedural standards to be met;
available background information (e.g., the environmental
information packet);
EA document standards (e.g., word processing, format,
graphics, number of pages, printing, distribution);
a single point-of-contact selected by the decisionmaker who
understands the issues and possible decisions and who has
been delegated the authority to make interim decisions;
- a reasonable schedule for deliverables;
- budgetary allocations; and
procedures for review and comment, to include consolidation
and clarification of comments by the point-of-contact before
delivery to the EA team.
The proponent is responsible for the quality and accuracy of the
information and analyses in an EA document, as well as the
conduct of the EA process (i.e., interagency coordination, scoping,
public hearings, document review, and general oversight).
Public Involvement Strategy. Public involvement in the EA
process, other than being required by law, is also a good
management practice. It helps the proponent understand the
expectations and concerns of the interested and affected publics,
2-5
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identify the potential for controversy, and obtain additional
information relevant to the proposed activity. It also enhances the
proponent's credibility and lessens the chances for public
grievances, appeals, litigation, and media attacks. The proponent
must encourage and facilitate public involvement by providing
public notice of hearings, meetings, and availability of EA
documents. Moreover, the public must be given an opportunity to
comment on EA documents. In turn, the proponent must remain
flexible and ready to respond to public comments and suggested
alternatives and issues related to the proposed activity.
Development of a public involvement strategy should start as soon
as a decision is reached on the level of EA. The proponent should
consider:
- Who might be interested or affected by the proposed activity?
Who might have information or expertise needed for the EA?
What information is needed from each person, government
agency, and NGO on the list?
What is the most effective way of obtaining the information?
There are a number of techniques for communicating with the
public (Table 2-1); however, each letter, notice, or meeting must
be planned to suit the specific proposed activity.
Planning Records. Because records documenting the EA
procedures may be required by law, it is important that a plan for
record keeping is established early in the planning process. When
the EA decision document is signed, the Mies should be closed.
However, the records must be available upon request except for
classified information or information on specific locations of
endangered species or cultural resources which may be exempt
from the law. Such classified information should be kept in a
separate and locked file. The contents of a planning record are
outlined in Attachment 2.D.
The planning record is a critical part of a proponent's defense
should a lawsuit occur. The object is to be able to document that
the procedural requirements of EA were followed in good faith and
that a reasonable decision was made based on the information
obtained using the procedures. Depending on the size of the
project, a data base index might be useful in tracking documents,
letters, etc. Fields could be: date, author, agency, organization,
addressee, document type, and issue.
2-6
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Table 2-1. Techniques for communicating with the public. Adapted from Bishop, 1973. .
(Source: Federal Environmental Assessment Review Office (FEARO). 1986. Initial
Assessment Guide. Federal Environmental Assessment Review Office, Ottawa K1A OH3)
Communication
Characteristics
Public Information and
Participation Objectives
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•— ID
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2
2
1
2
1
1
1
1
2
1
1
2
3
1
3
1
1
1
1
1
1
1
2
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1
1
2
1
2
3
2
3
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1
1
3
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3
3
3
3
3
3
3
3
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1
2
3
2
2
3
1
3
1
3
2
2
1
2
1
1
3
3
3
3
3
3
1
Public Participation/Communication Techniques
Public Hearings
Public Meetings
Informal Small Group Meetings
General Public Information Meetings
Presentations to Community Organization
Information Coordination Seminars
Operating Field Offices
Local Planning Visits
Information Brochures and Pamphlets
Field Trips and Site Visits
Public Displays
Model Demonstration Project*
Material for Mass Media
Response to Public Inquiries
Press Releases Inviting Comments
Letter Requests for Comments
Workshop*
Advisory Committees
Task Forces
Employment of Community Residents
Community Interest Advocates
Ombudsman or Representative
Public Review of Initial Assessment
Decision Document
Inform/Educate 1
1
X
X
X
X
X
X
X
X
X
X
X
X
X
Identify Problems/
Values |
X
X
X
X
X
X
X
X
X
X
X
X
X
4)
"o
01
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"Jo
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X
X
X
X
X
X
X
X
X
X
X
ipeqpaaj
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
4)
JJ
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9
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X
X
X
X
X
X
X
X
X
X
Resolve Conflict/ f
Consensus |
X
X
X
X
X
X
X
• low, 2 — medium, 3 «= high
X » Capability
2-7
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The following suggestions for organizing planning records are
excerpted from the U.S. Forest Service Litigation Support Handbook:
- Establish the organizational structure, put it in writing, and
delegate authority to one person for maintaining the record.
- Use a format based on subject (not date or EIA chapter) so that
someone not familiar with the project or with the EA process can
retrieve documents easily. Use headings such as:
External Agency Communications
Internal Agency Communications
Public Involvement
Resource References and Reports
Maps and Other Visuals
Data and Inventories
NEPA Documents
Decision Documents
- Format all documents to a standard size and place in 3-ring binders
or similar folders.
- Signatures must be original, carbon copy, or electronic copy ("/s/"
is not admissible in U.S. courts).
- Margins should be no less than 1".
- Attach all slides and photographs (including photos of oversized
maps and visuals) to standard size paper.
- Replace double-sided document with single-sided copies; remove
all paper clips, post-it notes and staples; copy all documents
clearly, correctly, and completely; retype all illegible documents,
mark them as duplicates, and include the original and the duplicate
in the record.
- Documents should be ordered chronologically within each
subdivision.
- Pages in the planning record should be clearly numbered
consecutively, with page 1 being the first page of the oldest
document.
TOOLS
Regulations, Guidelines. United States government agencies are
required to formally adopt procedures to implement the federal
regulations. Among other things, the procedures must specify criteria
for and identification of categories of action that normally:
- do not require environmental impact statements (EISs);
- do not require an EIS or an environmental assessment (EA)
document (these are categorical exclusions); or
- require EAs but not necessarily EISs.
2-8
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These categories of action are used in the screening process to
determine the appropriate level of EA for a proposed activity. The list
of categorical exclusions includes actions that do not individually or
cumulatively have significant effects based on agency experience.
In addition, agencies should prepare written procedures/guidelines/
handbooks that describe their particular EA process and establish
offices with responsibility for document review and oversight.
ISSUES
EA and Planning. Environmental assessment must be integrated with
other planning at the earliest possible time so that the EA
documentation will be completed and ready to be included in every
report or recommendation on proposals submitted to the decisionmaker
A "proposal" originates when an agency has a goal and is actively
preparing to make a decision on one or more means of accomplishing
it, and the effects of that decision can be meaningfully evaluated. EA
documents should not be prepared until prospective proposals are more
concrete than mere contemplation. However, EA document
preparation should not be put off so as to delay underlying actions.
The initiation of EA should coincide with the feasibility analysis stage
of projects and the EA documentation should be available before the
project has reached a stage of investment or commitment to
implementation likely to determine subsequent development or restrict
later alternatives.
All government agencies should adopt procedures to integrate EA with
their planning processes so that projects are better sited and better
designed and proposals that have unacceptable environmental impacts
will be modified or canceled. However, the extent that EA is
integrated into decisionmaking will vary from agency to agency and
sometimes from project to project (Bear 1987). Some agency officials
resist the application of EA, citing conflicting purposes between EA
and their "real" mission. Other agency decisionmakers believe the
primary value of compliance is to avoid litigation. While in some
agencies, the EA process is a vital part of their decisionmaking
process. How an agency views and implements the EA process will
depend on the commitment of the decisionmaker(s), high-level staff in
environmental review or compliance offices, and the solicitator's or
general counsel's office.
Coordination with Other Laws. Environmental impact assessments
should be prepared "concurrently with and integrated with" other
environmental analyses and reviews to reduce duplication between
federal, regional and local EA activities. In addition to the U.S.
2-9
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federal laws listed in Part D, other federal laws contain provisions that affect the
content and scope of EA under certain circumstances. Laws on water pollution
control, clean air, and surface mining control and reclamation are good examples.
Permits or licenses may also require baseline data. There is no one way of
accomplishing this integration because of differences in agencies' projects and
differences in regional and local procedures. However, the EA process lends
itself to a unifying role because it deals with every aspect of the environment, and
thus provides a focus for multiple approval processes (Yost 1989). The key to
success lies with early planning and some flexibility in project scheduling.
The proponent must:
- establish contact with the relevant agencies to learn their concerns
and requirements;
- determine how cooperation can best be achieved;
- prepare a project schedule that coordinates agency requirements
and EA milestones, and
- maintain contact to ensure that cooperation continues.
LINKAGES
Initiation may be the most important element of the EA process. At this
time, commitments are made to support (philosophically and financially)
consideration of the environment in decisionmaking. Tentative alternatives are
generated and the level of EA is determined. These activities influence the
makeup of the EA team, the assessment effort, and the documentation required.
Integration of the early stages of EA with the feasibility discussions and planning
for proposed actions results in more effective compliance with environmental
standards; improvements in the design and siting of construction projects; savings
in capital and operating costs; speedier approval of development applications; and
the avoidance of costly adaptations to projects once in operation (Lee 1988).
REFERENCES
Bear, D. 1987. Does NEPA make a difference. In: Environmental Impact
Assessment, Proceedings of a Conference on the Preparation and Review
of Environmental Impact Statements, West Point, New York. New York
State Bar Association, One Elk Street, Albany, New York 12207.
329 pp.
Canter, L. W. 1991. Interdisciplinary teams in environmental impact
assessment. Environmental Impact Assessment Review 11: 375-387.
Environmental Law Institute. 1989. NEPA Deskbook. Environmental Law
Institute, Washington, D.C. 438 pp.
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European Economic Community. 1985. Council Directive on the Assessment
of the Effects of Certain Public and Private Projects on the Environment.
85/337/EEC. Official Journal of the European Communities, No. L 175,
S.7.85. pp. 40-48.
Kirsch, P. J., and C. M. Rippy. 1991. Defining the scope of alternative in an
EIS after Citizens Against Burlington. Environmental Law Reporter 12
ERL 10701-10710.
Lee, N. 1988. Training requirements for environmental impact assessment. In:
Environmental Impact Assessment. Theory and Practice (ed. P.
Wathem). Unwin Hyman, Boston. 332 pp.
Stein-Hudson, K.E. 1987. How local and regional public participation affect the
EIS process. In: Environmental Impact Assessment, Proceedings of a
Conference on the Preparation and Review of Environmental Impact
Statements, West Point, New York. New York State Bar Association,
One Elk Street, Albany, New York 12207. 329 pp.
U.S. Forest Service. 1989. Litigation Support Handbook 1509.21, Region 2,
Supplement 3. Denver, Colorado.
Yost, N. C. 1987. One project-one process: an applicant's perspective on
coordinating the EIS process at the federal and state level. In:
Environmental Impact Assessment, Proceedings of a Conference on the
Preparation and Review of Environmental Impact Statements, West Point,
New York. New York State Bar Association, One Elk Street, Albany,
New York 12207. 329pp.
2-11
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2-12
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Section 2.1
Identification of Issues
Issues are unresolved concerns or questions, often about the environmental
consequences of proposed activities, that have societal significance. They are
usually raised during scoping and document review by interested or affected
individuals, groups, organizations or agencies that value a certain resource. The
identification of issues early in the planning process helps to limit the scope of
EA to potentially significant impacts, relevant concerns, and workable, acceptable
solutions to problems that are useful to the decisionmaker and the project planner.
To be meaningful and effective, EA must be relevant to regulatory needs and
public concerns as well as scientifically valid.
Although issues are mostly project-specific, public concerns with
environmental matters generally fit into the following categories (FEARO 1986,
Beanlands 1988):
• impacts on human health and safety;
• threats to livelihood (e.g., loss of important commercial species or
commercially available production; concern for habitat losses
which represent a foreclosure on future production);
• life-style modifications (e.g., loss of home or changes in life style
due to visitors or new residents with different values);
• threats to valued resources (e.g. recreational, aesthetic,
educational, scientific and historic features, and the preservation
and conservation of biological populations, communities, and
natural areas);
• land-use conflicts (especially when available land is limited and the
proposed uses are mutually exclusive); and
• supply and demand (i.e., when there are perceived imbalances
between supply and demand of resources and their development
within a local, regional or national context).
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NEEDS
Clear purpose and need statements (Attachment 2.A), project
descriptions, tentative alternatives, and known potential
environmental impacts and mitigation measures, so that the publics
and agencies understand the proposed action and can participate in
scoping and document review in a meaningful way.
Distribution of project information to interested/affected publics
and agencies.
Public and agency participation in scoping meetings.
Identification early in the EA process of the valued environmental
components so that the assessment is focused on the important
issues and the assessment endpoints necessary for impact analysis
can be determined.
TOOLS
The use of checklists can help the proponent and the EA team
identify potential impacts and issues associated with a proposed
activity (Attachment 2.B; also Chapter 4.1 and 4.2).
Public involvement is necessary to determine the social relevance
of environmental issues (i.e., the value placed on the change by
different affected groups). If a component has little public value,
it may not warrant extensive effort in the assessment. However,
there can also be issues of interest to other governmental agencies
or issues of scientific and ecological/environmental importance that
must be resolved but which may not elicit public interest.
In addition to techniques for communicating with the public listed
in Table 2-1, the proponent should solicit input from appropriate
professionals and other government agencies. Surveys,
questionnaires, and brainstorming sessions can provide
opportunities for identification of issues.
Use of the following questions will help to focus the issues and
impacts:
Who is interested in the issue and what are the chief
concerns?
What is the threshold of concern (i.e., the point at which
an impact becomes unacceptable)?
If possible, determine the threshold of concern (i.e., a maximum
or minimum number or other value for an environmental impact
or resource use which, if exceeded, causes it to take on new
importance) in terms of the following criteria:
magnitude [the probable severity of each potential impact
(e.g., degree, extent, or scale)];
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prevalence (relation to cumulative impacts);
duration and frequency (long-term, short-term, recovery
during inactive periods);
risks (probability of environmental effects); and
precedent (does the project create a precedent that is likely
to be duplicated or extended elsewhere?).
ISSUES
• Lack of public understanding of the proposed action and its
potential environmental impacts.
• Care should be taken that issues identified during scoping are not:
too broad to be useful for analytical purposes (e.g., cultural
impacts - what does this mean? What are the impacts that
should be examined?);
causes rather than issues (e.g., oil and gas development is
a cause that fails to go beyond the obvious to the specific
effects that are of concern); and
outside of agency control (e.g., mandated by legislation).
• Once issues are identified, the proponent must refine broad general
topics and specify which issues need analysis and evaluation,
eliminate from detailed study those issues that are not significant,
and identify those issues that have been covered by prior
environmental review.
• Often an issue is not clearly stated and it is difficult to determine
the underlying concern or question. As a result the document may
not address a relevant issue and the adequacy of the document is
open to challenge.
• Characterization and analysis of issues is often difficult because
baseline data are lacking and the degree of uncertainty is high.
LINKAGES
Early identification of important issues during initiation and scoping gives
direction to EA and allows more focused efforts. However, the potential exists
for new or additional information to become available throughout the EA process
(i.e., assessment, decisionmaking. and post-decision analysis): thus, new issues
may need to be addressed at any time.
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REFERENCES
Bardwell, L. V. 1991. Problem-framing: a perspective on environmental
problem-solving. Environmental Management 15:603-617.
Beanlands, G. 1988. Scoping methods and baseline studies in EIA. In:
Environmental Impact Assessment: Theory and Practice
(ed. P. Wathern). Unwin Hyman, Boston 332 pp.
FEARO (Federal Environmental Assessment and Review Process). 1986. Initial
Assessment Guide. Federal Environmental Assessment Review Office,
Ottowa, Canada. 36 pp.
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Section 2.2
Generation of Alternatives
United States federal regulations require analysis of reasonable alternatives
to a proposed action, including the option of not proceeding with any action at all
(the "no action" alternative) (Part D). This is considered the heart of EA because
it organizes and clarifies choices available to the decisionmaker and presents the
consequences of each choice. The description of the no action alternative
provides a baseline of information on the present and future environment for
comparing and contrasting the impacts of the proposed action among other
alternatives (see Chapter 4.1 for baseline information).
Preliminary alternatives are generated at the initiation stage by the
proponent. These are included in the environmental information packet that is
prepared for distribution at scoping meetings and elsewhere. Additional
alternatives may be generated by the public, NGOs and other governmental
agencies during scoping and at other stages of the EA process (e.g., document
review). Alternatives can be different ways of accomplishing the purpose and
need (i.e., alternatives & a project such as conservation, recycling, new or
different technologies) or different ways of accomplishing the proposed action
(i.e., alternatives within a project such as options for siting, scaling, phasing,
timing of construction and operation; mitigation, use of resources, management
of residuals).
NEEDS
• A clear description of the purpose and need for the proposed
action in order to identify and bound reasonable alternatives
(Attachment 2.A).
• A description of the proposed action, its potential impacts, and any
known related issues.
• Relationship of the proposed action to other known or reasonably
foreseeable actions (projects, programs, policies) including possible
cumulative effects.
• Any policy, programmatic, legal, regulatory or other constraint to
the proposed action.
• A list of the alternatives considered during the preparation of the
proposal.
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TOOLS
• A no action alternative as a benchmark against which to compare
and contrast the anticipated effects of the proposed action among
other alternatives.
• Intra-agency consultation to generate preliminary alternatives.
• Scoping meetings and interagency consultation to generate other
alternatives.
• A screening procedure to reduce alternatives to a reasonable
number that are practical, feasible and representative of the
complete array of viable alternatives.
ISSUES
• Generation of preliminary alternatives should occur as soon as the
purpose and need are established so that planning to select the
proposed action does not bias the choice of alternatives.
• Reasonable alternatives include those that are practical or feasible
from the technical and economic standpoint and using common
sense, rather than simply desirable from the standpoint of the
. proponent.
• Reasonable alternatives are not limited to the jurisdiction of the
proponent.
• The alternatives should offer substantive choices.
• All reasonable alternatives, including the preferred alternative,
should be given equal treatment in EA documentation.
Identification of a preferred alternative provides a focal point for
commentary by other organizations and the public. Moreover, it
is required by U.S. federal regulations (Part D).
LINKAGES
The generation of preliminary alternatives starts during the initiation stage
of a proposed action. Additional alternatives are generated during scoping and
may even be identified during the analysis and decisionmaking stages of EA. In
general, after scoping there is agreement on the alternatives to be evaluated in the
EA document. Documentation is prepared for those alternatives eliminated from
detailed study, including the reasons for their elimination.
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ATTACHMENT 2.A
PURPOSE AND NEED
• Introduction: Defining the Purpose of and Need for a Proposed Action
• Schmidt, 0. L. 1988. The statement of underlying need defines the range of
alternatives in environmental documents. Environmental Law 18:371-381.
• Kirsch, P. J., and C. M. Rippy. 1991. Defining the scope of alternatives in an EIS
after Citizens Against Burlington. Environmental Law Reporter 21:10701-10710.
2.A-1
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2.A-2
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Introduction: Defining the Purpose of and Need for a Proposed Action
In the United States, an EIS must briefly specify the underlying purpose and need to
which an agency is responding in proposing alternatives, including the proposed action. The less
detailed U.S. NEPA document (i.e., an environmental assessment) must have a statement of
underlying need, but need not have a statement of purposes.
Webster defines need as the lack of something requisite, desirable, or useful or a
condition requiring relief. Purpose is defined as an object or end to be achieved. Consequently,
the two terms should be seen as complimentary. The EIS discussion of purpose and need should
demonstrate that the purpose of a proposed action is to attain or achieve at least part of the
underlying need for the proposed action (Kirsch and Rippy 1991).
The CEQ regulations and most U.S. agencies do not distinguish between purpose and
need and the terms are used together and separately in NEPA documents. Such flexibility is
considered desirable because of the widely disparate nature of agency activities to which the
CEQ regulations apply. However, lack of distinction in agency statements of purpose and need
can lead to litigation (Attachment 2.A).
Both the CEQ regulations and case law recognize that it is the statement of need that
defines the scope of alternatives in an EIS (Kirsch and Rippy 1991). If the need for an action
is defined too broadly, the number of alternatives that might require analysis could be limitless.
For example, a Department of Interior EIS defined the underlying need for the issuance of oil
and gas leases in the Gulf of Mexico as the need to meet the Nation's energy crisis.
Subsequently, as a result of Natural Resources Defense Council, Inc. v. Morton, the court
required the agency to consider all reasonable ways to meet the energy crisis in their EIS
(including eliminating oil import quotas, developing oil shale, tar sands and geothermal
resources, desulfurizing coal, and coal liquefaction and gasification) even though the agency did
not have the authority to implement all of the alternatives.
On the other hand, it is inappropriate in most situations, to define the underlying need
so narrowly that only the proposed action is applicable. For example, if a site needs to perform
laboratory analyses within 24 hours of water sampling in order to meet quality assurance
procedures, an inappropriate statement of need would be that the agency needs to construct a
new onsite laboratory. A new onsite laboratory is but one way of meeting the agency's need;
other alternatives might include expansion of existing onsite, facilities or use of nearby off site
facilities.
In general, it is useful to think of the purpose of the proposed action as one way to
satisfy the underlying need for the action. The statement of need should be an objective
description of the reason that the proposed action is being pursued (Kirsch and Rippy 1991).
The statement of purpose follows from the statement of need. It can be a subjective statement
2.A-3
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that refers to the agency's mission, reflects the limits on the agency's statutory authority,
explains how the proposed action satisfies the need, and justifies the decision to choose the
preferred alternative (Kirsch and Rippy 1991).
2.A-4
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TrlHf STATEMENT OF UNDERLYING NEED
DEFINES THE RANGE OF ALTERNATIVES IN
ENVIRONMENTAL DOCUMENTS
BY
OWEN L. SCHMIDT*
. . L INTRODUCTION
We propose to build a dam because we need a dam. We pro-
pose to cut trees because we need to cut trees. We propose to drill
wells because we need to drill wells. We propose action because
we need action.
This simple logic may satisfy the unenquiring, but probing
minds want to know the underlying reason action is proposed.
Without knowing why action is needed, we cannot know what
other ways we might have to meet those needs, or what would
happen if we did not meet those needs. We cannot know if any
action at all is really needed.
When Federal agencies propose to take action, we expect an
explanation of what action is proposed, what need would be met
by taking that action, what alternative actions would also meet
that need, and we expect to see a comparison of the alternatives
alongside the proposed action.'In short, this is the decision mak-
ing process that was perhaps envisioned by the National Environ-
mental Policy Act (NEPA)1 and its implementing regulations.*
Are Federal agencies fulfilling this vision?
II THE UNDERLYING PURPOSE AND NEED
Environmental impact statements (EISs) must include a
brief statement of "the underlying purpose and need to which the
agency is responding in proposing the alternatives including the
• Attorney, Office of General Counsel, Bonneville Power Administration
(BPA), Portland, Oregon; J.D. 1977, Northwestern School of Law of Lewis &
Clark College; B.A. 1969. St Cloud State University; M.A. 1973, St Cloud State
University. The views expressed here are those of the author, and not necessarily
those of BPA, the United States Department of Energy, or the U.S. Government
1. 42 U.S.C. |i 4321-4370 (1982).
2. 40 C.F.R. || 1900-1508 (1987).
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ENVIRONMENTAL LAW
[V.
proposed action."* These few words have great impact on the con-
tents of an EIS, but the Council on Environmental Quality (CEQ)
does not elaborate on what it meant by the words "underlying
purpose and need."
Maybe CEQ meant a single statement of "purpose and
need," using two words to express the concept when one might
have been enough, or maybe CEQ meant two statements, one for
"purpose" and one for "need." CEQ does not say what it meant4
The two words have different meanings. A "need" is the lack
of something requisite, desirable, or useful, or a condition requir-
ing supply or relief.' Purposes, on the other hand, are goals, or
ends to be attained.' Thus if we give these two words their literal
meanings, a statement of underlying purpose and need will actu-
ally have two parts: needs (lack of something wanted, presence of
something not wanted), and purposes (goals, ends to be attained).
The words are not synonyms. A need is not a purpose, and a
purpose is not a need. If use of both words was intentional, then
Federal agencies must write a "purpose and need" statement in
two parts. If use of both words was in any way unintentional,
then Federal agencies may have more latitude in how they pre-
pare this section of an EIS.
I suggest that whether or not use of two words was inten-
tional, purposes and needs are different elements of an EIS. Fed-
eral agencies should write a statement of needs, and a statement
of purposes. Each has its place in the decision making process. If
agencies do that, their EISs will take on a structure like that
presented in this article.
3. 40 C.F.R. | 1502.13 (1987).
4. See CEQ, Forty Most Asked Questions Concerning CEQ's National Envi-
ronmental Policy Act Regulations, 46 Fed. Reg. 18.026 (1981) (hereinafter Forty
Questions). This document's title is self-explanatory; however, it does not address
or explain the "underlying purpose and need" requirement.
5. "Needs" is defined as "2a: a want of something requisite, desirable, or use-
ful;" and "3: a condition requiring supply or relief." A "need" can be seen as the
lack of something wanted, or the presence of something unwanted. WEBSTER'S
THIRD New INTERNATIONAL DICTIONARY (1971).
6. "Purposes" is defined as "an object to be attained: an end or aim to be
kept in view in any plan, measure, exertion, or operation." Id. Thus a "purpose"
can be seen a* a goal to be attained, perhaps while seeking to satisfy an underlying
need.
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1988] ENVIRONMENTAL DOCUMENTS 373
IIL A PROPOSAL FOR ACTION TO MEET AN UNDERLYING NEED
The NEPA process starts with a proposal for action/ A pro-
posal for action starts with an underlying need.
The CEQ's regulation on underlying need seems to suggest
that needs come first—"the underlying purpose and need to
which the agency is responding in proposing the alternatives in-
cluding the proposed action." Agencies respond to needs. Needs
come first, then agencies respond to them by proposing action.
What action? Action that somehow meets the underlying
need. Action that supplies something that is lacking, or takes
away something that is not wanted.
! There is no rule that the action must completely meet the
underlying need,' or be the only way to meet the underlying need,
'or even be the best way. The rule is that there must be some sort
of relationship between the proposed action and the underlying
need.
For example, a Federal agency proposes to build a dam.
Why? Flood control, power, and recreation. Is this the correct
statement of underlying needs? It may be. If it is established that
there are floods, then there may be a condition requiring relief.
' That would be the correct definition of an underlying need.
Whether there is also a need for power and recreation requires
further proof. If it can be established that there is a need for
power, then the proposal to build a dam meets two underlying
needs—flood control and power. And for recreation, if there is a
condition requiring relief, building a dam may meet three needs.
But if there is no "need" for power or recreation, the needs may
become "purposes"—goals to be attained while building a dam to
meet the need for flood control.
7. "An agency shall commence preparation of an environmental impact state-
ment as close as possible to the time the agency is developing or is presented with
a proposal... so that preparation can be completed in time for the final state-
ment to be included in any recommendation or report on the proposal" 40 C.F.R
| 1602.5 (1987).
8. "(TJhe EIS must nevertheless consider such alternatives to the proposed
action as may partially or completely meet the proposal's goal and it must evalu-
ate their comparative merits." Natural Resources Defense Council v. Callaway,
524 F.2d 79.93 (2d Cir. 1975). The case uses the word "joaT rather than "under-
lying ne^fet tfc* concept is the same.
37.4
ENVIRONMENTAL LAW
(VoL 18:371
Thus there is established a structure for preparing EISs: a
proposed action (build a dam), to meet an underlying need (flood
control), while achieving other purposes (power and recreation in
this example).
IV. ALTERNATIVE WAYS TO MEET THE NEED
Nothing better characterizes the NEPA process than the de-
velopment of alternatives. But which alternatives? The proper al-
ternatives in an EIS are alternative ways to meet the underlying
need.*
Take the above example of a proposal to build a dam to meet
the underlying need for flood control. What are other ways to
meet the underlying need? Perhaps an upstream program of lev-
ees, weirs, and vegetation management would also control floods.
Perhaps a number of smaller upstream dams would work. There
may be other ways.
But what if there were also a need for power? Then would
any of these alternatives still work? Probably not Levees and up-
stream vegetation management are not alternative ways to meet
the underlying need for power. Thus a Federal agency defines the
range of alternatives in an EIS by defining the underlying need.
When the underlying need is for both flood control and power,
only a dam will meet that need and the range of alternatives may
become very narrow.
Take the case of City of New York v. United States Depart-
ment of Transportation.19 The Department of Transportation
(DOT) proposed to regulate the highway transport of radioactive
materials. The underlying need to which DOT was responding
9. The "rule of reason" for the range of alternatives is well known. See, e.g.,
Vermont Yankee Nuclear Power Corp. v. Natural Resources Defense Council, 435
U.S. 519, 551 (1978). Thus only "reasonable" alternatives are required. CEQ de-
fines the kinds of alternatives required within the scope of an EIS as the no action
alternative, other reasonable courses of action, and mitigation measures not in the
proposed action. 40 C.F.R § 1508.25(b) (1987). These rules are entirely consistent
with each other. The "no action alternative" is defined in this article as "the alter-
native of not meeting the need." "Other reasonable causes of action" are other
reasonable ways of meeting the underlying need. "Mitigation measures" are a spe-
cial class of alternatives and can be added to an EIS without conflicting with the
range of alternatives responding to the underlying need.
10. 715 F.2d 732 (2d Cir. 1983), cert, denied, 466 US. 1055 (1984).
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ENVIRONMENTAL DOCUMENTS
375
was the need fpr Federal regulation for safe highway routing of
radioactive materials. The City of New York criticized DOT's
rulemaking and urged DOT to consider barging radioactive
materials around the city as an alternative to highway transport."
Is barging an alternative to highway transport? Yes, of course it
is. But is barging an alternative way to meet the underlying need?
No:
The scope of alternatives to be considered is a function of how nar-
rowly or broadly one views the objective of an agency's proposed
action. In this case, for example, if DOT's objective is to improve
the safety of highway transportation of radioactive materials, rele-
vant alternatives might include a choice of routes, a choice of
equipment, and a choice of driver qualifications. If DOT is con-
cerned more broadly with all transportation of these materials, it
might consider alternative modes of transportation. If the objective
is viewed still more broadly as reducing the hazards of radiation
exposure, the Department might consider alternative sources of
power that could reduce the generation of spent nuclear fuel."
The court used the word "objective" rather than "underlying
need," but the concept is the same--the range of alternatives is
defined by the statement of underlying need. Barging is not an
alternative to highway safety, although it would be an alternative
to highway transport DOT need not have considered barging ra-
dioactive materials around New York as an alternative in its envi-
ronmental document" because it was responding to the need for
safe highway transport of radioactive materials, not to the need
for transportation of some kind.
There are very few cases making this point. In Natural Re-
sources Defense Council, Inc. v. Morton,14 the Secretary of the
11. "Throughout the rule-making process, the City of New York was a vocal
critic of DOTs proposals and repeatedly urged DOT to broaden the scope of its
inquiry and to consider barging as an alternate means of transporting large-quan-
tity shipments of radioactive materials around urban centers that lack circumfer-
ential highways." City of New York v. United States Dep't of Transp., 715 F.2d at
739.
12. Id. at 743.
13. It is not relevant here that DOT had prepared an Environmental Assess-
ment (EA) rather than an EIS. The court was not construing 40 C.F.R. 5 1502.13,
which pertains only to EIS*. The point is the same whether agencies prepare EAs
or EIS*.
14. 458 F.2d 827 (D.C. Clr. 1982).
376
ENVIRONMENTAL LAW
[V,
Interior prepared an EIS prior to issuing Gulf of Mexico oil and
gas leases. The underlying need to which the Secretary was re-
sponding stemmed from the problem of the energy crisis of the
early 1970s. Other ways to meet the need included eliminating oil
import quotas, developing oil shale, tar sands, and geothermal re-
sources, desulfurizing coal, and coal liquefaction and gasifica-
tion.1' Even though it was beyond the Secretary's jurisdiction to
change the oil import quota or implement the other alternatives,
the court required these alternatives in the Secretary's EIS, not-
ing that the level of detail needed for some kinds of alternatives
might be affected by "the needs to which the underlying proposal
is addressed."1' Once Interior had defined the underlying need as
the need to meet the nation's energy crisis, all reasonable ways to
meet the energy crisis had to go into the EIS. Those that were
less reasonable could perhaps be described in less detail.
In Izaak Walton League of America v. Marsh," an EIS on a
Corps of Engineers' proposed replacement lock and dam was held
adequate even though it did not include a rehabilitation alterna-
tive because that alternative would not meet the underlying need
for expanding the lock and dam, did not include a railroad alter-
native because that alternative would not meet the need for more
safety at the lock and dam, and did not include the alternative of
controlling congestion at the existing lock and dam because that
alternative would not meet the need for expanding the capacity of
the waterways system." "It would certainly be a waste of agency
resources to test the efficiency of an alternative which is not only
beyond the agency's power, but also incapable of either fully solv-
ing the problem at hand or fulfilling the mandate of Congress.""
15. Id. at 834, 836-37.
16. Id. at 837-38.
17. 655 F.2d 346 (D.C. Cir.), cert, denied sub. nom. Atchison, T. & S.F. Ry. v.
Marsh. 454 U.S. 1092 (1981).
18. Id., 644 F.2d at 372-74.
19. Id. at 374. The court is apparently adding three criteria to the proper
range of alternatives: (1) the alternative must be within the agency's power, (2)
the alternative must be "fully capable of solving the problem .at hand," and (3)
the alternative must fulfill the mandate of Congress. Even partial solutions may
be a reasonable alternative. See Natural Resources Defense Council v. Callaway,
524 F.2d 79, 93 (2d Cir. 1975) ("[T]he EIS must nevertheless consider such alter-
natives to the proposed action as may partially or completely meet the proposal's
goal and it must evaluate their comparative merits."). As to being within the
agency'* power and fulfilling the mandate of .Congress, BIS* must include alterna-
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1988]
ENVIRONMENTAL DOCUMENTS
377
In Trout Unlimited v. Morton,*0 the court upheld the range
of alternatives in an EIS on a proposed dam project. Of the need
for flood control, the alternative of levees was considered. Of the
need for irrigation water, the alternative of groundwater pumping
was considered. "The range of alternatives that must be consid-
ered need not extend beyond those reasonably related to the pur-
poses of the project."*1 The court used the term "purposes" of the
project rather than "underlying needs," but the concept is the
same.
Thus the structure of an EIS continues with the added twist
that it is not alternatives to the proposed action that must be
analyzed in an EIS, but alternative ways to meet the underlying
need. If a particular alternative does not meet the need very well,
or is otherwise not very reasonable, it might be analyzed in less
detail
V. No ACTION—Nor TO MEET THE NEED
A "no action" alternative is required in EISs.** Many EISs
treat the no action alternative literally as "not taking the pro-
posed action." If the. proposed action is to build a dam, the no
action alternative may be treated simply as not building a dam.
The impacts of not building a dam are then treated as not flood-
ing farmland, not relocating displaced landowners, not building
access roads, etc.
A more insightful approach would be to treat the no action
alternative as not meeting the need. In our example, there is a
need to control floods. What would happen if the need were not
met? Continued floods! What is the impact of continued floods?
lives outside the mandate of Congress and agency's statutory authority. See Natu-
ral Resources Defense Council v. Morton, 458 F.2d 827, 835 (D.C. Cir. 1972)
("While the Department of Interior does not have the authority to eliminate or
reduce oil import quotas, such action is within the purview of both Congress and
the President, to whom the impact statement goes"). The better rule would be
that none of these criteria are valid reasons to leave an alternative out of an EIS
entirely, but these factors may affect the level of detail to which the alternatives
are analyzed.
20. 509 F.2d 1276 (9th Cir. 1974).
21. Id. at 1286.
22. 40 C.F.R. § 1508.25(b)(2) (1987). CEQ does provide guidance on this in
"Forty Most Asked Questions." See Forty Questions, tupra note
4, at 18
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ENVIRONMENTAL LAW
[VoL 18:371
And what is the impact of the proposed dam? With this analysis,
decision makers, and the public, would have before them the true
difference between building and not building the dam.
One court has acknowledged this approach. In Trout Unlim-
ited v. Morton, above, the Ninth Circuit upheld an EIS which
"considered the alternatives of (1) no development whatsoever
(the alternative of not accomplishing the project's purposes),"*'
but the court did not elaborate. CEQ has also acknowledged this
approach. "'No action* . . . would mean the proposed activity
would not take place, and the resulting environmental effects
from taking no action would be compared with the effects of per-
mitting the proposed activity or an alternative activity to go for-
ward."*4 Following CEQ's advice, an agency would analyze the
impacts of not meeting the need rather than simply not taking
the proposed action.
VI. PURPOSES BECOME DECISION FACTORS
A troublesome part of this model is to distinguish "needs"
from "purposes." A handy rule of thumb is that needs have alter-
natives and purposes do not. In other words, agencies develop
reasonable alternative ways to meet needs, but not purposes.
Purposes are those collateral decision factors that help sort
out the alternatives. For example, if an agency presented four al-
ternatives in an EIS—each equal in every respect except that one
was cheapest—and if one of the agency's purposes was to save
money, then the cheapest alternative would be favored by that
decision factor. In our earlier example, the underlying need was
to control floods. Alternatives included levees and vegetation
management. If one of the agency's purposes were to provide rec-
reation, then the alternative that had the best recreation benefit
would be favored by that factor in the decision making process. In
our example, building the dam would probably provide the best
recreation benefits and the proposed action would thus be favored
by thia purpose.
Purposes appear in two places in the decision making pro-
cess: in the "purpose and heeds" section of the EIS** and again in
23. 509 F.2d at 1286.
24. 46 Fed. Reg. 18027, March 23,1981.
25. 40 C.F.R. | 1602.13 (1987).
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ENVIRONMENTAL DOCUMENTS
379
the Record of Decision (ROD).1' The CEQ regulations do not say
that purposes appear in a ROD, but decision factors must be
disclosed:
An agency may discuss preferences among alternatives based on
relevant factors including economic and technical considerations
and agency statutory missions. An agency shall identify and discuss
all such factors including any essential considerations of national
policy which were balanced by the agency in making its decision
and state how those considerations entered into its decision."
The logic for tying "purposes" in an EIS to "decision factors" in
the ROD is threefold. First, the ROD should be based on the rec-
ord before the agency. In many agency proceedings, the EIS is
perhaps the only record created prior to the decision, and so the
EIS is the best place if not the only place to put matters that are
relevant to the decision. Second, there may be acute public
awareness of and interest in the pending decision. Disclosure of
all relevant decision factors in the EIS—long before they are dis-
closed in the ROD—serves as public notice and invites comments
o& decision factors that may affect the public. Third, putting
these factors into the EIS paves the way for those who follow to
write the ROD. The eleventh decision making hour, when ROD
writers are hard at work, is not the best time to start listing the
relevant decision making factors.
Thus the structure of an EIS continues with the decision fac-
tors—as they will ultimately be used in the ROD—being dis-
closed in the purpose and need section.
VII SPECIAL RULES FOR ENVIRONMENTAL ASSESSMENTS (EAs)
EAs must have a statement of underlying need, but need not
have a statement of purposes: "Environmental Assessment . . .
[s]hall include brief discussions of the need for the proposal
. . ."*• Why did CEQ leave "purposes" out of EAs? A simple ex-
planation, consistent with the model described above, is that for
EISs, purposes are only relevant at the time of preparing the
ROD. Because EAs are not followed by RODs,*' there is no rea-
26. 40 C.F.R. | 1608.2 (198^.
27: 40 C.F.R. | 150S.2(b) (1987).
28. 40 C.FJL | 160&9(b) (1987).
29. CEQ regulations only require RODe in cases where ElSe are prepared. 40
380
ENVIRONMENTAL LAW
son to put purposes into EAs. In other words, purposes are rele-
vant at the time of decision as decision factors. Decision factors
must be disclosed in RODs. RODs are not required in cases where
EISs are not prepared. Thus the reason purposes are required in
EISs is simply not present when an EA is prepared.
Agencies may choose to prepare RODs following EAs, and
thus should put purposes into EAs as well as EISs. In any event,
at the time of decision, when decision makers are balancing all
relevant factors, the record should disclose somewhere what deci-
sion factors—underlying purposes—the agency was responding to.
VHL A CHECKLIST FOR THE PURPOSE AND NEED STATEMENT
The statement of proposed action and underlying need can
never be the same. "We propose to build a dam because we need
a dam" is not a proper statement of underlying need; it is just a
repetition of the proposal, and in any event it is hot analytic.
The reasonable alternatives to be presented in an EIS are
the reasonable ways to meet the underlying need. Alternatives
that do not meet the need can in some cases be eliminated from
study and hi other cases be analyzed in less detail. The proper
question is not "What alternatives are there to this proposal,"
but "What alternatives are there to meet this underlying need.'1
Needs are distinguished from purposes by the fact that
needs have alternative solutions, but purposes do not. For exam-
ple, saving money is nearly always an agency objective. But agen-
cies do not usually engage in decision making processes for the
sole purpose of saving money. Normally agencies apply the factor
of cost savings when deciding between alternative ways to meet
an underlying need.
Purposes are goals to be attained while meeting the under-
lying need, and become decision factors at the time of making
the decision. Decision factors conveniently fall into three catego-
ries: economic, technical, and environmental. The choice between
alternatives often requires a balance between these factors.
"No action" means not to meet the need. There is very little
CJMt { 1505.2 (1987) ("At the time of its decision . . . each agency shall prepare
• concise public record.of decision"). This section only applies to cesee where an
EIS is prepared.
-------
1988) ENVIRONMENTAL DOCUMENTS 381
analysis in defining the no action alternative simply as not to take
action. A better perspective comes from analyzing the alternative
of not meeting the need.
Agencies are free to define the underlying need to which
they are responding, subject to judicial review under an as-yet-
undefined standard. The law in this area has not yet developed.
Agencies should expect, however, not to define arbitrarily or ca-
priciously an underlying need, and to show a rational connection
between proposed action, other alternative courses of action, and
the underlying need.
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12-91
ENVIRONMENTAL LAW REPORTER
NEWS & ANALYSIS
21 ELR 10701
ARTICLES
Defining the Scope of Alternatives in an EIS After Citizens
Against Burlington
by Peter J. Kitsch and Conrad M. Rippy
Editors' Summary: NEPA requires federal agencies to prepare ElSsfor major
federal actions that significantly affect the quality of the human environment.
EISs must discuss all reasonable alternatives to the proposed action. The
discussion ofalternatives is the heart of an EIS. In Citizens Against Burlington,
Inc. v. Busey, the D.C. Circuit appears to have narrowed the scope ofalter-
natives that a federal agency must consider when it issues a permit or other
federal approval This Arric't analyzes the case and proposes an interpretation
that would reconcile Citiwns Against Burlington with CEQ regulations and
NEPA case law on the scopeof alternatives.
In the recent case of Citizens Against Burlington, Inc. v.
Busey,' the D.C. Circuit interpreted the National Envi-
ronmental Policy Act (NEPA)1 and its requirement that
federal agencies, when preparing an environmental impact
statement (EIS), must consider all reasonable "alternatives
to the proposed action."1 On its surface, the opinion by
Circuit Court Judge Clarence Thomas4 appears to reject
both NEPA regulations and longstanding case law on the
proper scope of alternatives that an agency must consider
in an EIS. The opinion seems to sanction a narrower scope
of alternatives when a federal agency issues a permit or
other federal approval than when a federal agency is the
Peter J. Kirsch a an attorney with Cutler & Stanfield in Washington,
D.C His practice specialize* in federal environmental and land use law
and complex public sector negotiations. Conrad M. Rippy is a third-year
law student at the University of Virginia where he is Notes Editor of the
Virginia Law Review.
I. 938 F.2d 190, 21 ELR 21142 (D.C. Cur. 1991).
2. 42 U.S.C 55432M370a, ELR STAT. NEPA 001412.
3. NEPA 8102(2)(Q(iii). 42 U.S.C. }4332(2XCXiii). ELR STAT.
NEPA 003.
4. On October 15,1991. the Senate confirmed Clarence Thomas as an
Associate Justice of the U.S. Supreme Court.
Judge Thomas has not taken an overly friendly view of environ-
mental concerns in the oast For example, in Cross-Sound Ferry
Services. Inc. v. Interstate Commerce Comm'n, 934 F.2d 327 (D.C
Cir. 1991), Judge Thomas concurred in a judgment denying a NEPA
claim. Moreover, he would have denied sanding to the plaintiff,
arguing, contrary to the majority, that the national transportation
policy set forth at 49 U.S.C. {10101 could not be interpreted to
encompass environmental factors. Judge Thomas contended that
statutory language mandating efficient transportation "surely did
not mean to ... promote ecological consciousness-raising" or any
factors other than "the economics of transportation." Id. at 338.
Judge Thomas thus seems unwilling to consider environmental pro-
tection as an element of a cost-benefit equation.
Although he has not written any other significant environmental
principal proponent of a project This Article explores the
court's reasoning and proposes an interpretation of the case
that reconciles the apparent conflict between Citizens
Against Burlington and 20 years of case law defining the
proper scope of alternatives in an EIS.
NEPA requires that federal agencies prepare an EIS
on "major Federal actions significantly affecting the qual-
ity of the human environment."s The regulations of the
Council on Environmental Quality (CEQ), which form
the foundation for all other federal regulations under
opinions. Judge Thomas' basic indifference towards environmental
claims appears in other environmental cases in which he has sided
with the majority in denying claims based on federal environmental
laws. See, e.g.. National Wildlife Fed'n v. United States Envtl.
Protection Agency. 925 R2d 470. 21 ELR 20365 (D.C Cir. 1991)
(denying petition for review of a decision by EPA allowing states,
for limited time periods, not to comply with the Safe Drinking Water
Act); Tongass Conservation Soc'y v. Cheney, 924 F.2d 1137. 21
ELR 20558 (D.C Cir. 1991) (upholding as adequate the considera-
tion of a range of alternatives in an EIS prepared by the Department
of Defense for siting of a submarine base); Macht v. Skinner, 916
F.2d 13, 21 ELR 20.004 (D.C. Cir. 1990) (holding that neither
federal funding for an EIS for a light rail .vehicle project otherwise
entirely funded by the state of Maryland nor Army Corps of Engi-
neers issuance of a wetlands permit for a "negligible" part of the
project constitutes major federal action for the purposes of NEPA
or 54(0 of the Transportation Act); Hazardous Waste Treatment
Council v. United States Envtl. Protection Agency, 910 F.2d 974,
20 ELR 21359 (D.C. Cir. 1990) (denying a petition for review of
a Resource Conservation and Recovery Act "no migration" haz-
ardous waste disposal exemption). But see Linemaster Switch Corp.
v. United States Envtl. Protection Agency, 938 F.2d 1299.21 ELR
21359 (D.C. Or. 1991) (denying plaintiffs' petition for review of
decision by EPA to add hazardous waste sites owned by plaintiffs
to the national priorities list under the Comprehensive Environmental
Response, Compensation, and Liability Act).
5. NEPA }102(2XC), §4332(2XQ. ELR STAT. NEPA 003.
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21 ELR 10702
ENVIRONMENTAL LAW REPORTER
12-91
NEPA, * require that an EIS contain, among other ele-
ments, a statement of the purpose of and need for the
action,' and a discussion of alternatives to the proposed
action.' It is these two requirements that were at issue
in Citizens Against Burlington.
The requirement to analyze alternatives to a proposed
project is the heart of NEPA. It is absolutely essential that
an EIS contain "detailed and careful" analysis of the relative
merits and demerits of the proposed action and proposed
alternatives, a requirement which courts have characterized
as the "linchpin" of an EIS.9
Citizens Against Burlington v. Busey
Background of Toledo Airport Expansion EIS
Citizens Against Burlington arose from the approval by
the Federal Aviation Administration (FAA) of plans to
expand Toledo Express Airport near Toledo, Ohio. The
Toledo-Lucas County Port Authority sought to expand
Toledo Express Airport to accommodate plans by Burl-
ington Air Express to move its air cargo operation to
Toledo from Fort Wayne, Indiana. Toledo predicted that
Burlington's move would bring more than 1,000 jobs to
the city's depressed economy. As an incentive to attract
Burlington, the Port Authority proposed to enhance
Toledo Express Airport by constructing new facilities
and lengthening a runway and taxiways at the airport, all
of which required FAA approval. The Port Authority also
sought FAA funding for the expansion project.
One of the first steps in seeking FAA approval or funding
is the preparation of the required NEPA documentation on
the proposal. As required by FAA regulations,>0 the Toledo
Port Authority prepared an environmental assessment,"
which the FAA converted into an environmental impact
statement." The draft EIS generated considerable contro-
versy from both the public and the Environmental Protection
Agency." In its final EIS, under a subhead entitled "Need
for the Proposed Federal Action," the FAA explained that:
6. 40 C.F.R. {1507.1 (requiring all federal agencies to comply with
CEQ regulations).
7. Id. 91502.13.
8. Id. J1502.14.
9. Natural Resources Defense Council, Inc. v. Callaway, 524 R2d 79; •
92, 5 ELR 20640. 20647~(2ci <3r 197SJ (quoting Mo'iwoe Cooirty"
Conservation Soc'y, Inc. v. VblfSVKT? E2d 693, 697-98, 3 ELR '
20006. 20007 (2d Cir. 1972)).
10. See FED. AVIATION AOMIN., U.S DEP*T OF TKANSP., OIDEK
5050.4A, AIRPORT ENVIRONMENTAL HANDBOOK (1985) [hereinaf-
ter FAA ORDER 5050.4A]; FED. AVIATION ADMIN., U.S. DEP'T
OF TRANSP., ORDER 1050.ID. POLICIES AND PROCEDURES FOR
CONSIDERING ENVIRONMENTAL IMPACTS (1986).
11. FAA ORDER 5050.4A. supra note 10, pan. 43 et teq.
12. Id. at pan. 72 et seq.
13. See 55 Fed. Reg. 8983 (Mar. 9,1990) (EPA comments finding that
draft environmental impact statement was "inadequate to fully assess
all environmental impacts and therefore does not meet the purpose
and intent of NEPA" and that the project was "environmentally
unsatisfactory"). EPA comments on the draft EIS resulted in so
much intengency controversy that EPA was able to pressure the
FAA into signing a letter agreement over the manner in which
impacts for future airport expansions would be analyzed. Letter
from Barry Lambert Harris, Deputy Administrator, Federal Aviation
Administration, to F. Henry Habicht ID, Deputy Administrator,
Environmental Protection Agency (June 15,1990).
The purpose and need for this action lies in FAA's
responsibility to review the airport design and runway '
configuration with respect to its safety, efficiency and
utility within the national airspace system and its envi-
ronmental impact on the surrounding area.
The key item in this regard is the need for extending
Runway 7-25 to provide safe and adequate length
Another purpose and need for the proposed Federal
action is that FAA has a statutory mandate to facilitate
the establishment of air cargo hubs u
The FAA reviewed and dismissed several alternatives
before concluding that it had to consider in depth the en-
vironmental impacts of only two alternatives: the approval
of the airport expansion plan as proposed by Burlington
and the Port Authority, and the no-action alternative. The
FAA explained that
[wjith respect to this proposal for establishment of an air
cargo hub at Toledo Express Airport, the role of the FAA
in selecting alternatives is limited The FAA has
verified the need for the proposed project The FAA
has further reviewed the site selection process that Burl-
ington began in 1987..."
Following issuance of the EIS, the FAA approved the
proposed airport expansion in July 1990. "
Judge Thomas's Opinion on Review of the EIS
The petitioners in Citizens Against Burlington sought rej
view of the FAA's decision approving the Toledo expansion
plan on the grounds that the EIS impermissibly discussed
only the alternatives of approving the plan as proposed by
the Port Authority and the no-action alternative. Petitioners
argued that the FAA should have considered other alterna-
tives in detail, including the alternative of expanding Burl-
ington Air Express operations at its existing Fort Wayne,
Indiana, facility." Petitioners also raised a number of issues
relating to the adequacy of the EIS discussion of noise
impacts, to the scope of analysis required for compliance
with §4(f) of the Department of Transportation Act" and
§509(b)(5) of the Airport and Airway Improvement Act of
1982," and relating to NEPA conflict-of-interest rules,20
which are beyond the scope of this Article.
•MrFtor AVIATION ADMIN., U.S. DEP*T OF TRANSP., FINAL ENVI-
RONMENTAL IMPACT STATEMENT ON ESTABLISHMENT OF AIR
CARGO HUB, TOLEDO EXPRESS AIRPORT, TOLEDO, OHIO, at 1-3
(May 11,1990) [hereinafter TOLEDO EIS].
15. Id. at 2-1.
16. FED. AVIATION ADMIN., GREAT LAKES REGION, U.S. DEP*T OF
TRANSP., RECORD OF DECISION FOR TOLEDO EXPRESS AIRPORT,
TOLEDO OHIO (July 12,1990).
17. Brief for Petitioners, On Petition for review of a Decision of the
Federal Aviation Administration at 1, Citizens Against Burlington,
Inc. v. Busey. 938 F.24 190. 21 ELR 21142 (D.C. Cir. 1991)
[hereinafter Pet Br.J.
18. Section 4(0 of the Transportation Act of 1966 prohibits the FAA
from approving any project that uses protected parks, recreation or,
wildlife areas, or historic structures unless there is no prudent and!
feasible alternative to using the land and the project includes all"
possible planning to mitigate for harm to protected lands. 49 U.S.C.
J303(c).
19. The Airport and Airway Improvement Act is similar in language to
}4(f) of the Transportation Act but broader in scope in that it prohibits
FAA funding of a airport expansion project that "may have a
significant impact" on any environmental factor unless no feasible
-------
12-91
NEWS & ANALYSIS
21 ELR 10703
For the present discussion, it is important to understand
the issues on review as articulated in petitioners' brief. The
principal issue was the scope of alternatives in the EIS:
Whether the FAA has violated NEPA by relying on an
environmental impact statement which (a) fails to ana-
lyze the continuation of Burlington's operations in Ft
Wayne even though this is a feasible and reasonable
alternative..."
Petitioners argued at length that the FAA should have
considered the alternative that the Burlington Air Express
facility would remain at Ft Wayne, Indiana, * and criticized
the agency's assertion that legally it was limited in its action
to accepting or rejecting Toledo's application.M
The D.C. Circuit panel, with Judge James Buckley
dissenting, upheld the scope of alternatives in the EIS.
Writing for the majority. Judge Clarence Thomas under*
took a wide-ranging discussion of an agency's obligations
under NEPA to consider alternatives in an EIS.2* Noting
that the term "alternatives" as used in NEPA is not
self-defining," Judge Thomas observed that "[i]f... the
consideration of alternatives is to inform both the public
and the agency decisionmaker, the discussion must be
moored to 'some notion of feasibility.'" u Judge Thomas
explained that an alternative is reasonable—and must,
therefore, be analyzed in an EIS—"if it will bring about
the ends of the federal action."27 In other words, he
concluded, "[t]he goals of an action delimit the universe
of the action's reasonable alternatives." **
Court's Definition of Goals of Federal Action
The court started by explaining its standard of review: "the
agency... bears the responsibility for defining at the outset
the objectives of an action," * and the court will "uphold
an agency's definition of objectives so long as the objectives
that the agency chooses are reasonable." " Nevertheless,
an agency may not define the objectives of its action in
terms so unreasonably narrow that only one alternative
. . . would accomplish the goals of the agency's ac-
tion. ... Nor may an agency frame its goals hi terms so
unreasonably broad that an infinite number of alterna-
tives would accomplish those goals..."
and prudent alternatives exist and "all reasonable steps have been
taken to minimize" environmental impae**. «» u.S.C. app.
i22O8(bX5). This sun"* -fltcnv-tr repm-ej die FAA to implement
al! mias'nrw •«-
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21 ELR 10704
ENVIRONMENTAL LAW REPORTER
the FAA's goal in Toledo was to help fuel the Toledo
economy by launching a cargo hub at its airport.4I
Adequacy of Discussion of Alternatives
Having determined the agency's goals, the court proceeded
to explore whether the scope of alternatives in the EIS
appropriately reflected those goals. It concluded that the
FAA acted properly by evaluating the impacts only of the
proposal submitted by the Port Authority and by excluding
any other potential alternative. Strictly relying on the lan-
guage found in NEPA,42 the court explained that an agency
need examine only alternatives to the federal action, not
alternatives to the entire proposed project.41 Because a
federal permitting agency like the FAA often is limited
simply to granting or denying a permit, and has no sub-
stantive role in shaping the applicant's project. Judge Tho-
mas concluded that an EIS need not examine alternatives
to an applicant's proposal that lie outside the purview of
the federal involvement **
Citing Van Abbema v. Fornell,4* the petitioners argued
that the scope of alternatives must be defined as "alternative
means to accomplish the general goal of an action; it is not
an evaluation of the alternative means by which a particular
applicant can reach his goals."46 The court explicitly re-
jected the Van Abbema reference to "general goals," be-
cause of the difficulty of determining "how to distinguish
general goals from specific ones and just who does the
distinguishing."47 Arguing that Van Abbema implies that
the court should do this distinguishing. Judge Thomas dis-
agreed that this is a proper role for either the court or the
permitting agency.
An agency cannot redefine the goals of the proposal that
arouses the call for action; it must evaluate alternative
ways of achieving its goals, shaped by the application at
issue and by the function that the agency plays in the
decisional process. Congress did expect agencies to con-
sider an applicant's wants when the agency formulates
the goals of its own proposed action.
Without citing any authority for the proposition. Judge
Thomas concluded that the scope of alternatives in an EIS—
just like the definition of the agency's goals—properly
should depend on the "function that the agency plays in
the decisional process."49 With respect to such airport ex-
pansions as proposed at Toledo, the FAA's function gen-
erally is to "nurture aspiring cargo hubs" but not to "de-
termine the siting of the nation's airports." " Consequently,
the court concluded that the FAA had no business examining
alternative airport locations for the Burlington Air Express
41. See id at 198,21 ELR at 21146.
42. NEPA 5I02(2XQ, 42 U.S.C §4332(2XC). ELR STAT. NEPA 003
(an agency must examine "alternatives to the proposed action").
43. 938 F.2d at 199, 21 ELR at 21147.
44. Id.
45. 807 R2d 633.17 ELR 20429 (7th Or. 1986).
46. Id. at 638. 17 ELR at 20432 (emphasis in original); Pet Br., supra
note 17, at 21-22.
47. 938 R2d at 199,21 ELR at 21147.
48. Id. (emphasis in original).
49. Id.
50. Id. at 197.21 ELR at 21146.
cargo hub, once Burlington made clear its preference fj|
the Toledo location.
Judge Buckley's Dissent
Judge James Buckley dissented in part from the majority
opinion, on the grounds that the FAA impermissibly had
limited the alternatives in the EIS to the single alternative
in which Burlington Air Express had expressed an inter-
est. He saw a disparity between the majority view that
"would limit consideration of alternatives to those avail-
able" to the Toledo Port Authority," and the FAA's view
that it had to consider any reasonable alternative that was
available to either the Port Authority or Burlington Air
Express, the real beneficiary of the project." The dissent
faulted the FAA and the majority for their unquestioning
acceptance of assertions by both the Toledo Port Author-
ity and Burlington Air Express that Toledo Express Air-
port was the only airport suitable for the project. Instead
of testing these assertions, the FAA "simply accepted
Burlington's Toledo-or-bust' position," " notwithstand-
ing its obligation under NEPA to "exercise a degree of
skepticism in dealing with self-serving statements from
a prime beneficiary of the project." "
As Judge Buckley explained, the majority opinion leaves
the scope of an EIS in the hands of the beneficiary of a
federally permitted project. If the beneficiary claims that
one and only one project alternative is acceptable, then thdl
agency's EIS need only examine that proposal and the^
no-action alternative."
Implications of the Citizens Against Burlington Case
The plain language of Citizens Against Burlington suggests
two potentially far-reaching consequences. First, the court
appears to have held that an agency may accept the "needs
and goals" of a nonfederal applicant as the defining criteria
for its own "goals" or "objectives." Second, since the court
says that the range of alternatives properly is defined by
the federal agency's "goals" or "objectives," the scope of
alternatives in an EIS also should be defined by the appli-
cant's desires and the nature of the agency's role in the
decisionmaking process.
If these two propositions were accepted as the holdings
of Citizens Against Burlington, they would portend a
situation in which any applicant for a federal permit could
limit NEPA analysis to consideration of only the project
and no-project alternatives, merely by informing the per-
mitting agency that it would not consider modifications
to its project. Either proposition effectively eviscerates
51. Id at 207, 21 ELR at 21151.
52. Id. at 208.21 ELR at 21152 ("Burlington makes the demands that
define the project; Toledo enjoys the benefits that result").
53. Id.
54. Id. at 209.21 ELR at 21153. See Van Abbema v. Fbrnell. 807 F.2d '
633.642,17 ELR 20429,20434 (7th Or. 1986) (criticizing agency
for its "blind reliance" on information submitted by an applicant);
Trinity Episcopal School Corp. v. Romney. 523 F.2d 88,94,5 ELR
20497,20500 (2d Cir. 1975) (agency must determine for itself the
availability of alternatives).
55. 938 E2d at 209.21 ELR at 21153.
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12-91
NEWS & ANALYSIS
21 ELR 10705
the alternatives requirement in any EIS for a federally
permitted action.M
Acceptance of either proposition means throwing to the
wind almost 20 years of NEPA case law and CEQ guidance
in three fundamental respects. First, NEPA requires an
agency to examine all "reasonable" alternatives, without
reference to the agency's jurisdiction to implement the al-
ternative. " Second, both CEQ and the case law consistently
have held that the scope of alternatives in an EIS must
reflect only technical, economic, and common sense prac-
ticability. Third, both the regulations and case law are
highly critical of any EIS that relies on information and
analysis provided by an applicant and that has not been
evaluated independently by the federal agency."
56. Because the evaluation of alternatives is the "heart" of any envi-
ronmental impact statement, 40 C.F.R. 81502.14, and is the "linch-
pin" of its authority, Monroe County Conservation Council, Inc. v.
Volpe, 472 F.2d 693.697-98. 3 ELR 20006.20007 (2d Cir. 1972).
it is unclear how NEPA is to continue to fulfill its mission as
described by Congress: to "assure for all Americans safe, healthful,
productive, and aesthetically and culturally pleasing surroundings."
NEPA 8101(bX2), 42 US.C S4331(bX2), ELR STAT. 003.
57. 40CJ?.R.}1502.14(c)(anBSmustincIude"reasonablealtematives
not within the jurisdiction of the lead agency"); CEQ, MEMORAN-
DUM: QUESTIONS AND ANSWERS ABOUT THE NEPA REGULA-
TIONS, 46 Fed. Reg. 18026 (Mar. 23.1981). ELR ADMIN. MATE-
RIALS 35020, at Q. 2a (Mar. 17,1981) [hereinafter FORTY QUES-
TIONS]. ("In determining the scope of alternatives to be considered,
the emphasis is on what is 'reasonable' rather than on whether the
proponent or applicant likes or is itself capable of carrying out a
particular alternative"). See Methow Valley Citizens Council v.
Regional Forester. 833 F.2d 810. 815-16, 18 ELR 20163, 20165
(9th Cir. 1987) (exclusion of any viable but unexamined alternative
renders an environmental impact statement inadequate), rev'd on
other grounds tub nom. Robertson v. Methow Valley Citizens Coun-
cil, 490 US. 332, 19 ELR 20743 (1989); Van Abbema. 807 F.2d
at 638,17 ELR at 20432 (alternatives evaluation must be based on
the general agency goal for the action, not on the goals of the
applicant); Natural Resources Defense Council v. Morton, 458 F.2d
827,836,2 ELR 20029, 20033 (D.C Cir. 1972) (consideration of
alternatives must "permit a reasoned choice ... so far as environ-
mental aspects are concerned," and must include even solutions that
do not fully solve the problem before the agency); Sierra dub v.
Marsh, 714 F. Supp. 539. 577-78. 20 ELR 20216. 20235 (D. Me.
1989) (simply because an applicant "desires" certain features of a
project does not mean that an agency may exclude otherwise rea-
sonable alternatives from its NEPA analysis; instead, the agency
must look to the core goals of the project to define reasonable
alternatives); California ex rel. Van de Kamp v. Marsh, 687 F. Supp.
495.499.19 ELR 20165.20166 (N.D. Cal. 1988) (failure to consider
any alternative other than that submitted by the applicant excludes
from consideration some reasonable alternatives and thus violates
NEPA); Residents in.Protest—I-35E v. Dole. 583 F. Supp. 653.660
(D. Minn. 1984) (agency goals should not be so tailored to an
applicant's wishes that the agency goal is preordained).
58. See FORTY QUESTIONS, supra note 57, at Q. 2a ("Reasonable al-
ternatives include those that are practical at feasible from the tech-
nical and economic standpoint and using common sense, rather than
simply desirable- from the standpoint of the applicant") (emphasis
added); Sierra Club v. Marsh. 714 F. Supp. at 577,20 ELR at 20235
(a consideration of reasonable alternatives must have as its basis "a
rational relationship to the technical and economic integrity of the
project" beyond the desires of an applicant).
59. See. e.g.. Van Abbema. 807 F.2d at 642,17 ELR at 20432-33 (agency
failure to conduct an independent investigation of information sub-
mitted by an applicant in formulating an agency goal amounts to
"blind reliance" on such material and a violation of NEPA);Johnson
v. Davis. 698 F.2d 1088.1095 (10th Cir. 1983) (an agency may not
rely on information provided by another party without doing its own
research if there is a chance that such reliance would cause the EIS
to be misleading); Trinity Episcopal School Corp. v. Romney, 523
F.2J 88. 93-94. 5 ELR 20497. 20500 (2d Cir. 1975) (an agency
may not accept an applicant's "self-serving statements" that alter-
natives are limited; instead, the agency must examine all reasonable
It is possible to reconcile Citizens Against Burlington,
however, with both CEQ regulations and guidance" and
other NEPA cases addressing the scope of alternatives. To
do so requires examination of the meaning of the terms
"purpose" and "need" as they are used in the NEPA context
and an understanding of the contexts in which courts have
addressed the alternatives requirement of NEPA.
Importance of Defining Purpose and Need
This discussion must begin with four basic definitions and
propositions. First, although it has been widely used by
courts in many circuits. Judge Thomas's term "goal" is not
defined in NEPA, used in the CEQ regulations, nor ex-
plained in CEQ guidance documents. Because there is,
furthermore, no generally accepted definition, the term goal
has variously been used to refer to the need for a proposed
action, the purpose of a federal action, or the mission or
mandate of a federal agency. (Incidentally, while the term
does appear in some EISs, the FAA did not use the term
in the Toledo EIS. The description of the agency's goals
in Citizens Against Burlington is Judge Thomas's interpre-
tation of the EIS.)
Second, while NEPA requires an EIS to include discus-
sion of "alternatives to the proposed action," the statute
itself does not indicate whether "the proposed action" for
this purpose is identical to the "major Federal action"
referred to in an earlier clause of the statute. Contrary to
Judge Thomas's unsupported assertions, CEQ regulations
and guidance have interpreted the phrase "alternatives to
the proposed action" to be broader than alternatives to the
federal action alone." The CEQ requires that the foundation
for consideration of alternatives be the entire underlying
project, including those elements in which there is no federal
participation.62
Third, the CEQ requirement that the scope of alternatives
not be limited by the agency's jurisdiction is reinforced by
the definition of the project or proposed action for NEPA
purposes. If a federal action (e.g.. a license or permit) is a
necessary precondition to other parts of a project (e.g..
construction of a new runway or taxiways), the entire pro-
ject—not just the federal element—becomes the proposed
alternatives and "study, develop and describe each alternaiivt for
appropriate consideration").
60. In addition to its regulations, 40 C.F.R. pt 1500, CEQ has published
several memoranda setting forth its interpretation of the statute and
the regulations. CEQ guidance and interpretation of NEPA is entitled
to great deference. Andrus v. Sierra Club. 442 US. 347.358.9 ELR
20390.20393 (1979).
61. 40 CF.R. J1502.14. See also FORTY QUESTIONS, supra note 57. at
Q. 2a, 2b (agency is required to analyze alternatives both outside
its jurisdiction and outside the capability of the applicant if such
alternatives are practical and feasible, rather than simply desirable);
CEQ, MEMORANDUM: GUIDANCE REGARDING NEPA REGULA-
TIONS, 48 Fed. Reg. 34263 (July 28.1983). ELR ADMIN. MATERIALS
35045.35048 (July 23.1983) [hereinafter CEQ MEMORANDUM ON
GUIDANCE] (there is no inherent distinction in scope of alternatives
for "traditional" federal actions and federally permitted actions).
62. 40 CF.R. 81502.14; Van Abbema, 807 F.2d at 638. 17 ELR at
20432 (EIS alternatives analysis must look at the general goal of
an action, not "alternative means by which a particular applicant
can reach his goal"); Sierra Club v. Marsh, 714 F. Supp. at 575.20
ELR at 20234 (consideration of alternatives is to examine general
objectives, not specific goals).
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21 ELR 10706
ENVIRONMENTAL LAW REPORTER
12-91
action for NEPA purposes; alternatives to the entire project
must be examined."
Fourth, while the strict language of NEPA does not offer
a benchmark for determining "reasonable alternatives,"
CEQ regulations and guidance set forth such standards.
Reasonable alternatives are those that are "practical or
feasible from the technical and economic standpoint and
using common sense." M Because an agency's responsibili-
ties are bounded by some notion of feasibility, an agency
need not discuss "purely conjectural possibilities.""
These four definitions set the foundation for a theory on
how the elements of an EIS are interconnected. The CEQ
requires that the framework for the scope of alternatives be
the purpose and need for the proposed action. An EIS must
contain a statement of the purpose and need:
The statement shall briefly specify the underlying
purpose and need to which the agency is responding
in proposing the alternatives including the proposed
action.**
Just as practicality and feasibility determine whether an
alternative is reasonable, both CEQ regulations and case
law recognize that the statement of need defines the scope
of alternatives in an EIS." In other words, the broader the
statement of need, the greater the range of alternatives.
Beyond this, neither the statute nor the CEQ regulations
provides much assistance.
A careful distinction between "purpose" and "need" will
avoid much of the confusing terminology which cases like
Citizens Against Burlington have fostered." A need is the
lack of something requisite, desirable, or useful or a con-
dition requiring relief. ** Purpose is defined as an object or
end to be achieved.ro Consequently, the two terms should
be interpreted as complementary. The EIS discussion of
purpose and need should demonstrate that the purpose of
a proposed federal action is to attain or achieve at least part
of the underlying need for the proposed action.
The statements of purpose and need for the proposed
action each play a different role. The statement of need
should be an objective description of the reason that the
63. See National Forest Preservation Group v. Butt, 485 R2d 408, 3
ELR 20783 (9th Cir. 1973) (a private project that is enabled by a
federal action becomes the proposed action for NEPA purposes);
Friends of the Earth, Inc. v. Coleman. 518 F.2d 323.5 ELR 20428
(9th Cir. 1975) (nonfederal project elements that are "closely inter-
woven" with the federal action must be considered as pan of the
proposed action).
64. Sre40CRR.51502.14; FORTY QUESTIONS, *u/>ra note 57, at Q. 2a.
65. CEQ MEMORANDUM ON GUIDANCE, supra note 61,48 Fed. Reg.
at 34267, ELR ADMIN. MATERIALS at 35048.
66. 40 CF.R. {1502.13.
67. Id (1502.14; see Roosevelt Campobello Int'l Park Cornm'n v. US.
EPA. 684 F.2d 1041. 1047.12 ELR 20903,20905 (1st Or. 1982).
See also City of New York v. Dept of Transportation, 715 F3d
732, 743, 13 ELR 20823. 20827 (2d Cir. 1983) ("[t]he scope of
alternatives to be considered is a function of how narrowly or broadly
one views the objective of an agency's proposed action"); Trout
Unlimited v. Morton, 509 F.2d 1276, 1286. 5 ELR 20151. 20155
(9th Cir. 1974) (alternatives must be "reasonably related" to state-
ment of purpose).
68. For a general discussion of the distinction between "purpose" and
"need" in the NEPA context, see Schmitt, The Statement of Un-
derlying Need Defines the Range of Alternatives in Environmental
Documents, 18 ENVTL. L. 371 (1988).
69. WEBSTER'S NINTH NEW COLLEGIATE DICTIONARY.
70. Id.
project (not necessarily the federal action) is being pjj
sued.7I An EIS must include alternative methods of saf
fying the need, including any reasonable alternative mean!
that lie outside the jurisdiction of the federal agency. An
adequate discussion of alternatives will respond fully to the
statement of need.n
The statement of purpose follows from the statement of
need. It should be seen as the tool for understanding why
the federal agency has selected the preferred alternative
from among the alternative ways of meeting the need. Un-
like the objective statement of need, the statement of purpose
can be subjective, should refer to an agency's mission, and
should reflect the limits on an agency's statutory authority.
The statement of purpose further should explain how the
proposed federal action satisfies the need and should justify
the decision to choose the preferred alternative. Since an
EIS must be prepared only for a major federal action, the
statement of purpose should explain the nature of the federal
action and the relationship between the project and the
federal action.
This theory of the meaning of purpose and need suggests
that need must be defined first, framing and delimiting the
discussion of alternatives in an EIS. When need and purpose
are fused into a single statement—as in the past they fre-
quently have been—it becomes possible for an agency to
define the need for a project as the agency's purpose.
An example proves the point Suppose an area lacks ade-
quate electricity capacity, and an applicant wishes to build a
nuclear reactor to provide this capacity, for which a federeJj
license is required One of the benefits of the project might bl
the jobs and economic growth it would generate for the region.
A proper statement of need for the federal action would relate
to the provision of electricity capacity; the EIS on the project
must examine alternative ways of increasing regional electric-
ity capacity. A proper statement of purpose would relate to the
licensing of a nuclear power plant The federal action is the
granting of a license or permit necessary to construct the
additional electricity capacity. Were the regulatory agency
improperly to equate purpose and need in a single statement, it
might define the "purpose and need" as providing electricity
capacity and encouraging development of the nuclear industry
while also stimulating economic growth in the region. The
scope of alternatives is fundamentally different when the state-
ment of need is fused into a single statement of purpose and
need The latter, limited, definition of need allows no alterna-
tives other than that proposed by the applicant, effectively
short-circuiting the alternatives requirement of NEPA.
Judge Thomas sees a strikingly similar "goal" (combin-
ing need and purpose) behind the expansion of Toledo
Express Airport. The FAA could have devised several
different statements of need for the Toledo project that
could have required its EIS to examine not only alternative
71. Coalition for Canyon Preservation v. Bowers, 632 F.2d 774. 11
ELR 20053 (9th Cir. 1980). See also Concerned About Trident v.
Rumsford, 555 F.2d 817, 831 n.2, 6 ELR 20787, 20795 n.2 (D.C
Cir. 1977) (an agency should produce an EIS that observes "objec-
tive reasonableness" when evaluating the "concept" behind the |
action). '
72. 40 C.F.R. 81502.14; see also Natural Resources Defense Council
v. Morton. 458 F.2d 827.836.2 ELR 20029.20032 (D.C. Cir. 1972)
(alternatives analysis must include reasonable actions to satisfy the
need even if they lie beyond agency's jurisdiction).
73. 938 F.2d 190. 196. 21 ELR 21142. 21146 (D.C. Cir. 1991).
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12-91
NEWS & ANALYSIS
21 ELR 10707
locations for a Burlington air cargo hub, but also alternatives
to air cargo services altogether. At the other extreme, the
FAA could have defined the need for the project so narrowly
that the only practical and feasible alternative was the con-
struction of a cargo hub at Toledo Express precisely as
proposed by Burlington. Judge Thomas believes that the
FAA properly adopted this latter approach.
Judicial Review of the Statements of Purpose and Need
The principal utility of this paradigm separating the state-
ments of purpose and need is to define a clearer standard
of judicial review. In the past, in those few cases in which
the definition of purpose or need has been at issue, courts
have not articulated a clear standard of review." It can be
argued, however, that the standard of judicial review should
not be the same for the two statements.
Because the underlying need for a federal action is
supposed to be examined objectively,7J without regard
to the agency's policy aims or statutory mission, the
adequacy of its definition is easily susceptible to judicial
review under the well-established "rule of reason" stand-
ard by scrutinizing the scope of alternatives.7< Precisely
the opposite standard should apply to the statement of
purpose. Since this statement should reflect an agency's
policy decision on how, when, and to what degree it will
satisfy the need, the adequacy of a statement of purpose
is largely a discretionary, administrative determination,
and should be subject to judicial review under a much
more deferential standard.77 A statement of purpose
should be reviewed only to determine whether it violates
an agency's statutory authority or mission.
This distinction between the statements of purpose and
need should alleviate the difficulties of judicial review ex-
emplified by Citizens Against Burlington. As Judge Tho-
mas's discussion implies, courts are loath to second guess
an agency's decision when a court cannot distinguish be-
tween an agency's policy preferences and the objective facts
underlying that decision. Joint statements of purpose and
need, therefore, are likely to be upheld not because a court
finds that they meet the requirements of NEPA. but because
74. See, e.g.. Roosevelt Campobello Int'l Park Coram'n v. U.S. EPA,
684 F.2d 1041,1046,12 ELR 20903,20905 (1st Cir. 1982) ("need"
for a project not required to be updated "in order to accommodate
the most recent data and federal policy shifts"); Izaak Walton League
of America v. Marsh. 655 F.2d 346, 372, 11 ELR 20707. 20721
(D.C. Or. 1981). cert, denied, 454 U.S. 1092 (1981) (congressional
passage of a statute specifically authorizing a project narrows the
breadth of the investigation of alternatives (defined by the need and
purpose of the project)).
75. See supra note 71.
76. See Natural Resources Defense Council, 458 R2d at 835, 2 ELR
at 20031 (articulating the "rule of reason" standard for judicial
review). See also Roosevelt CampobeUo. 684 R2d at 1047,12 ELR
at 20905 (court "measures federal agency compliance with NEPA's
procedural requirements" by adhering to a "rule of reason"); Cali-
fornia v. Block, 690 F.2d 753,767,13 ELR 20092,20098 (9th Cir.
1982) (alternatives discussed provide the basis for the "rule of
reason" under which the agency decisionmaking process is reviewed
by the courts); Izaak Walton League, 655 F.2d at 371-72,11 ELR
at 20721 ("rule of reason" complied with as "long as the agency's
conclusions have a substantial basis in fact"); Concerned About
Trident v. Rumsford. 555 R2d 817,827.6 ELR 20787.20792 (D.C.
Cir. 1977) (**[i]n determining [NEPA compliance], we are governed
by the rule of reason" (citations omitted)).
77. See 938 F-2d at 196.21 ELR at 21145.
of reluctance to impose judicially established policy pref-
erences on federal agencies.
Although courts frequently have confused or combined
the concepts of purpose and need, at least one court has
successfully drawn the distinction. In Druid Hills Civic
Association v. Federal Highway Administration,n the Elev-
enth Circuit confronted the plaintiffs' claim that the Federal
Highway Administration, when considering alternatives to
the purpose for its proposed parkway construction, "did
not provide a full and fair discussion of the traffic and safety
justifications for the road because information was omitted
that did not support the perceived need for the project." "
The court drew a clear separation between the need for the
project ("[t]he proposed Parkway is premised on the need
for transportation improvements in the east-west corri-
dor")*0 and the purpose for the granting of construction
permits ("providing an alternative east-west route." thus
decreasing traffic volumes on the existing road, and "im-
provfing] safety conditions in the corridor" by reducing
traffic overflow onto local streets)." The court went on to
examine the discussion of alternatives to the need, and held
that although the EIS did not "contain what some may feel
is a detailed and careful analysis" of all potential alterna-
tives, the analysis was adequate.u
Druid Hills stands as an unusual example of a clearly
differentiated need and purpose for a project. The general,
objective need for improved traffic flow on the east-west
corridor was addressed not only by the preferred alternative
and the purpose of the federal action, but also by a consid-
eration in the EIS of subway, light rail, and other potential
solutions.u The court found no fault with the subjective
determination of the purpose for the action and held that
the discussion of alternatives reasonably fit the need."
Necessity for Alternatives to Reflect Need
This lengthy discussion of the statements of purpose and
need is critical to understanding Citizens Against Burlington
and earlier cases that have examined whether the discussion
of alternatives in an EIS is adequate. As has been seen, the
foundation for an adequate discussion of alternatives is the
statement of need. If a litigant does not challenge the pro-
priety of an agency's statement of need, then the reviewing
court is limited to examining whether the scope of alterna-
tives closely matches the statement of need. In the principal
cases in which courts have upheld the discussion of alter-
natives, the statement of need generally parallels closely
the range of alternatives.u Where courts have found the
78. 772 F.2d 700, 15 ELR 21082 (11th Cir. 1985).
79. Id. at 710,15 ELR at 21086.
80. Id. at 709,15 ELR at 21086.
81. Id. at 710,15 ELR at 21086.
82. Id. at 713,15 ELR at 21088.
83. Id.
84. Id.
85. See. e.g., Roosevelt CampobeUo Int'l Park Comm'n v. U.S. EPA.
684 F.2d 1041. 1047. 12 ELR 20903. 20905 (1st Cir. 1982) (ap-
proving a limitation of the range of alternatives based on the need
for a deepwater port); Izaak Walton League of America v. Marsh,
655 F.2d 346.372.11 ELR 20707,20721 (D.C. Cir. 1981) (where
need has been statutorily narrowly defined, the discussion of alter-
natives is similarly "relatively narrow"); North Slope Borough v.
Andres, 642 F.2d 589.601,10 ELR 20832.20838 (D.C. Cir. 1980)
(agencies have discretion to treat the discussion of alternatives
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21 ELR 10708
ENVIRONMENTAL LAW REPORTER
12-91
discussion of alternatives to be objectionable, it generally
is because the EIS has omitted reasonable alternatives that
would meet the need.M
For example, in Natural Resources Defense Council, Inc. v.
Morton,*1 the D.C. Circuit examined the adequacy of an EIS
on oil and gas leases issued under die Outer Continental Shelf
leasing program. The court held that the Department of Interior
improperly limited its discussion of alternatives to those mat
lay within its jurisdiction. The need for the project was set forth
in a message to Congress by President Nixon in which the
President proposed a coordinated plan to deal with research
and development toward the goal of clean energy." The EIS,
however, improperly omitted reasonable alternatives that did
not fulfill the entire need, the agency did not have authority to
implement, or would have required legislative implementa-
tion. * The court explained that the scope of alternatives must
match the need for the action:
When the proposed action is an integral put oft coordi-
nated plan to deal with * broad problem, the range of
alternatives that must be evaluated must be broadened.
While the Department of Interior does not have the
authority [to implement all alternatives] such action is
within the purview of both Congress and the President,
to whom the impact statement goes.w
The opposite result prevailed where Congress enacted
legislation specifically directing the construction of a pro-
ject. In Izaak Walton League of America v. Marsh, an EIS
was prepared on construction of new locks and dams on
the Mississippi River. Plaintiffs alleged that the Army Corps
of Engineers should have examined rehabilitation of exist-
ing facilities, alternative modes of transportation, and im-
proved congestion control as alternatives to the proposed
new locks and dams." The D.C. Circuit held that the agency
did not have to examine those alternatives because the need
for the project was set by congressional mandate to build
specially with respect to the goal of the project); Trout Unlimited
v. Morton, 509 E2d 1276, 1286, 5 ELR 20151. 20155 (9th Or.
1974) (finding consideration of alternatives adequate as long as all
"those reasonably related to the purposes of the project" are in-
cluded).
86. See. e.g., Van Abbenw v. Foroell. 807 R2d 633.638.17 ELR 20429.
20432 (7th Cir. 1986) (discussion of alternatives must "be an evalu-
ation of alternative means to accomplish the generic goal of an
action ... not an evaluation of the alternative means by which a
particular applicant can reach his goal"; discussion did not respond
to broad need and therefore inadequate); California v. Block, 690
F.2d 753. 767. 13 ELR 20092. 20098 (9th Cir. 1982) (where the
need to be addressed is "how to allocate a scarce rcsource-^wil-
demess—between the two competing and mutually exclusive de-
mands of wilderness use and development." it is unreasonable to
fail to examine any alternative that develops less than 37 percent
of the wilderness); Sierra Club v. Marsh, 714 F. Supp. 539, 577.
20 ELR 20216.20235 (D. Me. 1989) (striking down EIS as inade-
n because discussion of alternatives focussed too narrowly on
.iplicant's desires rather than the broader need for an expanded
deep-water port capacity); California ex rel. Van de Kamp v. Marsh,
687 F. Supp. 495.495-99.19 ELR 20165,20166 (ND. CaL 1988)
(obvious alternative of resolving need for an expanded airport by
locating pan of the project at another airport not discussed; hence
discussion inadequate).
87. 458 F.2d 827,2 ELR 20029 (D.C. Or. 1972).
88. Id. at 835,2 ELR at 20030.
89. Id. at 837.2 ELR at 20033-34.
90. Id. at 835.2 ELR at 20033.
91. 655 F.2d 346,372,11 ELR 20707. 20721 (D.C. Or. 1981).
new locks and dams; the agency properly examined all
reasonable alternative means of satisfying that mandate.n
One of the clearest examples of the necessity for the
range of alternatives to respond to the statement of need
appears in Sierra Club v. Marsh.n In that case, the district
court found that the Army Corps of Engineers had omitted
reasonable alternatives in its EIS for a federal permit to
construct a marine cargo terminal on the coast of Sears
Island, Maine. The federal agency argued that any alterna-
tive that would not satisfy the applicant's stated goals or
needs is inherently not reasonable. The court disagreed.
Quoting CEQ guidance, the court held that, while the agency
properly should not disregard the applicant's desires, those
desires alone are not enough to define the need for a pro-
ject. M The court examined the record in detail to discern
both the applicant's "primary project objective" and the
federal agency's "general goals" for the project.*1 The
court next reviewed each potential alternative proffered by
the plaintiff to determine whether it would satisfy the need
for the project. It then held that several omitted off-site
alternatives were not reasonable in the circumstances but
that omitted on-site alternatives should have been exam-
ined. w The court explained the relationship among the
statement of need, the applicant's desires, and the scope of
alternatives:
The central project goals identifiable in the present FEIS
contemplate an efficient marine dry cargo ... terminal
intheSearsportarea... .Although[theapplicant]amply
demonstrates that it "desires" a terminal facility capable
of expansion to six berths, unless its preferences bear a
rational relationship to the technical and economic integ-
rity of the project, they would not warrant exclusion of
some otherwise "reasonable alternative" from analysis
under NEPA. A project's principal goals must override
the stated preferences of the applicant for purposes of
NEPA's "reasonable alternatives" analysis.'7
Surprisingly, there are few cases in which the adequacy
of the agency's statement of purpose has been at issue.
There are several possible explanations for the absence of
such case law. First, agencies frequently prepare a single
statement of "purpose and need." thereby making it difficult
if not impossible to distinguish between the purpose and
need.w Some agencies—including the FAA in the case of
the Toledo airport EIS—prepare a single statement that
intersperses the terms "purpose" and "need" with intended
synonyms such as "goal," "objective," "mission," or simi-
lar words that blur the distinction. This fusing of purpose
and need makes.it nearly impossible for potential challeng-
ers (and the reviewing court) to determine whether the
agency has examined a reasonable range of alternatives to
meet the need." _^
92. Id. at 372-74,11 ELR at 20721-22.
93. 714 F. Supp. 539.20 ELR 20216 (D. Me. 1989).
94. Id. at 573-74. 20 ELR at 20233 (citations omitted).
95. Id. at 575-76. 20 ELR at 20234-35.
96. Id. at 577-82.20 ELR at 20235-37.
97. Id. at 577,20 ELR at 20235 (citations omitted).
98. This difficulty is exemplified by the Van Abbema opinion. There,
the court attempted to distinguish between the "general" and the
"specific" agency goals, a distinction which Judge Thomas in CM-
tens Against Burlington correctly criticizes as unworkable. 938 F.2d
190. 199, 21 ELR 21142. 21147 (D.C. Cir. 1991).
99. No alternative may be rejected on the grounds that it does not fully
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12-91
NEWS & ANALYSIS
21 ELR 10709
A good illustration of this problem is the First Circuit's
opinion in Roosevelt Campobello International Park Com-
mission v. Environmental Protection Agency.ICO The plain-
tiffs specifically challenged the adequacy of the agency's
statement of need for a deepwater port at Eastport, Maine,
as "totally outdated and of no present use."'*' The court
used such phrases as "justification for the project," and the
applicant's "primary objectives" that blurred the distinction
between the need for the project and the agency's purpose
in reviewing an applicant's proposals.m While the court
appeared to view the need to be the "longstanding federal
policy of encouraging the construction of domestic refining
capacity in order to promote national security," the court
also opined that the need to which the agency was respond-
ing was more limited:
[Evaluation of alternatives was explicitly based on the
premise that [the agency's] role in reviewing privately
sponsored projects "is to determine whether the pro-
posed site is environmentally acceptable "'**
It is noteworthy that the very next year, the CEQ criticized
the implication in Roosevelt Campobello that an agency's
role (i.e., the purpose of the federal action) properly defined
the scope of alternatives.IM
Other courts have used terminology that makes it nearly
impossible to distinguish between purpose and need. For
example, in Residents in Protest—I-35E v. Dole,1"" the
court used the phrases "purposes of the project," "goals
and objectives," and "underlying goals of the project,"
synonymously with the phrase "need which [the project]
was designed to serve." "* In Natural Resources Defense
Council, Inc. v. Callaway,im the court stated that the content
and scope of alternatives is a function of the "nature of the
proposal"; an EIS must discuss alternatives that "meet the
proposal's goals." '*
Both Judge Thomas and the FAA fell into the same trap
in Citizens Against Burlington. First, neither Judge Thomas
nor the FAA uses the terms carefully; Judge Thomas's
"goals" and "objectives" appear to be a combination of
the agency's purpose and the need for the project The EIS
itself contains no clearly articulated statement of purpose
and need, either separately or jointly.>m The EIS does not
even purport to include a statement of purpose; the section
of the EIS that was labeled as the agency's statement of
need contains a jumbled discussion of purpose, need, de-
scription of the project and benefits of the proposed federal
accomplish every goal of the originally proposed action. See Town
of Matthews v. United States Dep't of Transp., 527 F. Supp. 1055,
1058. 12 ELR 20345. 20346 (W.D. N.C 1981).
100. 684 F.2d 1041. 12 ELR 20903 (1st Cir. 1982).
101. Id. at 1046. 12 ELR at 20905.
102. Id at 1046-47.12 ELR at 20905.
103. Id. at 1046, 12 ELR at 20905.
104. CEQ MEMORANDUM ON GUIDANCE, supra note 61,48 Fed. Reg.
at 34267, ELR ADMIN. MATCIUALS at 35048.
105. 583 F. Supp. 653.66041 (D. Minn. 1984).
106. Id. at 659-60.
107. 524 F.2d 79. 93,5 ELR 20640. 20647 (2d Cir. 1975).
108. Id.
109. Toledo EIS, supra note 14. at 1-3 (subhead for section discussing
the purpose and need for the project is entitled "Need for the Federal
Action").
action."° It appears that the FAA believed that the need
for the proposed action was
to facilitate [Toledo-Lucas County Pott Authority's]
construction of facilities at the airport for an air cargo
hub that will serve as Burlington's permanent hub ...
[and to provide for] extending Runway 7-25 to provide
safe and adequate length to permit Burlington Air Ex-
press to operate fully loaded DC-8-63F aircraft to west
coast market destinations.'"
Instead of setting forth a clear statement of purpose, the
EIS sets forth the factors that the FAA says it considered
in meeting the need, including the agency's "statutory man-
date to facilitate the establishment of air cargo hubs," and
the FAA's
responsibility to review the airport design and runway
configuration with respect to safety, efficiency and utility
within the national airspace system and its environ-
mental impact on the surrounding area. "2
Although he claims that the court defers to the agency's
definition of the purpose and need for the project. Judge
Thomas does nothing of the sort. He weaves of whole cloth
the explanation in Citizens Against Burlington that the pur-
pose or need for the Toledo project was both construction
of a cargo hub for Burlington and the economic revitaliza-
tion of the Toledo economy. The court's explanation is
troubling not only because it is a court-imposed definition,
but also because it fuses purpose, need and beneficial im-
pacts of the project. Even if one accepted the court's implicit
conclusion that it is permissible to equate purpose and need,
this statement neither reflects the objective necessity for
the Toledo project (the need) nor bears any relationship to
the federal action that, by statute, is limited to the approval
(and possible funding) of the layout plan for the expansion
of Toledo Express Airport (the purpose). Consequently,
even under the court's assertion that the purpose and need
should reflect the nature of the agency's role, the court's
definition fails to pass muster.
The holding in Citizens Against Burlington is not, how-
ever, dependent on Judge Thomas's redefinition of the pur-
pose and need for the project. If one were to construct
separate statements of purpose and need for the Toledo EIS.
it appears that the FAA believed that the need for the Toledo
project was to provide a permanent air cargo hub at Toledo
Express Airport for Burlington. The purpose for the federal
action was to design a safe and efficient facility that meets
federal aviation standards.
Under this refined statement of purpose and need, it
appears that the FAA's decision to evaluate only two alter-
natives was unobjectionable. Because the parties focussed
strictly on whether the FAA had omitted discussion of
reasonable alternative ways of meeting the need, moreover.
the court did not need to examine the adequacy of the
statement of need.
Arguably, therefore. Judge Thomas's discussion of the
agency's goals and objectives is little more than dicta.'"
110. Id. at 1-3. 1-4.
HI. Id. at 1-3.
112. Id.
\ 13. Similarly, his supposed holding that the scope of alternatives is
defined by the agency's role is contradicted by a binding D.C. Circuit
precedent. Natural Resources Defense Council v. Morton. 458 F.2d
827. 834-37, 2 ELR 20029, 20032-33 (D.C. Cir. 1972). It is sig-
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21 ELR 10710
ENVIRONMENTAL LAW REPORTER
12-91
The only issue presented to the D.C. Circuit was whether
the OS discussed all reasonable alternative ways to provide
a permanent air cargo hub at Toledo for Burlington. If one
accepts either the FAA's or Judge Thomas's statement of
the need, the case is not a close one. It was reasonable for
the FAA to conclude that only the preferred alternative
could reasonably satisfy the need articulated in the EIS
because the FAA's statement equated need with purpose.
The case shows how, if need (i.e., the general, objective
necessity the project is designed to meet) is fused with
purpose (i.e., die specific, subjective policy choices of the
agency, taking into account the preferences of the applicant),
it becomes straightforward for an agency to avoid examining
any alternative but the preferred one. When the need for a
project is allowed to be defined as its purpose, by definition
there can be only one alternative. If the need is for an
expanded airport at Toledo to serve a specific air cargo
carrier, it is unreasonable to demand consideration of any
alternative site in Ft Wayne or elsewhere because such
alternatives do not fulfill the need. In Citizens Against
Burlington, either Judge Thomas's invention of an eco-
nomic goal for the project or the FAA's mixing together
of purpose and need leads to the same result: no examination
of any alternative other than the location of the expanded
cargo hub at Toledo Express.
Lessons for Agencies and NEPA Litigants From
Citizens Against Burlington
At first reading. Judge Thomas's opinion in Citizens Against
Burlington may be seen as a complete victory for NEPA
critics and federal agencies seeking to avoid the statute's
procedural hurdles. The lessons of the case, however, are
far less one-sided.
First, notwithstanding Judge Thomas's lengthy discus-
sion about deference to an applicant's desires, the case
should not be read as standing for die novel proposition
that the scope of alternatives in an EIS depends on the
nature of the federal action. At best, the discussion is an
explanation of why the scope of alternatives properly
matched the FAA's statement of the need for the project;
at worst, the discussion is mere dicta.
Several reasons are immediately apparent why Citizens
Against Burlington cannot establish a system of inquiry
under NEPA that is dependent on the nature and degree of
federal participation in a project Most obviously, such a
system would run counter to express CEQ guidance on the
scope of alternatives, guidance which the court does not
even discuss. A system that is dependent on the extent of
federal involvement also would conflict directly with case
law (including D.C. Circuit law), which holds that the scope
of an EIS—including the project's impacts and alterna-
tives—must include nonfederal elements of a project even
. when the federal government is only authorizing or permit-
ting a small portion of the project "4
nificant thai Judge Thomas does not attempt to distinguish Natural
Resource} Defense Council and its holding that the scope of alter-
natives in an EIS cannot be limited by the nature of the agency's
authority. That remains the law in the D.C Circuit and elsewhere.
114. See National Forest Preservation Group v. Butz, 485 R2d 408,
41M2. 3 ELR 20783. 20784 (9th Or. 1973); Scientists' Inst for
Pub. Information v. Atomic Energy Comra'n, 481 R2d 1079,1088-
89,3 ELR 20525,20529-30 (D.C Or. 1973).
Additionally, such a system would violate the bindin,
D.C. Circuit precedent in which the court has held that the
scope of alternatives cannot be defined by the nature of the
federal involvement in a project "5 Judge Thomas fails to
discuss this precedent as well. Finally, if the court had
intended to disregard CEQ guidance, shift NEPA law, and
overrule D.C. Circuit precedent it is reasonable to expect
that the court would at least have explained its intent to do
so. That the court was silent on such precedents suggests
that it had no such intention.
What Judge Thomas's discussion does highlight is the
importance of defining the need for a project. An interest-
ing—if hypothetical—question is whether the FAA's murky
statement of need could have survived close judicial scru-
tiny. That statement appears vulnerable because of its lack
of objectivity, its fusing of the agency's policy aims with
objective statements of fact, and because it set criteria that
made the preferred alternative the only reasonable alterna-
tive. One could argue that an agency's statement of need—
like that for Toledo—is prima facie improper if it allows
for examination of only a single alternative.
For prospective litigants, Citizens Against Burlington under-
scores the importance of challenging the adequacy of the
statement of need in the EIS commenting process and again on
judicial review. Making a record to demonstrate that the agency
is responding to a broad need would make it substantially easier
to show that a narrow range of alternatives is not responsive to
the need "* An EIS that rejects all alternatives but the preferred
one (or minor, cosmetic variations on the preferred alternative)
should raise immediate skepticism not only that the scope of'
alternatives is improper, but also that the agency has fused its
statements of purpose and need into a single self-justifying
policy statement
Similarly, agencies should be forced to distinguish between
the need and purpose for a project and should be challenged
when they use ill-defined terms such as "goals," "objectives,"
or "mission." The statutory and regulatory language is clear
and defined; agencies should use such language to avoid the
ambiguity that results when different courts try to use the same
words for different purposes (e.g., the Van Abbema court and
the Citizens Against Burlington court).
In Citizens Against Burlington, the FAA's confused state-
ment of need was not at issue. Had it been, the Toledo EIS
might have been vulnerable. A plaintiff can avoid a Citizens
rAgainst Burlington situation by ensuring that it creates a
record to support the need for the project and by supporting
' its rejection of alternatives with reference to that need.
While Judge Thomas's discussion suggests that an agency
can define its "goals" by reference to an applicant's desires,
agencies should not interpret that discussion as anything
more than a reaffirmation of an agency's wide discretion
to define the purpose of a federal action. Agencies still
must examine all reasonable alternatives that fulfill the need
for the proposed action, regardless of whether such alter-
natives match the agency's policy objectives or whether
the agency can implement them.
115. See. e.g.. Natural Resources Defense Council, 458 F.2d at 834-36,
2 ELR at 20032-33.
116. In Roosevelt Campobello, for example, the court criticized plaintiffs
for not challenging the adequacy of the statement of need during
the public comment period. 684 R2d 1041. 1046, 12 ELR 20903,
20905 (1st Or. 1982).
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ATTACHMENT 2.B
ENVIRONMENTAL IMPACT CHECKLISTS
• A Listing and Example of the World Bank Checklists for Projects with
Potentially Significant Environmental Impacts. (Source: The World Bank.
1991. Environmental Assessment Sourcebook, Volume H)
• Computer disks for Volumes I, n, and HI of the World Bank
Environmental Assessment Sourcebook.
• Model EIS Scoping Checklist. (Source: New York State Department of
Environmental Conservation. 1982. State Environmental Quality Review
Handbook)
• Checklist of Potential Environmental Impacts of a Transportation Project.
(Source: A. D. Little, Inc. 1971. Transportation and Environment:
Synthesis for Action: Impact of the National Environmental Policy Act of
1969 on the Department of Transportation, Vol. I-IQ, prepared for the Office
of the Secretary, Department of Transportation)
2.B-1
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2.B-2
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A Listing and Example of the World Bank Checklists for Projects with Potentially
Significant Environmental Impacts. (Source: The World Bank. 1991. Environmental
Assessment Sourcebook, Volumes n and HI)
VOLUME H
Table 8.1 Agroindustry
8.2 Dams and Reservoirs
8.3 Fisheries
8.4 Flood Protection
8.5 Natural Forest Management
8.6 Plantation Development/Reforestation
8.7 Irrigation and Drainage
8.8 Livestock and Rangelands Management
8.9 Rural Roads
Table 9.1 Analytical Framework for Urban Environmental Problems
9.2 Roads and Highways
9.3 Inland Navigation
9.4 Port and Harbor Facilities
9.5 Large-Scale Housing Projects
9.6 Solid Waste Collection and Disposal Systems
9.7 Tourism Development
9.8 Wastewater Collection, Treatment, Reuse, and Disposal System
VOLUME m
Table 10.1 Industrial Hazard Management
10.2 Electric Power Transmission Systems
10.3 Oil and Gas Pipelines
10.4 Checklist - Offshore Oil and Gas Development
10.5 Oil and Gas Development - Offshore
10.6 Checklist - Onshore Oil and Gas Development
10.7 Oil and Gas Development — Onshore
10.8 Hydroelectric Projects
10.9 Thermoelectric Projects
10.10 Cement
10.11 Chemical and Petrochemical
10.12 Fertilizer
10.13 Food Processing
10.14 Iron and Steel Manufacturing
10.15 Nonferrous Metals
10.16 Petroleum Refining
10.17 Pulp, Paper, and Timber Processing
10.18 Mining and Mineral Processes
2.B-3
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Table 9.8. Wastewater Collection, Treatment, Reuse, and Disposal Systems.
(Source: The World Bank. 1991. Environmental Assessment Sourcebook, Volume II)
Potcntud Ncgstivc Lnpflcts
Diract
1 . Disturbance of stream channels, aqoatic plant ^(K* ftqiiml
habitat, and spawning and ninety area* during
construction.
2. Attention* in watershed hydrologic balance when
wastewater is exported by collection in large upstream ateai
and discharge downstream.
3 . Degradation of neighborhoods or receiving water quality
from aewer overflow!, treatment world bypaiacs, or
treatment proceu failure.
»
4. Degradation of receiving water quality despite normal
system operation.
5. Public health hazard* in vicinity of discharge! or reuse ritei
during normal operation of system.
6. Contamination at land application sites:
soil and crops by toxic substances and pathogens
groundwater by toxic substances and nitrogen
7. Failure to achieve desired beneficial uses of receiving waters
despite normal system operation.
Mitigating Measures
1. • Do not route sewer lines in stream channels.
construction.
2. • Consider sub-regional and small community system*
in water-short areas.
• Take full advantage of opportunities for waitewater
reclamation/reuse, especially in water-short areas.
3. • Phase construction of collector systems and treatment
works to avoid raw wastewater discharges.
• Select appropriate technology.
• Design for reliability, ease of maintenance.
• Implement management and training
recommendations, monitoring program, and industrial
waste pretreatment program (see text for guidelines).
4. • Site and design treatment works and disposal or reuse
systems on the basis of adequate data on the
characteristics of the wastewater and the assimilative
capacity of the receiving water body.
• Use mathematical models for siting surface water
discharges and determining required level of
treatment, and for siting and designing ocean outfalls.
• Take full advantage of appropriate land application
alternatives, especially in water-short areas.
• Implement monitoring program and industrial waste
pro-treatment program (see text for guidelines).
5. • Select appropriate technology.
• Ensure preapplication treatment and operating
guidelines for land application and other water reuse
systems are adequate to safeguard health of humans
and livestock.
• Restrict access to wastewater or sludge disposal sites
where health hazards are unavoidable.
6. • Site and design treatment works and disposal or reuse
systems on the basis of adequate data on the
characteristics of the wastewater and land application
site.
• Implement monitoring program and effective industrial
waste pretreatment program (see text for guidelines).
• Ensure preapplication treatment and operating
guidelines for land application and other wastewater
reuse system* are adequate.
7. • Establish realistic use objective and select water
: quality criteria consistent with desired uses.
• Establish system performance ^"v^inft by *TtT"V'Mf|g
or other means which will result in meeting criteria.
2.B-4
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Table 9.8. Wastewater Collection, Treatment, Reuse, and Disposal Systems (continued)
Potential Negative Impacts
8.
9.
10.
11.
12.
13.
14.
15.
16.
17.
18.
operation.
Emissions of volatile organic compounds from treatment
process.
Soil, crop or groundwater contamination and disease vector
breeding or feeding at sludge storage, reuae or disposal
sites.
Worker accidenU during construction and operation,
especially in deep trenching operation.
Worker accidenU caused by gaa accumulation in sewers and
other confined spaces or by htTMxU*1* materials discharged
into sewers.
Serious public and worker health hazard from chlorine
accidenU.
and backups.
Failure to achieve public health improvement in serviced
area.
Dislocation of residents by plant siting.
Perceived or actual nuisances and adverse aesthetic impacts
in neighborhood of treatment works.
Accidental destruction of archaeological sites during
excavation.
Mitigating Measures
8. • She treatment works only near compatible land uses.
• • Select appropriate technology.
• Include odor control and low-noise equipment in
design.
(see text).
9. • Establish effective industrial waste pretreatment
program (see text for guidelines).
10. • Incorporate sludge management in system feasibility
studies, technology selection, design, sttffing,
training, budgeting and startup plan.
• Implement effective industrial waste pretreatment
program (see text for guidelines).
• Ensure preapplication treatment and operating
guidelines for land application and other reuae or
disposal systems are adequate to safeguard health of
human and livestock.
• Inspect for compliance with operating guidelines.
1 1 . Enforce adherence to safety procedures.
12. • Emphasize safety education and training for system
•Uff.
• Implement effective industrial waste pretreatment
program (aee text for guidelines).
• Provide appropriate safety equipment and monitoring
instruments.
• Enforce adherence to safety procedures.
13. • Incorporate safety provision in design, operating
procedures, and training.
• Prepare contingency plan for accident response.
14. • Routinely inspect aewera for illegal connection and
obstruction.
• Clean sewers as necessary.
• Provide monitoring system with alarms for pump
station failure.
• Provide alienate power supply at critical pump
station.
• Educate public to prevent disposal of solid waste in
sewers.
15. Conduct sanitation and hygiene education program.
16. Assist with resettlement (see 'Involuntary Resettlement*
section).
17.' Incorporate neighborhood improvements and useful public
facilities in project.
18. Include notification and protection procedures for cultural
properties in construction contract documents (see 'Cultural
Property* section).
2.B-5
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Table 9.8. Wastewater Collection, Treatment, Reuse, and Disposal Systems (continued) |
Potential Negathelmpactt
Indirect
19. Uaphnned development induced or fiwilitited by
infrastructure.
thidgt.
21 . Low of fisheries productivity.
22. Reduction of tourist or recreational activity.
Mitigating Measure*
19. • Coordinate installation of sewerage with land uie
planning.
• Strengthen land uie control regulations and
imtitutiooi.
• Integrate planning for infrastructure in urban
development projecti.
20. • Incorporate kludge, excreta and teptage in regional
•olid watte management planning and in waatewater
system feasibility studies and technology selection.
• Implement industrial waste pretreatment program.
21. • Evaluate importance of receiving water in local and
regional fisheries.
• Implement mitigating measure for direct impacts 3, 4
and?.
22. • Give special attention to real or perceived nuisances
and aesthetic impacts in selecting site and technology.
• Implement mitigating measures for direct impacts 3,
4, 5, 7, 8 and 14.
2.B-6
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Computer disks for Volumes I, n, and ffl of the World Bank
Environmental Sourcebdok
2.B-7
-------
2.B-8
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Source: New York State Department of Environmental Conservation.
State Environmental Quality Review Handbook.
1982.
Introduction
The following checklist of topics is intended
as a starting point for developing a detailed scope
for a project-specific Draft Environmental Impact
Statement. Typically, no one project will require a
discussion of all the topic areas contained in this
document. Through the scoping process, this list of
topics should be refined to reflect issues unique to
the proposed project. Topic areas may be deleted,
added, or elaborated upon, to arrive at the final
scoping document.
The purpose of the checklist format is to
identify the basic topic areas for the Draft EIS. This
is accomplished by reviewing the list and placing a
check in the box located to the left of those topics
which should be discussed. The model scoping
checklist can also be used as a worksheet, including
comments, suggestions and identification of the
particular examples) that are relevant to a detailed
discussion of the topic or issue that has been check-
ed. Conversely, those topics which are not checked,
are issues not associated with the project, and may
be eliminated from discussion in the Draft EIS.
Minimum requirements for any Draft EIS are
already checked for convenience.
The next step is to expand the list to include
or elaborate on those topics unique to the proposed
project. A blank sheet is included at the end of the
checklist for such additional information.
The scoping process involves several steps in
addition to compiling a list of topics. Scoping also
includes discussions on the quantity and quality of
information required and the methods for obtaining
that data.
NOTE: This checklist was designed to be
used in conjunction with the section on scoping con-
tained in the SEQR Guideline-Draft and Final ElS's.
It is also important to emphasize that this checklist
should serve only as a model to .assist in the scoping
of a Draft EIS. It should not be used as a substitute
for actively scoping a Draft EIS for a specific pro-
ject.
I. Cover Sheet
All ElS's (Draft or Final) shall begin with a cover
sheet that indicates:
A. Whether it is a draft or final statement
B. Name or other descriptive title of the project
C. Location (county and town, village or city) of
the project
D. Name and address of the lead agency which
required preparation of the statement and
the name and telephone number of a person
at the agency to be contacted for further in-
formation
E. Name and address of the preparers of any
portion of the statement and a contact name
and telephone number
F. Date of acceptance of the Draft EIS
G. In the case of a Draft EIS, the deadline date
by which comments are due should be in-
dicated
II. Table of Contents and Summary
A table of contents and a brief summary are re-
quired for Draft and Final ElS's exceeding 10 pages
in length. However, one should include these
features in any size EIS to provide the review agency
with easy reference to EIS topics.
The summary should include:
A. Brief description of the action
B. Significant, beneficial and adverse impacts,
(issues of controversy must be specified)
C. Mitigation measures proposed
D. Alternatives considered
E. Matters to be decided (permits, approvals,
funding)
HI. Description of the Proposed Action
Place a check in the box to the left of those
topics to be included in the draft EIS.
A. PROJECT PURPOSE AND NEED
1. Background and history
2. Public need for the project, and
municipality objectives based on adopted
community development plans
3. Objectives of the project sponsor
2.B-9
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D B. LOCATION
1. Establish geographic boundaries of the
project (use of regional and local scale
maps is recommended)
2. Description of access to site
3. Description of existing zoning of propos-
ed site
. 4. Other:
D C. DESIGN AND LAYOUT
1. Total site area
a.) proposed impervious surface area
(roofs, parking lots, roads)
b.) amount of land to be cleared
c.jopen space
2. Structures
a.) gross leaseable area (GLA), if ap-
plicable
b.) layout of buildings (attached, enclos-
ed, separate)
c.) site plans and profile views
3. Parking
a.) pavement area
b.) number of spaces and layout
4. Other:
D D. CONSTRUCTION AND OPERATION
1. Construction
a.) total construction period anticipated
b.) schedule of construction
c.) future potential development, on site
or on adjoining properties
d.) other:
2. Operation
a.) type of operation
b.) schedule of operation
c.) other:
] E. CLOSURE AND POST CLOSURE PLANS •
(for projects of planned limited life such as
landfills)
D F. APPROVALS
1. Required changes or variances to the zon-
ing regulations
2. Other permit approval or funding re-
quirements
IV. Environmental Setting
Place a check in the box to the left of those
topics to be included in the Draft EIS.
Natural Resources
D A. GEOLOGY
D 1. Subsurface
a.) composition and thickness of
subsurface material
examples:
—depth to, and nature of, bed-
rock formations and imperme-
able layers
—occurrence of an extractive
mineral resource
— usefulness as construction
material
b.) earthquake potential
D 2. Surface
a.) list of soil types
b.) discussion of soil characteristics
examples:
—physical properties (indication
of soils hydrological (infiltra-
tion) capabilities)
—engineering properties (soil
bearing capacity)
c.) distribution of soil types at pro-
ject site
d.) suitability for use
examples:
—agriculture
— recreation
— construction
—mining
e.) other:
D 3. Topography
a.) description of topography at pro-
ject site
examples:
—slopes
—prominent or unique features
b.) description of topography of sur-
rounding area
D B. WATER RESOURCES
1. Groundwater
a.) location and description
aquifers and recharge areas
examples:
—depth to water table
— seasonal variation
— quality
—quantity
—flow
of
2.B-10
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Human Resources .
D A. TRANSPORTATION
D 1. Transportation services
a.) description of the size, capacity
and condition of services
examples:
—roads, canals, railroads,
bridges
—parking facilities
—traffic control
b.) description of current level of use
of services
examples:
—a.m. and p.m. peak hour traffic
flow
—vehicle mix
—sources of existing traffic
volume
D 2. Public transportation
a.) description of the current
availability of service
b.) description of present level of
use
LJ 3. Pedestrian environment
D 4. Other
D B. LAND USE AMD ZONING
D 1. Existing land use and zoning
a.) description of the existing land
use of the project site and the
surrounding area
• examples:
—commercial
—residential
—agricultural
—business
—retail
—industrial
—vacant
b.) description of the existing zoning
of site and surrounding area
O 2. Land use plans
a.) description of any land use plans
or master plans which include
project site and surrounding area
b.) discussion of future development
trends or pressures
D 3. Other:
D C COMMUNITY SERVICES (for this section in-
clude a list of existing facilities and a discus-
sion of existing levels of usage and pro
jected future needs)
D 1. Educational facilities
D 2. Police protection
O 3. Fire protection
D 4. Health care facilities
D 5. Social services
D 6. Recreational facilities
D 7. Utilities
D 8. Other:
D D. DEMOGRAPHY
D 1. Population characteristics
a.) discussion of the existing popula-
tion parameters
examples:
—distribution
—density
—household size and composi-
tion
b.) discussion of projections for
population growth
D 2. Other
Q E. CULTURAL RESOURCES
O 1. Visual resources
a.) description of the physical
character of the community
example:
—urban vs. rural
b.) description of natural areas of
significant scenic value
; c.) identification of structures of
significant architectural design
O 2. Historic and archaeological
resources
allocation and description of
historic areas or structures listed
on State or National Register or
designated by the community
b.) identification of sites having
potential significant ar-
chaeological value
2.B-11
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b.) identification of present uses and
level of use of groundwater
examples:
—location of existing wells
—public/private water supply
—industrial uses
—agricultural uses
O 2. Surface water
• a.) location and description of sur-
face waters located on project
site or those that may be in-
fluenced by the project
examples:
—seasonal variation
—quality
—classification according to
New York State Department of
Health
b.) identification of uses and level of
use of all surface waters
examples:
—public/private water supply
—industrial uses
—agricultural uses
—recreation
c.) description of existing drainage
areas, patterns and channels
d.)discussion of potential for
flooding, si I tat ion, erosion and
eutrophication of water sources
D C. AIR RESOURCES
D 1. Climate
a.) discussion of seasonal variations
and extremes
examples:
-temperature
—humidity
—precipitation
—wind
D 2. Air quality
a.) description of existing air quality.
levels
examples:
—list the National and State Air
Quality Standards for the pro-
ject area and the compliance
status for each standard
b.) identification of existing sources
or pollutants-fixed or mobile
c.) identification of any sensitive
receptors in project area
examples:
—hospitals, schools, nursing
homes, parks
d.) description of existing monitor-
ing program (if applicable)
D D. TERRESTRIAL AND AQUATIC ECOLOGY
D 1. Vegetation
a.) list vegetation types on the pro-
ject site and within the surround-
ing area
b.) discussion of site vegetation
characteristics
examples:
—species present and abundance
—age
—size
—distribution
—dominance
—community types
—unique, rare and endange
species
—value as habitat for wildlife
—productivity
O 2. Fish and Wildlife
a.) list of fish and wildlife species on
the project site and within sur-
rounding area, including
migratory and resident species
b.) discussion of fish and wildlife
population characteristics
examples:
—species present and abundance
—distribution
—dominance
—unique, rare and endangered
species
—productivity
D 3. Wetlands
a.) list wetland areas within or con-
tiguous to the project site
b.) discuss wetland characteristics
examples:
—acreage
—vegetative cover
—classification
—benefits of wetland such
flood and erosion contr
recreation
'o^^T
2.B-12
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D 3. Noise
a.) identification of existing level of
noise in the community
b. identification of major sources of
noise
examples:
—airports
—major highways
— industrial/commercial facili-
ties
D 4. Other
V. Significant Environmental Impacts
Identify those aspects of the environmental set-
ting in Section IV that may be adversely or
beneficially affected by the proposed action and re-
quire discussion.
VI. Mitigation Measures to Minimize Environmen-
tal Impact
Describe measures to reduce or avoid potential
adverse impacts identified in Section V. The follow-
ing is a brief listing of typical measures used for
some of the major areas of impact.
Natural Resources
D A. GEOLOGY
1. Subsurface
a.) use excavated material for land
reclamation
b.)use facility wastes (ash, sludge)
for land reclamation
c.) other
2. Surface
a.) use topsoil stockpiled during
construction for restoration and
landscaping
b.) minimize disturbance of non-
construction sites
c.) design and implement soil ero-
sion control plan
d.) other
3. Topography
a.) avoid construction on areas of
steep slope
b.) design adequate soil erosion
devices to protect areas of steep
slope
c.) other
D B. WATER RESOURCES
1. Groundwater
a.) design adequate system of treat-
ment for stormwater runoff prior
to recharge of groundwater
b.) maintain permeable areas on the
site
c.) institute a program for monitor-
ing water quality in adjacent
wells
d.) other
2. Surface water
a.) ensure use of soil erosion control
techniques during construction
and operation to avoid siltation
examples:
—hay bales
—temporary restoration of
vegetation to disturbed areas
—landscaping
b.) design adequate stormwater con-
trol system
c.) restrict use of salt or sand for
road and parking area snow
removal
d.) avoid direct discharges to surface
water resources
e.) other
D C AIR RESOURCES
1. Air quality
a.) assure proper construction prac-
tices
examples:
—fugitive dust control
—proper operation and
maintenance of construction
equipment
b.) design traffic improvements to
reduce congestion and vehicle
delay
c.) install and ensure the proper
operation of emission control
devices
d.) initiate a program for monitoring
of air quality
e.) other
2.B-13
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D D. TERRESTRIAL AMD AQUATIC ECOLOGY
1. Vegetation
a.) restrict clearing to only those
areas necessary
b.) preserve part of site as a natural
area ' '
c.) after construction, landscape site
with naturally occurring vegeta-
tion
d.) purchase open space at another
location and dedicate to local
government or conservation
organization
e.) other
2. Fish and Wildlife
a.) provide adequate habitat (shelter
and food) for remaining wildlife
species
b.) schedule construction to avoid
sensitive periods of fish and
wildlife life cycles
c.) other:
Human Resources
D A. TRANSPORTATION
1. Transportation services
a.) design adequate and safe access
to project site to handle pro-
jected traffic flow
b.) install adequate traffic control
devices
c.) optimize use of parking areas
d.) encourage car pooling and opera-
tion of facility during non-peak
traffic times
e.) design special routing and
restricted hours for delivery truck
traffic
f.) other
2. Public transportation
a.) adjust public transportation
routes and schedules to service
the facility
b.) encourage use of public transpor-
tation by using incentive pro-
grams for employees or by sell-
ing tickets in facility
c.) other
D B. LAND USE AND ZONING
1. Existing land use and zoning
a.) design project to comply with ex-
isting land use plans
b.) design functional and visually ap-
pealing facility to set standard
and precedent for future
surrounding land use
c.) other:
D C. COMMUNITY SERVICES "~~
1. Police protection
a.) minimize local police protection
responsibilities by providing
private security force
b.) provide security systems, alarms
for facility
c.) provide equipment, funds or ser-
vices directly to the community
d.) other
2. Fire protection
a.) use construction materials that
minimize fire hazards
b.) incorporate sprinkler and ala
systems into building design
c.) provide equipment, funds or ser-
vices directly to the community
d.) other:
3. Utilities
a.) install utility services
underground
b.) incorporate water saving fixtures
into facility design
c.) incorporate energy-saving
measures into facility design
d.) other:
D D? CULTURAL RESOURCES
1. Visual resources
a.) design exterior of structure to
physically blend with existing
surroundings
b.) minimize- visual impact through
thoughtful and innovative design
of lighting and signs (consider
height, size, intensity, glare and
hours of lighting operation)
c.) design landscaping to be visually
pleasing and to serve as a buffer
between surrounding land uses,
parking areas, operational equip-
ment and facilities
d.) other:
hat I
mM
2.B-14
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2. Historic and archaeologic resources
a.) allow historical and ar-
chaeological officials access to
the project site during excavation
b.) devote space within project site
to a display of historical and ar-
chaeological artifacts of local in-
terest
c.) preserve architecturally signifi-
cant structures and make a
photographic and statistical
record of those that must be
destroyed
d.) other:
3. Moise
a.) schedule construction/operation
to occur during "normal
business" hours minimizing
noise impact during sensitive
times (early morning, night)
b.) assure adherence to construction
noise standards
c.) design berms and landscaping to
block and absorb noise
. d.) other
VII. Adverse Environmental Effects that Cannot
be Avoided if the Project is Implemented
Identify those adverse environmental effects in
Section V that can be expected to occur regardless
of the mitigation measures considered in Section
VI.
VIII. Alternatives
This section contains categories of alternatives
with examples. Discussion of each alternative
should be at a level sufficient to permit a com-
parative assessment of costs, benefits and. en-
vironmental risks for each alternative. It is not ac-
ceptable to make simple assertions that a particular.
alternative is or is not feasible. Identify those
categories of alternatives which should be included
in the EIS by placing a check in the box located to
the left of the topic.
D A. ALTERNATIVE DESIGN AND
TECHNOLOGIES
1. Site layout
a.) density and location of structures
b.) location of access routes, park-
ing and utility routes
2. Orientation
a.) compatibility with slope and
drainage patterns
b.)site size and setback re-
quirements
3. Technology
a.) pollution control equipment
b.)innovative vs. proven
technologies
4. Mix of activities
a.) addition of businesses which
would affect the operational
nature of the facility
D B. ALTERNATIVE SITES
1. Limiting factors
a.) availability of land
b.) suitability of alternate site to ac-
comodate design requirements
c.) availability of utilities
d.) suitable market area
e.) compatibility with local zoning
and master plan
f.) compatibility with regional ob-
jectives
g.) accessibility of site to transporta-
tion routes and the service
population
D C ALTERNATIVE SIZE
1. Increase or decrease project size to
minimize possible impacts
2. Increase or decrease project size to
correspond to market and com-
munity needs
D D. ALTERNATIVE CONSTRUCTION/OPERA-'
TION SCHEDULING
1. Commence construction at a dif-
ferent time
2. Phase construction/operation
3. Restrict construction/operation
work schedule
2.8-15
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D E ALTERNATIVE LAND CJSE
1. Suitability of site for other uses
a.) other types of commercial uses
b.) other types of industry
c.) different types of housing
d.) other:
2. Public vs. private use
D F. NO ACTION
1. Impacts of no action
a.) effect on public need
b.) effect on private developers'need
c.) beneficial or adverse en-
vironmental impacts
D G. OTHER:
IX. Irreversible and Irretrievable Commitment of
Resources
Identify those natural and human resources listed
in Section IV that will be consumed, converted or
made unavailable for future use.
X. Growth Inducing Aspects
Describe in this section the potential growth
aspects the proposed project may have. Listed
below are examples of topics that are typically af-
fected by the growth induced by a project.
D A. POPULATION
1. Increases in business and resident
population due to the creation or
relocation of business
2. Increases in resident population due
to the construction of housing
D B. SUPPORT FACILITIES
1. Businesses created to serve the in-
creased population
2. Service industries created to supply
new facility
D C. DEVELOPMENT POTENTIAL
1. Introduction or improvement of in-
frastructure (roads, waste disposal,
sewers, water) to service proposed
project
2. Creation of further growth potential
by construction -of improved in-
frastructure
D D. OTHER:
XI. Effects on the CIse and Conservation of Energy
Resources
Identify the energy sources to be used, an-
ticipated levels of consumption and ways to reduce
energy consumption. The examples listed below are
typical issues to be considered when addressing this
topic
D A. PROPOSED ENERGY SOURCES AND
ALTERNATIVES
D B. ANTICIPATED SHORT-TERM/LONG-TERM
LEVELS OF ENERGY CONSUMPTION
D C. INDIRECT EFFECTS ON ENERGY CON-
SUMPTION
1. Increased dependence on
automobile use
2. Increased levels of traffic due to pro-
posed project
D D. ENERGY CONSERVATION MEASURES
1. Design methods to reduce fuel use
for heating, cooling, and lighting
a.) conventional technology
examples:
—insulation
—thermopane windows
—use of low wattage lights
b.) innovative technology
examples:
—heat pumps
—solar panels
—wind energy
—use of waste heat from an in-
dustrial plant
c.) efficient layout
examples:
—orientation of structures in
relation to summer and winter
sunlight
—clustering of structures to
maximize common walls
—shortening of utility runs
—shared insulation and heating
2. Indirect energy benefits
a.) location and design of facility to
accomodate mass transit
b.) use of shuttle buses
c.) location of facility to minimize
travel distance
D E. OTHER:
2.B-16
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XII. Appendices
Following is a list of materials typically used in
support of the EIS.
A. List of underlying studies, reports and infor-
mation considered and relied on in preparing state*
ment
B. List all federal, state, regional, or local agen-
cies, organizations, consultants and private persons
consulted in preparing the statement
C. Technical exhibits (if any) at a legible scale
0. Relevant correspondence regarding the pro-
jects may be included (required in the Final EIS)
Additional Draft EIS Scoping Topics
Indicate any additional topics for discussion in the
Draft EIS. Attach additional sheets if necessary.
2.B-17
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2.B-18
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ChecUfctofPot
Action: Impcetof IbeNtfkailEiiviri
* of •Transportation Project (Source: A.D. Little. Inc. 1971. Transportation sod Enviromment: Synthesis for
ntal Policy Act of 1969 on the Department of Transportation. VoL MO, prepared for the Office of the Secretary,
Departmeotof Transportation. Jury 1971.)
CATEGORY
I. Noise Impacta
A. Public heakh
a LsndUse
D. Air Quality Impacts
A. Public beakh
a Land Use
A. Ground Water
1. Flow and water table alterations
2. Ii«ei»ctionwim surface dninaie
a Surface Water
1. Shoreline sad bottom attention
2. EHecfcoffiUfccsiridftdfini
3. Dnmafesad flood characteristic*
C. Quality Aspects
1. Effect of vflliiCDi losojnfs
2. Implication of other actions, such ss
a. Disturbance of benmiclsyen
fe. A •flSJtiOB of dUTEOfi
c. Chsofes in flow refine
d. S«lioeintrusio« in jround water
3. Land use
4. Public beakh
IV. Sod Erosion Impacta
A. Economic and Land Use
B. PoUutMoandSikation
V. Bcolofical Impacta
A. Plan
a Fauna (other than huroaw)
VI. Economic Impacts
A. Land Use
1. UMnrnedistevickMty of project
3. Inrefioa
a Tax Base
C. Employment
1. Access to existinc oppoittButies
2. Creation of new jobs
3. Dvplacenieot from jobs
D. Housinf and Public Services
1. Demand for new services
2. Alteration mexistmf services
E Income
VH. Sociopolitical Impacta
A. Damaf e to, or use of:
1. Cukural resources
2. Scientific resources
3. nuitoncal resources
4. RecreatiorMl areas
B. Lifestyle sod Activities
1* -• «Uttsfe. ',
2* DsWupliott of ooonuuly
C. rVrcqitiaaofcoit/baieArvaUfliacntcoheirvesTOups
1. Racial
2. Ethaic
3. Income chss
D. Personal Safety
A. Scenic Resources
a Urban Desifn
C. Noise
D. Air Quality
E Water Qualify
PLANNING.
DESIGN
_,
CONSTRUCTION
OPERATION
2.B-19
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2.B-20
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ATTACHMENT 2.C
THE INTERDISCIPLINARY EA TEAM
Hie Interdisciplinary Team - Its Characteristics and Responsibilities.
(Source: Shipley Associates. 1990. Applying the NEPA Process, Shipley Associates,
P.O. Box 460, Bountiful, Utah 84011)
2.C-1
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2.C-2
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The Interdisciplinary Team • Its Characteristics and Responsibilities (Source: Shipley
Associates. 1990. Applying the NEPA Process, Shipley Associates, P.O. Box 460,
Bountiful, Utah 84011)
The quality of the interdisciplinary team is more than just the sum of the quality of its
members—the creativity sparked by the interaction through brainstorming is explosive when
members are appropriate to the task and they understand their responsibilities. This information
provides the basis for selecting team members and directing the role that each member will fill
in the analysis process.
The Team Leader
A. The responsibilities of the team leader are to:
• Be fully accountable to the responsible official.
• Manage and direct all steps of the NEPA analysis process including scoping, as
delegated by the responsible official.
• Be the liaison between the responsible official and the team negotiating time
frames and responsibilities of individual team members, requesting clarification
and guidance from the responsible official, and reporting progress on the analysis
at appropriate milestones.
• Ensure that the results of all steps in the analysis are consistent with agency
management or master plans.
• Plan and manage (and possibly facilitate) all team meetings as well as meetings
with outside agencies, applicants, and the public as delegated by the responsible
official.
• Monitor the progress of work of each {team member.
• Ensure that all milestones and deadlines are met, and renegotiate them as
necessary.
• Evaluate the performance of all team members.
» Motivate team members to accomplish their best work efficiently.
• Mediate and resolve conflicts with the assistance of responsible official as
necessary.
• Ensure that all information provided by the team members is appropriate, timely,
complete, and analytic.
• Maintain the planning record or delegate the responsibility.
• Keep the results of the analysis organized.
• Be the liaison with the writer/editor of the document.
2.C-3
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B. Personal and professional characteristics and skills that the team leader must have are:
• Facilitation skills: the ability to manage team members in an interactive setting
that is personally risk-free for each member within a creative, positive, efficient,
caring, and objective atmosphere
• Knowing the steps required in the NEPA analysis process, including when to
return to a previous step and when to request clarification and guidance from the
responsible official, and being experienced in application of the process
• Being an active listener, ensuring that all team members understand and have a
chance to constructively comment and build on all comments made by team
members
• Being an accomplished communicator, using both verbal and body language
effectively
• Motivation skills including an understanding of the need of different personality
and temperament types, a sincere dedication to the success of the project, and a
willingness to work with individual team members to resolve difficulties
• Creativity, the ability to make the team more than a sum of its individual parts
• Sound judgment about local and regional agency politics
• Ability and willingness to meet deadlines and to recognize and renegotiate
inappropriate deadlines
• Ability to communicate effectively with people throughout the agency hierarchy
and with people from other agencies and the public
• Ability to communicate criticism and praise constructively and effectively
Core Team Members
A. The responsibilities of core team members are to:
• Interactively and objectively identify and clarify the environmental issues, develop
alternative ways to meet project objectives while minimizing or avoiding
environmental impacts, and clearly predict impacts on specific environmental
resources.
Gather appropriate data in a technically correct manner.
Help develop and implement an appropriate public involvement strategy.
Develop the document format.
Help write the document using the interdisciplinary process.
Provide clearly written information to any writer/editors.
Provide constructive peer review of written and verbal information.
Ensure all resource information and analyses are consistent with agency
management or master plans.
Interactively review proposal onsite as well as monitor implementation and
environmental effects.
2.C-4
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B. Personal and professional characteristics and skills that the core team members must have
are:
• Expertise, experience, and training in their particular resource field
• Knowledge of the NEPA analysis process and experience in application of the
process
• Team-building skills such as the ability to encourage the risk-free atmosphere for
all team members; ask questions affirmatively; disagree constructively; encourage
all members to actively participate; and negotiate objectively, flexibly, and with
tolerance
• Good communication skills including written, verbal, and body language
• Creativity in conceptualizing and solving problems
• Ability to understand different personality and temperament types and recognize
their value in maintaining diversity and creativity on the team
• Ability and willingness to communicate complex technical environmental
information in plain language to team members with little or no background in a
particular discipline
• Willingness to ask questions about a particular discipline and insist on clear
answers
• A sense of humor
Extended Team Members
A. The responsibilities of the extended team members are to:
• Provide resource data or data interpretation and other functional assistance as
requested by the team leader or members.
• Provide information and expertise for identifying issues, alternatives, and
environmental impacts as requested.
• Provide written information as requested.
B. Personal and professional characteristics and skills that the extended team members must
have are:
• Expertise, experience, and training in their particular resource field
• Ability and willingness to write and speak in plain language
• Ability and willingness to meet deadlines
• Ability to prioritize their time
2.C-5
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2.C-6
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ATTACHMENT 2.D
PLANNING RECORDS
Contents of a Planning Record. (Source: Environmental Policy and Procedures
Handbook. U.S. Forest Service Handbook 1909.15, Region 10, Supplement No. 1,
Juneau, AK 8/90)
2.D-1
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2.D-2
-------
Contents of a Planning Record. (Source: Environmental Policy and Procedures
Handbook. U.S. Forest Service Handbook 1909.15, Region 10, Supplement No. 1,
Juneau, AK 8/90)
A. The Planning Record includes:
• A copy of all notices appearing in the FEDERAL REGISTER.
• All formal recommendations and directions from line officers, staff/directors, the
interdisciplinary team (IDT) leader, or other entities and all formal requests for
such recommendations or directions.
• All records of consultation with the public, interest groups, and other agencies.
• A record of all announcements for public participation activities including a copy
of the announcement as published in each source, the date of the announcement,
the medium or source used to make the announcement (newspaper, magazine,
television, or radio), and the area of circulation.
• A record of each major public participation activity including the date and
location of the activity, names of participants or contributors, purpose of the
activity, and summary of accomplishments of the activity (public comments,
questions, suggestions, and decisions or agreements). Include hearing transcripts
and tapes.
• Any draft of a work product or other document if it is clear that (a) the draft was
used in the planning/decisionmaking process (e.g., an unsigned draft wilderness
plan used for its technical content) or (b) a draft circulated externally for
comment (e.g., drafts provided to state agencies or interest groups for comment).
• All transmittal memoranda or letters enclosing or documenting circulation of any
of the above products.
• All decision documents and any accompanying news release, circulation, or
mailing lists, or other attachments, summaries, and so forth.
• Published final and draft Environmental Impact Statements (EIS), Records of
Decision (ROD), Environmental Assessments (EA), Decision Notices (DN),
Decision Memos (DM), and any maps, charts, summaries, and so forth, made
publicly available with these documents.
• Documents referenced (including other NEPA documents or decisions) in a draft,
supplemental or final EIS, ROD, EA, DN, or DM. If the references are lengthy,
include a copy of the cover and the specific chapter, section, or page referenced
along with identifying information including the author, title, and date.
Documents which are not readily available should be included in their entirety.
• All completed work products, which may or may not be marked as final,
including IDT, specialist or resource reports, studies, inventories, or study plans
prepared by the Forest Service or other entities.
• Electronic data frozen at a date specified, such as the date of use in the decision
or the date of the decision. Include electronically generated data in the planning
record either as hard copy or on electronic storage media such as disks or tapes
suitable for producing a hard copy on demand.
2.D-3
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• Forms indicating the location and physical description (dimensions, number of
pages, color, edition, and so forth) of any document not physically included in
the planning record due to size, bulk, volume, or availability and examples of
such documents if available.
• Both formal and informal selection criteria for determining membership on the
interdisciplinary planning team.
• Each IDT member's specific qualifications including expertise, years of
experience and education, and the specific contribution the team member makes
to the development of the guide or plan*. Document when IDT members join and
leave the team.
• Minutes of interdisciplinary team meetings, management team meetings, or other
staff meetings including the date, all participants or contributors, their titles
and/or positions, and a summary of major happenings such as accomplishments,
agreements, and decisions.
• Documentation of all coordination activities with adjacent regions and national
forests including the date, major participants or contributors, their titles and/or
positions, and a summary of major happenings such as accomplishments,
agreements, and decisions.
• Records of each meeting or activity involving external coordination, including
other federal, state, county, local governments, Indian tribes and special interest
groups including the type, date, location of the activity, all participants or
contributors, purpose of the activity, summary of accomplishments, including
information exchanged, comments, questions, suggestions received, and decisions
or agreements.
• A dated copy of all agreements with Indian tribes and state or other federal
agencies.
• Final computer runs used in the analysis.
B: Documents Not Included in the Planning Record. The documents listed below are part
of the work process and may have some value as background or historical information.
These work documents should either be destroyed or be clearly disassociated from the
formal Planning Record.
The Planning Record should not include:
• Drafts of any document, except as specified above.
• Informal preliminary internal deliberations, such as comments on internal drafts,
informal notes of internal IDT meetings, and so forth.
• Other notes for which there is no documentation of circulation or adoption as
final recommendations, direction, inventory,, or analysis.
• Preliminary computer runs which were not used in the final decisionmaking
process.
• Personnel documents, other than IDT selection records, and fiscal documents.
2.D-4
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CHAPTERS
SCOPING
-------
CHAPTERS
SCOPING
Scoping is a process of interaction between interested publics, government
agencies and proponents to determine the important issues and alternatives that
should be examined in environmental impact assessment. In its broadest sense,
it includes public involvement throughout the EA process starting with public
scoping meetings as soon as the proponent decides that information on the
proposed activity is complete enough for the process to begin; continuing with
public review and comment on the assessment documentation; and culminating
with public involvement during the post-decision and follow-up phases. At any
time during these various phases, the scope of a project EA can change. In the
U.S., if there are substantial changes to a proposal or significant new
circumstances or information relevant to environmental concerns, a supplement
to an EA document can be prepared. Scoping is especially useful for
controversial activities that involve diverse interest groups and government
agencies.
During the scoping process, formal and informal opportunities should be
provided for the public and government agencies to voice their concerns, raise
new issues, suggest modifications to proposed actions, and present additional
alternatives. For the proponent, scoping provides the opportunity to describe the
proposed activity and to obtain additional information from the public and
government agencies (e.g., studies and reports relevant to the project,
identification of local expertise, and regulatory constraints). In addition, scoping
enhances the proponent's credibility, improves relationships with the affected
parties, and may help in avoiding unforseen developments or surprises.
A report summarizing the scoping process, the significant alternatives and
issues, and including comments received from the public should be prepared and
made available to all interested parties. The report should describe the issues and
the extent of coverage to be expected in the EIA.
The objectives of scoping (Attachment 3.A) are:
• To identify the affected public and agency concerns;
• To facilitate an efficient EIA preparation process, through
assembling the cooperating agencies, assigning EIA writing tasks,
3-1
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ascertaining all the related permits and reviews that must be
scheduled concurrently, and setting time or page limits;
• To define the issues and alternatives that will be examined in detail
in the EIA while simultaneously devoting less attention and time
to issues which cause no concern; and
• To save time in the overall process by helping to ensure that draft
statements adequately address relevant issues, reducing the
possibilities that new comments will cause a statement to be
rewritten or supplemented.
NEEDS
• Preliminary Project Information. Prior to public and
government agency involvement, the proponent should assemble
and make available to known interested parties a packet of
information about the proposed activity, including a preliminary
outline of the EIA. The information packet is based on
environmental information prepared during the initiation phase
(Chapter 2.1). The information serves as a starting point for
discussion at scoping meetings and any other public meetings; it
helps to focus discussion on the proposed activity. In general, the
information should:
describe the purpose and need for the proposed activity,
describe the proposed activity,
identify the potentially affected geographic area,
describe the important characteristics of the area,
review the preliminary alternatives, and
discuss known project-related issues.
• Early Planning. Scoping meetings should be held very early in
the EA process. The key to successful meetings is appropriate
notification and participation of the publics and government
agencies and availability/distribution of enough information on the
proposed activity so that the public and relevant agencies can
participate effectively. If the proposed activity is regional or
national in scale, several meetings may be held in different
locations. The duration of meetings will vary depending on the
level of controversy or interest in the proposed activity.
• Public Involvement Strategy. Public involvement, particularly
when it occurs early in the EA process, can result in better
reasoned and more legally defensible decisions, as well as, less
controversy and broader public acceptance of the decisions. There
3-2
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are a variety of techniques available for involving the public (Table
2-1); however, each public involvement strategy must be tailored
to the circumstances of the proposed activity, as well as the
community in which the public involvement process is to occur.
Once the interested publics and government agencies are identified,
their continued involvement should be solicited throughout the EA
process.
Although scoping meetings are designed to involve the public, the
proponent has the ultimate responsibility for selecting the
alternatives to be evaluated in the environmental assessment.
Thus, the proponent seldom tries to reach a consensus among
participants at meetings/hearings on what issues are significant and
which alternatives should be evaluated. Rather, careful notes are
taken (often by tape recorder or a court reporter) and revisions are
made to the scope of work later, as appropriate. Decisions on the
choice of alternatives are guided by public interest and the
proponent's mandated responsibilities.
TOOLS
• Public Meetings. There is no uniform set of guidelines for the
conduct of scoping meetings or public hearings. In general,
scoping meetings precede preparation of EA documentation and
public hearings follow publication of the draft EA documentation.
In public hearings, citizens can testify about the draft
documentation and hear the testimony of others. A scoping
meeting is generally less formal than a hearing. In either case,
meetings are best conducted by an independent, neutral moderator
who has a thorough understanding of EA requirements and who
has been involved in the development of the specific procedures to
be followed. Legal counsel is usually present at the meetings. A
professional moderator is trained to focus the discussions, maintain
the schedule, and de-fuse impending controversy. In the opening
remarks, the moderator should:
explain what scoping is,
describe the procedure for the meeting,
point out that comments should be relevant to the proposed
activity,
reiterate that no decision has been made on the proposal or
the contents of the EA documentation, and
encourage the audience to focus on the alternatives, issues,
and additional information that they can provide.
3-3
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Relative to public meetings, the following activities have
been shown to be useful:
A premeeting/prehearing conference of all identified and
potentially interested publics and government agencies to
identify key procedural and substantive issues related to the
proposed activity.
Preparation and distribution of a handout that explains what
- scoping is and how the particular meeting/hearing is to be
conducted.
Development of a format for the meeting/hearing to include
style of meeting, logistics and set up of the meeting room,
and procedures for speakers (i.e., registration, order of
speaking, time allowed). Question and answer sessions can
be useful in meetings as well as hearings, provided the
process is carefully structured in advance (i.e., the
appropriate expertise is present to respond). Town hall
meeting forums (a roving moderator with microphone) are
useful if the meeting is small. In general, for scoping
meetings, the moderator's opening statement can be brief
and informal. For hearings, the moderators opening
statement is more formal, longer, and proponent
presentations are generally limited.
A post meeting/hearing consultation with key participants
to provide additional information and
clarification/understanding of each others positions. Such
meetings should be informal but the basic ground rules
need to be clear to everyone.
The process of scoping is not limited to interagency and public meetings.
Other activities that have been shown to be useful include:
• Advisory Committees. When projects are large and/or
controversial, appointment of an advisory committee of
independent experts can help to identify issues, generate
alternatives, provide mitigation measures, and review and comment
on EA documentation.
• Workshops. Representatives of interested groups can be invited
to work together in small groups to assess alternatives and evaluate
their feasibility.
In each of the above cases, however, the final decision on the scope and content
of the EA is the responsibility of the agency.
3-4
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• Other Public Involvement Strategies. Table 2-1 lists public
involvement strategies and evaluates their usefulness. In addition
to these, agencies are increasingly using a special telephone
number (i.e., a hotline) to take public comments before, after or
instead of a public meeting.
ISSUES
The importance of scoping to the preparation of adequate and effective EA
documentation is recognized by most publics and government agencies. It
originated in response to the uneven implementation of NEPA by U.S.
government agencies (i.e., some agencies obscured the important issues in
massive EA documents while others prepared brief documents that failed to
analyze the important issues). The concept has been adopted by other countries
(e.g., Canada, The Netherlands, Poland) as a means to determine important issues
and alternatives to be examined during EA. Although the principle of scoping is
appropriate at all levels of decisionmaking, at the broadest level of government
decisionmaking (i.e., for policy, program, and plan initiatives), scoping is mostly
internal to an agency. Other affected government agencies may be asked to
participate, but the public is seldom invited.
In practice, approaches to scoping vary widely depending on the nature of
a proposed activity, the proponent's resources, and the public interest.
Throughout the process, it is important to remain flexible, keeping in mind that
the overall goal of EA is providing appropriate information and analyses in order
that informed decisions can be made.
• The benefits of scoping include:
early identification of areas that will need attention (e.g.,
information gaps, additional research, additional
professional expertise, regulatory constraints);
improved efficiency and effectiveness. The public is
provided with opportunities to understand and influence the
EA process early on and the proponent gains insight into
the issues of real concern. As a result, the proponent can
focus the environmental analyses on realistic alternatives
and mitigation measures at the early stages of project
planning;
resolution of problems before documents are prepared and
decisions are made which lessens the opportunities for
surprises and for litigation; and
enhanced credibility and public support. Although conflicts
may still arise, if the public understands the purpose and
need for the proposed activity and if it is clear that the
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proponent is considering all reasonable alternatives, then I
the public is more likely to be satisfied with the final
decision.
• Some common problems associated with scoping are:
poorly defined purpose, need, and objectives of the
proposed action,
poorly, prepared and/or tardy information packets,
failure to contact all affected parties,
• lack of interest/participation by the public and government
agencies,
unprepared participants,
negative public attitude toward the proposed activity, and
unfocused public comments that fail to address the effects
that the EA documentation should evaluate.
LINKAGES
Scoping and the results of scoping are integral parts of the overall
environmental assessment process. Formal scoping meetings are a catalyst for
careful planning at the initiation stage. The results of the scoping process
determine the alternatives, issues and mitigation measures analyzed in the EA
documentation. Decisionmaking is influenced by public participation.
REFERENCES
Bregman, J. I. and K. M. Mackenthun. 1992. Environmental Impact
Statements. Lewis Publishers, Inc., Chelsea, Michigan. 279 pp.
Federal Environmental Assessment Review Office (FEARO). 1976. Initial
Assessment Guide. Federal Assessment Review Office, Ottawa K1A
OH3, Ontario, Canada.
U.S. Council on Environmental Quality (CEQ). 1981. Memorandum: Scoping
Guidance. Washington, D.C. 19 pp.
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ATTACHMENT 3.A
SCOPING GUIDANCE
• Memorandum: Scoping Guidance. (Source: Council on Environmental Quality,
April 30, 1991)
3.A-1
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3.A-2
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Memorandum: Scoping Guidance
(Council on Environmental Quality
April 30, 1981)
I. Introduction
A. Background of this document.
In 1978, with the publication of the proposed
NEPA regulations (since adopted as formal
rules, 40 C.F.R. Parts 1500-1508), the Council
on Environmental Quality gave formal
recognition to an increasingly used term -
scoping. Scoping is an idea mat has long been
familiar to those involved in NEPA compliance:
In order to manage effectively the preparation of
an environmental impact statement (EIS), one
must determine the scope of the document - that
is, what will be covered, and in what detail.
Planning of this kind was a normal component
of EIS preparation. But the consideration of
issues and choice of alternatives to be examined
was in too many cases completed outside of
public view. The innovative approach to scoping
in the regulations is that the process is open to
the public and state and local governments, as
well as to affected federal agencies. This open
process gives rise to important new opportunities
for better and more efficient NEPA analyses;
and simultaneously places new responsibilities
on public and agency participants alike to
surface their concerns early. Scoping helps
insure that real problems are identified early and
properly studied; that issues mat are of no
concern do not consume time and effort; that the
draft statement when first made public is
balanced and thorough; and that the delays
occasioned by re-doing an inadequate draft are
avoided. Scoping does not create problems that
did not already exist; it ensures mat problems
that would have been raised anyway are
identified early hi the process.
Many members of the public as well as agency
staffs engaged hi the NEPA process have told
the Council mat the open scoping requirement is
one of the most far-reaching changes engendered
by the NEPA regulations. They have predicted
mat scoping could have a profound positive
effect on environmental analyses, on the impact
statement process itself, and ultimately on
decisionmaking.
Because the concept of open scoping was new,
the Council decided to encourage agencies'
innovation without unduly restrictive guidance.
Thus the regulations relating to scoping are very
simple. They state that "there shall be an early
and open process for determining the scope of
issues to be addressed" which "shall be termed
scoping," but they lay down few specific
requirements. (Section 1501.7*). They require an
open process with public notice; identification of
significant and insignificant issues; allocation of
EIS preparation assignments; identification of
related analysis requirements hi order to avoid
duplication of work; and the planning of a
schedule for EIS preparation that meshes with
the agency's decisionmaking schedule. (Section
1501.7(a)). The regulations encourage, but do
not require, setting time limits and page limits
for the EIS, and holding scoping meetings.
(Section 1501.7(b)). Aside from these general
outlines, the regulations left the agencies on their
own. me Council did not believe, and still does
not, that it is necessary or appropriate to dictate
the specific manner in which over 100 federal
agencies should deal with the public. However,
the Council has received several requests for
more guidance. In 1980 we decided to
investigate the agency and public response to the
scoping requirement, to find out what was
working and what was not, and to share this
with all agencies and the public.
The Council first conducted its own survey,
. asking federal agencies to report some of their
scoping experiences. The Council then
'All citations are to the NEPA regulations,
40C.F.R. Parts 1500-1508 unless otherwise
specified.
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contracted with the American Arbitration
Association and Clark McGlennon Associates to
survey the scoping techniques of major agencies
and to study several innovative methods in
detail.** Council staff conducted a two-day
workshop hi Atlanta in June 1980, to discuss
with federal agency NEPA staff and several EIS
contractors what seems to work best in scoping
of different types of proposals, and discussed
scoping with federal, state and local officials hi
meetings hi all 10 federal regions.
This document is a distillation of all the work
that has been done so far by many people to
identify valuable scoping techniques. It is
offered as a guide to encourage success and to
help avoid pitfalls. Since scoping methods are
still evolving, the Council welcomes any
comments on this guide, and may add to it or
revise it hi coming years.
B. What scoping is and what it can do.
Scoping is often the first contact between
proponents of a proposal and the public. This
fact is the source of the power of scoping and of
the trepidation that it sometimes evokes. If a
scoping meeting is held, people on both sides of
an issue will be hi the same room and, if all
goes well, will speak to each other. The
possibilities that flow from this situation are
vast. Therefore, a large portion of this
document is devoted to the productive
management of meetings and the de-fusing of
possible heated disagreements.
"The results of this examination are reported hi
"Scoping the Content of EISs: An Evaluation of
Agencies' Experiences," which is available from
the Council or the Resource Planning Analysis
Office of the U.S. Geological Survey, 750
National Center, Reston, Va. 22092.
Even if a meeting is not held, the scoping
process leads EIS preparers to think about the
proposal early on, hi order to explain it to the
public and affected agencies. The participants
respond with their own concerns about
significant issues and suggestions of alternatives.
Thus as the draft EIS is prepared, it will
include, from the beginning, a reflection or at
least an acknowledgement of the cooperating
agencies' and the public's concerns. This
reduces the need for changes after the draft is
finished, because it reduces the chances of
overlooking a significant issue or reasonable
alternative. It also in many, cases increases
public confidence hi NEPA and the
decisionmaking process, thereby reducing
delays, such as from litigation, later on when
implementing the decisions. As we will discuss
further in this document, the public generally
responds positively when its views are taken
seriously, even if they cannot be wholly
accommodated.
But scoping is not simply another "public
relations" meeting requirement. It has specific
and fairly limited objectives: (a) to identify the
affected public and agency concerns; (b) to
facilitate an efficient EIS preparation process,
through assembling the cooperating agencies,
assigning EIS writing tasks, ascertaining all the
related permits and reviews that must be
scheduled concurrently, and setting time or page
limits; (c) to define the issues and alternatives
that will be examined in detail in the EIS while
simultaneously devoting less attention and time
to issues which cause no concern; and (d) to
save time in the overall process by helping to
ensure that draft statements adequately address
relevant issues, reducing the possibility that new
comments will cause a statement to be rewritten
or supplemented.
Sometimes the scoping process enables early
identification of a few serious problems with a
proposal, which can be changed or solved
because the proposal is still being developed, in
these cases, scoping the EIS can actually lead to
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the solution of a conflict over the proposed
action itself. We have found that this extra
benefit of scoping occurs fairly frequently. But
it cannot be expected in most cases, and scoping
can still be considered successful when conflicts
are clarified but not solved. This guide does not
presume that resolution of conflicts over
proposals is a principal goal of scoping, because
it is only possible in limited circumstances.
-Instead, the Council views the principal goal of
scoping to be an adequate and efficiently
prepared EIS. Our suggestions and
recommendations are aimed at reducing the
conflicts among affected interests that impede
this limited objective. But we are aware of the
possibilities of more general conflict resolution
that are inherent in any productive discussions
among interested parties. We urge all
participants in scoping processes to be alert to
this larger context, hi which scoping could prove
to be the first step hi environmental
problem-solving.
Scoping can lay a firm foundation for the rest of
the decisionmaking process. If the EIS can be
relied upon to include all the necessary informa-
tion for formulating policies and making rational
choices, the agency will be better able to make
a sound and prompt decision. In addition, if it is
clear that all reasonable alternatives are being
seriously considered, the public will usually be
more satisfied with the choice among them.
n. Advice for Government Agencies
Conducting Scoping
A. General context.
Scoping is a process, not an event or a meeting.
It continues throughout the planning for an EIS,
and may involve a series of meetings, telephone
conversations, or written comments from
different interested groups. Because it is a
process, participants must remain flexible. The
scope of an EIS occasionally may need to be
modified later if a new issue surfaces, no matter
how thorough the scoping was. But it makes
sense to try to set the scope of the statement as
early as possible.
Scoping may identify people who already have
knowledge about a site or an alternative proposal
or a relevant study, and induce them to make it
available. This can save a lot of research time
and money. But people will not come forward
unless they believe their views and materials will
receive serious consideration. Thus scoping is a
crucial first step toward building public
confidence hi a fair environmental analysis and
ultimately a fair decisionmaking process.
One further point to remember: the lead agency
cannot shed its responsibility to assess each
significant impact or alternative even if one is
found after scoping. But anyone who hangs back
and fails to raise something that reasonably
could have been raised earlier on will have a
bard time prevailing during later stages of the
NEPA process or if litigation ensues. Thus a
thorough scoping process does provide some
protection against subsequent lawsuits.
B. Step-by-step through the process.
1. Stan scoping after you have enough
information.
Scoping cannot be useful until the agency knows
enough about the proposed action to identify
most of the affected parties, and to present a
coherent proposal and a suggested initial list of
environmental issues and alternatives. Until that
time there is no way to explain to the public or
other agencies what you want them to get
involved in. So the first stage is to gather
preliminary information from the applicant, or to
compose a clear picture of your proposal, if it is
being developed by the agency.
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2. Prepare an information packet.
In many cases, scoping of the EIS has been
preceded by preparation of an environmental
assessment (EA) as the basis for the decision to
proceed with an EIS. In such cases, the EA will,
of course, include the preliminary information
that is needed.
If you have not prepared an EA, you should put
together a brief information packet consisting of
a description of the proposal, an initial list of
impacts and alternatives, maps, drawings, and
any other material or references that can help the
interested public to understand what is being
proposed. The proposed work plan of the EIS is
not usually sufficient for this purpose. Such
documents rarely contain a description of the
goals of the proposal to enable readers to
develop alternatives.
At this stage, the purpose of the information is
to enable participants to make an intelligent
contribution to scoping the EIS. Because they
will be helping to plan what will be examined
during the environmental review, they need to
know where you are now in that planning
process.
Include in the packet a brief explanation of what
scoping is, and what procedure will be used, to
give potential participants a context for their
involvement. Be sure to point out that you want
comments from participants on very specific
matters. Also reiterate mat no decision has yet
been made on the contents of the EIS, much less
on the proposal itself. Thus, explain that you do
not yet have a preferred alternative, but that you
may identify the preferred alternative in the draft
EIS. (See Section 1502.14(e)). This should
reduce the tendency of participants to perceive
the proposal as already a definite plan.
Encourage them to focus on recommendations
for improvements to the various alternatives.
Some of the complaints alleging that scoping can
be a waste of tune stem from the fact that the
participants may not know what the proposal is
until they arrive at a meeting. Even the most
intelligent among us can rarely make useful,
substantive comments on the spur of the
moment. Don't expect helpful suggestions to
result if participants are put in such a position.
3. Design the scoping process far each project.
There is no established or required procedure for
scoping. The process can be carried out by
meetings, telephone conversations, written
comments, or a combination of all three. It is
important to tailor the type, the timing and the
location of public and agency comments to the
proposal at hand.
For example, a proposal to adopt a land
management plan for a National Forest in a
sparsely populated region may not lend itself to
calling a single meeting in a central location.
While people living in the area and elsewhere
may be interested, any meeting place will be
inconvenient for most of die potential
participants. One solution is to distribute the
information packet, solicit written comments, list
a telephone number with the name of the
scoping coordinator, and invite comments to be
phoned in. Otherwise, small meetings in several
locations may be necessary when face-to-face
communication is important.
In another case, a site-specific construction
project may be proposed. This would be a better
candidate for a central scoping meeting. But you
must first find out if anyone would be interested
in attending such a meeting. If you simply
assume that a meeting is necessary, you may
hire a hall and a stenographer, assemble your
staff for a meeting, and find that nobody shows
up. There are many proposals that just do not
generate sufficient public interest to cause people
to attend another public meeting. So a wise early
step is to contact known local citizens groups
and civic leaders.
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In addition, you may suggest in your initial
scoping notice and information packet that all
those who desire a meeting should call to request
one. That way you will only hear from those
who are seriously interested in attending.
The question of where to hold a meeting is a
difficult one in many cases. Except for site
specific construction projects, it may be unclear
where the interested parties can be found. For
example, an EIS on a major energy development
program may involve policy issues and
alternatives to the program mat are of interest to
public groups all over the nation, and to
agencies headquartered in Washington, D.C.,
while the physical impacts might be expected to
be felt most strongly in a particular region of the
country. In such a case, if personal contact is
desired, several meetings would be necessary,
especially in the affected region and hi
Washington, to enable all interests to be heard.
As a general guide, unless a proposal has no site
specific impacts, scoping meetings should not be
confined to Washington. Agencies should try to
elicit the views of people who are closer to the
affected regions.
The key is to be flexible. It may not be possible
to plan the whole scoping process at the outset,
unless you know who all the potential players
are. You can start with written comments, move
on to an informal meeting, and hold further
meetings if desired.
There are several reasons to hold a scoping
meeting. First, some of the best effects of
scoping stem from the fact that all parties have
the opportunity to meet one another and to listen
to the concerns of the others. There is no
satisfactory substitute for personal contact to
achieve this result. If there is any possibility that
resolution of underlying conflicts over a
proposal may be achieved, this is always
enhanced by the development of personal and
working relationships among the parties.
Second, even in a conflict situation people
usually respond positively when they are treated
as partners in the project review process. If they
feel confident that their views were actually
heard and taken seriously, they will be more
likely to be satisfied that the decisionmaking
process was fair even if they disagree with the
outcome. It is much easier to show people that
you are listening to them if you hold a
face-to-face meeting where they can see you
writing down their points, than if their only con-
tact is through written comments.
If you suspect that a particular proposal could
benefit from a meeting with the affected public
at any time during its review, the best time to
have the meeting is during this early scoping
stage. The fact that you are willing to discuss
openly a proposal before you have committed
substantial resources to it will often enhance the
chances for reaching an accord.
If you decide that a public meeting is
appropriate, you still must decide what type of
meeting, or how many meetings, to hold. We
will discuss meetings in detail below in
"Conducting a Public Meeting." But as part of
designing the scoping process, you must decide
between a single meeting and multiple ones for
different interest groups, and whether to hold a
separate meeting for government agency
participants.
The single large public meeting brings together
all the interested parties, which has both
advantages and disadvantages. If the meeting is
efficiently run, you can cover a lot of interests
and issues in a short time. And a single meeting
does reduce agency travel time and expense. In
; some cases it may be an advantage to have all
interest groups hear each others' concerns,
possibly promoting compromise. It is definitely
important to have the staffs of the cooperating
agencies, as well as the lead agency, hear the
public views of what the significant issues are;
and it will be difficult and expensive for the
cooperating agencies to attend several meetings.
3.A-7
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But if there are opposing groups of citizens who
feel strongly on both sides of an issue, the
setting of die large meeting may needlessly
create tension and an emotional confrontation
between the groups. Moreover, some people
may feel intimidated in such a setting, and won't
express themselves at all.
The principal drawback of the large meeting,
towever, is that it is generally unwieldy. To
keep order, discussion is limited, dialogue is
difficult, and often all participants are frustrated,
agency and public alike. Large meetings can
serve to identify the interest groups for future
discussion, but often little else is accomplished.
Large meetings often become "events" where
grandstanding substitutes for substantive
comments. Many agencies resort to a formal
hearing-type format to maintain control, and this
can cause resentments among participants who
come to the meeting expecting a responsive
discussion.
For these reasons, we recommend that meetings
be kept small and informal, and that you hold
several, if necessary, to accommodate the
different interest groups. The other solution is to
break a large gathering into small discussion
groups, which is discussed below. Using either
method increases the likelihood that participants
will level with you and communicate their
underlying concerns rather than make an
emotional statement just for effect.
Moreover, hi our experience, a separate meeting
for cooperating agencies is quite productive.
Working relationships can be forged for the
effective participation of all involved in the
preparation of the EIS. Work assignments are
made by the lead agency, a schedule may be set
for production of parts of the draft EIS, and
information gaps can be identified early. But a
productive meeting such as this is not possible at
the very beginning of the process. It can only
result from the same sort of planning and prepa-
ration that goes into the public meetings. We
discuss below the special problems of
cooperating agencies, and their information
needs for effective participation in scoping.
4. Issuing the public notice.
The preliminary look at the proposal, in which
you develop the information packet discussed
above, will enable you to tell what kind of
public notice will be most appropriate and
effective.
Section 1501.7 of the NEPA regulations requires
that a notice of intent to prepare an EIS must be
published hi the Federal Register prior to initia-
ting scoping.*** This means that one of the
appropriate means of giving public notice of the
upcoming scoping process could be the same
Federal Register notice. And because the notice
of intent must be published anyway, the scoping
notice would be essentially free. But use of the
Federal Register is not an absolute requirement,
and other means of public notice often are more
""Several agencies have found it useful to
conduct scoping for environmental assessments.
EAs are prepared where answering the question
of whether an EIS is necessary requires
identification of significant environmental issues;
and consideration of alternatives in an EA can
often be useful even where an EIS is not
necessary. In both situations scoping can be
valuable. Thus the Council has stated that
scoping may be used hi connection with
preparation of an EA, that is, before publishing
any notice of intent to prepare an EIS. As in
normal scoping, appropriate public notice is
required, as well as adequate information on the
proposal to make scoping worthwhile. But
scoping at this early stage cannot substitute for
the normal scoping process unless the earlier
public notice stated clearly that this would be the
case, and the notice of intent expressly provides
that written comments suggesting impacts and
alternatives for study will still be considered.
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effective, including local newspapers, radio and
TV, posting notices in public places, etc. (See
Section 1506.6 of the regulations.)
What is important is that the notice actually
reach the affected public. If the proposal is an
important new national policy in which national
environmental groups can be expected to be
interested, these groups can be contacted by
form letter with ease. (See die Conservation
Directory for a list of national groups."*")
Similarly, for proposals that may have major
implications for the business community, trade
associations can be helpful means of alerting
affected groups. The Federal Register notice can
be relied upon to notify others that you did not
know about. But the Federal Register is of little
use for reaching individuals or local groups
interested in a site specific proposal. Therefore
notices hi local papers, letters to local
government officials and personal contact with a
few known interested individuals would be more
appropriate. Land owners abutting any proposed
project site should be notified individually.
Remember that issuing press releases to
newspapers, and radio and TV stations is not
enough, because they may not be used by the
media unless the proposal is considered
"newsworthy." If the proposal is controversial,
you can try alerting reporters or editors to an
upcoming scoping meeting for coverage in
special weekend sections used by many papers.
But placing a notice hi the legal notices section
of the paper is the only guarantee that it will be
published.
5. Conducting a public meeting.
In our study of agency practice hi conducting
scoping, the most interesting information on
The Conservation Directory is a publication
of the National Wildlife Federation, 1421 16th
St., N.W., Washington, D.C. 20036.
what works and doesn't work involves the
conduct of meetings. Innovative techniques have
been developed, and experience shows that these
can be successful.
One of the most important factors turns out to be
the training and experience of the moderator.
The U.S. Office of Personnel Management and
others give training courses on how to run a
meeting effectively. Specific techniques are
taught to keep the meeting on course and to deal
with confrontations. These techniques are
sometimes called "meeting facilitation skills."
When holding a meeting, the principle thing to
remember about scoping is that it is a process to
initiate preparation of an EIS. It is not concerned
with the ultimate decision on the proposal. A
fruitful scoping process leads to an adequate
environmental analysis, including all reasonable
alternatives and mitigation measures. This
limited goal is in the interest of all the
participants, and thus offers the possibility of
agreement by the parties on this much at least.
To run a successful meeting you must keep the
focus on this positive purpose.
At the point of scoping therefore, hi one sense
all the parties involved have a common goal,
which is a thorough environmental review. If
you emphasize this hi the meeting you can stop
any grandstanding speeches without a heavy
hand, by simply asking the speaker if he or she
has any concrete suggestions for the group on
issues to be covered in the EIS. By frequently
drawing the meeting back to this central purpose
of scoping, the opponents of a proposal will see
that you have not already made a decision, and
they will be forced to deal with the real issues.
In addition, when people see that you are
genuinely seeking their opinion, same will
volunteer useful information about a particular
subject or site that they may know better than
anyone on your staff.
As we stated above, we found that informal
meetings hi small groups are the most
3.A-9
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satisfactory for eliciting useful issues and
information. Small groups can be formed in two
ways: you can invite different interest groups to
different meetings, or you can break a large
number into small groups for discussion.
One successful model is used by the Army
Corps of Engineers, among others. In cases
where a public meeting is desired, it is
•publicized and scheduled for a location that will
be convenient for as many potential participants
as possible. The information packet is made
available in several ways, by sending it to those
known to be interested, giving a telephone
number hi the public notices for use in
requesting one, and providing more at the door
of the meeting place as well. As participants
enter the door, each is given a number.
Participants are asked to register their name,
address and/or telephone number for use in
future contact during scoping and the rest of the
NEPA process.
The first part of the meeting is devoted to a
discussion of the proposal in general, covering
its purpose, proposed location, design, and any
other aspects that can be presented in a lecture
format. A question and answer period
concerning this information is often held at this
time. Then if there are more than 15 or 20
attendees at the meeting, the next step is to
break it into small groups for more intensive
discussion. At this point, the numbers held by
the participants are used to assign them to small
groups by sequence, random drawing, or any
other method. Each group should be no larger
than 12, and 8-10 is better. The groups are
informed that their task is to prepare a list of
significant environmental issues and reasonable
alternatives for analysis in the EIS. These lists
will be presented to the main group and
combined into a master list, after the discussion
groups are finished. The rules for how priorities
are to be assigned to the issues identified by
each group should be made clear before the
large group breaks up.
Some agencies ask each group member to vote i
for the 5 or 10 most important issues. After
tallying the votes of individual members, each
group would only report out those issues that
received a certain number of votes. In this way
only those items of most concern to the
members would even make the list compiled by
each group. Some agencies go further, and only
let each group report out the top few issues
identified. But you must be careful not to ignore
issues that may be considered a medium priority
by many people. They may still be important,
even if not in the top rank. Thus instead of
simply voting, the members of the groups should
rank the listed issues in order of perceived
importance. Points may be assigned to each item
on the basis of the rankings by each member, so
that the group can compile a list of its issues in
priority order. Each group should then be asked
to assign cut-off numbers to separate high,
medium and low priority items. Each group
should then report out to the main meeting all of
its issues, but with priorities clearly assigned.
One member of the lead agency or cooperating
agency staff should join each group to answer
questions and to listen to the participants'
expressions of concern. It has been the
experience of many of those who have tried this
method that it is better not to have the agency
person lead the group discussions. There does
need to be a leader, who should be chosen by
the group members. In this way, the agency staff
member will not be perceived as forcing his
opinions on the others.
If the agency has a sufficient staff of formally
trained "meeting facilitators," they may be able
to achieve the same result even where agency
staff people lead the discussion groups. But
absent such training, the staff should not lead the
discussion groups. A good technique is to have
the agency person serve as the recording
secretary for the group, writing down each
impact and alternative that is suggested for study
by the participants. This enhances the neutral
status of the agency representative, and ensures
3.A-10
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that he is perceived as listening and reacting to
the views of the group. Frequently, the
recording of issues is done with a large pad
mounted on the wall like a blackboard, which
has been well received by agency and public
alike, because all can see that the views
expressed actually have been heard and
understood.
When the issues are listed, each must be
clarified or combined with others to eliminate
duplication or fuzzy concepts. The agency staff
person can actually lead in this effort because of
his need to reflect on paper exactly what the
issues are. After the group has listed all the
environmental impacts and alternatives and any
other issues that the members wish to have
considered, they are asked to discuss the relative
merits and importance of each listed item. The
group should be reminded that one of its tasks is
to eliminate insignificant issues. Following this,
the members assign priorities or vote using one
of the methods described above.
The discussion groups are then to return to the
large meeting to report on the results of their
ranking. At this point further discussion may be
useful to seek a consensus on which issues are
really insignificant. But the moderator must not
appear to be ruthlessly eliminating issues that the
participants ranked of high or medium
importance. The best that can usually be
achieved is to "deemphasize" some of them, by
placing them in the low Priority category.
6. What to do with the comments.
After you have comments from the cooperating
agencies and the interested public, you must
evaluate them and make judgments about which
issues are in fact significant and which ones are
not. The decision of what the EIS should contain
is ultimately made by the lead agency. But you
will now know what the interested participants
consider to be the principal areas for study and
analysis. You should be guided by these
concerns, or be prepared to briefly explain why
you do not agree. Every issue that is raised as a
priority matter during scoping should be
addressed in some manner in die EIS, either by
in-depth analysis, or at least a short explanation
showing that the issue was examined, but not
considered significant for one or more reasons.
Some agencies have complained that the time
savings claimed for scoping have not been
realized because after public groups raise
numerous minor matters, they cannot focus the
EIS on the significant issues. It is true that it is
always easier to add issues than it is to subtract
them during scoping. And you should realize
that trying to eliminate a particular
environmental impact or alternative from study
may arouse the suspicions of some people.
Cooperating agencies may be even more
reluctant to eliminate issues in their areas of
special expertise than the public participants. But
the way to approach it is to seek consensus on
which issues are less important. These issues
may then be deemphasized in the EIS by a brief
discussion of why they were not examined in
depth.
If no consensus can be reached, it is still your
responsibility to select the significant issues. The
lead agency cannot abdicate its role and simply
defer to the public. Thus a group of participants
at a scoping meeting should not be able to
"vote" an insignificant matter into a big issue. If
a certain issue is raised and in your professional
judgment you believe it is not significant,
explain clearly and briefly in the EIS why it is
not significant. There is no need to devote time
and pages to it in the EIS if you can show that
it is not relevant or important to the proposed
action. But you should address in some manner
all matters that were raised in the scoping
process, either by an extended analysis or a brief
explanation showing that you acknowledge the
concern.
Several agencies have made a practice of
sending out a post-scoping document to make
public the decisions that have been made on
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what issues to cover in the EIS. This is not a
requirement, but in certain controversial cases it
can be worthwhile. Especially when scoping has
been conducted by written comments, and there
has been no face-to-face contact, a postscoping
document is the only assurance to the
participants that they were heard and understood
until the draft EIS comes out. Agencies have
acknowledged to us that "letters instead of
•meetings seem to get disregarded easier." Thus
a reasonable quid pro quo for relying on
comment letters would be to send out a
post-scoping document as feedback to the
commentors.
The post-scoping document may be as brief as a
list of impacts and alternatives selected for
analysis; it may consist of the "scope of work"
produced by the lead and cooperating agencies
for their own EIS work or for the contractor; or
it may be a special document that describes all
the issues and explains why they were selected.
7. Allocating work assignments and setting
schedules.
Following the public participation in whatever
form, and the selection of issues to be covered,
the lead agency must allocate the EIS
preparation work among the available resources.
If there are no cooperating agencies, the lead
agency allocates work among its own personnel
or contractors. If there are cooperating agencies
involved, they may be assigned specific research
or writing tasks. The NEPA regulations require
that they normally devote their own resources to
the issues in which they have special expertise or
jurisdiction by law. (Sections 1501.6(b)(3), (5),
and 1501.7(a)(4)).
In all cases, the lead agency should set a
schedule for completion of the work, designate
a project manager and assign the reviewers, and
must set a time limit for the entire NEPA
analysis if requested to do so by an applicant.
(Section 1501.8).
8. A few ideas to try.
a. Route design workshop
As part of a scoping process, a successful
innovation by one agency involved route
selection for a railroad. The agency invited
representatives of the interested groups
(identified at a previous public meeting) to try
their hand at designing alternative routes for a
proposed rail segment. Agency staff explained
design constraints and evaluation criteria such as
the desire to minimize damage to prime
agricultural land and valuable wildlife habitat.
The participants were divided into small groups
for a few hours of intensive work. After learning
of the real constraints on alternative routes, the
participants had a better understanding of the
agency's and applicant's viewpoints. Two of the
participants actually supported alternative routes
that affected their own land because the overall
impacts of these routes appeared less adverse.
The participants were asked to rank the five
alternatives they had devised and the top two
were included in the EIS. But the agency did not
permit the groups to apply the same evaluation
criteria to the routes proposed by the applicant
or the agency. Thus public confidence in the
process was not as high as it could have been,
and probably was reduced when the applicant's
proposal was ultimately selected.
The Council recommends that when a hands-on
design workshop is used, the assignment of the
group be expanded to include evaluation of the
reasonableness of all the suggested alternatives.
b. Hotline
Several agencies have successfully used a special
telephone number, essentially a hotline, to take
public comments before, after, or instead of a
public meeting. It helps to designate a named
staff member to receive these calls so that some
continuity and personal relationships can be
developed.
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c. Videotape of sites
A videotape of proposed sites is an excellent tool
for explaining site differences and limitations
during the lecture-format part of a scoping
meeting.
d. Videotape meetings
One agency has videotaped whole scoping
meetings. Staff found that the participants took
their roles more seriously and the taping
appeared not to precipitate grandstanding tactics.
e. Review committee
Success has been reported from one agency
which sets up review committees, representing
all interested groups, to oversee the scoping
process. The committees help to design the
scoping process. In cooperation with the lead
agency, the committee reviews the materials
generated by the scoping meeting. Again,
however, the final decision on EIS content is the
responsibility of the lead agency.
f. Consultant as meeting moderator
In some hotly contested cases, several agencies
have used the EIS consultant to actually run the
scoping meeting. This is permitted under the
NEPA regulations and can be useful to de-fuse
a tense atmosphere if the consultant is perceived
as a neutral third party. But the responsible
agency officials must attend the meetings. There
is no substitute for developing a relationship
between the agency officials and the affected
parties. Moreover, if the responsible officials are
not prominently present, the public may interpret
that to mean that the consultant is actually
making the decisions about the EIS, and not the
lead agency.
g. Money saving tips
Remember that money can be saved by using
conference calls instead of meetings,
tape-recording the meetings instead of hiring a
stenographer, and finding out whether people
want a meeting before announcing it.
C. Pitfalls.
We list here some of the problems that have
been experienced in certain scoping cases, in
order to enable others to avoid the same
difficulties.
1. Closed meetings.
In response to informal advice from CEQ that
holding separate meetings for agencies and the
public would be permitted under the regulations
and could be more productive, one agency
scheduled a scoping meeting for the cooperating
agencies some weeks in advance of the public
meeting. Apparently, the lead agency felt that
the views of the cooperating agencies would be
more candidly expressed if the meeting were
closed. In any event, several members of the
public learned of the meeting and asked to be
present. The lead agency acquiesced only after
newspaper reporters were able to make a story
out of the closed session. At the meeting, the
members of the public were informed that they
would not be allowed to speak, nor to record the
proceedings. The ill feeling aroused by this
chain of events may not be repaired for a long
time. Instead, we would suggest the following
possibilities:
a. Although separate meetings for agencies and
public groups may be more efficient, there is no
magic to them. By all means, if someone insists
on attending the agency meeting, let him. There
is nothing as secret going on there as he may
think there is if you refuse him admittance.
Better yet, have your meeting of cooperating
agencies after the public meeting. That may be
the most logical time anyway, since only then
can the scope of the EIS be decided upon and
assignments made among the agencies. If it is
well done, the public meeting will satisfy most
3.A-13
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people and show them that you are listening to
diem.
b. Always permit recording. In fact, you should
suggest it for public meetings. All parties will
feel better if there is a record of the proceeding.
There is no need for a stenographer, and tape is
inexpensive. It may even be better then a typed
transcript, because staff and decisionmakers who
-did not attend the meeting can listen to the
exchange and may learn a lot about public
perceptions of the proposal.
c. When people are admitted to a meeting, it
makes no sense to refuse their requests to speak.
However, you can legitimately limit their state-
ments to the subject at hand-scoping. You do
not have to permit some participants to waste the
others' time if they refuse to focus on the
impacts and alternatives for inclusion in the EIS.
Having a tape of the proceedings could be useful
after the meeting if there is some question that
speakers were improperly silenced. But it takes
an experienced moderator to handle a situation
like this.
d. The scoping stage is the time for building
confidence and trust on all sides of a proposal,
because this is the only time when there is a
common enterprise. The attitudes formed at this
stage can carry through the project review
process. Certainly it is difficult for things to get
better. So foster the good will as long as you
can by listening to what is being said during
scoping. It is possible that out of that dialogue
may appear recommendations for changes and
mitigation measures that can turn a controversial
fight into an acceptable proposal.
2. Contacting interested groups.
Some problems have arisen in scoping where
agencies failed to contact all the affected parties,
such as industries or state and local
governments. In one case, a panel was
assembled to represent various interests in
scoping an EIS on a wildlife-related program.
The agency had an excellent format for the
meeting, but the panel did not represent
industries that would be affected by the program
or interested state and local governments. As a
result, the EIS may fail to reflect the issues of
concern to these parties.
Another agency reported to us that it failed to
contact parties directly because staff feared that
if they missed someone they would be accused
of favoritism. Thus they relied on the issuance
of press releases which were not effective. Many
people who did not learn about the meetings hi
time sought additional meeting opportunities,
which cost extra money and delayed the process.
In our experience, the attempt to reach people is
worth the effort. Even if you miss someone, it
will be clear that you tried. You can enlist a few
representatives of an interest group to help you
identify and contact others. Trade associations,
chambers of commerce, local civic groups, and
local and national conservation groups can
spread the word to members.
3. Tiering.
Many people are not familiar with the way
environmental impact statements can be "tiered"
under the NEPA regulations, so that issues are
examined in detail at the stage that decisions on
them are being made. See Section 1508.28 of
the regulations. For example, if a proposed
program is under review, it is possible that site
specific actions are not yet proposed. In such a
case, these actions are not addressed in the EIS
on the program, but are reserved for a later tier
of analysis. If tiering is being used, this concept
must be made clear at the outset of any scoping
meeting, so that participants do not concentrate
on issues that are not going to be addressed at
this time. If you can specify when these other
issues will be addressed it will be easier to
convince people to focus on the matters at hand.
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4. Scoping for unusual programs.
One interesting scoping case involved proposed
changes in the Endangered Species Program.
Among the impacts to be examined were the
effects of this conservation program on user
activities such as mining, hunting, and timber
harvest, instead of die other way around.
Because of this reverse twist in the impacts to be
analyzed, some participants had difficulty
focusing on useful issues. Apparently, if the
subject of the EIS is unusual, it will be even
harder than normal for scoping participants to
grasp what is expected of them.
In the case of the Endangered Species Program
EIS, the agency planned an intensive 3 day
scoping session, successfully involved the
participants, and reached accord on several
issues that would be important for the future
implementation of the program. But the
participants were unable to focus on impacts and
program alternatives for the EIS. We suggest
that if the intensive session bad been broken up
into 2 or 3 meetings separated by days or weeks,
the participants might have been able to get used
to the new way of thinking required, and thereby
to participate more productively. Programmatic
proposals are often harder to deal with in a
scoping context than site specific projects. Thus
extra care should be taken in explaining the
goals of the proposal and in making the
information available well in advance of any
meetings.
D. Lead and Cooperating Agencies.
Some problems with scoping revolve around the
relationship between lead and cooperating
agencies. Some agencies are still uncomfortable
with these roles. The NEPA regulations, and
the 40 Questions and Answers about the NEPA
Regulations, 46 Fed. Reg. 18026, (March 23,
1981) describe hi detail the way agencies are
now asked to cooperate on environmental
analyses. (See Questions 9,14, and 30.) We will
focus here on the early phase of that
cooperation.
It is important for the lead agency to be as
specific as possible with the cooperating
agencies. Tell them what you want them to
contribute during scoping: environmental
impacts and alternatives. Some agencies still do
not understand the purpose of scoping.
Be sure to contact and involve representatives of
the cooperating agencies who are responsible for
NEPA-related functions. The lead agency will
need to contact staff of the cooperating agencies
who can both help to identify issues and
alternatives and commit resources to a study,
agree to a schedule for EIS preparation, or
approve a list of issues as sufficient. In some
agencies that will be at the district or state office
level (e.g., Corps of Engineers, Bureau of Land
Management, and Soil Conservation Service) for
all but exceptional cases. In other agencies you
must go to regional offices for scoping
comments and commitments (e.g., EPA, Fish
and Wildlife Service, Water and Power
Resources Service). In still others, the field
offices do not have NEPA responsibilities or
expertise and you will deal directly with
headquarters (e.g., Federal Energy Regulatory
Commission, Interstate Commerce Commission).
In all cases you are looking for the office that
can give you the answers you need. So keep
trying until you find the organizational level of
die cooperating agency that can give you useful
information and that has the authority to make
commitments.
As stated in 40 Questions and Answers about the
NEPA Regulations, the lead agency has the
ultimate responsibility for the content of the EIS,
but if it leaves out a significant issue or ignores
the advice and expertise of the cooperating
agency, the EIS may be found later to be
inadequate. (46 Fed. Reg. 18030, Question
14b.) At the same tune, the cooperating agency
will be concerned that the EIS contain material
sufficient to satisfy its decisionmaking needs.
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Thus, both agencies have a stake in producing a
document of good quality. The cooperating
agencies should be encouraged not only to
participate in scoping but also to review the
decisions made by the lead agency about what to
include in the EIS. Lead agencies should allow
any information needed by a cooperating agency
to be included, and any issues of concern to the
cooperating agency should be covered, but it
'usually will have to be at the expense of the
cooperating agency.
Cooperating agencies have at least as great a
need as the general public for advance
information on a proposal before any scoping
takes place. Agencies have reported to us that
information from the lead agency is often too
sketchy or comes too late for informed
participation. Lead agencies must clearly explain
to all cooperating agencies what the proposed
action is conceived to be at this time, and what
present alternatives and issues the lead agency
sees, before expecting other agencies to devote
time and money to a scoping session. Informal
contacts among the agencies before scoping gets
underway are valuable to establish what the
cooperating agencies will need for productive
scoping to take place.
Some agencies will be called upon to be
cooperators more frequently than others, and
they may lack the resources to respond to the
numerous requests. The NEPA regulations
permit agencies without jurisdiction by law (i.e.,
no approval authority over the proposal) to
decline the cooperating agency role. (Section
1501.6(c)). But agencies that do have
jurisdiction by law cannot opt out entirely and
may have to reduce their cooperating effort
devoted to each EIS. (See Section 1501.6(c) and
40 Questions and Answers about the NEPA
Regulations, 46 Fed. Reg. 18030, Question
14a.) Thus, cooperators would be greatly aided
by a priority list from the lead agency showing
which proposals most need their help. This will
lead to a more efficient allocation of resources.
Some cooperating agencies are still holding back
at the scoping stage in order to retain a critical
position for later in the process. They either
avoid the scoping sessions or fail to contribute,
and then raise objections in comments on the
draft EIS. We cannot emphasize enough that the
whole point of scoping is to avoid this situation.
As we stated in 40 Questions and Answers about
the NEPA Regulations, "if the new alternative
[or other issue] was not raised by the
commentator during scoping, but could have
been, commentors may find that they are
unpersuasive hi their efforts to have their
suggested alternative analyzed in detail by the
[lead] agency." (46 Fed. Req. 18035, Question
29b.)
HI. Advice for Public Participants
Scoping is a new opportunity for you to enter
the earliest phase of the decisionmaking process
on proposals that affect you. Through this
process you have access to public officials
before decisions are made and the right to
explain your objections and concerns. But this
opportunity carries with it a new responsibility.
No longer may individuals hang back until the
process is almost complete and then spring forth
with a significant issue or alternative that might
have been raised earlier. You are now part of
the review process, and your role is to inform
the responsible agencies of the potential impacts
that should be studied, the problems a proposal
may cause that you foresee, and the alternatives
and mitigating measures that offer promise.
As noted above, and in 40 Questions and
Answers, no longer will a comment raised for
the first time after the draft EIS is finished be
accorded the same serious consideration it would
otherwise have merited if the issue had been
raised during scoping. Thus you have a
responsibility to come forward early with known
issues.
In return, you get the chance to meet the
responsible officials and to make the case for
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your alternative before they are committed to a
course of action. To a surprising degree this
avenue has been found to yield satisfactory
results. There's no guarantee, of course, but
when the alternative you suggest is really better,
it is often hard for a decisionmaker to resist.
There are several problems that commonly arise
that public participants should be aware of:
A. Public input is often only negative
The optimal tuning of scoping within the NEPA
process is difficult to judge. On the one hand, as
explained above (Section E.B.I.), if it is
attempted too early, the agency cannot explain
what it has in mind and informed participation
will be impossible. On the other, if it is delayed,
the public may find that significant decisions are
already made, and their comments may be
discounted or will be too late to change the
project. Some agencies have found themselves in
a tactical cross-fire when public criticism arises
before they can even define their proposal
sufficiently to see whether they have a
worthwhile plan. Understandably, they would be
reluctant after such an experience to invite public
criticism early in the planning process through
open scoping. But it is in your interest to
encourage agencies to come out with proposals
in the early stage because that enhances the
possibility of your comments being used. Thus
public participants hi scoping should reduce the
emotion level wherever possible and use the
opportunity to make thoughtful, rational
presentations on impacts and alternatives.
Polarizing over issues too early hurts all parties.
If agencies get positive and useful public
responses from the scoping process, they will
more frequently come forward with proposals
early enough so that they can be materially
unproved by your suggestions.
B. Issues are too broad
The issues that participants tend to identify
during scoping are much too broad to be useful
for analytical purposes. For example, "cultural
impacts" - what does this mean? What precisely
are the impacts that should be examined? When
the EIS preparers encounter a comment as vague
as this they will have to make their own
judgment about what you meant, and you may
find that your issues are not covered. Thus, you
should refine the broad general topics, and
specify which issues need evaluation and
analysis.
C. Impacts are not identified
Similarly, people (including agency staff)
frequently identify "causes" as issues but fail to
identify the principal "effects" that the EIS
should evaluate in depth. For example, oil and
gas development is a cause of many impacts.
Simply listing this generic category is of little
help. You must go beyond the obvious causes to
the specific effects that are of concern. If you
want scoping to be seen as more than just
another public meeting, you will need to put in
extra work.
IV. Brief Points For Applicants.
Scoping can be an invaluable part of your early
project planning. Your main interest is in getting
a proposal through the review process. This
interest is best advanced by finding out early
where the problems with the proposal are, who
the affected parties are, and where
accommodations can be made. Scoping is an
ideal meeting place for all the interest groups if
you have not already contacted them. In several
cases, we found that the compromises made at
this stage allowed a project to move efficiently
•through the permitting process virtually
unopposed.
The NEPA regulations place an affirmative
obligation on agencies to "provide for cases
where actions are planned by private applicants"
so that designated staff are available to consult
with the applicants, to advise applicants of
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information that will be required during review,
and to insure that the NEPA process commences
at the earliest possible time. (Section 1501.2(d)).
This section of the regulations is intended to
ensure that environmental factors are considered
at an early stage hi the applicant's planning
process. (See 40 Questions and Answers about
the NEPA Regulations, 46 Fed. Reg. 18028,
Questions 8 and 9.)
Applicants should take advantage of this
requirement in the regulations by approaching
the agencies early to consult on alternatives,
mitigation requirements, and the agency's
information needs. This early contact with the
agency can facilitate a prompt initiation of the
scoping process in cases where an EIS will be
prepared. You will need to furnish sufficient
information about your proposal to enable the
lead agency to formulate a coherent presentation
for cooperating agencies and the public. But
don't wait until your choices are all made and
the alternatives have been eliminated. (Section
1506.1).
During scoping, be sure to attend any of the
public meetings unless the agency is dividing
groups by interest affiliation. You will be able to
answer any questions about the proposal, and
even more important, you will be able to hear
the objections raised, and find out what the real
concerns of the public are. This is, of course,
vital information for future negotiations with the
affected parties.
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CHAPTER 4
ASSESSMENT
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CHAPTER 4
ASSESSMENT
In this part of the sourcebook, "assessment" is used narrowly and includes
tasks associated with the preparation of EA documents (i.e., those activities for
which the core team is directly responsible). These include:
• description of the affected environments,
• description of the future environmental setting (without the
proposed action),
• identification of potential environmental impacts of a proposed
action and its reasonable alternatives,
• analysis and quantification, if possible, of potential impacts,
• evaluation of the significance of potential environmental impacts,
• description of mitigation measures for unavoidable environmental
impacts, and
• preparation of an EA document for use by the decisionmaker.
However, "assessment" is often used broadly to include policy related activities
such as defining issues, evaluating the overall significance of a proposed action,
and choosing the appropriate alternative. For purposes of this sourcebook, we
use "environmental assessment (EA) process" to describe the broad implications
of environmental assessment. These include, in addition to assessment, the
activities that precede and follow assessment (i.e., initiation, scoping,
decisionmaking and post-decision analysis).
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4-2
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4.1
Affected Environments
The description of the affected environments must identify the important
physical, biological, and social/cultural characteristics of the areas potentially
exposed to the proposed action and alternatives and explain the reasons for the
boundaries of the study areas. Only those elements which are relevant to the
issues identified for the proposed action and alternatives need be identified and
evaluated. It is normally one of the first activities undertaken in the assessment
phase of EA and has been described as a "description of conditions existing at a
point in time against which subsequent changes can be detected through
monitoring" (Hirsch 1980). The approach commonly taken is subdivision of the
resources into categories (Table 4.1-1). Depending on the size and complexity
of the EA, core team members are chosen with expertise in the appropriate areas
(Attachment 2.C). Experience from similar projects can be helpful in identifying
environmental components that should be described.
The initial description of the affected environment should identify
important gaps for which subsequent field or laboratory investigations are needed.
For many areas which have already been studied, even if in a fragmented way,
a meaningful characterization can be developed based on existing information.
In other areas, field reconnaissance or study may be required even to complete
a rough or initial characterization (Hirsch 1980). Reconnaissance-level
information is that which is available from open literature, published or
unpublished reports, existing records, authoritative sources, or brief field surveys
performed by recognized experts. It is not based on information that can only be
obtained by detailed onsite monitoring programs or studies (McBrayer et al.,
1981).
4-3
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Table 4.1-1. General Baseline Information on a Site and its Surroundings.'
Category
Type of information
Sources of information
Land use and zoning
Floodplains and wetland*
Prime and unique farmlands
Cultural and aesthetic'
resources
Geology
Terrestrial and aquatic ecology
Maps and tables showing present land use on the site and
surrounding area; land ownership; regional, state, and local land-
use plans and controls pertinent to the site and surrounding area.
Maps showing the locations of the 100- and 500-year floodplains
and onsite wetlands; table showing onsite area for each floodplain
or wetland; description of each onsite wetland, including
dominant features and abundance of each wetland type.
Soils map of the site; description of onsite soil types; area of
.each soil on the site that is classified as prime or unique
farmland.
Location and description of cultural and aesthetic resources on or
in the vicinity of the site, including historic and archaeological
sites, Indian tribal resources, scenic, and other aesthetic
resources.
Geological bedrock, and surface formations; topography; location
and description of potential geologic hazards, including
consideration of slope stability, mass movement, faults,
subsidence, settlement, liquefaction, and volcanic activity.
Map and description of vegetation types on the site; wildlife
species and habitats; presence of rare, unique, or important
ecological communities or habitats; description of aquatic habitat
types and aquatic species present in water bodies; abundance of
important species, trends in abundance, and distributions relative
to the proposed project.
State, regional, and local planning commissions; state agencies,
such as Departments of Conservation, Pish and Game, and Parks;
federal agencies, such as U.S. Geological Survey (USGS), Soil
Conservation Service (SCS), Bureau of Land Management
(BLM), Forest Service; onsite observations.
Department of Housing and Urban Development (HUD) Flood
Insurance Rate Maps and Federal Emergency Management
Agency (FEMA) Flood Hazard Boundary Maps; USGS
topographic maps; county soil surveys; U.S. Fish and Wildlife
Service (FWS) National Wetlands Inventory; U.S. Army Corps
of Engineers (COE); onsite observations.
SCS; state soil conservationist and fecal soil conservation office;
state agricultural colleges.
State historic preservation office; National Register of Historic
Places; National Register of Natural Landmarks; U.S. Bureau of
Indian Affairs; fecal tribal headquarters; onsite observations.
USGS national distribution center, Reston, Virginia; USGS
depositories of publications at each state land grant university;
state geologist; USGS topographic and land-use maps; onsite
observations.
Ecologists and other biologists at fecal and state colleges and
universities; private environmental and conservation
organizations; state fish and game and conservation agencies;
onsite observations, FWS habitat evaluation procedures.
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Table 4.1-1. (continued)
Category
Type of information
Sources of information
Endangered and threatened
species
Groundwater
Surface water
Climate end air quality
Noise**
Lists and descriptions of federal and state endangered,
threatened, rare, and protected specie* and their critical habitat
present in.the region of the site; observations and reports of such
species and habitats on the site or on other areas to be affected
by the project.
Description of groundwater resources potentially affected by the
project, including aquifer characteristics, flow system
characteristics, competing water use and availability, water
quality, designation of any sole source aquifer; locations and
depths of existing wells.
Description of surface water features that will be affected by the
project; a map showing the drainage pattern of the site and its
• surroundings and onsite water bodies: data on water availability
and water quality of affected water bodies; identification of
existing permitted discharges to surface water.
Important climatic parameters, such as, average temperatures,
relative humidity, precipitation, wind direction and speed, wind
stability classes, mixing heights, fog occurrence, and
meteorological extremes (e.g., tornado or hurricane frequency);
identification of air quality control regions in which the site is
located and those affected by emissions from the facility;
description of the attainment or nonattainment status for the
criteria pollutants; description of present ambient air quality;
State Implementation Plan (SIP) restrictions; location of any
Class I area (nondegradation areas, e.g., wilderness areas or
national parks) affected by project emissions; discussion of trends
in pollutant levels over time where data on air quality is
available.
Existing ambient background noise levels on the site and in the
vicinity; major existing or planned noise sources and sensitive
receptors (e.g., hospitals).
Federal listing of endangered and threatened species, published
annually and updated as needed in the Federal Register: state lists
of endangered and threatened species, generally published by
state departments of fish and game or conservation; local
chapters of organizations concerned with environment and
conservation (e.g., the National Audubon Society or the National
Wildlife Federation); consultation with FWS regional office;
onsite observations.
USOS; U.S. Environmental Protection Agency (EPA); delegated
state agencies for administering EPA permit programs; state
geological survey; geologists and hydrologists at local and state
colleges and universities; National Waterwell Association; onsite
well records.
USGS topographic maps; aerial photographs; comprehensive data
bases such as Water Resources Abstracts, WATSTORE,
NAWDEX, and STORET; state and federal agencies responsible
for permitting, including EPA, COE and delegated state agencies;
onsite observations.
National Weather Service or Federal Aviation Administration
stations; National Climatic Center, Asheville, North Carolina;
local airports; U.S. EPA or state agency delegated to administer
air quality permits; other industrial or research facilities that
collect climatic or air quality data.
Onsite measurements; contacts with local and state agencies;
examination of area maps.
-------
Table 4.1-1. (continued)
Category
Type of information
Sources of information
Socioeconomk*
Definition of (ocioeoonomic impact region; current and projected
population and relevant demographic characteristics; local
government revenues, expenditures, and revenue-sharing
arrangements; current and projected housing capacity; current
and planned public service capacity (water, sewer, transportation,
police, fire, health, education, and welfare); economic structure
and labor force characteristics; local government characteristics;
local organizations and interest groups; social structure and life
styles; local support or opposition to the proposed project.
U.S. Bureau of Census, U.S. Department of Transportation,
Department of Labor Statistics, Department of Commerce
publications; employment commissions; chambers of commerce;
tourist bureaus; academic reports • especially by local
institutions; local newspapers; interviews with government
officials; researchers; and interested parties; inspection of the site
and region.
i
o»
"The National Wildlife Federation's annual Conservation Directory lists organizations, agencies, and officials concerned with
natural resource use and management.
"The Federal Interagency Committee on Urban Noise (1980) has published an excellent description of the noise policies and
programs of federal agencies relating to land use.
-------
• Establishment of time and space boundaries for the affected
environment is a critical first step in EA. The team can expect
more than one set of boundaries depending on the issue(s). The
setting of boundaries usually represents a trade-off of constraints
imposed by:
administrative boundaries (e.g., political, social, and
economic realities),
project boundaries (e.g., the spatial and temporal extent of
the project),
ecological boundaries (e.g., time and space scales over
which affected natural systems operate), and
technical boundaries (e.g., the limited state-of-the-art in
predicting or measuring ecological changes).
It is important to distinguish between the categories since some are
under the control of the EA team while others are relatively fixed
(Beanlands and Duinker 1983).
• The data requirements for relevant analyses are based on
understanding of the proposed action and any tentative mitigation,
clearly defined EA objectives, and the requirements of the
methodologies to be used for prediction of impacts. The EA team
will:
assemble, evaluate, and present baseline data on the
relevant environmental characteristics of the study area,
including information on any changes anticipated before the
project commences;
collate data from the various disciplinary areas and evaluate
data usefulness, needs, and availability in relation to the
proposed action;
identify gaps in information; and
avoid collecting unnecessary information and data.
• Before using existing environmental data for project assessment,
a number of possible limitations must be checked. The quality of
reported environmental data must be assessed, and this is generally
not an easy task. One should look for quality control and
assurance programs as an integral part of any past monitoring
efforts. Responsible agencies, laboratories, or monitoring or
analytical personnel should be contacted for information on the
4-7
-------
estimated quality of the reported data. In general, work done by major federal
agencies that have standard reference methods for sample collection and analysis
should be useful. However, laboratories that may be consistent internally (be
highly precise) in their sample analysis may show inaccuracies with other
analytical groups.
The reliability and comparability of existing data to present site-
specific conditions should be checked. Existing data for
geographic areas removed from exact locations of interest will
usually have to be verified in the field for comparability. Any
significant environmental changes after the field data have been
collected, such as from new pollution sources or from recent
environmental events such as flooding or fire, should be
determined.
TOOLS
The use of checklists can help the EA team identify potential
impacts (Attachment 2.B, Part 4.2), ensure that significant
environmental parameters are not overlooked, and provide an
outline of data needs. It can also help to identify alternatives
which might lessen impact. Checklists are suited to identification
of direct impacts but generally not to identification of indirect
impacts. A matrix is an extension of a checklist where one axis
lists description of the proposed action while the other lists
environmental conditions. The Leopold matrix (Leopold et. al.
1971) provides a format for comprehensive review to remind
investigators of the variety of interactions that might be involved
(Figure 4.1-1). The number of actions listed horizontally in the
complete Leopold matrix is 100 and the vertical list of
environmental characteristics contains 88, which give a total
of 8,800 possible interactions. The vertical list can be used as a
checklist to identify important environmental factors.
4-8
-------
.O *O .c to .a «- u o
co* CD cdi o cj a a z
(A
a>
A. 2. d. Water quality
A. 3. a. Atmospheric quality
A. 4. b. Erosion
A. 4. c. Deposition, Sedimentation
B. l.b. Shrubs
B. I.e. Grasses
B. 1. f. Aquatic plants
B. 2. c. Fish
C. 2. e. Camping and hiking
C. 3. a. Scenic views and vistas
C. 3. b. Wilderness qualities
C 3. h. Rare and unique species
C 4. b. Health and safety
•° g,
If
D> c
£ O
2> 5
CO
IS^i5« °J2
0) o — i 0> *• T5
* S I 1 8 8 I 5
•=«»8(B»S._E-o
CQ Sk v* PK •* UJ U ^
f S, ^ u) 0> _ J^?J S
iSc^cow-sj**8
S-e etf«2 JR ^? •» «>
•g ™ « S t:
.E if
o> to n ^
= •"• m w
V
V
V
V
V
V
W
V
yy
yy
FIGURE 4.1-1. A reduced matrix for a phosphate mining lease.
(Source: Leopold et al. 1971)
Environmental field studies can be more or less extensive
depending upon the existing information. Their scope will vary in
relation to the nature of the proposed action and the information
gaps that need to be filled. Field studies document the existing
environmental conditions and contribute to trend information in the
potentially affected region. They provide a reference baseline
from which the assessment team can predict the effects of the
proposed action, recommend alternatives, define appropriate
mitigation measures, and design future programs to monitor the
accuracy of predictions and the effectiveness of mitigation.
4-9
-------
An environmental field study is only part of the EA process
as such is influenced by external factors. These include, for
example:
other socioeconomic studies being performed,
political and legal requirements to be met,
specific features and timing of the proposed action,
project planning and engineering,
- , stages of the decisionmaking process requiring environ-
mental input, and
how the baseline data will be used in the construction,
operation, and closure phases of an approved action.
For example, the identification of permeable strata in geotechnical
studies may dictate an emphasis on biological effects of leachates
contaminating surface waters down-slope from a development; or
frequent temperature inversions detected by atmospheric studies
may call for increased emphasis on the biological effects of
gaseous emissions; or water resource studies may reveal a general
lack of surface water in a region, thereby requiring greater
emphasis on a few surface water bodies as critical habitats in the
ecological studies.
Most important is the integration of environmental field studies
with engineering design studies. Impact predictions will be
accurate only to the extent that the best possible environmental
knowledge is combined with detailed engineering plans in the
presence of good professional judgment.
Once environmental components of interest are identified, it is
necessary to choose methods for measuring the appropriate
parameters. Methods selection is tempered by the limitations of
the state of the art, which include considerations of accuracy,
efficiency, and cost-effectiveness, and the amenability of various
methods to statistical analysis. Stepwise procedures for applying
these important constraints to the final design of environmental
studies are too extensive to be included in this sourcebook.
However, the U.S. Fish and Wildlife Service Manual "A Systems
Approach to Ecological Baseline Studies" (1978) contains the
conceptual framework for field studies and practical step-by-step
approaches to designing baseline studies.
4-10
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Whenever possible, existing data should be used to reduce the
costs of EA. Attachment 4.A lists some of the sources of
environmental monitoring data in the United States and elsewhere.
In developing countries, such data are less available which limits
description of the affected environment and prediction of potential
impacts.
Federal and state air and water quality monitoring generally is
designed as a large-scale regional surveillance effort, and thus is
particularly useful for policy, plan, and program EA. When local
data can be located, they often are not in a readily usable form;
specific parameters and analytical methods may not be adequate,
or quality control and assurance may not be sufficient. Existing
data usually are not computerized with an adequate and
comprehensive indexing code for geographical locations. Thus,
they are useful only to describe general environmental conditions
and recent trends in environmental quality and will generally have
limited use for site-specific analysis of environmental change.
Unfortunately, in the U.S. and other countries, central sources for
identifying all national, regional, and local monitoring efforts do
not exist. Information can be gathered from individual federal
(Attachment 4.A) and regional agencies by contacting the agency
directly or, in some rare instances, by contacting a central
information source (e.g., the Oak Ridge National Laboratory
Carbon Dioxide Information Analysis Center; Attachment 4.A).
In addition to the U.S. federal laws listed in Part D, other federal
laws contain provisions that affect the content and scope of an EA
under certain circumstances. Laws on water pollution control,
clear air, and surface mining control and reclamation as well as
permits or licenses may require baseline data. If a development
involves leasing lands from federal agencies, studies may be called
for in lease stipulations (e.g., leases for prototype oil shale
development). Requirements at the regional level of government
may be more strict than those at the federal level. In the U.S.,
sixteen states, the District of Columbia, and Puerto Rico have
environmental policy acts or "little NEPAs", and 18 other states
and the District of Columbia have limited environmental review
requirements established by statute, executive order or other
administrative directives (Part D). For the most part, proponents
will have had previous experience on similar projects and will be
able to direct the assessment team to other agencies that should be
contacted.
4-11
-------
A summary of applicable legal requirements should be preparedfl)
that includes:
federal, tribal, regional, or local agencies with decision-
making or review responsibilities;
applicable federal, tribal, regional, or local laws, regula-
tions or permits and their specific environmental require-
ments;
official interpretations of the laws, regulations or permits;
information needs identified by federal, tribal, regional, or
local agency representatives; and
specific requirements of any reports that must be produced.
Once this information is available, the existing data for the site
should be compared to the requirements (e.g., water quality
criteria) to determine the information gaps and the extent of
additional monitoring data or other required information (e.g.,
archaeological or protected species surveys).
ISSUES
• Descriptions of the affected environment must concentrate on
issues that are significant and appropriate for the size and location
of the proposed action and alternatives rather than amassing
needless detail. The level of detail should be sufficient to convey
to a reader or reviewer the nature of the natural and human
resources. Where an action (and its anticipated effects) is
essentially confined to a particular piece of property, it may be
appropriate to describe natural and man-made features of the
property and vicinity. Where the action extends across several
regions or political subdivisions, as with a transmission line,
pipeline, or canal, the discussion of existing environments may
necessarily be less detailed in certain categories.
• Field studies should not be undertaken without clearly defined
objectives and understanding of the problem to which the data will
be applied. The data must be consistent with the needs of: the
EA team for modeling or predictive purposes, the decisionmaker
and the project planners, and the legal and socioeconomic
requirements.
• Careful consideration must be given to the need for and value of
existing data in relation to their inherent limitations (e.g.,
fragmented, inaccessible, unstandardized) and their usefulness in
I
4-12
-------
impact analysis and prediction. The focus is often on collecting
information and data that are readily available rather than on what
is needed for analysis. The data requirements should be defined
by what is needed for assessment of the endpoints.
In addition to the seriousness of anticipated impacts, the level of
effort expended on description of the affected environment is
determined by cost and time factors. In general, the resources
available will be no more, and often less, than the minimum that
is required by the decision process. Thus, it is important to focus
on those elements of the affected environment most pertinent to the
decision process and to use those methods that are most cost
effective in obtaining adequate data. Time may influence the
scope of this part of EA in several ways. For instance, the
environmental parameters of interest may vary from season to
season and even year to year and data collection to establish these
patterns may not be synchronized with the needs of the
decisionmaker.
Data collected must be amenable for use in models, experimental
designs or statistical analysis so that project-induced effects can be
separated from naturally occurring changes.
LINKAGES
Description of the affected environment should be structured
around the issues, valued resource components, and assessment
endpoints identified during initiation and scoping. The results of
data collection and any field studies are the basis for assessment of
potential environmental impacts of proposed actions and
alternatives. An appropriate, well-documented description of the
affected environment will aid the decisionmaker in the
identification and resolution of problems associated with the
proposed action. Moreover, it is the basis for post-decision
monitoring.
4-13
-------
REFERENCES
Beanlands, G. E., and P. N. Duinker. 1983. An Ecological Framework for
Environmental Assessment in Canada. Institute for Resource and
Environmental Studies, Dalhousie University, Halifax, Nova Scotia and
Federal Environmental Assessment Review Office, Hull, Quebec.
Bregman, J. I., and K. M. Mackenthun. 1992. Environmental Impact
Statements/ Lewis Publishers, Inc. 121 South Main Street, Chelsea,
Michigan 48118. 279pp.
Federal Interagency Committee on Urban Noise. 1980. Guidelines for
Considering Noise in Land Use Planning and Control.
Hirsch, A. 1980. The baseline study as a tool in environmental impact
assessment. In: Biological Evaluation of Environmental Impacts, The
Proceedings of a Symposium. Fish and Wildlife Service FWS/OBS-
80/26. pp. 84-93.
McBrayer, J. F., S. B. Gough, R. C. Robertson, and H. E. Zittel. 1981.
Identifying alternatives at a reconnaisance level. Environmental Impact
Assessment Review 2:190-195.
Leopold, L. B., F. E. Clarke, B. B. Hanshaw, and J. R. Balsley. 1971. A
Procedure for Evaluating Environmental Impact. U.S. Department of the
Interior, Geological Survey Circular 645.
U.S. Fish and Wildlife Service. 1978. A Systems Approach to Ecological
Baseline Studies. FWS/OBS-78/21. 406 pp. Available from National
Technical Information Service, telephone (703) 487-4780.
National Wildlife Federation. Annual Conservation Directory. National Wildlife
Federation, Washington, D.C., telephone (202) 797-6800.
4-14
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ATTACHMENT 4.A
SOURCES OF ENVIRONMENTAL DATA
• Federal Interagency Initiatives to Coordinate Environmental Data and Analysis
(Source: Council on Environmental Quality. 1993. Environmental Quality. 23rd
Annual Report)
• Environmental Statistics Programs Managed by Agencies of the U.S. Government
(Source: Council on Environmental Quality. 1993. Environmental Quality. 23rd
Annual Report)
• Summary and table of contents for the Manual of Federal Geographic Data Products
(Source: Federal Geographic Data Committee. 1993)
• State of the Environment Reports and Statistical Compendia Published by
International Organizations (Source: Council on Environmental Quality. 1992.
Environmental Quality. 22nd Annual Report)
• Table of contents for A Guide To Selected National Environmental Statistics In The
U.S. Government (Source: U.S. Environmental Protection Agency. 23Q-R-92-003.
April 1992)
4.A-1
-------
4.A-2
-------
Federal Interagency Initiatives to Coordinate Environmental Data and
Analysis (Source: Council on Environmental Quality. 1993. Environmental
Quality. 23rd Annual Report)
Program
Lead Agency
Coverage
Interagency Committee on
Environmental Trend*
CEQ
In 1991 CEQ eittbliihed an interagency committee with the participation of all
agencies involved in environmental data to undertake development of a
framework for U.S. atate-of-the-environment reporting.
National Acid Precipitation
Aateatment Program 1990
(NAPAP)
CEQ
NAPAP, established by me 1980 Acid Precipitation Act, coordinate* federally
funded research and assessment to develop a firm scientific basil for acid rain
policies. The Clean Air Act Amendments of 1990 extended NAPAP, which
monitors the influence of the Clean Air Act on environmental impact*.
Environmental Monitoring
and Aaseatment Program
(EMAF)
EPA
A long-term research, monitoring, and assessment program, initiated in 1988 to
provide regional and national reports on the conditions of U.S. ecological
resources. During the next five yean, EMAP monitoring network* will estimate
trend* in national ecological indicator* on a regional ban*; monitor (elected
indicator* of natural and anthropogenic stresses; seek association* between
human-induced stresses and ecological condition* and provide periodic statistical
summaries and interpretive report* on status and trend* for resource manager* and
the public.
EPA Center for
Environmental Statistic*
EPA
EPA Development Staff established the Center for Environmental Statistic* to
gather environmental data from a variety of sources; address data quality and
statistical issue*; and use data to provide information on environmental
conditions. The Center currently is situated within the EPA Environmental
Statistic* and Information Division.
Intergovernmental
Monitoring Task Force
EPA and USGS
Established in 1991 by the EPA Office of Water and the USGS. The task force
coordinates efforts with NOAA, FWS, COE, USDA, OMB, and DOE to identify
and recommend solutions to water quality monitoring problem*; establish a
national framework for water quality monitoring; agree on environmental
indicator*; and share water quality data through system linkage* and increased
quality assurance and control.
Federal Geographic Data
Committee (FGDC)
DOI
FGDC, with 14 departments and agencies promotes coordinated development,
u*e, and dissemination of surveying, mapping, and related spatial data.
Established by OMB Circular A-16, "Coordination of Surveying, Mapping, and
Related Spatial Data Activities," the committee stresses coordination and
standards.
Ocean Pollution Data and
Information Network
(OPDIN)
NOAA
A 10-year interagency effort by 11 federal agencies to improve accessibility and
usefulness of data and to increase communication and coordination on ocean and
Great Lakes pollution information; the network publishes information guides and
responds to request* for information.
FCCSET/CEES
IWGMDGC
OSTP
Within the President's Office of Science and Technology Policy (OSTP), the
Federal Coordinating Council for Science, Engineering and Technology
(FCCSET) established the Committee on Earth and Environmental Science*
(CEES) aa a forum to coordinate interagency program*, including the U.S. Global
Change Research Program (USGCRP). Chaired by NASA and NOAA, the
Interagency Working Group on Data Management for Global Change
(IWGDMGQ is developing recommendation* on interagency management of
research data. In 1991 the National Research Council drafted a 'U.S. Strategy
for Global Change Data and Information Management.*
4.A-3
-------
Federal Inter-agency Initiatives to Coordinate Environmental Data and
Analysis (continued)
Lead Agency
Coverage
President'* Water Quality
Initiative
USDA
This initiative addresses nonpoint source contamination of surface water and
gfoundwater by agricultural chemicals: 11 agencies, including TV A, USGS,
EPA, NOAA, FWS, and COB, comprise the working group on the Water
Quality. Cooperative programs include the USDA Management Systems
Evaluation Areas, the USGS National Water Quality Assessment, and the EPA
Midwest Agrichemical Surface/Subsurface Transport and Effects Research
project.
Water Information
Coordination Program
(WICP)
uses
OMB Memorandum M-92-01 of December 10, 1991, established the Water
Information Coordination Program to include all federal organizations that fund,
collect, or use water resources information. WICP convenes an Interagency
Coordinating Committee for Water Information and a Federal Advisory
Committee on Water Data for Public Use. The program is establishing effective
working relationships with state and local agencies, Indian tribes, and the private
sector. WICP will plan, design, and operate a cost-effective national network for
water-data collection; develop uniform standards for water information collection,
management, and dissemination; establish a National Water Information
Clearinghouse; and annually report to OMB to document funding and program
activities.
National Resources
Inventory (NRJ)
USDA Soil
Conservation
Service
This national multi-resource inventory is conducted every 5 years to determine
status, condition, and trends of soil, water, and related resources NRI and
associsted soils data are used to formulate policy and assist in strategic planning
of conservation and environmental programs at national, regional, and local
levels.
Forest Health Monitoring
Program
USDA Forest
Service
This long-term monitoring program was started in 1990 to measure, interpret, and
report effects of forest pests, air pollution, other stressors, and management
methods on the health of U.S. forests. The program included 14 states in 1992
and will be expanded nationwide in future yean. It has three increasingly
intensive phases: detection monitoring to determine annual differences from
baseline conditions or trends; in-depth evaluation monitoring to determine cause,
extent, and severity of detected changes; and intensive-site ecosystem monitoring
to provide detailed, long-term research data for predicting future conditions.
Cooperators include EPA, the National Association of State Foresters, and other
state and federal resource agencies.
4.A-4
-------
Federal Intel-agency Initiatives to Coordinate Environmental Data and
Analysis (continued)
Lead Agency
Coverage
NOTE: The foDowiof abbreviations appear in the eurironmental data tables:
BLM
CEQ
COE
DOC
.DOE
DOI
EC
EPA
FAO
FWS
NASA
NOAA
OMB
OSTP
RPA
USDA
USOS
Bureau of Land Management, Department of Interior
President's Council on Environmental Quality
U.S. Depaftment of Defense, Army Corpi of Engineer*
U.S. Department of Commerce
U.S. Department of Energy
U.S. Department of the Interior
European Community
U.S. Environmental Protection Agency
United Nation! Food and Agriculture Organization
Fiih and Wildlife Service, Department of the Interior
National Aeronautic! and Space Administration
National Oceanic and Atmospheric Administration, Department of Commerce
President's Office of Management and Budget
President's Office of Science and Technology Policy
Forest and Rangeland Renewable Natural Resources Policy Act
U.S. Department of Agriculture
U.S. Geological Survey, Department of the Interior
4.A-5
-------
4.A-6
-------
Environmental Statistics Programs Managed by Agencies of the U.S.
Government (Source: Council on Environmental Quality. 1993. Environmental
Quality. 23rd Annual Report)
•>
rrognuB
Major Uses of Land in
the United State*
Agricultural Chemical
Usage Statistics
Pollution Abatement
Control Expenditure!
(PAQ
Energy and
Environment*!
Databaae
Forest Iniect end
Disease Conditions in
the United States
RPA AMeument of the
Forest and Rangeland
Situation
Land Aicaaoftbe
National Fore* System
Tree Planting in the
United States
Survey of Pollution
Abatement Costs and
Expenditures
Sponsor
USDA Economic
Research Service
t
USDA National
Agricultural Statistics
Service and Economic
Research Service
DOE Bureau of
Economic Analysis
DOC Bureau of the
Census, Center for
Economic Studies
(CES)
USDA Forest Service
USDA Forest Service
USDA Forest Service
USDA Forest Service
DOC Bureau of the
Census
Coverage
Estimated acreage and inventories of major U.S. land
uses and of cropland used for craps.
Estimated treatment acreage and application quantity of
fertilizer nutrients and pesticide ingredients applied to
field crops, vegetables, and fruits; includes state
estimate* for those states where the commodities are
predominantly produced.
Summary of all spending for PAC by business,
government, and consumers, and by type.
Census Bureau and EPA data files have been integrated,
yielding longitudinal plant and firm level data on
production inputs, outputs, costs, energy consumption,
pollution emissions, and pollution abatement
expenditures.
Data for U.S. federal, state, and private forestlands;
data analyses by region, ownership, type of
insect/disease, area affected, trend data available
Inventory with trend information on extent, condition,
ownership, and composition of U.S. forests; wildlife
habitat, forage production, and other resource
characteristics.
Data on extent and characteristics of forest, range, and
related lands in the National Forest System.
Summary of tree planting in the United States.
Annual operating costs and capital expenditures for
pollution abatement activities in manufacturing
industries.
Frequency/Most
Recent Report
Intervals of major
land uses coincide
with the Census of
Agriculture; 1991
report with 1987
data. Annual reports
for cropland used for
craps; 1992 report
with preliminary
1992 data.
Annual collection for
field crops; 1992
report with 1991
data. Biennial
report* for vegetables
and fiuits; 1991
report for vegetable*
with 1990 data and
1992 report for fruit*
with 1991 data.
Annual reports; 1992
report with 1990
data.
Annual collection
Annual collection;
1992 report with
1991 data.
5-year cycle; 1989
reports with 1987
data.
Annual reports.
Annual reports; 1992
report with 1991
data.
Annual collection.
4.A-7
-------
Environmental Statistics Programs (continued)
Program
Clarified Shellfishing
Waters
Fisheries Sutiftici
'Program
National Climatic Data
Center (NCDC)
National
Oceanographic Data
Center (NODQ
National Geophysical
Data Center (NGDC)
National Coactal
Pollutant Discharge
Inventory Program
Sponsor
NOAA
NOAA
NOAA
NOAA
NOAA
NOAA
Co?erage
Monitors classified shellfishing waters a* indicator! of
bacterial water quality nationwide; classifies waters for
commercial harvest of oysters, clams, and mussels
based on actual or potential pollution sources and
coliform bacteria levels in surface water*.
National compilation, analysis, and dissemination of
biological, economic, and sociological statistics from
U.S. commercial (domestic and high seas) and
recreational fisheries. Mostly marine; historical time
series, some dating back to 1800s; some world (FAO,
EC) fishery data, foreign nation data on fisheries in
U.S. Waten. Data types include landings, prices and
fishing efforts; number of vessels, gear and fishermen;
annual processed products; trade in fisheries products;
species composition; length frequencies; per capita
consumption; and aquaculture.
NCDC collects, processes, archives, and disseminates
worldwide meteorological and climatological data from
a global network of stations; coverage is global, land
and sea, primarily of U.S. dependencies, especially for
summarized data.
NODC collects, processes archives, and disseminated
such worldwide oceanograpbic data as marine biology,
marine pollution, wind and waves, surface and
subsurface currents, and temperature.
NGDC collects, processes, archives, and disseminates
such worldwide geophysical data as solid earth
geophysics, earthquake seismology, geomagnetic
surveys, marine geology and geophysics, solar-
terrestrial physics, and glaciology.
Compiles pollutant-loading estimates for point,
nonpoint, and riverine sources in coastal counties or the
200-mile Exclusive Economic Zone. Such sources
discharge to the estuarine, coastal, and oceanic water*
of the contiguous United Slates, excluding the Great
Lakes.
Frequency/Most
Recent Report
5-year surveys; most
recent 1990.
Collect
daily/monthly/yearly
information from
primary and
secondary sources;
monthly, quarterly,
and annual
publications; user
requests via bard
copy, magnetic
tapes, diskettes.
CD-ROM, PC
Bulletin Board.
Responds to over
33,000 user requests
per year, these
records date from
mid-nineteenth
century to present.
Responds to over
10,000 user requests
per year; record*
date from late-
nineteenth century to
present.
Responds to 11,000
user requests per
year; record* date
from mid-nineteenth
century to present.
East, West and Gulf
Coast estimates are
for 1982, 1984, and
1987 respectively.
In 1993 estimates
will be updated to
1991 for all three
marine coasts.
4.A-8
-------
Environmental Statistics Programs (continued)
Program
National Estuarine
Inventory
Month and Slate
Current Emissions
Trends
National Energy
Information Center
Carbon Dioxide
Information Analysis
Center
Integrated Data Base
Program
National Wetlands
Inventory
Gap Analysis
National Contaminant
Biomonilonng Program
North American
Breeding Bird Survey
Sponsor
NOAA
DOE Argonne
National Laboratory
DOE Information
Administration
DOE Oak Ridge
National Laboratory
DOE
FWS
FWS
FWS
FWS
Coverage
Compiles, evaluates, and assesses information on 102
estuaries in the continental United States, including data
on salinity, bottom sediments, freshwater inflow,
pesticide use, land use, distribution of estuarine fishes
and invertebrates, population, water quality, recreation
use, and wetlands.
Emissions estimates for NOx, SO2, and VOCs by
month and state from 1975 to the present for 68
emission source groups.
Collects and publishes data; prepares analyses on
energy production, consumption, prices, and reaourcea;
makea projections of energy supply and demand.
Compiles, evaluates, and distributes information related
to carbon dioxide.
Maintains data on all spent radioactive fuel and waste in
the United States.
Develops comprehensive information on the
characteristics and extent of U.S. wetlands resources;
wetlands map coverage for 70% of lower 48 states,
22% of Alaska, and all of Hawaii, Puerto Rico, and
Guam.
Develops standardized distribution maps of surface
vegetation, terrestrial vertebrates, and endangered
species in the lower 48 states and Hawaii.
Documents temporal and geographic trends in
concentrations of persistent environmental contaminants
that may threaten fish and wildlife; covers major V.S.
riven and Great Lakes.
Provides uniform basis for assessing long-term trends in
avian populations throughout North America; total
number of individuals by species, survey route, and
stale.
Frequency /Most
Recent Report
Many projects are
others involve a
snapshot view of
existing data. Topics
of the Coastal Trends
aeries include a
summary report on
U.S. estuaries
(1990), coastal
wetlands (1991),
housing starts
(1992), coastal
pollution (expected
1993), oil spills
(expected 1993).
Monthly; 1975 to
present.
Annual reports.
Data collection
ranges from hourly
to decadal.
Annual data
collection and
reporting.
Continuous wetlands
trend for lower 48
states; statistical
estimates of U.S.
wetlands acreage
beginning in 1990.
First analysis, 1988
national assessment
to be completed in
1998, to be updated
at 5-year intervals.
2-to-4 year intervals.
2-year intervals.
4.A-9
-------
Environmental Statistics Programs (continued)
Program
Waterfowl Breeding
Population and Habitat
Statistics and
Information Service!
Public Land Statictica
National Stream
Quality Accounting
network (NASQAN)
and National
Hydrologic Benchmark
Network
National Trend*
Network
National Water
Condition* Reporting
System
National Land Ute and
Cover Program
Water Data Program
National Water Uae
Information Program
Sponsor
FWS
Bureau of Mine* ''
BLM
uses
uses
uses
USOS
uses
USOS
Coverage
Provide* annual breeding population ettimatea;
measure* breeding habitat change* over major portion
of duck breeding range in North America.
Collect*, analyze*, and publiihe* data on metal
production and consumption, including wrap and waste.
Collect* summary statistic* of land ownership in the
United States and BLM natural resource management
program* at the state level.
NASQAN provides a national uniform basi* for
assessing large-scale, long-term trend* in physical,
chemical, and biological characteristic* of water*;
monitor* for pH, alkalinity, sulfate, nitrate, phocphorui,
calcium, nugneaium, (odium, potasiium, chloride,
suspended sediment, fecal coliform bacteria, fecal
streptococci) bacteria, dissolved oxygen, dissolved
oxygen deficit, and trace elements; the Benchmark
Network monitors water quality in surface water*
largely unaffected by human activities
Monitor* atmospheric deposition under National Acid
Precipitation Assessment Program (NAPAP); 150
stations predominantly in rural areas, in combination
with USDA National Atmospheric Deposition Program
(NADP); almost 200 *ite* nationwide.
Collect* and analyze* streamflow data, groundwater
levels, reservoir content*, and limited water-quality data
from 5 site* on major rivers.
Includes land-use and land-cover map* and digitized
data. Statistics by political units, hydrologic units, and
census county subdivisions are available. Classes
include urban or built-up land, agricultural land,
rangeland, forcslland, water areas, wetland, barren
land, tundra, and perennial snow and ice. Maps are
available for most of the country at 1 :250,000 scale.
Nearly 60,000 water-data stations throughout the nation
are used to obtain record* on stream-flow, stage
(height), reservoir and lake stage and storage,
groundwater levels, well and spring discharge, and
quality on surface water and groundwater. Data, stored
in the WATSTORE database, are available in machine
readable form or a* computer printed tables or graphs,
statistical analyses, and digital plots.
Determines purpose* for U.S. fresh and saline surface
water and groundwater withdrawn, water consumed
during use; and water returned to source after use.
Frequency/Most
Recent Report
Annual survey* and
report*.
Monthly, quarterly,
and annually.
Annual reports.
Yearly data
summaries for each
state.
NAPAP publications.
Published in month
newsletter. National
Water Conditions.
USGS publications.
Published by water
year for each state.
National
compilation* every 5
yean; most recent.
4.A-10
-------
Environmental Statistics Programs (continued)
Program
Water Reaource*
Assessment Program
Earth Obterviog
System
National Air PoUution
Control Program
Comprehensive
Environmental
Reaponae,
Compensation, and
Liability Information
System
Environmental
Radiation Ambient
Monitoring System
(ERAMS)
Hazardouiand
Monhazardout Survey*
Toxica Release
Inventory
Water PoUution
Control Act Section
105/M Assessment*
Ambient Water
Monitoring
Program/STORET
Sponsor
uses
NASA
EPA Office of Air
Quality Planning and
Standarda
EPA Office of
Emergency and
Remedial Response
EPA Office of
Radiation Programs
EPA Office of Solid
Waste
EPA Office of Toxic
Substances
EPA Office of Water
EPA Office of Water
Coverage
Summarize* statistics on state and national water
resources for USOS biennial report, National Water
Summary, each report oriented to water resource theme,
such as groundwater quality.
Measure* key environmental variable* using aerie* of
unmanned aatelite*; part of NASA Mission to Planet
Earth program; EODIS, it* data and information
system, will coordinate with the Global Change Data
and Information System, which includes the NOAA
data and information system.
Collect* and analyze* data on ambient air quality and
air pollution levels and compares them to National
Ambient Air Quality Standard* (NAAQS).
Contain* information on over 30,000 abandoned or
uncontrolled bazardoua waste lite*.
Moniton radiation in air, drinking water, surface water,
and milk.
Collect data through survey and regulated entity report*
on hazardous and non-hazardous (solid) wastes
generation and management; information on regulated
entities and the waste volume* they generate and
manage.
Mandatory annual inventory of releaae* of 328 toxic
chemical* to air, water, land, and off-site disposal from
more than 17,000 manufacturing facilities across the
country. Material is available on CD-ROM.
Compiles stale reports on water quality status of surface
water and groundwater, a* required by section 305(b),
Federal Water Pollution Control Act; the date* prepare
assf stmrnts usinff various monitorinff data
*• ^
largest database for water quality information; data
contained in STORET with over 170 million data point*
from slate* and federal agencies, such as USGS, on
surface water and groundwater quality, sediment*,
streamflow, and fish tissue contamination.
Frequency/Mo**
Recent Report
Biennial; 1991 report
covered floods and
drought*.
NASA publication*.
Annual report* on air
quality and emission
estimates.
Updated on-line.
Sampling interval*
from twice weekly to
bi-annual, baaed on
analyses, at 332
stations; since 1973.
Current data is from
1985 biennial report
and two 1986
surveys.
Annual report*.
1990 biennial report
aa of 1988.
Updated on-line.
4.A-11
-------
Environmental Statistics Programs (continued)
fft n , ,,
rrognun
Public Water System
Supervision Program
National Pollutant
Discharge Elimination
System Ptognm
Municipal Conitniction
Program
Coastal and ocean
Protection Programs
Note: Neither this table i
maintains mission-orients
DOC Bureau of Census n
on marine resource* and <
and NFS collects compan
production, consumption,
hunting, and wildlife-aiso
cover, and EPA conducts
U.S. Coast Guard mainta
Source: U.S. Environme
Statistics in the U.S. Gov
Sponsor
EPA Office of Water
EPA Office of Water
EPA Office of Water
EPA Office of Water
Coverage
Contains information about public water supplies
(PWSs) and their compliance with monitoring
requirements, maximum contaminant level (MCL)
regulations, and other requirements of the Safe
Drinking Water Act; data is stored in the Federal
Repotting Data System.
Tracks permit compliance and enforcement status of
facilities covered by water pollution permits;
information is contained in the Permit Compliance
System. (PCS)
Inventory of existing or proposed publicly owned
treatment works (POTWs) that need construction or
renovation to meet Clean Water Act requirements;
information is maintained in the Needs Survey System.
Coven environmental data (water quality, biological,
permitting, environmental impact data) for discharges
and pollutant loadings to coastal waters as well as ocean
dumping; information contained in Ocean Data
Evaluation System (ODES).
Frequency/Mot*
Recent Report
Quarterly state and
EPA regional
reports.
Monthly facility
reports entered on an
ongoing basis.
2-year update from
each state; biennial
report submitted to
the Congress.
Biennial reports to
the Congress for
National Estuary
Program; annual
reports to the Ocean
Dumping Program;
special reports on
coastal programs.
wr the source document, which describes 72 federal programs, are exhaustive. For instance, USDA also
1 statistics in such areas as crops, snowpack, soil erosion, national forests management, and wildfires. The
laintains social, demographic, and economic statistics relevant tot he environment. NOAA maintains statistics
oastal wetlands. BLM maintains statistics for BLM lands, including condition, wildlife, minerals, and use;
ible statistics on the status of national paries. The Bureau of Mines collects, interprets, and publishes data on
and trade of over 100 minerals. FWS maintains data on FWS land* and conducts surveys of fishing,
ciated recreation every 5 yean, with the most recent report in 1991. USGS maps national land use and land
regional and other pollution surveys. DOT compiles highway and other transportation statistics, and the
ins data on marine pollution spills.
ntal Protection Agency, Center for Environmental Statistics, Guide to Selected National Environmental
emment (draft), (Washington, DC; EPA, 1992).
4.A-12
-------
Summary and Table of Contents for the Manual of Federal Geographic Data
Products (Source: Federal Geographic Data Committee. 1993)
Manual of Federal Geographic Data Products
The Manual of Federal Geographic Data Products describes Federal geographic data products
that are national in scope and commonly distributed to the public. Geographic data products
include maps, digital data, aerial photography and multispectral imagery, earth science, and
other geographically-referenced data sets. Federal agencies were encouraged to list only those
geographic data products that are supported by an office to which the public could make
inquiries and place orders. Federal agencies also were encouraged to list only those geographic
data that would be available by January 1993.
Data products are described in a standardized format and grouped by producing agency. A
cross-reference matrix is provided to help readers find products by data type.
The products listed in the Manual include only those that currently are distributed by the
agencies. Readers interested in historical Federal geographic data products should contact the
Reference Services Staff of the National Archives and Records Administration at (202) 501-
5579. The Map and Geography Division of the Library of Congress also has an extensive
collection of current and historical geographic data products from Federal and non-Federal
sources. The Division can be reached at (202) 707-MAPS.
While much effort was made to ensure that the Manual is comprehensive, inevitably there will
be products that were overlooked. In addition, rapidly changing geographic data technologies,
especially digital technologies, are resulting in new products and new forms of existing products.
Readers should contact the offices listed in the Manual to inquire about the availability of new
products and references to other Federal geographic data. The FGDC intends to revise the
Manual approximately every 2 years.
Readers are invited to provide corrections and to suggest other Federal products or information
for inclusion in future editions of the Manual. Readers also are encouraged to comment on the
usefulness of the Manual, and to suggest improved methods of presenting the information.
For more information about the FGDC, its activities, the Manual, or to be added to the
newsletter mailing list, please contact-
Federal Geographic Data Committee Secretariat
U.S. Geological Survey
590 National Center
Reston, VA 22092
USA
(703) 648-4533
4.A-13
-------
Table of Contents
Preface iii
Federal Geographic Data Committee Overview v
Data Product Keyword Matrix . . . . vii
1 United States Department of Agriculture
Agriculture Stabilization and Conservation Service 1-1
Forest Service ,1-5
Soil Conservation Service 1-21
2 United States Department of Commerce
Bureau of the Census 2-1
Bureau of Economic Analysis 2-31
National Environmental Satellite, Data, and Information Service 2-35
National Ocean Service 2-85
National Weather Service 2-111
3 United States Department of Defense
Defense Mapping Agency 3-1
4 United States Department of Health and Human Services
Centers for Disease Control 4-1
5 United States Department of the Interior
Bureau of Land Management 5-1
Bureau of Mines 5-29
Bureau of Reclamation 5-33
Minerals Management Service 5-37
National Park Service 5-45
United States Fish and Wildlife Service 5-51
United States Geological Survey 5-59
6 United States Department of Transportation
Federal Highway Administration 6-1
7 Independent Agencies
Federal Emergency Management Agency .._....- 7-1
National Aeronautics and Space Administration 7-5
Tennessee Valley Authority 7-13
Appendix A: Reader Response Form A-l
4.A-14
-------
State of the Environment Reports and Statistical Compendia Published by
International Organizations (Source: Council on Environmental Quality. 1992.
Environmental Quality. 22nd Annual Report)
Comnrnaon of the European CnmmimirifH (CEC)
CEC, The State of fa Environment In the European Community 1986, (Luxembourg: CEC, 1987). Earlier edition! wen publiibed in 1977 and
1979.
Eurostat, Batte Statistic* a/the Community, annual (Luxembourg: CEC, 1990).
Eurostat, Environment Statistics 1989, annual (Luxembourg: CEC, 1990).
OijiaiMtiM for Economic Cooperatioa and Development (OECD)
OECD, Environmental Data Compendium 1991, (Pkria: OECD, 1991). Earlier versions wen publiahed in 1984 (pilot), 1985. and 1987.
OECD, The State of the Environment, (Pan*: OECD, 1991). Previous editions wen publiahed in 1979 and 1985.
United Nation
A. L. Dahl and L. L. Baumgart, The State of ike Environment In the South Pacific, (Geneva, Switzerland: UNEP, 1983).
United Nationi Economic and Social Commiaaion for Asia and the Pacific, State of the Environment in Asia and the Pacific, (Bangkok:
UNESCAP, 1985).
United Nations Environment Programme (UNEP), Environmental Data Report 1991-92, biennial (Oxford, England: Basil Blackwell, 1991).
This report is coproduced with Kings College, London; the World Resources Institute in Washington, D.C.; and the U.K. Department of the
Environment. It was intended to complement the more easily understood World Resources Report.
UNEP, State of the World Environments, annual (Nairobi: UNEP, 1991). The 1982 and 1987 reports wen also published aa, respectively, M.
W. HoMgate, M. Kassas, and O. F. White, eds., The World Environment 1972-1982, (Dublin: Tycooly International, 1982); and B. H-Humawi
and M. H. Hashmi, The State of the Environment, (Cuildford, England: Butterworth-Heinemann, 1987).
UNEP, State of the World Environments, annual (Nairobi: UNEP. 1991). The 1982 and 1987 reports wen also publiahed aa, respectively, M.
W. Holdgate, M. Kassas, and O. F. White, eds., The World Environment 1972-1982, (Dublin: Tycooly International, 1982); and E. Et-Hinnawi
and M. H. Hashmi, The State of the Environment, (Cuildford, England: Butterworth-Heinemann, 1987).
UNEP, The State of the Marine Environment: UlfEP Regional Seas Programme, (Nairobi: UNEP, 1990). The following regions wen covered
for the years indicated: West and Central Africa (1984), East Africa (1980,1982,1984, and 1985), Kuwait (1985), South Asia (1985), East
Asia (1985), Red Sea and Gulf of Aden (1985). Indian Ocean (1985), and Oceania and the Pacific (1985).
United Nations Statistical Office and United Nations Economic Commission for Europe, Environmental Statistics In Europe and North America:
An Experimental Compendium, (New York: UNSO and UNECE, 1987).
World Bank
World Bank, The World Bank and the Environment, (Washington, DC; World Bank, 1990).
World Bank, World Development Report 1991, annual, (Oxford, England: Oxford University Pnss, 1991).
Worid Resources Institute
A.L. Hammond, ed., World Resources 1990-1991, biennial, (Oxford, England: Oxford University Pnss, 1990). This publication is coproduced
with UNEP and the International Institute for Environment and Development.
World Resources Institute. The 1992 Information Please Environmental Almanac, (Boston: Houghton Mifflin, 1991).
Source: J. Parker and C. Hope, The state of the environment: a survey of reports from around the world,* Environment 34(1):20. (Heldnf
Publications).
4.A-15
-------
4.A-16
-------
United States Policy, Planning,
Environmental Protection And Evaluation
A
Agency
EPA
(PM-223)
230-R-92-003
April 1992
A Guide To Selected National
Environmental Statistics
In The U. S. Government
-------
TABLE OF CONTENTS
Statistical Programs
ACKNOWLEDGMENTS Jii
FOREWORD v
TABLE OF CONTENTS vu
INTRODUCTION .ri
DEPARTMENT OF AGRICULTURE
Economic Research Service
Major Uses of Land in the United States 1
Soil Conservation Service
National Resources Inventory 3
U.S. Forest Service
Forest Insect and Disease Conditions in the United States 5
Forest Inventory and Analysis 6
Forest Service Range Management Information System 8
Land Areas of the National Forest System 9
Recreation Information Management System 10
Tree Planting in the United States 11
Wildland Fire Statistics 12
DEPARTMENT OF COMMERCE
Bureau of the Census
Farm and Ranch Irrigation Survey 13
Annual Surveys of Government Finances and Government Employment 14
Decennial Census of Population 16
National and Subnational Population Estimates and National and State Population Projections 18
Survey of Pollution Abatement Costs and Expenditures 20
National Oceanic and Atmospheric Administration
Classified Shellfishing Waters 21
Fisheries Statistics Program . 22
Living Marine Resources 23
National Climatic Data Center 25
National Coastal Pollutant Discharge Inventory Program 27
National Status and Trends Program 29
DEPARTMENT OF ENERGY
Argonne National Laboratory
Month and State Current Emissions Trends 31
Energy Information Administration
National Energy Information Center 32
Oak Ridge National Laboratory
Carbon Dioxide Information Analysis Center 33
Integrated Data Base Program 35
SELECTED ENVIRONMENTAL STATISTICS IN THE U.S. GOVERNMENT PAGE vii
-------
DEPARTMENT OF HEALTH AND HUMAN SERVICES
National Center for Health Statistics
Health and Nutrilion Examination Surveys 36
DEPARTMENT OF THE INTERIOR
Bureau of Land Management
Public Lands Statistics 38
Range Site Inventory 39
Timber Sale Information System 40
Bureau or Mines
Minerals Information Program 41
National Park Service
Master Deed Listing 4.1
National Park Service Gaseous Pollutant Monitoring Network 44
National Park Service Visibility Monitoring Network 45
National Recreational Trails, Long-Distance Trail Management, and National Trail Inventory and Plan . 46
National Wild and Scenic Rivers System 4X
Public Use Analysis and Reporting Program 49
U.S. Fish and Wildlife Service
National Contaminant Biomonitoring Program 50
National Survey of Fishing, Hunting, and Wildlife-Associated Recreation 52
National Wetlands Inventory 54
North American Breeding Bird Survey ._5/>
U.S. Fish and Wildlife Service Lands
Waterfowl Breeding Population and Habitat Survey
U.S. Geological Survev
National Hydrologic Benchmark Network Program 59
National Land Use and Land Cover Mapping Program 61
National Stream Quality Accounting Network 62
National Trends Network 64
National Water Conditions Reporting System 66
National Water Use Information Program 67
Water Resources Assessment Program 69
DEPARTMENT OF TRANSPORTATION
Federal Highway Administration
Highway Statistics 70
Research and Special Programs Administration
National Transportation Statistics 72
UJ5. Coast Guard
Marine Pollution Retrieval System .- 73
ENVIRONMENTAL PROTECTION AGENCY
Office of Air Quality Planning and Standards
National Air Pollution Control Program 74
i
PAGE viii SELECTED ENVIRONMENTAL STATISTICS IN THE U.S. GOVERNMENT
-------
ENVIRONMENTAL PROTECTION AGENCY (Continued)
Office of Ecological Processes and Effects Research
Environmental Monitoring and Assessment Program, Long-Term Monitoring Project 75
National Surface Water Survey 76
Office of Emergency and Remedial Response
Comprehensive Environmental Response, Compensation and Liability Information System 78
Office of Radiation Programs
Environmental Radiation Ambient Monitoring System 79
Office of Solid Waste
/•
- Hazardous and Non-Hazardous Waste Surveys 80
Office of Toxic Substances
Toxics Release Inventory 82
INDEX OF KEY WORDS , 83
INDEX OF DATA PROGRAMS 85
SELECTED ENVIRONMENTAL STATISTICS IN THE U.S. GOVERNMENT PAGEix
-------
ATTACHMENT 4.B
COMPUTER-AIDED ENVIRONMENTAL ASSESSMENT
Luhar, A. K., and P. Khanna. 1988. Computer-aided rapid environmental impact
assessment. Environmental Impact Assessment Review 8:9-25.
4.B-1
-------
4.B-2
-------
ENVIRON IMPACT ASSESS REV 1988:8:9-25
COMPUTER-AIDED RAPID ENVIRONMENTAL
IMPACT ASSESSMENT
ASHOK K. LUHAR AND P. KHANNA
Environmental impact assessment of a project attempts to bring about compatibility
between ecology and economics. A computer-aided, quantitative and rapid meth-
odology for environmental impact assessment is presented in this paper. The cost
of abatement of deleterious environmental impacts is one of the factors used to
identify the best project option from environmental and cost considerations. The
methodology is based on the three basic steps of environmental impact assessment
vis-a-vis identification, prediction, and evaluation. Several models and predictors
for different environmental components are incorporated in the computer program.
An evaluation method is presented based on mathematical functions for value
function graphs for different aesthetic, environmental, and health risks.
Most of the countries had to review their environment policies following the
Stockholm Conference on Human Environment (June 1972) wherein developed
countries visualized environmental problems as an affliction of industrialization
and suggested "no growth" policy as the only viable means of protecting the
biosphere. However, developing countries, including India, shared the view that
environmental problems of developing countries are mostly due to lack of de-
velopment rather than excessive development. Clearly, therefore, the raison
d'etre of environment policy in developing countries must be development with
conservation.
The environment is now firmly on the political agenda in both developed and
developing countries and there is a growing realization that procedures, methods,
and techniques to assess the likely environmental, health, and social impacts of
projects, plans, and policies must now be given the same emphasis that economic
assessments have been accorded thus far. It is here that environmental impact
assessment (EIA) must play a crucial role in resolving the conflicts between
developmental objectives and the concern for environmental quality.
*> IQRB M«»..!.r C^i...- H..I.I: I • "
-------
10
ASHOK K. LUHAR AND P. KHANNA
TABLE 1. Identification information used as input
Environmental Component
Information Needed
Air Existing air quality, meteorology, topography, emission rates of
different pollutants, some physical parameters of the project
components, etc.
Water Existing water quality, aquatic ecosystem of receiving body, water
temperature, water flow and chemical composition of effluent,
physical parameters of the receiving body, etc.
Land Present stale of the soil, porosity of the. soil, other physical and
chemical properties of the soil, etc.
Biological Existing state of the biological environment (flora and fauna) of the
area, population and its distribution, etc. '
Socioeconomic Demography, ethnic composition of the area, age distribution of
the people, etc.
Noise . Type of noise sources (vis-a-vis point, line, etc.) and their relative
intensity, etc.
Notwithstanding the fact that EIA is conceived to be a valuable planning and
decision-making tool, in practice it suffers from several limitations, particularly
its major requirements for time, finance, expertise, and data. It is therefore not
surprising that most developing countries have resorted to rudimentary ap-
proaches (eg, checklists) in the absence of objective screening and scoping
criteria, guidelines for rapid EIA, and tools for prediction and evaluation. In
addition, there is the problem of quantifying intangible impacts of the project.
With a view to obviating some of the aforementioned limitations, a rapid and
quantitative methodology for EIA is presented in this paper. The present con-
tribution provides an approach, and therefore no attempt has been made to
incorporate all parameters and rigorous mathematical models available in the
literature. However, it does include the cost of mitigating detrimental environ-
mental impacts.
Definition of EIA
Many definitions of EIA have been provided (Battelle 1978; UNEP 1978; Munn
1979), but none of them may be accepted as complete. The work presented in
this paper is based on the definition given by Heer and Hagerty (1977):
EIA consists in establishing quantitative values for selected parameters which indicate the quality
of the environment before, during and after an action.
Computer-Aided Rapid EIA
The technique presented here is a rapid EIA technique for assessing impacts on
the major envirruraental components: air, water, land, noise, biological, and
socioeconomic.^•most relevant to developing countries.
COMPUTER-AIDED RAPID ENVIRONMENTAL IMPACT ASSESSMENT
The process of EIA can be divided into three parts: identification, prediction
and evaluation of impacts (Canter 1977). The computer algorithm has bee
prepared based on these general steps of EIA.
Identification
The identification part of EIA involves the description of existing environment;)
components, the project, and the project area. The description included in com
puter-aided methodology is presented in Table 1. The identification of significant
impacts in individual cases is project specific and no attempt has been made in
this paper to incorporate these as the objective here is to suggest general purpose
methodology.
Prediction
Prediction is essentially the quantification step. The impacts of project activities
are predicted through mathematical models and other predictors of environment;)!
quality. It should be noted that a model should be calibrated, verified, and
validated before use.
Unfortunately, in developing countries, nonavailability of sufficient data ham
pers the efforts to calibrate, verify, and validate the models. The attempt in this
paper, therefore, is to incorporate models with limited data requirements. Such
an approach is considered rational in the context of rapid assessment.
Evaluation
In the evaluation step, impacts are converted into environmental quality predic-
tors with recourse to value function graphs. Value function graphs have been
prepared for different environmental components based on the aesthetic, envi-
ronmental, and health risks of different pollutants and their standards. The math
ematical forms of value function curves have been formulated through polynomial
regression and incorporated in the computer program. Subindices are converted
into a single index by taking their weighted sum. The weights given to different
environmental risks and costs for various environmental components depend on
the type of project under assessment.
A Computer Package for Rapid EIA
A computer algorithm is depicted in Figure I. The algorithm is designed in
keeping with the nonavailability of complete databases in da^feting countries.
Instead, the program uses simple identification information^^rented in Table
1 as input available from the project area.
-------
12
ASHOK K. LUHAR AND P. glJANNA
COMPUTER-AIDED RAPID ENVIRONMENTAL IMPACT ASSESSMENT
(T)-
(A) IDENTIPICATION
I READ INPUT PARAMETERS fOII PREDICTION OP IMPACTS
ON AIR, HATER. LAUD. BIOLOGICAL AND 8OCIOECONONIC '
ENVIRONMENT
READ INPUT PARAMETERS PON PMDICTION OP NOISI LIVBL '
MAD HA MATRIX (MAXIMUM 8CORI I.I. MBIOHTAOI
OIVIN TO ASOVI INVIRONNINTAL CONPONINTS INCLVDINO '
NOISI POB DiPPIRINT INVIROmiNTAL RISKS)
LRIAO COST MATRIX (MAXIMUM 1.1. MIICHTAOI GiylN TO TH1 A8ATEMENT\
COST NIXING HEIGHT
ON
RECEPTOR HEIGHT> NIX DO mofT
T
(I)
FIGURE 1. General Row Chart of Computer-Aided Rapid Environmental Impact As-
sessment. (A) Identification; (B) Prediction; (C) Cost-Effective Evaluation.
CALCULATE CONCENTRA'
TION POR THIS CASE
IS
SIGMA Z > 1.6
IXING REI
I
CALCULATE CONCENTRAT
ION PON THIS CASE
CALCULATE CONCEN-
TRATION POR STABLE
CASE (UNLINITED
MIXING >
CORRECT THE CONCENTRATION POR
CHEMICAL ATTENUATION
*)
(3)
CALCULATE TOTAL CONCENTRAT-
ION AT A RECEPTOR DUE TO ALL
SOURCES POR DIFTOew POLLUMNIS
CALCULATE CONCENTRATION POR
DIPPERENT AVERAGING TIMES
((B) Continued)
CALCULATE VISIBILITY
(5)
FIGURE I. (Continued)
-------
14
ASHOK K. LUHAR AND P. KHANNA
CALCULATE THE CONCENTRATION OP SUBSTANCES
DUB TO LAND DISPOSAL OP THI HASTE THROUGH
DISPERSION EQUATIONS
CALCULATE THE VALUES OP PREDICTORS OP BIO-
LOOICAL ENVIRONMENT (WHICH NEASURB THE EFFECTS
OP A PROJECT ON PLORA AND PAUNA)
CALCULATE THE INCREASE IN THB NOISE LEVEL
DUB TO THB PROJECT
<(B) Continued)
CALCULATE THB VALUES OP PREDICTORS OP SOCIO-
ECONOMIC ENVIRONMENT (WHICH MEASURE THE
CHANCES IN SOCIAL' AND ECONOMIC STATUS OP THB
PEOPLE LIVING IN THE AREAS NEARBY )
(6)
FIGURE 1. (Continued)
COMPUTER-AIDED RAPID ENVIRONMENTAL IMPACT ASSESSMENT
15
16)
(C)
COST-BPPECTIVl
EVALUATION
FUNCTION TO CALCULATE
QUALITY INDSI FOR ENVI-
RONMENTAL RISKS DUE TO
INCREASE IN WATER TEMP.
SU8ROUTINB TO CALCULATE
QUALITY IMDEI POR HEALTH
RISKS DUI TO LAND POLLUTION
SUBROUTINE TO CALCULATE
QUALITY INDEX POR A8THETIC
RISES DUE TO LAND POLLUTION
SUBROUTINE TO CALCULATE
QUALITY INDEI POR ENVIRON-
MENTAL RISKS DUB TO LAND
POLLUTION
SUBROUTINE TO CALCULATE
QUALITY INDEX POR
SOCIOECONOMIC ENVIRON-
MENT
CONVERT THB PREDICTORS OP
ALL ENVIRONMENTAL COMPON-
ENTS INTO THEIR RESPECTIVE
QUALITY INDICES (REAL
SCORES)
( EXCLUDING COSTS )
SUBROUTINE TO CALCULATE
QUALITY INDEX POR HEALTH
RISKS DUE TO AIR POLLUTION
SUBROUTINE TO CALCULATE
QUALITV INDEI TOR ENVIRON-
MENTAL RISKS DUE TO AIR
POLLUTION
SUBROUTINE TO CALCULATE
QUALITY INDEX POR ASTHETIC
RISKS DUE TO AIR POLLUTION
SUBROUTINE TO CALCULATE
QUALITV INDEX POR BIO-
LOGICAL ENVIRONMENT
(PLORA AND PAUNA)
FUNCTION TO CALCULATE
QUALITY INDEX POR NOISE
CALCULATE THE OVERALL COST
EFFECTIVE INDEX
1 J k
(J • l,« INCLUDING COST)
FIGURE 1. (Continued)
-------
16
ASHOK K. LUHAR AND P. KHANNA
Brief dtsa^Sons of mathematical models incorporated in the program for
prediction of impacts follow:
Air
A short-term Gaussian point source model, which has been incorporated in the
RAM program of the US Environmental Protection Agency (Novak and Turner
1976), has been used for the prediction of air pollution levels. The model uses
P-G dispersion parameters and calculates plume rise using Briggs' equations.
Wind speed is corrected at the stack height using the power law relation given
by Deacon (Wark and Warner 1981). Concentrations are corrected for stack
downwash and chemical attenuation (Dobbins 1979). The latter correction, how-
ever, cannot be applied to all pollutants because of the complex chemistry
associated with them. The concentrations are converted for different averaging
times, as required by value function curves, using the power law relation (Stern
1976). Visibility is reckoned from the concentration of particulates. The pol-
lutants considered in the program are NO2, CO, O3, SO2, TSP, and hydrocarbons.
The model can also be used for long-term predictions by taking the average over
a wind rose. The assessment of impacts on air quality is described in detail by
Clark et aJ. (1984), Jakeman and Simpson (1985), and Shen (1986).
Water
The program incorporates the case of thermal pollution (as in thermal power
projects) with recourse to simple diffusion equations (Parker and Krenkel 1970;
Zaric 1978) for predicting the increase in temperature of a water body (river,
lake, or estuary) at different locations. The program can be generalized (for
other projects) by incorporating prediction models for conservative and noncon-
servative pollutants.
Land
The prediction refers to the horizontal and vertical concentrations of pollutants
consequent to land disposal of waste waters. The model parameters are highly
dependent on soil characteristics.
Biological Environment
Various predictors, described in the literature (Rau and Woolen 1980) have been
used to predict the impacts of a proposed project on a biological environment.
Sample plot or quadrants methods and a roadside count method are used to
CUMPinU AJMJD RAPID ENVIRONMENTAL IMPACT ASSESSMENT
predict the impacts of the project on flora and fauna, respectively. The predictio
refers to the Importance Value and Census Index.
Socioeconomic Environment
Two predictors, the Index of Qualitative Variation and the Dependency Ratio
calculated from demographic data, have been used to predict the impacts of tin.
project on the socioeconomic environment.
TABLE 2. Environmental impact assessment matrix
Environmental
Component (i)
Associated risks
and control costs (j)
Environmental parameters
and predictors (k)
Air
Water
Land
Biological
Socioeconomic
Noise
Health risks
Environmental risks
Aesthetic risks
Cost of control2
Health risks
Environmental risks
Aesthetic risks
Cost of control2
Health risks
Environmental risks
Aesthetic risks
Cost of control2
Environmental risks
Aesthetic Risks
Cost of control2
Environmental risks
Cost of control1
Health risks
Aesthetic risks
Cost of control2
NO2. CO, TSP x SO2, O,
NOj, CO, SO,, TSP,
hyrocarbons
Visibility, odor'
NO2. SO2. TSP
Helminths,1 virus,1 colifonns'
BOD, temperature
Mosquito,1 fly,1 and odor*
nuisances, suspended
solids
BOD, temperature
Pathogens on land1
BOD
Mosquito,1 fly,1 and odor1
nuisances
BOD
Importance value,1
census index1
Importance value,1
census index1
Flora, fauna
Index of qualitative
variation,' dependency
ratio1
Socioeconomic status
Noise level
Noise level
Noise level
'Monitored data required for the program
'Control cost dm required for the program
BOD ~ Biochemical oxygen demand
-------
18
ASHOK K. LUHAR AND P. KHANNA
Noise
Models are available in literature to predict the noise levels from point and line
sources (Rau and Wooten 1980; Magrab 1975). Inputs for the models are receptor
location, sound intensity, or sound power (for a point source), number of vehicles
and their speeds (for a line source), etc.
The tabular form of the EIA matrix, used in the program, is shown in Table
2. Out of some number (preferably 1000), weight is assigned to each element
of the matrix based on its relative significance. A subindex is calculated for each
of the matrix elements using value function graphs incorporated in the program
in mathematical forms. A subindex value of 1 is considered best while a value
of 0 is considered worst. Value function graphs for aesthetic, environmental,
and health risks for the air environment are included in Figures 2 through 12.
Average time for Figures 6, 7, 9, and 11 is 24 hours; for Figures 4, 5, 8, 10,
and 12 the average times are annual, one hour, three hours, eight hours, and
LOO
x 0.75
O.5O
0-23
100
SO
60
40
w
20-
x
•
X
*o>
8 t
6 Z
tn
A >
FIGURE
I
100 200 400 600
PARTICULATE CONCENTRATION «/»fl/«3)-»-
ie Function Curve for Visibility (Aesthetic Risk)
COMPUTER-AIDED RAPID ENVIRONMENTAL IMPACT ASSESSMENT
0*9
0*4
x
w
o
Z 0-3
3 0.2
o
HICAVY FREQUENT J
POLLUTION *j*
MODERATE
OCCASIONAL •+»
POLLUTION I
CLEAR
H
FIGURE 3. Value Function Curve for Odor (Aesthetic Risk)
two hours, respectively. An overall index is calculated by taking the weighted
sum of subindices for all the project options including the no-project option.
Overall index i _ v» v v v c
of a project option ' ~ f f f X«k F«"
i = number of environmental components (max. i = 6)
j = number of environmental risks (+ one cost element) for /th
component (max. j = 4)
k = number of pollutants or predictors for ith component and /th
risks (max. k = 5)
X = quality subindex of a particular element, i, j, and k
F = maximum score or weight given to a particular^^gent, i,
j, and k
-------
OOS OJO 0'IS 0*20
NITROOENOIOXIOC CONCENTRATI 01* (•|/U—*•
FIGURE 4. Value Function Curve for NO] (Environmental Risk)
1-0
0-0
2 0-6
a
0-4
0-2
10 20 30 40 50
CARBON MONOXIDE CONCENTRATION (mg/!»-»•
FIGURE 5. Value Function Curve for CO (Environmental Risk)
0-8
g 0-6
t
hi
O
s
•
9
n
t 0-4
j
O-2
0 0-4 0-8 1-2 1-6 2-0 2-4
SULPHUR 010X101 CONCENTRATION ««t/l)—••-
FIGURE 6. Value Function Curve for SO2 (Environmental Risk)
2-8
1-0
0-8
* 0-6
o >
X
>•
t
3
0-4
0-2
0 IOO 200 300 400
PARTICULATES CONCENTRATION
FIGURE 7. Value Function Curve for Particulates (Environmental Ri
-------
0 04 0-2 0-3 0-4
HYDROCARBONS CONCENTRATION <«••/!)
FIGURE 8. Value Function Curve for Hydrocarbons (Environmental Risk)
0
FIGURE 9.
NITROOENOIOXIOE CONCENTRATION
Curve for NOi (Health Risk)
IO 102 10s
CARBON MONOXIDE CONCENTRATION (»«/l)
FIGURE 10 Value Function Curve for CO (Health Risk)
1-0
0-8
f ""
x
w
o
O-6
t 0-4
3
or
0-2
0 I
rOOO 2000 3OOO 4OOO 900O 6OOO
T8PX8O, CONCENTRATIONS (^
FIGURE 11. Value Function Curve for TSP x SO, (Health Risk)
-------
24
ASHOK K. LUHAR AND P. KHANNA
1-0
to.
X
w
o
0-6
50-4
9
O
0-2
K>
10* K)8
OZONE CONceNTMATION (/i«/m'l
10'
FIGURE 12. Value Function Curve for O3 (Health Risk)
The option that provides highest Value of I is considered as the best option
followed by other project options according to their decreasing indices.
Conclusions
The scope of EIA in most developing countries is restricted to the questionnaire
type checklists defeating the purpose of the exercise as a decision-making tool.
This presentation is a limited step in the development of computer-aided quan-
titative EIA. The paper essentially presents a framework for rapid EIA and covers
six environmental components (air, water, land, noise, biological, and socio-
economic environments) and the costs of mitigation measures.
The work presented here forms a part of a project sponsored by the Ministry of Environment and
Forests, Government of India.
REFERENCES
Battelle Institute. 1978. The Selection of Projects for EIA. Brussels. Commission of the
European Communities Environment and Consumer Protection Service.
COMPUTER-AIDED RAPID ENVIRONMENTAL IMPACT ASSESSMENT
Canter, L. W. 1977. Environmental Impact Assessment. New York: McGraw-Hill.
Clark, A. I., Mclntre. A. E.. Lester. J. N., and Perry, R. 1984. Air quality impa.
assessment. Environ. Monit. and Assess. 4:205-232.
Dobbins, R. A. 1979. Atmospheric Motion and Air Pollution. New York: Wiley-Info
science.
Hecr, J. E., and Hagerty, D. J. 1977. Environmental Assessments and Statements. Ne\
York: Van Nostrand Reinhold.
Jakeman, A. J., and Simpson, R. W. 1985. Assessment of air quality impacts from ai
elevated point source. J. Environmental Management 20(l):63-72.
Magrab, E. B. 1975. Environmental Noise Control. New York: Wiley.
Munn, R. E. (ed). 1979. Environmental Impact Assessment: Principles and Procedures
Toronto: International Council of Scientific Unions, Scientific Committee on Problem?
of the Environment.
Novak, J. H., and Turner, B. 1976. An efficient Gaussian plume multiple source aii
quality algorithm. J. AirPollut. Control Assoc. 26(6):570-575.
Parker, F. L., and Krenkel, P. A. 1970. Physical and Engineering Aspects of Thermal
Pollution. London: Butterworths.
Rau, J. G.. and Woolen, D. C. (eds). 1980. Environmental Impact Analysis Handbook
New York: McGraw-Hill.
Shen, T. T. 1986. Assessment of air pollution impact. Atmospheric Environment
20(10):2039-2045.
Stem, A. C. 1976. Air Pollution. Vol. 1. New York: Academic Press.
UNEP. 1978. Draft Guidelines for Assessing Industrial Environmental Impact and En-
vironmental Criteria for the Siting of Industry. Paris: UNEP Industry and Environmental
Office.
Wark, K., and Warner, C. P. 1981. Air Pollution, Its Origin and Control. New York:
Harper and Row.
Zaric, Z. P. (ed). 1978. Thermal Effluent Disposal from Power Generation. Washington.
DC: Hemisphere.
-------
4.2
Impact Identification
Many choices have to be made in the EA process, among which are the
choice of impacts that should be assessed (Chapters 2 and 3) and the level of
analysis that is required. An impact is described as a change in an environmental
or socioeconomic parameter, resulting from a proposed action compared to the
situation had the proposed action not been initiated (Wathern 1988). Because
there are so many possible impacts of a proposed activity, limits and constraints
must be determined early in the planning process and endpoints must be
established. For example, issues that are identified during scoping are often too
broad for analytical purposes (e.g., ecosystem health). They must be focused on
expected impacts to valued ecosystem components (e.g., Hudson River striped
bass population) and then decisions made on an assessment endpoint (e.g.,
abundance or yield). The nature of the impacts must also be determined (e.g.,
direct/indirect, short/long term, reversible/irreversible). Estimates of the
magnitude, likelihood, and temporal and spatial distribution of potential impacts
from the proposed activity must be provided to the EA team by the proponent.
Five main classes of impact-identification techniques exist: ad hoc methods (e.g.,
brainstorming, expert panels, field reconnaissance), checklists, matrices,
networks, and map overlays (Westman 1985).
NEEDS
An interdisciplinary approach is critical to the impact identification stage(s)
of the EA process. During project initiation all of the technical and scientific
experts, including the proponent, must gather to identify and clarify the potential
impacts of the proposed action on valued resources. Discussions should include
the how, where, and when of directly, indirectly, and cumulatively affected
resources. During and following scoping, the team can expect additional impacts
to be identified. Effective assessment depends on team members understanding
how the proposed action and the affected resources are interrelated and the role
that each discipline has in the integrated analysis.
TOOLS
• Early intra-and interagency consultation and public scoping provide
opportunities for identifying potential impacts and determining the
extent of subsequent analyses. In particular, federal, tribal,
4-15
-------
regional, and local regulatory agencies should be contacted to
determine if the proposed action violates any ordinances, laws,
plans or policies.
There are generally 18 categories for consideration in EA many of
which have some regulatory constraints:
Geology Land Use
' Topography Demography
Soils Noise
Ground Water Resources Socioeconomics
Surface Water Resources Infrastructural
Terrestrial Ecology Services
Aquatic Ecology Transportation
Environmentally Sensitive Cultural Resources
and Species Economics
Air Quality Human Health and
Safety
Existing environmental analyses should always be used to the
extent possible in identifying and analyzing impacts. This
approach builds on work that has already been done and that has
passed public and agency scrutiny. It helps to ensure that
appropriate impacts are identified and allows the EA team to
concentrate on issues that are unique to the proposed action.
Existing analyses can include resource management plans, activity
plans, EIAs for similar or related actions including programmatic
EIA documents. The pertinent information can be summarized for
use and the documents referenced in order to keep the content of
the EA document focused on significant impacts.
Ad hoc procedures involve assembling panels of specialists to
identify impacts in their areas of expertise (Canter 1977). Such
panels were used in the early days of EA but have been mostly
replaced by scoping, interagency consultation, the growth of
experienced multidisciplinary EA teams and, if appropriate, the
formal expert judgment process (Chapter 4.3). Ad hoc panels
have value in early planning for assembling information,
comparing alternative sites and developing strategies (Lohani and
Halim 1987). The resulting information is usually qualitative and
readily understood (e.g., identification of general areas and types
of impacts) rather than technical, quantitative, and suitable for
predictive analyses.
4-16
-------
Held reconnaissance is essentially qualitative in contrast to
baseline studies that gather data to resolve specific problems (e.g.,
sampling of plant or animal populations to determine variability).
A site reconnaissance is conducted to complement and confirm
background information from the literature and from human
sources on the environmental and socioeconomic setting for a
proposed action (McBrayer et al. 1981). It is normally one of the
first activities of the EA team and its value for understanding
problems associated with the proposed action is inestimable. Site
visits must be planned around clearly defined objectives. If
multiple sites are involved, it is essential to gather information that
is comparable from site to site. Of particular importance is the
understanding of what information is needed and to what
problem(s) it will be applied; otherwise, the needs of the
decisionmaker will not be met. The results of scoping and the
completion of a preliminary checklist or matrix can help focus the
reconnaissance activities of the EA team. The Fish and Wildlife
Service Manual (States et al., 1978) is useful for outlining and
describing the elements of reconnaissance and baseline studies.
The checklist was one of the first EA methods to be applied and
it is still in general use, although in many different forms, both
generic and project specific. The main advantage of a checklist is
that it promotes thinking about the array of impacts in a systematic
way and allows summarization of effects (Westman 1985).
Furthermore, the use of a checklist early in the planning process
can aid in determining whether the impacts of a proposed action
warrant the preparation of an EIA. The simplest of checklists is
a one-dimensional list of environmental factors to be considered.
Various agencies have prepared such checklists for particular types
of projects (Attachment 2.B, Chapter 4.1).
There are disadvantages to the use of checklists: they may be too
general or incomplete; interactions between effects are not
identified; the same effect may be listed in more than one place
under headings that overlap which results in "double counting";
and the large number of categories to be reviewed can distract
attention from the most significant impacts. The identification of
effects is qualitative and subjective thus the predictions cannot be
tested empirically with precision and the content of a checklist can
vary depending on the investigator (Westman 1985). Furthermore,
no statements of likelihood of occurrence are made.
4-17
-------
Matrices are very likely the most popular and widely used impact
identification methodology. One common application is in the
comparison of alternative actions. Alternative actions (measures,
projects, sites, designs) are listed as column headings, while the
rows are the criteria that should determine the choice of
alternative. In each cell of the matrix, a conclusion can be listed
indicating whether the alternative action is likely to have a positive
or negative effect on the indicated criterion. Very often, the
conclusion is stated as a numerical value or symbol indicating the
level of intensity of the effect. There is an opportunity, moreover,
to apply relative weighting to the various criteria when evaluating
the completed matrix (Chapter 4.3, Figure 4.3-1, Attachment
4.D).
The evolution of an impact identification methodology from
checklist to matrix is intuitively and easily accomplished. A
checklist can be viewed as a single-column summary of a proposed
action, with only a coarse characterization of the nature of
potential environmental impacts. An environmental impacts
assessment matrix provides a finer degree of impact identification
by associating a set of columns (effects) with each row
(environmental attribute) of the matrix (Leopold et al. 1971). As
a first step, the columns that correspond with the nature of the
proposed action are checked off. Then, for each column that is
marked, the cells corresponding to environmental effects are
examined. The interpretation of the matrix is based on the
professional judgment of the individual(s) performing the EA.
Within the Leopold matrix (Chapter 4.1), only a few of the
interactions would be likely to involve impacts of such magnitude
and importance that they deserve comprehensive treatment.
Although the items listed represent most of the basic actions and
environmental factors likely to be involved in a proposed action,
not all would apply to every project. Even such a large matrix
may not contain all elements necessary to make a full analysis of
every project encountered. However, the coding and format are
designed for easy contraction or expansion to include additional
items. Preliminary trials suggest that the number of applicable
interactions for a typical project usually will be between 25 and
SO. An impact matrix (Chapter 4.3) is an expanded checklist that
includes estimates of the relative magnitude (i.e., significance) of
the environmental impacts (Figure 4.3-1).
4-18
-------
Several variants of the Leopold matrix have been prepared; some
of them have been adapted for computerized analysis (Schlesinger
and Daetz, 1973). These variants may integrate the scores in
groups of cells to provide a quantitative and/or graphical summary
of the matrix scoring.
With the characterization of a particular action expanded to two
dimensions, comparison of several alternatives requires the
addition of a third dimension. This is readily accomplished both
conceptually and practically. The Leopold matrix analysis can be
performed on several alterative scenarios, yielding graphical
summaries that can be visually or mathematically compared. The
three-dimensional spreadsheet software programs now available
also lend themselves to the comparison of environmental impact
assessment matrices in three-dimensional format.
Networks, also known as systems diagrams, consist of a number
of linked impacts, known to result from initial actions (Figure
4.2-1); even mitigation and control measures can be illustrated.
If a magnitude and importance score is assigned to each impact
and the probability of occurrence of each impact is known, a final
index value can be calculated for the network (Westman 1985).
The advantage of a network approach is that it shows indirect
impacts and the effects of change can be followed through the
intermediaries. However, there are several problems associated
with networks among which are the postulation of indirect effects
that do not occur, obtaining reliable data on probabilities of
occurrence of effects, and as with all grand index approaches, the
final index value may obscure important uncertainties in the effects
data (Elliot 1981).
Overlay mapping is useful in displaying areas of environmental
sensitivity, the sum of natural succession, and the development and
associated landscape impacts due to multiple projects (McHarg
1969). Time series of maps from aerial photographs can be used
to view, cumulative impacts over space and time. A base map is
prepared showing the location of the project and the boundaries of
the area to be considered in the impact assessment. Additional
transparent maps at the same scale are prepared for the critical
environmental features of concern identified during initiation and
scoping (e.g., wetlands, cultural resources, wildlife habitat,
vegetative communities, protected areas). The maps are then
overlaid to highlight potential impacts.
4-19
-------
Aerial application
of herbicides
I
Water herbicide
contamination
Decreased growth
of algae, phyto-
plankton, etc.
Food chain
contamination
in water
1
Loss of
riparian
vegetation
Decreased
dissolved
oxygen
L
Increased
water
temperature
Increased
water
runoff
Food chain
contamination
on land
Figure 4.2-1. Example of a network to identify the potential
impacts of herbicide application [Source: Thoretal. (1978)]
4-20
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Geographical Information Systems (GISs) are essentially
computerized graphical overlay systems (Attachment 4.E).
Environmental features are mapped, and the mapping digitized and
stored in a CIS data base. The mapped features can be combined
to produce computer-generated displays of one or more
environmental features in a specified geographical area. If CIS
mapping is conducted systematically, information acquired on
specific projects can be combined, and the CIS data base becomes
more detailed over time. Overlay mapping is an excellent tool for
showing spatial dimensions of impacts, but is less successful in
dealing with other impact characteristics such as probability, time,
and reversibility.
The field of environmental modeling to identify and evaluate
environmental impacts has developed very rapidly due essentially
to two factors (Jdrgensen 1991; Chapter 4.3):
The development of computer technology, which has made
possible the handling of complex mathematical systems.
A better understanding of pollution problems, including the
application of ecology in this context.
Modeling is the most advanced EA method available but it depends
on experts to know which components and processes should be
included; it can be costly; and it is only as good as the available
data and the assumptions that bound the analysis. The general
components of modeling and types of models are discussed by
Jtfrgensen (1991). Bregman and Mackenthun (1992) provide
information on computer models for surface water quality and air
quality. Attachment 4.C describes models that are useful for
predicting the fate of chemicals in multimedia systems (i. e.,
fugacity models) as well as remediation, aquatic, soil, food chain,
atmospheric, and spill models.
Luhar and Khanna (1988; Attachment 4.B) present a framework
for computer-aided rapid EA that covers six environmental
components (air, water, land, noise, biological, and socio-
economics) and the costs of mitigation measures. The authors
recognize that data availability in developing countries often is
limited; thus, their models have minimal data requirements. Some
computer-aided impact identification and data summarization
systems are discussed by Strand et al. (1983), Riggins (1980-81),
and Lein (1993).
4-21
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ISSUES
• As described above, an impact is a change in an environmental or
socioeconomic parameter. Westman (1985) limits the term impact
to the effect of a human-induced action on an ecosystem.
Decisionmakers and the publics are normally most concerned with
major impacts (i.e., those that would occur and for which no
mitigative measures are proposed or possible to decrease the level
of impact), violations of standards or controversial issues (e.g.,
those resulting from disagreements among experts and occasionally
from public concerns). It is important to remember that only those
valued resources identified as having the potential of being
significantly impacted need be analyzed in detail (Bureau of Land
Management 1992). However, decisions made not to evaluate
resources in detail must be supported by adequate information.
• Selecting appropriate geographical and temporal boundaries for
impacts requires learning about the types and rates of release,
movement, and transformation of materials and energy (Irwin and
Rodes 1992). It means understanding ecological processes, such
as bioaccumulation, that control these rates. It also means
understanding the ranges of plants and animals and the life span of
valued resources.
Early in the planning process, it is important to establish
geographic boundaries of potential impact(s) for proposed actions
to avoid unnecessary data collection and analysis. In most cases,
it is necessary to go beyond the immediate project site, especially
for determination of cumulative impacts. The geographic area of
analysis is likely to vary depending on the specific resource of
interest. There may be physical boundaries such as watersheds,
biological boundaries such as habitats, socioeconomic boundaries
such as market areas or regions or political boundaries such as
counties (Bureau of Land Management 1992; Irwin and Rodes
1992). A rule of thumb is to consider effects as far away as
necessary for those resources identified as important during
scoping. Usually the area of assessment is established as the area
beyond which the influence of the project is negligible or
decreasing. At a minimum, this area should be as large as the
"service area" of the proposed project. At this locus of points
(i.e., along the boundary line of the assessment area/volume), it
should be possible to demonstrate that the impacts are clearly not
significant (Bureau of Land Management 1992).
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In addition to identifying the geographic area of potential impacts
and valued resources, the life of the project(s) must be identified
and related to the life span of the potentially affected resource.
Impacts can be single, repeated, or multiple. They can occur
rapidly over a matter of days or slowly over decades building to
cause cumulative impacts. The past is analyzed to see if trends
have been established; the future is assessed to see what effect the
proposed action(s) might have on valued resources identified
during initiation and scoping. The barriers to selecting spatial and
temporal boundaries are usually both institutional [e.g., legal
constraints (regulations) and a lack of means to set goals,
determine roles, and resolve disputes among different agencies and
levels of government] and technical (e.g., lack of integrated data
and acceptable models, limited understanding of environmental
processes, uncertainty) (Cada and Hunsaker 1990).
Traditional impact assessment usually examines the consequences
of a single source of environmental disturbance (i.e., a discrete
event or project) on valued resources and neglects or gives short
shrift to die problem of potential cumulative impacts.
Assessment of cumulative impact examines the consequences of
multiple sources of environmental disturbance that impinge on the
same valued environmental components. The characteristic
"multiple" nature of cumulative impacts may arise in three ways:
the same kind of source recurs sufficiently frequently
through time;
the same kind of source recurs sufficiently densely through
space; and
different kinds of sources impose similar consequences on
a valued resource.
Identifying and evaluating potential cumulative impacts is difficult
for at least four reasons (Irwin and Rodes 1992):
the intricacies of environmental systems have only begun
to be understood;
there are seldom adequate data for environmental changes
or their causes, particularly at appropriate time frames and
spatial distributions;
predictions of what will happen are inherently uncertain;
and
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legal mandates and organizational interests frequently do
not match the boundaries of environmental problems.
Dealing with the problems requires learning to address multiple
actions or sources and additive or interactive effects at appropriate
time and space boundaries (Irwin and Rodes 1992).
EPA (1992a) provides a proposed methodology to assist wetland
regulators in assessing the cumulative effect of individual wetland
impacts within a landscape. It is designed for situations in which
time, resources, and information are limited. The approach does
not provide a precise quantitative assessment of the cumulative
effects within a particular area. Rather, it provides a mechanism
to compare cumulative impacts between areas.
• Any environmental assessment must have defined endpoints (Suter
1989,1990; U.S. Environmental Protection Agency 1992b; Cairns
and Niederlehner 1993). Information compiled during initiation
and scoping is used to help select endpoints that are relevant to
decisions made about protecting the environment. Environmental
assessment practitioners often distinguish between assessment
endpoints and measurement endpoints. Often the assessment
endpoint cannot be measured directly, so a measurement
endpoint(s) is selected that can be related, either quantitatively or
qualitatively, to the assessment endpoint (U.S. Environmental
Protection Agency 1992b). An assessment endpoint is an explicit
expression of an environmental value that is to be protected (e.g.,
a sport fish population). A measurement endpoint is a quantitative
summary of a monitoring study, a toxicity test or other activity
that reveals the effects of a proposed action on the valued
assessment endpoint. For example, a decline in a sport fish
population (the assessment endpoint) may be evaluated by using
laboratory studies on the mortality of surrogate species, such as the
fathead minnow (the measurement endpoint).
Sound professional judgment is necessary for proper assessment
and measurement endpoint selection, and it is important that both
the selection rationale and the linkages between measurement
endpoints, assessment endpoints, and policy goals be clearly stated.
In order for the results of an assessment to be meaningful for the
decisionmaker, endpoints should have the following characteristics:
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societal relevance (i.e., understood and valued by the
public and by the decisionmaker),
unambiguous (e.g., effects on the abundance of the Hudson
River striped bass population in contrast to "ecosystem
health"),
biological relevance (e.g., effects on populations or
ecosystems rather than individuals),
assessable to prediction or measurement (i.e., if the
response of an endpoint cannot be measured or estimated
from measurements of similar or related responses, it can
not be assessed), and
susceptibility (i.e., the endpoint must have the potential for
exposure and be responsive to the hazard).
Identification of impacts is only the first step of the assessment
phase. The predicted impacts must also be interpreted for the
decisionmaker and the public in terms of their influence on the
human environment. For each of the alternatives and the proposed
action, the EIA should address whether the predicted impacts are:
beneficial or adverse,
direct or indirect (triggered at a future time, or different
place),
short-term or long-term (and thus potentially cumulative),
and
irreversible (and thus detrimental to sustainability).
Ecological risk assessment procedures can provide insight to the
likelihood that an adverse impact will occur and the magnitude of
the consequences (EPA 1992b).
Regulatory agencies should be consulted before embarking on
modeling exercises because they frequently have specific models
that are required or recommended for use in environmental impact
analysis. The results of other models may not be acceptable unless
the models have undergone rigorous validation processes.
Although developing countries may not have adequate data and
human and financial resources for elaborate EA, the use of rapid
identification procedures (e.g., checklists and matrices) requires
little collection of technical/ecological data, but rather a general
familiarity with the region and with the nature of the proposed
action (Biswas and Geping 1987). Lohani and Halim (1987)
describe the application of a checklist and different types of
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matrices to a proposed pulp mill project in Thailand (Part C). They conclude that
checklists and matrices result in rapid identification of likely impacts and that
their use depends on the expert judgment and coordination and participation of all
concerned, the proponent, the EA team, the public, and the government agencies
responsible for various resources (e.g., fisheries, forests, agriculture).
LINKAGES
Identification of potential impacts of a proposed action is a process that
begins informally with the proponent during initiation and gains momentum
during early intra-and interagency consultations and the public scoping process.
Impact identification culminates during the assessment phase when the EA team
describes the impacts of the proposed action and alternatives, quantifies the extent
of the predicted impacts, identifies measures to mitigate the unavoidable
environmental impacts, and prepares an EA report for the decisionmaker and the
public.
REFERENCES
Biswas, A. K., and Q. Geping. 1987. Environmental Impact Assessment for
Developing Countries. Tycooly International. 232 pp.
Bregman, J. I., and K. M. Mackenthun. 1992. Environmental Impact
Statements. Lewis Publishers, Boca Raton. 279 pp.
Bureau of Land Management. 1992. Draft Guidelines for Assessing and
Documenting Cumulative Impacts.
Cada, C. F., and C. T. Hunsaker. 1990. Cumulative impacts of hydropower
development: Reaching a watershed in impact assessment. The
Environmental Professional 12:2-8.
Cairns, J. Jr., and B. R. Niederlehner. 1993. Ecological function and
resilience: neglected criteria for environmental impact assessment and
ecological risk analysis. The Environmental Professional 15:116-124.
Elliot, M. L. 1981. Pulling the pieces together: amalgamation in environmental
impact assessment. Environmental Impact Assessment Review 2:11-38.
Irwin, F., and B. Rodes. 1992. Making Decisions on Cumulative
Environmental Impacts: A Conceptual Framework, World Wildlife
Fund, Washington, D.C. 54 pp.
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Jdrgensen, S. E. 1991. Environmental management modelling. In:
Introduction to Environmental Management (eds. P. E. Hansen and S. E.
Jdrgensen). Elsevier, New York. 403 pp.
Lein, J. K. 1993. Formalizing expert judgment in the environmental impact
assessment process. The Environmental Professional 15:95-102.
Leopold, L. B., E. Clarke, B. B. Hanshaw, and J. B. Balsley. 1971. A
Procedure for Evaluating Environmental Impact. U.S. Geological Survey
Circular 645, U.S. Geological Survey, Washington, D.C.
Lohani, B. N., and N. Halim. 1987. Recommended methodologies for rapid
environmental impact assessment in developing countries: Experiences
derived from case studies in Thailand. In: Environmental Impact
Assessment for Developing Countries (eds., A. K. Biswas and Q.
Geping). Tycooly International, London.
Luhar, A. K., and P. Khanna. 1988. Computer-aided rapid environmental
impact assessment. Environmental Impact Assessment Review 8:9-25.
McBrayer, I. F., S. B. Gough, R. C. Robertson, and H. E. Zittel. 1981.
Identifying alternatives at a reconnaissance level. EIA Review 2:190-195.
McHarg, I. 1969. Design with Nature. Natural History, New York.
Riggins, R. E. 1980-81. Comprehensive computer-aided environmental impact
analysis. Journal of Environmental Systems 10:81-91.
Schlesinger, B., and D. Daetz. 1973. A conceptual framework for applying
environmental assessment matrix techniques. Journal of Environmental
Science 16: 11-16.
States, J. B., P. T. Haug, T. G. Shoemaker, L. W. Reed, and E. B. Reed.
1978. A Systems Approach to Ecological Baseline Studies. U.S.
Department of Interior, Fish and Wildlife Service, FWS/OBS-78/21.
Strand, R. H., M. P. Farrell, J. C. Goyert, and K. L. Daniels. 1983.
Environmental assessments through research data management. Journal
of Environmental Management 16:269-280.
Suter, G. W. U. 1990. Endpoints for regional ecological risk assessments.
Environmental Management 14:9-23.
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Suter, G. W. n. 1989. Ecological endpoints. In: Ecological Assessment of
Hazardous Waste Sites: A Field and Laboratory Reference Document
(eds. W. Warren-Hicks, B. R. Parkhurst, and S. S. Baker, Jr). EPA
600/3-89/013. Corvallis Environmental Research Laboratory, Oregon.
Thor, E. C., G. H. Eisner, M. R. Travis, and K. M. O'Loughlin. 1978. Forest
environmental impact analysis - a new approach. Journal of Forestry
76:723-725.
U.S. Environmental Protection Agency (EPA). 1992a. A Synoptic Approach to
Cumulative Impact Assessment, A Proposed Methodology. EPA/600/R-
92/167. Office of Research and Development, Washington, DC 20460.
U.S. Environmental Protection Agency (EPA). 1992b. Framework for
Ecological Risk Assessment. EPA/630/R-92/001.
Wathern, P. 1988. An introductory guide to EIA. In: Environmental Impact
Assessment: Theory and Practice (ed. P. Wathern). Unwin Hyman,
Boston, 332 pp.
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4.3
Impact Analysis and Prediction
Methods for impact analysis and prediction range from relatively simple
matrices to sophisticated computer models (Westman 1985, ERL 1984). Choice
of the various methods is determined by the EA team based on the nature of the
proposed action and the needs of the decisionmaker. Often, many of the impacts
of a proposed action are trivial and a decision depends upon a small subset of
issues of importance. The nature of the analysis must reflect these needs.
In developing a general approach to analyzing environmental impacts,
there are several fundamental questions that must be asked early in the planning
process. They include:
• What effects must be predicted (i.e., what are the assessment
endpoints?)
• What are the most relevant methods for analysis and prediction of
environmental impacts?
• What ad hoc standards or generally-accepted criteria can be used
to distinguish significant levels of environmental impacts from all
possible levels of impacts?
• Are mathematical or statistical methods available for objectively
estimating levels of impacts, or will subjective scoring be used at
one or more stages of the assessment?
• Are there documented studies of the effects of prior similar
actions?
• How can the analysis provide the information needed by the
decisionmaker?
• Is the necessary time, money, and expertise available?
The term analysis refers to formal methods for predicting/estimating
effects of proposed activities. Broadly, these methods can be grouped as
professional judgment (e.g., Delphi technique, impact matrices, expert systems;
however, it should be noted that professional judgment is applied throughout the
EA process); comparison to similar projects (analog studies); field and laboratory
experiments (microcosms and mesocosms); and predictive modeling. Risk
assessment is part of EA (Andrews 1988) and typically involves several or more
quantitative techniques to estimate the likelihood (or probability) and severity of
harm to human health and the environment resulting from exposure to a risk
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agent (e.g., a chemical substance, biological organism, radioactive material, or
other potentially hazardous substance or activity). Risk assessment usually
depends on the following distinct but related parts: source/release data, exposure
assessment, dose-response data, and risk characterization (i.e., integration of the
previous steps into a risk statement that includes one or more quantitative
estimates of risk). The use of risk assessment in EA depends on the nature of the
proposed activity, the issues, and the needs of the decisionmaker.
In a study of 140 EIAs (ERL 1984) to determine the use of formal,
predefined and repeatable methods of prediction, it was found that mathematical,
physical or experimental methods were used in 25 percent of the studies; in a
further 15 percent, simple methods such as inventories of receptors affected (e.g.,
numbers of people or properties, areas of habitat) were used to describe effects.
In the remaining documents, other approaches not involving formal methods were
used (e.g., expert judgment, analogous studies, comparisons with standards).
Informal and formal approaches to prediction were often used together in order
to qualify and interpret results.
In another study (described in Wathern 1988), staff from four U.S. federal
agencies were given a list of methods and asked to indicate their use within the
agency. The results show that the traditional techniques (e.g. overlay mapping,
habitat evaluation, and the Leopold matrix) are used more often than modeling.
However, three of the agencies polled are responsible for land management
activities (i.e., Bureau of Land Management, Forest Service, and Soil
Conservation Service). Thus, an emphasis on habitat evaluation procedures is to
be expected. However, the agencies also indicated that they often rely on their
own approaches rather than existing techniques.
NEEDS
Impact analysis commonly requires 1) data about the proposed action
(e.g., the construction phase and subsequent operational characteristics) and the
environmental setting (i.e., baseline conditions) and 2) methods for estimating
effects of:
contaminant releases,
physical destruction or modification of habitat,
harvesting (either deliberate or incidental as in entrainment
of larval fish), and
socioeconomic disruption.
Canter (1977) describes traditional EA methods while Jdrgensen (1988) and Suter
(1993) provide more recent developments in the area of statistical and
mathematical models. With the advent of computers, sophisticated multi-
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compartment models (Attachment 4.C) have been developed but their use in
everyday EA is limited. Most EA depends on simple single-media air and water
dispersion models for estimates of pollutant concentration coupled to standards or
toxicity data to estimate effects on species of interest (Bregman and Mackenthun
1992). It is important, if at all possible, to use accepted methods and models and
to document their use carefully.
Jdrgensen (1991) describes three important steps in establishing the
credibility of computer models: calibration, verification, and validation. These
steps are generally useful for other quantification methods as well.
Calibration is an attempt to reconcile computed and
observed data by systematically varying selected
parameters. Calibration can be carried out by trial-and-
error methods or by use of software to find the parameter
values that give the best fit between observed and computed
data.
Verification is a test of the internal logic of a model. It
answers the question, does the model react as expected? It
is a subjective assessment of the behavior of a model.
Validation, in contrast to verification, is an objective test
of how well the model output fits the data. In this step, the
modeler tests the model against a data set which is
independent of all data previously used.
TOOLS
• Professional Judgment. Environmental assessments are based on
scientific data that are frequently difficult and complex, conflicting
or ambiguous, or incomplete. Analyses of such data depend on
professional judgment based on scientific expertise. Professional
judgment is necessary to:
design and conceptualize an environmental assessment;
evaluate and select methods and models;
determine the relevance of available data to the assessment;
develop assumptions based on logic and scientific principles
to fill data gaps;, and
interpret the ecological significance of predicted or
observed effects.
Because professional judgment is so important, specialized
knowledge and experience in the various phases of environmental
assessment are required. Thus, an interactive multidisciplinary
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team that includes experienced biologists, ecologists and other
appropriate experts (e.g., socioeconomists) is a prerequisite for a
successful assessment. Other agencies that have special expertise
with respect to environmental issues can also be asked to provide
data for impact analysis and to participate in document preparation
and review. Independent experts can be asked to conduct
'brainstorming sessions" to generate impact scenarios and to
participate in panels to estimate the likelihood of impacts and to
address uncertainty surrounding predictions of magnitude (Lein
1993).
If the EA team determines that objective analysis and
quantification are impossible, expert opinion can be used to derive
numerical estimates. One approach known as the Delphi technique
(i.e., conceptual polling) solicits estimates from independent
experts that are averaged with those of other experts and the
median and range of the estimates are resubmitted to the group for
a second round of comment. This process of iterative refinement
continues until a group consensus is reached on the issue being
investigated. However, it must be made clear to the public and the
decisionmaker that such predictions or estimates are based on
expert opinion that reflects the current range of opinion of the
scientific community and are not a guarantee of correctness.
Using formal professional judgment is expensive and time
consuming and, therefore, should be considered only for major,
potentially costly issues after available quantitative methods have
failed to provide resolution.
One example of an EA methodology developed using the Delphi
technique is the National Sanitation Foundation Water Quality
Index (NSF-WQI) developed in the United States. The goal here
was to derive a system for indexing key water quality variables
and integrating the small group of variables into an indexing
system. In this way, water quality data could be used in a
standardized system of rating that had utility for comparisons in
space and time.
Expert Systems. Recently, expert systems have been developed
as a tool that incorporates expert judgment, experience, and the
EA process (Lein 1989, 1993). A computer program is encoded
with and applies knowledge of a specific area of expertise toward
the solution of problems within a subject area. It takes the general
form of IF (condition) — THEN (conclusion)' statements. Expert
systems can be useful in screening a project for identification of
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factors that might contribute to a significant primary impact
(analogous to an intelligent questionnaire) and as attribute
interpreters (i.e., relating project characteristics to environmental
knowledge). Their use is limited for impact analysis and
quantification.
• Analog Studies. One of the best approaches to impact analysis is
reviewing the effects on the environment of similar activities and
existing disturbances or pollution sources. EA documents should
be reviewed for assessment methods and predicted impacts.
Observational field studies of existing sites can then serve as
models for similar sites exposed to similar contaminants or
disturbances. Such comparisons have been termed "analog
studies" by the National Research Council (1986). For example,
in the assessment of whether a proposed reservoir would become
eutrophic, the most credible evidence was the fact that a similar,
nearby reservoir was eutrophic (Goodman 1976).
Observational field studies provide a realism that laboratory studies
or modeling lack. However, there is always uncertainty associated
with the observed effects of contaminants or disturbances due to
variation in the natural environment of the presumed "similar"
sites. Confidence in causal relationships can be improved by
carefully selecting comparable reference sites or by evaluating
changes along a gradient where differences in other environmental
factors are minimized. It is important to consider potential site
specific factors during the analysis. Westman (1985) provides
references to methods used for predicting pollutant dispersion in
water and air (e.g., dye tests, toxicity texts).
If one type of environmental disturbance is considered to be
analogous to others, then relatively well-developed models and
assessment approaches for one disturbance can be used to assess
others (Suter 1993). For example, the effects of fishing on fish
populations have been used as a model for effects of mortality
from power plant cooling systems (McFadden 1977) and toxic
chemicals (Goodyear 1972, Barnthouse et al. 1987, 1990). To the
extent that actions resemble fishing, in that they cause mortality at
different rates on different life stages, the mathematical models and
computational techniques developed by fisheries scientists can also
be employed in environmental assessments.
• Impact Matrices. An impact matrix (i.e., scaled matrix) is an
expanded checklist that includes estimates of the relative magnitude
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(i.e., significance) of the environmental impacts (Leopold et al.
1971, Figure 4.3-1, Attachment 4.D ). Values are assigned to the
identified impacts and these values can be summed to aid
interpretation of the impacts of various alternatives, to evaluate the
temporal phases of a project, to identify beneficial and detrimental
impacts (through the use of plus and minus signs) or to describe
impacts associated with spatial boundaries (site vs. region) (Canter
1977).
4 -o f. m .0 »: J o
m m m u
llflf !
^ C (B
T 21* *? O) •!
£ 5 E c S
e
A. 2. d. Water quality
A. 3. a. Atmospheric quality
A. 4. b. Erosion
A. 4. c. Deposition, Sedimentation
B. 1. b. Shrubs
B. 1. c. Grasses
B. 1. f. Aquatic plants
B. 2. c. Fish
C. 2. e. Camping and hiking
C. 3. a. Scenic views and vistas
C. 3. b. Wilderness qualities
C. 3. h. Rare and unique species
C. 4. b. Health and safety
FIGURE 4.3-1. A reduced matrix for a phosphate mining lease.
(Source: Leopold et al. 1971)
Since the evaluation of the relative magnitude and importance of
impacts is subjective and various scales are used (e.g., one-to-ten;
high, low, medium; Westman 1985), documentation of the
procedure is particularly important. For example, a one-to-three
scale might be described as follows:
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One — Effects occur but are of only slight concern;
slightly important effects.
Two — Effects of moderate concern; moderately
important effects.
Three — Effects are of particular concern; most
important effects.
Blank — The perturbation has no effect on the
process or component.
In addition to having the same problems as checklists (Chapter
4.2), scaled matrices convey objectivity when in fact the values are
subjective and generated by a very restricted group(s) (e.g., the
EA team, other independent experts, or decisionmakers). The use
of summation values, although they provide the decisionmaker
with an easy way to compare a complex variety of impacts from
a number of alternatives, obscures the relative contributions of
different elements and actions. Moreover, the database is
simplified enormously to generate an index. The implications of
index values should be corroborated by other assessment
techniques. Also, any such assessment index should be validated
by field testing. Nonetheless, the use of indices derived from the
consensus of experts can facilitate comparison of data from
different geographical areas or from different points in time
(Attachment 4.D).
Field and laboratory tests and experiments. The kind of data
needed for analysis of environmental effects depends on the source
of the impact (e. g., contaminant, disturbance) and the environ-
mental endpoint of interest. Effects can range from mortality and
reproductive impairment in individuals and populations to
disruptions in community and ecosystem function such as primary
productivity. In relation to EA, field and laboratory tests are
usually conducted only when available data are lacking or
inadequate. It is particularly important that such tests are relevant
to the endpoints selected during the identification of issues, that the
quality of the data is assured, and that the need for extrapolation
is minimized.
Controlled laboratory (e.g. microcosms) arid field tests (e.g.,
mesocosms) are often called physical models. They can provide
strong causal evidence linking a contaminant or disturbance with
a response and can also help discriminate between multiple sources
of impact (Suter 1993, Westman 1985, ffilbom and Walters 1981).
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The most common type of physical model is the laboratory test
(e.g., a bean seedling in a flask of hydroponic solution as a model
of the crop in the field). The objective of these microcosm studies
is to isolate environmental components and processes and to
subject the components to various levels of perturbation. One of
the principal advantages of this approach is that it provides some
control of boundary conditions so that observed variations can be
attributed to the response under investigation. A disadvantage is
that results of experiments under controlled conditions must be
extrapolated with caution to the natural system. The EPA has
developed standard microcosm protocols for toxicity testing for
soil microbial communities (EPA 1987, Suter and Sharpies 1984,
Van Voris et al. 1985) and excised aquatic communities (EPA
1987, Giddings 1986, Perez et al. 1984). However, microcosm
tests are seldom used in EA.
Field tests (i.e., mesocosms) are tests of the effects of a
contaminant or disturbance in an unconfined environment
conducted at approximately the same scale as the predicted effect.
They are the most difficult and expensive type of test, but if
properly conducted, they provide realistic evidence of impacts.
However, the responses in field tests are complex and so
influenced by uncontrolled variables (e.g., weather, movement of
organisms) that the results may be difficult to understand and
generalize. Also, they are often unreplicated and have few
treatment levels because of expense and the difficulty of finding
sufficiently similar sites. The only field tests that have been
required by regulation are the natural pond tests formerly required
by the EPA Office of Pesticide Programs and the terrestrial field
tests for effects on wildlife still required by the EPA for certain
pesticides (File et al. 1988).
Predictive Models. Models are used in EA to predict the
environmental consequences of an action (Attachment 4.C). They
are mathematical, statistical, or conceptual expressions of the
essential elements of a problem and, as such, every model contains
simplifications. As a result, predictions derived from models can
neither be completely accurate nor can they ever correspond
exactly to reality. It is a task for specialists to develop models;
however, their use by decisionmakers must be restrained by an
understanding of the advantages and disadvantages of modeling.
The phases associated with development of a model include:
— defining a volume in space;
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— defining the various reaction rates of processes of interest
(e.g., biodegradation, hydrolysis, photolysis);
— defining the various discharges to the system;
— defining the transport rates between the various media; and
— solving the equation to obtain an expression for the
substance of interest.
The use of the resulting estimates in EA involves an understanding
of the tolerances of species to pollutants, the transfer and
transformation of pollutants in ecological systems, and the effect
of toxification of one part of the ecosystem on remaining portions
(Westman 1985). In addition to the models that are described in
Attachment 4.C, the reader is referred to discussions in Westman
[1985), Cohrssen and Covello (1989), and Bregman and
Mackenthun (1992) for information on mathematical models for
predicting pollutant dispersion in air, water, and soil.
Vlass balance is a fundamental concept in modeling in which a
relume in space of the environment is identified and a mass or
naterial balance equation is written for the volume (Figure 4.3-2;
tfackey and Paterson 1993). The "Volume" may be water in a
iver, a region of the atmosphere, soil to a specific depth or even
in organism. It has defined physical boundaries and, hopefully,
air homogeneity. A mass balance equation states that change in
he components of a volume will equal the sum of the inputs less
PHASE OR COMPARTMENT
INFLOW I /ENVELOPE IN SPACE
_ OUTFLOW X
DISCHARGES D-
»> REACTION R
^M. CONCENTRATION C/
FORMATION F " _ ^ TRANSFER TO OTHER
TRANSFER FROM OTHER COMPARTMENTS T
COMPARTMENTS J
INVENTORY CHANGE « INPUTS - OUTPUTS
Vde/dt -I+D+F+J-X-R-T kg/year
At (teady stale dc/dt * 0
I *DtF + J» X + R+T kg/year
Figure 43-2. Fundamental mass balance equation.
(Source: Mackay and Paterson 1993)
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the sum of the outputs. Input terms may include flow in air and
water, direct discharges, or formation of chemicals. Outputs may
include flow (e.g., water from a lake) or degrading reactions or
diffusion to another medium. The modeler's task is to develop
quantities (in compatible units) for each of the terms in a mass
balance equation.
The following discussion of predictive models is largely a
paraphrase of Suter and Barnthouse (1993).
Mechanistic (i.e.. mathematical) models are what most
people associate with the term "model". In this approach
to EA, the principal cause-effect relationships of a
proposed action are described in terms of mathematical
functions and combined to yield a mathematical model
capable of predicting future environmental conditions.
Mathematical "models" come in all degrees of complexity,
from simple variations on mass balance equations to highly
complex multivariate systems. The mathematical functions
may be purely deterministic, or may have strong stochastic
elements contributing to the model output. Some models
include statistical routines for estimating error associated
with model outputs. Most commonly used mathematical
models for impact assessment have been adapted for
computers.
It has often been argued that mechanistic models are
unsuited to EA because natural systems are so complex.
Approximations and simplifying assumptions always have
to be made and these necessarily introduce errors and
uncertainty. Nevertheless, mechanistic models are useful
components of many assessment studies. Examples include
predicting ecological effects of climate change, responses
of landscapes to regional air pollution (Hunsaker and
Graham 1991), long-term management of fisheries (Walters
1986) and remediation of PCB contamination (Limburg
1986). Where there is (as there almost always is)
substantial uncertainty about the "true" nature of the
mechanisms and the values of critical parameters, astute
use of more than one model can provide valuable guidance
in making informed management decisions (Walters 1986).
Another important use of mechanistic models is to integrate
complex sets of observations made in different times and
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places. Ecosystem simulation models are often used for
this purpose [e.g., the Narragansett Bay model of Kremer
and Nixon (1978) and the forest stand composition and
succession models of Shugart and West (1980) and West et
al. (1980)].
Yet another use of mechanistic models is to predict
variables or events that are difficult or impossible to
measure from more readily measurable variables [see
Christensen et al. (1976) on the effects of the operation of
power plants on the abundance of fish populations].
Readers interested in learning mathematical modeling
techniques should consult one of the several available
textbooks on this subject, including Hall and Day (1977),
Jtfrgensen (1988), Rau and Woolen (1980), and Swartzman
and Kaluzny (1987). For water quality modeling,
Thomann (1972) is an excellent text. The journal
Ecological Modeling publishes a variety of papers on both
theory and applications of environmental models.
Statistical models derive generalizations by using statistical
techniques [e.g., regression, principal components analysis;
see Snedecor and Cochram (1980) or any introductory
textbook for description of these basic statistical methods]
to summarize experimental or observational data. There
are three distinct purposes for using statistical models in
EA: hypothesis testing, description, and extrapolation.
Hypothesis testing was originally developed to determine
whether data from controlled studies provided sufficient
support for hypothesized relationships between controlled
independent variables and the observed responses of
dependent variables. It is most often used in EA for
comparison of contaminated and reference sites in
monitoring studies. However, it can lead to conclusions of
statistical significance that have no relationship to
ecological significance.
The second use,of statistical models is description. For
example, a multivariate regression model might be used to
describe the results of a pollution monitoring study by
regressing concentration against distance downstream and
flow rate. Similarly, a multivariate classification method
such as principal component analysis might be used to
distinguish the sets of natural and pollution-adapted biotic
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communities within an ecosystem. This description of
patterns and relationships in observational data is the major
activity of statistical ecologists. The results can be used to
frame hypotheses which are then tested in experimental
studies, to guide further sampling, or simply to increase
understanding of the system. Readers interested in
multivariate analysis should consult Gauch (1982).
The third use of statistical models is extrapolation, the use
of a model to statistically estimate something other than the
data from which it was derived. The most familiar type of
extrapolation is extrapolation of a model to conditions
outside the range of the data from which the model was
derived. This range extrapolation is considered bad
practice but is sometimes necessary in EA. Another more
useful type of extrapolation is extrapolation from a type of
data that is available to a type that is desired but
unavailable. For example, extrapolation techniques were
used to estimate the effects that ingestion of food
contaminated with chemical nerve agents would have on
wild birds based on pesticide data for rats. The
organophosphorous nerve agents and pesticides are similar
in chemical structure and biological activity. Available
data were sufficient to develop models for mallards and
ring-necked pheasant (Sigal and Suter 1989).
In assessments of impacts of acidification on surface
waters, statistical models have been used extensively to
extrapolate from observations on subsamples of lakes and
streams to impacts on regional surface water resources
(Baker et al. 1990). Exercises of this kind are sometimes
referred to as "empirical modeling"; they are an important
part of basic field ecology.
Strictly speaking, a statistical model makes no presumption
to explain observation in terms of causal relationships
between the independent and dependent variables. The
model simply summarizes the relationship between the
variables.
A conceptual model usually contains three elements: the
variables of the ecosystem of interest; the external variables
that affect the state of the ecosystem of interest; and the
interrelationships between them (i.e., the processes
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involved in the response of the environment to the action).
A conceptual model is often the preliminary step in the
formulation of a mathematical model. Figure 4.3-3 shows
a conceptual diagram of the nitrogen cycle in a late. The
ecosystem variables are nitrate, ammonium (which in the
un-ionized form ammonia is toxic to fish), nitrogen in
phytoplankton, nitrogen in zooplankton, nitrogen in fish,
nitrogen in sediment and nitrogen in detritus. The external
variables are: the water inflow and outflow, the
concentration of nitrogen components in the in- and
outflow, the solar radiation (indicated by the arrow
PHOTO) and the temperature; the latter is not shown on
the diagram, but it influences all process rates. The arrows
in the diagram illustrate the processes; these can be
expressed by use of mathematical equations in building a
mechanistic model. This conceptual model might be
applied to an assessment of the aquatic impacts of a facility
that would release ammonia. Such conceptual models can
serve as an aid to qualitative assessments and simple
quantitative assessments as well as mathematical models.
OENIT
PHOTO NFIX
Inflow
Outflow Ljs
Figure ».3-3 . The conceptual dlagraa of a nitrogen cycle In an
aquatic ecosystra Is shorn. The processes are: 1) uptake of
nitrate and aMonlin by algae, 2) photosynthesis, 3) nitrogen
fixation, 4) grazing with loss of undigested utter, 5), 6) and 7)
are predatlon and loss of undigested utter, 8) Mortality, 9)
•Inerallzatlen, 10) settling of algae, 11) settling of detritus, 12)
excretion of aMMonluM frra zooplankton, 13) release of nitrogen from
the sedlwnt, 14) nitrification, IS), 16) and 18) Input/output, and
17) denltrlflcatlon.
[Source: Jrfrgensen, S. 1. 1991. Environmental Management Modelling. In:
Introduction to Environmental Management (eds. P. E. Hansen and S. E. J^rgensen)
Elsevler, New York. 403 pp.]
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Specialized Analysis and Prediction Methods. As discussed
above, there is no universal method for analysis and prediction of
environmental impacts. Experimental testing is the scientific ideal
but not generally feasible except on small scales. Thus, alternative
methods have been developed to assess specific types of problems.
This section describes some, but by no means all, of the recent
methods used in EA.
Habitat Evaluation Methods. Because habitat includes all
the components, both biotic and abiotic, necessary for the
survival of a species (e.g. food, cover, water, breeding
areas), knowing the general habitat requirements of a
species allows determination of the potential value of an
area for wildlife. (See EPA 1993 for discussion of habitat
issues relevant to environmental assessment.) This
information is useful in predicting effects of physical
disturbance or destruction on fish and wildlife populations.
For example when habitat is destroyed, the loss of a
wildlife species will approximately equal the sum over
habitat types of the wildlife density in a habitat type times
the area of that habitat lost. This assumes that the species
of interest is effectively immobile or that habitat is limited.
An approach that allows the user to apply a value
systematically to a habitat was developed by the U.S. Fish
and Wildlife Service (FWS) (Fanner 1980, 1981) in
cooperation with various conservation groups and state and
other federal agencies. Called Habitat Evaluation
Procedures (HEP), the technique is designed to provide a
consistent means of assessing project development impacts
by: 1) assigning a quantitative index value for existing
habitat conditions; 2) determining the difference between
index values of existing conditions and conditions that will
result from a proposed project; and 3) demonstrating, in
habitat-value units gained or lost, the beneficial or adverse
impacts anticipated as a result of projected development.
This habitat evaluation procedure provides a framework for
determining habitat quality for specific fish and wildlife
species and has been extended in an attempt to consider
pollution effects (U.S. Department of Interior 1987). The
FWS has programmed the models to be used interactively
on microcomputers.
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An investigator choosing to evaluate a particular
geographical area can select appropriate endpoint species
from a master list, and use the habitat requirements of
these species to generate a sublisting of environmental
variables that must be analyzed or quantified. After these
environmental variables are measured or evaluated in field
studies, the habitat information can be entered into the
interactive program.
The HEP output reports each habitat type in terms of its
Habitat Suitability Index (HSI), scaled from 0.0 to 1.0.
These HSIs are computed for each of the endpoint species
and, as a weighted mean, for the total area being evaluated.
The investigator can also examine intermediate model
outputs and perform a sensitivity analysis of the input
variables. The HSIs and the areas of the habitats can be
combined (by simple multiplication) to yield Habitat Units
(HUs) for each habitat category and for a series of
scenarios (target years) with varying combination of land
use.
The HEP outputs can be used to assess environmental
impacts by comparing the HUs available to each endpoint
species in pre-action and several post-action scenarios.
Additionally, if the areas of certain habitats are to be
created or enhanced through mitigation, the effects of such
changes can be compared with the unmitigated scenario.
Atkinson (1990) describes a Simplified Habitat Evaluation
(SHE) technique for biological impact assessment. SHE is
based on the theory of diversity and an assumption that as
the biological quality of an area increases so does its
diversity. A study of 132 habitat-based methods showed
that measurements of diversity obtained from SHE are
highly correlated to HEPs. Moreover, SHE can be easily
adapted to digital remote sensing imagery and the data can
be analyzed with a computerized SHE.
Landscape Mapping/Geographic Information Systems.
Sets of landscape characteristics/attributes (e.g., sensitive
habitat, cultural resources, slope, soils) can be used alone
or in combination to assess the suitability or vulnerability
of an area for various uses. Typically each attribute of
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interest is separately mapped and relevant maps are
overlaid on a baseline map. Mapping has evolved from
hand-drawn transparency maps (McHarg 1969) to
computerized mapping systems, sometimes attached to
automatic systems of data input from satellite photos
(Westman 1985). Collections of automated spatial data on
landscape attributes are called geographic information
systems (CIS) and their application in EA is increasing.
Their usefulness depends on the nature of the proposed
action, the availability of computerized data, and the EA
objectives. CIS systems can incorporate economic,
ecological, and aesthetic criteria into the process of
comparing alternatives. Decisions are then based on how
closely each plan comes to achieving specific goals (Jensen
and Gault 1992; Attachment 4.E).
Hopkins (1977) compares major approaches to land
suitability mapping and Westman (1985) provides three
examples of the application of computerized systems to the
study of land resources [the Boston Metropolitan Landscape
Planning Model (METLAND), the Australian CSIRO South
Coast Study (SIRQ-PLAN), and the Rasmussen et al.
(1980) technique for selecting road paths through forest].
Westman (1985) notes the following limitations to GISs:
— In the process of constructing quantitative or
economic indexes of landscape value, much
information is lost, information is extrapolated
beyond the empirical data base, and sources of
statistical error are compounded.
- The spatial interdependence of landscape units is
often not accounted for (i.e., the landscape
attributes reflect the structural rather than the
dynamic features of the environment).
— Natural ecological boundaries are usually not
recognized (e.g., in relation to species dispersal,
water-or airshed boundaries). Hence dispersal of
air or water pollutants are typically modeled
separately, as is movement of species between
landscape units.
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Ecological Risk Assessment. Ecological risk assessment
is a process that evaluates the likelihood that adverse
ecological effects may occur or are occurring as a result of
exposure to one or more contaminants and/or disturbances
(e.g., chemical, physical or biological agents, construction
activities) (EPA 1992, Suter 1993). The process involves
identifying hazards such as the release of a toxic chemical
to surface waters that support fisheries, and using
measurement, testing, and mathematical or statistical
models to quantify the relationship between the initiating
event and the effects. Ecological risk may be expressed in
a variety of ways. While some ecological risk assessments
may provide true probabilistic estimates of both the adverse
effect and exposure elements, others may be deterministic
(i.e., parameters are assumed to be constant and accurately
specified) or even qualitative in nature. In these cases, the
likelihood of adverse effects is expressed through a
semiquantitative or qualitative comparison of effects and
exposure.
Ecological risk assessments can help identify environmental
problems, establish priorities, and provide a scientific basis
for regulatory actions (Cohrssen and Covello 1989). The
process can identify existing risks or forecast risks of
chemical, physical or biological agents or other activities
not yet present in the environment. However, while
ecological risk assessments can play an important role in
identifying and resolving environmental problems, risk
assessments are not a solution for addressing all specific
environmental problems. For example, for protection of
habitats and endangered species, professional judgment and
the mandates of a particular statute will be the driving
forces in making decisions.
Models of interest for ecological risk assessment are
categorized into two classes: exposure models and effects
models.
Exposure models simulate the movement and
transformations of toxic contaminants in the environment.
Processes generally simulated in transportation and fate
models include the physical movement of particles and
dissolved materials, chemical transformations, and
exchanges between major compartments (e.g., air, water,
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soil) of the environment. A detailed account of the use of
fate models in risk assessment can be found in Mackay and
Paterson (1993). Attachment 4.C summarizes some of the
available exposure models (e.g. multimedia, remediation,
aquatic, soil, fish uptake and food chain, atmospheric, and
spill models) which can be used for exposure estimation.
Food web models are a special subclass of fate models
often used to simulate (1) exchanges between biotic and
abiotic components of the environment and (2) transfer of
contaminants from prey to predators (Suter 1993). The
emphasis in food web models is on the biological
components of the environment, especially the movement
of materials through grazing, predation, and human
harvest. Models of DDT and PCB bioaccumulation
(Harrison et al. 1970, Thomann and Conolly 1984) and of
contaminant movement through food chains (Baes et al.
1987, Lipton and Gillett 1991) are excellent examples of
this type of model.
Effects models simulate the effects of stress on biota. This
is by far the most diverse category of models of interest in
environmental assessment (Suter 1993). The "stresses" that
have been modeled include human exploitation,
environmental contamination on both local and regional
scales, and, more recently, climate change resulting from
increasing atmospheric carbon dioxide. Organism-level
effects models include toxicodynamic models (Mancini
1983, Kooijman and Metz 1984, Lassiter 1985, Lassiter
and Hallam 1990) that relate the risk of death of organisms
to the uptake and internal concentration of contaminants.
Models of energetics and growth (Kitchell et al. 1977, Rice
et al. 1983) are also relevant to environmental assessment
but have not been extensively applied to date.
The population-level models of current or potential use in
environmental assessment include the many models
developed for management of fish and wildlife populations.
Logan (1986) and Barnthouse et al. (1987, 1989, 1990)
have provided examples of the use of fisheries-derived
models in contaminant risk assessment. Although such
models have not yet been used to assess risks of
contaminants to wildlife populations, Emlen (1989) has
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reviewed the available wildlife population models and
discussed their potential uses.
Community-level and ecosystem models are the most
diverse of ecological effects models. These models may be
site-specific (Kremer and Nixon 1978) or generic (O'Neill
et al., 1982). Spatial scales considered range from
microcosms (Rose et al. 1988) to regions or landscapes
(Dale and Gardner 1987). Suter and Bartell (1993) discuss
the reasons why ecosystem-level testing and ecosystem
models have not fulfilled their promise as tools for EA.
Among the reasons is the lack of clear goals. At the
ecosystem level, many endpoints have been used but none
have the endorsement of the regulatory agencies or the
scientific community. This problem is analogous to that of
not having indicators for assessment of sustainability
(Chapter 1).
A few integrated exposure/effects models that permit
changes in biotic compartments (e.g., flora, fauna) to affect
the fate of chemical contaminants have been developed
(Bartell et al. 1988). Such models are applicable
principally to cases in which (1) biota are a major sink for
contaminants (true only rarely), and (2) contamination is
sufficient to cause major disruption of the biota.
Human Health Risk Assessment. The goal of human
health risk assessment is to estimate the severity and
likelihood of harm to human health occurring from
exposure to a risk agent (e.g., a chemical substance,
biological organism, radioactive material, or other potential
substance or activity). Although U.S. regulations require
assessment of the impacts of proposed activities on the
public health and welfare, such assessments are often
lacking or inadequate in EA. Difficulties associated with
health assessment in EA are similar to those associated with
assessment of impacts on natural resources (i.e., lack of
data and knowledge regarding dose/response relationships)
and proponent concern about referring to the health impacts
of a project in terms of morbidity, disease incidence,
mortality, or projected death rates (Giroult 1988).
Human health risk assessment consists of the following
related steps (Cohrssen and Covello 1989):
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- Source/Release Assessment-estimates the amounts,
frequencies, and locations of the introduction,
release, or escape of risk agents (e.g., toxic
chemicals) from specific sources (e.g.,
manufacturing plants) into occupational, residential,
or outdoor environments.
- Exposure Assessment - provides quantitative data on
individuals, populations, or ecosystems that are, or
may be, exposed to a risk agent; the concentrations
of the risk agent; and the duration and other
characteristics of exposure.
- Dose-Response Assessment - provides quantitative
data on the specific amounts of a risk agent that
may reach the organs or tissues of exposed
individuals or populations and attempts to estimate
the percentage of the exposed populations that might
be harmed or injured and, where relevant, the
characteristics of such populations (for example,
sensitive subgroups such as children or the elderly).
— Risk Characterization - integrates the results of the
previous steps into a risk statement that includes
one or more quantitative estimates of risk.
Although the approach to human health and ecological risk
assessment is conceptually similar, human health
assessment considers effects on individuals of a single
species and has a well-defined set of values to be protected
that can be generally applied.
Economic-Demographic Assessment Models. Economic-
demographic models integrate economic, demographic,
public service, and fiscal projections that are essential for
EA of broad planning efforts. Models of this general type
have been used for macrostructural international analysis
(Sanderson 1978) and in the projection of the impacts of
resource development (Leistritz and Murdock 1981).
These models have recently been adapted to project
changes in key economic and demographic indicators for
smaller areas such as counties or individual towns (Leistritz
etal. 1990). Output from the models includes projections
of:
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— demographic factors such as total population and
population by age and gender;
— economic factors such as business volume,
employment by type, personal income;
- public service demands for housing, school
enrollments, medical and criminal justice service
needs; and
- public costs and revenues by type and net fiscal
balances by jurisdiction.
ISSUES
• The lack of reliable baseline data is one of the major problems for
quantitative EA. It has made objective evaluation of changes in
environmental quality difficult and often impossible. Moreover,
acquiring baseline data is generally one of the most expensive and
time-consuming activities in the EA process.
• Most studies of man-made impacts focus on structural responses
of individual organisms. These components are relatively sensitive
and are easy and inexpensive to measure; however, linkages of
these parameters to adverse impacts on biological populations,
communities, and ecosystems are mostly lacking. Measurements
of effects at the higher levels of organization are confounded by
natural variability, long response times, climatic variation,
pathogens, and other factors. In addition, the lack of replication
and of true control areas creates severe problems for design of
monitoring programs and testing of hypotheses concerning effects
(Sigal and Suter 1987, Jdrgensen 1991).
• A mathematical model represents the synthesis of knowledge and
data and thus is dependent on the depth of understanding of the
particular system being modeled, the expertise of the modeler, and
the quality of the available data. A model cannot fill gaps in
knowledge or data. However, it can provide new understanding
about the reactions and properties of a system (Jdrgensen 1991).
Generally, an ecologist, an environmental scientist, or an
environmental engineer with some knowledge of mathematics and
computer science is a better fit to developing and using ecological
and environmental models than a mathematician with some
knowledge of ecology and environmental science (Jorgensen 1991).
However, the very best development and use of environmental
models is carried out by a team representing all the relevant
4-49
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disciplines, such as ecology, environmental engineering,
mathematics, and computer science.
• The major types of uncertainty in EA are uncertainty in impact
prediction and uncertainty in relation to decisionmaking (De Jongh
1988). The extent of the uncertainty in predictions about direct
and indirect changes in the environment depends on the data and
the methods used. Decreasing uncertainty in prediction usually
involves more sophisticated methods, additional expertise, more
resources, and almost invariably more information about the
proposed activity, the local environment, and the behavior of
possible environmental contaminants. Most predictive methods
involve either a mathematical, physical, or conceptual model of the
environment. The sources of uncertainty in the development and
application of models include the following (De Jongh 1988):
data collection (i.e., accuracy in measurement and sampling
and the inherent variability of environmental data);
structural error (i.e., simplification of ecological processes,
incorrect assumptions about functional relationships,
imprecise spatial and temporal resolution);
numerical error (i.e., approximations in numerical
solutions);
use outside the range of circumstances for which a model
was developed and calibrated; and
simple human mistakes.
Approaches to estimating uncertainty in modeling include
sensitivity analysis and Monte Carlo error analysis (De Jongh
1988). Sensitivity analysis is a technique for identifying the
variable or parameter within a model that causes the largest change
in model output per unit variance in input. Monte Carlo analysis
is a simulation approach that estimates the variance in model
output resulting from the estimated variance in the input
parameters. Methods for reducing uncertainty in prediction are
summarized by Environmental Resources Limited (1985).
The uncertainty in decisionmaking is the result of politics and
subjective choices made during the EA process (De Jongh 1988).
These include, but are not limited, to:
political sensitivity of the proposed action;
the choice of alternatives to be investigated;
the choice of impacts to be studied and their relative value;
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definition of the limits and constraints of an assessment;
and
confidence in impact predictions.
Management approaches to resolving uncertainty related to
decisionmaking in the EA process include decision analysis (Figure
4.3-4), amalgamation (i.e., the pulling together of many impact
variables into a few valuative indices; see Elliot 1981), better
guidelines for the application of EA, and better communication
between the proponent and the public and the assessment team and
the decisionmaker (De Jongh 1988).
DECISION ANALYSIS
Decision analysis provides a consistent method for structuring
and clarifying the decision problem. Expert opinion Is used
to derive numerical estimates for subjective considerations .
when objective probabilities are not available. Decision
analysis rests upon two assumptions. First, there are
Incomplete data; secondly, the decisionmaker will be
Influenced by the likelihood of events occurring and the
values associated with the possible consequences. One of the
main tools In decision analysis Is the 'decision tree*, In
which different actions, along with their likely consequences,
resulting from alternative decisions are shown systematically
1n graphical form.
ACTION
FUOTHfR ACTION
• •CTOHTUIH ,x
• KMtWUNCtHUMTV l\
•MW.UU* ! \—
Figure 4.3-4.
A decision tree for the problem of groundwater contamination.
(Source: OeJongh 1988)
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• There are no procedures for the systematic integration of the
environmental components of a study with the social and economic
aspects. It is possible in some instances to construct ecological-
economic models, but such models are not yet sufficiently well
developed to give reliable results (Jtfrgensen 1991, Kjeldsen-Kragh
1991).
LINKAGES
Impact analysis is linked to all of the EA elements. . During initiation and
scoping, alternatives and issues requiring in-depth analysis are identified. Any
cross-media (e.g., effects of air pollutants on water quality) and cross-impact
(e.g., effects of wetland loss on waterfowl) linkages are determined and the
assessment endpoints are identified. Other applicable laws and regulations (e.g.
for permits) are identified and reviewed for any specific requirements for analysis
related to the proposed action and the issues of interest. The result of impact
analysis should be a succinct, comparative presentation of information about the
proposed alternatives for use by the decisionmaker and the public. It identifies
areas where monitoring and/or mitigation are needed. Thus, it forms the basis
for post-decision analysis and follow-up.
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ATTACHMENT 4.C
SUMMARY OF FATE MODELS USED IN ENVIRONMENTAL
ASSESSMENT
Summary of Fate Models used in Environmental Assessment. (Source: Mackay, D.,
and S. Paterson. 1993. Exposure assessment: mathematical models of transport and
fate. In: Ecological Risk Assessment (ed. G. W. Suter, n). Lewis Publishers, Inc.,
Chelsea, Michigan)
4.C-1
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4.C-2
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Summary of Fate Models used in Environmental Assessment. (Source: Mackay, D.,
and S. Paterson. 1993. Exposure assessment: mathematical models of transport and fate.
In: Ecological Risk Assessment (ed. G. W. Suter, n). Lewis Publishers, Inc.,
Chelsea, Michigan)
This attachment provides a list of some of the models that can be used for exposure estimation.
It is not a comprehensive list. The reader should consult Mackay and Paterson (1993) for
additional information about this list. Reviews of available models are also found in Cohen
(1986), OECD (1989), Dickson et al. (1982), and Jdrgensen (1984). See references to Part 4.3
for citations.
MULTIMEDIA MODELS
A series of fugacity-based (i.e., fate) models has been developed in the last
decade at the University of Toronto by Mackay and co-workers (Mackay, 1979,
Mackay and Paterson, 1993, Mackay et al., 1985). They vary in complexity
from a simple equilibrium distribution of a conservative chemical, to steady state
and time varying descriptions of the fate of reactive compounds. These models
are primarily useful for predicting the fate of chemicals in multimedia systems.
GEOTOX. GEOTOX (McKone and Layton, 1986) is a comprehensive
multimedia compartmental model which calculates chemical partitioning,
degrading reactions and diffusive and non-diffusive interphase transport. The
concentrations estimated for various environmental compartments are
subsequently combined with appropriate human inhalation and ingestion rates, and
absorption factors to calculate exposure. It treats an environment representative
of the South Eastern United States, consisting of the following compartments: air
(gas), air (particles), biomass, upper soil, lower soil, groundwater, surface water
and sediments.
Enpart (Environmental Partitioning Model). Enpart (OECD, 1989) is one of
a set of models developed by the EPA as a first level screening tool for new and
existing organic chemicals of possible concern. It is a fugacity-based model
which estimates the steady-state equilibrium or dynamic partitioning of organic
chemicals among environmental compartments. It identifies dominant pathways
and data gaps and estimates the chemicals' persistence and bioconcentration
potential.
Toxscreen. Toxscreen (Hetrick and McDowell-Boyer, 1983) is a time-dependent
multimedia model, developed by the EPA to assess the potential for
environmental transport and accumulation of chemicals released to the air, surface
4.C-3
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water or soil. It is modular in concept and incorporates intermedia transfer
processes. It is intended as a screening tool to assess the human exposure
potential of organic chemicals.
Environmental Exposure Potentials (EEP). EEP (Klein et al., 1988) is a
fugacity-based equilibrium multi-compartment model used by member states of
the European Community to determine exposure potential of new organic
chemicals. The methodology is applied to chemicals being imported or produced
in quantities of 1 metric ton per year or more.
SIMPLESAL. SIMPLESAL (OECD, 1989) is a spreadsheet-based multimedia
fugacity compartmental model which can be used to estimate steady state or time-
dependent concentrations of organic compounds as well as heavy metals. It
determines dominant environmental pathways and processes for contaminants and
was designed for use in The Netherlands as a screening tool to predict results of
various scenarios for emission control of new and existing chemicals such as
benzene, cadmium, lindane and copper. It considers compartments of air, water,
suspended solids, aquatic biota, sediment and soil.
REMEDIATION MODELS
AERIS. AERIS (Senes Consultants, 1989) is a multimedia risk assessment model
that estimates environmental concentrations and subsequently human exposure in
the vicinity of contaminated land sites. It is intended for use at sites where
redevelopment is being considered. The model is novel in that is runs within a
user-friendly expert system programming environment. An "intelligent"
preprocessor interrogates the user about the redevelopment scenario to be
assessed, assisting the user where necessary, or supplying default values.
AQUATIC MODELS
Persistence. The persistence model (Roberts et al., 1981; Asher et al., 1985)
was developed for the National Research Council of Canada as a screening
method to estimate the fate of various organic chemicals but especially pesticides
which are released into the aquatic environment. It considers four compartments:
water, catch-all (representing suspended solids, invertebrates or other components
of water systems excluding fish), sediment, and fish. It calculates both a steady-
state or fixed solution and a time-dependent solution. Default environments for
the model are a Standard Pond and a Standard Lake simulating a small, eutrophic
pond and a deep oligotrophic lake. Removal pathways include photodegradation,
volatilization, and hydrolysis in water; biodegradation in fish; and microbial
degradation in suspended solids and sediments.
4.C-4
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EXAMS - Exposure Analysis Modeling System. EXAMS (Bums et al., 1981)
is an interactive mass balance model developed at the EPA Research Laboratory
in Athens, Georgia, which predicts the fate of organic contaminants in stratified
surface waters as a result of continuous or intermittent releases. It is widely used
by EPA and other environmental agencies in the U.S.
EXWAT. EXWAT (OECD, 1989) is a steady state model, developed in
Germany, to describe chemical fate in water bodies. It is a simple approach
suitable for application to continuous single point sources. It is intended for use
as a screening tool to assess comparative hazards of existing chemicals in the
Rhine River. It is also a submodel of the multimedia E4CHEM system (Exposure
and Ecotoxicity Estimation for Environmental Chemicals), an exposure and
hazard assessment model developed in Germany for priority setting within
OECD.
Inorganic Chemical Models (e.g., metals and phosphorus). Modeling of
inorganic compounds in the aquatic and other environments proves to be more
difficult in the sense that the chemical properties and speciation tend to be unique,
thus the generalizations which apply to organic chemicals do not usually apply.
Bonazauntas et al. (1988) have reviewed fate models for such chemicals.
Speciation Models, e.g., MINTEQAI. MINTEQAI (Brown and Allison, 1987)
is an example of an equilibrium metal speciation model applicable to metallic
contaminants in surface and groundwaters. It is thus quite different in purpose
from the mass balance models discussed earlier. It calculates the equilibrium
aqueous speciation, adsorption, gas phase partitioning, solid phase saturation
states, and precipitation-dissolution of 11 metals (arsenic, cadmium, chromium,
copper, lead, mercury, nickel, selenium, silver, thallium and zinc). It contains
an extensive thermodynamic base and is designed to make minimal demands on
the user.
SOIL MODELS
Several models have been developed to describe chemical fate in soils. Notable
are SESOIL [a Seasonal Soil Compartment Model, OECD, (1989)], Bonazountas
and Wagner (1984), PRZM (Pesticide root zone model) by Carsel et al. (1984),
PESTAN (Pesticide Analytical Model) by Enfield et al. (1982), and the "Jury"
Model by Jury et al. (1983).
FISH UPTAKE AND FOOD CHAIN MODELS
Because of the importance of the human exposure route via fish consumption,
considerable effort has been devoted to estimating chemical concentrations in fish.
Contaminants may enter fish via the gills (bioconcentration) and, especially in the
4.C-5
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case of hydrophobia chemicals, by way of food (biomagnification). These
pathways are the subject of discussion in recent examples by Thomann (1989),
Clark et al. (1990) and the text by Connell (1989).
ATMOSPHERIC MODELS
Numerous air dispersion models with general or limited geographic applicability
have been developed with the objective of deducing ground level concentrations,
and hence exposures, from stack emissions. Most texts or handbooks on air
pollution contain full descriptions of such models. Models range from simple
application of Gaussian dispersion equations to complex, multi-source models
containing allowances for depositing particles and topographic features of the
terrain. The use of such models is often written into legislation as a means of
translating desired ground level concentrations into acceptable stack emission
rates.
SPILL MODELS
Several models are available that deduce the fate of chemical spills. These are
often used to provide guidance for spill response personnel. An example is the
POSSM (PCB On-site Spill Model) described by Brown and Silver (1986). Most
regulatory agencies and many industries concerned with the marine environment
(e.g., the Coast Guard) have available models which can describe the movement
and fate of spills of materials such as oil, when subject to variable winds and
currents.
4.C-6
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ATTACHMENT 4.D
PROBLEMS ASSOCIATED WITH AMALGAMATION OF DATA
• Elliot, M. L. 1981. Pulling the pieces together: amalgamation in environmental impact
assessment. Environmental Impact Assessment Review 2:11-38.
4.D-1
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4.D-2
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fe
-
I
Cnnid Tcion
10 HA RKVIK.W 2 I
Pulling the Pieces
Together:
Amalgamation in
Environmental
Impact Assessment
Michael Lawrence Elliott
Michael Elliott is an instructor and doctoral candidate in tlir
Department of L'rban Studies and Planning at the Massnchn
setts Institute o/ Technology, Cambridge, Massachusetts. In /all
1981, he U'lll be a I'. O. Key Fellow at the Joint Center for I'rbnn
Studies of MIT and Harrard Ihiwersity.
It may seem rotinieriimiiiive, but (be more effectively environmenial
impacts are specified, ibe more difficult the problem of choosing
among project or policy options becomes. Impact specification, if
done well, should cause decision makers loconsider tradeoffs (hey had
not previously considered. The more impacts enumerated in an envi-
ronmental assessment, the iidler the array of tradeoffs. The more
obvious the tradeoffs, the more complex the task of evaluation.
To facilitate the evaluation task of the decision maker, environ-
mental analysis have experimented with a wide variety of environmen-
tal impact statement (EIS) presentation techniques. The traditional
presentation technique of list ing all potential impacts is of I it lie use to
either decision makers or public interest groups. Many analysis, there-
fore, have attempted (o meet the information nerds of the EIS leadei by
summarizing and by directly comparing polity or project options
based on the significance of the impacts.
In the absence of scientific and political consensus about what
constitutes a desirable environment, analysis have found ibis task of
pulling the pieces together rather difficult. Scientifically, many quali-
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lies of the environment most relevant to public policy are those least
amenable to direct measurement, and many changes in qualities that
are measurable are not easily predicted. Politically disparate sectors of
the community perceive and value the same impacts differently.
Taken together, EIS data (particularly forecasts and evaluations) are
frequently scientifically inconclusive and value-laden.
EISs, however, can be informative without being completely
objective or value-free. To reconcile competing social goals, policy-
makers require information that discriminates between policy
choices. The simplification of environmental data can be misleading
unless it simultaneously clarifies the potential impact of each alterna-
tive. If an EIS is to reveal rather than obscure the choices available, the
assumptions behind the methods of data manipulation must be exam-
ined carefully.
This article, then, is about ways of manipulating EIA data-
ways that are analytically correct and ways that are faulty. More
specifically, the article focuses on how analysts convert disassociated
sets of predicted impacts (many of which are difficult to quantify) into
comprehensive indices of environmental quality. I am calling this
process amalgamation because the term best captures the pulling
together of many impact variables into a few evaluative indices for
presentation in an EIS.
To help us better understand the problems associated with
amalgamation, the EIA process used for the Jackson, Wyoming,
wastewater treatment plant will be described first. This process is
typical of the twenty-one environmental impact assessment processes
studied at the Massachusetts Institute of Technology (MIT) last
summer,1 with one important exception: the Jackson EIS is presented
in a concise format that employs a comprehensive method for amalga-
mating and evaluating impacts. The Jackson story is illustrative of
how and why amalgamative methods are used, as well as how an EIS
fits into the decision-making process. Using the case, we will lookata
wide range of amalgamative methods, and conclude with lessons that
can be drawn from the discussion.
THE JACKSON EIA PROCESS: KEY ANALYTIC PROBLEMS
Jackson is a rapidly growing city in the foothills of the Teton moun-
tain range.* The town is largely surrounded by federal land. Since
1972, the town's wastewater treatment plant had been out of com-
pliance with slate and federal regulations. The town could only grow
south, and so proposed to locate a new plant six miles to the south of
the town line, which would accommodate all future private develop-
ment in the Jackson-South Park area. Simultaneously, Teton County
was preparing a comprehensive plan and zoning restrictions, which
were expected to severely limit growth in South Park. The county
therefore argued that Jackson should upgrade its existing plant to
accommodate town growth only.
12 EIA
2/1
Because the wastewater treatment plant was to be built with
federal moneys on a wildlife preserve, an EIS was required. In addi-
-tion, the U.S. Environmental Protection Agency (EPA) saw the EIA
process as an opportunity to intervene in the dispute. EPA suggested
seven alternatives for the treatment of the wastewater. These included
two process methods (a mechanical treatment plant and a stabi lization
pond) at four sites, including Jackson's original proposal for con-
struction of an aerated lagoon in the South Park Elk Feedground.
Jackson preferred the feedground site because it would serve all future
development by gravity flow, thereby lowering opera ting and main-
tenance costs. The state-owned site also preserved the limited tracts of
private developable land for other uses. EPA, on the other hand,
recognized the severe growth pressure that a sewage treatment plant
and interceptor line could create on previously unserviced land and
was sympathetic to the county's efforts to manage future growth on the
uniquely scenic county land.
In 1976, the EPA Region VIII staff of the Environmental
Impact Assessment Branch launched into the EIA process (Fig. I).
While this article focuses on the latter stage of this process, even in the
initial stages analysts faced several key problems common to the
assessment of large-scale projects.1 Outer limits of impacts were diffi-
Figure 1. Steps followed in the environmental impact assessment
process of the Jackson wastewater treatment plan t project.
EIA REVIEW 2/1 13
-------
cult UMB^iiu e the project had mulli|>le effects, data on environmental
condi^Hp were not specifically collected for the assessment, and
institurTOiial boundaries did not always coincide with the location of
impacts. Alternatives had lo be generated even (hough guidelines for
selecting appropriate alternatives did not exist. Since environmental
conditions change even in the absence of any project, appropriate
baseline conditions had to be estimated. Expensive models and mea-
surements were required 10 precisely and accurately predict the magni-
tude and distribution of those impacts thai could be quantified. EPA
and two engineering consulting firms found that the effect of waste-
w;ilri iir.miu'iii on water quality and estimates of capital and main-
tenance costs could be quantified, but that most other impacts could
only be qualitatively described.
The analysts then entered the final stage of the EIA process, the
stage on which this article concentrates. In this stage, iheenvironmen-
tal information collected and analyzed is linked with the informa-
tional requirement of political decison makers. The analysis knew
that the administrator of EPA Region VIII would not wade through
disaggregated data on fish saved, elk herds redirected, and growth
induced.4 Tradeoffs among the EIS alternatives would not be obvious
if predicted impacts were listed without distinction as to their environ-
mental significance. To focus attention on the most important trade-
offs, predicted impacts (such as changes in dissolved oxygen and
turbidity) were amalgamated along fewer dimensions of concern (such
as water quality), with each impact and dimension of concern being
ei'aluated as to its significance.
Environmental analysts such as Eugene Odum of the Institute
of Ecology,5 Charles Solomon of the U.S. Army Engineer Waterways
Experiment Station,6 and Norbert Dee of Battelle Columbus Labora-
tories' have attempted to devise standard methods for amalgamating
many impact variables into a few, more comprehensible indices. Other
analysis, such as Wes Wilson of EPA in our Jackson case study, have
created more individualized methods to be applied to a specific EIA.
Each of these methods can be judged in part by its validity and clarity.
This article, without discussing all methods, discusses the basis for
devising or evaluating an amalgamaiive method.* Before specifically
describing the amalgamaiive method employed in the Jackson EIS, let
us first consider the problems with amalgamtion generally.
PROBLEMS IN AMALGAMATION
While amalgamation can greatly assist decision makers and the inter-
ested public to better understand tradeoffs, it is open to misleading
mathematical manipulations, which can cause problems. In the EIA
processes we studied,9 virtually all EISs were presented without any
attempt to amalgamate the hundreds of bits of information, or were
amalgamated in a manner that could easily lead to faulty or overly
confident conclusions.
II EIA REVIEW
Jarkson Area of Telon Couniy, Wyoming
c£i Existing Wastewater Treatment Plant Located on Flat Creek
A South Park Site
D Elk Feedground Site
KIA RF.VIF.W 2/1 lr»
-------
Amalgamation is diffit nil because ii requires thai I lit- signif-
iranrc of impacts be evaluated. Tlu* significance of impacts can be
(leicrminetl only if a common basis for comparing the magnitude of
predicted effects can be developed. A common basis for significance in
turn presupposes both scientific consensus on theory and political
consensus on value. Neither is readily available, particularly when
environmental impacts are being compared to (he nonenvironmental
costs and benefits of the proposed project. Thus, great care must be
taken to maintain the original data's uncertainly and diversity when
amalgamating data in an EIS.
Amalgamation involves the compression of information.
Amalgamation makes data more comprehensible by reducing driail.
that is to say, by discarding some information and rrorganifing what
remains. The result of amalgamation is a summary judgment about
how estimated impacts of a project will affect some dimension of
environmental quality. Consequently, proper techniques for amal-
gamation will depend on both how the impacts were first measured
and how environmental quality is defined. These are problems of
scaling and weighting, of magnitude and significance.
Because environmental quality cannot be directly measured,
analysts must rely on indicators of environmental quality that
can be measured or estimated. Each measure, however, is tailored to
the indicator in question. Consider the Jackson example. The EPA
analysis estimated flood damages and capital construction in dollars,
BOO and phosphorus load in milligrams per liter, the elks' wintering
habitat and agricultural land in acres, and growth pressures in "signif-
icance" of effect. How can Jackson's Elk Feedground stabilization
pond proposal be compared to the alternative that upgrades the exist-
ing wastewater treatment plant? How can dollars and milligrams be
compared to acres and unquantified "pressures" when a hundred
indicators and measurements must be considered?
Proper amalgamation of several impact indicators into one
dimension of concern requires consideration of both magnitude (scal-
ing) and significance (weighting). The magnitude of an impact is the
measured or predicted change in_the environment. The effect of Jack-
son's waste water treatment plant on dissolved oxygen (DO), for ex-
ample, can in principle be estimated with some degree of certainly.
The magnitude of changes in DO for each alternative can be directly
compared. On the other hand, magnitudes of DO and phosphorus
cannot be directly compared or aggregated. To aggregate DO and
phosphorous into a -single dimension of concern (water quality), a
common scale of magnitude must be applied to each impact variable
and a model of significance must be used to weight the relative impor-
tance of each variable. Only then can the magnitudes of the two
variables be combined. Thus, the analyst must consider issues of both
scaling and significance in any process of amalgamation that starts
with more than one impact variable. These issues are not easily
16 EIA RE
sWw
2/1
resolved since great uncertainly remains within the environmental
sciences, and public interests frequently disagree on definitions of
. environmental quality.
SCALING THE MAGNITUDE OF IMPACTS
Scaling is based on the levels of measurement used to predict the
magnitude of each variable. There are four levels of measurement:
nominal, ordinal, interval, and ratio. Nominal measurements offer
the least precise information and ratio the most precise. Amalgama-
tion is valid only if the new composite scale is no more precise than the
least detailed data scale. Reseating data using inappropriate mathe-
matical functions or assigning nominal scaled data to ordinal or ratio
scaled dimensions of concern may lead to significant errors in
amalgamation.
Nominal Scales
The least flexible level of measurement, the nominal scale, assigns
data into categories. For example, the Jackson EIS categorizes land use
into residential, agricultural, wildlife, and commercial zones. Nomi-
nal data can be reclassified into oilier nominal scales, but no malhe-
matical operation can be performed. Nominal data can also be
assigned to ordinal scales if the desirability of each category can be
rated or ranked. If preferences among categories cannot be deter-
mined, the nominal data cannot be compared.
Nominal scales require the least amount of quantification and
measurement and hence are used to classify variables that are difficult
to quantify. EISs are filled with lists of varieties of wildlife, yet rarely
provide bird counts, nor indicate preferences for trumpeter swans over
peregrine falcons. Likewise, changes in land use, displacement of
archaeological sites, rare and endangered species, natural hazards, and
many cultural and political patterns are either listed or classified, but
not quantified.
Nominally scaled data can only be amalgamated by combining
precise classifications of bald eagles and snail darters into composite
classes of birds and fish. Consequently, nominally-scaled impacts are
frequently dropped from amalgamations. An inherent bias is intro-
duced when unquantified or imprecisely quantified data is over-
looked. Summaries that highlight unquantified data can usefully
accompany presentations of more quantified amalgamation
techniques.
Figure 2 shows an informational display technique used in
several EISs to summarize nominal data. The display technique com-
bines verbal descriptions with analytic quantifications and allows all
forms of data to be summarized in one table. Obviously, as the number
of variables and alternatives increases, these tables can become very
complex (see Fig. 4). In addition, comments are needed to communi-
cate the potential significance of each variable. Despite it
EIA REVIEW 2/1 17
-------
Figui
An example of information organization used in the
HaverhiJI, Massachusetts. Resource Recovery Plant EIS.
The original chart included three additional alternatives!
The information is presented inconsistently. Biological
impacts are ranked, noise impacts are rated, air quality is
described, and economic impacts are quantified. How do
all these impacts relate to each other? Certainly more
consistency was possible, and a comment column could
have related the significance of each impact group to the
other impacts. (From M. Schippereit, E. Williams, and H.
Yaffee. "Site Evaluation for the Northeast Massachusetts
Resource Recovery Project." MITRE Corporation,
August 1977.)
Steam Martcta
Air Quillty
Note. DEQE
lydrofeotofy
Wtllindi. DEQE)
Water Mlu Uon
:ontrol, DEQE)
Water Reaourcea)
Biological Impacli
Flaheriei It Wildlife
Impacli
»l
Lowell
Surrounded by
residential
area*. Impact
would be in
Downtown Lowell
given the pre-
vailing weiter
ly wtndl. Ac-
ceptable, but
a relatively
poor choke.
Moderate Impact
rotential In-
volvement wllh
Wellandi. ProL
Act Small]
No rVoblenu)
#6 - Lagoon Re-
ub-ei Dralnlni)
»l - Acceptable
un Value
avbigi - fl.70
Inemployment
ate • 6.6%
#J
Metbuen
Near Lawrence
but ihould not
Impact aignifl-
cantly on the
City due to the
prevailing wmda.
Near the N.H.
border, but will
have little to-
pact n N.H. for
the lame reuon.
Abo. reilden-
till area adja-
cent to ilte.
Minor Impact
Potential In-
volvement Small)
Dralnaf e Would
Apparently Re-
barge Wellanda
or Go to Spick-
II River)
#1 - Moderately
Favorable)
« - Acceptable
FuIIVahie
•vim, - 12.80
Unemployment
Rale - 7.9%
#6
Bhby Intl.
Impact would be
fa Newburyporl
population cen-
ter, em and
generally down-
wind of the
die. Air qual-
ity m the area
b|oo
-------
focus. Simpler presentations, such as shown in Figures 2 and 8, are
easier to read because they summarize information at a less detailed
level. The proper choice of detail will of course vary among impact
assessments, but in general an overly difficult table only creates confu-
sion. If a table contains complex, detailed information, the preparers
should consider breaking the table into several charts and highlight-
ing important impacts with comments..
Figure 3. Summary chart from the New York Southern Tier
Expressway EIS. The original chart compared eleven
alternatives by ranking each alternative within each
problem and impact area, and then adding the ranks for a
total score. These ranks and scores are shown for four
alternatives as the numbers outside the parentheses.
Consider what would happen if we used this scoring
. method to rank only these four alternatives. The results of
the new ranking are shown in bold type within the
parentheses. We note that concept 6 now ranks behind
concept 10 and that concept 2 ranks behind concept 9.
Why did this happen? Also note that environmental
impacts is only one of seven classes of problems and
impacts. Concept 6, which ranked first out of eleven
alternatives, ranked tenth in environmental impacts. In
poker a chart like this would be called a stacked deck.
(Department of Transportation, Federal Highway
Administration, Southern Tier Expressway Study,
Albany. New York, September 1977.)
Concept! Concepts CoKtptf Concept 10
MOSLEMS:
Improve depravrd
economy
Improved dcprcued
employment and Income
Improve community
Krvicct
Improve travel
ufety
IMPACTS: '
Economk
Social
Environmental
TOTAL PROBLEMS
AND IMPACTS
RANK
Improve
all rill
.tcrvkca
• w
1 W
10 (4)
> m
» m
5 (3)
s m
44 (II)
Slh(4lk)
Completion
of Sou them
Tier
CkprcuwAy
i <>)
*(»)
4(t)
3 (1)
1 (0
« (4)
10 (4)
n (is)
lit (Snd)
Incnued
but
•ervlcct
10(4)
* (4)
1 (3)
' (*)
10(4)
3 (*)
1 «)
4S (SO)
lOlb(Srd)
Induitrial
development
programs
4 (D
1 (D
I ID
10(4)
4 (*)
1 (D
31 (14)
4lb(lat)
• Light numbers score all eleven original alternatives. Bold
numbers rescore four of the alternatives.
20 EIA REVIEW 2/1
Figure 4. Summary chart from the United Kingdom North West
Water Authority Regional Water Resource Studies report.
The three alternatives displayed here are examples of the
fifteen contained in the original. Summary charts of this
complexity provide little understandable information for
decision makers and the public. (North West Regional
Water Resources Studies, Environmental Appraisal of
Four Water Resource Schemes, Report of the
Environmental Impact Study, United Kingdom,
November 1978.)
tO*m* *i*nab Ant. Otftk im*.
.-"•I-I
0»
mr*
aiktlr Mo> HrllilkU'Millo* m lii«ln>nn
I«"•!»-I
• l«M»t bltnm •
0»
0»
Ua» • Mo- Lo» fc.iu.fc Mg/tUllo.
• Strategic long term irreversible
D Strategic long term revenible
• Local long term irreversible
O Local long term revenible
O Short term reversible
A Beneficial
V Adverse
? Area of uncertain impact
Interval and Ratio Scales
Interval, or continuous, scales are quantitative. Intervals between
units of measurement are constant. Ten exceeds nine exactly as much
as two exceeds one. However, the zero point is arbitrary. Measurements
of the dissolved oxygen deficit of Jackson's Flat Creek is an example of
an interval scale. While at any point in time an assessor can estimate
the deficit, to do so he or she must arbitrarily select a point of zero
deficit. The zero point depends on the aquatic life, mechanical fea-
tures, and temperature of the stream. A deficit of two is not twice as big
as a deficit of one, since by redefining the zero point the two and one
may be transformed into a five and four. Only mathematical opera-
tions that do not affect the relative differences between units can be
employed, division or multiplication by a constant, additioiL sub-
traction, integration, and differentiation fulfill this
EIA REVIEW 2/1 21
-------
tio scales are also quantitative. In addition to constant inter-
n units, ratio scales also have nonarbilrary zero points. The
total amount of phosphorus released into Flat Creek is a ratio-scaled
measurement. The zero point is fixed at the point of no release. All
mathematical operations, including multiplication by a variable,
power functions, and log transformations, are analytically justifiable
in ratio scales.
Analysts typically quantify a number of environmental condi-
tions using interval and ratio scales; water and air quality indicators,
project costs, and engineering data are common examples. Each indi-
cator quantifies the magnitude, not the significance, of impact. Attri-
butes are measured along interval or ratio scales that are tailored to
each impact. For example, area can be measured in square miles,
hectares, or acres. Two different attributes cannot therefore be amal-
gamated by simple addition. Addition would allow a characteristic
measured in large absolute numbers (e.g., square miles) to dominate
the comparison and would be arbitrary since a simple linear reseating
of the units (from square miles to acres) could reverse the apparent
comparative value of two alternatives. Amalgamation requires the
creation of a common scale, a scale consistent with judgments about
the relative significance of the variables and along which both attri-
butes can be measured.
Two approaches to the unequal interval problem have been
developed by environmental analysts:11 standardized proportions and
quality scaling. Proportions are calculated using a standard level
selected by the analyst. The standard can be a target level (possibly
established by environmental regulations) or the highest value of each
dimension that is forecasted among the alternatives. The latter is not a
reliable method since the inclusion of a new alternative can change the
rank order of the original alternatives. Without theory to set target
levels, the standardized proportion method is arbitrary.11
To create standardized proportions, the value of each forecast is
divided by the standard level. The Oak Ridge Air Quality Index
(OR AQI), for example, amalgamates forecasts of the concentrations of
five air pollutants by converting each of them to proportions of federal
standards, adding the five scores, and then rcscaling the resulting
index to range between ten for "unpolluted" and a hundred for "com-
pletely polluted" air.M The standardized proportions method assumes
that environmental quality decreases linearly as impacts increase. The
assumption is questionable since many environmental impacts have
threshold or synergistic effects.
Impacts can also be standardized using a postulated quality
scale. The Battelle environmental evaluation system for water-
resource development uses this procedure.15 Each dimension is calcu-
lated and converted into a rating, which varies from zero (poor
environmental quality) to one (good environmental quality). As
shown in Figure 5, the value of the rating may vary nonlinearly or
22 EIA REVIEW 2/1
Figure 5. Examples of environmental value functions from the
Baitelle environmental evaluation system: (a) terrestrial
carrying capacity for browsers and grazers; (b) dissolved
oxygen, assuming 9 mg/l as saturation. How would you
evaluate these functions? Consider the discussion of
dissolved oxygen in the section titled Preferences. (N. Dee
et al., Environmental Evaluation System for Water
Resource Planning. Final report prepared by Battelle-
Columbus for the Bureau of Reclamation, January 31,
1972.)
1.0
0.8
0.6
0.4
0.2
20 40 60 80 100%
Percent of canybif capacity bated OR animal unit*
10 m./l
nonmonotonically relative to observed measures. The impact of an
action on the quality of the environment is measured as the change in
the score along each dimension before and after the decision.
These standardized methods of rescaling introduce specific
notions of "goodness." The ORAQI index is set against external
targets. Baitelle standardizes a measure of quality against which the
impacts are scored. Notions of "goodness" cannot be determined
solely from scales of magnitude. They emerge from explicit (or
implicit) judgments about the significance of a variable. Combining
several variables into a common dimension of concern requires not
only careful scaling of magnitudes (as discussed in this section) but
also careful estimation of significance.
EVALUATING THE SIGNIFICANCE OF IMPACTS
Preferences
The amalgamation of impacts produces an overall ranking of prefer-
ence, not a composite measure of impact. This distinction is impor-
tant. Amalgamation of several impact variables into a common index
involves judgments about the relative importance of each variable.
EIA REVIEW 2/1 23
-------
These judgments, once injected into the EIA process, are indicative of
a preference for specific qualities of the environment.
Consider the following example. Dissolved oxygen (DO) is an
important indicator of water quality. Yet, not all groups equally
prefer the qualities that a high DO level indicates." While complete
oxygen depletion creates a lake unfit for either fish or humans, high
levels of DO do not necessarily make the water more inviting. Ecolo-
gists may be equally concerned with nutrient levels that could create
algal blooms when DO is increased. Swimmers will equally avoid
disease-carrying organisms, toxic chemicals, and turbidity. Boaters are
concerned with visual and olefactory qualities of water and with
material floating on the surface. Industrial users actually prefer a low
DO level because pipes rust in the presence of oxygen. Thus, many
indicators may be used to measure water quality and each is likely to be
important to different groups. Environmental impacts can be scientif-
ically estimated against some standard of quality, but a standard of
quality cannot be set except as a function of what individuals or
groups prefer or value.
Preferences also depend on risk. The evaluation of significance
is therefore complicated by the environmental analyst's frequent
inability to prove causal relationships or accurately estimate changes
in baseline conditions. The greater or more uncertain a risk, the more
significant an impact may be evaluated. Unfortunately, few assess-
ment techniques are explicit about risk and uncertainty.
Formal techniques for determining the relative significance of
probable environmental impacts must be logically consistent with the
types of scales along which the impacts are measured. Different tech-
niques can be used to incorporate judgments about significance into
nominal, ordinal, interval, and ratio scales. Because, as we have seen,
some mathematical operations are valid only for interval or ratio
scaled data, techniques applicable to ratio scales are not necessarily
applicable to nominal scales and vice versa. In the EIA process, tech-
niques for determining significance generally fall into the two catego-
ries of screening and weighting methods.
Screening
Screening consists of "knocking out" alternatives that exceed a preset
level of impact along a particular dimension. The preset level may be
derived from a legal standard or from an analysis of the political
realities in a given situation. For example, an oil refinery site that
threatens an endangered species of bird might immediately be elimi-
nated no matter how attractive other aspects of the site were. Exclu-
sionary screening is inexpensive and requires relatively simple data.
Nominal scales can be used for screening purposes. If dimen-
sions of impact can be ordered by significance, alternatives can be
screened by the most important dimension first, the next most impor-
tant second, and so on until the number of alternatives has been
24 EIA REVIEW 2/1
narrowed.17 Thus, we may exclude from consideration all sites that are
located in marshlands or in residential zones. Ordinally scaled data
can also be evaluated using screening methods. Project or policy ob-
jectives can be arrayed in order of significance. Options are then rated
against each objective. The results of such evaluations can be dis-
played in a matrix such as is shown in Figure 6. Alternatives can then
be compared to each other, although not against an objective standard.
A set of noninferior options can be selectd by retaining alternatives
that dominate other alternatives across all dimensions.
Figure 6. Summary table in site screening used in thcTAPCO LNG
Plant and Pipeline EIS. Fourteen sites were evaluated on
this chart. All but three received a "very poor" in at least
one factor and were screened out by this criterion.
Screening can oversimplify the decision making process.
Option 12c is equal to or superior to4a and 12b in all but
one impact area, yet this option was screened out while the
others were retained. A more reliable but less discerning
method of screening is by dominance. Option I could be
eliminated since in no impact area is it better than option
2a. (Tenneco Atlantic Pipeline Company el al., Draft
Environmental Impact Statement for the TAPCO Project,
U.S. Federal Power Commission, 1977.)
o
o
FKIM*
i«f«r
UMt>fm»Mckclund
Itlarie coadUtau
ComratcKr* fi
of AccK«u fi
Ship irndi ikM
Key
O Excellent
(3 Good
3 Fair
9 Poor
• Very poor
EIA REVIEW 2/1 25
-------
ling can be used to eliminate obviously unacceptable
s, but it should be used with care. Screening can easily
oversimplify reality. Nominal scales assume homogeneity within cate-
gories and step-function differences between categories. Important
differences, however, could be hidden within categories. Moreover,
statistical uncertainties that surround environmental analysis and
possibilities of mitigating impacts by.altering project designs can
make the distinction between screened and unscreened alternatives
dubious. Figure 6 demonstrates the problems of oversimplification
more fully.
In general, it is best to remove only those alternatives domi-
nated by other alternatives unless there is sufficient reason to act
otherwise. Screening should not be used as a presentation device when
the unscreened alternatives will not be further analyzed. Such screen-
ing unnecessarily simplifies the alternatives presented to the decision
maker and to the public.
Weighting
Amalgamation of several variables into a composite dimension of
concern is a common EIS presentation technique. Amalgamation
requires judgments about the relative weight (or significance) of each
variable's contribution to the dimension of concern. Weights are not
necessarily quantitative; ordinal comments such as "variable A is the
most important factor to consider in evaluating the alternatives" also
weight the significance of impacts. However, weights cannot be used
in amalgamation unless they are quantitative since amalgamation
requires the mathematical manipulation of data. In like manner, the
impact factors being weighted must also be quantitative (that is,
interval or ratio scaled).
The most commonly developed evaluation systems are based on
weighting-summation models. These models take the general form of
U(F)
n
2
w(f,
where
U(F) = desirability or utility, either along a composite
dimension of concern (such as water quality) or along
an overall index of environmental quality,
w. = the i'h weight, and
f. = the i* impact factor.
Because the EIA process rarely produces ratio scaled data, several
restrictions apply to the weighting-summation model. Interval scaled
variables cannot be multiplied by a second variable. Such multipli-
cations are unreliable since by moving the arbitrary zero point of the
interval scale, the rank of alternatives can be changed. Models of
26 EIA REVIEW 2/1
interaction and nonlinearides require multiplication of two variables
and are therefore invalid for interval scaled data. Ecological and
preference interaction models cannot be incorporated, nor can non-
linear risk aversion models. Since environmental preferences are fre-
quently the product of interacting factors, and decison makers are
rarely risk neutral, the linearity assumption is usually invalid.
Along the same line of reasoning, the weights must always be
ratio scaled. Weights are multiplied by variable impact scores and are
unreliable if scaled with an arbitrary zero point; Yet few methods for
determining significance are careful about setting the zero point.
Nonarbitrary zero points of desirability are created by answering the
question: "Is the ratio of points X and Y a correct indicator of the ratio
of desirability of those two factors?" More concretely, "Do I really
prefer a factor scored at four twice as much as another factor (or
alternative) scored at two?"
Despite the logical difficulties associated with the weighting
summation model, methods based on this model are often used in
amalgamation. The weighting of impacts usually proceeds as a var-
iant of the process shown. The magnitude of variables is standardized,
the significance of variables is weighted, the two are multiplied, and
all products are added to produce a composite index. The resulting
index is not an impact magnitude; it has no independent value and can
only be used to compare different alternatives similarly indexed. Abso-
lute differences between alternatives are lost in the index.
This reduction of absolute data to a relative index may not help
decision makers who must later incorporate nonenvironmental fac-
tors into their decisions. Nonenvironmental data will not be similarly
indexed, and cannot be easily compared. Tradeoffs once incorporated
into a weighted-summation analysis may be difficult to trace. Neither
decision makers nor the public may be aware of the consequences of
particular weights. Furthermore, significance, as a measure of prefer-
ence, can only be determined from the viewpoint of a particular class
of people. In the absence of social theories for analytically combining
different viewpoints, amalgamation across groups is not possible.
Amalgamation across viewpoints is a political problem. Therefore, to
amalgamate only into dimensions of concern (such as air or water
quality) is generally preferable. Where differences of preference exist
within a dimension of concern, an analysis of the sensitivity of the
index to different assumptions should be provided.
There are a number of methods for selecting weights, some
more theoretically valid than others. Ranking and rating are the least
precise of these methods; decision analysis is among the most precise.
The methods fall into two categories: client explicated methods that
query various groups about what they value, and observer derived
methods that use multiple regressions of observed behavior to calcu-
late weights. Hobbs and Voelker provide an excellent review of these
weighting schemes."
EIA REVIEW 2/1 27
-------
THE JACKSON WASTEWATER TREATMENT PLANT
REVISITED
The cnviromnenial analysis who produced (he Jackson EIS
approached (he problem of presentation with care. Most importantly,
they wrote a clear, concise draft EIS of two hundred pages. But the EPA
piojeci manager fell that an explicit comparison of the alternatives
was needed 10 convince the EPA Regional Administrator to reject the
town's proposal.19 The evaluation matrix and rating system shown in
Figures 7a and 7b were therefore included in the draft EIS. The matrix
is both a professional judgment about potential impacts and a politi-
cally motivated summary statement about preferred alternatives. The
draft EIS was designed to assist EPA in (he partisan debate between
Jackson and Teton County. The evaluation matrix, while a creative
attempt to deal with the problem of amalgamation, underlines the
difficulties of this operation. Before moving to the next section, take a
few minutes to examine the matrix in Figure 7a. Can you see what the
difficulties are?
Problems with the EIA Matrix
Perhaps as you examined the matrix you noticed that mathematical
operations are used incorrectly. The rating system and the weights are
treated as if they are interval scales. The mathematical operations of
addition and multiplication are employed. However, scales that
assign variables into minor, significant, or major impact classes are
ordinal, not interval. The addition or multiplication of ordinal data is
misleading. A single impact that results in major long-term and
extensive adverse damage is likely to be more significant than five
minor adverse impacts over limited areas. Yet both will yield ratings of
five when added.
Of equal importance, the matrix is dominated by EPA's oppo-
sition to growth in rural South Park. The lowest scores were invar-
iably given to options that opened (he most land to development.
Jackson's proposal received the lowest scores becaue the Elk Feed-
ground site woidd induce the most growth. The impacts of urbaniza-
tion are repeatedly incorporated into the matrix as separate impact
areas; induced development cost, loss of agricultural productivity,
regulatory/legal, aesthetic values, adherence to the planning process,
growth inducement, and growth regulation are all alternative con-
cepts for the same Urbanization effects. These seven impact areas
a< count for one-third of the impact variables and approximately two-
thirds of the points scored negatively by the proposal. By repeatedly
incorporating these variables and scoring them as they did, the EPA
analysts were showing (heir cleardispleasure with the possible urbani-
zation of South Park. The town council of Jackson, on the other hand,
fell (hat a desirable South Park environment was an urban environ-
ment. Clearly this conflict of values is buried in the EIS evaluation
matrix.
28 HA RKVIF.W 2/1
S!V'..';..
;j*«r*w."-**'j ;>.«
The terrain of South Park and the Elk Feedground is
open, flat rangeland. In the early 1970s, the county
government sought to preserve the agricultural and
wildlife character of the area, while (he town council
favored its development.
Aftermath of the Jackson Draft EIS
In July 1977, three months after the EIS draft was released, Jackson's
town council announced its approval of a new South Park site for the
wastewater treatment plant—on private lands immediately north of
the Elk Feedground and the former site. The EPA matrix (see South
Park Road option shown in Fig. 7a) shows this site to be the second to
worst alternative. The council majority gave little consideration to
alternatives suggested in the Draft EIS. The council wanted the plant
constructed as far south as possible to serve future development in
South Park by gravity flow interceptor lines.*0
Four options, which according to the Draft EIS were the
second, third, fourth, and fifth best alternatives, were eliminated from
further consideration. The expansion of the existing plant alternative
(scoring best in the EIS and preferred by EPA and the county) and (he
southern South Park alternative (scoring sixth in the EIS and preferred
by the town council) received continued attention. During the summer
of 1977, EPA Region VIII staff became increasingly aware of Jackson's
commitment to urbanization. Early efforts by EPA project officer Wes
Wilson failed to open discussion; town officials considered Wilson
biased toward the county's preservationist position.
EPA's role in the dispute changed markedly with theSe
1977 appointment of Alan Merson as Regional
F-IA REVIEW 9/1 90
-------
Figur
A simplified version of the Jackson EIS Environmental
Evaluation Matrix. The original matrix included
evaluations of four alternatives not shown in this figure.
(U.S. Environmental Protection Agency, Region VIII,
Draft Environmental Impact Statement, Jackson
Wastewater Treatment System, Town of Jackson,
Wyoming, Denver, Colorado, May 1977.)
Figure 7b.
NATURAL ENVIRONMENTAL VALUES
Ab Quality (localbed)
Water Quality (whet)
Wild Quality (pound)
Wildlife
Fbhcriei
Vegetation and Habitat
Rare and Endangered Spcclea
Natural Huardi
TOTAL
ECONOMIC VALUES
Local Capital Con
O It M Coil
Induced Development Coiu
Individual Cost
Lew of Af. Productivity
TOTAL
SOCIAL-CULTURAL VALUES
Htttorlc-Archaeological
Public AcceplabBltr
Regulatory /Legal
Cultural rattero (life atyle)
Aenhclfci Valuei
Recreational Valuei
TOTAL
LAND USE PLANNING VALUES
Adherence to the running Proc.
Growth Inducement
Growth Regulation
TOTAL
.
\A Y*A
•13
-22
a*
•tt
yy*
10
-12
*/•*/>
*/*/*
18
II
•5
-22
/.*/+
-16
-w
*•*/*
-12
'/*/•
'/•*/,
-17
•7
The ordinal rating system used in the Jackson EIS.
±5 Major long term, exlemive effect.
±4 Major effect, but characterized ai either ihort term or of
' limited extent.
±3 Significant effect; either long term covering a limited area,
or thort term covering an extemive area.
±2 Minor effect, but of a long term or extentive nature.
±1 Minor effect over a limited area.
0 No effect.
30 EIA REVIEW 2/1
To construct the evaluation matrix, impact variables were
scaled into dimensions of concern using the rating system
shown in 7b. The system was developed by EPA and their
consultants and is based on an ordinal scale. What does
this imply for amalgamation? The ratings were
judgments of significance produced by the analysts.
Primary and secondary impacts were rated for each
environmental impact variable. The evaluation matrix
presented in 7a shows these ratings in the upper and lower
corner of each box. The grey box shown in 7a indicates a
primary impact of -3 and a secondary impact of -2. The
relative importance of the environmental impact variable
to the decision-making process is weighted from I (little
significance) to 3 (extraordinary signifance) in the last
column. The weight for "wildlife" is 2. The weighting
factor is multiplied by the sum of the primary and
secondary impacts to produce a weighted score for each
alternative. Thus, the grey box shows us that the proposed
Elk Feedground Site received a Wildlife score of -10
because 2[(-2)+(-3)] equals -10. The specific impact
categories (i.e., wildlife) are then added to produce a sum
for the general value category (i.e., natural environmental
values). These sums are then compared. This evaluation
matrix, while a creative attempt to deal with
amalgamation, underlines the difficulties of this
operation. Before returning to the text, examine the
matrix carefully. Can you see what the difficulties are?
Region VIII. Former administrator Green had been following staff
advice to threaten withdrawal of 201 funds if Jackson did not agree to
expand its existing plant. Merson was reluctant to threaten Jackson
without first exploring other possibilities with town and county offi-
cials. He also sensed that an EPA-mandaled action would only delay
compliance, and he realized the political costs to EPA of a noncomply-
ing plant in a scenic, heavily-visited area such as Jackson Hole.
EIA REVIEW 2/1 31
-------
Finally, Merson also believed thai South Park would develop rapidly,
the county plan notwithstanding. Merson feared that Flat Creek's
water quality would suffer if South Park development was served by
package plants and individual septic systems.
Recognizing that serious differences still remained between the
two parties, Merson in mid-December 1977 hired Andrew Briscoe, of
the planning firm Briscoe, Murray, Muphis.and Lamong(BMML), to
negotiate a settlement between the town and county. On April 13,
1978, an agreement to accept the South Park site was reached. The
agreement specified plant size and design capacity, empowered the
county to limit annual out-of-town sewer hookups as part of its
comprehensive plan, and required the town to base out-of-town hook-
up policies on a specified set of customer classes, and sewage hookup
fees on a "full-cost pricing" system—both policies subject to EPA
review and approval.
Like so many projects, agreement on the Jackson wastewater
treatment plant required negotiations and compromise. The draft EIS
provided much of the analysis on which negotiations were eventually
based, but it did not clarify the issues nor incorporate different view-
points. The impacts predicted in the EIS were amalgamated based
only on the EPA analysis' judgments of significance. EPA's judgment
was too narrow. It did not allow for uncertainty (such as whether
South Park would develop with or without the proposed wastewater
treatment plant) nor for alternative values (such as the town council's
urbanization preference), and it employed invalid operations to
manipulate data (such as addition of ordinal data). The EPA analysts,
working hard to produce a concise EIS, fell into several of the traps
common to most EISs that use amalgamation. These traps, while
common, are not inevitable. The next section will review the discus-
sion on amalgamation, and suggest ways of using it to produce more
accurate and informative EISs.
SUGGESTIONS ON THE USE OF AMALGAMATION
As the Jackson case makes quite clear, alternatives are eventually
chosen not by optimization but by the interaction of interest groups.
Confrontation, negotiation, mediation, and compromise are the final
arbiters.11 For a political decision, well-structured information on a
range of alternatives is needed. Since amalgamation simplifies details
as well as interprets the data, amalgamate only to the extent that it
facilitates comparisons of policy options. Selective use of amalgam-
ation to highlight significant problem areas and tradeoffs among
interest groups is an important aid to decision makers. Indescriminate
use of amalgamation, however, obscures problems and hides tradeoffs.
Amalgamation implicitly involves value judgments. Whenever
impacts are rescaled and combined into more concise dimensions of
concern, describe the original impacts in the units in which they are
measured in a second summary chart. An attempt at displaying
facilitate comparisons is shown in Figure 8. Also, describe
riitt i
* « 2~S
6 J 1*1
jas^is
•f* M M -JT.X —*
iillil i
If"-9
^ ^.S 2 i
•a «j •« S c
32 E1A REVIEW 2/1
EIA REVIEW 2/1 33
-------
the ^fen for amalgamation. When individual impacts are displayed
in tl^PIr form, present the significance of each individual impact in
the same table. A column for comments may be usefully employed to
indicate the importance of individual impacts.
Give special care to the summary of nominal (named or catego-
rized) data. Such data cannot be amalgamated (since they are not
quantified), and thus are easily forgotten. Make certain that attention
is focused on unquantified values in summary tables.
Avoid amalgamating interval or ordinal data into nominal
scales. If criteria are established to judge the significance of an impact,
indicate the extent to which the criteria are exceeded. Simple yes/no
scoring is of limited use to decision makers.
Express ordinal scales alphabetically (A, B), verbally ("signifi-
cant," "slight"), or symbolically (I , ?). Avoid the use of numerical
scales because they create the temptation to add the rankings across
categories. Since ordinal scales do not account for the absolute magni-
tude of individual impacts, any mathematical manipulation is inap-
propriate. Frequency distributions are the most common method of
amalgamation.
Ordinal scales that rate the relative difference between impacts,
rather than simply ranking their order of importance, are generally
preferable. More information is contained in the statement "Alterna-
tive A has a serious effect on water quality while Alternative B has no
effect" than in the statement "Alternative A has a more serious effect
on water quality than does Alternative B."
When using interval data, take care to differentiate between
magnitude and significance. The magnitude of a specific impact may
be a poor measure of community preference or ecological vulnerabil-
ity. Amalgamation of interval data can be accomplished if the relative
significance of several variables can be weighted. Since weighting
implicitly involves value judgments, explicitly identify the process of
arriving at weights. The views of affected partiesare important sources
of value identification. When expert judgment is employed, identify
the expert along with his or her affiliation and the basis for making the
evaluation. Avoid the temptation to over-amalgamate.
Clearly indicate the degree of uncertainty in professional or
community judgments in the body of the EIS and in the summary.
Highlight uncertainty, interactive effects, or lack of data and their
possible repercussions. Show differences in impacts over time when
impacts accumulate, when projects are staged, or when environmental
conditions change. Demonstrate the implications of giving greater
weight to one type of impact over another. Also show the sensitivity of
the analysis to changes in the assumptions.
Finally, careful analysis is a necessary but not sufficient crite-
rion for writing an effective EIS. There are a vast number of methods
for determining significance and for amalgamating. The most effec-
tive are those that not only use techniques that are valid and reliable,
34 EIA REVIEW 2/1
but also explicitly examine the range of values that ex
communities.
our
ACKNOWLEDGMENTS
The case studies of twenty-one assessments from which material was
drawn for this article were prepared for Environmental Resources
Limited of London. Special thanks to my four colleagues Lawrence
Susskind, Julie Wondolleck, and John Horberry of MIT and Alan
Weinsteinof the University of Wisconsin at Milwaukee, toSteven Hill
for his help in researching the Jackson, Wyoming, case, and to
Michael Bever and Rebecca Packard for their helpful comments.
NOTES
1. A team of five U.S. researchers examined twenty-one U.S. and
Canadian environmental impact assessments (see
Acknowledgments). An additional sixteen case studies were
conducted in France, Germany, Norway, Sweden, and the
United Kingdom by Environmental Resources Limited. A
more complete description of the study can be found in
Environmental Resources Limited (ERL), Environmental
Impact Assessment: Studies on Methodologies, Scoping and
Guidelines, Final Report (Prepared for the Ministry of Health
and Environmental Protection of the Netherlands by ERL,
London, January 1981).
2. The Jackson, Wyoming, case study is based on the following
sources: Steven Hill, "201 Grants for Municipal Wastewater
Treatments: Mediating an Intergovernmental Dispute in
Jackson, Wyoming" (Draft paper prepared for the U.S.
Environmental Protection Agency through a project at MIT,
July 1980); Steven Hill, personal communication, 1980; Phil
Hocker (Sierra club spokesman and head of "Citizens for the
Plan"), personal communication, 1980; U.S. Environmental
.Protection Agency (EPA), Region VIII, Draft Environmental
Impact Statement, Jackson Wastewater Treatment System,
Town of Jackson, Wyoming, EPA-908/5-77-002, May 1977.
U.S. EPA, Region VIII, Final Environmental Impact
Statement, Jackson Wastewater Treatment System, Town of
Jackson, Wyoming, EPA-908/5-79-001 B, February 1979. U.S.
EPA, Region VIII, Record of Decision: Jackson Wastewater
Treatment System, Town of Jackson, Wyoming, EPA-908/5-
79/001 C. April 1979; Wes Wilson (Project Officer, EPA Region
VIII), personal communication, 1980.
EIA REVIEW 2/1 35
-------
3. For a discussion of the key analytic problems found in the EIA
process, see Craig Miller and Michael Bever, Assessing the
Environmental Impacts of Resource Recovery Facilities
(Laboratory of Architecture and Planning, MIT, Cambridge,
1978). and Lawrence Bacow, "The Technical and Judgmental
Dimensions of Impact Assessment," Environmental Impact
Assessment Review 1, no. 2 (June 1980): 109-24.
4. Wes Wilson, personal communication, 1980.
5. Institute of Ecology, Optimum Pathway Matrix Analysis
Approach to the Environmental Decision Making Process
(Institute of Ecology, University of Georgia, Athens, Georgia,
1971). Eugene Odum et al., "Totality Indices for Evaluating
Environmental Impact" in Environmental Impact
Assessment, ed. Marian Blisset (Lyndon B. Johnson School of
Public Affairs. University of Texas, Austin, Texas, 1976).
6. Charles Solomon, et al., Water Resources Assessment
Methodology (WRAM): Impact Assessment and Alternative
Evaluation" (U.S. Army Engineer Waterways Experiment
Station, Vicksburg, Mississippi, February 1977).
7. Norman Dee et al., "An Environmental Evaluation System for
Water Resource Planning," Water Resources Research 9, no. 3
(June 1973): 523-35.
More detailed discussions of specific amalgamative methods
are available to the interested reader. A recent study by the
author produced an inventory of thirty different methods for
amalgamating impacts and determining their significance.
The best known include Battelle's Environmental Evaluation
System, Rolling's Adaptive Environmental Assessment, the
Institute of Ecology's Optimum Pathway Matrix Analysis,
Leopold's Matrix Procedure, Hill's Goal-Achievement Matrix,
McHarg's Overlay Technique, and the U.S. Army Corps'
Water Resource Assessment Methodology. Three good
discussions of these and other methods can be found in (a)
Brian Clark, Ronald Bisset. and Peter Wathern,
Environmental Impact Assessment: A Bibliography with
Abstracts (New York: Bowker, 1980); (b) Donald McAllister,
Evaluation in Environmental Planning (Cambridge, Mass.:
The MIT Press, 1980); and (c) Robert Nichols and Eric Hyman,
A Review and Analysis of Fifteen Methodologies for
Environmental Assessment (Center for Urban and Regional
Studies. University of North Carolina, Chapel Hill, February
1980). An excellent but more specialized discussion is offered by
B. Hobbs and A. Voelker, "Analytical Multiobjective Decision
Making Techniques and Power Plant Siting: A Survey and
Critique," Draft ORNL-5288 (Oak Ridge National
Laboratory. Oak Ridge. Tennessee, 1977).
8.
iravi
36 EIA SEVlEW 2/1
9. See Note 1.
10. The Economic Evaluation for the U.K. Bristol Area Transport
Study makes paired comparisons across seven dimensions of
concern, then identifies the preferred alternative by examining
the pairs. This ranking of all alternatives based on the ranking
of many pairs is invalid unless one alternative clearly
dominates in all dimensions. Otherwise, the dimensions must
be weighted, and weighting cannot be incorporated into
ordinal data. See Jamieson MacKay and Partners, Strategic
Environmental Evaluation Technique—Bristol Study, Part I,
Application of the Methods. (United Kingdom, 1975.)
11. The McHarg Overlay Technique is based on an overlay of map
transparencies, each map dealing with specific environmental
and land-use characteristics. Each of these characteristics is
shaded differently to represent three degrees of "compatibility
with the highway." By using overlain maps, one of which is the
proposed route, a comprehensive picture showing the spatial
distribution and intensity of impacts can be obtained.
However, this method requires that all data be converted to
ordinal scales. Considerable information contained in interval
or ratio scales can be lost by such a conversion. Once all
measures are scaled ordinally, the tonal variation with respect
to each environmental parameter and the comparative color
densities for the scales of the different transparencies must be
determined. The former is an implicit judgment about scaling
the magnitude of individual environmental parameters, the
latter about weighting the relative importance of different
environmental parameters. Since these judgments are not
explicit, they tend to be subjective. Moreover, the process of
overlaying the maps is equivalent to visually adding the
parameters. As this article points out, ordinally scaled para-
meters cannot be added or weighted because the scales
associated with the various parameters are in different units of
measure. Additions and weightings are valid only if a standard
point of reference and fixed intervals are set for the full range of
parameters, and this is not possible with ordinal data. See Ian
McHarg, "A Comprehensive Highway Route-selection
Method," Highway Research Record, No. 246 (Highway
Research Board, Washington, D.C., 1968), and McHarg,
Design with Nature (Garden City, N. Y.: Natural History Press,
1969.)
12. A third alternative can be noted, but is of limited use in
environmental impact assessment. Data can be standardized
using standard deviations when a large number of alternatives
are being compared. For each dimension, the difference
between the observed measurement of that characteristic and
the mean is calculated. This difference is
aracteristic a
dividedj^^t
EIA REVIEW 2/1 37
-------
standard deviation. The resulting "z-score" can be added to z-
scores of other characteristics because each characteristic is
expressed in terms of standard deviation from a mean. Z-scores
can be amalgamated. Social impacts are frequently derived in
this fashion. The means and standard deviation methods do
not directly indicate goodness, but provide instead a
statistically stable tool to meas-ure differences by internal
comparisons. Since environmental impact statements usually
assess a limited range of alternatives, internal comparisons are
not likely to be helpful.
IS. Standardized proportions are unreliable. The inclusion of a
new alternative can change the rank order of two previous
alternatives. Consider a simple water quality index based on
toxic ammonia and total phosphorus. We compare two
alternatives with ammonia values of .007 and .012 and
phosphorus values of .01 and .005 milligrams per liter
respectively. We divide by the largest values (.012 and .01) and
add. Alternative 1 equals (.007/.OI2) M (.OI/.OI) M 1.6.
Similarly, alternative 2 equals 1.5. Now, if we include a new
alternative with an ammonia value of .02 and a phosphorus
value of .05, the new largest values are .02 and .05, and the
standardized proportions for alternatives 1, 2, and 3 are 0.55,
0.7, and 2.0 respectively. Alternative 1 and 2 have changed
order.
14. Lyndon Babcock and Niren Nagda, "Indices of Air Quality" in
Indicators of Environmental Quality, ed. W. Thomas (New
York: Plenum Press, 1972).
15. Dee. See Note 7.
16. Bruce Ackerman el al., The Uncertain Search for
Environmental Quality (New York: The Free Press, 1974).
17. N. Georgescu-Rogen, "Choice, Expectations, and Measur-
ability." Quarterly Journal of Economics 64 (1954).
18. Hobbs and Voelker. See Note 8.
19. See Note 2, especially personal commuication with Wilson.
20. Steven Hill, "201 Grants for Municipal Wastewater
Treatments," p. 24. See Note 2.
21. Lawrence Susskind et al., Resolving Environmental Disputes:
Approaches to Intervention. Negotiation, and Conflict
Resolution (Laboratory of Architecture and Planning, MIT,
Cambridge, 1978).
38 F.IA REVIEW 2/1
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4.D-18
-------
JENSEN and GAULT
Resource Discipline
Biological Resources
Cultural Resources
Earth Resources
Land Uses
Visual Resources
Table 3. Resource Discipline Impacts
Individual Impact Assessment
Ground Disturbance Public Accessibility
Wildlife
Botanical
Known Sites
Predictive Model
Soil Erosion
Water Resources
Parks, Recreation, and Preservation
Existing and Planned Land Uses
Agricultural Lands
Military Operating Areas
Views from Residences
Views from Sensitive Recreation Areas
Views from Sensitive Travel Routes
Scenic Quality Impacts
Wildlife
Botanical
Known Sites
Predictive Model
A
16.8
202.7
118.8
98.7
40.9
13
39.1
623
22.8
72.6
me
77.9
B
16.8
206.9
963
115.5
45.5
1.4
39.1
37.7
31.4
87.3
0.0
109.0
67.2
Table 4. Alternative Routes
Construction
Access Levels
16.8
199.9
117.2
97.8
40.1
16.8
211.4
103.9
105.1
42.9
16.8
187.8
96.7
98.8
43.7
22.0
210.5
119.8
933
37.4
16.8
199.9
117.2
97.8
40.1
Natural Environment
13
39.1
342
24.4
72.6
0.0
78.4
70.4
13
39.1
68.1
20.0
72.4
0.0
96.0
93.5
13
39.1
60.8
22.8
72.6
0.0
92.6
72.4
13
39.1
34.9
24.4
66.6
0.0
78.4
73.9
13
39.1
34.2
24.4
72.6
0.0
78.4
70.4
Agricultural lands
Existing access with spur roads
New access roads in flat (0-8%) terrain
New access roads in rolling (8-35%) terrain
New access roads in steep (35-65%) terrain
Wildlife
Ferruginous hawk nest buffers
Desert tortoise habitat
Sage grouse (leks or winter range)
Crucial big game habitat
Crucial nesting habitat
Sensitive fish species
Federally-listed or candidate species
Other sensitive species
-------
IMPACT ASSESSMENT
and maps were collapsed into the five resource disciplines:
visual, biological, cultural, land use, and earth resources. The
process of collapsing the data involved CIS operations that
overlaid several residual impact maps from each resource to
create a single integrated map that represented the maximum
or worst-case impacts for that resource discipline. For
example, the higher biological impacts always took prece-
dence over the lower impacts in the same location. The
impact values of high, moderate, and low for each of the
twenty-two individual impact assessments were developed
using the same criteria. As an example, a high impact for
cultural resources was considered to have a parallel effect to
high impact to soils.
The collapsed biological resource impact map was derived
using the CIS from the four individual impact assessments
done for biology (Table 3). In addition, the CIS produced
summary reports of the resource discipline impacts for each
of the alternative routes. These summaries will be used in
selecting the environmentally-preferred alternative.
As a tool to assist the selection of preferred alternative routes
for each resource discipline (e.g., biological resources), the
CIS was queried to select the least impact route. An imped-
ance model was developed to identify the "path of least
resistance" for each resource discipline by adding up impacts
(e.g., impedance) along alternative route segments until it
arrived at its destination point. The results of the impedance
models were used to construct eleven alternative routes from
the numerous alternative corridor segments.
These alternative routes will be compared in the EIS. The
summarized alternative route comparison data, supplemented
by the results of the impedance models, will be used to select
an environmentally-preferred alternative route in the EIS.
Table 4 shows examples of construction disturbance ex-
pected and some of the critical wildlife resources that would
be crossed for seven of the alternative routes (A through G).
Similar summary data tables were produced for each of the
resource disciplines. The summary data are displayed in a
format to facilitate comparing the alternatives.
SUMMARY
The application of CIS technology has been instrumental in
the management of the voluminous data gathered for the
studies of this transmission line project. The development of
59
the capability to model the potential impacts associated
the construction and operation of a transmission line pro-
vided planners with the data needed for a strong siting
process, and provided decisionmakers with the best informa-
tion available to assist mem in the selection of a preferred
alternative route for this project
Environmental planners are charged with integrating the
activities of man into a fragile and sensitive environment
The advanced technologies of CIS are available to manage
large databases and to perform comprehensive impact assess-
ments. The CIS is a tool that is gaining widespread accep-
tance and credibility with industry, environmental interests,
and land managers; it can be utilized effectively to perform
detailed analysis, as well as to provide the much-needed
consistency to environmental documentation. Coupled with
other advanced technologies, like remotely-sensed data and
other large databases, CIS is a powerful tool for the informa-
tion age.
The value to our society of utilizing these types of automated
tools is to incorporate the increasing volumes of data and
information into die decision-making process. Credible
methodologies applied by environmental planners and close
observation by agencies and activists are the irreplaceable
human elements. An intimate sense of what is crediblj
needed, and sustainable should be the heart and soul of
planning, environmental, and development missions.
data management and analysis tool, CIS can help guide those
missions into the future.
REFERENCES
40 Code of Federal Regulations Pansl500-1508.
Howald. KJ. 1990. CIS Analyzes Poweriine Corridor. CIS World
3(5): 4649.
Public Law 88-552. 1964.
(USDI)U-S.DepartmentofInterior. 1990.SouthwestImenie Project
HS/PA Cultural Resources Impact Assessment Report (unpub-
lished document). Boise, ID.
(USDI) U.S. Department of Interior. 1989a, Southwest Interne
Project Public and Agency Scoping Notebook (unpublished
scoping document). Boise, ID.
(USDI) U.S. Department of Interior. 1989b. Southwest Interne
Project Transmission Line Regional Environmental Repon (un-
published scoping document). Boise, ID.
(USDI) U.S. Department of Interior. 1986. Visual Resource Con-
trast Rating. BLM Manual Handbook 8431-1. Washington. DC.
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ATTACHMENT 4.E
GEOGRAPHIC INFORMATION SYSTEMS
Jensen, J., and G. Gault. 1992. Electrifying the impact assessment process. The
Environmental Professional 14: 50-59.
4.E-1
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4.E-2
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PROFESSIONAL REPORTS
ELECTRIFYING THE IMPACT ASSESSMENT PROCESS
James Jensen
Gregory Gault
Dames and Moore
SS^^S1^*1"^^ m teing br°Ught to beir °n *" Environmental Impact Statement (EIS) and Plan Amendment (PA) for the
?£T!i meiSTF* a Iu8h-volta«e transmission line project proposed in Idaho. Utah, and Nevada. Dames and Moore is conducting
theithini party EIS/PA for the USDI Bureau of Land Maiiagement,USDA Forest Service, USDI National Park Seivia. and me USDIfiS
£^!!ZTIL ??e ?TOjeCtinvolves *" "* of a SeograP™0 information system (CIS). To supplement conventional types of data collection
two types of satellite imagery and digital terrain data were read into the GIS. Thematic Mapper satellite imagery was used to identify various
agncultural land types, vegetation associations, wetlands, riparian areas, urban areas, water bodies, etc. The GIS used these data to evaluate
ground water disturbance potential and potential effects from increasing public accessibility into remote areas. Project visibility visual
^^ T management classes also were modelled using the GIS. Impact assessment and mitigation plairnrng^mcluding mips and
dmreponrng for each of the 1,800 miles of alternatives were developed using the GIS, which also was used to assist the identification and
selection of the environmentally-preferred routing alternative.
The GIS and other advanced technologies have been demonstrated to play an increasingly important role in managing public lands and in
a^fb^r
This paper illustrates with a case study the utility of a
geographic information system (GIS) to assess the potential
environmental impacts and to compare alternative routes for
a major regional transmission project for an EIS.
PROJECT DESCRIPTION
The Southwest Intertie Project is a 500 kilovolt (kV) trans-
mission line proposed to originate from southern Idaho and
extend southward to the Las Vegas, Nevada, area. A second
portion of the project will extend from roughly the midpoint
of the north-south segment (near Ely, Nevada) to Delta, Utah
(Figure 1). The total project length is about 1,140 kilometers
(700 miles). For over 25 years, the need for the project to
provide reliable power and regional power exchange has
been recognized by the utility companies in the western
United States and in the Congress (PL 88-552,1964).
The EIS is being prepared for the United States Department
of Interior (USDI) Bureau of Land Management, the federal
lead agency. Cooperating agencies include the United States
Department of Agriculture (USDA) Forest Service, USDI
National Park Service, the USDI Bureau of Reclamation, and
the USDI Bureau of Indian Affairs.
The project was conducted in two major phases:
• Phase 1 - regional studies to identify alternative corridors
• Phase 2 - corridor studies for the EIS
The Phase 1 work involved an area of approximately 97,500
square kilometers (60,000 square miles) in southern Idaho,
0191-5398/92 $3.00 + .00
Copyright C National Association ol Environmental Professionals
INTRODUCTION
^fee 1970, the National Environmental Policy Act (NEPA)
^Phe implementing regulations (40 CFR1500-1508) have
provided the mandate for environmental considerations in the
federal decision-making process. Environmental Impact
Statements (EISs) and Environmental Assessments (EAs)
are prepared routinely by federal agencies to evaluate alter-
natives to a proposed action, to document the environmental
consequences, and to show clearly what rationale was used to
determine the preferred alternative among proposed actions,
alternatives to a proposed action, or no action.
In its 20-year history, NEPA has matured into a more sophis-
ticated planning mandate and decision-making tool for fed-
eral agencies due to several factors: (1 )litigation interpreting
the intent of NEPA and Council of Environmental Quality
(CEQ) regulations, (2)higher environmental standards of the
federal agencies, (3)higher public environmental conscious-
ness, (4)more significant technology brought to bear in pro-
viding decisionmakers with more complete information.
James Jensen is a landscape architect and environmental planner. As
an associate with Dames and Moore, 1750 Front St, Suite 100,
Boise, ID 83702, Mr. Jensen has managed a wide variety of
multidisciplinary environmental planning and recreation studies in
the western U.S.
Gault is a private consultant with the firm of Dames and
where he is responsible for guiding the design and coordi-
the implementation of environmental resource studies.
This paperwas presented at the 1991 annual meeting of the National
Association of Environmental Professionals.
THE ENVIRONMENTAL PROFESSIONAL Volume 14 pp. 50-591992.
Printed ki the USA. Al rights reserved
-------
IMPACT ASSESSMENT
51
Figure 1. Regional Study Area
Midpoint
Substation
western Nevada, and eastern Utah (USDI, 1989b). The
purpose of the regional study was to identify alternative
corridors that would be considered "reasonable and feasible"
for routing transmission line alternatives (Figure 2).
GEOGRAPHIC INFORMATION SYSTEMS
DATABASE
A database was constructed using a CIS at 1:500,000 scale.
Secondary, or existing data, in the form of documents and
maps, were collected and input into the CIS system through
digitizing or through reading digital data from tapes. In
addition. United States Geological Survey (USGS) digital
elevation mapping and remotely-sensed data (Multi-Spectral
Scanner imagery) complemented the environmental data-
base. Data were organized and arranged by distinct types,
forms, or categories into files or layers for use in modeling
and data reporting.
The remotely-sensed data used in the Phase 1 studies were
classified into land cover types (e.g., agricultural lands,
vegetation types, etc.) using an image processing system
(Howald, 1990). Once compiled, the CIS database was used
to identify opportunities and constraints based on environ-
mental and engineering parameters that could affect
mission line routing.
-------
Figure 2. Alternatives for Detailed Studies
«JIDMricfBoundMlMl
U8F8
The Phase 1 regional study results were presented at a series
of public scoping meetings held during die beginning of the
Phase 2EIS studies (USDI, 1989a). From over4,900 kilome-
ters (3000 miles) of alternative corridors identified during the
Phase 1 studies, about 2,900 kilometers (1800 miles) of
alternative corridors were carried forward into Phase 2 for
detailed study as "reasonable and feasible" transmission line
routing alternatives.
The regional database then was enhanced for the corridor
i (Phase 2) by retaining the secondary data from the
I studies and modifying these data to accommodate the
I scale required for the Phase 2 studies. Refined Phase
1 data were supplemented with additional detailed data from
resource field studies, collected and mapped at 1:100,000
scale. Detailed data were mapped within a six-mile wide
JENSEN and GAULT
corridor centered on the assumed centerline of alternative
routing corridors. The individual CIS data layers mapped for
the corridor studies are listed in Table 1.
IMPACT ASSESSMENT MODELS
The purposes of assessing the potential environmental im-
pacts of placing a transmission line along each of the alterna-
tive routes are to document environmental effects and to
determine the alternative route that has the lowest overall
impact (i.e., environmentally-preferred alternative), for the
decision-making agency. The CIS was used as a tool to
estimate and document potential environmental consequences
and to provide summary information to the public and the
agencies to assist the decision-making process. The key word
forusing advanced technology in the NEPA process is "tool."
Because CIS lacks the ability to understand complex, inter-
related environmental systems or issues, it should not replace
traditional methodologies used on many linear projects to
assess impacts and compare alternative routes, which gener-
ally are considered by professionals and public and agency
reviewers as credible and defensible. Conversely, it should
be used to facilitate consistency in applying impact assess-
ment methodologies and documenting their results in a thor-
ough and defensible EIS document
To determine potential impacts, it is necessary to determine
what types of impacts are expected. For example, most
resource impacts from a transmission line project on public
lands in the western United States can be determined by
asking three questions; (1 )How will ground disturbance from
construction and operation affect sensitive resource features
or values? (2)How will increased access from new roads
constructed in remote areas affect sensitive resource features
orvalues typically protectedby theirremoteness? and (3)What
direct or indirect effects will the presence of transmission line
structures have?
Modelling the Affected Environment
To answer these predictive questions, it was necessary to
develop several "pre-impact assessment" models to establish
the magnitude of change that would occur in the environment
from the introduction of a SOOkV transmission line. Most
modelling of potential impacts was done using two basic pre-
impact assessment models: (1 )the ground disturbance model
and (2)the public accessibility model.
Based on five slope categories that considered the estimated
mileage of road needed to access towerconstruction sites and
the estimated size of construction areas at tower sites, a set of
assumptions called access levels was developed. These ac-
cess levels provided the basis with which the pre-impact
assessment models measured the potential change in the
environment, per mile of transmission line constructed.
By using components of the GIS database (Table 1), other
capabilities of the GIS, and the two basic pre-impact assess-
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IMPACT ASSESSMENT
53
Data Layer
Table 1. GIS Inventory Data Base
Comments
Residences and Other Structures
Transportation and Access
Parks, Recreation, and Preservation
Land Uses
Miltary Air Space
Range Allotments
Wildlife
Botany
Scenic Quality Gasses
Visual Resource Management Classes
Soils
Water Resources
Cultural Resources
Land Cover
Terrain/Elevation
Locations interpreted from satellite imagery
Existing highways and paved and unpaved roads
Wilderness areas, national parks, state parks, other public and
private recreation facilities
Transmission lines, pipelines, mines, wells, corrals, and other surface uses
Military flight research and training areas (to 100 feet above the ground)
Public land areas used for livestock grazing
Threatened and endangered species, other sensitive species, and sensitive habitat
Rare and sensitive plants and their habitat
Federal agency classification of landscape aesthetics
Federal agency designations for the management of the visual landscape
Erosion and structural load characteristics. Prime/Unique farmland designations
Rivers, perennial and intermittent streams, other waterbodies, floodplain
areas, high water table
Known archaeological/historical sites
Classified from Thematic Mapper (TM) data
USGS Digital Terrain data and mapping
ment models mentioned above, several other pre-impact
assessment models were developed:
• visibility from sensitive viewpoints (e.g., residences,
parks, recreation areas, scenic overlooks)
• visual contrast from vegetation removal, changes in
landform from road construction, and presence or ab-
sence of structures such as buildings or other transmis-
sion lines
• cultural resources predictive model (USDI, 1990)
• buffers for critical habitats for some sensitive plant and
wildlife species locations (e.g., distance or zone around
the nesting site of a threatened or endangered raptor
species, which generally is considered necessary to
protect the nest)
• slope categories.
Hie data and mapping that resulted from the pre-impact
assessment models were used as the basis for determining the
specific locations and severity of resource impacts. These
pre-impact assessment models are described in more detail
below.
Ground Disturbance Model - The project will utilize existing
unpaved roads and will require the construction of some new
access roads for construction crews to place tower footings,
erect towers, and string the conductors. Where no access
roads exist, new roads will have to be built Also, some
existing roads will need to be upgraded to support construc-
tion equipment and vehicles. In either case, some ground
disturbing activities will be necessary to construct and oper-
. ate the transmission line.
The ground disturbance model combined the GIS
layers of land cover, slope categories, and transportation
listed in Table 1 to quantify and map the area of potential land
disturbance into five levels of magnitude. The level of distu^^
-------
Figure 3. Ground Dlsturlfl^ Model
GROUND DISTURBANCE
LEVEL
UNK DESIGNATION
Southwest Intertie
Project
m
w
m
CD
a
O
-------
IMPACT ASSESSMENT
55
bance varies depending upon the presence or absence of
existing roads, the terrain that might require grading, and the
circuitous routing for grade limitations. Figure 3 illustrates
the ground disturbance levels.
Public Accessibility Model-This model estimated the degree
of remoteness of areas along each of the transmission line
routing alternatives. The primary assumption of developing
this model was that impacts could occur to certain resources
if new access roads are constructed and maintained in largely
remote areas. Legal or illegal hunting could endanger sensi-
tive plant or wildlife species and increase pressure on game
species. Cultural resources (e.g., early-man sites) may be
more susceptible to vandalism or damage due to the cumula-
tive impacts (e.g., repeated damage from vehicle tire tracks)
by public land users (USDI, 1990).
The public accessibility model utilized the transportation
layer of the CIS database in conjunction with the results of the
ground disturbance model. The model estimated the increase
in the area accessible by roads in remote areas expressed in
terms of five percentage values. Several of the impact
assessments models used these values to predict the potential
impacts associated with increased access. Figure 4 illustrates
the five levels of access.
Visibility - This model was constructed using the digital
terrain data and selected land uses (e.g., residences, parks,
scenic overlooks, highways) that were considered to be
sensitive viewpoints. Mapping of viewsheds was generated
through a CIS operation that "looks out" from these view-
points over the digitally-modeled terrain of the project study
area. The resulting maps represented visibility as distance
thresholds of visual perception (0-500 meters, 500-1500
meters). These maps later were utilized by CIS impact
models to determine the potential visual impacts of the
construction and operation of the transmission line.
Visual Contrast - Visual contrast is a measure of visible
change in the landscape (USDI, 1986). The visual contrast
model was developed by combining the results of two other
pre-impact assessment models. The first of these models was
created to predict the contrasts that would result from vegeta-
tion removal and changes in landform. This model used the
landcover and terrain database layers in conjunction with the
ground disturbance model to determine the contrast from
ground disturbing activities. The second model, structure
contrast, was created from elements of the land use database
layer (e.g., existing structures, transmission lines) and the
proposed project description (e.g., types of new towers pro-
posed). Mapping of visual contrast represented the level of
change in the characteristic landscape. Visual impacts were
determined through an evaluation of how visual contrasts
were perceived from sensitive viewpoints.
Cultural Resources Predictive Model - The locations of most
cultural resources (prehistoric, ethnohistoric, and historic) in
the western U.S. are not known or recorded, except where
specific surveys have been conducted. To assist in determin-
ing where sensitive cultural resources likely may be foun^k
cultural resources predictive model was developed. ^^B
model includes the landcover, terrain, and water resources
database layers. The probability of rinding culturally-sensi-
tive sites was estimated by a model that evaluated several key
environmental factors, such as proximity to water, presence
of specific vegetation types, and elevation.
Sensitive Habitats - The CIS buffering capability was applied
to establish zones of potentially sensitive habitats associated
with known habitat locations. For example, a buffer of 812
meters (1/2 mile) was used around known locations of sage
grouse leks or spring strutting grounds to include potential
nesting habitat Similarly .ferruginous hawk nests, bald eagle
nests, and other sensitive wildlife habitat or botanical loca-
tions were buffered to establish a zone where potential
disturbances from the construction or operation of the trans-
mission line could be assessed.
5/ope-Five slope categories were mapped using the 1:250,000
scale USGS digital elevation mapping. The slope categories
were selected based upon degree of soil erosion potential,
construction difficulty, and other environmental and con-
struction parameters. These categories were important in the
development of the access levels for use in the ground
disturbance and public accessibility pre-impact assessment
models, described previously.
Combining the results of the pre-impact assessment i
with the selected layers of the CIS database, the ii
assessment models performed three functions: (l)estimated
the potential initial impacts of placing a transmission line in
the landscape, (2)facilitated the application of selective miti-
gation measures based on the severity of the predicted im-
pacts, and (3)estimated the residual impacts.
Residual impacts, those expected to remain following mitiga-
tio^wereusedtodetenninepotentialsignificanteffects. The
impact assessment models combined the specific locations,
quantities, and magnitudes of predicted project disturbances
determined by the pre-impact assessment models (described
earlier) with the geographic locations of environmental re-
source features or values provided by the CIS database layers.
Based on the sensitivity or susceptibility to disturbances (e.g.,
ground disturbance and public accessibility), the impact
assessment models estimated the effects on resource features
or values. Potential impacts were assessed in increments of
162 meters (0.1 mile) along the centerline of each alternative
transmission line corridor, a unit of measurement easily.
understood by the general public.
A series of matrices was applied by the impact assessment
models that assigned impacts to specific resource features
and values based on the level of ground disturbance. For
example, a sage grouse lek and the adjacent nesting
ar^u
-------
Figure 4. Public AccesJN ffity Model
salmty
PUBLIC ACCESSIBILITY
PERCENT CHANGE
IN ROAD DENSITY
UNK DESIGNATION
m
BMII«s
Southwest Intertie
Project
m
m
a
-------
IMPACT ASSESSMENT
57
would be disturbed when crossed by the assumed centerline
of a routing alternative. If the ground disturbance is expected
to be low, the potential to disturb sage grouse habitats would
be minimal. Minimal ground disturbance would be the case
if the alternative route parallels an existing road or similar
linear land-use feature.
Similarly, a series of matrices was applied by the impact
assessment models that assigned impacts to specific resource
features and values (e.g., cultural, wildlife, and botanical
resources) based on the level of potential increase in public
access. For example, ferruginous hawks are less likely to be
disturbed during sensitive nesting periods or shot illegally if
they are in inaccessible or remote areas. Where areas of
significant change in accessibility coincide with sensitive
resource features or values, potentially significant effects are
likely to result.
The next step in the process of determining and documenting
potential impacts was to recommend mitigation that would be
effective in reducing initial impact levels. A standard set of
mitigation measures was developed for the project Matrices
were used to apply mitigation measures to specific locations
and to specific types of impacts. For example, one might
expect impacts upon big game species, such as pronghom
antelope or elk, during their sensitive breeding or fawning
periods, but these impacts can be eliminated effectively by
applying the mitigation measure of avoiding construction
during these sensitive periods.
The final step in the automated impact assessment process
was to determine residual impacts, or those impacts expected
to remain following mitigation. A matrix again was i
to determine the level of residual impact The
location and quantified severity of residual impacts were
documented in printed tabular reports and illustrated in
impact maps generated by the CIS. Both the maps and tabular
reports document impacts on an increment of approximately
162 meters (0.1 mile) along each of the 2,900 kilometers
(1800 miles) of alternative routes. An example of the tabular
report for ground disturbance impacts related to wildlife
resources is illustrated in Table 2.
Preliminary maps were generated for each step in the impact
assessment process, initial impacts, mitigation, and residual
impacts, to verify modeling operations and to assure data
integrity. A total of 22 impact assessment models was
developed to evaluate the ground disturbance, public access,
or visual effects of a transmission line on the resources in the
layers of the CIS database (Table 1). The results of each of
the individual impact assessments were compiled to summa-
rize impacts and determine an environmentally-preferred
alternative.
SELECTING AN ENVIRONMENTALLY.
PREFERRED ALTERNATIVE
Because of the inherent difficulty in comprehending the
voluminous data generated by the twenty-two individual
impact assessments, the data from the tabular impact repofls.
Mile
From
Post
To Length
Table 2.
Access
Level
Ground Disturbance Impacts to Wildlife
Initial Mitigation Residual
Resource Theme Impact Measures Impact
1
Comments
Route Link 167
0.0
0.1
1.3
1.5
1.7
2.3
0.1 0.1
1.3 1.2
1.5 0.2
1.7 0.2
2.3 0.5
2.6 03
Level 2
Level 2
Level 2
Level 2
Level 4
Level 4
Sage grouse lek
Sage grouse lek
Sage grouse lek
Sage grouse lek
Sage grouse lek
Background
4
4
4
4
4
1
30
30
30
30
30
0
4
3
4
3
3
1
crosses within
1/4 mile of lek
crosses edge of 1/2 mile
habitat buffer
crosses within
1/4 mile of lek
crosses edge of 1/2 mile
habitat buffer
crosses edge of 1/2 mile
habitat buffer
-------
4.4
Determination of Significance
Significance is that characteristic of an impact that determines its degree
of influence on a decision. In the U.S., significance is described in terms of
context and intensity. The significance of an action will vary within the context
of the action (e.g., local vs. global scale) and the intensity (i.e., magnitude) of
the impact. Generally accepted criteria for determination of significance are
described below.
Significance is a key factor in (1) determining the appropriate level of EA
for a proposed action, (2) deciding on measures that avoid or mitigate predicted
impacts, and (3) choosing among alternative actions. If potential impacts are
thought to be significant, the EA review generally results in a formal EA
document (i.e., an EIS in the U.S.). When, as a result of the EA process,
predicted impacts are shown to be significant and treatable, mitigation measures
must be included in the EIS and in a public record of decision. However, the
choice of alternatives is a management decision that is based on many factors
including government policy, applicable laws and regulations, agency mission and
objectives, as well as public values and biological significance.
The significance of a proposed action is considered at both the beginning
and the end of the EA process. In the beginning, the proponent determines the
appropriate level of EA review and documentation based on screening the
proposed action. When a proposed action is precedent-setting, unique, and/or the
potential impacts are unknown or thought to be significant or the ability to
mitigate effects is unknown, a formal EA document is appropriate. The public
plays a role early in planning (i.e., during scoping) in determining the
significance of issues and the choice of alternatives for analysis. Determination
of significance at the end of the EA process involves evaluation of the predicted
impacts for each of the alternatives and, as described above, ultimately rests with
the decisionmaker. Explicit procedures, which identify the values of the public
and the significance of the effects of the alternatives on each value, provide a
better basis for rational analysis, decisionmaking, and public acceptance of the
proposed action.
In the U.S., the NEPA review and documentation process is predicated on
the significance of proposed federal actions. Elsewhere (e.g., the United
Kingdom), a significant impact is considered one for which the developer should
4-63
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seek some form of mitigation. Significance is determined by reference to legal
or accepted standards as far as possible, but if no standard is available, the EA
team evaluates significance basing their determination on clearly described ad hoc
criteria.
NEEDS
It is the job of the EA team to identify, clarify the options and trade-offs,
and summarize the potentially significant impacts for the decisionmaker. For
this, criteria are needed to determine significance of effects of an action on a
particular entity and also a method is needed for scaling effects for each criterion.
• Criteria for significance upon which decisions are based include
the:
— value of the potentially affected entity. Particularly
important are public health and safety, threatened and
endangered species, and important geographic areas (e.g.,
historic sites, park lands, prime farmlands, wetlands, wild
and scenic rivers, ecologically critical areas);
— magnitude of the effect (severity);
— nature of the effect;
— spatial extent of the effect;
— duration of the effect;
— predicted degree of recovery;
— political repercussions;
— public concern; and
— legal mandates.
Furthermore, actions or effects that are likely to be highly
controversial, involve unique or unknown risks, or establish an
important precedent are also considered to be significant.
• Determination of significance requires predicting change (Part
4.3). These impact predictions are, along with societal values, the
major input to significance determinations. The input must be
good if the output is to be good. Ideally, change should be
compared against thresholds of concern, some of which may be
legally mandated and others which may be levels or states of
valued components determined by the public, the decisionmaker,
or the EA team. However, because all alternatives may be above
the threshold or all may be below the threshold, it is necessary to
at least estimate relative magnitudes of effects in order to compare
significance.
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Burton, I., J. Wilson, and R. E. Munn. 1983. Environmental impact
assessment: national approaches and international needs. Environmental
Monitoring and Assessment 3:133-150.
Cohrssen, J. J., and V. T. Covello. 1989. Risk Analysis: A Guide to
Principles and Methods for Analyzing Health and Environmental Risks.
Council on Environmental Quality, Washington, D.C. 407 pp. Available
from the National Technical Information Service, U.S. Department of
Commerce, 5285 Port Royal Road, Springfield, Virginia 22161.
Conover, S. A. M., K. W. Strong, T. E. Hickey, and F. Sander. 1985. An
evolving framework for environmental impact analysis I. methods.
Journal of Environmental Management 21:343-358.
Elliot, M. L. 1981. Pulling the pieces together: amalgamation in environmental
impact assessment. Environmental Impact Assessment Review 2:11-38.
Federal Environmental Assessment Review Office (FEARO). 1986. Initial
Assessment Guide. Federal Environmental Assessment Review Office.
Ottawa, Ontario. 36 pp.
Giroult, E. 1988. World Health Organization interest in environmental health
impact assessment. In: Environmental Impact Assessment, Theory and
Practice (ed. P. Wathem). Unwin Hyman, Boston. 332 pp.
Haug, P. T., R. W. Burwell, A. Stein, and B. L. Bandwiski. 1984.
Determining the significance of environmental issues under the National
Environmental Policy Act. Journal of Environmental Management 18:15-
24.
Hirsch, A, 1980. The baseline study as a tool in environmental impact
assessment. In: Biological Evaluation of Environmental Impacts, The
Proceedings of a Symposium. Fish and Wildlife Service. FWS/OBS-
80/26.
Hollick, M. 1986. Environmental impact assessment: an international
evaluation. Environmental Management 10:157-178.
James, T. E. Jr., S. C. Ballard, and M. C. Devine. 1983. Regional
environmental assessments for policy making and research and
development planning. Environmental Impact Assessment Review 4:9-24.
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Leistritz, F. L., and S. H. Murdock. 1981. The Socioeconomic Impact of
Resource Development: Methods for Assessment. Westview
Press/Boulder, Colorado. 286 pp.
Murdock, S. H., F. L. Leistritz, and R. R. Hamm. 1986. The state of
socioeconomic impact analysis in the United States of America:
limitations and opportunities for alternative futures. Journal of
Environmental Management 23:99-117.
Richmond, H. M. 1981. A framework for assessing health risks associated with
national ambient air quality standards. The Environmental Professional
3:225-233.
Schaffman, P. 1986. Assessing the assessors: toward "risk aware" courts.
Environmental Impact Assessment Review 6:331-343.
Thompson, M. A. 1990. Determining impact significance in EIA: a review of
24 methodologies. Journal of Environmental Management 30:235-250.
Tomlinson, P., and S. F. Atkinson. 1987. Environmental audits: a literature
review. Environmental Monitoring and Assessment 8:239-261.
U.S. Environmental Protection Agency. 1992. Framework for Ecological Risk
Assessment. EPA/630/R-92/001.
Westman, W. E. 1985. Ecology, Impact Assessment, and Environmental
Planning. John Wiley & Sons. New York. 532 pp.
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Traditionally, the emphasis in EA has been on the biophysical
environment. However, human concerns about project-
environment interactions and the associated risk have contributed
to the development of socioeconomic impact assessment (Murdock
et al. 1986). Numerous computerized models are available that
quantitatively integrate social, economic, demographic, public
service, and fiscal impacts (Leistritz and Murdock 1981), but the
models are most appropriate for large-scale development activities
and are rarely integrated with biological analyses.
The task of evaluating an EIA and communicating the conclusions
to the public and the decisionmakers is complex. It is the
responsibility of the EA team to summarize and highlight the key
findings, including discussion of those issues determined not to be
significant.
Except for exceedance of standards set by government regulations
(e.g., National Ambient Air Quality Standards), the description of
significance is largely judgmental, subjective, and variable.
Conover et al. (1985) present a system to rate impacts as
negligible, minor, moderate or major impacts (Attachment 4.F).
Haug etal. (1984) present a system that ranks thresholds of
potential impacts on the basis of legal factors, principles of sound
resource use, and human preferences. These are described as
having highest, very high, high, moderate, or low priority
(Attachment 4.F). FEARO (1986) described the need to determine
thresholds of concern (i.e., a maximum or minimum number or
other value for an environmental impact or resource use which, if
exceeded, causes it to take on new importance) based on statistical,
ecological, social, and safety and health significance.
Terms used to describe the significance of project-induced changes
can and should be simple and clearly defined (e.g., major, short-
term, local, regional). In the absence of clear definitions, such
terms are subject to a wide range of interpretation.
TOOLS
Comparison of predicted levels of pollutant emissions or effluents
to legally mandated thresholds (e.g., against national ambient air
quality standards) can identify exceedances that would clearly
result in significant impacts. However, generally, predicted
impacts are not those related to exceedances of set standards
4-65
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because the reason for such excursions would be mitigated during
project design.
• Coordination of surveys and studies required by executive orders
and other environmental review laws (e.g., U.S. Fish and Wildlife
Coordination Act, National Historic Preservation Act, and the
Endangered Species Act) with the preparation of the EIA document
can ensure that protected resources are identified early on and
factored into the decisionmaking process. (Part D summarizes
some of the U.S. environmental laws written to protect specific
resources.)
• In addition to legally mandated thresholds, Haug et al. (1984)
discusses functional, normative, controversial, and preference
thresholds (Attachment 4.F). Sometimes an environmental impact
will not be a concern if it is small or if it occurs in an already
disturbed area. However, the significance of such concerns is
usually determined by the affected public. If possible, negotiating
a threshold of concern for an environmental impact or resource use
which, if exceeded, will cause the impact or use to take on new
importance, usually resolves the conflict (Attachment 6.A).
Although establishing numerical values for such thresholds is often
impossible, identification of the concern aids the decisionmaker,
helps to establish monitoring needs or criteria for mitigation, and
satisfies the public.
• Risk assessment provides information that can be useful in
weighing alternatives and analyzing trade-offs, especially when
answers are not obvious and available information in ambiguous
and uncertain. However, neither health risk assessment nor
ecological risk assessment (Part 4.3) determines significance. The
significance of an estimated risk is determined by the
decisionmaker.
• Professional standards (e.g., general usage and engineering
standards) based on population ratios (e.g., hospital beds/1000
population, recreation acres/1000 population) are often used for
projecting needs for social services. These standards should be
used cautiously because they vary widely from one information
source to another and they are unlikely to be applicable to areas
(particularly rural areas) that are dissimilar to the areas for which
they were developed (Leistritz and Murdock 1981). On the other
hand, the standards are widely used and accepted, easy to apply,
and some of the standards are based on analytical analyses.
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Public opinion and the level of controversy associated with a
proposed action help to identify and to determine the relative
significance of environmental impacts. Useful input requires that
the public be informed on the proposed action, alternatives, and
major potential impacts, and encouraged to participate in the EA
process, particularly during scoping and document review.
However, it has been documented that public meetings do not
naturally attract the representative cross-section of society that
would provide a balanced input to the EA process (Thompson
1990). Thus, values and significance are probably determined by
groups of self-selected people.
ISSUES
The technical interpretation of significance is based on impact
assessment techniques that exist on a continuum from those that
simply summarize to those that also evaluate impacts (Part 4.3).
Westman (1985) notes that all of the quantitative assessment
techniques can be criticized from one or another perspective:
either they summarize too much or not enough; attempt to quantify
based on inadequate (subjective) data or remain too qualitative; are
arbitrary and incomplete in their selection of impacts to include or
are too exhaustive; and take away too much judgment from
decisionmakers or leave too much to be decided. However, he
notes that the need for evaluation is inescapable. In the absence
of explicit evaluation, implicit evaluation is performed by
decisionmakers. The job of the EA team is to choose methods
whose assumptions and data requirements are appropriate to the
task and to remind the decisionmaker of the assumptions and
limitations of the evaluation methods being used (Westman 1985).
Even the use of legally-set standards to determine significance can
be misleading. Standards are compromise figures based on
scientific information on species tolerance to toxic substances,
primarily from single-species bioassays and, to a lesser extent,
from field studies. A panel of experts determines the
recommended "standard" based on available literature. Thus, even
legally set standards are only crude guides to acceptable levels of
protection (Westman 1985).
Some recent papers on the value of EA methods suggest that the
accuracy of prediction in EA leaves much to be desired (Thompson
1990, Attachment 4.G; Tomlinson and Atkinson 1987; Bisset
1988; Elliot 1981, Attachment 4.D; Hollick 1986). There is
uncertainty associated with determinations of significance that are
4-67
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predictive methods. Comparison of proposed actions to similar
ongoing activities is suggested as a way to reduce the level of
uncertainty.
• Public perception of the significance of an issue is influenced by
(1) the existence of competing demands for the resource in
question, (2) differences in human values regarding the relative
worth of resources, and (3) the availability of knowledge and level
of understanding of the costs, benefits, and risks related to the
issue (Westman 1985). Ensuring that the public who has (or
should have) a substantive interest in the proposed action plays a
role in deciding the issues is the most effective way of determining
the significance of the issues and also is the most effective way of
avoiding conflict.
LINKAGES
Significance is linked to almost all aspects of EA. Initially, the required
level of documentation is determined by screening at the initiation stage of EA
review. For those actions thought to have potentially significant effects, an EIA
is prepared. During scoping, the public has the opportunity to identify significant
issues, and these significant issues and concerns help to determine the range of
alternatives that are analyzed during assessment. Decisionmaking is based on the
significance of the predicted environmental impacts along with other economic
and technical considerations and agency statutory missions. Mitigation is
designed to reduce potentially significant effects that are unavoidable or to
compensate for them. It is usually associated with a monitoring program during
and after implementation of the project.
REFERENCES
Bisset, R. 1988. Developments in EIA methods. In: Environmental Impact
Assessment, Theory and Practice (ed. P. Wathern). Unwin Hyman,
Boston. 332pp.
Bonano, E. J., S. C. Hora, R. L. Keeney, and D. von Winterfeldt. 1990.
Elicitation and use of expert judgment in performance assessment for
high-level radioactive waste repositories. NUREG/CR-5411. Sandia
National Laboratory, Albuquerque, New Mexico.
Buffington, J. D., R. K. Sharma, and J. T. McFadden. 1980. Assessment of
ecological damage: consensus. In: Biological Evaluation of
Environmental Impacts, The Proceedings of a Symposium. Fish and
Wildlife Service. FWS/OBS-80/26.
4-68
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MA.
Jft
243
The difficulty in achieving effective public participation was highlighted in work by
Ertel (1979). The following are statistics for the attendees of a public meeting:
I. 13-1% of attendees were not educated beyond secondary school level.
2. 37-7% had done college work.
3. 48-1% had college degrees.
4. 35-5% had yearly family incomes in excess of $20000.
It was further revealed that 44-8% had attended more than five public meetings in the
preceding five years and that 36-7% held elective or governmental positions. This result
suggests that public meetings do not naturally attract the representative cross-section of
society that would provide a balanced input to the EIA process.
It is therefore apparent that special efforts must be made to involve the disadvan-
taged and less well-educated sections of society. Over half the attendees in the survey
were present as a result of receiving a direct postal invitation, far fewer having responded
to media advertisements. This suggests that personal invitations to members of target
populations may help redress the balance. Another remedy may lie with the use of
polling or extensive questionnaire surveys, an effective example of which, the Yosemite
National Park Master Plan, is outlined in McAllister (1980).
As applied in Table 1, the methodologies that qualify are those in which public
participation is an integral part. In others, such as Stover (1972) and Clark et al. (1983)
participation is suggested, but left to the discretion of the study-team.
3.4. IS THE LEVEL OF QUANTIFICATION RESTRICTED TO THAT ADEQUATE FOR A
DECISION?
From the beginning of an assessment, the aim of the study must be clearly defined, based
on an appreciation of the exact nature of the decision to be made. Study resources
should then be directed towards a continual clarification of the main issues involved and
a refining of the study team's judgement. Quantification of impacts far beyond the point
where the difference between alternatives is apparent may be wasteful of resources that
would be better used on areas of study where differences are less clear. The methodolo-
gies that score on this criterion do not advocate exhaustive attention to detail.
3.5. ARE QUANTITATIVE AND QUALITATIVE DATA PRESENTED TOGETHER?
The attraction of quantitative data lies in their apparent objectivity, whether real or
illusory, and with the fact that they facilitate easy comparison between alternatives.
Where both quantitative and qualitative data are presented, care should be exercised
that the former are not given undue importance. On no account should qualitative data
be discarded because they do not fit conveniently into an assessment technique; instead,
a way must be found to incorporate them. Certain impacts may be better presented in a
quantitative manner whilst others lend themselves to a qualitative treatment. Criteria
number five highlights those methodologies where both types of data are likely to be
presented. The extent to which they are segregated to allow equal consideration is,
however, a presentational matter, the success of which will vary from one case to the
next.
to EIA
3.6. STUDY TEAM DOES NOT EXERT UNDUE INFLUENCE ON THE OUTCOME
The shortcomings inherent in relying solely upon expert opinion when assigning
significance to impacts were outlined in 3. This criterion applies to those methodologies
where some input of public opinion serves to limit the influence of the study team.
3.7. IS A STRUCTURED GROUP DECISION-MAKING TECHNIQUE SUGGESTED?
Methods used by a study team to achieve consensus on key issues can have an effect on
the outcome and are thus worthy of consideration. The effectiveness of various methods
was investigated by Delbecq and Van de Ven (1974). Although not applied specifically to
EIA, their study is of interest as it shows a way in which consensus decisions might best
be achieved. A comparison was conducted between conventional interacting groups, the
Delphi technique, and one of their own devising, the Nominal Group Technique. The
latter uses a strict procedure for group meetings. The meeting begins with all participants
writing down ideas. One idea from each person is taken in turn and written on an agenda
board. These ideas are discussed for clarification before independent voting via ranking
or rating is used to reach decisions.
The three methods were assessed for their ability to bring new ideas to light, and on
the satisfaction with the decision-making process as expressed by those taking part.
Results suggested that there exist a number of inhibiting influences that decrease the
performance of conventional interacting groups in decision-making. These included too
much time being spent on maintaining the social/emotional relationships of group
members, and not enough on actual business. An absence of time to think things
through individually, a tendency for group norms to emphasize conforming behaviour
and for discussions to dwell on areas of agreement at the expense of areas of conflict,
were also cited. Furthermore, a problem with higher status/stronger personalities whose
views were given a disproportionately large amount of time was also identified.
It was suggested that the Nominal Group and Delphi techniques avoided many of
these pitfalls, with the former being the preferred method as it made provision for some
structured group interaction. The Delphi technique was favoured when, for logistical
reasons, a meeting could not be convened. Work by Baumann et al. (1972) suggests that,
to the ends of alerting a decision-maker to all the possible options involved and
highlighting areas of conflict as well as consensus, the Delphi technique can be
particularly useful.
3.8. IS THE DEVELOPMENT OF LOW IMPACT ALTERNATIVES ENCOURAGED?
The value of EIA as a tool for project modification cannot be stressed too strongly. Its
success in this function may depend largely on the way in which any given EIA
methodology is applied to the project in hand. There are some methodologies, however,
which by their design, lend themselves to this function. The prime example of this is
McHarg (1969) where the whole purpose of the process is to create the low impact
alternative. Other techniques, such as the computer overlay of Krauskopf and Bunde
(1972), also have this capability. Sorensen (1971) may also qualify in this respect,
although more indirectly, by identifying impact networks and key areas of concern.
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245
3.9. WHEN WEIGHTING IS PERFORMED ARE A NUMBER OF ITERATIONS USED?
Uncertainty as to the reliability of any weighting scheme can be overcome to some extent
by using a successive series of weights. These can be derived from any number of
reference publics or by the study team itself. Computer-based methodologies are
particularly suited to the manipulation of weights. The value of this process lies in the
way it reveals the emphasis placed by any particular weighting system by comparison
with other systems. Successive treatments may well define key areas of impact, which
emerge regardless of the weighting system used. The use of the technique is probably best
confined to that of an in-house tool, refining the study-team's insight into the trade-offs
involved. The methodology of Krauskopf and Bunde (1972) is computer-based,
allowing easy manipulation of weighting schemes. In this respect, it is similar to the
method developed and practiced by British Coal (Alien, 1986).
3.10. IS THE METHODOLOGY EASILY ADAPTED FOR USE ON ANY TYPE OF PROJECT?
Whilst it is acknowledged that a technique developed for a particular type of project may
be of value, as long as it is used in appropriate circumstances, the flexibility of a
methodology is itself an important asset. The ability to shape the assessment technique
to fit the unique situation at hand should increase the likelihood of a reliable report
being produced. The use of rigid methodologies, with predefined impact categories and
weighting schemes, where inappropriate, will distort the assessment and greatly reduce
its value.
3.11. IS PROGRESSION THROUGH THE STAGES OF ASSESSMENT EXPLICIT?
The importance of this criterion lies in the need for an assessment to be readily
intelligible to lay decision-makers and the public. If it proceeds via a number of clearly
defined steps, such as predictions of impact magnitude, followed by conversions to
impact significance and explanation of the choice of key trade-offs, then this goal is more
likely to be achieved. As applied to the 24 methodologies, this criterion excludes those
that were lacking in specific guidelines or those such as Leopold el al. (1971) which
consist of only one stage.
3.12. ARE RESOURCES TARGETED TOWARDS REACHING A DECISION?
This criterion is essentially a combination of moderate resource needs and a clear
presentation of trade-offs. It implies that an on-going clarification of issues will be
achieved during the process, without incurring unnecessary costs.
3.13. ARE TRADE-OFFS PRESENTED CLEARLY?
This criterion highlights those methodologies which are likely to provide the decision-
maker with a clear series of choices between different areas of impact. It disqualifies both
those methodologies that proceed to presentation of a final score and those that progress
no further than a disaggregated presentation of data.
246
•tetaf tapKt dfniflcucc la EIA
3.14. DOES THE METHODOLOGY CONTAIN A TECHNIQUE THAT, IN ITSELF, IS A USEFUL
ANALYTICAL TOOL?
It is important that the value of quantitative techniques to the EIA process is not
overlooked. Their role should, however, be confined to that of an in-house analytical
tool, applied only to the types of impact that lend themselves to a quantitative treatment.
Scaling procedures such as the function curves used to define environmental quality in
the Battelle methodology (Dee el al., 1973) and WRAM (Solomon et al., 1977) are of
value in this respect. Also noteworthy are the transparent impact map overlays to be
found in McHarg (1969), and the impact identification networks of Sorenson (1971).
3.15. RESOURCE NEEDS OF THE METHODOLOGY ARE UNLIKELY TO BE EXCESSIVE?
The methodologies that do not qualify in respect of .this criterion are those which are
likely to incur high costs, either through the need for such high quality data or via
expensive public participation programmes.
3.16
Examination of Table 1 allows comparison of the performance of the 24 methodologies
against the IS evaluative criteria. The criteria can all be seen as positive aspects,
worthwhile goals for any assessment technique. The qualification of a methodology for a
particular criterion is indicated by a "X" in the appropriate cell of the table. It is thus
possible to give a broad outline of the attributes held by the methodologies within each
of the six groups.
It appears that the methodologies in group I consider impact significance explicitly,
perform a number of weighting operations where appropriate and progress explicitly
towards a fully aggregated "final score" presentation. In most other criteria they fail to
score, although aspects of some would be useful components of a methodology for
which quantitative presentation of certain impacts was necessary.
Group 2 methodologies appear generally to be an improvement on those in group 1.
They incorporate public opinion in some cases, which tempers the influence of the study
team, and favour semi-aggregation of impacts and a restricted use of quantification with
the emphasis on targeting resources towards the clarification of trade-offs.
PADC methodology (Clark etal.,\ 983) of group 3, scores highly, except that there is
no specific provision for public participation which, it is felt, is a major omission. The
methodology of Leopold et al. (1971) scores poorly, but was a forerunner of many
techniques and as such contributed to development of EIA procedure.
Group 5 and 6 methodologies are at fault in not presenting an explicit indication of
significance, relying instead on a composite value that is part impact magnitude and part
subjectively assigned importance. In general, they adapt well to many different types of
project and have lower resource needs than their counterparts in groups 1-4. Some of
group 6 aid the development of low impact alternatives, and McHarg (1969) scores
highly by virtue of its presentational qualities.
It would, however, be wrong to sum the number of Xs for each methodology in order
to determine a rank order. To do so would effectively place an equal weight on each
criterion when such is not the case. Of the IS evaluative criteria, it is felt that several are
absolutely essential to the development of good EIA practice. Significance must be
considered discreet from impact magnitude; and there must be some input^
opinion to regulate the influence of the study team. Development of
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ATTACHMENT 4.F
DEFINITIONS FOR DESCRIBING SIGNIFICANCE OF IMPACTS
Impact definitions currently used in the Canadian approach to biophysical
environmental impact analysis. (Source: Conover, S. A. M., K. W. Strong, T. E.
Hickey, and F. Sander. 1985. An evolving framework for environmental impact
analysis. I. methods. Journal of Environmental Management 21:343-358)
Thresholds of potential impacts. (Source: Haug, P. T., R. W. Burwell, A. Stein, and
B. L. Banduski. 1984. Determining the significance of environmental issues under the
National Environmental Policy Act. Journal of Environmental Management 18:15-24)
4.F-1
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4.F-2
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Impact definitions currently used in the Canadian approach to biophysical
environmental impact analysis. (Source: Conover, S. A. M., K. W. Strong,
T. £. Hickey, and F. Sander. 1985. An evolving framework for environmental
impact analysis. I. methods. Journal of Environmental Management 21:343-
358)
Impact Definitions
A Major Impact is defined as one affecting a whole population or species in sufficient
magnitude to cause a decline in abundance and/or change in distribution beyond which natural
recruitment (reproduction, immigration from unaffected areas) would not return that population
or species, or any population or species dependent on it, to its former level within several
generations. (In some instances, with respect to resource use by humans, an impact that might
not satisfy the above conditions might nevertheless result in significant effects on the human
user. Thus, a major impact may also be classified as one that affects a subsistence or
commercial activity to the detriment of the user.)
A Moderate Impact is defined as one affecting a portion of a population which may result
in a change in abundance and or distribution over one or more generations of that portion of the
population or any population dependent on it, but which does not change the integrity of any
population as a whole. It may be localized.
A Minor Impact is defined as one affecting a specific group of individuals in a population
at a localized area and/or over a short period (one generation or less), but not affecting other
trophic levels or the integrity of the population itself.
A Negligible Impact is defined as one affecting the population or specific group of
individuals at a localized area and/or over a short period in such a way as to be similar in effect
to small random changes in the population due to environmental vagaries, but having no
measurable effect on the population as a whole.
In many instances, either no interaction occurs, or the interaction does not result in an
impact of any sort. Such instances will be identified as no impact.
In some cases, a positive impact may be registered. These will also be identified, using
the same definitions as above with the positive nature of the impact identified.
4.F-3
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Thresholds of potential impacts. (Source: Haug, P. T., R. W. Burwell, A.
Stein, and B. L. Banduski. 1984. Determining the significance of environmental
issues under the National Environmental Policy Act. Journal of Environmental
Management 18:15-24)
Thresholds of Potential Impacts
Highest priority - legal thresholds. Thresholds of impacts or resource use established by
law or regulation. These may not be exceeded under any circumstances.
Very high priority -functional thresholds. Thresholds established for resource use, or
thresholds involving unavoidable adverse impacts on the human environment, and so great that,
if these thresholds are exceeded, the impacts will disrupt the functioning of an ecosystem
sufficiently to destroy resources important to the nation or biosphere irreversibly and/or
irretrievably.
High priority - normative thresholds. Thresholds of impacts or resource use that are
clearly established by social norms, usually at the local or regional level, and often tied to social
or economic concerns.
Moderate priority - controversial thresholds. Thresholds of impacts or resource use that
are highly controversial, or which are sources of conflict between various individuals, advocacy
groups, or organizations, and which do not warrant higher priority for other reasons.
Low priority - preference thresholds. Thresholds of impacts or resource use that are
preferences of individuals, groups, or organizations only, as distinct from society at large, and
which do not warrant higher priorities for other reasons.
4.F-4
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ATTACHMENT 4.G
DETERMINING IMPACT SIGNIFICANCE IN EIA
Thompson, M. A. 1990. Determining impact significance in EIA: a review of 24
methodologies. Journal of Environmental Management 30:235-250.
4.G-1
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4.G-2
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Journal
Oj^^^^gmntn\
tal Management (1990) 30, 235-250
Determining Impact Significance in EIA: a Review of 24
Methodologies
Mark A. Thompson
IS Atherford Road, London SW9. U.K.
Received21 November 1988
The determination of impact significance from predictions of impact magnitude
is a source of much debate among proponents and practitioners of
environmental impact assessment (EIA). Of particular concern has been the use
of formal quantitative methodologies for comparing project alternatives in
order to produce a total impact score for each alternative. It has been suggested
that this technique removes the responsibility for the decision from the hands of
elected decision-makers. This study concerns a review of 24 EIA methodologies,
concentrating on the way in which each addresses the issue of impact
significance. The methodologies are each assigned to one of six groups
according to their performance against a number of basic criteria. The
characteristics of each group are outlined with, by way of illustration, a ''••
description of one methodology from each group. A set of 15 evaluative criteria
is then presented. These criteria emerged from discussions with a number of
EIA practitioners and from reviews of previous general critiques of
•methodologies. The criteria are then used to re-evaluate the 24 methodologies in
order to display the merits and limitations of each, and to highlight attributes
essential to any worthwhile methodology. Finally, recommendations for a
coherent approach to EIA and warnings against using unsuitable techniques are
presented, together with suggestions for future training and research that might
benefit EIA practice.
Keywords: environmental impact assessment, significance, methodology
1. Introduction . .
The recent implementation of the European Directive on Environmental Assessment
(85/337/EEC) makes environmental impact assessment (EIA) mandatory for certain
types of development project and discretionary for many others. It is likely that the next
few years will see an increase in the number of EIAs produced. The directive has the
following to say regarding the application of EIA in the planning process:
... development consent for public and private projects which are likely to have significant
effects on the environment should be granted only after prior assessment of the likely
significant environmental effects of these projects has been carried out (Council of the
European Communities, 1985).
0301-4797/90/03023 J+16103.00/0
235
(Q 1990 Academic Pren Limited
taQA
This need to determine "significant effects" reinforces the importance of understanding
the various methods that can be used to arrive at a list of significant impacts.
2. Classification of EIA methodologies according to treatment of Impact
significance
In order that EIA may fulfil its function as a decision-making tool, it is necessary that
there be a clear distinction between impact magnitude and impact significance. The
former is arrived at by prediction based upon empirical measurement, the latter is an
expression of the cost of a predicted impact to society. Previous studies have tended toj
stress the organizational characteristics of EIA methodologies, classifying them as being
of an Ad Hoc, Checklist, Matrix. Network or Overlay type. It is felt that a reclassifica-
tion on the basis of the approaches used to determine significance is more appropriate.
Accordingly, a group of 24 methodologies has been examined for the extent to which
they fulfil the following criteria:
1. Is the issue of impact significance considered at all, and, if so. is it handled
discretely from impact magnitude?
2. Can the methodological guidelines for determining significance be described as:
(a) precise and explicit?
(b) non-existent?
(c) intermediate between (a) and (b)?
3. Are directions given for aggregation of impacts for use in comparing project
alternatives?
4. Does the methodology explicitly require an element of public participation?
Whilst it is recognired that the methodologies could arguably be represented as
different points on a continuum, it is felt that six discrete groupings can be defined using
the above criteria (see Figure I) from which further assessment can proceed. By way of
illustration, an example from each of the six groups is presented.
2.1. GROUP I
The Water Resources Assessment Methodology (WRAM) (Solomon et al., 1977) makes
explicit use of scaling and weighting methods. Environmental, social and economic
components are weighted by an interdisciplinary team using a ranked pairwise compari-
son technique. Scaling is achieved by three alternative approaches; the use of the scaling
part of the weighted ranking technique; the use of function curves (see also Dee et al.,
1973); and the proportioning of resulting scaled impacts. Full details are included on
how this scaling may be carried out. Values obtained for the effects of each alternative on
specific environmental components are expressed in terms of "alternative choice co-
efficients". Weighting and scaling values are multiplied in a matrix to produce a final
aggregate score for each alternative. At no stage is there an input of public opinion.
2.2. GROUP 2
The Crawford Methodology (Crawford, 1973) has less explicit guidelines than those
exhibited in group I. It was devised for use in highway route planning and makes
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217
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extensive use of public involvement by employing a Delphi technique on three reference
publics to gather information for the following:
I. The assigning of relative weights.
2. The prediction of consequences for the alternatives to be evaluated.
3. Estimations of probability for the predicted consequences.
4. Numbers to represent the magnitude of the impact of each consequence on each
evaluative criterion.
An interdisciplinary panel of experts is responsible for predicting consequences and
estimating probabilities for each highway corridor alternative. Estimates of impact
magnitude are developed on a seven point scale, from + 3 to - 3. The impact of an
alternative on each of a set of evaluative criteria is then calculated by multiplying impact
size by its probability. Results are then presented showing each highway alternative as a
percentage of the maximum possible positive or negative impact. Crawford presents this
as a basis for analysing the value trade-offs involved in a decision between project
alternatives.
2.3. GROUP 3
The PADC methodology (Clark
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M. A.
239
A rating scheme from I to 10 is suggested as a means of discouraging purely
subjective opinion and the method asks that impact statements should contain the
reasoning behind the assignment of values for magnitude and importance.
2.5. GROUP 5
The Fischer and Davis methodology (Fischer and Davis, 1973) does not explicitly
differentiate between impact magnitude and significance. A complex three-phase process
is handled by an interdisciplinary team to develop an implicit indicator of significance.
Impacts are assigned a " + " (benefit) or " - " (cost), for which some guidance is given,
and the degree of impact from I (low) to 5 (high) is assigned subjectively by the team.
Additionally an "s" or "I" suffix is used to indicate short-term or long-term impacts.
Those achieving plus or minus 4 or 5 scores are transferred from an "environmental
compatibility matrix" to a "decision matrix".
The exclusion of "low strength" impacts from the decision matrix can be seen as
risking the loss of valuable information, or as focusing the study upon "key issues",
depending upon one's viewpoint. The authors claim that the methodology:
... recognises that many decisions are based upon judgement and works to sharpen that
judgement rather than increase precision at the expense of clarity. (Fischer and Davis, 1973, p.
225.) .
2.6. GROUP 6
The Loran methodology (Loran, 1975) does not consider significance explicitly and
makes no specific provision for input of public opinion. It uses a matrix of 234 project
activities and 27 environmental features. Each element is scaled according to a forecast
severity of impact from 0 (none) to 5 (severe) by the interdisciplinary team. The result is
'recorded using a computer algorithm and a primitive aggregation of impacts is achieved
via a "clustering" of highly rated impacts.
It is suggested that the technique serves to identify critical environmental areas. No
further evaluation is made and it is not clear how project variant discrimination should
proceed. Neither is it clear how isolated high impact values, distant from the "clusters"
should be treated.
2.7
The different approaches to handling impact significance, represented by the above
examples, exhibit a wide range of techniques from highly quantitative through to
qualitative. Whilst it is not suggested that any are ideal, many incorporate ideas or
techniques that could be included in any useful EIA methodology. Having outlined the
existing range of EIA methodologies, the following section presents a number of
attributes which it is felt are either essential or desirable in an EIA methodology. On the
basis of these attributes, the 24 methodologies are further evaluated.
3. Evaluation of EIA methodologies
Information gained from three sources namely: the review of 24 methodologies already
presented, together with conclusions drawn from discussions with a number of EIA
practitioners, and examination of general methodology reviews (see, for example,
240
ripttem* to EIA
Environmental Resources Ltd, 1981) provided the basis for the set of evaluative criteria
that follows. It is felt that using the experience gained in the practical application of EIA
to evaluate and criticise methodologies should serve to highlight a group of components
to be included in any useful methodology. The wide variety of applications to which EIA
can be put, however, precludes the possibility of defining a single technique of universal
suitability. The following list of criteria should be used as a guide to Table 1 wherein the
extent to which the methodologies fulfil the criteria is shown.
3.1. IS IMPACT SIGNIFICANCE CONSIDERED DISCRETE FROM IMPACT MAGNITUDE?
It is of paramount importance to the EIA process that an attempt is made to ascribe
significance to any given impact. Not to do so is to leave a project unrelated to the
proposed receiving environment. As each site is unique, it will respond in a unique way
to any given development. Statements of impact magnitude will, therefore, differ in
significance between any two sites. What the decision-maker requires is an expression of
this significance. As applied to the 24 methodologies, this criterion differentiates between
those that present raw or scaled data with a derived value to indicate significance, and
those that simply present one value to indicate importance.
3.2. IS SEMI-AGGREGATION THE END RESULT OF THE PROCESS?
The attraction of an aggregate "final score" for each project alternative at the end of a
complex assessment procedure is understandable. An "answer" may be felt to help
justify expenditure of effort and resources. The main disadvantage of this approach is
that scores mask the strengths and weaknesses within each project alternative. This
works against the interests of effective project modification because information needed
to perform trade-offs between different areas of impact is obscured.
In contrast, semi-aggregation, where impacts are grouped under any number of
suitable headings such as "ecology" and "infrastructure" makes clear which project
alternative will produce the best result in relation to any given heading. This allows the
decision-maker to draw conclusions based upon a relatively small number of trade-offs
and the degree of priority he or she feels is appropriate to different areas of concern. For
instance, if "ecology" and "agriculture" are favoured, alternative "A" may be chosen,
whilst weighting in favour of "housing" and "employment" might lead alternative "B"
to be chosen.
Semi-aggregation should also help to avoid giving the misleading impression of
scientific accuracy to which full aggregation of impacts is prone. It has been argued that
the latter may be used to avoid scrutiny by members of the lay public. Bisset (1978)
remarks that:
Those who choose the method of assessment are able to make a strategic choice which may
give a tactical advantage when pursuing a particular outcome. (Bisset, 1978, p. 56.)
He suggests that opposition views may be weakened by putting them through a method
designed to overcome opposition and so remove assessment from public debate. Hobbs
(1985) also advises caution on the use of impact amalgamation which, it is argued,
should only proceed to a level consistent with maximum clarification of trade-offs. This
leaves room for the essential subjective element of the assessment process that is the
responsibility of the elected and accountable decision-maker.
-------
M. A.T*»BIWM 241
3.3. ARE METHODS PROPOSED TO ENSURE PUBLIC PARTICIPATION?
The significance or an impact is essentially an expression of the cost or value of an
impact to society. Beanlands and Duinker (1983) state that:
... what is really or concern at the derision-making level is the significance to society as
determined through social and economic values. Significance ... cannot be confined to what
we regard as biologically significant (Beanlands and Duinker, 1983. p. 45.)
The focus of EIA, therefore, must be a judgement as to whether or not impact* are
significant, based upon the value-judgements of society, or group* of people chosen to
represent the wishes of society. As stated by Pattison (1976):
Our benchmarks for clean air, clean water or clean street* have lea* to do with a definable
"degrees above zero" than with what various member* of the public consider acceptable or
attainable. No matter how accurately the probability and magnitude of certain fish kills are
quantified, the "impact" of such kills is essentially subjective, loaded with emotional factors
not amenable to cost value analysts. It is the impact of a particular set of findings or
predictions upon the minds of men, not the impact of the pollutant on the environment per se
that is our key unknown. (Pattison, 1976.) -.
If this is accepted, then it is clear that an assessment of the way in which significance is
handled by EIA methodologies should include consideration of the value-judgements
made, whose values they actually represent, and whether or not they can be taken as
representative of society as a whole.
Unless a methodology contains specific provision for an element of public opinion,
there is a danger that the views of study-team members may exert undue influence upon
the result. Few would question the use of experts to define impact magnitude, but leaving
them as sole arbiters of significance is open to challenge. O'Riordan (1976) quotes
Joseph Sax, a noted American lawyer and EIA advocate:
... the special knowledge of the highly trained mind produces its own limitations, and it may
be argued that expertise sacrifices the light of common sense to the intensity of experience. It
breeds an inability to accept new views from the very depths of its preoccupation with its own
conclusions There is also a class spirit about it so experts tend to neglect all evidence that
does not come from their own ranks. Above all, where human problems are concerned, the
expert fails to see that whatever judgements he makes, which are not purely factual in nature.
bring with them a score of value* which has no special validity about it (O'Riordan, 1976, p.
279.)
An example of expert judgement likely to be at odds with public opinion can be
found in the Battelle methodology (Dee et at., 1973) where, as observed by Dickert and
Domeny (1974) the assignment of over a third of possible weighting points to
environmental pollution, whilst only 26 (out of a total 1000) go to housing and
employment opportunities, is unlikely to find favour with those from low socio-
economic groups.
There is a clear need to achieve a balance between expert opinion and the wishes of
society in general. The assignment of weights in favour of long-term considerations such
as the continued integrity of ecological systems may be at odds with the more immediate
socio-economic needs of huge sections of society, but, if the EIA process is to gain the
support of the general public, then their immediate needs cannot be overlooked.
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-------
M. A-l^fem 247
I should be encouraged and resources targeted towards a clear presentation of
trade-offs.
A number of other points are worthy of consideration prior to the formulation of an
approach to any EIA.
3.17. CLARIFICATION OF ASSESSMENT GOALS
A correct approach to EIA requires thorough forward planning. The aim of the study
must be clearly defined, based on an understanding of the exact nature of the decision to
be made. Project resources can then be directed towards a continual clarification of the
main issues involved and a sharpening of the judgement of the team responsible for the
study. Specific assessment techniques should be selected to perform appropriate tasks
and not used simply because they are suggested in any set of guidelines.
3.18. PRESENTATION OF DATA
Where both quantitative and qualitative data are presented, care should be taken that
the former are not given undue emphasis. The conversion of raw data by scaling,
ranking or rating, results in a loss of information that may be both of use and readily
comprehensible to the decision-maker. If it is accepted that a semi-aggregated presenta-
tion of data under broad impact-type headings is of most use to a decision-maker, then
complex data manipulations can be avoided. Qualitative impact descriptions, combined
with quantitative data where appropriate, should suffice to indicate which project option
is favourable for any given impact type. It is then for the decision-maker to make the
necessary value-judgements.
The presentation techniques chosen should serve to highlight trade-offs. The use of
checklists, matrices, graphs, summary tables and transparent map overlays may all be of
value as long as their use is integral to the assessment, and not merely cosmetic. Such
graphic presentation may be very persuasive and should be justified by the importance of
the information it represents.
3.19. THE STUDY-TEAM INFLUENCE
All decisions made by the study-team should be adequately documented if possible in the
main body of the report and not in appendices or additional volumes. Whilst the
attraction of separating details of the techniques employed is understood, it is necessary
that the decision-maker and any lay-readers have the reasons for any decision or line of
procedure readily to hand. If not, their understanding of the report will be incomplete.
The use of structured group decision-making techniques should be considered by the
study-team to ensure that a true consensus of views within the group is reached.
3.20. UNSUITABLE TECHNIQUES
It is recommended that the degree of quantification of impacts should be carefully
regulated, particularly in cases where only a few project alternatives exist, and a
relatively "coarse" assessment may be adequate to determine the standing of each
alternative with respect of any particular impact. Further refinements, which are
unnecessary to the decision, may prove costly in time and money and might only serve to
complicate the issue.
MS DettraWivlapMtripttcwiittlaEIA
It is strongly recommended that methodologies which proceed through full aggrega-
tion of impacts to a "final score", should not be used as an assessment technique, the
results of which are intended for use by the decision-maker. Such an approach would
remove the decision from those appointed or elected for that purpose and place it in the
hands of the study-team. There is, however, a strong case for using certain component
techniques from such methodologies as in-house tools for the clarification of certain
impacts.
Arbitrary weighting schemes that are the product of study-team preferences should
also be avoided. The impression gained from consultation with EIA practitioners is that
weighting of impacts is commonly performed, but most agreed that it is necessary to
confine this weighting to an in-house procedure. If a public consultation process is
operating, the basis of a weighting scheme not derived solely from expert opinion should
be readily to hand.
4. Future training and research
An awareness and understanding of the use of quantitative techniques is essential to the
production of good EIAs in the future. Appreciation of their merits, limitations and
most appropriate areas of application will hopefully serve to eliminate the use of
numbers for their own sake. In its place must come appropriate quantification, i.e.
quantification that is both reserved for impacts that lend themselves to such treatment
and that results in a clarification and not a clouding of the issues. Accordingly,
competence in the performing of impact prediction, scaling, weighting and aggregation
is essential for the analyst. This competence should, however, be accompanied by an
appreciation that the role of these techniques is best restricted to the in-house level.
A point worthy of strong emphasis, when training future EIA practitioners, is that
standard methodologies and techniques are, in every case, of secondary importance to
an appreciation of the unique nature of the project and its interaction with the
environment. Quantitative techniques should be seen as useful tools to aid the
evaluation and expression of this interaction. Otherwise, a pre-occupation with compre-
hensive assessment methodologies runs the risk of reducing the project's status to that of
a source of raw data with which to complete the various "boxes" of a methodology.
Prediction, probability and risk analysis are areas in which improvements in
information and understanding would benefit the EIA process, by working towards
more reliable statements of impact magnitude.
Study could also usefully be made of current trends and practice in public
consultation. Within the field of EIA, this study will determine the current state and
highlight areas of deficiency. A study of related fields where information is gathered
from populations may provide a number of techniques which could be applied
innovatively in EIA.
It is important that the products of any such research are effectively communicated.
Alerting the developers responsible for large projects to the benefits of public consul-
tation is worthwhile, one of the main benefits being the avoidance of costly and
protracted public inquiries.
The range of methods available to a study team for maximising the objectivity of
their output is also worthy of study. Useful options must exist in other fields, which
could be applied to the EIA process.
-------
24»
References
Adkins, W. O.. and Burke D. Jr. (1974). Social. Economic and Environmental Fatten In Highway Decision-
Making. Research Report 148. Teui A and M Univenily College Station. Texas.
Allell, E. J. (1986). Environmental impact assessment «nd decision analysis. Journal of Operational Research
Society 37, 901-910.
Baumann. N., Ervin, O. and Reynolds, O. (1982). The policy Delphi and public involvement program*. Water
Resources Research 18, 721-729.
Beanlands, O. E. and Duinker. P. N. (1983). An Ecological Framework of EM at Canada. Institute for
Resource and Environmental Studies. Dalhousie Uni.
Bissett, R. (1978). Quantification, dedsion-inaking and environmental impact assessment in the U.K. Journal
of Environmental Management 7,43-58.
Bissett, R. (1980). Methods of environmental impact assessment: recent trends and future prospects. Journal of
Enrironmental Management II, 27-43.
Clark. B. D.. Chapman, K., Bisset, R.. Wathern, P. and Barrett, M. (1983). A Manual for the Assessment of
Major Development Proposals. PADC Aberdeen University. London: HMSO.
Council of the European Communities (1985). Council Directive 85/337/EEC. Official Journal of the European
Communities.
Crawford, A. B. (1973). Impact Analyst, Using Differentially Weighted Evaluation Criteria, in Multiple Criteria
Decision Making. Cochnne, J. L., and Zdcny, M. (eds). Columbia, SO University of South Carolina
Press.
Dee, N., Drobny. N.. Duke, K., Whimann, I.. Fahringer, D. (1973). An evaluation system for water resources
planning. Battelle Laboratory Water Resources Research 9. 523-535.
Delbecq, A. L. and Van De Yen, A. H. (1974). The effectivenesi of nominal, Delphi and interacting group
decision-making processes. Academy of Management Journal 17.
Dkkert, T. O. and Domeny, K. R. (eds). (1974). Environmental Impact Assessment: Guidelines and
Commentary. Berkeley, California.
Eliotl, M. L. (1981). Pulling the pieces together amalgamation in EIA. EIA Review 2, 11-38.
Environmental Impact Centre, Inc. (1973). A Methodology for Assessing the Environmental Impact of Water
Resources Development. PB-226 545. VS. Dept. of the Interior, Bureau of Reclamation, Denver.
Colorado.
Environmental Resources Limited. (1981). Environmental Impact Assessment. Studies on Methodologies.
Scoping and Guidelines. Final Report for the Oovt. of the Netherlands. London: ERL.
Environment Canada (1974). AH Environmental Assessment ofNamomo Port Alternatives. Ottawa. Environ-
ment Canada.
Ertel, M. O. (1979). A survey research evaluation of citizen participation strategies. Water Resources Research
IS, 757-763.
Fischer, D. W.. and Davis, O. S. (1973). An approach to assessing environmental impact! Journal of
Environmental Management I, 207-227. ..
Hill, M. (1966). A method for evaluating alternative plans: the goats-achievement matrix applied to
transportation plans. Ph.D. Dissertation, Univenily of Pennsylvania, Philadelphia, PA.
Hobbs, B. F. (1985). Choosing how to choose: comparing amalgamation methods for EIA. EIA Reviews, XI-
319.
Hollick. M. (1981). The role of quantitative decision-making methods in environmental impact assessment.
Journal of Environmental Management 12,65-78.
Kane,}., Vertinsky. I. and Thompson, W. (1973). A methodology for interactive resource simulation (KSIM).
Water Resources Research 9,65-79.
Keeney. R. L. and Robilliard. O. A. (1977). Assessing and evaluating environmental impact at proposed
nuclear power plant sites. Journal of Environmental Economies and Management 4, 153-66.
Knuskopf. T. M. and Bunde, D. C. (1972). Evaluation of environmental impact through a computer
modelling process. In Environmental Impact Analysis—Philosophy and Methods. Dillon. R. and Ooodale,
T. (eds), pp. 107-125. Madison Wl: Univenily of Wisconsin Sea Grant Program, 107-125.
Leopold, L. R., Clark. F. A.. Henshaw. B. R. and Balsey, J. R. (1971). A Procedure for Evaluating
Environmental Impact. VS. Geological Survey Circular 64S.
Loran, B. (1975). Quantitative amiuiirut of environmental impact Journal of Environmental Systems S, 247-
256.
McAllister, D. M. (1980). Evaluation In Environmental Planning. Assessing Environmental. Social. Economic
and Political Tradeoffs. Cambridge, MA: MIT Press.
Matthew, W. H. (1975). Objective and subjective judgements in environmental impact assessment. Environ-
mental Conservation*, \2l-\l\.
McHarg, I. L. (1969). A Comprehensive Highway Route Selection Method, In Design with Nature, pp. 31-41.
New York: Doutrieday.
Multiagcncy Task Force. (1972). Guidelines for Implementing Principles and Standards for Multtoojective
Planning of Water Resources. Review Draft. Washington. D.C.: U.S. Bureau of Reclamation.
ISO Ornnalafcg tauwct tJgmfirtmn vrn DA
Odum E. P. (1971). Optimum Pathway Matrix Analysis Approach to the Environmental Decision Making
Process: Test COM. Relative Impact of Proposed Highway alternatives. Athens, OA: University of Georgia.
Institute of Ecology.
O'Riordan. T. (1976). Enviiownentallsm. London: Pion.
Pattison, E. S. (1976). The key ecological unknown. Technology Review 3.
Rosa, J. M. (1976). The Numeric Weighting of Environmental Interactions. Occasional Paper No. 10. Ottawa
Lands Directorate. Environment Canada.
Soil Conservation Service (1977). Guide for Environmental Assessment. U.S. Depl. of Agriculture.
Solomon, R. C. Colbert. B. K.. Hansen. W. J.. Richardson. S. E., Canter. L. and Vlachos, E. C. (1977). Water
Resources Assessment Methodology (WRAM) Impact Assessment and Alternative Evaluation. Technical
Report No. Y-77-1 Vickiburg, Mississippi, U.S. Army Corps of Engineers.
Sondheim. M. W. (1978). A comprehensive methodology for assessing environmental impact. Journal of
Environmental Management 6, 27-42.
Sorensen. J. (1971). A Framework for Identification and Control of Resource Degradation and Conflict In the
Multiple Vse of the Coastal Zone. Berkeley, CA: Dept. of Landscape Architecture, University of California
at Berkeley.
Stover, L. V. (1972). Environmental Impact Assessment. A Procedure. Miami. FL: Sanders and Thomas.
Thompson, M. A. (1988). The determination of impact significance in environmental impact assessment. MSc.
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39pp. Vehicle Highway Research Council. Charlottesville, VA.
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4.5
Mitigation
Mitigation measures are actions designed to minimize or to compensate for
undesirable impacts of a proposed activity. Furthermore, they are often the focal
points for opposition and debate relative to projects. (Canter et. al 1991;
Attachment 4.H). Although the U.S. regulations implementing NEPA include
avoidance as a mitigation measure, many practioners make a distinction between
avoidance as a mitigation measure and other types of mitigation [i.e., reducing
or eliminating parts of the proposed activity; repairing, rehabilitating, or restoring
the affected environment; instituting management practices over the life of a
project to reduce or eliminate the impact; or replacing or providing substitute
resources or environments (i.e. compensation) (Table 4.5-1)]. These categories
of mitigation are arranged in order of their desirability; compensation is the least
desirable approach.
Table 4.5-1. Categories of Mitigation. (Source: Adaptation of Council on
Environmental Quality Regulations, 40 CFR 1508.20)
1. Avoidance: Mitigation by not carrying out the proposed action or the unacceptable part* of the
proposed action. For example, if the only area available for a regional airport happen*
to be an area of extensive wetland* that would be filled in by construction of the airport,
avoidance of the action might be the only reasonable way to protect those wetlands.
2. Minimization: Mitigation by scaling-down the magnitude of a project, reorienting the layout of the
project, or employing technology that reduce* the factors generating the undesirable
environmental impact. For example, the treatment capacity of a wastewater treatment
plant discharging to a river might be reduced or it might be required to use advanced
water treatment technique*.
3. Rectification: Mitigation thiough the restoration of environments affected by the action. For example,
area* cleared for the installation of pipelines or power lines can be regraded and then
replanted with native vegetation.
4. Reduction: Mitigation by talcing maintenance steps during the course of the action. For example,
stonnwater management system* can be designed to trap sediment* from developed areas.
5. Compensation: Mitigation through the creation, enhancement or acquisition of environment* similar to
those affected by an action. This step should only be considered after all steps above
have been completed. A* a last resort, donation of land or money for a regional program
of habitat creation or enhancement could be considered.
4-71
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Ideally, potential impacts of a proposed activity are identified early during
the initiation and scoping stages of a project and all reasonable means to avoid
and minimize impacts are incorporated into the alternatives that are being
considered. Compensation for the remaining impacts is a final stage of
mitigation.
If the acceptability of an alternative depends on fulfillment of certain
mitigation measures, then it is important to clearly specify and consider the
mitigation measures) in the analysis of alternatives and to ensure that any
mitigation measures are incorporated into the final decision on the proposed
activity. Records of decision in the United States must identify the mitigation
measures and the monitoring and enforcement programs that the agency has
committed to adopt. These commitments are legally enforceable when they are
included in permits, licenses or grants. However, other than monitoring for
conditions written into permits, licenses or grants, the EA laws of most countries,
(excepting the United States and The Netherlands) do not explicitly require post-
EA monitoring for the effectiveness of mitigation measures. Thus, there is
generally no motivation to confirm that mitigation measures identified during the
planning stages of a proposed activity and/or written into a decision document are
actually carried out.
NEEDS
• Effective mitigation planning based on the availability of
information for and understanding of the proposed activity, its
potential impacts, and the affected environment.
• Identification of realistic mitigation goals and measures.
Innovative approaches and attitudes should be encouraged in
solving problems and developing mitigation plans. The public may
provide acceptable ways of resolving local issues of concern
(Attachment 6.A).
• Identification of any local, regional, tribal, national or international
laws, regulations, or standards that may affect proposed mitigation
measures. For instance, the U.S. Surface Mining Control and
Reclamation Act has requirements which must be undertaken to
avoid, reduce or compensate for adverse impacts of mining
activities.
• Surveillance and legal and regulatory enforcement of mitigation
measures. Non-governmental organizations can play an important
role in overseeing the effectiveness of mitigation actions.
4-72
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• Periodic evaluation of mitigation measures and subsequent
modification as appropriate (Chapter 6).
TOOLS
• Checklists
For many major activities, the environmental issues and
potential environmental impacts are well known and there
are recognized common mitigation measures. Checklists,
either computerized or otherwise are a good way to screen
proposed activities for potential impacts and to identify
potential mitigation measures. The U.S. Army
Construction Engineering Research Laboratory
(Champaign, Illinois) operates an Environmental Impact
Computer System that indicates, for various project
activities, the probability of impact occurrence, why the
activity was scored as it was, and ways to lessen or avoid
the impacts of the activity. The World Bank has recently
published (1991) an Environmental Assessment Sourcebook
that reviews the major issues and provides checklists of
potential negative impacts and mitigating measures for 32
different development, urban, energy, and industry projects
(Attachment 2.B).
• Case Studies
Review of EA documents for similar projects is a useful
way to identify potential impacts and associated mitigation
measures. Canter et al. (1991) summarized the general
biological impact mitigation measures for wastewater
treatment projects, surface mining operations and highway
projects found in 18 environmental impact statements and
three project reports (Attachment 4.H). Certain impacts
were generic to nearly all major construction activities;
operational phase impacts were addressed less frequently.
The specifics of the mitigation measures varied in
accordance with the location and magnitude of the proposed
activity. Table 4.5-2 summarizes the predicted impacts and
associated mitigation measures of these 21 studies. It is
not meant to be all inclusive but is included here as an
indication of some of the approaches to mitigation.
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Table 4.5-2. Summary of Impacts and Mitigation Measures
for 21 Projects (Eight Wastewater Treatment Facilities, Five Surface
Mining Operations, and Eight Highway Construction Projects.
Adapted from Canter et. al. 1991).
Impact
Mitigation Measure
Lot* or disturbance of vegetation
Disruption or lou of wildlife (including
habitat and outing area*)
Erosion BIK^ aedimentation
Potential iotnxiuctioa of toxic aubitancei
into aoU or surface water
Limit/zone areas to be cleared; Conserve lopaoil; Revegetation
program; Management of reclaimed landi; No uae of herbicide* or
defoliant*
Consult wildlife agencies; Minimize habitat disturbances; Avoid
sensitive areas; Replacement of affected areas (e.g., nesting area);
Creation of aquatic habitat (ponds); Enhancement of habitat; Plan
activities around critical periods for wildlife (e.g., migration,
spawning); Management program; Bus transportation to work site
Schedule activity during dry months; Buffer zones along streams;
Limit area disturbed at any one time; Avoid stream crossing by
boring beneath or bridging across; Temporary cover crops prior to
revegetation; Use of silting basins, traps; Keep excavation
materials away from streams; Slope contouring; rip-rap on bridges
and approach slopes; Stream reconstruction
Control rate of application to acceptable amounts; Dike treatment
works, storage tanks, etc.
Design specifications
During initiation, mitigation measures applicable to design,
construction, operation, and abandonment should be
defined and subsequently incorporated into final design
documents (e.g., best engineering practices; practices
specified by state and local requirements for construction
such as erosion control; American Society for Testing and
Materials Standards). Consultation among project
managers, engineers, and environmental staff helps bring
about clear direction on mitigation through planning,
design, project phasing, construction techniques and
scheduling. Some measures must be individually adapted
to specific project situations, others can be drawn from
reliable resource documents with acceptable mitigative
4-74
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measures (e.g., Forest Service Management Plans).
Individual or innovative measures should be field tested to
verify their adequacy under a range of conditions prior to
wide-spread use.
Once mitigative measures have been incorporated into
project planning and design, the remaining potential
impacts are evaluated during the analysis of alternatives.
The remaining (residual) impacts resulting from the project-
environment interactions will consist of those which were
reduced but not eliminated by mitigative measures and
those for which mitigative measures were not necessary,
not possible or not implemented. Residual impact analysis
can also identify the persistence and duration of any
impacts that may extend beyond the life of the project,
including permanent environmental alterations.
• Expert judgment
The value of expert judgment in the choice and design of
mitigation measures (and to the EA process; Part 4.3) lies
in the ability of the professional to: sort through irrelevant
information to get to the root issue; reach solutions using
incomplete data; make finer categorical distinctions than
non-experts; and perceive recurring patterns in a problem
and to associate solutions to the patterns. This ability is
based on conceptual, analytical and experimental
knowledge acquired through training and practice. The
principal limitations to expert judgment in EA relate to the
quality of expertise and the uncertainty inherent in the
judgment and reasoning of the expert. Moreover, there is
often a great diversity of opinion among experts on any
given environmental question (Nelson 1990). Nevertheless,
there are experts on mitigation who should be consulted on
practices such as revegetation, wetland reclamation, and
erosion control.
ISSUES
• Mitigation strategies may require integrated planning and
negotiation to reduce conflicts with local views, needs, and
customs and local, state, tribal, and other federal agencies
(Attachment 6.A).
4-75
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• Institutional arrangements for implementing and evaluating
mitigation measures must be defined, agreed to, and adequately
budgeted for at the time of decisionmaking. Mitigation, to be
meaningful, must be able to last over time thus the need for post-
project analysis and financial guaranties to ensure that if mitigation
does not succeed initially, as proposed, further efforts will be
made to achieve the objectives described in the decision document.
The selected alternative and its associated mitigation then become
the basis for the conditions of permits, contracts, and the detailed
design of the project.
• There are many approaches to identifying potential mitigation
measures for adverse biological impacts of proposed projects (e.g.,
checklists, computerized systems, case studies, professional
judgment). However, the information provided is mostly generic
and must be adapted to site-specific conditions; the methodologies
have not been used extensively as a part of the EA process; and
data are lacking on the effectiveness of the mitigation measures.
• The reasons given by Lee (1987) for lack of success in mitigation
for wetland loss are applicable to other situations as well. These
include:
inaccurate bounding/delineation of the predicted impact;
use of mitigation as a means to access the resource and/or
to assuage regulators;
inadequately developed or understood technical means to
achieve the mitigation objectives;
use of spatial and temporal scales for mitigation that are
inconsistent with site-specific impacts;
lack of project continuity; although goals are set and
planning is completed, projects are never begun, finished,
or monitored for success.
• Care must always be taken that a mitigation measure does not shift
a problem in one medium to another medium (e.g., air pollution
to waste disposal)
LINKAGES
Consideration of mitigation measures is linked to each element of the EA
process. During the early planning stages of initiation, determination of the need
for and development of mitigation measures starts with the proponent and
continues during scoping with input from the public and other agencies. During
4-76
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the assessment stage, mitigation measures are factored into the analysis of
alternatives. For decisionmaking. EA documentation should include the options
for mitigation of impacts for each of the alternatives if necessary. Throughout
implementation of the project (i.e., construction, operation, and abandonment),
post-decision analysis should evaluate the impacts and the effectiveness of
mitigation measures to allow for modification of the project or development of
addition mitigation measures in case of unpredicted impacts. A post-decision
analysis of mitigation measures provides feedback on the accuracy of impact
predictions and the effectiveness of the mitigation in order to transfer the
experience to future activities of the same type.
REFERENCES
Canter, L. W., J. M. Robertson, and R. M. Westcott. 1991. Identification and
evaluation of biological impact mitigation measures. Journal of
Environmental Management 33:35-50.
Lee, L. C. 1987. Mitigation for wetland loss: how much is appropriate? In:
Environmental Impact Assessment, Proceedings of a Conference on the
Preparation and Review of Environmental Impact Statements (ed. N. A.
Robinson). New York State Bar Association, One Elk Street, Albany,
New York 12207.
Nelson, R. W. 1990. Can experts agree on policy directions toward wetlands
and agriculture? The Environmental Professional 12:131-143.
World Bank. 1991. Environmental Assessment Sourcebook. Volumes I, H, ffl.
The World Bank, Washington, D.C.
4-77
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4-78
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ATTACHMENT 4:
MITIGATION MEASURES
Canter, L. W., J. M. Robertson, and R. M. Westcott. 1991. Identification and
evaluation of biological impact mitigation measures. Journal of Environmental
Management 33:35-50.
4.H-1
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4.H-2
-------
Identification and Evaluation of Biological
Impact Mitigation Measures
L. W. CANTER, J.M. ROBERTSON AND R. M. WESTCOTT
Identification and Evaluation of Biological Impact Mitigation
Measures
L. W. Canter/ J. M. Robertsonf and R. M. Westcott*
•Environmental and Ground Water Institute University of Oklahoma. Norman.
Oklahoma, U.S.A. and ^University of Oklahoma, Norman. Oklahoma. U.S.A.
Received 26 February 1990
Identification and evaluation of mitigation measures for advene biological
impacts of proposed projects are often the focal points for opposition and
debate relative to the projects. This paper delineates several positive approaches
for both identifying and evaluating potential mitigation measures. Identification
approaches include the review of utilized measures for similar projects,
computer-based literature and information searches, and the use of
computer-generated checklists of potential measures. Utilized measures for eight
waslcwaler treatment projects, five surface mining operations and eight highway
projects are described. Evaluation approaches include posl-EIS environmental
monitoring, pre-project qualitative evaluation based on case studies, and
pre-project quantitative evaluation using structured habitat-based methods.
Based upon this review, it has been determined that there are an ample number
of approaches which can be used to identify potential mitigation measures for
the adverse biological impacts of proposed projects. However, while systematic
methodologies are available for evaluating the potential effectiveness of
mitigation measures, these methodologies have not been used extensively as a
part of the EIS process. Additional attention needs to be given to the
incorporation of mitigation evaluation schemes in pre-project environmental
impact studies.
Keywords: environmental impact, monitoring, wastewater, mining, highway
projects
Reprinted from the
Journal of Environmental Management
Vol. 33, No. I, pp. 35-50
July 1991
I. Introduction
Planning and implementation of appropriate mitigation measures for adverse biological
impacts represent important activities in the environmental impact assessment process.
Actual mitigation measures may encompass several techniques. For example, the
Council on Environmental Quality (CEQ) in the United States has indicated that impact
mitigation should include the sequential consideration of the following (Council on
Environmental Quality, 1978): (I) avoiding the impact altogether by not taking a certain
action or parts of an action; (2) minimizing impacts by limiting the degree or magnitude
of the action and its implementation; (3) rectifying the impact by repairing, rehabilitat-
ing or restoring the affected environment; (4) reducing or eliminating the impact over
0301-4797/91/0)0035+16103.00/0
O 1991 Academic Press Limited
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U W. Cuttr *t «t
37
time by preservation and maintenance operations during the lire of the action; and (5)
compensating for the impact by replacing or providing substitute resources or environ-
ments.
Sequential consideration suggests that (he more easily implemented techniques
should be selected first, for example, avoiding impacts or minimizing impacts. Compen-
sation would only be considered if other techniques do not completely satisfy the
mitigation needs. It should also be noted that the techniques are not mutually exclusive,
that is, several might be used in combination in an overall mitigation plan Tor a given
project.
The purpose of this paper is to document several approaches which can be used to
identify both potential biological impact mitigation measures and evaluate their
potential effectiveness prior to and following implementation. The paper will begin with
background information on the institutional requirements for mitigation; this will be
followed by the delineation of several approaches for the identification and evaluation of
specific mitigation measures.
2. Institutional requirements for mitigation
The generic legislation within the United States which calls for biological impact
mitigation is the National Environmental Policy Act (NEPA) of 1969 (PL 91-190).
Procedures for implementing the environmental impact statement (EIS) requirements of
NEPA have been developed by the CEQ. Agencies within the United States are required
to prepare records of decisions (RODs) on projects having EISs. The RODs must state
what the decision was and identify all alternatives considered by the agency in reaching
its decision, specifying the alternative or alternatives which were considered to be
environmentally preferable (Council on Environmental Quality, 1978). In addition, the
RODs shall state whether all practicable means to avoid or minimize environmental
harm from the alternative selected have been adopted, and if not, why they were not. A
monitoring and enforcement program shall be adopted and summarized where appli-
cable for any mitigation program.
Several specific environmental quality and natural resources protection laws have
been adopted within the United States. These laws typically include policies and
implementation requirements for biological impact mitigation measures. Table I
includes an example listing of some of these laws. Two notable laws in addition to NEPA
are the Surface Mining Control and Reclamation Act (SMCRA) which delineates
mitigation requirements directed toward restoring habitat disturbed by surface mining
operations; and the Endangered Species Act (ESA) which addresses requirements for the
protection of habitat for threatened or endangered plant or animal species.
3. Identification of mitigation measures
Systematic approaches can be used to identify potential mitigation measures for the
adverse biological impacts of proposed projects. A complete review of all approaches is
beyond the scope of this paper; however, three examples will be presented: (I) review of
utilized measures for similar projects; (2) use of specific literature-based information on
appropriate measures for reducing particular adverse impacts; and (3) use of a
computer-generated checklist of potential mitigation measures. The review of EISs and
documents can be useful in gaining insight into mitigation requirement
s. To illustrate this usefulness, examples for United States projects in
TABU I. Example listing of United States laws which may directly or indirectly address biological
impact mitigation measures
Anadromout Fish Conservation Act
Bald Eagle Protection Act
Clean Air Act
dean Water Act
Coastal Zone Management Act
Comprehensive Environmental Response, Compensation and Liability Act (Supcrfuml)
*
Endangered Species Act
Federal Insecticide, Fungicide and Rodenticide Act
Fish and Wildlife Coordination Act
Golden Eagle Protection Act
Marine Mammal Protection Act
Marine Protection, Research and Sanctuaries Act
Migratory Bird Conservation Act
National Environmental Policy Act
Resource Conservation and Recovery Act
Superfund Amendments and Reauthorizalion Act
Surface Mining Control and Reclamation Act
Toxic Substances Control Act
Wild and Scenic Rivers Act
Wild Horses and Burros Protection Act
categories—wastewater treatment facilities, surface mining operations and highway
projects—will be presented.
3.1. UTILIZED MITIGATION MEASURES FOR WASTEWATER TREATMENT PROJECTS
Development and implementation of wastewater treatment systems are presumed to be
beneficial to the physical-chemical and biological environments in that the pollutions!
components of wastewaler discharges are minimized. While this is generally true, there
may be many adverse impacts associated with wastewater treatment facilities, including
those that occur to the biological environment. Table 2 contains a summary of the
general biological impact mitigation measures identified in eight EISs. Four major
biological impacts were associated with the construction phases of the facilities.
including two direct impacts (loss of vegetation and disruption of wildlife) and two
indirect impacts (erosion and sedimentation, and destruction of streams and degrada-
tion of water quality). The most frequently used mitigation measure was a revegctation
program. Operational phase impacts were less frequently addressed and include only
two issues: (I) problems from land application of wastewater, and (2) eutrophication
from nutrient additions or accidental discharges.
Construction phase erosion represents one of the major impaq^fetconcern fur
wastewater treatment plants. Basic information necessary for estimf erosion in-
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TABLE 2. Summary of biological impact mitigation measure* for eight wastewater treatment
facilities
Wastewater treatment facililyt
Impact
Mitigation measure
Construction phase
Lou of vegetation
Disruption of
wildlife
Erosion and
sedimentation
Destruction of
streams and
degradation of
water quality
Revegetation pro-
gramme
Reduced destruction
by zoning construction
areas
No use of herbicides
or defoliants
Plan activities around
critical periods for
wildlife
Minimize habitat dis-
turbance
Plan activities during
dry months
Use temporary cover
crops or immediate re-
vegetation
Use silt basin and
structures to catch silt
in runoff
Accomplish stream
crossings by boring
beneath or bridging
across
Keep excavation
materials away from
stream
Operational phase
Land application
of wastewater to
vegetated areas
Eutrophication
and/or degradation
of water quality
+ t +
Control rate of appli-
cation to acceptable
amounts
Use non-phosphate de-
tergents
Enclose major treat-
ment works with dikes \,
fThe facilities are in: (I) El Paso. Texas (U.S. Environmental Protection Agency, 1980); (2) Steamboat
Springs. Colorado (U.S. Environmental Protection Agency. 1977); (3) Fort Worth, Texas (U.S Environmental
Protection Agency, 19836); (4) Beniie County, Michigan (U.S. Environmental Protection Agency. 1979); (5)
Norman, Oklahoma (U.S. Environmental Protection Agency. 19820); (6) Tuba, Oklahoma (U.S. Environ-
mental Protection Agency, 19820); (7) Monterey. California (Monterey Peninsula Water Pollution Control
Agency n al.. 1977); and (8) Blooming-Ion, Indiana (U.S. Environmental Protection Agency, 1976).
t Plus sign denotes mitigation measure mentioned in the EIS for the facility.
UW. Carter «*<* . 39
eludes selected soil properties such as erosion potential, soil suitability for various land
uses and geographical distribution. This information can be procured from several
sources, including a computer data base called SOILS; this data base is part of the
Environmental Technical information System of the U.S. Army Construction Engineer-
ing Research Laboratory (U.S. Army Construction Engineering Research Laboratory.
1988). The information in soils is from the data collection program of the U.S. Soil
Conservation Service.
Commonly used erosion mitigation measures include planning construction during
drier months so that there is less potential for the impact, and revegetation involving
seeding or replanting the area as soon as possible. Physical measures involve the building
of dikes, diversions and stabilizing structures. Table 3 addresses erosion and sedimen-
tation impacts and mitigation measures as related to wastewater treatment facilities:
included are some alternative revegetation enhancement methods (FilzPatrick el al..
1977). There are ample mitigation measures which can be used to minimize the
detrimental biological impacts which might occur as a result of erosion during the
construction phase for wastewater treatment facilities.
3.2. UTILIZED MITIGATION MEASURES FOR SURFACE MINING OPERATIONS
Surface mining activities may cause numerous undesirable impacts on the biological
' environment. The key law related to mitigation measures for surface mining operations
TABLE 3. Mitigation measures for erosion during wastewater treatment facility construction
(FiUPatrick el al., 1977)
Plan development based on drainage patterns, topography and soils of site.
Avoid removal of trees and surface vegetation wherever feasible.
Minimize exposed land area and duration of exposure.
Divert runoff around exposed areas to stabilize outlets.
Provide temporary cover on areas of critical erosion hazards, and establish permanent cover as
soon as possible.
Construct impoundments to trap sediment and reduce runoff peaks before flow leaves the
construction areas.
Fording streams should be carried out by bridging, sheeting, using conveying equipment, or '
constructing a stabilized roadbed into and through the stream.
Control soil by revegelalion and mulching bare slope* (netting over mulch may increase
effectiveness of mulching). Examples of revegetation enhancement methods include:
(a) Grading of spoil area*; if revegelalion must be delayed, cover area with tarpaulin.
burlap or mulch.
(b) Dikes and ditches to control runoff.
(c) Development of adequate fertility of denuded soil (treated wastewater is good Tor
vegetation growth).
(d) Shallow tillage of area immediately prior to seeding.
(e) Seed mixture containing fast and slow growing species.
(0 Mulching area which has been seeded or planted.
(g) Supplemental controlled irrigation until growth established.
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40
BMoftctl hunci •Irititi
L W. Carter tt*L
41
is the SMCRA of 1977. Section SOI(b) of SMCRA requires that a permanent regulatory
program be implemented, and the regulatory program which has been developed
contains requirements which must be undertaken as a part of mining activities. These
requirements may be considered as mitigation measures in that they avoid, reduce or
TABLE 4. Summary of biological mitigation measures suggested by the regulatory program as
mandated by Section 50l(b) in SMCRA (U.S. Department of Interior, 1979)
Biological impact
Possible mitigation measures/requirements of regulatory
program
Loss of wildlife
and wildlife habitat
Disturbance of aquatic
organisms and aquatic
habitats
Erosion and sedimentation
Destruction of •
vegetation
A wildlife protection plan is required as part of mining permit
application
Wildlife agencies will be consulted
Timing, shaping and sizing operations will be conducted to
avoid breeding or nesting season and trees, protecting key food,
cover and water resources
Fencing will keep large mammals from direct contact with toxic
chemicals in sedimentation ponds and from roadways to reduce
number of roadkills
Revegetation will use species with high nutritional or cover
value
Topsoil handling and replacement prior to revegetation will be
conducive lo wildlife
Topsoil storage will be covered with vegetation, thus providing
cover for wildlife
A 30m buffer zone on each side of streams will be undisturbed
Implementation of a regulatory program designed for re-
storation, protection, enhancement and maintenance of aquatic
life
Casing and sealing of surface and underground mine openings
to prevent escape of acid and toxic discharge
Buffer strips be left between mining operations and waterways
Restoration of all streams to include alternating patterns of
riffles, pools and drops
All diversions will be removed
Surface runoff will be collected in sediment ponds
Disturbed soils will be revegetated
Affected land must be restored lo pre-mining productive capa-
city
Topsoil must be removed, segregated, stored and redistributed
with minimum loss or contamination
Topsoil and subsoil may be removed separately and replaced in
sequence
Establish native vegetation or appropriate substitutes after
mining
Agricultural lands must he reformed la the same or greater
productive capacity as pr»-mmH«f cmtdftiom
TABLE S. Summary of biological impact mitigation measures for five surface mining operations
Surface mining operation!
I 2 3 4 $
Impact
Mitigation measure
Destruction of vegetation
Disturbance of wildlife
Erosion and
sedimentation; and
destruction of
streams and
aquatic organisms
Revegetation programme
Limiting areas lo be cleared
Management of reclaimed
lands
Enhancement of habitat
Creation of ponds
Management program
Transportation to work site-
reduce road kills
30 m buffer zone
on each side of stream
Use of sedimentation ponds
Temporary crops prior lo
revegelalion
Scheduling operations during
dry periods or around spawn-
ing seasons
Stream reconstruction
Slope contouring
+ ) +
+ +
+ +
+ +
+ +
+
+ +
+ +
+
+
+
+
+
t The surface mining operations are in: (I) Rusk County. Texas (U.S. Environmental Protection Agency.
I983o); (2) Deioto Parish, Louisiana (U.S. Environmental Protection Agency. I983r). (3) Mercer County.
North Dakota (U.S. Department of Energy, 1980); (4) Campell County. Wyoming (U.S. Department of the
Interior, 1980); and (S) Robertson County, Texas (U.S. Environmental Protection Agency. I982r).
} Plus sign denotes mitigation measure mentioned in the EIS for the operation.
compensate for adverse impacts. A summary of some mitigation measures which relate
to biological systems or biological impacts is presented in Table 4 (U.S. Department of
the Interior, 1979).
In order to determine which impacts are actually being identified, and what
mitigation measures are being suggested to offset these impacts in actual practice, five
EISs which include mining activities were reviewed. Table 5 contains a summary of the
identified impacts and general mitigation measures for implementation. The most
commonly used mitigation measures were the development of? a revegetation program
and enhancing the habitat for wildlife. All five of the EISs examined implemented some
measures which fit these categories, though the specifics varied in accordance with the
needs created by the mining activities.
3.3. UTILIZED MITIGATION MEASURES FOR HIGHWAY PROJECTS
Many sensitive areas are traversed by highways. These include: wetla
deserts; and areas that are habitats for endangered species. Mitigation
(pine areas;
rbcedures for
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«p|,,| aWVMiTO
these sensitive areas may include replacement of habitat size for size, selection of
alternate route(s), or complete abandonment of the project (U.S. Department of
Transporation, 1975). In order to investigate mitigation measures being addressed in
highway projects, five EISs and three project reports were reviewed. Table 6 provides a
comparison of the types of impacts versus the mitigation procedure used for the eight
projects. Certain impacts are associated with nearly all highway construction activities,
including loss of vegetation, erosion and sedimentation, loss of habitat and loss of
wildlife.
Proper revegetation and reforestation is essential to alleviate vegetation loss and also
the erosion and sedimentation related to vegetation loss. Erosion control devices vary
from project-to-project depending on variables such as topography, soil type and
rainfall. In most cases, revegetation is best accomplished using native species. Fertilizers
may be useful but care should be taken so that excessive amounts are not used; excessive
use can cause .reduced water quality and stream eutrophication. In some wetland
situations, important considerations may involve dredging or filling operations and the
possibility of dredging toxic substances. Testing prior to moving the dredged material is
a very important aspect which is required by current legislation and regulations. If a
dredged material is found to be toxic, it should be placed upland in a secure landfill.
3.4. SPECIFIC LITERATURE-BASED INFORMATION
Usage of computer-based bibliographic retrieval systems can be an effective approach
for identifying potential mitigation measures for biological impacts. These systems
provide a fast, efficient means of conducting literature searches that produce lists of titles
and abstracts of published materials relative to specifically identified topics. There are
several commercial companies that provide access to traditional systems such as the
National Technical Information Service, Air Pollution Technical Information Center,
Water Resources Abstracts, Biosis Previews, Compendex, Pollution Abstracts, Agri-
cola, Smithsonian Scientific Information Exchange and Enviroline.
One example of the usage of a computer-based literature search will be cited. Water
resources projects involving the construction of dams and creation of surface water
reservoirs may cause certain environmental health impacts via vector-borne diseases.
Several mitigation measures are available for controlling vector-borne diseases, and
Table 7 provides a summary identified via a literature search (PEEM Secretariat, 1983).
Mitigation measures can be considered in terms of environmental modification or
manipulation, or modification or manipulation of human habitation or behavior. These
measures were identified as a part of developed guidelines for addressing the biological
impacts of water resources projects (PEEM Secretariat, 1983).
Some specific data bases have direct applicability for identifying mitigation
measures. For example, the U.S. Fish and Wildlife Service has developed an Endangered
Species Information System (ESIS) for storage and retrieval of information on nation-
ally listed threatened or endangered plants or animals (U.S. Fish and Wildlife Services,
1988). Records for 435 species were available as of mid-1988, and additional records are
still being added. Mitigation-related information in ESIS include reasons for the species'
present status, actions recommended for the species' recovery and habitat requirements.
Usage of ESIS, and the 66 data items of information for each species, record, would
enable the systematic identification of potential mitigation measures for threatened or
endangered plant or animal species in a project study area.
TABLE 6. Comparison of mitigation measures used in eight highway conslniclion^rojecls
•
«
Impact
1 AM A?
vegetation
Losi of habitat
and nesting areas
Loss of wetlands
Effects on
endangered
species
Erosion and
sedimentation
Possible
introduction of
toxic substances
of fill materials
into surface
waters
Highway construction projectf
Mitigation measure 12345678
• _l_ J. 0. J. J.
programme
Replacement of affected
areas +
Creation of aquatic
habitats + + + + +
Plant green-tree
reservoir + + + +
Replacement of affected
areas + +
Excavations designed to
produce wetland
habitats (proper water
depths) + - + +
Planning so route will
not affect nesting or
Replacement of nesting + ' +
areas and other sensitive
areas
Revegetation and
reforestation including
sodding, sprigging and
Construction of silting
basins and traps + + + +
Rip-rap on bridges and
approach slopes + + +
Limit amount of soil
disturbed at any one
lime • + +
Test all fill material
placed into surface
waters for toxic
substances -I- +
Place toxk material
upland or in secure
landfill +
t The highway construction projects are in: (I) five separate locations (Schuldincr el al.. 1979); (2) Monterey
County, California and Interstate 10 in Florida (U.S. Department of Transportation. 1975); (3) Tennessee
Slate Route 29. North Dakota 1-94, New Meiico 1-40. Georgia 1-95. Colorado I-10. West Virginia 48. Oregon.
numerous projects. (Desjardins, 1979); (4) Oklahoma Cily. Oklahoma. SH-74 (U.S. Department of Transpor-
tation, 1985); (5) Woodward County. Oklahoma, SH-15 (U.S. Department of Transportation. I988a): (6)
Virginia-Maryland, District of Columbia. George Washington Memorial Parkway (U.S. National Park
Service. 1985); (7) Mays County Oklahoma. SH-J3 (U.S. Department ofTraniportalion. 19886); and (8) Tulsa
and Osaie Counties. Oklahoma. Osaie Route (I) S rVnartment of Transportation. 1980)
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3.5. COMPUTER-BASED CHECKLIST
The final example for identifying potential mitigation measures involves the use of a
computerized system called the Environmental Impact Computer System (EICS). The
U.S. Army Construction Engineering Research Laboratory in Champaign. Illinois.
U.S.A., operates EICS (U.S. Army Construction Engineering Research Laboratory.
1981). The EICS includes eight areas of project activities called functional areas, and the
"environment" includes 13 categories called technical specialties. The specialties are
further disaggregated into basic attributes or indicators. The project activities are then
compared to the attributes in each technical specialty, and the system indicates the
probability of impact occurrence, rather than the potential magnitude of the impact.
, Keyed to the activity are ramification and mitigation statements. Ramification remarks
explain why the activities were scored as they were. The mitigation statements describe
ways to lessen or avoid the impact of that activity (U.S. Army Construction Engineering
Research Laboratory, 1981).
An early activity in any environmental impact study could include the use of EICS
for a preliminary identification of potential impacts, and the assemblage of pertinent
generic information on the ramifications and mitigation measures for those potential
impacts. The functional areas include: construction; mission change; operation, main-
tenance, and repair; training; industrial; procurement; research development, testing,
and evaluation; and real estate. The 13 technical specialties include ecology, health and
safety, air quality, surface water, ground water, sociology, energy and resources.
economics, earth science, land use, noise, transportation, and aesthetics. To serve as an
example of the types of mitigation measures which can be identified with EICS, Table 8
summarizes a portion of the key ramifications and mitigations for the impacts from
construction on ecology. This information can be used to develop preliminary plans for
impact mitigation programs. '*•
4. Evaluation of mitigation measures
An issue which is often not addressed in an environmental impact study is the evaluation
of the potential or actual effectiveness of planned or previously implemented mitigation
measures. Systematic evaluations of proposed measures are becoming increasingly
important due to the costs of such measures, cost-sharing requirements for water
resources development projects and the growing usage of the concept of incremental
justification of mitigation measures in an overall mitigation program. This section will
highlight three examples of evaluation approaches: (I) post-project monitoring; (2) pre-
project qualitative evaluation; and (3) pre-project quantitative evaluation.
4.1. FOST-EIS MONITORING
The CEQ regulations do not specifically address the evaluation of mitigation measures
except in the context of follow-up monitoring to ensure that planned measures are
implemented and working (Council on Environmental Quality, 1978). Specifically,
paragraph 1505.3 in the regulations states (Council on Environmental Quality, 1978):
"Agencies may provide for monitoring to assure that their decisions are carried out and should
do so in important cases. Mitigation and other conditions established in the EIS or during it*
review and committed to as part of the decision shall be implemented by Ihc^flagcnty or
other appropriate consenting agency. The lead agency shall: (a) include appron^^A>ndilions
in grants, permits or other approvals; (b) condition funding of actions on miliglHrcfc) upon
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E 8. Sun
L.W. Crater «*«t
47
TABLE 8. Summary of • portionf of the ecology impact ramifications from construction and
mitigation measures as obtained from the environmental impact computer system (U.S. Army
Construction Engineering Research Laboratory, 1981)
EICS code
number Selected ramifications and mitigations
1060 Ramifications
Establishment of the support facilities for a major construction project often
disturbs vegetation and wildlife for a wide area around the site itself,
especially if not regulated.
Mitigations
Limit spread of support facilities by contract provisions and/or temporary
fencing, especially if adjacent areas contain trees or other vegetation which is
to be retained.
1061 Ramifications
• Construction of temporary access roads may represent the first major
intrusion into a remote building site. Numerous superfluous roads may cause
more terrain damage than the project itself.
Mitigations
Plan access roads carefully; improve them if necessary; then restrict develop-
ment of all other roads and paths.
1064 Ramifications
Vehicle fueling and servicing areas, especially temporary ones, may lack
precautions against disposal of petroleum wastes on the soil surface or in
drainage ways where it then damages aquatic life.
Mitigations
Require that fuel and oil storage be diked and that drain oil be removed
from the site in closed containers and disposed of properly, preferably by sale
to reclaimers.
t This it in example only; • number of additional EICS code numben have been omitted.
request, inform cooperating or commenting agencies on progress in carrying out mitigation
measures which they have proposed and which were adopted by the agency making the
decision; and (d) upon request, make available to the public the results of relevant
monitoring."
Planning and implementation of a post-EIS environmental monitoring program for
a project typically involves a number of activities. Detailed information on these
activities is beyond the scope of this paper; such information is available elsewhere
(Canter and Fairchild, 1986). While details will not be provided herein, the use of such
monitoring data to evaluate the effectiveness of mitigation measures is obvious.
4.2. PRE-PROJECT QUALITATIVE EVALUATION
Systematic evaluation of potential mitigation measures for biological impacts should be
accomplished as a part of the EIS process. This evaluation should enable-the selection
and implementation of the most cost-effective mitigation program. This pre-project
evaluation is not a substitute for post-EIS monitoring; both are needed in a positive
program for successfully mitigating adverse environmental impacts.
Pre-project evaluation approaches can be considered in two categories—qualitative
and quantitative. A qualitative approach is represented by the evaluation of measures
used for similar types of projects. In this context, the earlier section on identification
could be considered as an approach to validate qualitatively the effectiveness of
identified measures. However, the explicit assumption is that the implemented
measures) will be successful, and this is not necessarily so. For example, Race (1987)
summarized a number of studies of the effectiveness of man-created wetlands used as
mitigation measures in the San Francisco Bay area. It was concluded that reports of the
success of these man-made wetland projects have been over-staled. Therefore, the key
consideration in a pre-project qualitative evaluation should be related to the demon-
strated effectiveness of the measures. Case studies which incorporate post-EIS monitor-
ing to verify mitigation program effectiveness would be extremely useful; however, at
this time the number of such studies is minimal.
4.3. PUB-PROJECT QUANnTATTVB EVALUATION
Several structured habitat-based methodologies have been developed for evaluating
both biological impacts and the potential effectiveness of proposed mitigation measures.
Three examples include: (I) the habitat evaluation system (HES); (2) the habitat
evaluation procedure (HEP); and (3) the wetland evaluation technique (WET). The first
two examples can be used for determining mitigation land requirements for projects
impacting fish and wildlife resources (U.S. Army Corps of Engineers, 1980; and U.S.
Fish and Wildlife Service, 1980). The latter example can be used systematically to
evaluate mitigation measures for projects exhibiting wetland impacts through considera-
tion of wetland functions and values (Adamus ef a/., 1987). It is beyond the scope of this
paper to review thoroughly all three examples; however, the HEP will be briefly
described to illustrate its usefulness in a pre-project evaluation of proposed biological
impact mitigation measures.
The HEP is a method which can be used to document the quality and quantity of
available habitat for both aquatic and terrestrial animal species (U.S. Fish and Wildlife
Service, 1980). The HEP is based on the assumption that habitat for selected species can
be described by a habitat suitability index (HSI). This index value (from 00 to I 0) which
is indicative of quality is multiplied by the area of available habitat (quantity) to obtain
habitat units (HUs). The first step of a HEP application consists of: (I) defining the
study area; (2) delineating cover types; and (3) selecting three to five evaluation species.
Information on species selection is contained elsewhere (U.S. Fish and Wildlife Service,
1980).
A HEP analysis is structured around the calculation of HUs for each evaluation
species in the study area. The total area of available habitat for an evaluation species
includes all areas that can be expected to provide some support to the species. The total
area of available habitat is calculated by summing the areas of all cover types likely to be
used by the species. The HSI values are described via HSI models. The HSI models are
usually presented in graphic, descriptive and mathematical formats (Schamberger el al.,
1982). HSI models have been published for about ISO evaluation species, and more are
being developed.
Impact in the HEP is defined as the difference between HUs with the project and
HUs without the project. Averaged annual HUs are used in the impact calculations. The
final step in the HEP involves the development of mitigation plans, if appropriate.
Studies can be used to identify measures that would offset unavoidable HU losses due to
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48
Biological taaart •MftllM I
measures to existing habitat to effect a net increase in HUs. The existing habitat may or
may not be located in the "impact" study area. In order to obtain mitigation, the HU
losses due to the proposed action must be fully offset by the specified acquisition and/or
management measures. The three possible mitigation goals are (U.S. Fish and Wildlife
Service, 1980):
I. In-kind (no trade-off)—This goal is to offset precisely the HU loss for each
evaluation species. Therefore, the list of target species must be identical to the list
of negatively impacted species. The ideal compensation plan will provide, for each
individual species, an increase in HU's equal in magnitude to the HU losses.
2. Equal replacement (equal trade-off)—This goal is lo offset precisely the HU
losses through a gain of an equal number of HUs. With this goal, a gain of one
HU for any target species can be used to offset the loss of one HU for any
evaluation species. The list of target species may or may not be identical to the list
of impacted species.
3. Relative replacement (relative trade-off)—With this goal, a gain of one HU for
any target species is used to offset the loss of one HU for an evaluation species at a
differential rate depending on the species involved. The trade-off rates can be
defined by relative value index (RVI) values for each species.
After the goals are set, the mitigation analysis is the same as that used to identify
project impacts. The steps in the process are to:
I. Select a candidate mitigation study area. The area can be of any size but must be
. at least large enough to be a manageable unit for the target species. Develop a
cover type map and determine the area of each cover type.
2. Conduct a baseline habitat assessment for each target species. Baseline data for
individual species in the "impact" area may be used if the candidate compensation
area is similar in terms of HSI values. If this is not the case, additional field work
lo determine HSIs will be necessary in the study area.
3. Determine the average annual HUs for the study area assuming no future
proposed action.
4. Identify a proposed management action that will achieve specified goals. Specify
the management measures (e.g. prescribed burning, selective timber cutting and
others) that will be used to increase the HUs for the target species in the candidate
area.
5. For the mitigation area, contrast the HUs without management to the HUs with
proposed management measures and determine the net increase in HUs.
One brief example of a HEP analysis will be mentioned, with this analysis focused on
evaluating thermal mitigation alternatives for two nuclear reactors. Specifically, Mackey
el al. (1987) evaluated the potential effects on wildlife of the implementation of thermal
mitigation alternatives for the C and K reactors at the Savannah River Plant in South
Carolina, U.S.A. The HEP approach as modified by the Savannah River Laboratory
was used. This approach enabled the relative ranking of project alternatives and/or
mitigation strategies wilh respect to representative wildlife species over the life of the
project or for selected time periods in the future. For the Cand K reactors the potential
wildlife impacts and/or benefits of once-through and recirculating cooling towers were
evaluated for both near-term (30 year) and long-term (100 year) time periods.
Based upon this brief review of the HEP, it can be stated that this method can be used
to evaluate the costs and potential effectiveness of differing mitigation strategies for
: structured nature of the HEP is conducive to its use as an evaluation I
I impact mitigation measures.
tdmtiftratio* t*d rv*huuo» of mitigation measures for adverse biological impacts of
proposed project* IMS become an important component in the EIS process. The focal
point for opposition and debate relative lo a proposed project often centers on the type
and extent of appropriate mitigation measures. This paper has delineated, several
approaches for both identifying and evaluating potential mitigation measures. Examples
of identification approaches include the review of utilized measures for similar projects.
the use of computer-based literature and information searches, and the use of computer-
generated checklists of potential measures. Examples of evaluation approaches include:
post-EIS environmental monitoring; pre-projecl qualitative evaluation based on cnsc
studies; and pre-project quantitative evaluation using structured habitat-based methods.
Based upon this review, the following conclusions can be drawn:
I. There are an ample number of approaches which can bttused to identify potential
mitigation measures for the adverse biological impacts of proposed projects.
2. While systematic methodologies are available for evaluating the potential effec-
tiveness of mitigation measures, these methodologies have not been extensively
used as a part of the EIS process. Perhaps one reason for limited usage is the
uncertainty associated with measures such as habitat development and enhance-
ment.
3. Post-EIS environmental monitoring can be a definite aid to impact management
and determination of the actual effectiveness of implemented mitigation
measures.
4. Many have the perception that mitigation is simply an unnecessary add-on cost
for a project. However, while the implementation of a mitigation program may be
costly, it may be much more cost-effective lo have a mitigation program from the
beginning of a project rather than having lo initiate an even mojc cosily
environmental clean-up program al some future point in time.
References
Adamus, P. R.. CUirmln, E. 1., Smith. R. D. and Young. R. E. (1987). Wetland Evaluation Technique (H'ETI
Volume II—Methodology. Vicktbur|. Mississippi: U.S. Army Engineer Waterways Experiment Station.
Canter. L. W. and Fairchild, D. M. (1986). Post-EIS environmental monitoring. In Methods and Experience* in
Impact Aueiment (H. Becker and A. Porter, eds). pp. 265-285. The Hague, The Netherlands: Reidcl
Publishing Company.
Council on Environmental Quality (1978). National Environmental Policy Act—Regulations. Federal Regitter
43 (230). 29 November, 55978-56007.
Desjardins, C. R. (1979). Ecological Mitigation: A viable option in the federal-aid highway program. In Thi-
Mitigation Symposium-A National Workshop on Mitigating Losses offish and Wildlife Habitats, pp. 562
565. Washington. D.C.: U.S. Forest Service.
FiUPatrick. M., Willson, I.. Ericson. D.. Fai. O and Wood. D. (1977). Manual for Evaluating SetonJan
Impacts of Wastewater Treatment Facilities, pp. I ll-l 12. EPA-600/S-78-OOJ. Washington O.C.: Environ-
mental Protection Agency.
Mackey. H. E. el al. (1987). Habitat Evaluation fioceJun (HEP) Assessment for Thermal Mitiguiii'ii
Alternatives for C and K Reactor*. DPST-87- 578. Aiken. South Carolina: DuPonl de Nemours (E.l.) ami
Co.
Monterey Peninsula Water Pollution Control Agency. U.S. Environmental Protection Agency and Junes ami
Stokes Associates Inc. (1977). Final Environmental Impact Statement and Enviroranerual Impact Rrrxiri
North Monterey Facilities Plan. pp. XVIII-XXI and 188-198. Monterey. California.
PEEM Secretariat (1983). Panel of Experts on Environmental Management for Vector Control (PEF.AII.
Report of the Third Meeting. Rome 12-16 September 193}. VBC/8J-4. Geneva. Switzerland: World I Icallli
Organization. ^^^
Race, M. S. (1987). "San Francisco Bay experience". In Proceedings of the Conference on J^^W" HVrAimA
What Are They? For Whom? For What?, pp. 201-209. Seattle. Washington: InslituU^^Hvironmcnlal
Studies, University of Washington. ^^^
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4.H-12
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4.6
Documentation
The outcome of the EA process is usually a formal document that provides
the decisionmaker with environmental information and conclusions about the
consequences of a preferred action and reasonable alternatives. In the U.S., there
are two types of documents, the environmental assessment (EA) with its
associated finding of no significant impact (FNSI) and the environmental impact
statement (EIS) with its associated record of decision (ROD). An EA may also
be used to determine whether to prepare an EIS. These documents are the
primary sources of information for interested and affected individuals and
organizations. As such, they must present clearly and objectively the alternatives
to be considered in the decisionmaking process (Weiss 1989; Attachment 4.1).
Often, formal documentation is not necessary for actions that an agency
has predetermined not to have individual or cumulative significant effects on the
human environment (i.e., categorical exclusions; Chapter 2). However, in some
cases, agency requirements call for some formal documentation. In die U.S.,
formal environmental impact assessment documents and, if appropriate, associated
determinations are required if the proposed action is 1) one that the agency has
pre-determined to require an EIS or 2) it is not known if the potential impacts are
significant. When it is known that the potential impacts of a proposed action are
significant (Chapters 2.1 and 4.4), an in-depth EIS and the associated
determination are required. Table 4.6-1 provides an annotated list of the major
elements of an EIS. When as a result of an EA, the potential impacts of a
proposed action are determined to be "not significant", a FNSI is issued.
Environmental assessment documentation has a variety of names
throughout the world. However, there is a general consensus, with minor
variations, on the content of such documents. Recent review of European EA
documents showed that for the most part, alternatives to a proposed action were
not evaluated, nor were monitoring or follow-up needs discussed. Other aspects
frequently not covered were technical and regulatory uncertainties, cumulative
impacts, and external policy constraints. Other countries frequently incorporate
EA into regional planning documents with the result that the environmental
impacts and conclusions related to a project (and alternatives, if any) are neither
summarized nor easily accessible.
4-79
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• A coordinated team approach to the generation, evaluation, and
presentation of information. Integrating the various sections of an
EIA document is the responsibility of the team leader; however,
the findings and specific data and their interpretation should be
discussed by the team as a whole prior to drafting the document.
Such an effort ensures that everyone has a common understanding
of the problem, the existing data, and the data gaps. Moreover,
it helps to focus the document on the important issues.
• Use of clear language (Attachment 4.1) that can be understood by
lay persons reading the document. Where effects are understood,
they should be stated clearly and objectively; where sophisticated
analyses are performed, the summaries of the analyses should
explain the findings in ordinary phrases. Avoid the use of vague
generalities, cliches, or professional jargon.
• Objective presentation of relevant information in terms and formats
that are meaningful and useful to interested and affected publics,
agencies, and decisionmakers. A glossary of acronyms should be
included. All sources of information should be thoroughly
documented. Methods for collecting and processing original data
should be described and included as appendices.
TOOLS
• A standard organization and format (i.e., the sequence in which
information is presented should be the same in all kinds of EA
documents so mat reviewers and the interested public can easily
find relevant information).
• Use of visual displays for descriptions of existing and future
conditions, data sets, impact analyses, alternatives comparison, and
mitigation measures (Tufte 1983,1990). Maps and/or photographs
should be used to familiarize readers with the affected area.
Graphs, bar charts, pie diagrams, summary matrices, and similar
information summaries should be used where possible. The visual
displays can be briefly explained and discussed in accompanying
text. In areas where language barriers or literacy may be a
problem, video presentations are an effective way of reaching the
affected public.
4-80
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Table 4.6-1. Format and content of an EIS as required by CEQ regulations
Format
Content
00
Cover Page
Summary
Table of Content*
Purpose of and need for
action
Alternatives including
proposed action
Affected environment
Environmental
consequences
List of prepaiers
List of agencies,
organizations, and
persons to whom copies
of the report are sent
Index
Appendices
A single page listing the responsible agency and cooperating agencies; the title of the proposed action and it* location; the name, address, and telephone number
of a contact person; a designation of the EIS as draft or final; a one-paragraph abstract; and the date by which comments must be received.
A nontechnical summary °t the proposed action, preferably less than 15 pages in length, that accurately and adequately describe* the content of the EIS. The
summary should stress the final conclusions, areas of controversy, and the issues to be resolved.
A list and page number index of the chapters, sections, and subsections in the EIS, including a list of table* and* list of figure*.
A brief statement of the purpose and need to which the agency is responding in proposing the alternatives, including me proposed action.
A presentation of the environmental impacts of the preferred action and all reasonable alternatives in comparative form, exploring each alternative, including
the no-action alternative, and the reason(s) why certain alternatives were recommended or eliminated. Include appropriate mitigation measure*.
A succinct description of the environment of the areas to be affected by the alternatives under consideration. Data and analyses for any given subject area should
be commensurate with the importance of the impact in that subject area, with less important material summarized or referenced.
A discussion of the environmental impact* of the various alternatives being considered, identifying any advene environmental effect* mat cannot be avoided if
the action is implemented; all mitigation measures to be employed to reduce the adverse effects; residua] effects of mitigation; the relationship between short-term
uses of the environmental and the enhancement of long-term productivity; and any irretrievable or irreversible commitments of resources that would occur if
the action were implemented as proposed.
A list of names and summaries of .the professional qualifications for persona who were primarily responsible for the preparation of the EIS or significant
background materials.
A list detailing the agencies, organizations, and persons that have been sent copies of the EIS, including the addresses of public repositories (libraries, government
offices) where the report is available for review by the public.
A listing of the major components of the EIS by topic or issue, together with page number references.
Materials prepared in connection with an EIS that substantiate analyses, that relate to the decision to be made, and that should be circulated with the EIS. Material
incorporated by reference ia generally not included in these appendices.
A listing of written comments submitted by governmental agencies, public and private organizations, and interested individua!;, ^ ' —'mutted in public
hearings on the project. Substantive comments and responses should be attached to the final EIS. The author of the comiuc.ku. o4 by name and.
address. Comments may be paraphrased, and repetitive comments or questions may be listed once and cross-referenced. If the response reference* material
already contained in the EIS, the pertinent page number should be cited.
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Professional technical editing of the draft document for consistency
in style and content. Environmental impact assessment documents
are generally drafted by interdisciplinary teams and differences in
sources of information and writing style often result in
contradictory statements or information in various sections of the
document.
In the U.S., federal agencies are responsible for the scope,
content, and accuracy of EA documents. Thus, technical review
of draft documents by agency staff and independent experts prior
to publication is common practice. By virtue of Section 309 of the
Clean Air Act, the U.S. EPA has been placed in a special review
role. This section of the Clean Air Act requires that the U.S.
EPA comment in writing on the environmental impact of newly
authorized federal actions or legislation and also upon the
adequacy of draft EISs. Attachment 4.J outlines the EPA rating
system. In addition, draft EISs are subject to public review for a
period of 45 days.
ISSUES
Generally, effective communication depends on identifying the
audience(s) and shaping and styling a publication to meet their
specific needs. However, an EIA document must serve multiple
functions, being simultaneously a decisionmaking document, a
technically rigorous scientific analysis of potential environmental
impacts, a record of the EA process and participants, and a source
of information for the public. Preparing a report that serves these
different uses and audiences requires careful consideration of the
ways in which information is presented.
Legitimate differences of scientific opinion should not be omitted,
but should be included in an EIA document to provide the public
and the decisionmaker with an unbiased analysis and presentation
of the alternative ways of meeting a declared purpose and need.
Approaches to identifying and assessing the impacts of a proposed
action and its alternatives are not always available or universally
accepted. This contributes to the fact that in the U.S., the
adequacy of EA documents is the second most frequent legal
challenge under NEPA (CEQ 1993).
4-82
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LINKAGES
An EIA document is a record of the EA process and the judgments made
by the team. The objective is to communicate information to the decisionmaker
and other interested publics and agencies. It reflects the results of early input
from initiation and scoping and it describes what is expected after the decision is
made (i.e., mitigation and monitoring'). Coherent, integrated assessment of
reasonable alternatives including the no-action alternative is the linchpin of the
EA process. The essential findings of the assessment process must be presented
in a concise document.
Council on Environmental Quality (CEQ). 1993. Environmental Quality. 23rd
Annual Report. U.S. Government Printing Office. Superintendent of
Documents, Mail Stop: SSOP, Washington, DC 20402-9328. ISBN 0-16-
041612-4.
Tufte, E. R. 1990. Envisioning Information. Graphics Press, Box 430-Y,
Cheshire, Connecticut 06410. 128 pp.
Tufte, E. R. 1983. The Visual Display of Quantitative Information. Graphics
Press, Box 430-Y, Cheshire, Connecticut 06410. 197 pp.
Weiss, E. H. 1989. An unreadable EIS is an environmental hazard. The
Environmental Professional 11:236-240.
4-83
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4-84
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ATTACHMENT 4.1
AN UNREADABLE EIS IS AN ENVIRONMENTAL HAZARD
• Weiss, E. H. 1989. An unreadable EIS is an environmental hazard. The Environmental
Professional 11:236-240.
4.1-1
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4.1-2
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PHUFESSIONAL REPORT
An Unreadable EIS is an Environmental Hazard
Edmond H.Weiss
Cherry Hill, New Jersey
Abstract An Environmental Impact Statement alerts the government and public to the possible hazards of proposed actions.
An unreadable EIS is an environmental hazard, potentially as deadly as stack emissions or dioxin in the groundwater.
Many EISs, of course, are written by engineers and re-
searchers, without benefit of professional "wordsmiths."
The engineer's notorious aversion to writing (and the un-
willingness of most firms to buy writing services) means
that EISs are at least as unreadable as most other technical
documents prepared by a team of middling writers working
to an unforgiving deadline.
But, despite what some consultants may think, the bad
writing in an EIS is much more serious than a matter of
esthetics; the issue is not "English" or refinements of style.
The issue is the quality of the document, its usefulness in
support of the goals of environmental legislation, and, by
implication, the quality of the environmental
stewardship entrusted to the scientific community.
PART OF THE PROBLEM
OR PART OF THE SOLUTION
An unreadable EIS not only hurts the environmental
protection laws and, thus, the environment. It also turns the
sincere environmental engineer into a kind of "polluter."
Consider the irony. Environmental engineers, those
solitary champions of environmental quality, usually more
than ready to do battle with well-financed developers and
Edmond H. Weiss, Ph.D. is an independent consultant, writer,
and lecturer, specializing in technical communication. He spends
most of his time traveling throughout North America teaching
writing seminars for engineers, scientists, and computer profes-
sionals. He is the author of The Writing System for Engineers and
Scientists (Prentice-Hall, 1982), How To Write a Usable User
Manual (\S\ Press, 1985), and How To Document a System (Oryx
Press. 1990). His base is Cherry Hill, New Jersey.
Requests for reprints may be addressed to Edmond H. Weiss,
Ph.D., 1612 Crown Point Lane, Cherry Hill, New Jersey 08003
(609/795-5580).
well-connected waste handlers, are increasingly perceived
as paid apologists for the people whose actions may foul
the environment. Why? Because most Environmental Im-
pact Statements are so difficult and unpleasant to read that
they make people suspicious. Even someone only
moderately skeptical might suspect that readers are dis-
couraged from reviewing the report too carefully. And, in
a time when bright people worry that environmental laws
can be manipulated and undermined by powerful interests,
the inaccessible and unreadable EIS has come to be viewed
as part of the problem instead of part of the solution.
Some EISs, then, are seen as a deliberate effort to obscure
the questions, to inhibit debate and intimidate all the op-
ponents of a proposed project or action.
Of course, this public perception is unfair. Although en-
vironmental consultants occasionally err in the favor of the
agencies who pay their fees, the typical individual or firm
is scrupulously honest in describing and predicting en-
vironmental consequences. Whether motivated by the
noble ethics of the profession or just by the mundane fear
of being discredited in the consulting marketplace, en-
vironmental specialists would be the last to defeat the spirit
of the environmental protection laws and codes. Quite the
contrary. The typical EIS is not obscure by intent. It only
seems that way —the consequence of certain bad habits of
thought and expression.
There are three broad classes of errors that undermine the
clarity and credibility of many EISs:
Strategic Errors are mistakes of planning,
failure to understand why the EIS is being written
and for whom.
Structural Errors are mistakes of organization,
failure to arrange the elements in the document in
a way that makes them easy to follow, and
THE ENVIRONMENTAL PROFESSIONAL Volume 11 pp. 236 - 240 0191-5398/88 0191-5398/89 $3.00 +.00
1989. Printed in the USA. All rights reserved. . Copyright © National Association of Environmental Professionals
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UNREADABLE EIS
237
Tactical Errors are mistakes of editing, failure
to test and revise the texts for clarity and
readability.
STRATEGIC ERRORS
A strategic error is tantamount to writing the wrong docu-
ment. That is, the engineers and others, for a variety of
reasons, produce an EIS that misses the true objective of
the project— even while it complies with federal or state
"guidelines." Especially when the EIS is composed by
several authors working independently, the risk is great
that the final product will meet the letter of the law but not
the spirit.
More specifically, EISs are often undermined by naive
attitudes, the most prevalent being that the document is a
dispassionate, objective collection of unambiguous, hard
facts about environmental effects. Typically, though an
EIS vitally affects hundreds or thousands of people—in-
cluding a few very rich and powerful ones. In a sense, the
principal function of the EIS is to provide facts, projec-
tions, and analyses that raise the level of debate among
those thousands at interest
In countless cases the EIS has affected the commercial
interests of developers and contractors, even the political
aspirations of local officials whose campaigns include
promises of projects with environmental implications. No
matter what the guidelines say, and no matter what dis-
claimers appear in the introduction, the findings in an EIS
may potentially help or hurt the progress of some project.
At the very least, it can uncover adverse effects that add
corrective costs to a proposed action. In extreme cases, it
can curtail the plans of the very agency or firm that paid
for the study.
Moreover, an EIS, like even the best science done in
support of public policy and health, contains a substantial
number of extrapolations and inferences, many built on
simplifying assumptions, debatable theses, and even
secondhand data from parties with vested interests. (Given
two or three questionable presumptions, environmental
assessment becomes only slightly more precise than stock
market forecasting.)
In short, an EIS is a work of science, as opposed to an
aggregation of hard facts; it is rich with, to use Popper's
term, intelligent conjecture. Consultants, often under
pressure from sponsors to produce unambiguous con-
clusions, must remember that the quality of their assess-
ments derives from the quality of the underlying warrants
(Stephen Toulmin's term) in their models.
The document should be much more than a compendium
of technical details, interesting mainly to readers with the
appropriate technical background. But, without meaning
to, most EIS authors aim their writing at the
audience. .They assume not only that the work will be
almost exclusively by environmental engineers and
specialists, but also that each specialized component (air,
water, archeology, odor...) will be read only by persons
with that specialty.
Even though many of the readers are such specialists, the
most important readers are not. Quite the contrary, the
main readers of the EIS are in three motivated groups:
A higher jurisdiction of government, respon-
sible for a series of decisions, often including
enforcement, frequently under political pressure
to approve or disapprove (in the guise of "neutral"
review for compliance)
Supporters of the proposed action, hoping that
the EIS will not forecast any unavoidable conse-
quences or more attractive alternatives, impatient
to have it approved as quickly as possible
Opponents of the action, alert to any instance in
which its adverse effects are minimized or in
which those of the alternatives are exaggerated,
especially skeptical of all assumptions, inferen-
ces, and secondhand or imputed data.
By failing to appreciate that the EIS is a work of scientific
conjecture, aimed at motivated and even cynical readers,
environmental engineers commit the worst strategic error
of all, the one that undermines not only EISs but many other
technical documents as well: lack of apparent function
or purpose. (That is, there is a tendency among among
intellectual writers—scientists, engineers, scholars—to act
as though the purpose of the document was to write about
the subject. An effective EIS, though, or any effective
technical publication, is designed and written to ac-
complish specific communication objectives in well-
defined audiences. Ironically, the more fascinated the
author is with the subject, the greater the risk that the
document will lack purpose and frustrate its readers.)
An EIS, in addition to presenting its facts and projections,
must assure those who deserve to be assured, arouse those
whose interests are at risk, satisfy the stewards of environ-
. mental laws, and stimulate enlightened discussion among
decisionmakers and their constituents.
The assessment of environmental impact is hardly ever
simple, objective, or uncontroversial. Rather, it is a prob-
lem in scientific advocacy, in which the main issue is
whether the investigating team has assembled enough
credible evidence and argument to prove a central thesis.
Either that:
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EDMOND H. WEISS
The proposed action will have no important ad-
verse effect on the environment, or
The proposed action is better for the environment
than "no action," or
The proposed action is clearly better for the en-
vironment than the alternatives, or
Although there is an environmentally superior
alternative, its greater costs are not justified by its
environmental benefits (or are justified)
For an EIS to have an effective thesis (one of those above,
or some other more appropriate to the situation), the Project
Director must assert responsibility and take intellectual
risks. Put simply, he or she must direct the project and see
that the EIS has a coherent point of view—that each of the
five or ten or twenty specialists at work on each of the
"parameters" knows the audience and the thesis. Without
such direction, the EIS will look as so many of them do: a
patchquilt
STRUCTURAL ERRORS
If form follows function (as some architects are fond of
saying), it is not surprising that many EISs are in a form
that reflects their lack of thesis and their indifference
toward the audience. Generally, they are huge and inacces-
sible. Like a patchquilt, they are filled with beginnings and
endings, choppy, inconsistent, ragtag.
Most EISs appear to be organized in a way that makes them
easier to review or "check off" than to study and question.
They are arranged so that even a superficial reviewer will
quickly see that everything that is supposed to be in the
document is there. And if that were the only mission of the
EIS, to satisfy some mindless bureaucratic checklist, such
an organization would be appropriate. Furthermore, if that
were the only function of the EIS, there would be no reason
to write this essay!
But that is not the sole mission or function. EISs are
important documents meant to be read by interested
readers with vital concerns. (Not just compendiums of fact
to be appraised with a checklist.) It is shamelessly cynical
for environmental consultants to regard the writing and
reviewing of the EIS as nothing more than "going through
the motions" of environmental assessment, a tiresome ad-
ministrative hassle, "red tape" en route to getting the
project approved.
For many readers, the typical EIS has an inaccessible
organization. Most readers do not want to study each
"environmental parameter" in depth. They do not want to
reflect on the history of the planet before they find out
whether the local groundwafer is likely to be fouled. Nor
do they want to read several hundred pages to leam if there
are any unavoidable consequences of the project
For the sake of most readers, the EIS should be organized
to allow direct and immediate comparison of the proposed
action with the "no action" alternative, followed by a
similar comparison with alternative sites, technologies,
and actions. Moreover, the comparisons should address
only what is relevant. If the effect on a certain parameter
is inconsequential, it should be reported briefly and dis-
missed (even though we paid a hefty fee to the subcontrac-
tor specialist). If differences between alternatives are too
small to matter, they need not be discussed—unless there
is reason to believe that part of the audience is especially
interested. Nowadays it is hard to escape the impression
that the controversial or "soft" parts of the study are being
deliberately camouflaged beneath hundreds of pages of
unimportant detail.
In a well-made EIS, the average reader—including the
lay reader—should be able to find what he or she wants
to know in less than five minutes. One minute, if the
findings are unusually straightforward.
An effective EIS should be well-endowed with "search
tools": introductions, summaries, overviews, reviews,
digests, or abstracts. It is even easy to imagine an EIS that
is mainly summaries, with much of the technical detail
relegated to attachments and appendixes. In contrast,
though, what do we usually see?
The introduction is malnourished; it reads like an
afterthought.
The table of contents is incomplete, and the head-
ings (the names of the sections) do not address the
questions raised by readers. In effect, one must be
an expert to find anything.
There are no chapter introductions or section in-
troductions; no marginal glosses.
There is hardly any typographic emphasis or ac-
cent: underscoring, boldfacing, italics, indenta-
tion, color, capitalization—none of the simple
techniques for making the most pointed and con-
clusive sentences stand out from the dense back-
ground of the page.
(I recently read a 500-page EIS that had not one
underscored sentence. When I proposed changes
in presentation and typography, I was told direct-
ly by the sponsor that he didn't want the EIS to
stimulate any more discussion than neces-
sary!)
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UNREADABLE OS
239
Because of the way they are written, most EISs are clumsy
and disjointed.
They are obviously the work of many authors, with jarring-
ly different styles of writing. Typically, each author
doesn't care much about what the others are up to; the
project director spends more time reassuring the sponsor
than ensuring that all the authors are working on a coherent
document.
Often, the several sections are at radically different levels
of detail or difficulty—some containing sophisticated
models, others high school primers on the measurement of
sound. The worst problem is the disjunction of text and
exhibits, the needless separation of text from the charts,
tables, photos, and figures. Readers are perpetually told to
"see Map X"—which is typically several pages away, or in
another volume.
My own research in technical communication has led me
to conclude that this simple mechanical problem—the
separation of the text from the exhibits needed to make it
clear—is the single greatest barrier to the reading of EISs
and other technical publications. In a well-designed EIS
(Note: EISs must be designed, not just assembled!), nearly
every time a reader is told to see a chart or table it will be
either on the same page or a facing page. The more we
ask readers to jump, skip, detour—the more often we ask
them to be in two places at once—the greater their
suspicion that the writers do not really want the material
read.
Of course, most of the people who write the separate parts
of an EIS do not even think about so pedestrian a question
as the position of the charts and maps. That, after all, is an
editor's problem—or, in some places, the typist's problem.
Generally, the only writers who care deeply about the
physical layout of the document are those who want it to
be easy to read.
TACTICAL ERRORS
Tactical errors are failures of editing. They include the
mechanical mistakes—misspellings, errors of grammar
and punctuation— as well as misused words and phrases.
More subtle, and more serious, are failures of style: clumsy
syntax or awkward, wordy sentences. When most en-
gineers think about "writing," it is these tactical issues that
come to mind. And when most engineers disparage their
writing, it is actually their editing that is at fault.
Tactical errors add "friction" to communication. Where
there should be a simple transfer of facts and ideas from
writer to reader, instead there are distractions, irritations,
rubs.
There are two broad kinds of tactical errors: obvious viola-
tions and subtle mistakes. The obvious ones are lesj
dangerous, because they are more likely to be detected ar^
corrected. Misspelling "supersede," using the word criteria
as a singular, using "due to" in place of "because of": these
are the bugs that should be caught by the writer, or even
such "style-checking" software as RightWriter or Gram-
matik.
The trouble with the subtler mistakes is that they are rarely
textbook errors. And, unless there is a real editor or an
especially literate Ph.D in the firm, no one is likely to
correct them. These are errors of style, like the "smothered
verb" ("perform the computation of" versus "compute";
"conduct an inspection of versus "inspect"). Or the
"vitiated predicate" ("The possibility of damage to the
crops from the steam exists" versus The steam might
damage the crops").
There are also scores of wordy, windy, wasteful construc-
tions, like "consensus of opinion" or "ten-year period of
time" or "visible to the eye." And ostentatious synonyms,
like "utilize" for "use" or "facilitate" for "aid." And
misused words, like "fortuitous" (which does not mean
lucky) and "enormity" (which does not mean immensity)
or "preventative" (which is not the same word as preven-
tive) or "remediate" (which is a solecism on the verge of
being a barbarism, no matter how many people use it).
Recently I edited an EIS in which I removed the wortN
"situated" more than 100 times. "X is situated in Y" be-
comes "X is in Y." "Q is situated west of P" becomes "Q
is west of P." In the same document I also changed
"presently" to "currently" at least fifty times.
Why are there so many young professionals who cannot
distinguish "historical" form "historic"? And why is there
no basic agreement on whether the word "impact" itself
refers to all effects or only to undesirable ones. (Does "no
impact" mean no effect, or no harm? If all "impacts" are
bad, why do we write "adverse impact"?) Would it improve
our EISs if we wrote them without any form of the word
"impact"? Answer Yes
And these are the easy mistakes, the ones even a green
editor would correct in a minute. What about the more
difficult problems, though? The unbearably long sentences
and paragraphs? The lack of links to connect one sentence
to the next? The jarring differences in style from section to
section? The oppressive lack of variety in sentence pat-
terns? These problems need a better editor, who, in turn,
needs the time and authority to correct them.
Most EISs have never been visited by a real editor. Of those
I've read, about one in five shows evidence of anything.
more than rudimentary editing. Partly, this is because mos|
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240
EDMOND H. WEISS
of the smaller consulting firms believe that they cannot
afford an editor, forgetting that their main product is
reports. But mainly it is because of deadlines. Almost
universally, project directors on environmental assess-
ments regard editing as an incidental frill, a step that can
always be sacrificed for the sake of delivering a draft two
or three days earlier.
The worship of deadlines is understandable and, in some
cases, forgivable. But it is also wrong.
If. for the sake of meeting a review deadline, the consult-
ants allow an unreadable draft to be distributed (and most
first drafts by engineers are unintelligible to anyone but the
•uthor and some friends), then the consultants are morally
compromised. If the purpose of the ETS is to support a frank
discussion of the consequences of the proposed action, then
an unreadable document is an impediment, an environmen-
tal hazard.
If some of the aggrieved readers of the EIS suspect decep-
tion, and if the inaccessibility of the text contributes to that
suspicion, then the consultants are part of the perceived
conspiracy.
SOLVING THE PROBLEM
For the three groups of errors there are three paths of attack.
Eliminating strategic errors calls for genuine project
leadership by a project director with intellectual vigor. The
various specialists on the assessment team, including sub-
contractors, must not begin to write "their sections" until
their respective findings and conclusions have been dis-
cussed and evaluated.
As impractical as it may sound, and as far from standard
practice in most firms, the individual contributors should
not be turned loose on their writing assignments until they
have presented written summaries of their data and
interpretations for discussion by the team as a whole.
Specialists must not be encouraged to formulate their judg-
ments while they are writing their first (and last) drafts. Put
bluntly: competent scientists and engineers ought to be
able to summarize what they are going to write before they
begin; too many of the people who work on EISs, though,
cannot tell you what they are going to say until they have
said it. More than a few engineers have told me that their
writing assignment was little more than "covering enough
pages."
Only afteY the overall sense of the findings has been
clarified, only after the conflicts and inconsistencies have
been resolved, should the project director permit the
separate pieces to be written.
In this context, only what i- relevant should be featured
prominently in the body of the EIS. Incidental information,
tutorials and primers on environmental science, and mis-
cellaneous exhibits should be relegated to appendixes.
(Note: I did not say that only what is "favorable" to the
thesis should be in the body of the document; I said what
is "relevant." Surely, unfavorable data are quite relevant)
Eliminating structural errors calls for more professional
document design. The documents should be packaged and
summarized in a way that lets most readers find what they
need to know at once. Most important, the central questions
of any EIS must be answered prominently: Are there
unavoidable consequences? Are there alternative sites or
technologies with less environmental hazard? Etc
The most useful way to help readers follow complicated
discussions is to unify the text with the associated tables,
maps, and charts. For more than thirty years, certain in-
dustries have been preparing "modular" publications, in
which the entire document is conceived of as a set of
two-page spreads, with text and exhibit on facing pages.
(Currently, the only efficient way to read an EIS is to have
two copies, with one open to the referenced chart or table.)
And finally, the only way to eliminate or control tactical
errors is with a professional editor. At the very least, such
a person is needed to clean up after the parade of technical
specialists has marched through. Every EIS, like every
final report, needs the attentions of someone who knows
how to reduce the burden on the reader, to contain the effort
and "overhead" needed to read and use the document.
To do that job, however, takes time. Schedules must allow
room for the editor to work. And project directors must be
less willing to deliver undercooked drafts to eager spon-
sors.
Quality Assurance specialists are fond of saying that the
bitterness of poor quality lingers long after the sweetness
of meeting a deadline. I might add that the bitterness of an
unreadable EIS can undermine the intellectual authority of
the environmental engineer. And even foul the air.
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4.1-8
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ATTACHMENT 4J
EPA RATING SYSTEM CRITERIA FOR DRAFT EISs
The U.S. Environmental Protection Agency rating system criteria for review of draft
environmental impact statements. (Source: U.S. Environmental Protection Agency.
1984. Policy and Procedures for the Review of Federal Actions Impacting the
Environment. EPA Manual 1640)
4J-1
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4J-2
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The U.S. Environmental Protection Agency rating system criteria for review
of draft environmental impact statements (Source: U.S. Environmental
Protection Agency. 1984. Policy and Procedures for the Review of Federal
Actions Impacting the Environment. EPA Manual 1640)
SUMMARY OF RATING DEFINITIONS AND FOLLOW-UP ACTION
Environmental Imoact of the Action
Lo—Lack of Objections. The EPA review has not identified any potential environmental
impacts requiring substantive changes to the proposal. The review may have disclosed
opportunities for application of mitigation measures that could be accomplished with no more
than minor changes to the proposal.
EC—Environmental Concerns. The EPA review has identified environmental impacts that
should be avoided in order to fully protect the environment. Corrective measures may require
changes to the preferred alternative or application of mitigation measures that can reduce the
environmental impact. EPA would like to work with the lead agency to reduce these impacts.
EO—Environmental Objections. The EPA review has identified significant environmental
impacts that must be avoided in order to provide adequate protection for the environment.
Corrective measures may require substantial changes to the preferred alternative or consideration
of some other project alternative (including the no action alternative or a new alternative). EPA
intends to work with the lead agency to reduce these impacts.
EU- Environmentally Unsatisfactory. The EPA review has identified adverse environmental
impacts that are of sufficient magnitude that they are unsatisfactory from the standpoint of public
health or welfare or environmental quality. EPA intends to work with the lead agency to reduce
these impacts. If the potential unsatisfactory impacts are not corrected at the final EIS stage,
this proposal will be recommended for referral to the CEQ.
Adequacy of the Impact Statement
Category 1—Adequate. EPA believes the draft EIS adequately sets forth the environmental
impact(s) of the preferred alternative and those of the alternatives reasonably available to the
project or action. No further analysis or data collection is necessary, but the reviewer may
suggest the addition of clarifying language or information.
4J-3
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Category 2-Insufficient Information. The draft EIjS does not contain sufficient information |
for EPA to fully assess environmental impacts that should be avoided in order to fully protect
the environment, or the EPA reviewer has identified new reasonably available alternatives that
are within the spectrum of alternatives analyzed in the draft EIS, which could reduce the
environmental impacts of the action. The identified additional information, data, analyses, or
discussion should be included in the final EIS.
Category 3-Inadequate. EPA does not believe that the draft EIS adequately assesses
potentially significant environmental impacts of the action, or the EPA reviewer has identified
new, reasonably available alternatives that are outside of the spectrum of alternatives analyzed
in the draft EIS, which should be analyzed in order to reduce the potentially significant
environmental impacts. EPA believes that the identified additional information, data, analyses,
or discussions are of such a magnitude that they should have full public review at a draft stage.
EPA does not believe that the draft EIS is adequate for the purposes of the NEPA and/or Section
309 review, and thus should be formally revised and made available for public comment in a
supplemental or revised draft EIS. On the basis of the potential significant impacts involved,
this proposal could be a candidate for referral to the CEQ.
4J-4
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PARTD
SELECTED LAWS AND REGULATIONS
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United States September
Environmental Protection 1989
Agency
Enforcement & Compliance Monitoring (LE-133)
c/EPA Facts About
The National
Environmental
Policy Act
The National Environmental Policy Act (NEPA),
[42 U.S.C. 4321 et seq.], was signed into law on
January 1,1970. The Act establishes national
environmental policy and goals for the
protection, maintenance, and enhancement of
the environment and it provides a process for
implementing these goals within the federal
agencies. The Act also establishes the Council
on Environmental Quality (CEQ).
NEPA Requirements
Title I of NEPA contains a Declaration of
National Environmental Policy which requires
the federal government to use all practicable
means to create and maintain conditions under
which man and nature can exist in productive
harmony. Section 102 requires federal agencies
to incorporate environmental considerations in
their planning and decision-making through a
systematic interdisciplinary approach.
Specifically, all federal agencies are to prepare
detailed statements assessing the environmental
impact of and alternatives to major federal
actions significantly affecting the environment.
These statements are commonly referred to as
environmental impact statements (EISs). Section
102 also requires federal agencies to lend
appropriate support to initiatives and programs
designed to anticipate and prevent a decline in
the quality of mankind's world environment.
Title n of NEPA establishes the Council on
Environmental Quality (CEQ) and requires the
President to transmit to Congress, with the
assistance of CEQ, an annual Environmental
Quality Report on the state of the environment.
Oversight Of NEPA
The Council on Environmental Quality, which is
headed by a fulltime Chairperson, oversees
NEPA. A staff assists the Council. The duties
and functions of the Council are listed in Title
n, Section 204 of NEPA and include: gathering
information on the conditions and trends in
environmental quality; evaluating federal
programs in light of the goals established in
Title I of the Act; developing and promoting
national policies to improve environmental
quality; and conducting studies, surveys,
research, and analyses relating to ecosystems
and environmental quality.
Printed on Recycled Paper
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Implementation
In 1978 CEQ promulgated regulations [40 CFR
Parts 1500-1508] implementing NEPA which are
binding on all federal agencies. The regulations
address the procedural provisions of NEPA and
the administration of the NEPA process,
including preparation of EISs. To date, the only
change in the NEPA regulations occurred on
May 27,1986, when CEQ amended Section
1502.22 of its regulations to clarify how agencies
are to carry out their environmental evaluations
in situations where information is incomplete or
unavailable.
CEQ has also issued guidance on various
aspects of the regulations including: an
information document on "Forty Most Asked
Questions Concerning CEQ's National
Environmental Policy Act", Scoping Guidance,
and Guidance Regarding NEPA Regulations.
Additionally, most federal agencies have
promulgated their own NEPA regulations and
guidance which generally follow the CEQ
procedures but are tailored for the specific
mission and activities of the agency.
The NEPA Process
The NEPA process consists of an evaluation of
the environmental effects of a federal
undertaking including its alternatives. There are
three levels of analysis depending on whether or
not an undertaking could significantly affect the
environment. These three levels include:
categorical exclusion determination; preparation
of an environmental assessment/finding of no
significant impact (EA/FONSI); and preparation
of an environmental impact statement (EIS).
At the first level, an undertaking may be
categorically excluded from a detailed
environmental analysis if it meets certain
criteria which a federal agency has previously
determined as having no significant
environmental impact. A number of agencies
have developed lists of actions which are
normally categorically excluded from
environmental evaluation under their NEPA
regulations.
At the second level of analysis, a federal
agency prepares a written environmental
assessment (EA) to determine whether or not a
federal undertaking would significantly affect
the environment. If the answer is no, the agency
issues a finding of no significant impact
(FONSI). The FONSI may address measures
which an agency will take to reduce (mitigate)
potentially significant impacts.
If the EA determines that the environmental
consequences of a proposed federal undertaking
may be significant, an EIS is prepared. An EIS is
a more detailed evaluation of the proposed
action and alternatives. The public, other federal
agencies and outside parties may provide input
into the preparation of an EIS and then
comment on the draft EIS when it is completed.
If a federal agency anticipates that an
undertaking may significantly impact the
environment, or if a project is environmentally
controversial, a federal agency may choose to
prepare an EIS without having to first prepare
anEA.
After a final EIS is prepared and at the time of
its decision, a federal agency will prepare a
public record of its decision addressing how the
findings of the EIS, including consideration of
alternatives, were incorporated into the agency's
decision-making process.
During the latter half of the 1980s,
approximately 450 draft and final EISs were
prepared annually on federal actions. During
that same period between 10,000 and 20,000
EAs were prepared annually.
EA And EIS Components
An EA is described in Section 1508.9 of the
Council's NEPA regulations. Generally, an EA
includes brief discussions of the following: the
need for the proposal; alternatives (when there
is an unresolved conflict concerning alternative
uses of available resources); the environmental
impacts of the proposed action and alternatives;
and a listing of agencies and persons consulted.
An EIS, which is described in Part 1502 of the
regulations, should include discussions of the
purpose of and need for the action, alternatives,
the affected environment, the environmental
consequences of the proposed action, lists of
preparers, agencies, organizations and persons
to whom the statement is sent, an index, and an
appendix (if any).
Federal Agency Roles
The role of a federal agency in the NEPA
process depends on the agency's expertise and
relationship to the proposed undertaking. The
agency carrying out the federal action is
responsible for complying with the requirements
-------
of NEPA. In some cases, there may be more than
one federal agency involved in an undertaking.
In this situation, a lead agency is designated to
supervise preparation of the environmental
analysis. Federal agencies, together with state or
local agencies, may act as joint lead agencies.
A federal agency having special expertise with
respect to an environmental issue or jurisdiction
by law may be a cooperating agency in the
NEPA process. A cooperating agency has the
responsibility to assist the lead agency by
participating in the NEPA process at the earliest
possible time; by participating in the scoping
process; in developing information and
preparing environmental analyses including
portions of the environmental impact statement
concerning which the cooperating agency has
special expertise; and in making available staff
support at the lead agency's request to enhance
the lead agency's interdisciplinary capabilities.
Under Section 1504 of CEQ's NEPA
regulations, federal agencies may refer to CEQ
interagency disagreements concerning proposed
federal actions that might cause unsatisfactory
environmental effects. CEQ's role, when it
accepts a referral, is generally to develop
findings and recommendations, consistent with
the policy goals of Section 101 of NEPA. The
referral process consists of certain steps and is
carried out within a specified time frame.
In deciding whether or not to refer an action,
an agency must consider the extent of potential
adverse environmental impacts including:
possible violation of national environmental
standards or policies, severity, geographical
scope, duration, importance as precedents, and
availability of environmentally preferable
alternatives. A referring agency must advise the
lead agency of its intention to refer the matter to
CEQ and notify CEQ. In advising the lead
agency, the referring agency will address the
reasons for the referral and recommendations for
remedying the situation. If the lead agency does
not satisfactorily respond to the referral agency,
then the matter is forwarded to CEQ. CEQ may
take several actions to resolve the situation
including:
• Discussing the matter with both agencies.
• Holding public meetings to obtain additional
information.
• Determining that the issue is not of national
importance and that the agencies should
proceed with their decision-making.
• Publishing its findings and recommendations.
• Submitting (when appropriate) the referral
and its recommendations to the President for
action. Although not binding, CEQ's
recommendations carry weight and influence.
Agencies generally follow CEQ's guidance.
EPA's Role
The Environmental Protection Agency, like
other federal agencies, prepares and reviews
NEPA documents. However, EPA has a unique
responsibility in the NEPA review process.
Under Section 309 of the Clean Air Act, EPA is
required to review and publicly comment on the
environmental impacts of major federal actions
including actions which are the subject of EISs.
If EPA determines that the action is
environmentally unsatisfactory, it is required by
Section 309 to refer the matter to CEQ. In the
period between 1974 to 1989, there were 24
referrals to CEQ, of which 14 were submitted by
EPA. EPA's 309 review process is described at
the end of this pamphlet.
Also, in accordance with a Memorandum of
Agreement between EPA and CEQ, EPA carries
out the operational duties associated with the
administrative aspects of the EIS filing process.
The Office of Federal Activities in EPA has been
designated the official recipient in EPA of all
EISs prepared by federal agencies.
The Public's Role
The public has an important role in the NEPA
process, particularly during scoping, in
providing input on what issues should be
addressed in an EIS and in commenting on the
findings in an agency's NEPA documents. The
public can participate in the NEPA process by
attending NEPA-related hearings or public
meetings and by submitting comments directly
to the lead agency. The lead agency must take
into consideration all comments received from
the public and other parties on NEPA
documents during the comment period.
NEPA And Other Environmental Laws
The NEPA review takes into consideration the
effect that an action may have on various
aspects of the environment. Some of these areas,
such as impacts on endangered speciss and
cultural resources, are also covered by other
environmental laws including the Endangered
-------
Species Act, the National Historic Preservation
Act, etc. To reduce paperwork and avoid delays
in the decision-making process, federal agencies
must, to the fullest extent possible, integrate the
NEPA review with the analytic and consultation
requirements of these other environmental laws.
The NEPA review also takes into
consideration whether a federal undertaking is
in compliance with statutes such as the Clean
Water Act and the Clean Air Act. In these cases,
the lead agency would consult with the agencies
overseeing these statutes to ensure compliance
with any criteria and standards promulgated
under these laws.
Integration Into Federal Decision-Making
The CEQ NEPA regulations require federal
agencies to make the environmental review
documents and any comments and responses a
part of the record in formal rulemaking and
adjudicatory proceedings. These documents
must also accompany the proposal through the
federal agency's review process. In making its
decision on a proposal, an agency must consider
a full range of alternatives including ones
evaluated in the NEPA review.
Most federal agencies have promulgated
NEPA regulations which address how the NEPA
review will be incorporated into their various
programs. Agencies are encouraged to prepare
broad EISs covering policy or programmatic
actions and to tier subsequent NEPA reviews to
individual actions included within the program
or policy. For legislative proposals, the NEPA
process is integrated with the legislative process
of Congress. Federal agencies are required to
integrate the NEPA review early in program or
project planning. In the preparation of EISs, the
scoping process provides for early identification
and consideration of environmental issues and
alternatives.
The Benefits Of NEPA
NEPA has caused federal agencies to incorporate
environmental values in their decision-making.
For most agencies, the NEPA review is now an
integral part of program planning. To oversee
compliance with NEPA, many agencies have
organized multi-disciplinary staffs. The primary
benefit has been more protection for the
environment in federal undertakings. This has
come about because of the NEPA review process
and resultant changes in projects, such as
alterations in project design, location or
operation; agency consideration of a greater
range of alternatives; implementation of
mitigation measures; and enhanced opportunity
for public involvement in the decision-making
process. An additional benefit has been a
reduction of some project costs because of
changes made in projects. The NEPA review
process has also enabled agencies to address
compliance with other environmental laws as
part of a single review process rather than
separate reviews under each law, thereby
reducing the amount of paperwork, staff time,
and effort.
State NEPAs
Following the passage of NEPA, which only
applies to federal actions, a number of states
passed laws which incorporate consideration of
environmental effects into state actions. Many of
the state NEPAs, or "little NEPAs" as they are
commonly called, are modelled after the federal
NEPA. Presently, 11 states have passed laws
with comprehensive environmental review
requirements. Fourteen states have limited
environmental review requirements established
by executive order or other administrative
directives.
EPA's "309" Review Process
Section 309 of the Clean Air Act states:
(a) "The Administrator shall review and
comment in writing on the environmental
impact of any matter relating to duties and
responsibilities granted pursuant to this chapter
or other provisions of the authority of the
Administrator, contained in any (1) legislation
proposed by any federal department or agency.
(2) newly authorized federal projects for
construction and any major federal agency
action (other than a project for construction) to
which Section 4332 (2) (C) of this title applies,
and (3) proposed regulations published by any
department or agency of the federal government
Such written comment shall be made public at
the conclusion of any such review.
(b) In the event the Administrator determines
that any such legislation, action, or regulation is
unsatisfactory from the stand-point of public
health or welfare or environmental quality, he
shall publish his determination and the matter
shall be referred to the Council on
Environmental Quality."
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This Section was added to the Clean Air Act
in 1970, at the time the NEPA was passed and
EPA was formed. The rationale was that the
EISs that federal agencies would be developing
under NEPA should have an independent '
review and that the newly formed EPA should
perform it.
EPA developed implementing procedures in
1971 to carry out this responsibility and, in
conjunction with the CEQ, has since refined
these procedures. Operating procedures are
contained in the manual, Policies and
Procedures for the Review of Federal Actions
Impacting the Environment (revised in 1984).
In accordance with these operating
procedures, EPA reviews, comments, and makes
the comments available to the public, on all
federal draft and final EISs, proposed
environmental regulations, and other proposed
major actions EPA considers to have significant
environmental effects. EPA has reviewed all of
the draft and final EISs prepared by federal
agencies since the passage of NEPA.
The major elements of the 309 review process
include the following:
• EPA reviews and comments on both the
adequacy of the analysis and the environmental
impacts of the proposed action itself.
• EPA comments on issues related to its "duties
and responsibilities", which include all
environmental media (i.e., air, water, etc.),
methodologies related to media-impact
assessment, and areas related to its regulatory
responsibilities.
• EPA comments on potential violation of or
inconsistency with national environmental
standards and determines whether adequate
information has been provided to
assess potential environmental impacts of the
proposed action.
• In general, the degree to which the Agency
gets involved in attempting to modify a
proposed project depends on the level of
environmental impacts, the ability and
willingness of the proposng federal agency to
mitigate those impacts, and the level of
responsibility EPA has over the type of impact
at issue.
• If the action is a federal project to be located
in or on a specific site, the appropriate EPA
regional office has the jurisdiction and delegated
responsibility for carrying out the Section 309
CAA review and working with the proposing
federal agency to resolve any problems. If the
action by the proposing federal
department/agency is legislative or regulatory,
generally the Section 309 CAA review will be
conducted directly in EPA headquarters.
• For federal-project cases, EPA headquarters
becomes involved if the region finds that the
proposed action in the draft EIS is
"environmentally unsatisfactory", or that the
draft EIS is "inadequate" to assess the
potentially significant environmental impacts of
proposed actions. In these cases, headquarters
must approve the regional comment letter before
it is sent. In addition, EPA headquarters works
with regional personnel in informing interested
parties about the EPA action and will assist the
region, as needed, in meeting with the
proposing federal agency to resolve the issues.
The CEQ is always notified of a draft EIS which
has been rated "unsatisfactory" or "inadequate"
by EPA.
• If the region finds that the subsequent final
EIS is still "environmentally unsatisfactory", the
region recommends to the Administrator that
the matter be referred to the CEQ for resolution.
At this time, EPA headquarters becomes
significantly involved in the factual
determination and judgment on the EIS.
• The process is carried out so as to ensure the
independence of the EPA review responsibilities
and to coordinate in a manner which
emphasizes consultation with the lead agency
and informing interested parties of EPA actions
and concerns.
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Council on Environmental Quality Regulations for Implementing the
Procedural Provisions of the National Environmental Policy Act.
(Source: 40 Code of Federal Regulations Parts 1500 - 1508)
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FORTY MOST ASKED QUESTIONS CONCERNING
CEQ'S NATIONAL ENVIRONMENTAL
POLICY ACT REGULATIONS
The Council on Environmental Quality published answers
to the "forty most asked questions concerning CEQ's
National Environmental Policy Act Regulations" in the
March 23, 1981 Federal Register (46 PR 18026-18038).
The answers to the questions were prepared by the General
Counsel of CEQ in consultation with the Office of Federal
Activities of EPA. The answers do not impose any
additional requirements beyond those of the NEPA
regulations but are meant to provide aid in the practical
application of the regulations. The subjects covered by the
40 questions are as follows:
1. Range of alternatives
2. Alternatives outside the capability of applicant or
jurisdiction of agency
3. No action alternative
4. Preferred alternative of the agency
5. Proposed action vs. preferred alternative
6. Environmentally preferable alternative
7. Difference between sections of EIS on alternatives
and environmental consequences
8. Early application of NEPA
9. Applicant who needs other permits
10. Limitations on action during 30-day review period
for final EIS
11. Limitations on actions by an applicant during EIS
process
12. Effective date and enforceability of the regulations
13. Use of scoping before notice of intent to prepare EIS
14. Rights and responsibilities of lead and cooperating
agencies
IS. Commenting responsibilities of EPA
16. Third party contracts
17. Disclosure statement to avoid conflict of interest
18. Uncertainties about indirect effects of a proposal
19. Mitigation measures
20. Wont case analysis
21. Combining environmental and planning documents .
22. State and federal agencies as joint lead agencies
23. Conflicts of federal proposal with land use plans, on
policies and controls
24. Environmental impact statements on policies, plans
or programs
25. Appendices and incorporation by reference
26. Index and keyword index in EISs
27. List of preparen
28. Advance or photocopies of EIS
29. Responses to comments
30. Adoption of EISs
31. Application of regulations to independent regulatory
agencies
32. Supplements to old EISs
33. Referrals
34. Records of decision
35. Time required for the NEPA process
36. Environmental assessments (EA)
37. Findings of no significant impact (FONSI)
38. Public availability of EAs vs. FONSIs
39. Mitigation measures imposed in EAs and FONSIi
40. Propriety of issuing EA when mitigation reduces
impacts
QUESTIONS AND ANSWERS
la. Q. What is meant by "range of alternatives" as referred
to in Section 1505. l(e)?
A. The phrase "range of alternatives" refers to the
alternatives discussed in environmental documents. It
includes all reasonable alternatives which must be
rigorously explored and objectively evaluated, as well as
those other alternatives which are eliminated from detailed
study with a brief discussion of the reasons for eliminating
them (Section 1502.14). A decision maker must not
consider alternatives beyond the range of alternatives
discussed in the relevant environmental documents. More-
over, a decision maker must, in fact, consider all the
alternatives discussed in an EIS (Section 1505. l(e)).
ft). Q. How many alternatives have to be discussed when
there is an infinite number of possible alternatives?
A. For some proposals there may exist a very large or even
an infinite number of possible reasonable alternatives. For
example, a proposal to designate wilderness areas within a
national forest could be said to involve an infinite number
of alternatives from 0 to 100% of the forest. When there
are potentially a very large number of alternatives, only a
reasonable number of examples, covering the full spectrum
of alternatives, must be analyzed and compared in the EIS.
An appropriate series of alternatives might include
dedicating 0, 10, 30, 50, 70, 90, or 100% of the forest to
wilderness. What constitutes a reasonable range of
alternatives depends on the nature of the proposal and the
facts in each case.
2a. Q. If an EIS is prepared in connection with an
application for a permit or other federal approval, must the
EIS rigorously analyze and discuss alternatives that are
outside the capability of the applicant, or can it be limited
to reasonable alternatives that can be carried out by the
applicant?
A. Section 1502.14 requires the EIS to examine all
reasonable alternatives to the proposal. In determining the
scope of alternatives to be considered, the emphasis is on
what is "reasonable" rather than on whether the proponent
or applicant likes it or is itself capable of carrying out a
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particular alternative. Reasonable alternatives include those
that are practical or feasible from the technical and
economic standpoint, using common sense, rather than
those simply desirable from the standpoint of the applicant.
2b. Q. Must the EIS analyze alternatives outside the
jurisdiction or capability of the agency or beyond what
Congress has authorized?
A. An alternative that is outside the legal jurisdiction of the
lead agency must still be analyzed in the EIS if it is
reasonable. A potential conflict with local or federal law
does not necessarily render an alternative unreasonable,
although such conflicts must be considered (Section
1506.2(d)). Alternatives that are outside the scope of what
Congress has approved or funded must still be evaluated in
the EIS if they are reasonable, because the EIS may serve
as the basis for modifying the Congressional approval or
funding in light of the goals and policies of NEPA (Section
1500.1 (a)) .
3. Q. What does the "no action" alternative include? If an
agency is under a court order or legislative command to
act, must the EIS address the "no action" alterative?
A. Section 1502.14(d) requires the alternatives analysis in
the EIS to "include the alternative of no action." There are
two distinct interpretations of "no action" that must be
considered depending on the nature of the proposal being
evaluated. The first situation might involve an action such
as updating a land management plan where ongoing
programs initiated under existing legislation and regulations
will continue, even as new plans are developed. In these
cases, "no action" is "no change" from current
management direction or level of management intensity. To
construct an alternative that is based on no management at
all would be a useless academic exercise. Therefore, the
"no action" alternative may be thought of in terms of
continuing with the present course of action until that
action is changed. Consequently, projected impacts of
alternative management schemes would be compared in the
EIS to those impacts projected for the existing plan. In this
case, alternatives would include management plans of both
greater and lesser intensity, especially greater and lesser
levels of resource development.
The second interpretation of "no action" is illustrated
in instances involving federal decisions on proposals for
projects. "No action" in such cases would mean the
proposed activity would not take place, and the resulting
environmental effects from taking no action would be
compared with the effects of permitting the proposed
activity or an alternative activity to go forward.
Where a choice of "no action" by the agency would
result in predictable actions by others, this consequence of
the "no action" alterative should be included in the
analysis. For example, if denial of permission to build a
railroad to a facility would lead to construction of a road
and increased truck traffic, the EIS should analyze this
consequence of the "no action" alternative. In light of the
above, it is difficult to think of a situation where it would
not be appropriate to address a "no action" alternative.
Accordingly, the regulations require the analysis of the "no
action" alternative even if the agency is under a court order
or legislative command to act This analysis provides a
benchmark, enabling decision makers to compare the
magnitude of environmental effects of the "no action"
alternatives. It is also an example of a reasonable alterative
outside the jurisdiction of the agency which must be
analyzed (Section 2502.14(c); see Question 2 above).
Inclusion of such an analysis in the EIS is necessary to
inform the Congress, the public, and the president as
intended by NEPA (Section 1500.1 (a)) .
4a. Q. What is the "agency's preferred alternative"?
A. The "agency's preferred alternative" is the alternative
which the agency believes would fulfill its statutory mission
and responsibilities, giving consideration to economic,
environmental, technical, and other factors. The concept of
the "agency's preferred alternative* is different from the
"environmentally preferable alternative", although, in some
cases, one alternative may be both (see Question 6 below).
It is identified so that agencies and the public can
understand the orientation of the lead agency.
4b. Q. Does the "preferred alternative" have to be
identified in the draft EIS and the final EIS or just in the
final EIS?
A. Section 1502.14(e) requires the section of the EIS on
alternatives to "identify the agency's preferred alternative
if one or more exists, in the draft statement, and identify
such alternative in the final statement ..." This means
that if the agency has a preferred alternative at the draft
EIS stage, that alterative must be labeled or identified as
such in the draft EIS. If the responsible federal official in
fact has no preferred alternative at the draft EIS stage, a
preferred alternative need not be identified there. By the
time the final EIS is filed, Section 1502.14(e) presumes the
existence of a preferred alternative and requires its
identification in the final EIS, "unless another law prohibits
the expression of such a preference."
4c. Q. Who recommends or determines the "preferred
alterative"?
A. The lead agency official with line responsibility for
preparing the EIS and assuring its adequacy is responsible
for identifying the preferred alternatives) of the agency.
The NEPA regulations do not dictate which official in an
agency shall be responsible for preparation of EISs, but
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agencies can identify thii official in this implementing
procedures, pursuant to Section 1507.3.
Even though the preferred alternative of the agency
is identified by the EIS preparer in the BIS, the statement
must be objectively prepared and not slanted to support the
choice of the preferred alternative of the agency over the
other reasonable and feasible alternatives.
Sa. Q. b the "proposed action" the same thing as the
"preferred alternative"?
A. The "proposed action" may be, but is not necessarily,
the "preferred alternative of the agency. The proposed
action may be a proposal in its initial form before
undergoing analysis in the EIS process. If the proposed
action is internally generated, such as preparing a land
management plan, the proposed action might end up as the
preferred alternative of the agency. On the other hand, the
proposed action may be granting an application to a
nonfederal entity for a permit. The agency may or may not
have a "preferred alternative" at the draft EIS stage (see
Question 4 above). In that case, the agency may decide at
the final EIS stage, on the basis of the draft EIS and the
public and agency comments, that an alternative other than
the proposed action is the "preferred alternative" of the
agency.
5b. Q. Is the analysis of the "proposed action" in an EIS
to be treated differently from the analysis of alternatives?
A. The degree of analysis devoted to each alternative in the
EIS is to be substantially similar to that devoted to the
"proposed action". Section 1501.3 is titled, "Alternatives
included in the proposed action," to reflect such
comparable treatment. Section 1502.14(96) specifically
requires "substantial treatment" in the EIS of each
alternative, including the proposed action. This regulation
does not dictate an amount of information to be provided,
but rather prescribes a level of treatment which may, in
turn, require varying amounts of information to enable a
reviewer to evaluate and compare alternatives.
6a. Q. What is the meaning of the term "environmentally
preferable alternative", as used in the regulations with
reference to records of decision? How is the term "envi-
ronment" used in the phrase?
A. Section 1505.2(b) requires that, in cases where an EIS
has been prepared, the record of decision (ROD) must
identify all alternatives that were considered, "...
specifying the alternative or alternatives which were
considered to be environmentally preferable." The
environmentally preferable alternative is the alternative that
will promote the national environmental policy as expressed
in NEPA, Section 101. Ordinarily, this means the
alternative that causes the least damage to the biological
and physical environment; it also means the alternative
which best protects, preserves, and enhances historic,
cultural, and natural resources.
The Council recognizes that the identification of the
environmentally preferable alternative may involve difficult
judgments, particularly when one environmental value must
be balanced against another. The public and other agencies
reviewing a draft EIS can assist the lead agency to develop
and determine environmentally preferable alternative* by
providing their views in comments on the draft EIS.
Through the identification of the environmentally preferable
alternative, the decision maker is clearly faced with a
choice between that alternative and others, and must
consider whether the decision accords with the
Congressionally declared policies of the act.
6b. Q. Who recommends or determines that which is
environmentally preferable?
A. The agency EIS staff is encouraged to make
recommendations of the environmentally preferable
altemativc(s) during EIS preparation. In any event, the lead
agency official responsible for the EIS is encouraged to
identify the environmentally preferable altemative(s) in the
EIS. In all cases, comments from other agencies and the
public are also encouraged to address this question. The
agency must identify the environmentally preferable
alternative in the ROD.
7. Q. What is the difference between the sections in the
EIS on "alternatives" and "environmental consequences"?
How do you avoid duplicating the discussion of alternatives
in preparing these two sections?
A. The "alternatives" section is the heart of the EIS. This
section rigorously explores and objectively evaluates all
reasonable alternatives, including the proposed action
(Section 1502.14). It should include relevant comparisons
on environmental and other grounds. The "environmental
consequences" section of the EIS discusses the specific
environmental impacts or effects of each of the alternatives,
including the proposed action (Section 1502.16*). In order
to avoid duplication between these two sections, most of
the "alternatives" section should be devoted to describing
and comparing the alternatives. Discussion of the
environmental impacts of these alternatives should be
limited to a concise, descriptive summary of such impacts
in a comparative form, including charts or tables, thus
sharply defining the issues and providing a clear basis for
choice among options (Section 1502.14). The
"environmental consequences" section should be devoted
largely to a scientific analysis of the direct and indirect
environmental effects of the proposed action and of each of
the alternatives. It forms the analytic basis for the concise
comparison in the "alternatives" section.
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8. Q. Section 1501.2(d) of the NEPA regulation* requires
agencies to provide for the early application of NEPA to
cases where actions are planned by private applicants or
nonfederal entities and are, at some stage, subject to
federal approval of permits, loans, loan guarantees,
insurance, or other actions. What must and can agencies do
to apply NEPA early in these cases?
A. Section 1S01.2
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EPA (Sections 1505.2 and 1506.10). Section 1505.2
requires this decision to be stated in a public record of
decision. Until the agency issues its record of decision, no
action by an agency or applicant concerning the proposal
shall be taken which would have an advene environmental
impact or limit the choice of reasonable alternatives
(Section 1506. l(a)). But this does not preclude preliminary
planning or design work which is needed to support an
application for permits or assistance (Section 1506.1(d).
When the impact statement in question is a program
EIS, no major action concerning the program may be taken
which may significantly affect the quality of the human
environment, unless the particular action is justified
independently of the program, is accompanied by its own
adequate environmental impact statement, and will not
prejudice the ultimate decision on the program (Section
1506. l(c)).
lOb. Q. Do these limitations on action (described in*
Question lOa) apply to state or local agencies that have
statutorily delegated responsibility for preparation of
environmental documents required by NEPA, for example,
under the HUD Block Grant program?
A. Yes, these limitations do apply, without any variation
from their application to federal agencies.
11. Q. What actions must a lead agency taken during the
NEPA process when it becomes aware that a nonfederal
applicant is about to take an action within the jurisdiction
of the agency that would either have an adverse
environmental impact or limit the choice of reasonable
alternatives (e.g., prematurely commit money or other re-
sources towards the completion of the proposal)?
A. The federal agency must notify the applicant that the
agency will take strong affirmative steps to insure that the
objectives and procedures of NEPA are fulfilled (Section
1506. l(b). These steps could include seeking injunctive
measurements under NEPA, or the use of sanctions
available under either the permitting authority of the
agency or statutes setting forth the statutory mission of the
agency. For example, the agency might advise an applicant
that if such action is taken, the agency will not process the
application.
12a. Q. What actions are subject to the new regulations of
CEQ, and what actions are grandfathered under the old
guidelines?
A. The effective date of the CEQ regulations was July 30,
1979 (except for certain HUD programs under the Housing
and Community Development Act, 42 U.S.C. 5304(h), and
certain state highway programs that qualify under Section
102(2)(D) of NEPA for which the regulations became
effective on November 30,1979). All the provisions of the
regulations are binding as of that date, including those
covering decision making, public participation, referrals,
limitations on actions, EIS supplements, etc. For example,
a record of decision would be prepared even for decisions
where the draft EIS was filed before July 30, 1979.
But in determining whether or not the new
regulations apply to the preparation of a particular
environmental document, the relevant factor is the date of
filling of the draft of that document Thus, the new
regulations do not require the redrafting of an EIS or
supplement if the draft EIS or supplement was filed before
July 30, 1979. However, a supplement prepared after the
effective date of the regulations for an EIS issued in final
before the effective date of the regulations would be
controlled by the regulations.
Even though agencies are not required to apply the
regulations to an EIS or other document for which the draft
was filed prior to July 30,1979, the regulations encourage
agencies to follow the regulations "to the fullest extent
practicable," i.e., if it is feasible to do so, in preparing the
final document (Section 1506.12(a)).
12b. Q. Are projects authorized by Congress before the
effective date of the CEQ regulations grandfathered?
A. No. The date of Congressional authorization for a
project is not determinative of whether the CEQ regulations
or former guidelines apply to the particular proposal. No
incomplete projects or proposals of any kind are
grandfathered in whole or in pan. Only certain
environmental documents, for which the draft was issued
before the effective date of the regulations, are
grandfathered and subject to the former guidelines of the
CEQ.
12c. Q. Can a violation of the regulations give rise to a
cause of action?
A. While a trivial violation of the regulations would not
give rise to an independent cause of action, such a cause of
action would arise from a substantial violation of the
regulations (Section 1500.3).
13. Q. Can the scoping process be used in connection with
preparation of an environmental assessment, i.e., before
both the decision to proceed with an EIS and publication of
a notice of intent?
A. Yes. Scoping can be a useful tool for discovering
alternatives to a proposal or significant impacts that may
have been overlooked. In cases where an environmental
assessment is being prepared to help an agency decide
whether to prepare an EIS, useful information might result
from early participation by other agencies and the public in
a scoping process.
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The regulation* tUtc that the scoping process is to be
preceded by t notice of intent (NOI) to prepare an EIS. But
that is only the minimum requirement. Scoping may be
initiated earlier, as long as there is appropriate public
notice and enough information available on the proposal so
that the public and relevant agencies can participate
effectively.
However, scoping that is done before the assessment,
and in aid of its preparation, cannot substitute for the
normal scoping process after publication of the NOI, unless
the earlier public notice stated clearly that this possibility
was under consideration, and the NOI expressly provides
that written comments on the scope of alternatives and
impacts will still be considered.
14a. Q. What are the respective rights and responsibilities
of lead and cooperating agencies? What letters and
memoranda must be prepared?
A. After a lead agency has been designated (Section
1501.5), that agency has the responsibility to solicit
cooperation from other federal agencies that have jurisdic-
tion by law or special expertise on any environmental issue
that should be addressed in the EIS being prepared. Where
appropriate, the lead agency should seek the cooperation of
state or local agencies of similar qualifications. When the
proposal may affect an Indian reservation, the agency
should consult with the Indian tribe (Section 1508.5). The
request for cooperation should come at the earliest possible
time in the NEPA process.
After discussions with the candidate cooperating
agencies, the lead agency and the cooperating agencies are
to determine by letter or by memorandum which agencies
will undertake cooperating responsibilities. To the extent
possible at this stage, responsibilities for specific issues
should be assigned. The allocation of responsibilities will
be completed during scoping (Section 1501.7(a)(4)).
Cooperating agencies must assume responsibility for
the development of information and the preparation of
environmental analyses at the request of the lead agency
(Section 1501.6(b)(3)). Cooperating agencies are not
required by Section 1501.6 to devote staff resources that
were normally used to critique or comment on the draft
EIS after its preparation, much earlier in the NEPA
process-primarily at the scoping and draft EIS preparation
stages. If a cooperating agency determines that its resource
limitations preclude any involvement, or the degree of
involvement (amount of work) requested by the lead
agency, it must so inform the lead agency in writing and
submit a copy of this correspondence to the Council
(Section 1501 .6(c)).
In other words, the potential cooperating agency must
decide early if it is able to devote any of its resources to a
particular proposal. For this reason, the regulation states
that an agency may reply to a request for cooperation that
"other program commitments preclude any involvement or
the degree of involvement requested in the action that is the t
subject of the environmental impact statement* (Emphasis
added.) The regulations refers to the "action", rather than
to the EIS, to clarify that the agency is taking itself out of
all phases of the federal action, not just draft EIS
preparation. This means that the agency has determined
that it cannot be involved in the later stages of EIS review
and comment, as well as decision making on the proposed
action. For this reason, cooperating agencies with
jurisdiction by law (those which have permitting or other
approval authority) cannot opt out entirely of the duty to
cooperate on the EIS (see also Question 15, relating
specifically to the responsibility of EPA).
14b. Q. How are disputes resolved between lead and
cooperating agencies concerning the scope and level of
detail of analysis and the quality of data in impact
statements?
A. Such disputes are resolved by the agencies themselves.
A lead agency, of course, has the ultimate responsibility
for the content of an EIS. But it is supposed to use the
environmental analysis and recommendations of
cooperating agencies with jurisdiction by law or special
expertise to the maximum extent possible, consistent with
its own responsibilities as lead agency (Section
1501.6(a)(2)).
If the lead agency leaves out a significant issue or
ignores the advice and expertise of the cooperating agency,
the EIS may be found later to be inadequate. Similarly,
where cooperating agencies have their own decisions to
make and they intend to adopt the environmental impact
statement and base their decisions on it, one document
should include all of the information necessary for the
decisions by the cooperating agencies. Otherwise they may
be forced to duplicate the EIS process by issuing a new,
more complete EIS or supplement EIS, even though the
original EIS could have sufficed if it had been properly
done at the outset. Thus, both lead and cooperating
agencies have a stake in producing a document of good
quality. Cooperating agencies also have a duty to
participate fully in the scoping process to ensure that the
appropriate range of issues is determined early in the EIS
process.
Because the EIS is not the record of decision, but
instead constitutes the information and analysis on which to
base a decision, disagreements about conclusions to be
drawn from the EIS need not inhibit agencies from issuing
a joint document, or adopting an EIS of another agency, if
the analysis is adequate. Thus, if each agency has its own
"preferred alternative", both can be identified in the EIS.
Similarly, a cooperating agency with jurisdiction by law
may determine in its own ROD that Alternative A is the
environmentally preferable action, even though the lead
agency has decided in its separate ROD that Alternative B
is environmentally preferable.
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14c. Q. What are the specific responsibilities of federal and
state cooperating agencies to review draft EISs?
A. Cooperating agencies (i.e., agencies with jurisdiction by
law or special expertise) and agencies that are authorized
to develop or enforce environmental standards must
comment on environmental impact statements within their
jurisdiction, expertise, or authority (Sections 1503.2,
1508.5). If a cooperating agency is satisfied that its views
are adequately reflected in the environmental impact
statement, it should simply comment accordingly.
Conversely, if the cooperating agency determines that a
draft EIS is incomplete, inadequate, or inaccurate, or it has
other comments, it should promptly make such comments,
conforming to the requirements of specificity in Section
1503.3.
14d. Q. How is the lead agency to treat the comments of
another agency with jurisdiction by law or special expertise
which has failed or refused to cooperate or participate in
scoping or EIS preparation?
A. A lead agency has the responsibility to respond to all
substantive comments raising significant issues regarding a
draft EIS (Section 1500.4). However, cooperating agencies
are generally under an obligation to raise issues or
otherwise participate in the EIS process during scoping and
EIS preparation if they reasonably can do so. In practical
terms, if a cooperating agency fails to cooperate at the
outset, such as during scoping, it will find that its
comments at a later stage will not be as persuasive to the
lead agency.
15. Q. Are responsibilities of the EPA to review and
comment on the environmental effects of agency proposals
under Section 309 of the Clean Air Act independent of its
responsibility as a cooperating agency?
A. Yes. EPA has an obligation under Section 309 of the
Clean Air Act to review and comment in writing on the
environmental impact of any matter relating to the authority
of the administrator contained in proposed legislation,
federal construction projects, other federal actions requiring
EISs, and new regulations (42 U.S.C. Sec. 7609). This
obligation is independent of its role as a cooperating agency
under the NEPA regulations.
16. Q. What is meant by the term "third party contracts"
in connection with the preparation of an EIS? (See Section
1506.5(c).) When can "third party contracts" be used?
A. As used by EPA and other agencies, the term "third
party contract" refers to the preparation of EISs by
contractors paid by the applicant. In the case of an EIS for
a National Pollution Discharge Elimination System
(NPDES) permit, the applicant, aware in the early planning
stages of the proposed project of the need for an ESS,
contracts directly with a consulting firm for its preparation
(Section 40 CFR 6.604(g)). The "third party" is EPA
which, under Section 1506.5(c) must select the consulting
firm, even though the applicant pays for the cost of
preparing the EIS. The consulting firm is responsible to
EPA for preparing an EIS that meets the requirements of
the NEPA regulations and the NEPA procedures of the
EPA. It is in the applicant's interest that the EIS can
comply with the law so that EPA can take prompt action on
the NPDES permit application. The "third party contract"
method under the NEPA procedures of the EPA is purely
voluntary, though most applicants have found it helpful in
expediting compliance with NEPA.
If a federal agency used "third party contracting",
the applicant may undertake the necessary paperwork for
the solicitation of a field of candidates under the direction
of the agency, so long as the agency complies with Section
1506.5(c). Federal procurement requirements do not apply
to the agency because it incurs no obligations or costs
under the contract, nor does the agency procure anything
under the contract
17a. Q. If an EIS is prepared with the assistance of a
consulting firm, the firm must execute a disclosure
statement. What criteria must the firm follow in
determining whether it has any "financial or other interest
in the outcome of the project" which would cause a conflict
of interest?
A. Section 1506.5(c), which specifies that a consulting firm
preparing an EIS must execute a disclosure statement, does
not define "financial or other interest in the outcome of the
project." The Council interprets this term broadly to cover
any known benefits other than general enhancement of
professional reputation. This includes any financial benefit
such as a promise of future construction or design work on
the project as well as indirect benefits the consultant is
aware of (e.g., if the project would aid proposals sponsored
by the other clients of the firm). For example, completion
of a highway project may encourage construction of a
shopping center or industrial park from which the
consultant stands to benefit. If a consulting firm is aware
that it has such an interest in the decision on the proposal,
it should be disqualified from preparing the EIS to preserve
the objectivity and integrity of the NEPA process.
When a consulting firm has been involved in
developing initial data and plans for the project, but does
not have any financial or other interest in the outcome of
the decision, it need not be disqualified from preparing the
EIS. However, a disclosure statement in the draft EIS
should clearly state the scope and extent of the prior
involvement of the firm to expose any potential conflicts of
interest that may exist.
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17b. Q. If the firm in fact has no promise of future work
or other interest in the outcome of the proposal, may the
firm later bid in competition with others for future work on
the project if the proposed action is approved?
A. Yes.
18. Q. How should uncertainties about indirect effects of
a proposal be addressed, for example, in cases of disposal
of federal lands when the identity or plans of future
landowners is unknown?
A. The EIS must identify all the indirect effects that are
known, and make a good faith effort to explain the effects
that are not known, but are "reasonably foreseeable*
(Section 1508.8(b)). In the example, if there is total
uncertainty about the identity of future land owners or the
nature of future land uses, then of course the agency is not
required to engage in speculation or contemplation about
their future plans. But, in the ordinary course of business,
people do make judgments based upon reasonably
foreseeable occurrences. It will often be possible to
consider the likely purchasers and the development trends
in that area or similar areas in recent years; or the
likelihood that the land will be used for an energy project,
shopping center, subdivision, farm, or factory. The agency
has the responsibility to make an informed judgment and to
estimate future impacts on that basis, especially if trends
are asccrtainable or potential purchasers have made
themselves known. The agency cannot ignore these
uncertain, but probable, effects of its decisions.
19a. Q. What is the scope of mitigation measures that must
be discussed?
A. The mitigation measures discussed in an EIS must cover
the range of impacts on the proposal. The measures must
include such things as design alternatives that would
decrease pollution emissions, construction impacts,
aesthetic intrusion, as well as relocation assistance, possible
land use controls that could be enacted, and other possible
efforts. Mitigation measures must be considered even for
impacts that by themselves would not be considered
"significant". Once the proposal itself is considered as a
whole to have significant effects, all of its specific effects
on the environment (whether or not "significant") must be
considered, and mitigation measures must be developed
where it is feasible to do so (Sections 1502.14(0,
1502.160i), 1508. 14).
19b. Q. How should an EIS treat the subject of available
mitigation measures that are (I) outside the jurisdiction of
the lead agency or cooperating agencies or (2) unlikely to
be adopted or enforced by the responsible agency?
A. All relevant, reasonable mitigation measures that could
improve the project are to be identified, even if they are
outside the jurisdiction of the lead agency or the
cooperating agencies and thus would not be committed as
part of the ROD* of these agencies (Sections 1502.16(h),
150S.2(c)). This will serve to alert agencies or officials
who can implement these extra measures and will
encourage them to do so. Because the EIS is the most
comprehensive environmental document, it is an ideal
vehicle in which to toy out not only the full range of
environmental impacts, but also the full spectrum of
appropriate mitigation.
However, to ensure that environmental effects of a
proposed action are fairly assessed, the probability of the
mitigation measures being implemented must also be
discussed. Thus, the EIS and the record of decision should
indicate the likelihood that such measures will be adopted
or enforced by the responsible agencies (Sections
1502.1600, 1505.2). If there is a history of
nonenforcement or opposition to such measures, the EIS
and record of decision should acknowledge such opposition
or nonenforcement. If the necessary mitigation measures
will not be ready for a long period of time, this fact, of
course, should also be recognized.
20a. Q. When must a worst case analysis be included in an
EIS?
A. If there are gaps in relevant information or scientific
uncertainty pertaining to an evaluation of an agency of
significant adverse impacts on the human environment, an
agency must make clear that such information is lacking or
that the uncertainty exists. An agency must include a worst
case analysis of the potential impacts of the proposal and an
indication of the probability or improbability of their
occurrence if (a) the information relevant to adverse
impacts is essential to a reasoned choice among alternatives
and the overall costs of obtaining the information are
exorbitant, or (b) the information relevant to adverse
impacts is important to the decision and the means to obtain
it are not known. NEPA requires that impact statements, at
a minimum, contain information to alert the public and
Congress to all known possible environmental consequences
of agency action. Thus, one of the most important
obligations of the federal government is to present to the
fullest extent possible the spectrum of consequences that
may result from agency decisions and the details of their
potential consequences for the human environment.
20b. Q. What is the purpose of a worst case analysis? How
is it formulated, and what is the scope of the analysis?
A. The purpose of the analysis is to carry out the mandate
of NEPA for full disclosure to the public of the potential
consequences of any agency decisions, and to cause
agencies to consider those potential consequences when
acting on the basis of scientific uncertainties or gaps in
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available information. The analyiis is formulated on the
basil of available information, using reasonable projections
of the wont possible consequences of a proposed action.
For example, if there are scientific uncertainties and
gaps in the available information concerning the numbers
of juvenile fish that would be entrained in a cooling water
facility, the responsible agency must disclose and consider
the possibility of the loss of the commercial or sport
fishery.
In addition to an analysis of a low
probability/catastrophic impact event, the worst case
analysis should also include a spectrum of events of higher
probability, but of less drastic impact
21. Q. Where an EIS or an EA is combined with another
project planning document (sometimes called
"piggybacking"), to what degree may the EIS or EA refer
to and rely upon information in the project document to
satisfy the requirements of NEPA?
A. Section 1502.25 of the regulations requires that draft
EISs be prepared concurrently and integrated with
environmental analyses and related surveys and studies
required by other federal statutes. In addition, Section
1506.4 allows any environmental document prepared in
compliance with NEPA to be combined with any other
agency document to reduce duplication and paperwork.
However, these provisions were not intended to authorize
the preparation of a short summary or outline EIS, attached
to a detailed project report or land use plan containing the
required environmental impact data. In such circumstances,
the reader would have to refer constantly to the detailed
report to understand the environmental impacts and
alternatives which would have been found in the EIS itself.
The EIS must stand on its own as an analytical
document which fully informs decision makers and the
public of the environmental effects of the proposal and
those of the reasonable alternatives (Section 1502.1). But,
as long as the EIS is clearly identified and is
self-supporting, it can be physically included in or attached
to the project report or land use plan and may use attached
report material as technical backup.
Forest Service environmental impact statements for
forest management plans are handled in this manner. The
EIS identifies the preferred alternative of the agency, which
is developed in detail as the proposed management plan.
The detailed proposed plan accompanies the EIS through
the review process, and documents are appropriately cross
referenced. The proposed plan is useful for EIS readers as
an example to show how one choice of management options
translates into effects on natural resources. This procedure
permits initiation of the 90-day public review of proposed
forest plans which is required by the National Forest
Management Act.
All the alternatives are discussed in the EIS which
can be read as an independent document. The details of the
management plan are not repeated in the EIS, and vice
vena. This is a reasonable functional separation of the
documents: the EIS contains information relevant to the
choice among alternatives; the plan is a detailed description
of proposed management activities suitable for use by the
land managers. This procedure provides for concurrent
compliance with the public review requirements of both
NEPA and the National Forest Management Act
Under some circumstances, a project report or
management plan may be totally merged with the EIS, and
the one document labeled as both "EIS" and "management
plan" or "project report". This may be reasonable where
the documents are short or where the EIS format and the
regulations for clear, analytical EISs also satisfy the
requirements for a project report.
22. Q. May state and federal agencies serve as joint lead
agencies? If so. how do they resolve law, policy, and
resource conflicts under NEPA and the relevant state
environmental policy act? How do they resolve differences
in perspective where, for example, national and local needs
may differ?
A. Under Section 1501.5(b), federal, state, or local
agencies, as long as they include at least one federal
agency, may act as joint lead agencies to prepare an EIS.
Section 1506.2 also strongly urges state and local agencies
and the relevant federal agencies to cooperate fully with
each other. This should cover joint research and studies,
planning activities, public hearings, environmental
assessments, and the preparation of joint EISs under NEPA
and the relevant "little NEPA" state laws so that one
document will satisfy both laws.
The regulations also recognize that certain
inconsistencies may exist between the proposed federal
action and any approved state or local plan or law. The
joint document should discuss the extent to which the
federal agency would reconcile its proposed action with
such plan or law (Section 1506.2(d); see Question 23).
Because there may be differences in perspective, as
well as conflicts among federal, state, and local goals for
resources, management, the Council has advised
participating agencies to adopt a flexible, cooperative
approach. The final EIS should reflect all of their interests
and missions, clearly identified as such. The final document
would then indicate how state and local interest have been
accommodated, or would identify conflicts in goals (e.g.,
how a hydroelectric project, which might induce second
home development, would require new land use controls).
The EIS must contain a complete discussion of scope and
purpose of the proposal, alternatives, and impacts so that
the discussion is adequate to meet the needs of local, state,
and federal decision makers.
23a. Q. How should an agency handle potential conflicts
between a proposal and the objectives of federal, state, or
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local land we plans, policies, and controls for the area
concerned? (See Section 1502. JO(c)).
A. The agency should first inquire of other agencies
whether there are any potential conflicts. If there would be
immediate conflicts, or if conflicts could arise in the future
when the plans are finished (sec Question 23b below), the
EIS must acknowledge and describe the extent of those
conflicts. If there are any possibilities of resolving the
conflicts, these should be explained as well. The EIS
should also evaluate the seriousness of the impact of the
proposal on the land use plans and policies and whether, or
how much, the proposal will impair the effectiveness of
land use control mechanisms for the area. Comments from
officials of the affected area should be solicited early and
should be carefully acknowledged and answered in the EIS.
23b. Q. What constitutes a "land use plan or policy" for
purposes of this discussion?
A. The term "land use plans", includes all types of
formally adopted documents for land use planning, zoning,
and related regulatory requirements. Local general plans
are included, even though they are subject to future
change. Proposed plans should also be addressed if they
have been formally proposed by the appropriate govern-
ment body in a written form and are being actively pursued
by officials of the jurisdiction. Staged plans, which must go
through phases of development such as the Level A, B, and
C planning process of the Water Resources Council, should
also be included, even though they are incomplete.
The term "policies" includes formally adopted
statements of land use policy as embodied in laws or
regulations. It also includes proposals for action such as the
initiation of a planning process or a formally adopted
policy statement of the local, regional, or state executive
branch, even if it has not yet been formally adopted by the
local, regional, or state legislative body.
23c. Q. What options are available for the decision maker
when conflicts with such plans or policies are identified?
A. After identifying any potential land use conflicts, the
decision maker must weigh the significance of the conflicts
among all the other environmental and noncnvironmental
factors that must be considered in reaching a rational and
balanced decision. Unless precluded by other law from
causing or contributing to any inconsistency with the land
use plans, policies, or controls, the decision maker retains
the authority to go forward with the proposal, despite the
potential conflict. In the record of decision, the decision
maker must explain what the decision was, how it was
made, and what mitigation measures are being imposed to
lessen adverse environmental impacts of the proposal,
among the other requirements of Section 1505.2. This
provision would require the decision maker to explain any
decision to override land use plans, policies, or controls for
the area.
24a. Q. When are EISs required on policies, plans or
programs?
A. An EIS must be prepared if an agency proposes to
implement a specific policy, to adopt a plan for a group of
related actions, or to implement a specific statutory
program or executive directive (Section 1508.18). In
addition, the adoption of official policy in the form of
rules, regulations, and interpretations pursuant to the
Administrative Procedure Act, treaties, conventions, or
other formal documents establishing governmental or
agency policy which will substantially alter agency
programs could require an EIS (Section 1508.18). In all
cases, the policy, plan, or program must have the potential
for significantly affecting the quality of the human
environment in order to require an EIS. It should be noted
that a proposal "may exist in fact as well as by agency
declaration that one exists" (Section 1508.23).
24b. Q. When is an area-wide or overview EIS
appropriate?
A. The preparation of an area-wide or overview EIS may
be particularly useful when similar actions, viewed with
other reasonably foreseeable or proposed agency actions,
share common timing or geography. For example, when a
variety of energy projects may be located in a single
watershed, or when a series of new energy technologies
may be developed through federal funding, the overview or
area-wide EIS would serve as a valuable and necessary
analysis of the affected environment and the potential
cumulative impacts of the reasonably foreseeable actions
under that program or within that geographical area.
24c. Q. What is the function of tiering in such cases?
A. Tiering is a procedure which allows an agency to avoid
duplication of paperwork through the incorporation by
reference of the general discussions and relevant specific
discussions from an environmental impact statement of
broader scope into one of lesser scope or vice versa. In the
example given in Question 24b, this would mean that an
overview EIS would be prepared for all of the energy
activities reasonably foreseeable in a particular geographic
area or resulting from a particular development program.
This impact statement would be followed by she--or
project-specific EISs. The tiering process would make each
EIS of greater use and meaning to the public as the plan or
program develops, without duplication of the analysis
prepared for the previous impact statement.
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25a. Q. When is it appropriate to use appendices instead of
including information in the body of an EIS?
A. The body of the EIS should be a succinct statement of
all the information on environmental impacts and
alternatives that the decision maker and the public need in
order to make the decision and to ascertain that every
significant factor has been examined. The EIS must explain
or summarize methodologies of research and modeling and
the results of research that may have been conducted to
analyze impacts and alternatives.
Lengthy technical discussions of modeling
methodology, baseline studies, or other work are best
reserved for the appendix. In other words, if only
technically trained individuals are likely to understand a
particular discussion, then it should go in the appendix, and
a plain language summary of the analysis and conclusions
of that technical discussion should go in the text of the EIS.
The final statement must also contain the response of
the agency to comments on the draft EIS. These responses
will be primarily in the form of changes in the document
itself, but specific answers to each significant comment
should also be included. These specific responses may be
placed in an appendix. If the comments are especially
voluminous, summaries of the comments and responses will
suffice. (See Question 29 regarding the level of detail
required for responses to comments. )
2Sb. Q. How does an appendix differ from incorporation
by reference?
A. First, if at all possible, the appendix accompanies the
EIS, whereas the material which is incorporated by
reference does not accompany the EIS. Thus, the appendix
should contain information that reviewers will likely want
to examine. The appendix should include material that
pertains to preparation of a particular EIS. Research papers
directly relevant to the proposals, lists of affected species,
discussion of the methodology of models used in the
analysis of impacts, extremely detailed responses to
comments, or other information would be placed in the
appendix.
The appendix must be complete and available at the
time the EIS is filed. Five copies of the appendix must be
sent to EPA with five copies of the EIS for filing. If the
appendix is too bulky to be circulated, it instead must be
placed in conveniently accessible locations or furnished
directly to commentors upon request. If it is not circulated
with EIS, the Notice of Availability published by EPA must
so state, giving a telephone number to enable potential
commentors to locate or request copies of the appendix
promptly.
Material that is not directly related to preparation of
the EIS should be incorporated by reference. This would
include other EISs, research papers in the general
literature, technical background papers, or other material
that someone with technical training could use to evaluate
the analysis of the proposal. These must be made available,
either by citing the literature, furnishing copies to central
locations, or sending copies directly to commentors upon
request.
Care must be taken in all cases to ensure that
material incorporated by reference, and the occasional
appendix that does not accompany the EIS, are in fact
available for the full minimum public comment period.
26a. Q. How detailed must an EIS index be?
A. The EIS index should have a level of detail sufficient to
focus on areas of the EIS of reasonable interest to any
reader. It cannot be restricted to the most important topics.
On the other hand, it need not identify every conceivable
term or phrase in the EIS. If an agency believes that the
reader is reasonably likely to be interested in a topic, it
should be included.
266. Q. Is a key word index required?
A. No. A key word index is a relatively short list of
descriptive terms that identifies the key concepts or subject
areas in a document. For example, it could consist of 20
terms which describe the most significant aspects of an EIS
that a future researcher would need: type of proposal, type
of impacts, type of environment, geographical area,
sampling or modelling methodologies used. This technique
permits the compilation of EIS data banks, by facilitating
quick and inexpensive access to stored materials. While a
key word index is not required by the regulations, it could
be a useful addition for several reasons. First, it can be
useful as a quick index for reviewers of the EIS, helping to
focus on areas of interest. Second, if an agency keeps a
listing of the key word indexes of the EISs it produces, the
EIS preparers themselves will have quick access to similar
research data and methodologies to aid their future EIS
work. Third, a key word index will be needed to make an
EIS available for future researchers using EIS data banks
that are being developed. Preparation of such an index
now, when the document is produced, will save a later
effort when the data banks become operational.
27a. Q. If a consultant is used in preparing an EIS, must
the list of preparers identify members of the consulting
firm as well as the agency NEPA staff who were primarily
responsible?
A. Section 1502.17 requires identification of the names and
qualifications of persons who were primarily responsible
for preparing the EIS or significant background papers,
including basic components of the statement. This means
that members of a consulting firm preparing material that
is to become part of the EIS must be identified. The EIS
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ihould identify theie individual! even though the
coniultant'i contribution may have been modified by the
agency.
27b. Q. Should agency staff involved in reviewing and
editing the EIS also be included in the list of prcparers?
A. Agency personnel who wrote basic components of the
EIS or significant background papers must, of course, be
identified. The EIS should also list the technical editors
who reviewed or edited the statements.
27c. Q. How much information should be included on each
person listed?
A. The list of preparers should normally not exceed two
pages. Therefore, agencies must determine which
individuals had primary responsibility and need not identify
individuals with minor involvement. The list of preparers
should include a very brief identification of the individuals
involved, their qualifications (expertise, professional
disciplinei), and the specific portion of the EIS for which
they are responsible. This may be done in tabular form to
cut down on length. A line or two for each person's
qualifications should be sufficient.
28. Q. May an agency file photocopies of an EIS with EPA
pending the completion of printing the document?
A. Photocopies of an EIS may be filed with EPA prior to
printing only if the photocopies are simultaneously made
available to other agencies and the public. Section 1506.9
of the regulations, which governs EIS filing, specifically
requires federal agencies to file EISs with EPA no earlier
than the EIS is distributed to the public. However, this
section does not prohibit photocopying as a form of
reproduction and distribution. When an agency chooses
photocopying as the reproduction method, the EIS must be
clear and legible to permit ease of reading and ultimate
microfkhing of the EIS. Where color graphs are important
to the EIS, they should be reproduced and circulated with
the photocopy.
29a. Q. What response must an agency provide to a
comment on a draft EIS which states that the EIS
methodology is inadequate or inadequately explained? For
example, what level of detail must an agency include in its
response to a simple post card comment making such an
allegation?
A. Appropriate responses to comments are described in
Section 1503.4. Normally, the responses should result in
changes in the text of the EIS, not simply a separate
answer at the back of the document. But, in addition, the
agency must state what its response was, and if the agency
decides that no substantive response to a comment is
necessary; it must briefly explain why.
An agency is not under an obligation to issue a
lengthy reiteration of its methodology for any portion of an
EIS if the only comment addressing the methodology is a
simple complaint that the EIS methodology is inadequate.
But agencies must respond to comments, however brief,
which are specific in their criticism of agency
methodology. For example, if a commentor of an EIS said
that the air quality dispersion analysis or methodology of
an agency was inadequate, and the agency had included a
discussion of that analysis in the EIS, little if anything need
be added in response to such a comment. However, if the
commentor said that the dispersion analysis was inadequate
because of its use of certain computational techniques, or
that a dispersion analysis was inadequately explained
because computational techniques were not included or
referenced, then the agency would have to respond in a
substantive and meaningful way to such a comment.
If a number of comments are identical or very
similar, agencies may group the comments and prepare a
single answer for each group. Comments may be sum-
marized if they are especially voluminous. The comments
or summaries must be attached to the EIS, regardless of
whether the agency believes they merit individual
discussion in the body of the final EIS.
29b. Q. How must an agency respond to a comment on a
draft EIS that raises a new alternative not previously
considered in the draft EIS?
A. This question might arise in several possible situations.
First, a commentor on a draft EIS may indicate that there
is a possible alternative which, in the view of the agency,
is not a reasonable alternative (Section 1502.14(a)). If that
is the case, the agency must explain why the comment does
not warrant further agency response, citing authorities or
reasons that support the position of the agency and, if
appropriate, indicate those circumstances which would
trigger agency reappraisal or further response (Section
1503.4(a)). For example, a commentor on a draft EIS on
a coal-fired power plant may suggest the alternative of
using synthetic fuel. The agency may reject the alternative
with a brief discussion (with authorities) of the
unavailability of synthetic fuel within the time frame
necessary to meet the need and purpose of the proposed
facility.
A second possibility is that an agency may receive a
comment .indicating that a particular alternative, while
reasonable, should be modified somewhat, for example, to
achieve certain mitigation benefits or for other reasons. If
the modification is reasonable, the agency should include
a discussion of it in the final EIS. For example, a
commentor on a draft EIS on a proposal for a pumped
storage power facility might suggest that the applicant's
proposed alternative should be enhanced by the addition of
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certain reasonable mitigation measures, including the
purchase and setting aside of a wildlife preserve to
substitute for the tract to be destroyed by the project. The
modified alternative including the additional mitigation
measures should be discussed by the agency in the final
EIS.
A third, slightly different possibility is that a
comment on a draft EIS will raise an alternative which is
a minor variation of one of the alternatives discussed in the
draft EIS, but this variation was not given any
consideration by the agency. In such a ease, the agency
should develop and evaluate the new alternative, if it is
reasonable, in the final EIS. If it is gualitatively within the
spectrum of alternatives that were discussed in the draft, a
supplemental draft will not be needed. For example, a
commentor on a draft EIS to designate a wilderness area
within a national forest might reasonably identify a specific
tract of the forest and urge that it be considered for
designation. If the draft EIS considered designation of a
range of alternative tracts which encompassed forest area
of similar quality and quantity, no supplemental EIS would
have to be prepared. The agency could fulfill its obligation
by addressing that specific alternative in the final EIS.
As another example, an EIS on an urban housing
project may analyze the alternatives of constructing 2000,
4000, or 6000 units. A commentor on the draft EIS might
urge the consideration of constructing 5000 units, utilizing
a different configuration of buildings. This alternative is
within the spectrum of alternatives already considered and,
therefore, could be addressed in the final EIS.
A fourth possibility is that a commentor points out an
alternative which is not a variation of the proposal or of
any alternative discussed in the draft impact statement and
is a reasonable alternative that warrants serious agency
response. In such a case, the agency must issue a
supplement to the draft EIS that discusses this new
alternative. For example, a commentor on a draft EIS on
a nuclear power plant might suggest that a reasonable
alternative for meeting the projected need for power would
be through peak load management and energy conservation
programs. If the permitting agency has failed to consider
that approach in the draft EIS, and the approach cannot be
dismissed by the agency as unreasonable, a supplement to
the draft EIS which discusses that alternative must be
prepared. (If necessary, the same supplement should also
discuss substantial changes in the proposed action or
significant new circumstances or information, as required
by Section 1502.9(c)(l) of the CEQ regulations.
If the new alternative was not raised by the
commentor during scoping, but could have been,
commentors may find that they are unpersuasive in their
efforts to have their suggested alternative analyzed in detail
by the agency. However, if the new alternative is
discovered or developed later, and it could not reasonably
have been raised during the scoping process, then the
agency must address it in a supplemental draft EIS. The
agency is, in any case, ultimately responsible for preparing
an adequate EIS that considers all alternatives.
30. Q. When a cooperating agency with jurisdiction by law
intends to adopt the EIS of a lead agency and it is not
satisfied with the adequacy of the document, may the
cooperating agency adopt only the part of the EIS with
which it is satisfied? If so, would a cooperating agency
with jurisdiction by law have to prepare a separate EIS or
EIS supplement covering the areas of disagreement with the
lead agency?
A. Generally, a cooperating agency may adopt the EIS of
a lead agency without recirculating it if it concludes that its
NEPA requirements and its comments and suggestions have
been satisfied (Section 1506.3(a),(c)). If necessary, a
cooperating agency may adopt only a portion of the EIS of
the lead agency and may reject that part of the EIS with
which it disagrees, stating publicly when it did not (Section
1506.3(a)).
A cooperating agency with jurisdiction by law (e. g
., an agency with independent legal responsibilities with
respect to the proposal) has an independent legal obligation
to comply with NEPA. Therefore, if the cooperating
agency determines that the EIS is wrong or inadequate, it
must prepare a supplement to the EIS, replacing or adding
any needed information, and must circulate the supplement
as a draft for public and agency review and comment. A
final supplemental EIS would be required before the agency
could take action. The adopted portions of the lead agency
EIS should be circulated with the supplement (Section
1506.3(b)). A cooperating agency with jurisdiction by law
will have to prepare its own record of decision for its
action, in which it must explain how it reached its
conclusions. Each agency should explain how and why its
conclusions differ, if that is the case, from those of other
agencies which issued their records of decision earlier.
An agency that did not cooperate in preparation of an
EIS may also adopt an EIS or portion thereof. But this
would arise only in rare instances, because an agency
adopting an EIS for use in its own decision normally would
have been a cooperating agency. If the proposed action for
which the EIS was prepared is substantially the same as the
proposed action of the adopting agency, the EIS may be
adopted as long as it is recirculated as a final EIS and the
agency announces what it is doing. This would be followed
by the 30-day review period and issuance of a record of
decision by the adopting agency. If the proposed action by
the adopting agency is not substantially the same as that in
the EIS (e.g., if an EIS on one action is being adopted for
use in a decision on another action), the EIS would be
treated as a draft and circulated for the normal public
comment period and other procedures (Section 1506.3(b)).
3 la. Q. Do the CEQ NEPA regulations apply to
independent regulatory agencies like the Federal Energy
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Regulatory CommiMion (FERC) and the Nuclear
Regulatory Commiukm (NRC)?
A. The ftatutory requirements of NEPA Section 102 apply
to 'all agenda of the federal government." The NEPA
regulations implement the procedural provisions of NEPA
as set forth in NEPA Section 102(2) for all agencies of the
federal government The NEPA regulations apply to
independent regulatory agencies; however, they do not
direct independent regulatory agencies or other agencies to
make decisions in any particular way or in a way
inconsistent with the statutory charter of an agency
(Sections 1500.3,1500.6, 1507.1, and 1507.3).
31b. Q. Can an executive branch agency, like the
Department of Interior, adopt an EIS prepared by an
independent regulatory agency such as FERC?
A. If an independent regulatory agency such as FERC has
prepared an EIS in connection with its approval of a
proposed project, an executive branch agency (e.g., the
Bureau of Land Management in the Department of Interior)
may, in accordance with Section 1506.3, adopt the EIS or
a portion thereof for its use in considering the same
proposal. In such a case, the EIS must, to the satisfaction
of the adopting agency, meet the standards for an adequate
statement under the NEPA regulations (including scope and
quality of analysis of alternatives) and must satisfy the
comments and suggestions of the adopting agency. If the
independent regulatory agency foils to comply with the
NEPA regulations, the cooperating or adopting agency may
find that it is unable to adopt the EIS, thus forcing the
preparation of a new EIS or EIS supplement for the same
action. The NEPA regulations were made applicable to all
federal agencies in order to avoid this result and to achieve
uniform application and efficiency of the NEPA process.
32. Q. Under what circumstances do old EISs have to be
supplemented before taking action on a proposal?
A. As a rule of thumb, if the proposal has not yet been
implemented, or if the EIS concerns an ongoing program,
EISs that are more than 5 years old should be carefully
recxamincd to determine if the criteria in Section 1502.9
compel preparation of an EIS supplement.
If an agency has made a substantial change in a
proposed action that is relevant to environmental concerns,
or if there are significant new circumstances or information
relevant to environmental concerns and bearing on the
proposed action or its impacts, a supplemental EIS must be
prepared for an ok) EIS so that the agency has the best
possible information to make any necessary substantive
changes in its decisions regarding the proposal. (Section
1502.9(c)).
33a. Q. When must a referral of an interagency
disagreement be made to the Council?
A. The referral procedure of the Council is a predecision
referral process for interagency disagreements . Hence,
Section 1 504. 3 requires that a referring agency must
deliver its referral to the Council not later than 25 days
after publication by EPA of notice that the final EIS is
available (unless the lead agency grants an extension of
time under Section 1504.3(b)).
33b. Q. May a referral be made after this issuance of a
record of decision?
A. No, except for cases where agencies provide an internal
appeal procedure which permits simultaneous filing of the
final EIS and the record of decision (Section
1506.10(b)(2)). Otherwise, as stated above, the process is
a predecision referral process. Referrals must be made
within 25 days after the notice of availability of the final
EIS, whereas the final decision (ROD) may not be made or
filed until after 30 days from the notice of availability of
the EIS (Sections 1504.3(b), 1506.10(b)). If a lead agency
has granted an extension of time for another agency to take
action on a referral, the ROD may not be issued until the
extension has expired.
34a. Q. Must records of decision be made public? How
should they be made available?
A. Under the regulations, agencies must prepare a 'concise
public record of decision," which contains the elements
specified in Section 1505.2. This public record may be
integrated into any other decision record prepared by the
agency, or it may be separate if decision documents are not
normally made public. The record of decision is intended
by the Council to be an environmental document (even
though it is not explicitly mentioned in the definition of
"environmental document" in Section 1508.10). Therefore,
it must be made available to the public through appropriate
public notice, as required by Section 1506.6(b). However,
there is no specific requirements for publication of the
ROD itself, either in the Federal Register or elsewhere.
34b. Q. May the summary section in the final
environmental impact statement substitute for or constitute
the record of decision of an agency?
A. No. An environmental impact statement is supposed to
inform the decision maker before the decision is made
(Section 1502.1,1505.2). The CEQ regulations provide for
a 30-day period after notice is published that the final EIS
has been filed with EPA before the agency may take final
action. During that period, in addition to the internal final
review of the agency, the public and other agencies can
comment on the final EIS prior to the final action of the
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agency on the proposal. In addition, the CEQ regulation!
make it clear that the requirements for the summary in an
EIS are not the same as the requirements for a ROD
(Sections 1502.12 and 1505.2).
34c. Q. What provisions should records of decision contain
pertaining to mitigation and monitoring?
A. Lead agencies "shall include appropriate conditions
(including mitigation measures and monitoring and
enforcement programs) in grants, permits' or other
approvals" and shall "condition funding of actions on
mitigation" (Section 1505.3). Any such measures that are
adopted must be explained and committed in the ROD.
The reasonable alternative mitigation measures and
monitoring programs should have been addressed in the
draft and final EIS. The discussion of mitigation and
monitoring in a record of decision must be more detailed
than a general statement that mitigation is being required,
but not so detailed as to duplicate discussion of mitigation
in the EIS. The record of decision should contain a concise
summary identification of the mitigation measures which
the agency has committed itself to adopt.
The record of decision must also state whether all
practicable mitigation measures have been adopted and, if
not, why hot (Section 1505.2(c)). The record of decision
must identify the mitigation measures and monitoring and
enforcement programs that have been selected and plainly
indicate that they are adopted as part of the decision of the
agency. If the proposed action is the issuance of a permit
or other approval, the specific details of the mitigation
measures shall then be included as appropriate conditions
in whatever grants, permits, funding or other approvals are
being made by the federal agency (Section 1505.3(a),(b)).
If the proposal is to be carried out by the federal agency
itself, the record of decision should delineate the mitigation
and monitoring measures in sufficient detail to constitute an
enforceable commitment or incorporate by reference the
portions of the EIS that do so.
34d. Q. What is the enforceability of a record of decision?
A. Pursuant to generally recognized principles of federal
administrative law, agencies will be held accountable for
preparing records of decision that conform to the decisions
actually made and for carrying out the actions set forth in
the records of decision. This is based on the principle that
an agency must comply with its own decisions and
regulations once they are adopted. Thus, the terms of a
record of decision are enforceable by agencies and private
parties. A record of decision can be used to compel
compliance with or execution of the mitigation measures
identified therein.
35. Q. How long should the NEPA process take to
complete?
A. When an EIS is required, the process obviously will
take longer than when an EA is the only document
prepared. But the CEQ NEPA regulations encourage
streamlined review, adoption of deadlines, elimination of
duplicative work, eliciting suggested alternatives and other
comments early through scoping, cooperation among
agencies, and consultation with applicants during project
planning. The Council has advised agencies that under the
new NEPA regulations, even large, complex energy
projects would require only about 12 months for the
completion of the entire EIS process. For most major
actions, this period is well within the planning time that is
needed in any event, apart from NEPA.
The time required for the preparation of program
EISs may be greater. The Council also recognizes that
some projects will entail difficult long-term planning and/or
the acquisition of certain data which of necessity will
require more time for the preparation of the EIS. Indeed,
some proposals should be given more time for the
thoughtful preparation of an EIS and development of a
decision which fulfills the substantive goals of NEPA.
For cases in which only an environmental assessment
will be prepared, the NEPA process should take no more
than 3 months, and in many cases, substantially less, as
part of the normal analysis and approval process for the
action.
36a. Q. How long and detailed must an environmental
assessment (EA) be?
A. The environmental assessment is a concise public
document which has three defined functions: (1) it briefly
provides sufficient evidence and analysis for determining
whether to prepare an EIS; (2) it aids the compliance of an
agency with NEPA when no EIS is necessary, i.e., it helps
to identify better alternatives and mitigation measures; and
(3) it facilitates preparation of an EIS when one is
necessary (Section 1508.9(a)).
Since the EA is a concise document, it should not
contain long descriptions or detailed data which the agency
may have gathered. Rather, it should contain a brief
discussion of the need for the proposal, alternatives to the
proposal, the environmental impacts of the proposed action
and alternatives, and a list of agencies and persons
consulted (Section 1508.9(b)).
While the regulations do not contain page limits for
EAs, the Council has generally advised agencies to keep
the length of EAs to not more than approximately 10 to 15
pages. Some agencies expressly provide page guidelines
(e.g., 10 to 15 pages in the case of the Army Corps). To
avoid undue length, the EA may incorporate by reference
background data to support its concise discussion of the
proposal and relevant issues.
36b. Q. Under what circumstances is a lengthy EA
appropriate?
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A. Agencies should avoid preparing lengthy EAi, except in
unusual cases where a proposal is so complex that a
concise document cannot meet the goals of Section 1508.9
and where it is extremely difficult to determine whether the
proposal could have significant environmental effects. In
most cases, however, a lengthy EA indicates that an BIS is
needed.
37a. Q. What is the level of detail of information that must
be included in a finding of no significant impact (FONSI)?
A. The FONSI is a document in which the agency briefly
explains the reasons why an action will not have a
significant effect on the human environment and, therefore,
why an BIS will not be prepared (Section 1508.13). The
finding itself need not be detailed, but must succinctly state
the reasons for deciding that the action will have no
significant environmental effects, and, if relevant, must
show which factors were weighted most heavily in the
determination. In addition to this statement, the FONSI
must include, summarize, or attach and incorporate by
reference the environmental assessment.
37b. Q. What are the criteria for deciding whether a
FONSI should be made available for public review for 30
days before the final determination of the agency or
whether to prepare an EIS?
A. Public review is necessary, for example, (I) if the
proposal is a borderline case, i.e., when there is a
reasonable argument for preparation of an EIS; (2) if it is
an unusual case, a new kind of action, or a
precedent-setting case such as a first intrusion of even a
minor development into a pristine area; (3) when there is
either scientific or public controversy over the proposal; or
(4) when it involves a proposal which is or is closely
similar to one which normally requires preparation of an
EIS (Sections 1501 .4(c)(2), 1508.27). Agencies also must
allow a period of public review of the FONSI if the
proposed action would be located in a floodplain or wetland
(E.O. 11988, Sec. 2(a)(4); E.O. 11990, Sec. 2(b)).
38. Q. Must EAs and FONSIs be made public? If so, how
should this be done?
A. Yes, they must be available to the public. Section
1506.6 requires agencies to involve the public in
implementing their NEPA procedures, and this includes
public involvement in the preparation of EAs and FONSIs.
These are public "environmental documents* under Section
1506.6(b), and, therefore, agencies must give public notice
of their availability. A combination of methods may be
used to give notice, and the methods should be tailored to
the needs of particular cases. Thus, a Federal Register
notice of availability of the documents, coupled with
notices in national publications and mailed to interested
national groups might be appropriate for proposals that are
national in scope. Local newspaper notices may be more
appropriate for regional or site-specific proposals.
The objective, however, is to notify all interested or
affected parties. If this is not being achieved, then the
methods should be reevaluated and changed. Repeated
failure to reach the interested or affected public would be
interpreted as a violation of the regulations.
39. Q. Can an EA and FONSI be used to improve
enforceable mitigation measures, monitoring programs, or
other requirements, even though there is no requirement in
the regulations in such cases for a formal record of
decision?
A. Yes. In cases where an environmental assessment is the
appropriate environmental document, there still may be
mitigation measures or alternatives that would be desirable
to consider and adopt, even though the impacts of the
proposal will not be "significant". In such cases, the EA
should include a discussion of these measures or
alternatives to "assist agency planning and decision
making" and to "aid an agency's compliance with (NEPA)
when no environmental impact statement is necessary"
(Section 1501.3(b), 1508.9(2)). The appropriate mitigation
measures can be imposed as enforceable permit conditions,
or adopted as part of the final decision of the agency in the
same manner mitigation measures are adopted in the formal
record of decision that is required in EIS cases.
40. Q. If an environmental assessment indicates that the
environmental effects of a proposal are significant, but that,
with mitigation, those effects may be reduced to
less-than-significant levels, may the agency make a finding
of no significant impact rather than prepare an EIS. Is that
a legitimate function of an EA and scoping?
A. Mitigation measures may be relied upon to make a
finding of no significant impact only if they are imposed by
statute or regulation or submitted by an applicant or agency
as part of the original proposal. As a general rule, the
regulations contemplate that agencies should use a broad
approach in defining significance, and should not rely on
the possibility of mitigation as an excuse to avoid the EIS
requirement (Sections 1508.8, 1508.27).
If a proposal appears to have adverse effects which
would be significant, and certain mitigation measures are
then developed during the scoping or EA stages, the
existence of such possible mitigation does not obviate the
need for an EIS. Therefore, if scoping or the EA identifies
certain mitigation possibilities without altering the nature of
the overall proposal itself, the agency should continue the
EIS process and submit the proposal and the potential
mitigation for public and agency reviews and comment.
This is essential to ensure that the final decision is based on
all the relevant factors, and that the full NEPA process will
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result in enforceable mitigation measure! through the
record of decision.
In some instances where the proposal itself so
integrates mitigation from the beginning that it is
impossible to define the proposal without including the
mitigation, the agency may then rely on the mitigation
measures in determining that the overall effects would not
be significant (e.g., where an application for a permit for
a small hydroelectric darn is based on a binding
commitment to build fish ladders, to permit adequate down
stream flow, and to replace any tost wetlands, wildlife
habitat, and recreational potential). In those instances,
agencies should make the FONSI and EA available for 30
days of public comment before taking action (Section
1501.4(eX2)).
Similarly, scoping may result in a redefinition of the
entire project as a result of mitigation proposals. In that
case, the agency may alter its previous decision to do an
BIS, as long as the agency or applicant resubmits the entire
proposal and the EA and FONSI are available for 30 days
of review and comment. One example of this would be
where the size and location of a proposed industrial park
are changed to avoid affecting a nearby wetland area.
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Summaries of Related U.S. Environmental
Laws. (Source: EPA, Cross-cutting
Environmental Laws, 21E 4001, January 1991.)
Endangered Species Act, 16 U.S.C. 1531 et seq.
The purpose of the Endangered Species Act (ES A) is
to ensure that federal agencies and departments use
their authorities to protect and conserve endangered
and threatened species. Section 7 of the Act requires
that federal agencies prevent or modify any projects
authorized, funded, or carried out by the agencies
that are 'likely to jeopardize the continued existence
of any endangered species or threatened species, or
result in the destruction or adverse modification of
critical habitat of such species." Implementing
regulations are found at SO CFR Parts 402,450.451,
452, and 453.
National Historic Presentation Act, 16 U.S.C. 470
The National Historic Preservation Act (NHPA), as
amended, directs federal agencies to integrate historic
preservation into all activities which either directly or
indirectly involve land use decisions. This is to
ensure federal leadership in the preservation of
prehistoric and historic resources of the United
States. Implementing regulations are found at 36
CFR Parts 60, 61, 63, 65, 68, 79 and 800.
Guidelines are found at 48 FR 190, Part IV and 53
FR 4727-46.
Archeological and Historic Preservation Act,
as amended, 16 U.S.C. 469-469c
The Archeological and Historic Preservation Act
(AHPA), as amended, furthers the policies of the
Historic Sites Act -of 1935 by providing for the
preservation of cultural resources that may be
damaged by federal or federally authorized
construction activities. The statute contains the
Reservoir Salvage Act of 1960 and amendments made
to it in 1974 (P.L.93-291, known as the Moss-
Bennett Act) and 1978 (P.L.95-625). The portions of
AHPA that may apply to federal agency projects are
Section 4(a) and Section 7(a). Section 4(a) requires
that the Secretary of the Interior be notified when
unanticipated archeological materials are discovered
during construction of a federal undertaking. Section
7(a) limits the amount of funds expended for
archeological data recovery as part of a federal
undertaking to one percent of project expenses.
However, Section 208 of the 1980 amendments to the
national Historic Preservation Act (P.L.96-515)
established a procedure for agencies to request the
Secretary of the Interior to waive the one percent
limitation. Implementing regulations are found at 36
CFR Part 800. •Standards and Guidelines for
Archeology and Historic Preservation" are found at
48 FR 44716.
The Wild and Scenic Rivers Act,
16 U.S.C. 271 et seq.
The purpose of the Wild and Scenic Rivers Act
(WSRA) is to preserve the free-flowing state of rivers
that are listed in the National Wild and Scenic Rivera
System (System) or under study for inclusion in the
System because of their outstanding scenic,
recreational, geologic, fish and wildlife, historic,
cultural, or other similar values. Rivers in the
System are classified as either wild river areas,
scenic river areas, or recreational river areas. The
WSRA establishes requirements applicable to water
resource projects and protects both the river, or river
segments, and the land immediately surrounding
them. Implementing regulations are found at 36 CFR
Part 297 Subpart A. Guidelines entitled "National
Wild and Scenic Rivers System, Final Revised
Guidelines for Eligibility, Classification and
Management of River Areas" were published in the
Federal Register on September 7, 1982.
The Fish and Wildlife Coordination Act,
16 U.S.C. 661 et seq.
The Fish and Wildlife Coordination Act (FWCA), as
amended in 1964, was enacted to protect fish and
wildlife when federal actions result in the control or
modification of a natural stream or body of water.
The statute requires federal agencies to take into
consideration the effect that water-related projects
would have on fish and wildlife resources; take action
to prevent loss or damage to these resources; and
provide for the development and improvement of
these resources. There are no implementing
regulations.
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Coastal Zone Management Act,
16 U.S.C. Section 1451 et seq.
are found at 50 CFR Part 35; 43 CFR Parts 19 and
8560; and 36 CFR Parts 293, 261 and 219.
The Coastal Zone Management Act (CZMA)
encourages the management of coastal zone areas and
provides grants to be used in maintaining coastal zone
areas. It requires that federal agencies be consistent
with the enforceable policies of state coastal zone
management programs when conducting or supporting
activities which affect a coastal zone. It is intended
to ensure that federal activities are consistent with
state programs for the protection and, where possible,
enhancement of the nation's coastal zones. As
defined in the Act, the coastal zone includes coastal
waters extending to the outer limit of state submerged
land title and ownership, adjacent shorelines and land
extending inward to the extent necessary to control
shorelines. The coastal zone includes islands,
beaches, transitional and intertidal areas, salt
marshes, etc. Implementing regulations are found at
15 CFR 930 Subpart D and Part 923.
Coastal Barrier Resources Act,
16 U.S.C. 3501 et seq.
The purpose of the Coastal Barrier Resources Act
(CBRA) is to protect ecologically sensitive coastal
barriers along the coasts of the U.S. The Act
establishes the Coastal Barrier Resources System
(CBRS) and, with certain exceptions, prohibits new
federal expenditures and financial assistance for
development within the System. Section 5(a) of the
Act lists expenditures and assistance specifically
prohibited, while Section 6 outlines the specific
exceptions to the general prohibition. The U.S. DOI
Coastal Barrier Act Advisory Guidelines were issued
by the Fish and Wildlife Service on October 6, 1983.
The Wilderness Act, 16 U.S.C. 1131 et seq.
The Wilderness Act (WA) established a system of
National Wilderness areas and a policy for protecting
and managing this system. With certain exceptions,
the Act prohibits motorized equipment, structures,
installations, roads, commercial enterprises, aircraft
landings, and mechanical transport. The Act permits
mining on valid claims, access to private lands, fire
control, insect and disease control, grazing, water-
resource structures (upon the approval of the
President), and visitor use. Implementing regulations
Farmland Protection Policy Act, 7 U.S.C. 4201
et seq., and EPA Policy to Protect
Environmentally Significant Agricultural Lands,
September 1978.
The purpose of the Farmland Protection Policy Act
(FPPA) is to minimi7A the extent to which federal
programs contribute to the unnecessary and
irreversible conversion of farmland to non-
agricultural uses, and to assure that federal programs
are administered in a manner that, to the extent
practicable, will be compatible with state, local, and
private programs and policies to protect farmland.
Additionally, EPA's policy is to protect the Nation's
significant/important agricultural lands from
conversions that are irreversible and result in the loss
of an essential food or environmental resource.
Implementing procedures are found at 7 CFR Part
658 and the USDA Final Rule, Farmland Protection
Policy of July 5, 1984 (proposed revisions published
on January 8, 1987).
Executive Order 11990-Protection of Wetlands
(May 24, 1977, 42 FR 26961).
The purpose of Executive Order 11990 is to
"minimize the destruction, loss or degradation of
wetlands and to preserve and enhance the natural and
beneficial values of wetlands". To meet these
objectives, the Order requires federal agencies, in
planning their actions, to consider alternatives to
wetland sites and limit potential damage if an activity
affecting a wetland cannot be avoided. The Order
applies to:
• acquisition, management, and disposition of
federal lands and facilities;
• construction and improvement projects
which are undertaken, financed or assisted
by federal agencies;
• federal activities and programs affecting land
use, including but not limited to water and
related land resources planning, regulation,
and licensing activities.
EPA's implementing procedures "Statement of
Procedures on Floodplain Management and Wetlands
Protection" were issued on January 5, 1979 (see
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Appendix A of EPA's NEPA regulations at 40 CFR
Part 6).
Executive Order 11988-Floodplain Management,
May 24, 1977.
Executive Order 11988 requires federal agencies to
avoid to the extent possible the long and short-term
adverse impacts associated with the occupancy and
modification of floodplains and to avoid direct and
indirect support of floodplain development wherever
there is a practicable alternative. In accomplishing
this objective, "each agency shall provide leadership
and shall take action to reduce the risk of flood loss,
to minimize the impact of floods on human safety,
health, and welfare, and to restore and preserve the
natural and beneficial values served by floodplains in
carrying out its responsibilities" for the following
actions:
• acquiring, managing, and disposing of
federal lands and facilities;
• providing federally-undertaken, financed, or
assisted construction and improvements;
• conducting federal activities and programs
attending land use, including but not limited
to water and related land resources planning,
regulation, and licensing activities.
EPA's implementing procedures were issued on
January 5, 1979 (see Protection of Wetlands above).
On February 10,1978, the Water Resources Council
published 'Floodplain Management Guidelines" at 40
FR 6030. In 1987, the Federal Emergency
Management Agency issued "Further Advice on EO
11988 Floodplain Management".
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States with Environmental Policy Acts. (Source: Council on Environmental
Quality. 1992. Environmental Quality. 22nd Annual Report)
Sixteen states, the District of Columbia, and Puerto Rico have environmental policy acts
or "little NEPAs."
State
Arkansas
California
Connecticut
District of Columbia
Florida
Hawaii
Indiana
Maryland
Massachusetts
Minnesota
Montana
New York
North Carolina
Puerto Rico
South Dakota
Virginia
Washington
Wisconsin
Citation
Ark. Stat Ann. §8-1-101 (1987)
Cal. Pub. Res. Code §§21000 et seq. (West 1982)
Conn. Gen. Stat Ann. §§22a-14 to 22a-20 (West Supp. 1974-75)
D. C. Code Ann. 1981 §6-981 et seq.
Fla. Stat. §§380.92 et seq.
Hawaii Rev. Stat. §§343-1 to 343-8 (1985)
Ind. Code Ann. §§13-1-10-1 to 13-1-10-8 (West 1987)
Md. Nat. Res. Code Ann. §§1-301 to 1-305 (1983 and Supp. 1987)
Mass. Gen. Laws Ann. ch. 30, §§61-62H
Minn. Stat. Ann. §§116D.01 et seq. (West 1977 and Supp. 1981)
Mont. Code Ann. §§75-1-101 to -105; §75-1-201 (1981)
N.Y. Envtl. Conserv. Law §§8-0101 to 8-0117 (McKinney 1984)
N.C. Gen. Stat, §§113A-1 to 10 (1978)
P.R. Laws Ann. tit 12, §§1121-1127
S.D. Codified Laws Ann. §§34A-9-l to 34A-9-12
Va. Code §§10.1-1200 through 10.1-1212 (Subject to redefinition by the Virginia General
Assembly in 1992)
Wash. Rev. Code §§43.21C.010-43.21C.910 (1974); Wash. Admin. Code R. 197-11
Wis. Stat. §1.11 et seq.; Department of Natural Resources WEPA rules are found in Wis. Admin.
Code NR 150.01-40
D-35
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D-36
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States with Limited Environmental Review Requirements Established by Statute, Executive Order, or Other
Administrative Directives. (Source: Council on Environmental Quality. 1992. Environmental Quality. 22nd
Annual Report)
Eighteen Mate* and the District of Columbia have limited environmental review
requirements eitablithed by statute, executive order, or other administrative directive*.
State
Arizona
O
co
Arkansas
California
Requirement
An Executive Order mandates that the Governor's
Commission on Arizona Environment evaluate environmental
problems, make recommendations to the Governor, and
establish a clearinghouse for the exchange of information
relating to environmental problems and their solutions.
In addition to a 'little NEPA,' Ark. Code Ann. |15-41-108
provides that the Arkansas Game and Fish Commission must
prepare an EIS for cutting timber on Commission land.
In addition to a 'little NEPA." the following California
Codes require environmental impact reports:
Cat. Food ft Agric. Code |33487 (new construction or
repair* of dairy farms)
Cal. Gov. Code 97075 (establishment of enterprise zones)
Cal. Gov. Code |7087.5 (initial study and notice of
preparation under Employment and Economic Incentive Act)
Cal. Gov. Code 151119 (timberland production zones;
exemption)
Cal. Gov. Code $65950.1 (extension of time for EIR for
planning and zoning of development projects)
Cal. Health A Safety Code 933333.3 (preparation and
adoption of community redevelopment plans)
Cal. Heahh & Safety Code {56040 (implementation and
administration for large scale urban development)
Cal. Pub. Re*. Code 96873.2 (oil and gas lease* on tide and
submerged land* and bed* of navigable riven and lake*)
Cal. Pub. Re*. Code 925540.4 (power facility and the
certification)
Cal. Pub. Re*. Code 930718 (implementation of port
development under California Coastal Act)
Cal. Sir. ft H. Code 9199.9 (mat* transit guideway system)
Delaware
District of Columbia
Georgia
Louisiana
Massachusetts
Michigan
Cal. Water Code 913389 (applicability of EIS* to Clean
Water Act)
In the Del. Code Ann. tit. 7, Chapter 66 concern* wetland*
permit*, and Chapter 20, coastal zone permit*.
In addition to a "little NEPA,* D.C. Code Ann. 943-1903
involve* public utility environmental impact statements.
The Code of Georgia provide* that on certain type* of action*
on a case by case ban*, the Mate may require that an
environmental assessment be prepared; EA* would be
reviewed by the state Department of Natural Resources,
Environmental Protection Division.
La. Rev. Slat. Ann. 930:2021 (West 1991) coven interstate
compact* on environmental control, for which the louitiana
Department of Environmental Quality serve* a* •
clearinghouse for all statement* of environmental impact to
be prepared or reviewed by Mate agencies (other than
Department of Transportation and Development), in
accordance with NEPA. The Department of Wildlife and
Fisheries is responsible for review and comment on any EIS
regarding fish and wildlife resources or their habitat, a* well
a* the discharge of dredge and fill material into Mate waters.
The Department of Health and Human Resources 1*
responsible for EIS* regarding public health.
In addition to a 'little NEPA,' Mai*. Gen. Law* Ann. ch.
111H, 930 concern low-level radioactive waste facility
licensing.
Executive Order 1974-4 require* each Mate agency to prepare
a formal environmental assessment for all major activities of
the agency having a possible significant impact on the
environment or human life. Mich. Comp. Law* Ann.
9281.655 et seq. coven EISs for sand dune mining and
model zoning plan* under the Lake* and Riven Sand Dune
Protection and Management Act.
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New Jersey
North Carolina
North Dakota
Oregon
o
co
CO
Pennsylvania
Rhode bland
South Dakota
Utah
Washington
Wisconsin
Executive Order No. 53 (1973) requires all date agencies and
departments to submit to the Department of Environmental
Protection • description of the environmental impact of all
major construction projects. NJ. Rev. Stat. |13:19-7
provides for EISs for such projects as coastal protection, N J.
Rev. Stat. {27:23-23.5 coven EISs for the New Jersey
Turnpike authority (highway sand turnpikes). NJ. Rev. Stat.
52:13F-4 refers to environmental impact statements on
specific legislative bills.
In addition to • 'little NEPA,' N.C. Gen. Stat. S104O-H
concerns low-level radioactive waste management technology
licensing.
N.D. Century Code §854-01-05.4provides that the Governor
may require EISs of • limited nature prior to the transfer of
any interest in state-owned land to federal agencies.
Although Oregon Rev. Stat. ch. 46 does not require EISs for
major actions having a significant impact on the environment,
permit applications for siting of major energy generating
facilities must include a background report addressing various
anticipated environmental impacts.
Executive Order requires Environmental Assessments for all
transportation projects. Various state regulations require EAs
for other state actions.
R.I. Gen. Laws §23-03-3 provides that a facility which plans
to export tire* for burning must submit an EIS conforming to
the EPA standards.
In addition to a 'little NEPA,' S.D. Codified laws Ann. §49-
41B-21 el seq. concern energy conversion and transmission
facilities.
State of Utah Exec. Order (Aug. 27, 1974).
In addition to • 'little NEPA,' Wash. Rev. Code Ann.
§78.52.125 (oil and gas conservation drilling that affects
surface waters) Wash Rev. Code Ann. 70.95.700 (solid waste
incineration or energy recovery facility).
In addition to a 'little NEPA,' Wis. Stat. Ann. §144.68
(solid waste, hazardous waste, and refuse).
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CHAPTERS
DECISIONMAKING
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CHAPTERS
DECISIONMAKING
For the purpose of this sourcebook, decisionmaking is the authorizing
decision for a proposed project. It does not refer to the incremental technical
decisionmaking that occurs throughout the EA process (e.g., choice of impact
analysis techniques) or decisions made early on during initiation and scoping
(e.g., choice of alternatives) or decisions made during screening that proposed
actions do not require the complete EA process. However, the real value of the
EA process may be in the avoidance of, or reduction in, adverse environmental
impacts as a result of incremental decisionmaking before a proposed action
reaches final decisionmaking.
Integration of EA into the decisionmaking process varies among countries.
In the U.S., EA is designed to assist agency planning and decisionmaking and not
to justify decisions that have already been made. An agency decision to adopt a
particular alternative is based on the EA document and formalized by a record of
decision that is available to the public. In the United Kingdom, the EA report is
seen as a supporting document to the submission of a project for authorization.
However, such projects have met a number of other statutory requirements during
their development.
In the U.S., decisionmaking can be seen as a two-stage process. Before
a draft EA document is ready for public and other agency review and comment,
the proponent must endorse the draft subject to additional information and
comment during public hearings and review. After the draft document is revised
to reflect public and other agency comment, the document is finalized, an agency
decision is made, and a formal record of decision is published.
NEEDS
Effective decisionmaking depends on 1) coordination and continuing
communication between the EA team leader and the decisionmaker(s), 2) a well-
organized executive summary of the final EA document that provides the
decisionmaker with concise and objective information relevant to the important
issues, and 3) a public decision document that summarizes the basis for the final
decision including the uncertainties and mitigation and/or monitoring
requirements.
5-1
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• Decisionmaking requires compromise among many elements (e.g.,,
technical, environmental, economic, political and administrative
factors). Thus, it is important that the decisionmaker is an integral
part of the EA process so that his/her decision is based on
understanding the choice of issues analyzed in the EA document
and the limitations of the analysis. Progress reports and periodic
briefings serve to eliminate surprises.
• Decisions are often made by persons who are not closely involved
with the EA. Thus, an executive summary, based on the table of
contents of the EA document, must provide the decisionmaker with
clear and concise information to facilitate comparison of
alternatives and to support the choice of the environmentally
preferred alternative. The executive summary should include brief
' discussion of the:
— proposed action with a schedule for implementation;
— viable alternatives that reflect the purpose of and need for
the proposed action;
— potential impacts of implementation (e.g., construction,
operation, accidents);
— relative importance of the environmental issues;
— basis for balancing the environmental impacts with other
impacts/benefits (e.g., economic, social, technical);
— recommendations and their implications;
— uncertainties and risks of proceeding and how the
uncertainties will be managed;
— concerns/views of the publics and technical specialists
(e.g., biologists, engineers); and
— mitigation in response to unavoidable impacts or
outstanding concerns and follow-up requirements.
As a general guide, an executive summary should be about 10
percent of the length of the report, up to a maximum of 10 pages.
It is often useful to print the executive summary on paper of a
different color (South Africa Department of Environment Affairs
1992)
• The decisionmaking process culminates in the preparation of a
concise public record of the decision. It should include:
— a statement of the decision;
— discussion of the alternatives considered in reaching a
decision, including identification of the environmentally
5-2
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preferable alternative or alternatives and any other relevant
factors that entered into the decision (e.g., economic and
technical considerations including, if appropriate, trade-offs
made in not selecting one of the preferred alternatives, as
well as agency statutory missions and national policy);
— a statement that all practical means to avoid or minimize
environmental harm from the selected alternative have been
adopted, and if not, why not; and
— a summary of the monitoring and enforcement program for
any mitigation measures.
TOOLS
Westman (1985) reviews the methods and limitations associated
with economic approaches to evaluating resources [e.g., cost-
benefit analysis, hypothetical valuation (willingness-to-pay
surveys)]. He notes that although monetary units have a familiar
meaning to decisionmakers and the public, they are almost
impossible to apply in a universally acceptable way to resources
that are not typically marketed (e.g., human life, bacteria, wind).
Nevertheless, the need for evaluation is inescapable and in the
absence of explicit evaluations, implicit evaluations are performed
by decisionmakers. Thus, it is important to remind decision-
makers of the assumptions and limitations of the evaluation
methods being used (Westman 1985). The use of sensitivity
analysis (see below), and of several different evaluation methods
simultaneously, can help to reveal the assumptions and limitations
of an analysis (Westman 1985).
— Cost-benefit analysis (CBA) among alternatives of projects
is widely used in decisionmaking to determine if the
economic benefits of development exceed the costs. The
costs and benefits considered include not only the
expenditures and revenues of public sector entities but also
benefits and costs experienced by private businesses and
individuals. It may go beyond consideration of direct
economic issues and also assess indirect effects and
"intangibles" (e.g., aesthetics) but is seldom addresses
"externalities" (e.g., media that act as pollutant sinks such
as atmosphere or watercourses). Thus, although CBA may
be important in decisionmaking it excludes most
environmental costs.
5-3
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— Cost-effectiveness analysis focuses on the cost of providing,
selected services, or more broadly, of achieving selected
objectives. This technique emphasizes determining the
least cost approach to achieving a given objective and
- typically considers a range of alternative actions within the
constraint of a fixed level of resources (Leistritz and
Murdock 1981).
— Results of public opinion polls show that individuals are
deeply concerned about the environment and that people in
both rich and poor nations give priority to environmental
protection over economic growth (Dunlap et al. 1992). At
present, however, scientific dispute and incomplete
knowledge limit our ability to balance scientific, social and
economic factors in decisionmaking. Nevertheless, there
is increasing interest in developing environmental indicators
that translate environmental data into a form that can be
readily understood and used by decisionmakers and the
public (Environment Canada 1991). Efforts have been
made to weight individual (expert-selected) environmental
indicators into composite environmental indices using
expert opinions (Inhaber 1976). More recently, an effort
has been made to use public opinion polls to weight
environmental aggregate indices (Alberti and Parker 1991).
To date, monitoring the status of environmental resources
has increased the volume of environmental data but has
failed to provide decisionmakers and the public with
specific answers to critical questions concerning actual
conditions, trends, and the causes of environmental damage
(Alberti and Parker 1991).
Trade-off analysis typically involves comparison of a set of
alternatives relative to a series of decision factors (Table 5-1).
5-4
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Table 5-1. Trade-off Matrix. (Source: Canter, L..W., S. F. Atkinson, and
F. L. Leistritz. 1985. Impact of Growth. Lewis Publishers, Inc.,
Chelsea, Michigan.)
Alternatives
Decision Factors 12345
Degree to Meeting
Needi and Objective*
Economic Efficiency
Social Concerns
(public preference)
Environmental Impact*
-Biophysical
-Cultural
—Socio-economic
(include health)
The following approaches can be used to complete the trade-off matrix (Canter
et al. 1985):
— qualitative approach in which descriptive information on
each alternative relative to each decision factor is presented
in the matrix;
— quantitative approach in which quantitative information on
each alternative relative to each decision factor is displayed
in the matrix;
— ranking, rating, or scaling approach in which the qualitative
or quantitative information on each alternative is
summarized via the assignment of a rank, or rating, or
scale value relative to each decision factor (the rank, or
rating, or scale value is presented in the matrix);
— weighing approach in which the importance weight of each
decision factor relative to each other decision factor is
considered, with the resultant discussion of the information
on each alternative (qualitative; quantitative; or ranking,
rating or scaling) being presented in view of the relative
importance of the decision factors; and
— weighing-ranking/rating/scaling approach in which the
importance weight for each decision factor is multiplied by
5-5
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the ranking/rating/scale of each alternative, then thei
resulting products for each alternative are summed to
develop an overall composite index or score for each
alternative.
Importance weighing and ranking techniques are described by
Canter et al. (1985). Description and references for the
weighing-scaling/rating/ranking approach are found in Canter
(1979). The problems associated with the development and use of
environmental indicators are discussed by Alberti and Parker
(1991; see Attachment S.A).
Scaling-weighing or ranking-weighing checklist methodologies
(Canter et al. 1985; Chapter 4.3) involve the assignment of
importance weights to environmental factors and the scaling or
ranking of the impacts for each alternative on each factor.
Comparisons of alternatives can be made through the development
of a product matrix which consists of multiplying importance
weights by the scale or rank for each alternative. Canter et al.
(1985) note that information for these approaches can be based on
impact prediction. They list some structured importance weighing
or ranking techniques as well as suggesting that less-formal
approaches such as scoping can be used as the basis for importance „
weighing.
Sensitivity analysis is a technique that identifies the parameter or
variable of a model that is most sensitive to change. It also
provides a measure of the sensitivity of the important variables to
changes in the parameters. For instance, if the endpoint of the
analysis is to predict the effects of herbicide application on insects,
then varying the kind or amounts of herbicides should be reflected
in the response(s) of the insect(s) of interest. Because there is so
much uncertainty associated with prediction in EA (e.g.,
assumptions underlying models, correctness of input data,
significance of results), examination of the sensitivity of a result
to differing assumptions on ranking and weighing within a
methodology helps modelers and decisionmakers understand how
changes to the input of an analysis affect the predicted impacts of
a proposed action (J6rgensen 1991).
ISSUES
In the U.S., there is a minimum 30-day period between publication
of a final EA document and publication of the agency decision on
5-6
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the proposed action. Thus, the public has an additional
opportunity to review the final EA document to make their views
blown and to take appeals on the forthcoming decision. However,
because the public has had ample opportunity to influence
decisionmaking during scoping, review of the draft document, and
any associated public hearings, the courts do not look favorably on
appeals at this point in the EA process.
• Even after the most thorough EA, the decisionmaker is still faced
with uncertainties about the future, about stochastic events, and
about uncertainties underlying the EA methods. All prediction
techniques, by their nature, involve some degree of uncertainty.
So along with each attempt to quantify an impact, the EA team
should also quantify the uncertainty of the prediction in terms of
probabilities or "margins of error". Factors contributing to
uncertainty are:
— limits on resources for planning and analysis,
— lack of evidence that a system is sensitive/insensitive to
uncertain input,
— inadequate training/understanding of probability and
statistics,
— concern about public acknowledgment of uncertainty, and
— lack of understanding of the importance/consequences of
uncertainty in decisionmaking.
• Decisions are not made solely on the basis of environmental
consequences. There are interagency agreements, regulatory
constraints, and political realities that must be considered when
selecting a course of action. Moreover, the decisionmaker must
take into account not only the facts, but also people's perceptions.
Once a decision is reached, perhaps with mitigation measures,
there are usually additional responsibilities. These may include
preparation and oversight of plans to reduce conflict (e.g., public
participation in planning, public education, compensation for
affected groups) and to provide for mitigation and monitoring
(Attachment 6.A).
• The scope of decisionmaking often is constrained by the nature of
the proposal. For instance, there are proposals with:
— no analysis of alternatives (e.g., legislatively directed
decisions in the "how-to-do" context),
5-7
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— limited analysis of alternatives (e.g., the mandated closure
of military bases under the Defense Base Closure and
Realignment Act of 1990), and
— analysis of multiple alternatives where the decisionmaker is
faced with sophisticated EA methods.
LINKAGES
Effective decisionmaking depends on integration of all of the elements of
EA. During initiation and scoping, issues are raised, alternatives are generated,
and valued resources are identified; public perception of the proposed action and
the potential for controversy are usually detected during these early stages. The
assessment process, beginning with description of the affected environment and
culminating with documentation, provides the decisionmaker with answers to the
following questions:
— what will happen as a result of the project?
— what will be the extent of the changes?
— do the changes matter?
— what can be done about them?
Mitigation is designed to address the last question and although most agencies do
not have requirements for follow-up studies, there is a growing interest in post-
decision analysis.
REFERENCES
Alberti, M., and J. D. Parker. 1991. Indices of environmental quality: the
search for credible measures. Environmental Impact Assessment Review
11:95-101.
Canter, L. W., S. F. Atkinson, and F. L. Leistritz. 1985. Impact of Growth.
Lewis Publishers Inc., Chelsea, Michigan.
Canter, L. W. 1979. Water Resources Assessment - Methodology and
Technology Sourcebook. Ann Arbor Science, Ann Arbor, Michigan.
Dunlap, R. E., G. H. Ballup, Jr., and A. M. Gallup. 1992. The Health of the
Planet Survey. The George H. Gallup International Institute, Princeton,
New Jersey.
Environment Canada. 1991. A Report on Canada's Progress Towards a
National Set of Environmental Indicators. SOE Report Number 91-1.
Environment Canada, Ottawa.
5-8
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Inhaber, H. 1976. Environmental Indices. Wiley Interscience, New York.
Jtfrgensen, S. E. 1991. Environmental management modeling. In: Introduction
to Environmental Management (eds. P. E. Hansen and S. E. Jdrgensen).
Elsevier, New York. 403 pp.
Leistritz, F. L., and S. H. Murdock. 1981. The Socioeconomic Impact of
Resource Development: Methods for Assessment. Westview Press,
Boulder, Colorado. 286 pp.
South Africa Department of Environment Affairs. 1992. Guidelines for Report
Requirements. Department of Environment Affairs, Private Bag X447,
Pretoria 001, Republic of South Africa. (One of six documents in The
Integrated Environmental Management Guideline Series that are available
on request).
5-9
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5-10
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ATTACHMENT 5.A
INDICES OF ENVIRONMENTAL QUALITY
Alberti, M, and J. D. Parker. 1991. Indices of environmental quality, the search for
credible measures. Environmental Impact Assessment Review 11:95-101.
5.A-1
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5.A-2
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ENVIRON IMPACT ASSESS REV 1991:11:95-101 95
VIEWPOINT
INDICES OF ENVIRONMENTAL QUALITY
THE SEARCH FOR CREDIBLE MEASURES
MARINA ALBERTI*
Massachusetts Institute of Technology
JONATHAN D. PARKER**
University of Cambridge
Informed choices about environmental policy require increasing our capacity to
monitor changes in the status of environmental quality. For example, monitoring
concentrations of toxic substances in the atmosphere, water, soil, and food chain
is crucial in order to prevent adverse health effects. Monitoring alterations in
the productivity and biodiversity of various ecosystems is essential 'to the antic-
ipation of problems before they reach critical proportions. Moreover, measuring
changes in environmental quality over time gives policymakers a basis for as-
sessing the effectiveness of environmental policies.
However, monitoring environmental change is much more difficult than most
people think. Environmental changes are difficult to interpret without • clear
understanding of how environmental systems work. There are sharp disagree-
ments among scientists and policymakers concerning the best measures and
methods for measuring changes in environmental quality. In this Viewpoint
article, we argue that the measures and methods used to monitor the status of
the environment play an important role in framing environmental problems and
in shaping the way we think about possible solutions. We suggest that the success
Udnu eamtpendatet »: M*rin» Afcetti. 9-534D. M.I.T.. Cunbridjc. fei.., „_.
•Mirim Afceri h i ft.D. ondidite * (be Deptrtme* of Uib» Stadta mi KMM^ of UK
iDiuUite of Technology, Cmbndfc* M
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-------
96
MARINA ALBERT! AND JONATHAN D. PARKE*
of environmental monitoring activities and their impact on policy-making depend
above all on our ability to handle disagreement among experts.
The Need for Environmental Indicators
Attempts to monitor the status of environmental resources have increased the
volume of environmental information available. However, they have failed to
provide decision makers and the public with specific answers to critical questions
concerning actual conditions, trends, and the causes of environmental damage.
First, environmental monitoring systems are designed to meet specific regulatory
purposes. They reflect the often fragmented approach of the regulations them-
selves. Secondly, monitoring data gathered by different agencies in different
periods using different methods are not comparable over time. Moreover, raw
data are often too complex to relate to poor or good conditions. Likewise,
fluctuations in physical, biological, and chemical variables are very difficult to
correlate to environmental trends.
To enhance their ability to monitor environmental change, national and in-
ternational organizations have recently specified sets of indicators. At the 1989
economic summit in Paris, the Group of Seven requested that the Organization
for Economic Cooperation and Development (OECD), within the context of its
work on integrating environment and economic decision making, examine how
selected environmental indicators could be developed (OECD 1989).
Several OECD countries have allocated substantial economic resources to set
up environmental monitoring systems and to produce national environmental
statistics. Currently, the Office of Research and Development of the U.S. En-
vironmental Protection Agency (EPA) is developing a monitoring system to
assess and document the changing condition of national ecological resources
(US EPA 1990a). The Canadian federal government is currently developing a
computerized environmental information system for specifying national and large-
scale regional environmental indicators. Several European countries, such as
France, the Netherlands, the Federal Republic of Germany, Denmark, and the
United Kingdom, who already produce regular reports on the state of the en-
vironment, have recently tried to upgrade existing environmental statistics. As
part of Scandinavian environmental cooperation among Denmark, Finland, Ice-
land, Norway, and Sweden the Integrated Monitoring Programme was begun in
Finland in 1985.
Currently, the OECD is developing environmental indicators in three specific
areas: 1) indicators for reporting on environmental conditions and trends, 2)
indicators for integrating environmental considerations into sectoral decision-
making, and 3) indicators for incorporating natural resources into overall eco-
nomic accounts. These indicators will be used to monitor the state of the en-
vironment and its evolution over time; evaluate the performance of projects,
plans; and communicate with the public and among decision
1991a, 1991b).
M«U4*
QUAUTY
97
Measuring Environmental Quality
The status of environmental resources can best be described through using phys-
ical, chemical, or biological variables. These variables in turn are used to con-
struct indicators of environmental change of various kinds. Indicators of air
quality, for example, are measures of the concentrations of air pollutants. In-
dicators of surface water quality consolidate changes in several variables such
as pH, dissolved oxygen, suspended solids, etc. The process of designing indices
of environmental quality implies simplification and the use of subjective judg-
ment.
Detecting variations in these indicators at local, regional, and national levels
is relatively simple. However, the choice of variables, the construction of in-
dicators, and the selection of measurement methods are critical. While some
environmental phenomena are relatively well understood, others are still unclear.
Incomplete and inadequate choice concerning indicators and measurement meth-
ods can lead to wrong interpretations.
The definition of environmental "indicators" and "indices" was taken up in a
exchange of views between Wayne Ott and Herbert Inhaber (Ott and Inhaber
1979) in the 1970s. Inhaber states, "Environmental indicators provide infor-
mation about the state of the environment, not obtainable in other ways" (Inhaber
1976). In his view the development of an environmental index is aimed at
reducing a large amount of unrelated data to a single measure. He defines an
index as "the comparison of a quantity to a scientific or arbitrary standards"
(Inhaber 1976). Ott prefers to define an indicator as a mathematical function
based on one pollutant variable (for example, the sulfur dioxide concentration)
and an index as a mathematical function based on two or more pollutant variables
(Ott 1978).
The EPA Environmental Monitoring and Assessment Program (EMAP) (see
US EPA 1990a) defines an environmental indicator as "a characteristic of the
environment that, when measured, quantifies the magnitude of stress, habitat
characteristics, degree of exposure to the stressor, or degree of ecological re-
sponse to the exposure" (US EPA 1990b). The EPA defines an environmental
index as a mathematical aggregation of indicators or metrics. One example is
the Index of Biotic Integrity (IBI), which combines several metrics describing
fish community structure, incidence of pathology, population sizes, and other
characteristics" (US EPA 1990b), proposed by the EPA to assess the quality of
streams.
Scientific Controversies
Environmental indicators and indices are essential to the development -of envi-
ronmental statistics. Yet, the task is not straightforward. Disagreement persists
among experts concerning appropriate definitions. Controversies exvtouthin and
across different disciplines. Ecologists express the conditions of
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98
MARINA ALBERTI AND JONATHAN O. PARKER
resources in terms of ecological integrity and assess them on the basis of observed
changes in ecological attributes. Experts disagree on the definition of ecological
integrity and on the characterization of critical conditions.
The basic controversy between advocates and opponents of environmental
indices concerns the distortion that can occur in the simplification process implied
by aggregating environmental variables into one single value. Advocates of
environmental indices maintain mat, while imperfect, measures of environmental
quality are useful tools and that some distortion is acceptable. The opponents
reject these possible distortions and warn about misleading the users of these
measures.
The EPA Environmental Monitoring and Assessment Program
The environmental indicators used in the EMAP are being developed for six
ecological resources categories: near-coastal waters, inland surface waters, wet-
lands, forests, arid lands, and agroecosystems. The EMAP strategy identifies
three main categories of indicators: 1) response indicators, 2) exposure or habitat
indicators, and 3) stressor indicators (US EPA 1990a).
Response indicators are characteristics of the environment measured to provide
evidence of the overall biological conditions of resources. They quantify the
response of ecosystems to anthropogenic stress by measuring organisms, pop-
ulations, communities, and ecosystems processes. For example, one response
indicator for arid land is soil erosion; for inland surface water an important
indicator is the Fish Index of Biotic Integrity.
Exposure or habitat indicators may be used to diagnose and measure ecosystem
exposure to pollutants and habitat degradation. Exposure indicators are measures
of the occurrence or magnitude of ecosystems exposure to physical, chemical,
and biological stress (i.e., ambient pollutant concentration). Habitat indicators
are physical attributes that characterize conditions necessary to support an or-
ganism, population, or community (i.e., abundance and density of key physical
features).
Stressor indicators measure socioeconomic, demographic, and natural pro-
cesses which cause changes in exposure and habitat conditions and are indicative
of environmental stress. They include hazard indicators (e.g., emissions of air
pollutants), management indicators (e.g., incidence of dredging and filling ac-
tivities), and natural process indicators (e.g., natural climatic fluctuations).
EMAP indicators are designed to answer critical questions such as: 1) What
is the current status, extent, and geographic distribution of our ecological re-
sources? 2) What proportions of these resources are degrading or improving,
where, and at what rate? 3) What are the likely causes of adverse effects? and
4) Are adversely affected ecosystems responding as expected to control and
mitigation programs (US EPA 1990b)7
INDICES OF ENVIRONMENTAL QUALITY
99
The EPA strategy of selecting indicators that will help to answer these specific
questions does not address the problem of subjective judgment. The review
process for selecting indicators includes several steps by which a large number
of experts will evaluate expected and actual performance of proposed indicators
and will specify those that match selected desirable criteria. How controversies
will be solved is not clear.
The EPA's Office of Research and Development claims that EMAP scientists
"will answer these questions by defining and implementing over the next five
years integrated monitoring networks ..." (US EPA 1990b). The EPA insists
also that "EMAP networks will use a statistically based sampling design to
provide unbiased estimates with quantifiable confidence limits over regional and
national scales for periods of years and decades" (US EPA 1990b).
Although the EPA approach is extremely well structured and responds to
accepted statistical principles, it does not address the critical question of how
best to resolve the scientific and political controversies involved in the choice
of indicators. We argue that there is no universal method for determining changes
in environmental quality, likely causes of adverse effects, or satisfactory re-
sponses. Environmental quality is a mixture of both tangibles (such as the con-
centration levels of chemical substances in the atmosphere) and intangibles (such
as an acceptable level of air quality for the exposed population and the envi-
ronment). Conflicts will continue to exist.
The Search for Credible Measures
The intended purposes of measuring environmental changes is to inform policy-
making. Therefore, a measure of its success is the impact of monitoring activities
on designing and adjusting environmental policies at the national, regional, and
local levels to meet new environmental emergencies and priorities.
Compared with economic and social indicators, environmental indicators have
little direct impact on environmental policy and even less impact on sectoral or
economic policies. Economic statistics are well developed worldwide. While the
development of economic indicators has been characterized by enormous con-
troversies, several economic indices such as Gross National Product (GNP) and
the price indices are recognized worldwide as measures of economic wealth.
These two economic indices are generally used as the basis for economic policy-
making.
Some important insights into the present debate on environmental indicators
may be gained by examining the controversial history of social indicators. While
social indicators now significantly influence social and economic policies, the
development of these indices was characterized by great controversies concerning
cause-and-effect relationships. A similar pattern of controversy can be observed
in the attempts to define indicators of environmental quality, particularly quality-
of-life indices (Carley 1981). Beesley and Russwurm contend that "social in-
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100
MARINA ALBERT! AND JONATHAN D. PARKER
dicators are embedded within a political and value judgment reality which may
pose problems in their design and use" (Beesley and Russwurm 1990). Also, it
is not always possible to establish relationships between the objective social
indicators and the social concepts that they are supposed to measure. This has
provoked considerable interest in searching for subjective social indicators which
might be particularly useful in highlighting social concerns and problems (Bees-
ley and Russwurm 1990). However, these attempts lack the "official" seal of
approval that objective indicators carry (Carley 1981).
Similar concerns emerge regarding the attempts to incorporate subjective judg-
ment in the development of aggregate environmental indices. Efforts have been
made to weight individual (expert-selected) environmental indicators into com-
posite environmental indices using expert opinions. These include the work of
Inhaber for Canada (Inhaber 1976) and those applying the Delphi technique.
Some current work uses public opinion polls to weight environmental indicators
in forming aggregate indices such as Hope, Parker, and Peake have done for
the United Kingdom (Hope and Parker 1990; Hope, Parker, and Peake 1990).
These approaches underscore the important role of social considerations in de-
veloping such measures.
Conclusions
Indicators of environmental quality will not influence the policy-making process
unless there is agreement on the choice and the design of such measures. As
Judith Innes has suggested for social indicators, "the intended purpose of de-
veloping measurements to be used in the policy-making process has to play a
role in the process of designing them" (Innes 1975). In her analysis of social
indicators and public policy she maintains that the things we measure and the
way we measure them contribute to the formation of norms and goals.
We suggest that measurement is an integral part of the process of identifying
problems as well as of searching for solutions. Our increased capacity to collect,
analyze, and manage information will not have an impact on policy-making
unless we are more careful about the information we select. Scientific disputes
and incomplete knowledge have serious implications for policy decisions. Fur-
thermore, the serious social implications of irreversible environmental changes
underscore the responsibility of the scientific community to take part in the
policy-making process. Designing appropriate measures to monitor environ-
mental problems requires the ability to balance scientific, social, and political
considerations in the process of designing and applying these measures. This
process will inevitably reflect tradeoffs between political and social actors. Ef-
fective and comprehensive policy making requires increased sophistication in
assessing conflicts between scientific experts.
INDICES OF ENVIRONMENTAL QUALITY
101
References
Alberti. M. 1990. Environmental indices. Ambiente Italia. Milan: Mondadori.
Beesley, K.B., and Russwurm. L.H. 1990. Social indicators and quality of life research:
Toward synthesis. Environments 20(1): 22-39.
Carley, M. 1981. Social Measurements and Social Indicators. London: Allen & Unwin.
Commission of the European Communities (CEC). 1990. Council Directive, 7 June 1990
on the freedom of access to information on the environment. Official Journal of the
European Communities No. L 158/56-58, 23-6-1990.
Innes J. 1975. Social Indicators and Public Policy. New York: Elsevier.
Hope, C.W., Parker, J.D.E. 1990. Environmental information for all-the need for a
Monthly Index. Energy Policy 18(4):312-319 (May 1990).
Hope, C.W., Parker. J.D.E., and Peake, S. 1990. A pilot index for the United Kingdom.
Management Studies Research Paper, University of Cambridge. 10/90.
Inhaber, H. 1976. Environmental Indices. New York: Wiley Interscience.
Organization for Economic Cooperation and Development (OECD). 1989. Summary
Conclusions of die OECD Workshop on Environmental Indicators. Dec 4-5. Paris:
OECD.
Organization for Economic Cooperation and Development (OECD). 1991a. The State of
the Environment. Paris.
Organization for Economic Cooperation and Development (OECD). 1991b. Environ-
mental Indicators—a preliminary set. Paris.
Ott, W. 1979. Environmental Indices: Theory and Practice. Ann Arbor, MI: Ann Arbor
Science Publishers.
Ott, W., Inhaber, H. 1979. Discussion on Canadian Air Quality. Atmospheric Environ-
ment 2:428-429.
U.S. Environmental Protection Agency (US EPA) 1990a. Environmental Monitoring and
Assessment Program. Office of Modeling, Monitoring Systems and Quality Assurance.
Washington DC: EPA.
U.S. Environmental Protection Agency (US EPA) 1990. Ecological Indicators for the
Environmental Monitoring and Assessment Program. Atmospheric Research and Ex-
posure Assessment Laboratory. Research Triangle Park, NC: EPA.
U.S. Environmental Protection Agency (US EPA) 1990c. International Symposium on
Ecological Indicators. Conference Proceedings, 15-19 October 1990. Fort Laudcrdale,
FL.
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CHAPTER 6
POST DECISION ANALYSIS
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CHAPTER 6
POST-DECISION ANALYSIS
Post-decision analyses (PDA) are environmental studies (i.e., data
collection and evaluation) undertaken during and following the implementation
phases of an activity after the decision to proceed has been made. They are also
known as follow-up studies and sometimes as environmental monitoring or audits.
There is no universally accepted set of principles defining an approach to PDA
(Davies and Sadler 1990). The analyses may be undertaken prior to construction,
during construction or operation, and at the time of abandonment to determine if
the project was carried out as planned in the EA documentation, to determine the
adequacy of impact prediction methods, to ensure accordance with regulatory
requirements and/or with terms imposed by EA documentation for mitigation or
monitoring, to modify mitigation measures if needed, to learn from the particular
activity, and to prevent irreversible environmental damage (United Nations 1990).
It is particularly important for activities that involve new technologies.
For purposes of this sourcebook, PDA is a generic term for a wide-range
of activities that can occur after a decision is made. The focus can be on
scientific, social and technical issues and also those dealing with procedural and
administrative matters. Related terms such as monitoring (Canter 1993) and
auditing (Culhane 1993) are narrower in concept. For instance, compliance
monitoring is designed to ensure that regulatory requirements are observed and
standards are met. Audits are independent and objective examinations of
compliance with legal requirements, internal policies and/or accepted practices.
However, the needs and tools discussed in this section are generally applicable
to any of these activities. Components within a broad definition of PDA include
as appropriate:
planning the collection of data to meet specific objectives
and environmental information needs;
designing monitoring systems and studies;
selecting sampling sites;
collecting and handling samples;
laboratory analysis;
reporting and storing the data;
assuring the quality of the data; and
analyzing, interpreting, and making the data available for
subsequent decisionmaking.
6-1
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NEEDS
• The purpose of PDA must be carefully defined and the planning
for PDA must be an integral part of the EA process. The focus of
PDA is usually on: issues of concern and valued resources for
which there is insufficient information; monitoring compliance
with regulatory requirements and agreed upon conditions; and
evaluating proper and cost-effective management. A decision on
a PDA plan should be made at the time that a decision is made
regarding the project.
• There must be a commitment to the PDA program at all levels of
management, including adequate financial support. Roles and
responsibilities must be defined for the proponent, other
government agencies, scientific and technical advisors, and the
public early in the EA planning process. Furthermore, provisions
must be made for:
— management responses to PDA findings, including how to
handle environmental surprises (i.e., unanticipated
impacts);
— revision of mitigation or monitoring if it is found to be
inadequate or unnecessary;
— ending the program if and when it is no longer needed.
• Independent design and implementation of the PDA program is
encouraged, particularly for those areas of the program that are
sensitive and for which work done by the proponent may not be
regarded as credible by the public.
• Monitoring programs are expensive to plan and implement; thus
every effort should be made to coordinate with and utilize
routinely collected data from ongoing monitoring programs as
appropriate. Various government agencies and the private sector
collect data which once identified can be aggregated and
interpreted relative to the particular area of interest (Attachment
4.A). There probably never is enough information collected to
thoroughly test PDA hypotheses. Therefore, it is usually
necessary for professionals to extrapolate from monitoring data to
arrive at an "educated best-guess".
• Periodic evaluation of PDA data and preparation of an annual
report for distribution to interested and affected publics.
6-2
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• A review of 11 case studies (United Nations 1990) showed four
important needs for PDA. These include:
development during EA planning of verifiable hypotheses
for testing during PDA;
collection of relevant baseline data for interpretation of
subsequent monitoring data and testing of impact prediction
hypotheses;
careful documentation throughout projects to lessen effects
of personnel turnover; and
use of appropriate statistical methods to test hypotheses so
that effects of projects can be satisfactorily isolated from
other environmental effects.
TOOLS
Monitoring (i.e., the systematic collection of data through a series of
repetitive measures) is usually an essential component of PDA. The
detailed means of monitoring and the issues monitored will vary greatly
depending on the proposed activity (ORNL 1978; U.S. EPA 1989; ASTM
1992; ANSI 1982; Canter 1993). In general, methods for assessing
adverse effects in freshwater systems are well developed while methods
for assessing adverse effects in terrestrial systems are less well developed.
Most PDA incorporates one or more of the following categories of
monitoring:
Compliance Monitoring. Periodic sampling and/or continuous
measurement of levels of waste discharge, emissions or
introductions to determine that regulatory conditions and/or
standards of good practice are met.
Effects Monitoring. Measurement of environmental parameters
during construction and/or operation to detect changes in the
parameters which can be attributed to the project or to test
predictions of an EA and/or the effectiveness of mitigation
measures.
Internal Audits. A methodological examination (sometimes
involving analyses and tests) and confirmation of local procedures
and practices leading to verification of compliance with legal
requirements, internal policies, and/or accepted practices.
Inspection and Surveillance. Depending upon the purpose of
PDA or where data are absent or inadequate, the analysis can be
6-3
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based on less quantitative methods such as inspection and
surveillance to determine adherence to environmental operating
conditions (e.g., road or pipeline construction).
Negotiation is currently seen as a promising tool in the design of
monitoring programs, particularly for resource development activities. It
creates a forum where affected interests can deal directly with
disagreements over what should be monitored and how those things should
be assessed and dealt with. Rolf (Attachment 6. A) notes three particularly
important factors with respect to negotiating a monitoring program:
symmetry of power and resources, a multiple issue agenda, and a
mechanism for resolving disputes. She argues that a negotiated
monitoring program leads to better decisions, fairness, and better
implementation.
ISSUES
• Space and time coordination of data collection is necessary to
eliminate variation in analytical results associated with differences
in geographical regions and changes in biota and pollutants over
time.
• Although in the U.S., CEQ regulations require federal agencies to
monitor the effects of proposed mitigation measures in "important
cases" and to report on the progress of such mitigation measures
to other agencies and the public on request, in practice, this
provision has not been enforced. Currently, except for The
Netherlands, there is a lack of formal PDA in most countries. As
a result, there is little opportunity to learn from and apply the
experience to subsequent activity. Sadler (1988) notes that the
lack of PDA stems from jurisdictional fragmentation (in Canada),
ambiguous mandates, and insufficient resources.
In cases where PDAs were done, Bisset and Tomlinson (1988)
note that only 12 percent of all predictions could be audited; of the
predictions tested about half were inaccurate. There was a
tendency for the inaccurate predictions to indicate impacts which
subsequently did not occur. They found that the nature of EA
documents makes it difficult to audit the predicted impacts of a
development for these reasons:
predictions are expressed in vague, imprecise language;
6-4
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impact predictions are not phased in a way that allows
auditing (e.g., design changes can eliminate the predicted
impact); and
monitoring programs often do not provide the data needed
to allow predictions to be tested in a scientifically
acceptable way.
• Bisset and Tomlinson (1988) suggest that decisionmakers do not
like to have their decisions questioned by subsequent
investigations. Thus, it is important that PDA is an integral part
of EA documentation with the stated goal of not questioning the
rationale of the decisionmaker but rather, of determining the
quality of the information in the EA document. Decisionmakers
need to be convinced that PDA will result in better information for
decisionmaking (i.e., less uncertainty), better EA at less cost, and
greater public confidence in the project.
• The PDA should focus on important issues and impacts for which
there are insufficient information. Identification of these issues
and impacts and their priorities occurs during the EA process and
a PDA plan, commensurate with their complexity and uncertainty,
should be prepared as an integral part of the EA process.
• PDA developed in response to public concerns must be credible,
and the proponent must be willing to respond even to unacceptable
results.
• Questions to consider in relation to EA and PDA might include:
were the important project-related impacts and mitigation
responses identified accurately in the EA?
did the EA process provide sound, relevant, and focused
information concerning project effects and their
implications?
were there clear levels of confidence and significance
placed on the predictions?
were the cumulative and secondary impacts traced
properly?
LINKAGES
For PDA to provide useful feedback for decisionmaking. it must be based
on issues identified during initiation and scoping. The assessment process must
result in testable hypotheses based on important issues. Mitigation and
6-5
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monitoring programs must be designed .to ensure that requisite data are available
for testing the hypothesis. Collection, evaluation, and publication of the results
of PDAs can contribute to reducing uncertainty in decisionmaking and
enhancement of agency credibility.
American National Standards Institute (ANSI). 1992. American National
Standard for Surveys of Terrestrial Ecology Needed to License Thermal
Power Plants. ANSI/ANS-18.5-1982. Published by the American
Nuclear Society, 555 North Kensington Avenue, LaGrange Park, Illinois
60525. 26pp.
American Society for Testing and Materials (ASTM). 1992. Annual Book of
ASTM Standards, Section II, Water and Environmental Technology.
Available from ASTM, 1916 Race Street, Philadelphia, PA 19103-1187.
1426pp.
Bisset, R., and P. Tomlinson. 1988. Monitoring and auditing of impacts. In:
Environmental Impact Assessment (ed. P. Wathem). Unwin Hyman,
Boston. 332pp.
Bisset, R. 1980. Problems and issues in the implementation of EA audits.
Environmental Impact Assessment Review 1:379-395.
Canter, L. W. 1993. The role of environmental monitoring in responsible
project management. The Environmental Professional 15:76-87.
Culhane, F. J. 1993. Post-EIS environmental auditing: a first step to making
rational environmental assessment a reality. The Environmental
Professional 15:66-75.
Davies, M., and B. Sadler. 1990. Post-project Analysis and the Improvement
of Guidelines for Environmental Monitoring and Audit. Report EPS
6/FA/l. Environment Canada, Ottawa, Ontario K1A OH3.
Graves, B. M., and P. L. Dittberner. 1986. Variables for Monitoring Aquatic
and Terrestrial Environments. U.S. Fish and Wildlife Service Biological
Report 86 (5). 55pp.
Marcus, L. G. 1979. A Methodology for Post-EIS (Environmental Impact
Statement) Monitoring. U.S. Department of the Interior, Geological
Survey Circular 782.
6-6
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Oak Ridge National Laboratory. 1978. Environmental Monitoring Handbook for
Coal Conversion Facilities. ORNL-5319 Special. Available from the
National Technical Information Service. U.S. Department of Commerce,
5285 Port Royal Road, Springfield, Virginia 22161.
Rolf, C. A. Negotiating a monitoring program. 1986. Impact Assessment
Bulletin 4:99-109.
Sadler, B. 1988. The evaluation of assessment: post-EIS research and process
development. In: Environmental Impact Assessment (ed. P. Wathern).
Unwin Hyman, Boston. 332 pp.
Sigal, L. L., and G. W. Suter n. 1987. Evaluation of methods for determining
adverse impacts of air pollution on terrestrial ecosystems. Environmental
Management 11:675-694.
United Nations Economic Commission for Europe. 1990. Post-Project Analysis
in Environmental Impact Assessment, ECE/ENVWA/11. 54 pp.
Available from the United Nations, Sales Section, New York.
U.S. Environmental Protection Agency. 1989. Ecological Assessment of
Hazardous Waste Sites: A Field and Laboratory Reference. EPA/600/3-
89/013.
6-7
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6-8
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ATTACHMENT 6.A
NEGOTIATING A MONITORING PROGRAM
• Rolf, C. A. Negotiating a monitoring program. 1986. Impact Assessment Bulletin
4:99-109.
6.A-1
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6.A-2
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Resource Impact Assessment
98
[40] Ucko, P.J., "Australian Academic Archaeology: Aboriginal Trans-
formation of Its Aims and Practices." Australian Archaeology, 1983,
10:11-38.
(41) Wells, Katie, John Tallow, Esther Tailfeathen and Gerald Conaty,
"Archaeological Research on the Blood Reserve. Alberta Archaeological
Review No. 9:3-16, 1984.
(42) Wildesen, Leslie E., "The Study of Impacts on Archaeological Sites.'
In Advances in Method and Archaeological Theory, volume 5. Michael
B. Schiffer (ed), pp. 59-96. Academic Press, New York, 1982.
(43) Winter, Joseph C., "Indian Heritage Preservation and Archaeolo-
gists." Am. Ant. 45:121-131, 1980.
Interlibraiy Loan
Photocopy
"•""'• Retention
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NEGOTIATING A MONITORING PROGRAM
Carol Anne RolP
INTRODUCTION
In February 1981, Western Fuels-Utah Inc. filed an application to de-
velop a 1.4 million tons per year coal mine in Rio Blanco County, Colorado
in order to supply a 400 megawatt power plant 33 miles away in Bonania,
Utah.1 Rio Blanco County was primarily an agriculture-based economy
with oil shale potential and a fairly sparse population of about 3,200 peo-
ple who would experience the most direct impacts of mine construction
and operation.
As is true with many instances of large scale resource projects, resi-
dents and local government officials recognised the potential benefits of
development, but they were concerned that negative impacts would im-
pose unacceptable burdens and disruptions upon both the existing and
project-related population. There was particular concern that locating
the power plant across the state line denied Rio Blanco County access to
tax revenues which would offset the increased costs of providing hard and
soft public services.3
In June 1981, Western Fuels-Utah and nine special districts in Rio
Blanco County signed a comprehensive socioeconomie impact mitigation
agreement worth $15 million in front end payments. Unlike many other
mitigation and compensation agreements, it included provisions to de-
•Graduate School of Public Policy, UC - Berkeley, Vancouver, B.C. V6S 1B9
'This case as well as other cases of American experience is analysed In Rolf, C.A.
Mandatory Negotiation: A Meant to Dttirmine Mitigation and Compentation in Me Contest
of Erwiyy Dtttlopmtnt. University of California, Berkeley: unpublished master's
thesis.
'interview: Mark Bubrlski, County Impact Coordinator, Rio Blanco County,
Colorado.
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Negotiating a Monitoring Program
100
velop and implement a monitoring program. The details of this program
were subsequently renegotiated over an 11 month period in 1983.3
This paper is about negotiating monitoring programs, which aspects
of the Colorado experience might be transferable to places such as the
Beaufort Region in the NWT, and the kinds of issues which must be
considered if a negotiation policy were adopted.
REASONS FOR NEGOTIATION
The value of impact monitoring is not in dispute. At the conceptual
level at least, there is considerable consensus as to why monitoring is
generally a good idea. Unfortunately, if not unexpectedly, monitoring
practices to date appear to fall rather short of their theoretical promise.
Whatever factors may contribute to this shortfall, it is clear from experi-
ence that no one monitoring model exists which can be universally applied
to resource development.4 In other words each monitoring program must
be tailor-made to suit its particular requirements and circumstances. In
this light, the problem of designing and implementing a monitoring model
may be recast as a problem of process: how should we go about the design-
ing and implementing? One answer to this question is to use negotiation.
Negotiation is a particularly apt tailoring process if the problem if
represented as a game. More specifically, it is not the kind of game where
winners are possible only when others lose: a sero-snm game. It is, in-
stead, a game where there are common interests as well as value conflict.6
. 'Interview: Reid Haughey, County Impact Coordinator, Rio Blanco County,
Colorado.
4See for example, Bankes, N. it Thompson, A.R. Monitoring for Impact Aiteiiment and
Management: An Anaiyiii of the Legal and Adminittratne framework, University of British
Columbia: Westwater Research Centre, 1980; Carley, M. Cumulative Socioeconomie
Monitoring: Inuei and Indieatori for Canada'i Beaufort Region. Prepared for Energy,
Mines and Resources Secretariat, G.N.W.T. and The Northern Economic Planning
Branch, Department of Indian Affairs and Northern Development, March 1984;
Veit, 3. Presentation to Workshop on Cumulative Socioeconomie Monitoring for th*
Beaufort Region. Sponsored by Energy Mines and Resource* Secretariat, G .N. W.T.,
June 11-12, 1084.
'Thomas Schelling calls this co-existence of vnlue conflict with common interests t
"mixed-motive game" and suggested that what would be rational strategic behavior
on the part of tho*e involved In a cero-ium gam* would be Irrational in the mixed-
motlv»See The Strategy of Conflict. Cambridge, Mass: Harvard University Press,
196
-------
Negn
Perhaps even more noteworthy, negotiation fosters the capacity to
adapt to changing conditions. In Colorado, for example, the company and
the county initially negotiated the development of a monitoring program
and were then able to re-negotiate the terms of that program as changes
became necessary.11
This advantage may be attributed to the fact that negotiation involves
an agreement between parties not to reach a solution in terms of rules but
to create the rules by which they can organize their relationship to one
another. 13 In other words, a monitoring program can be conceived as
a kind of relational contract where the parties create a structure through
which to address problems and make decisions over time.19 Not only does
this adaptability make sense in the real and uncertain world of resource
development, but the actual negotiation structure for making decisions is
considered to be economically efficient.14
2. Fairneas: Negotiating the design of a monitoring program may
enhance the equity of resource development. One reason is that helps
redress some of the powerlessness of affected communities (who do not
usually participate directly in the decision to develop the local resources)
by allowing direct participation in some of the decisions about the project.
A common form of public participation in resource development policy
is some version of the public hearing, and information gathered through
this essentially adversarial process may form the basis for designing a
monitoring program. Though this kind of input may have alleviated some
of the poverty of power at the local level, the participation role is not
'"Oiawa, C. it Suiiklnd, L. Mt&ating Seienae inttntiwt Paktic PeKeg Ditputti. Presented
to the Auociatlon for Public Policy Analytit and Management, New Orleans, Oc-
tober, 1984.
"Supra note 3.
"Gulliver (1073) riled In Nader. L. & Todd, H F. Jr., The Ditpvtinf Pnctu — Lam in
TVn Socittitt, New York: Columbia University Preit, 1978, p. 10.
"Williamson, O.B. Transaction-cost economic* the governance of contractual rela-
tion*. VuJowndc/lato anJEconomiei, 1979,22,233-201.
ulbld. Among other rea*on*, Williamson note* that negotiation creates relationships
that circumvent opportunism and al*o establish what he refer* to a* "communication
economics.*
C. A.
Rcflr
decision-making but one of information provision. The public hearing
process is generally absent in criteria for weighting different sources of
information and the built-in incentives are to persuade the deciders. As a
result, the information which is provided may represent those issues most
easily or powerfully argued, or most easily measured. These may not, and
are unlikely to be synonymous with what is of greatest concern in affected
communities.
Negotiation creates a forum where affected interests can deal directly
with disagreements over what should be monitored and how those things
should be assessed and dealt with. Although it comes with no guarantees
of authenticity or integrity, negotiation does provide an alternative avenue
of participation which may increase the level of representation in making
of decisions. In Wyoming, for example, where there is some experience
with community negotiated mitigation and compensation agreements, the
first stage in the negotiation is reported to be reaching a consensus on
projected impacts and their importance to various constituencies in the
community.16 This is particularly true with respect to impacts based on
population and demographic projections.
3. Better Implementation: Monitoring programs, like most poli-
cies, have suffered from intentional and unintentional implementation
problems.10 Negotiating the program may discourage intentional viola-
tion because participating in the design tends to increase the commitment •
of those responsible for implementation. That this is equally valuable for
energy companies and for communities is evidenced by the Western Fu-
els case where the company was initially worried that the county might
charge them for "cadillac servicing."IT
The flexibility and adaptive capacity created through negotiation con-
tributes to avoiding as well as detecting and correcting unintentional error.
The theory and so far relatively limited practice with negotiation in
this context suggest that negotiation promises to be an effective tool in the
design of monitoring programs. The degree to which it fulfills this promise
depends a great deal on how the negotiation process is structured. To this
"Supra note 1. Interview* with company and town negotiator*.
"See for example Banke* it Thompson and Thompson, Banke* It Souto-MaJor Supra
note 4.
"Supra not* 8.
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Negotiating a Monitoring Program
104
end, several issues and elements should be factored into the design of a
policy to negotiate an impact monitoring program.
DESIGN ELEMENTS
1. Negotiator Selection and Accountability: It is the interest!
which need to be represented in the negotiation rather than particular
constituencies." Nevertheless, there must be some way to get the right
people to the table and to make sure they are accountable to their con-
stituents. 'The right people* means that the negotiators are able to com-
mit their constituencies to supporting and implementing the monitoring
program, and that some mechanism for accountability exists which may
help assuage the problems of imperfect representation.
From the community point of view, the most appropriate way of choos-
ing negotiators and achieving accountability seems to be one tliat is com-
patible with the local political culture, and there are many variation*.
In the Western Fuels case, for example, three country commissioners and
the general manager negotiated on behalf of nine special districts and
the agreement was approved by those districts. And in Montana, when
the Northern Cheyenne successfully negotiated with the Montana Power
Company, the Tribal Council selected two negotiators (one a member of
the Council's Mineral Committee and one outside expert on energy re-
sources) and then ratified the final agreement.10
In Massachusetts and Connecticut, where hazardous waste siting leg-
islation provides statutory support for this kind of negotiation, a Local
Assessment Committee and a Local Project Review Committee respec-
tively are appointed to negotiate with project proponents.30 Town Coun-
cils do not have ratification power under these Acts but to ensure wider
accountability, the respective State Siting Councils must approve the fi-
"SuMkind, L.E., RichnHton, R.R. & HIMebranH, K.J. Retolving Environmental Db-
putet, MIT: Environmental Impact Attettment Project, 1078, p.26.
"Sullivan, T.J. The difflcultie* of mandatory negotiation (the Colitrip Power Plant
CMC) in L. SuMkind, L. Bacow, ti M. Wheeler (edt.) JhtoMn* £nmronmentof JhywV
toff Ditfndei, Cambridge, Mat*: Sehenkman Publishing Company, 1083, 56-85. Set
abo Supra note 1.
Wutt AcMy SHinf Att. PuWk Act fl-MO. Ch. 441 (ste h
16) and Mwtachutettt Hasardotw W»H« PacffHy IHb« Art, Ch. 101, ,
Act* 673, 111, >lc. (M« In particular • 1. 1. II)
105
C. A. Rolf
nal agreement.91 In Wyoming where the negotiation process is less for-
mally structured, the final agreements are usually approved by the Town
Council."
It should be noted, however, that peer pressure and the politics of
personality often found in small communities may threaten this kind of
accountability. In one case in Wyoming one leader of a group of dis-
affected citisens received threats to his life and business, and no local
attorney would agree to represent this group at public hearings." The
absence of dissent cannot be unambiguously equated with the legitimacy
of agreements, but presumably the more open the negotiation process,
the more accountable the results.
2. Negotiation Procedures: Of the multiple factors affecting the
•access of the actual negotiation process and the chances of reaching a
settlement,34 three seem particularly important with respect to negotiat-
ing a monitoring program: symmetry of power and resources, a multiple
issue agenda, and a mechanism for resolving disputes.
(a.) Power and Resource Symmetry: Symmetry is necessary to ensure
that negotiation is the "product of necessity*36 or in other words that
the alternative to negotiation, whatever that may be, is not a more at-
tractive option to one of the parties than negotiation. Problems of asym-
metry in this kind of negotiation are likely to lie in information, funding
and technical expertise, all of which may be in favour of senior govern-
ments and the energy companies unless deliberately designed otherwise.
The Northern Cheyenne in Montana have a Research Centre staffed by
planners and environmental scientists who conducted a study of coal de-
11 For one dltcuttlon of tome of the touet of wider accountability In the context of
environmental mediation (a related proeett) tee Suttklnd, L. & Osawa, C. Mediated
Negotiation In the Public Sector: Mediator Accountability and the Public Interest
Problem. Amtnatn 0«JUnomt Scitntui. 1083,17(2), 266-270.
"Supra note 1.
"Interview: Powder River Batln Retource Council, Douglat, Wyoming.
"See for example Cormick, G.W. The 'theory" and practice of environmental medi-
ation, Tin Enwitonmtntal Proftinonal, 1080, 2, 74-33; Sullivan, T.J. JbtoMnf Deed-'
orm**t Ditpvk» thrtmfH Ntfoiiatio*, New York: Plenum Prett, 1083; and Supra not*
I.
'tt|bJi tee Cormick.
-------
A
ting a Monitoring Program
velopment impacts.30 In Colorado, the county received a $200,000 loan
from the Governor's Office with which to hire legal assistance and two
university-based economists who reviewed Western Fuel's Environmen-
tal Impact Study.37 The Massachusetts and Connecticut legislation pro-
vides for Technical Assistance Grants of up to $15,000 but there is not
yet enough experience under these Acts to assess bow well this method
works.38
(b.) Multiple Issue Agenda: A narrow agenda may easily transform
the process into a cero-sum game because there is little opportunity for
reciprocal concessions, thus threatening the negotiation. Parties are un-
able to trade concessions in one issue for gains in another. A multiple
issue agenda makes bargaining more likely to be successful.30
After years of acrimony and an aborted attempt at negotiation, the
final success of the Northern Cheyenne and Montana Power negotiation!
is attributed partially to a broader agenda.90 And one of the strengths of
the Western Fuels Agreement is its "package program" nature instead of
a series of individual agreements between the company and various local
government entitites. In addition to broadening the agenda, this promotes
monitoring that is more likely to be comprehensive than fragmented.
(c.) Dispute Resolution Mechanism: This mechanism actually servei
dual purposes. One is to cope with the inevitable spectre of stalemate
and the other is to help to create some sense of urgency, or pressures
for decisiveness in the negotiations. Without this sense, negotiating the
monitoring program may be just another way of avoiding or delaying its
implementation. In the Western Fuels case, there were only five months
between the filing of applications and the expected construction start, and
the coal market had not softened yet. Rather than relying on idiosyncratic
circumstances or the world market, action-forcing deadlines may create
the same sense of urgency. In Massachusetts, for example, negotiation fa
statutorily required to be completed within 60 days (although up to two
30 day extensions may be granted).
a*8upra note 34 Sullivan.
aTSupra note >.
"Note in Connecticut, more money may be available if total project costs are ov«r
1500,000.
''Supra note 34 Sullivan.
$08upr» note M Sullivan.
C. A.
Another method would be for the parties to actually negotiate those
deadlines, an exercise which would also educate the negotiators by pro-
viding an opportunity to learn that agreement is possible.31 To parties
who have been locked in long-standing disputes, or where there is a his-
tory of mistrust, this can come as a surprising revelation. If the parties
were unsuccessful, one default option would be to resort to the dispute
resolution mechanism. This safeguards against such deadlines subverting
the process and forcing an illegitimate settlement.
The key variable to an effective dispute resolution mechanism is that
it not be more attractive than negotiation. A common provision is some
form of arbitration which trannfers the decision-making power to a third
party who has more or less authority to bind the parties to some decision.
Under the Massachusetts legislation, for example, stalemated parties have
the option of a three person arbitration panel (one person chosen from
each side and the third jointly selected) or one arbitrator jointly selected.
In the event that this too is stalemated, the State Siting Council will
iclect an arbitration panel. Veterans of this kind of negotiation report a
reluctance to transfer their authority and power; negotiating decisions, no
matter how difficult, is generally preferred to their external imposition.93
3. Enforcement Mechanism: In case of disputes or of intentional
violations during implementation, there must be some way of enforcing
the agreement. Some enforcement strength stems from the contract na-
ture of a negotiated agreement. Standard civil law remedies, or variations
thereof, might then be called upon.33
Substantial enforcement strength stems, however, from the ongoing
nature of monitoring and the possibility for re-negotiation. This ability
to deal with both intentional and unintentional problems with implemen-
tation contributes to the flexibility and legitimacy of the agreement and to
the continued evolution of the norms and rules governing the relationships
among the parties involved.
"Supra note 1.
M8upra note 1.
"For a diicuulon of possible rtmedit* and torn* of the Iftue* which mffht be Involved
M* Bankes it Thompson Supra note 4 and Barton, B.J., Fraiuon, R.T., tt Thomp-
son, A.R. A Contnct MoSdfa PcUutom Control. University of British Columbia:
Wtttwater Reitarch Centre, 1084.
-------
Negotiating a Monitoring Program
1M
In effect, this advantage requires a monitoring of monitoring and somt
way to resolve disputes, and the Western Fuels Agreement again provide!
an example. There, an Advisory Committee comprised of representative!
from each of the districts involved in the agreement and the coal and
power companies reviews the monitoring program and implementation of
the agreement. In an amendment to the initial agreement, the parties
agreed to bargain over disputes arising during implementation.34 Should
bargaining fail, and if the dispute originates with a local government entity
other than the County, the County resolves the issue with a final, binding
decision. (An aggrieved party may file a notice invoking arbitration withii
10 days). If the County is involved in the dispute, the problem goa
directly to arbitration.
As mentioned earlier, the Advisory Committee and this dispute reso-
lution mechanism have been tested. After problems arose with applyinf
fiscal formulae to calculate mitigation payments, the terms of the moni-
toring agreement were re-negotiated. Although the re-negotiation went 01
for nearly a year, neither side opted for arbitration; among other things,
a testimony to the alleged superiority of negotiation in making decision!
about monitoring.
CONCLUSION
Designing a monitoring program which is both meaningful to the peo-
ple affected by resource development and which will work is always going
to be a challenge. Negotiation, however provides one way to try and
meet that challenge which suits the nature of the game that is resource
development. Although it is a conflict solving process common to most
cultures, we know less about it works than we do about other procedure!
which involve third parties or the transfer of participant power.96. We
know even less about how it works in the making of policy decisions suck
as the design of a monitoring program.
From what we do know about negotiation, from what we know about
how it works in other contexts, and particularly from what we know about
how it works in the resource development context, it is possible to identify
some of the issues which needs be considered if one were to recommend
the negotiation of a monitoring program. We know enough to fabricate
»4W«itern Futlt Ajreement, Article XII.
. & Todd, H.F. Jr. Supra note 12
109
C. A. Rolf
at least a framework for this rather blunt policy instrument, the dynamic
nature of which may preclude precision even in the future. Neverthe-
less, more and more experience will allow more and more refinement and
growth.
As a maker of monitoring programs, negotiation may be imperfect. It
may be more craft than art or science. But given its superior ability to
weave decisions from uncertainty, complexity and conflict, and to weave
them with community power, it seems a worthwhile craft.
-------
PARTC
CASE STUDIES
-------
PARTC
CASE STUDIES
c-i
-------
C-2
-------
CASE STUDY OUTLINE
Case studies based on practical experience can provide useful lessons on
the institutional, procedural, and methodological elements of EA for proponents
of projects, preparers of EA documents, decisionmakers, and others involved in
the EA process. Users of the sourcebook (and others) are invited to submit case
studies that illustrate their experience with EA for inclusion in the sourcebook
particularly for policy and program level and regional and sub-regional EA.
To the degree possible, case studies should conform to the following
outline and be no longer than three pages. The area of interest should be
emphasized; other areas should be accounted for in very few words. Case studies
need not fit the outline in all respects in order to be useful. Please submit case
studies to Sourcebook for the EA Process, U.S. EPA Office of Federal Activities
(A-104), Washington, D.C. 20460.
Outline for Case Studies
The main elements of the study are summarized as follows:
Title:
Type of action:
Action characteristics:
Proponent:
Competent authority:
Main environmental impacts involved:
Decision/results
I. General Information on the Action
n. Planning Process (regulations, responsibility, screening, etc.)
m. Initiation of the EA Process (history of the process)
IV. Responsibility for Preparation of the EIA
V. Content of the EIA (may be table of contents)
VI. Description of the Proposed Action and Alternatives
vn. Selection Process for Alternatives
Vm. Description of the Existing Environment (what aspects were addressed?)
K. Scoping
X. Description of the Environmental Impacts of the Proposed Action,
Alternatives, and Assessment (comparison)
(a) Impact identification
(b) Methods used for predicting impacts
(c) Methods used for comparing the environmental effects of the
various alternatives
XI. Review and Public Participation
Decisionmaking
Monitoring
XTV. Time/Costs
C-3
-------
C-4
-------
LISTING OF CASE STUDIES
Case Study on the Application of EIA Methodologies to the
Phoenix Pulp Mill Project hi Thailand. (Source: Lohani, B.N.,
and N. Halum. 1987. Recommended methodologies for rapid
environmental impact assessment in developing countries:
experiences derived from case studies in Thailand. In:
Environmental Impact Assessment for Developing Countries (eds.
A.K. Biswas and Q. Geping). Tycooly International, London.
232 pp.)
C-5
-------
C-6
-------
ENVIRONMEN^felPACT ASSESSMENT FOR DEVELOPING COUNTRIES
CONCLU^N
The EIA is not only intended to identify impacts which will result from im-
plementation of a project, but is also an effective planning tool in environmental
management. The purpose of EIA is by no means to inhibit economic development.
In fact its aim is to enhance economic development. The EIA identifies potential
negatives which may on a long-term basis require substantial economic expenditure
for solutions. Environmental management plans should include impact studies for
prevention, minimization or mitigation of negative impacts, and enhancement of
positive impacts.
It may be understandable that developing countries may not have enough data,
manpower and budget to undertake elaborate impact studies. However, some of the
rapid identification techniques like the use of checklists and matrices in conjunction
with a set of established guidelines should be encouraged for wider cases, as they
could be of significance as a first step in identifying major impacts which have
detrimental impacts on the environment. Developing countries should also try to
draw up checklists and matrices as guidelines for examining development projects.
some countries such as Thailand having already accomplished such guidelines.
References
Canter, L. W., (1977). Environmental Impact Assessment. New York: McGraw-Hill.
Dee, N., et al.. (1979). Environmental Evaluation System for Water Resources Planning.
Columbus, Ohio: Battelle Columbus Laboratories
Evans, J. W., (1979). Environmental Impact Assessment in Thailand: An Environmental
Planning Tool. UNAPDI Regional Workshop on Area Development Planning and
Environment. Bangkok. August • .. '
Evans, J. W., (ed.), (1980). Proceedings and Report on In-House Workshop on Environmental
Impact Evaluation. Bangkok: National Environment Board
Evans, J. W., (1982). Rapid Techniques for Environmental Impact Assessment and their
Application in South-East Asian Countries. Inter-Country Workshop on Rapid Assessment
Techniques for Environmental Assessment in Developing Countries, sponsored by WHO/
SEARO in collaboration with the NEB and AIT. Bangkok
A Feasibility Study: 70.000MTIYR. Pulp Mill for Phoenix Pulp and Paper Company Limited
(1975). Bangkok
Moiling. C. A., (ed.), (1978). Adaptive Environmental Assessment and Management.
Chichester. UK: John Wiley
Hufschmidt. M., and Carpenter. R. A., (1980). Natural System Assessment and Benefit-Cost
Analysis for Economic Development. Hawaii: East-West Centre
Leopold. L. B.. et al.. (1971). A Procedure for Evaluating Environmental Impact. US
Geological Survey Circular 645. Washington, DC
Lohani, B. N., (1980). Environmental Impacts of Rural Transformation Activities and their
Assessment, in Singh. R. L. and Singh, P. B. (ed.). Rural Habitat Transformation in World
Frontiers. NGSI publication no. 30. ICRHS pub. 4 . .
Lohani, B. N.. and Arceivala. S. J.. (1982). Checklists and Matrices for Rapid Assessment of
Environmental Impacts. Inter-Country Workshop on Rapid Techniques for Enviromental
Assessment. AIT, Bangkok. January
92
METHODOLOGIES FOR RAPID EIA: CAS!
'IES IN THAILAND
Lohani. B. N.. and Kan. S. A.. (1982). Environmental Evaluation System f<>r Water Resources
Projects in Thailand: Water Supply and Management. Oxford. UK: Pcrgamon Press '
Lohani. B. N., and Thanh. N. C., (1980). Impacts of Rural Development and (heir Assessment
in Southeastern Asia. Environmental Conservation. 7 (3). Winter
Ludwig. H. F., (1982). Environmental Aspects of Multipurpose Reservoir Projects in
Developing Countries. Water Science Technology. 14, pp. 269-88
McHarg. I., (1968). A Comprehensive Highway Route-Selection Method. Highway Research
Record. 246. Washington. DC: Highway Research Board, pp. 1-15
Mekong Committee, (1982). Nam Pong Environmental Management Research Project. Final
Report for Phase H. Bangkok, April
NEB, (1979). Manual of NEB Guidelines for Preparation of Environmental Impact Evaluation.
Bangkok
Phillip and DeFillipi. J. A., (1976). A Matrix Approach for determining Wastewater Manage-
ment Impacts. WPCF48 (7)
Rau, J. G., and Woolen, D. G., (1980). Environmental impact Analysis Handbook. New
. York: McGraw-Hill
Seatec et al., (1978). Environmental and Ecological Investigation of Pattani Multipurpose
. Project. Vols. I-III, October •
UNEP, (1982). The Use of Environmental Impact Assessment for Development Project
Planning in ASEAN Countries. Bangkok: Regional Office for Asia and the Pacific
UNEP and UNAPDI, (1980). Environmental Impact Statements:. A Test Model Presentation.
Bangkok . ' • •' '
Warner. M. L'.; and Preston, E. H.. (1974). Review of Environmental Impact Assessment
Methodologies. Washington, DC: US Environmental Protection Agency
Welch. H. W.. and Lewis. G. D.. (1979). An Approach to Assessment. Journal of Environ-
mental Management 2 • . .
ANNEX
Case Study on the Application of EIA Methodologies to the
Phoenix Pulp Mill Project in Thailand
THE PHOENIX PULP MILL PROJECT
The proposed project is a pulp mill which will use kenaf as the basic raw material to
produce 70,000 t/year (tonnes per year) of bleached and unbleached pulp. The
project requires a land area of 1,065 rai (625 Rai = I km2). The annual requirement
of kenaf for the proposed mill would be 200.0001.
The basic raw material include the cellulosic raw material kenaf and process
chemicals (sodium sulphate, caustic soda, chlorine, chlorine dioxide, lime, sulphur,
alum and water). The raw water supply is from the Nam Pong River. The water
requirement will not exceed 0.7 m3/sec. It will be treated to meet the water quality
standards for industrial use, with a fraction treated to meet domestic use water
quality standards. .
Figures 2.8 and 2.9 show the location of the Phoenix Pulp Mill and the proposed
resettlement area.
93 •
-------
ENVIRONMENTAL IMPACT ASSESSMENT FOR DEVELOPING COUNTRIES
Figure 2.8. Plant site location
Legend:
C.".-J PtanfSiW
Norn Phong River
Friendship Highwoy
Ubolroto Road
power Tiansmistion Lint
Figure 2.9. Plant site and general Ubolratana resettlement area
94
METHODOLOGIES FOR RAPID EIA: CASE STUDIES IN THAILAND'
EXISTING ENVIRONMENTAL CONDITIONS
Physical resources. Most of the tributaries in the project area are intermittent
streams, including the Huai Chot; which is the drainage course for the plant site. The
Huai Chot is dry during drought seasons, and water quality in some parts is not
suitable for domestic use. . . • . •• • . :- , . •/..'
Both the air quality and land quality (pollution) of the area are good. There are no
mineral resources in the immediate project area. • • : «. . ~ • .;,
Ecological resources. Fisheries and aquatic ecosystems are not significant in the Nam
Pong river in the project area. Terrestrial wildlife populations are low or absent in'
the project area. , , • ; ,
Human use values. The land use in the project area is'mainly agricultural. Known
water uses are domestic water supply, agricultural water supply (including a large
irrigation district), fisheries, and industrial water supply.
Qualiry-of-life values. In the project area the average annual income is 6,169 Baht
(CUS$l=22.7Baht).
APPLICATION OF MATRICES
Different types of environmental impact matrices have been tried and they are •
briefly described here. , ;. .
i- * . • • •
Discussion on the Simple Environmental Impact Matrix •
Table 2.14 is a simple environmental impact matrix for the Phoenix Pulp Mill.
Activities such as wastewater discharge will have impacts on several environmental
components, such as surface water quality, fisheries, aquatic ecology, water supply
and health. The use of pesticide and fertilizer will affect the surface water quality,
fisheries, aquatic ecology and water supply. Other project activities such as solid
waste disposal, plant construction, etc. will have impacts on few environmental
parameters. •
* It may be noted that the technique does not provide information oh the magnitude
and importance of impact, the nature of impact, and whether adverse or beneficial,
etc.
Discussion on Graded Matrix . H
' - "• ' ' •
Table 2. IS shows the graded matrix for the proposed Phoenix Pulp Mill Project.
Effect of effluent discharge on surface water quality. The project proponent has
already included the wastewater treatment facilities that are expectedjagive effluent
95
-------
Table 2.14. Simple environmental impact matrix for the Phoenix pulp mill project
^^^ Project
Environ^^^ activities
mental ^^^.
components - ^"\_
Surface water
quality , ": -
Surface water
hydrology'
Air quality
Fisheries
Terrestrial wildlife
habitat
Terrestrial wildlife
Land-use pattern
Highways/railways
Water supply
Agriculture
Housing
Health
Socio-economic conditions
Plant
construc-
tion
X
X
Farming
of
kenaf
X
X
Use of
pesticide
fertilizer
X
' :
X
X
Transport-
ation of
raw
materials
X
X
. Water
intake
X
. • -
Solid
waste
X
• -
X
Effluent
discharge
X
X
X
.X
Emission
X
X
Employ-
ment
X
X
X
I
m
o
m
i
1
Table 2. IS. Graded environmental impact matrix for the Phoenix pulp mill project
^^ Project
^vactivities
Effects on ^x.
Surface water
quality
Surface water
hydrology
Air quality
Fisheries
Aquatic ecology
Terrestrial wildlife
habitat
Terrestrial wildlife
Land-use pattern
Highways/railways
Water supply
Agriculture
Housing
Health .
Socio-economic
conditions .
Plant
construc-
tion
3 6
3
4
•2 5
5 6
13 21
- Farming
of
kenaf
8 7
7 7
10
8
25 22
Use of
pesticide
fertilizer
6
7
2 5
2 6
3 6
13 24
Transport-
ation of
raw
materials
2 6
6 5
8 II
Water
intake
1
7
1 7
Solid
waste
4
4
/
3 5
1 9
Effluent
. discharge
2
8
2 7
2. 5
2 7
LL 8
"> 35
Emission
4 5
2 6
6 11
Employ-
ment
5
5
7 6
8
8
20 ,9
Total
17
2-1
1
7
9 17
4 12
4II
3
4
2 5
IJI3
6 5
5 13
7 7
7 6
7 19
IN
16
I
3
O
m
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ENVIRONMENTAL IMPACT ASSESSMENT FOR DEVELOPING COUNTRIES
with pollutant concentration as follows: BOD.8 ppm; SS.10 ppm; DS.10 ppm;
pH,7-8; temperature, 37"C. These are well within the allowable limits in the effluent
standard. Thus a negligible impact of magnitude 2 is considered in the matrix.
Effect of farming on surface water quality. Increased kenaf production may result in
increased use of pesticides and fertilizer, which if not properly used will lower the
surface water quality. An impact of magnitude 6 with importance of 7 is thus
assigned.
Effect of emission on air quality. Since control measures are incorporated in all the
equipment, the impact on air quality can be regarded as insignificant and of mag-
nitude 4.
Effect of effluent discharge on fisheries and aquatic ecology. With the proposed
wastewater treatment facilities, the effluent will have only minor effects on both
fisheries and aquatic ecology and may be denoted by an impact magnitude of 2.
> ' -
Effect of kenaf farming on agriculture. The agricultural industries will benefit from
the proposed project because there will be a steady demand for kenaf. This is
considered a major positive impact and is rated here as of magnitude 7.
Discussion on Modified Matrix
Table 2.16 shows the environmental baseline evaluation. Among the physical
resources, surface water quality, air quality, soil erosion and sedimentation have an
importance of 5. with also very good present conditions as denoted by scale 5. In the
human interest category, socio-economic and health factors have an importance of 5.
and the present condition is of scale 3.
Table 2.17 shows the environmental compatibility matrix. Four of the human
interest parameters (land-use pattern, agriculture, socio-economic, highways) are
positively significantly impacted by the project.
Table 2.18 shows the decision matrix, denoting that most of the significant impacts
of the project on environmental parameters are positive. The negative impacts are
contributed mainly to ecological and physical resources. The human interest
parameters are positively and significantly impacted, and the present condition for
most of them is unfavourable; this can be easily explained by the lack of development
of the region. Hence the project could be approved on environmental grounds.
CHECKLIST APPLICATION
A checklist which provides a qualitative assessment of the project as beneficial or
adverse, reversible or irreversible, short-term of long-term, and of local or wide
impact has been developed and is presented in Table 2.19.
The ecology of the area is unlikely to be disturbed. Since there is no evidence of
rare and endangered species, such an impact will be minor. Siltation is a long-term
effect resulting mainly from erosion of kenaf farmland. Air pollution abatement
98
METHODOLOGIES FOR RAPID EIA: CASE STUDIES IN THAILAND
Table 2.16. Environmental baseline evaluation of the Phoenix pump mill project'\ • •'•. «•'
i
Environmental
parameters
Terrestrial wildlife habitat
Terrestrial wildlife
Rare & endangered species (terrestrial)
Fisheries
Rare & endangered species (aquatic)
Surface water hydrology • •
Surface water quality
Groundwaler quality
Air quality
Soil erosion
Sedimentation
Land-use pattern
Highways/railways
Navigalion
Water supply
Power supply
Ariculture
Housing
Health
Socio-economic conditions
-------
8
N^
0
»-*
Table 2. 17. Environmental compitability matrix for the Phoenix pulp mill project . - '
Construction ' . • • Plant operation
/N. Pn?'?? .Site Highway/ Trans- Dri"inS Plant Waste- Air „, _ Solid
EnvroXacnvmes ^ »J & ^^ wa,er emi$. Water Power waste
mental ^v { rf £ blast- ^ dUch ; intake supply dis- .
parameters \. s . . mg . e . . . .posal
Ecological .-.'-. • • .
Terrestrial wildlife ,t 71 '•"•'.-' ,, „
habitat . . , " ' , . L
Terrestrial wildlife -2L -2L -3L
• Rare & endangered
speries (terrestrial)
Fisheries - -3S -3L
Rare & endangered •
species (aquatic)
Physical resources
Surfacewater -i
hydrology
Surfacewater -4S -4S -3L
quality • . . .
Groundwater . ' . _2[_
• quality
Airquality -4S -3L -4S -3L
Soilerosion -4S '
Soil fertility
Sedimentation -4S
Human interest " •
Land-use pattern .... * . .
Highways/railways ' ' +5L
• Navigation . • ."••-.' -
Watersupply -3L _
. Agriculture - • " . • •
Housing .'.-...
Health -4S -*S -3L -2L - -2L
Socio-economic "•• .+2L
conditions
Power supply - •
5
• <
3D
0
Z
r"
' Related activities Q
Hous- Employ- Kenaf ^
ing ment farming 2
3
30
5
o
3
-4L S
§
Z
-2L -.'L
.
-5L
S
S!
-41. 0
g
-5L x
m
i
71
30
+5L 5.
m
F
+3L 5
tn
+3L +5L +-5L <3
2
o
si
z
^
. i
-------
ENVIRONMENTAL IMPACT ASSESSMENT FOR DEVELOPING COUNTRIES
Table 2.18. Decision matrix for the Phoenix pulp mill project
Project alternative
Environmental parameter
'Terrestrial wildlife habitat .;
Terrestrial wildlife
Rare & endangered species (terrestrial)
fisheries
Rare & endangered species (aquatic) . '
Surface water hydrology
Surface water quality ...'• ^
Groundwaterquality . .
Air quality ..,
Soil erosion • '' ;-
Sedimehtation
Land-use pattern • •
Highways/railways •'••'.*
Navigation •
Water supply
Power supply
Agriculture • . . .
Housing ' • '
Health
Socio-economic conditions
No project
2
2
1
2
1
5
4
4
5
5
5 ,
4
3
_
4
2
3
_
3
3
With
the
project
-3L
-3L
_ . '
-4L
_
'• -2L •
-3L
-2L
-3L
-5L
.1
+5L •
. .+5L
_
-3L
+5L
+3L
+3L
+5L
measures will be adequately provided in the mill operation. Thus pollution due to
gaseous emission will be well within the standard value. The wastewater discharge
will be adequately treated to meet the effluent water quality standards, and the
impact can be considered negligible.
The project will provide a stable source of income for 20.000 farmers and employ
directly 700 workers, leading significant beneficial impact on the socio-economic
secton .
ASSESSMENT USING THE UNEP TEST MODEL
Ih presenting this section, the format recommended by the UNEP document is
followed. . .
Introduction
Theproposed Phoenix Pulp Mill will use kenaf as the basic raw material to produce
t nnn !-year °f bleacned and ""bleached pulp. The project requires a land area of
1,000 rai. The water requirement will not exceed 0.7 m3/sec. Approximately 80 per
102
METHODOLOGIES TOR RAPID EIA: CASE STUDIES IN THAILAND
19 (An */»>/•» the Phoenix pulp mill project •
Niiiurc of likely impacts
Adverse
Beneficial
Items . . -
. • •
Ecology
Fisheries .
Siltation •
Erosion ' .
Airquality
Surface water quality
Surface water hydrology
Land-use pattern
Highways/railways
Agriculture
Housing
Hedlth ;
Socio-economic conditions
*
**
c
. • .' J
X
X
X
'••,1
' -.
1 1
OD S>
J^^ • . 5 '
i
X
X
X
X X
X X
•
u
3
^ "5 4J
£ 3 &
X X
. X.
X X
X X
X X
X
•... • x •
II
^ cP
'1.5
X
X
X
X
X
X
c
tp-
JJ
00 .
i/5
• ,. .
X
X
X
-a
•'e
'z. .
•' 1 . .. .
• *•-'
• "^ "• • I-
'
X
X
X
• Here the short-term impact would mean the impact during the construction period. Impacts
persisting during the project life (ten years) are considered long-term effects.
cent of the water will be returned as wastcwater. The final discharge will be drained
into a small stream (Huai Chot) with treated discharge of 0.63 rn-Vsec.
. The project is considered to be serving the national interest for the following
reasons: ..
1. providing a reliable income for about 20,000 farmers and 700 workmen; .
2. saving foreign exchange; . . . ,
3. reducing dependency on foreign pulp and paper; , , ' . , .,(. •'•,
4. providing a new market for kenaf; •
5. providing for efficient utilization of kenaf.
It may be emphasized at this point that kenaf is an important cash crop and
sometimes the only cash crop of thousands of farmers in north-east Thailand. .
Cost-Benefit Presentation
The cost and benefits of the project, as they emerge from the data extracted from the
feasibility study of the project, are presented in tabular form. The data have been
organised in separate tables under different headings, such as resources used
directly, indirectly affected, exhausted, enhanced, etc.
The costs and benefits from an economic point of view are presented separately
from those arrived at from an environmental viewpoint. The economic assessment
has to be made on the basis of sort of commercial balance sheet, whereas environ-
mental assessment deals with social and other benefits in which some items may be
103
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IMPACT ASSESSMENT FOR DEVELOPING COUNTRIES
presented wst in the economic analysis: for example, wages paid may be a benefit
socially in the form of an employment created and consequent expectation of an
improved quality of life.
The main difficulty in this technique of analysis is the necessity of assigning money
values to every item of cost and benefit. In some instances assumptions are made
which are based on individual judgement and can easily introduce considerable error
in the cost-benefit results. •
Assessment . • •••
The Phoenix Pulp Mill as indicated in the cost-benefit analysis comes out as a
profitable and socially highly viable enterprise. For an investment cost of US$50
million (Table 2.20), employment is generated for 20,000 farmers and 700 workers.
An average of about 200.000 tonnes of kenaf valued at US$5.9 million, will be
processed each year.
Economic damage due to the degradation of river water quality is considered to be
negligible since the wastewater treatment scheme will meet effluent standards. In
addition, the proponent is planning .to determine an appropriate technique for
wastewater reuse in kenaf plantation and a process for lime mud burning to reclaim
calcium oxide for reuse in the pulping process - this may reduce solid waste by
approximately 65-70 per cent. It is expected that 75.0001 of pulp will be produced
annually, and this corresponds to a foreign exchange saving of US$31.5 million
annually. The gain to farmers and workers due to employment generation is
estimated to be US$4.24 million and $1.3 million respectively.
From the economic point of view, the benefit/cost ratio is 1.21:1 (Table 2.20).
Environmentally, the project is seen to generate benefit of US$5.6 million annually
(Table 2.21). This is wholly accounted for by considering incomes of 20.000 farmers
in the north-east and wages of 700 workmen in the project and the resulting improve-
Table 2.20. (a): Economic costs and benefits: investment stage (I)
Reference
Item
Costs • Benefit
US$ million p.a.
Land . 0.15
Civil construction ' . 3.5
Plant and machinery 32.5
Erection • . 2.45
Site development 0.575
Engg. services and technical know-how 1.0
Prc-operative expenses • 1.14
Miscellaneous fixed assets . 0.40
Start-up expense ' 1.5
Pre-opcrational interest and others 6.5
Total 50.0
104
METHODOLOGIES FOR RAPID EIA:
DIES IN THAILAND
menf in the quality of life. Owing to unavailability of data, the cost due to soil erosion
is not included in the analysis. : . . '
Table 2.20. (b): Economic costs anil benefits: production stage (II)
Reference
Item
Costs Benefit
US$ million p.a.
lla(l)3
lla(l)7&8
lla(l)9
Ha(l)IO •;
Ila(l)l7 .
Ha(l)l8
Ila(l)l9 ].
lla(l)20
lla(l)2l
lla(l)22 (,
lla(l)23
Kenaf
Chemicals
Utilities , ' >
Labour , • •
Repair and maintenance . ; , " '
Contingency •
Overhead and insurance •• ' v
• Depreciation ' .
Amortization . :
Interest
Selling expenses • " •. ;
Transportation charges up to Bangkok
Cost of pulp sold . .•••'•
Total
,. 5.9 ,
• ' i. / '
1.4 '- ".; . '
. 0.42 ; . . . : ' "
0.829 •: :.;
•• 0.42 ,
3.84 '
10.629 : .
1.51
0.499
0.56
31.5
26.021 31.5
Total cost I + II = $86.021 million p.a.; total benefit = $31.5 million p.a.
Table 2.21. Environmental costs and benefits
Reference
Item
Costs Benefit
US$ million p.a.
IV-2 Stable source of income created for 20.000 . 4.2
farmers in north-cast. Thailand (improved
quality of life •
IV-3 Provide direct employment to 700 workmen 1.4
(improved quality of life)
lla(ll)3 Lifestyle changes in adjoining area due to Negligible . -
noise and other factors
lla(ll)l Water pollution (wastewater treatment • Negligible
employed) . «
llh(ll)l Effluent containing wood wastes Negligible
llh(ll)l . Effluent containing sugar and <• : . Negligible
carbohydrates •
III-2 ";• Soil loss . N.A. .
Total . 5.6
N.A. Cost figures not available.
105
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ENVIRONMENTAL IMPACT ASSESSMENT FOR DEVELOPING COUNTRIES
Decision-Making
The Phoenix Pulp Mill producing 70,000 t/year will provide more than half of
bleached and unbleached pulp currently imported to Thailand annually and will save
exchange of US$31.5 million.
Kenaf as a jute substitute is a foreign exchange earner for Thailand, but the fibre
has been subjected to fluctuation in price and demand on the international market,
and the long-range trend is not encouraging. The new market for kenaf provided by
this project will add stability to this important segment of Thai economy and greatly
add to the well-being of the farmers.
Environmentally, the project may result in major negative impacts if pollution
abatement measures are not adequate. The major impacts can be minimized by the
proposed mitigation measures, and their effectiveness can be determined by the
monitoring programme.
The benefit/cost ratio, from both the economic and the environmental point of
view, indicates the project to be a profitable one.
METHODOLOGIES FOR RAPID EIA: CASE STUDIES IN THAILAND
Appendix* , .
• *
Description of the Project . •
Nature: Industrial • : ;
Title: The Phoenix Pulp Mill :
Time span: Amortization over ten years
Physical Boundary: The proposed project is located in the Ubolratana Self-Help
Resettlement Area near Bank Non Noi. Changwat Khon Kaen, north-east Thailaftd
(Figures 2.8 and 2.9). The project requires a land area of 1,000 Rai(l km2 = 625,
Rai). About 170,000 Rai of land will be under cultivation for the proposed project. .
Cost :' ••' '.'-.-'' ''••'' '•<'•-' : " ••'"••
Table I. Products and Values
Products
Pulp
Quantity
70,000 t/ycar
Value (US$m)
3.5 p.a.
' The various operations involved in pulping arc as follows:
1. chipping/cutting
2. chip washing or dust removal
3. cooking/digcstion/scgrcgalion of fibre
(a) mechanical pulping ' ' •.' •'
(b) semi-chemical/chcmi-mechanical pulping . "-•• .
(c) chemical pulp • , - • .
4. washing of cooked pulp .•'•••
5. screening and cleaning ' •' •
•6. bleaching • . .'.".•'
'7. finer cleaning for bleached grade pulp. ''•'..•
• The basic raw materials include the cellulosic raw kenaf and process chemicals (sodium
sulphate, caustic soda, chlorine, chlorine dioxide, lime, sulphur alum and water). The water
requirement will not exceed 0.7 m*/day. . -. ,.-•,.
The preliminary wastewater treatment scheme provides a maximum treatment capacity of
48.000 m3/day, based on projected daily wastewater load of 35,000 m'/day and a peak load of
48.000 m3/day. . . .'.'•.; '
The resources used are kenaf crop, processing and mill premises and facilities, effluent
treatment plant, and water for processing. The main resources indirectly affected are the riven
from which process water is drawn and into which effluents are discharged.
* This section is written as recommended in the UNEP document (UNEP and
. 107
ur^fw.
, 1980).
-------
ENVIRONMEI^B^IPACT ASSESSMENT FOR DEVELOPING COUNTRIES
(a): Resources
Serial no. Hem Quantity Jjjjf
Used directly
Ha(l)l76 Contingency @ 5% (kenaf. chemicals,
utilities, labour) .
Ila(l)l8 Overhead and insurance
Ila(l))9 , Depreciation
(11) on building® 5%
(value US$4,128,000)
(b) on machinery @ 10%
(value US$36,350,000) .
,IIa(l)2D Amortization @ 10%
(on US$6.290.000)
IIa(l)21 Interest • '
(a) on purchaser's credit @ 9.5% -
(b) on short-term loan @ 12%
IIa(l)22 Selling expenses, e.g. advertisement
lla(l)23 Transportation charges
Ila(l)l Land for mill premises l.OOORai 150/Rai
Ila(l)2 Kenaf . ; 200,000 1 29.5/t
lla(l)3 Chemicals 48.920 1
lla(l)4 Civil work
lla(l)S Equipment and machinery
lla(l)6 Erection
Ha(l)7 Power (purchased) 28 x 10* kWh . 0.0225
Ha(l)8 Fuel oil 75/kl
lla(l)9 Ubour
IIa(l)10 Maintenance
lla(l)ll Site development
Ila(l)l2 Engineering services _ ' .
IIa(l)13 Pre-operative expenses
Ila(l)14 Miscellaneous fixed assets
Ila(l)l5 Pre-operational interest and others
Ila(l)16 Start-up expense
IIa(l)l7a Contingency (price escalation,
construction and building)
Total
(US$m)
0.829
0.42p.a.
0.206 p.a.
3.635 p.a.;
0.629p.a.
• 1.043p.a.
0.463 p.a.
0.494 p.a.
0.56
0.15
5.9 p.a.
5.6 p.a. •
3.15
3.25
2.45
0.63 p.a.
3.02 p.a.
1.4 p.a.
I.155p.a.
0.575
1.0
1.14
0.04
6.5 ..
0.2
1.5
' i
j
1
i
t
\
i
i
i
i
\
. i
• ' i'
METHODOLOGIES K)R RAPID EIA: C
ASE^^C
DIES IN THAILAND
lla(l 1)3
• Land (due lo solid ivasles)'
Lifestyle changes in adjoining areas
due lo noise and other factors .
Land for kenaf cultivation
N.A. •
25.2»
* Treated discharge of 0.63 m-Vsec, having BOD: 8 ppm.SS: lOppm.DS: lOppm. These are.
lower than the effluent standard for discharge.
1 Although cost figures are not available, the proponent planning to reduce 65-70% of solid
waste by recycling and reuse. . .
» Unit cost of land is assumed to be the same as that provided for mill premises.
N.A. Cost figures not available. . ' •'.' . • ' •
(b): Products and Residues
Serial no. Item
Total
(US$m)
Products
Residues •
Pulp
Solid wastes
Effluent containing suspended fibres
and soluble organics consisting
mainly of sugar, carbohydrates and
related compounds
70,0001/
year •
450/t
3.5p.a.
N.A.
N.A. :••
N.A. .
N.A'. Cost figures not available.
Affected directly
IIa(ll)l Reduction in quality of river
(Huay Choi) in which the effluents
are discharged *
Negligible
108
109
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ENVIRONMENTAL IMPACT ASSESSMENT FOR DEVELOPING COUNTRIES
(c): Resources Exhausted, Depleted. Deteriorated
Serial no.
Ill-l
III-2
Item • Quantity
River into which effluents are
discharged:
(a) effect on fish and acquatic
life and other uses
(h) lossofwaterqualityfor
local purposes
Soil loss due to erosion during the
interval between replanting .
Rate m«a'i
(US$m)
Negligible
N.A.
* Wastewaler treatment facilities incorporated. .
N.A. Cost figures not available.
(d): Resources Enhanced and Residues, Utilized
Serial no.
IV-I
IV-2
IV-3
Related . . •
serial no. Item How enhanced
in section II
IIa(l)2 Kcnaf ' More efficient
utilization *
Gain to 20 .000 Increase the
farmers in the economic well-
. north-east beingofthe
; • farmers
Provide direct Directly employ
employment 700 workers of all
categories
Quantity rate Jg"^
Pulp 3.5 p.a.
70,(XX)t/year
4.24 p.a.
1.4 p.a.
* When used as a jute substitute, only the outer layer of the kenaf stalk can be utilized. For
pulping, the entire stalk is consumed. '
' As a jute substitute, the price of kenaf is subjected to fluctuations of international markets,
. and economic repercussions of unstable market have been severe. The project will provide
stability and add to the economic well-being of the grower.
110
METHODOLOGIES FOR RAPID EIA: CASE STUDIES IN THAILAND
(e): Resource Restoration. Maintenance and Expansion ' . ' ..'.-.
Serial no.
V-l
V-2
y-3 •
. Related scriiil . '•
no. in sections Item
11/111
llb(ll)l Solid wastes
j '
llb(1ll)2 . ' Effluent containing
soluble organics such
as sugar, carbo-
•.'•.. • hydrates and related
compounds
111-2 Soil loss due to
erosion during the
, • ' interval between
planting
What should be done
Separation of wood •
which can be used for
energy production through
pyrolysis* (reclaiming
calcium oxide from lince •
mud) : . ••'
Recovery of sugar ,
carbohydrates and related
compounds which can be
used as animal feed
Establishment of plant
cover, e.g. leguminous
C'osi
thousand
USSp.a.
N.A.
N.A." -.
N.A. .'
* The proponent of the project is exploring appropriate techniques for this which would finally
. reduce solid waste by 65-70 per cent. . .
N.A. Cost figures not available.
Ill
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PARTD
SELECTED ENmONMENTAL LAWS AND
REGULATIONS
D-l
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D-2
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SELECTED U.S. ENVIRONMENTAL LAWS AND REGULATIONS
• Facts About the National Environmental Policy Act. U.S. Environmental
Protection Agency. September 1989.
• Council on Environmental Quality Regulations for Implementing the
Procedural Provisions of the National Environmental Policy Act. (Source:
40 Code of Federal Regulations Parts 1500 -1508)
• Council on Environmental Quality Forty Most Asked Questions Concerning
CEQ's National Environmental Policy Act Regulations. (Source: 46 Federal
Register 18026 - 18038, March 23, 1981)
• Summaries of Related U.S. Environmental Laws. (Source: EPA, Cross-
Cutting Environmental Laws: A Guide For Federal/State Project Officers, 2 IE
4001, January 1991)
• States with Environmental Policy Acts. (Source: Council on Environmental
Quality. 1992. Environmental Quality. 22nd Annual Report)
• States with Limited Environmental Review Requirements Established by
Statute, Executive Order, or Other Administrative Directives. (Source:
Council on Environmental Quality. 1992. Environmental Quality. 22nd Annual
Report)
OTHER LAWS AND REGULATIONS (insert state, tribal, or other national laws
and regulations as appropriate)
D-3
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D-4
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PARTE
GLOSSARY
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PARTE
GLOSSARY
E-l
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E-2
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GLOSSARY
ANALYSIS — Analysis is a formal, more or less objective task of using quantitative techniques
to estimate the changes that are likely to occur as a result of a proposed action.
ASSESSMENT — As used in this sourcebook, assessment refers to analyzing and evaluating the
potential impacts of proposed actions on the environment.
BASELINE (EXISTING AND FUTURE) — Existing baseline conditions are the current
conditions of an area potentially affected by the proposed action. Existing baselines are
established prior to construction and operation of a proposed project in order to evaluate
the effects of the project. Future baseline conditions are based on current conditions and
reasonably foreseeable future conditions (e.g., 20 to 50 years hence) of an area without
the project. Future baselines are the basis for a no-action alternative to which other
alternatives are compared.
CATEGORICAL EXCLUSION (CX) — CX means a category of actions which do not
individually or cumulatively have a significant effect on the human environment and for
which, therefore, an EA nor an EIS is required.
CUMULATIVE EFFECTS — Cumulative effects (impacts) are those resulting from the
incremental effects of an action when added to other past, present, and reasonably
foreseeable future federal or non-federal actions. Cumulative impacts can result from
individually minor but collectively significant actions taking place over a period of time.
EFFECTS/IMPACTS — Effects and impacts as used in this sourcebook are synonymous.
Effects can be ecological (such as the effects on components of natural resources, the
structure and/or functioning of affected ecosystems), aesthetic, historic, cultural,
economic, and social and health, whether direct, indirect or cumulative.
ENDPOINTS — An endpoint is a characteristic of an ecological component that may be affected
by the proposed action. Two types of endpoints can be distinguished. Assessment
endpoints are explicit expressions of the actual environmental value that is to be protected
(e.g. a decline in a sport fish population). Measurement endpoints are measurable
responses to a contaminant or disturbance that are related to the valued characteristics
chosen as the assessment endpoints (e.g., increased mortality in fish). Effective
environmental assessment depends on clearly stated linkages between measurement
endpoints, assessment endpoints, and the basic objective of the assessment (e.g., policy
goals). Information compiled during the initiation and scoping phases of EA is used to
help select endpoints that are relevant to decisions made about protecting the
environment.
ENVIRONMENTAL ASSESSMENT (EA) — For purposes of this sourcebook, EA is the
process of examining proposed projects and their reasonable alternatives for potential
E-3
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environmental impacts prior to making decisions on implementation. EA is the most all
encompassing of the assessment traditions because of the diversity of activities to which
it is applied and because the law requires that it identify the full range of affected
environmental components, define the geographical and temporal extent of effects, and
identify secondary and even, tertiary effects.
ENVIRONMENTAL IMPACT ASSESSMENT (EIA) — For purposes of this sourcebook, an
EIA is a report that documents the EA process for a proposed activity. In the U.S., an
EIA is a formal document, either an environmental assessment (EA) or an environmental
impact statement (EIS). Elsewhere, an EIA has a variety of names; it may be a formal
document or the information may be dispersed in different parts of other documentation.
In the sourcebook, EIA is used for a document that results from the formal EA process.
"EA document" is used when the document can be an EIA or a lesser document.
ENVIRONMENTAL RISK ASSESSMENT — Environmental risk assessment deals with risks
that arise in or are transmitted through the air, water, soil or biological food chains to
man.
EVALUATION — Evaluation is a subjective task that depends on the application of human
values. It involves determining the significance of the potential impacts to the affected
and interested parties.
FATE MODELS — Compartmental models that estimate the relative distribution of pollutants
among environmental compartments (e.g., air, soil, water, sediment, biota). These
models are based on the tendency of a chemical to escape from one chemical phase into
another.
FINDING OF NO SIGNIFICANT IMPACT (FNSI) — A document briefly presenting the
reasons why a proposed action will not have a significant effect on the environment and
thus an EIA will not be prepared.
MULTI-COMPARTMENT MODELS — Models that account for transfers of chemicals among
different media (known as partitioning) and exposures from multiple environmental
pathways. Most multi-compartment models consist of linked, single-medium models,
which may simulate the physical and chemical processes that drive the transport of
chemicals across air/water, air/soil, and water/soil interfaces. The data requirements for
such models are substantial, and scientific understanding of intermedia transport
processes is still embryonic.
INDIRECT EFFECTS — Indirect effects are those caused by an action that are later in time or
farther removed in distance, but that are still reasonably foreseeable (e.g., development
in undisturbed areas as a result of road building for logging purposes.
E-4
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NON-GOVERNMENTAL ORGANIZATION (NGO) - NGO is a general term for
organizations outside of government agencies such as public organizations and
environmental interest groups.
PROPONENT — The entity responsible for a proposed action. For purposes of this
sourcebook, agency and proponent are synonymous because in the U.S., NEPA and its
EA requirements apply only to federal agencies. Private applicants for federal grants or
permits or other federally assisted activities may submit environmental information for
use by the agency in preparing an EA document, but the agency must evaluate the
information and assume responsibility for its accuracy.
RISK ASSESSMENT — A general term for techniques to estimate the likelihood (or probability)
and the severity of harm to human health and the environment occurring from exposure
to a risk agent. It includes a variety of quantitative and qualitative techniques used in
engineering, toxicology, epidemiology, sociology, and economics.
U.S. ENVIRONMENTAL ASSESSMENT (EA) - In the U.S., an EA is a concise public
document that provides sufficient information for determining whether to prepare an EIS
or a finding of no significant impact (FONSI).
U.S. ENVIRONMENTAL IMPACT STATEMENT (EIS) - In the U.S., an EIS is a detailed
public document that provides full and fair discussion of significant environmental
impacts and informs decisionmakers and the public of reasonable alternatives that would
avoid or minimize adverse impacts or enhance the quality of the human environment.
It is used by federal officials to plan actions and make decisions.
E-5
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E-6
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PARTF
COMPUTER SOFTWARE
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PART F
ENVIRONMENTAL ASSESSMENT RESOURCE
GUIDE*
F-l
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F-2
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Environmental Assessment. Resource Guide
'"Part F is a computer software supplement to this sourcebook. Disks
will be provided to recipients of the sourcebook when the computer
software program is completed.
F-3
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F-4
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