Trend and Comparative Profile of NEPA Considerations
in the Saginaw River Basin
Pilot Phase Report
U.S. Environmental Protection Agency
Environmental Impact Section (5 WFI)
USEPA Region V
230 South Rearborn Street
Chicago, Illinois 60604
Submitted by:
Science Applications International Corporation
8400 Westpark Drive
McLean, Virginia 22102
USEPA Contract No. 68-04-5035/009
SAIC Contract No. 2-813-06-193-09
October 28, 1985
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TABLE OF CONTENTS
Section Description Page
1.0 Purpose of Study-Pilot Phase 1-1
1.1 Introduction 1-1
1.2 Study Purpose 1-2
2.0 Scope of Issues Examined 2-1
2.1 Description of Work Tasks 2-1
2.1.1 Task 2 (Modified) 2-1
2.1.2 Task 3 (Modified) 2-1
2.2 Actual Scope of Work 2-2
3.0 Findings 3-1
3.1 Presentation of Data 3-1
3.2 Problems Encountered During
Evaluation Process 3-2
3.2.1 Baseline Data Collection 3-2
3.2.2 Field Data Collection 3-4
3.2.3 Data Transcription and Computer
Processing 3-5
3.2.4 Manual Review 3-7
4.0 Comparisons 4-1
4.1 Trends 4-1
4.2 Differences 4-1
5.0 Conclusions and Recommendations 5-1
5.1 Baseline and Field Data Collection .... 5-1
5.2 Data Transcription and Analysis 5-1
Appendices
A. Field Investigation Reports and Narrative Reports
B. SAS Data Listings
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LIST OF TABLES
No. Description Page
1 Summary of Cost and Effort Required for Evaluating
14 NEPA Considerations According to A Manual for
Evaluating Predicted and Actual Impacts of
Construction Grants Projects 2-4
Estimate of Hours Devoted to Major Tasks 2-5
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1.0 PURPOSE OF STUDY-PILOT PHASE
1.1 INTRODUCTION
On June 17, 1985, USEPA issued Delivery Order No. 009 entitled An
Evaluation of NEPA/Construction Grant Impact Predictions in Three River
Basins. During the next 4 weeks, SAIC assembled the appropriate staff and
prepared the first major deliverable, the Plan of Study. Due to the substan-
tial uncertainties within the Delivery Order tasks regarding the estimates for
data collection and the utility of procedures and evaluation forms described
in the Manual for Evaluating Predicted and Actual Impacts of Construction
Grants projects, SAIC divided each Delivery Order task into several subtasks,
then estimated time and labor hours accordingly. The resulting Plan of Study,
submitted to USEPA July 15, 1985, extended the end date of the project by
approximately 3 months and nearly doubled the costs.
A telephone conference call on July 19, 1985, between USEPA and SAIC
(Schauraburg and McLean), was arranged to discuss the Delivery Order and the
Plan of Study and attempt to resolve the differences between the two. It was
mutually agreed that in order to reduce the uncertainties of the Delivery
Order, it would be modified to provide for a "Pilot Phase" in which the
Saginaw River Basin containing about 15 projects would be used to assess the
data collection procedures, the evaluation form and the computerization/
analytical software. The Pilot Phase was to be concluded with this report of
findings and recommendations which will be the subject of a subsequent meeting
between USEPA and SAIC.
A follow-up letter from SAIC to USEPA (July 24, 1985) documented the
results of the telephone conference and provided recommended language for
modifying Delivery Order No. 009. On July 30, 1985 in a telephone conversa-
tion between Larry Adams (USEPA-Project Monitor) and Jim Williamson (SAIC-
Project Manager), Larry Indicated basic agreement with the recommended modifi-
cations and asked that SAIC proceed with the data collection and software
development tasks of the Pilot Phase while the amendment to the Delivery Order
was being processed. SAIC complied with this request. Delivery Order 009,
Amendment No. 1 was subsequently received by SAIC on September 11, 1985.
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1.2 STUDY PURPOSE
The purpose of the Pilot Phase study is to perform a preliminary portion
of the work described in Tasks 4, 5, and 6 of D.O. 9 (Modification No. 1), for
a small sample of projects. The Saginaw River Basin projects were subse-
quently selected as the preliminary study sites for this pilot phase. The
objectives are to:
o Determine the accuracy and completeness with which planning and
environmental review documents (NEPA documents) assessed predicted
environmental effects of Construction grants projects
o Identify the types of problems encountered in following the
methodology described in A Manual for Evaluating Predicted and Actual
Impacts of Construction Grants Projects
o Provide recommendations for overcoming the identified problems
o Estimate the time and costs required to complete the various parts of
the evaluation process, and provide an estimate of cost and time
required to complete the remaining 60 projects.
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2.0 SCOPE OF ISSUES EXAMINED
2.1 DESCRIPTION OF WORK TASKS
Since the Pilot Phase tasks were initiated on or about August 1, 1985 and
the Delivery Order Amendment was not received until September 11, 1985, the
work was guided by: 1) original Delivery Order No. 009, 2) SAIC's letter of
recommended modifications dated July 24th, and 3) conversations between SAIC
staff and USEPA. Tasks 2, 3 and 4 as modified by items 2 and 3 above were
carried out and formed the basis of this report.
2.1.1 Task 2 (Modified)
Task 2 was Produce an Interactive Program for Machine Readable Evaluation
Form. This task remained unchanged from the original Delivery Order and read
as follows:
A routine interactive program shall be developed by the Contractor to
allow a video presentation of the Evaluation Form on an IBM-AT or
compatible micro-computer. Data entered shall be convertable to data
sets, readable via Time Sharing Option (TSO) for Statistical Analysis
System (SAS) and vice versa. Storage of the Narrative Reports shall be
designed to telecommunicate with the Lexitron Word Processor.
Discussions with the Project Monitor and the Agency's ADP staff are
essential.
No additional interpretation of this task was necessary.
2.1.2 Task 3 (Modified)
Task 3 was Research and Document Baseline Information (from USEPA and
State Files). The task also remained unchanged from the original Delivery
Order except the number of sites would be limited to 15, all in the Saginaw
River Basin. This task read as follows:
The Contractor shall use the Evaluation Forms to collect data according
to the procedures provided in the Manual (Chapter II). EPA in-house data
sources consist of NEPA documents, including amendments, as defined in
the Manual. These data are to be supplemented, when necessary, with any
other related documents and interviews of State and EPA resource persons.
These data are to be transcribed onto the Evaluation Forms and will serve
as the data base of historical baselines per project, of predictive
statements, and of arrays of projects identifiers and geolocators. From
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the Evaluation Forms, the data shall be encoded to the interactive
program for machine readable evaluation forms (see Task 2, above). Due
to the sort formats of the computerized Evaluation Form, all data gather-
ing shall be consistent with the machine-readable format. This is
necessary in order to assure uniform data collection, particularly when
multiple responses are possible per type of data. For example, item 5,
(Location) on the Evaluation Form includes three project locators: river
basin, State, and latitudinal/longitudinal coordinates. The interactive
program will sort on each of the three locators, so the transfer of data
to the Evaluation form may require a transcribing procedure.
This task is open to much greater interpretation than Task 2. For example,
the first sentence refers the Contractor to procedures in the Manual.
Beginning on page II-4, Evaluation Steps 1, 2 and 3 apply to this task. Step
1 is to Identify Appropriate Data Bases. This requires the reviewer to first
determine which issues from the NEPA documents are to be evaluated. From
discussions between SAIC staff and USEPA, it was determined that all 12 issues
are potentially to be examined for the 15 projects (Pilot Phase) and the 55
projects (Second Phase). For any specific project, the issues examined were
to coincide with, but not be limited to, the impacts predicted in the NEPA
documents. Thus, examinations of all 12 issues for each project were
possible. This meant that, according to the instructions in the Manual, well
over 100 sources of baseline information in the 5 states were possible
including Federal, State and Regional or local offices. Based on SAIC's
review of the labor estimates for this project, an intensive, baseline data
collection effort of this magnitude was not indicated.
Sentences 2 and 3 of the Task go on to identify the sources of "data" to
be EPA inhouse NEPA documents which "...are to be supplemented, when neces-
sary, with any other related documents and interviews of State and EPA
resource persons." Phrases such as "are to be supplemented, when necessary"
and "other related documents" are open to substantial interpretation.
2.2 ACTUAL SCOPE OF WORK
The initial evaluation of the Saginaw River Basin projects involved the
identification and collection of NEPA documents in EPA Region V files and
assessing the environmental issues identified in these reports. The majority
of the documents were negative declarations, and subsequently contained only a
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minimum of information required for the evaluation process. This data was
transcribed onto the Evaluation Forms and distributed to the field personnel
for verification during the project site visits. The data collected from the
documents and the field investigations were subsequently entered into the
dBase III microcomputer program file. The data was not uploaded to the
mainframe, as comments concerning the data collection effort and data
transcription had not been received from EPA.
Upon review of the data, EPA determined that the data collection effort
to date was not yet sufficient enough to provide an accurate estimate of the
time and costs involved in following the evaluation process outlined in the
Manual. SAIC agreed to continue its baseline data collection efforts and to
upload the initial data to the mainframe. The data would then be properly
loaded into SAS data sets.
A summary of the time and costs involved in completing the evaluation
process outlined in A Manual for Evaluating Predicted and Actual Impacts of
Construction Grants Projects are presented in Tables 1 and 2.
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Table 1. Summary of Cost and Effort Required for Evaluating 14 NEPA Considerations According to
A Manual for Evaluating Predicted and Actual Impacts of Construction Grants
ro
i
Name
Jim Will lamson
Andrew Freeman
Denis Borum
Steve McComas
Terry Grist
Kathy Harrlgan
Ann Wltzlg
Farlba Koshnlvassan
George Wllkle
Levan Phan
Seth Ausubel
Cecil Cross
Barbara Menklng
TOTAL HOURS
Professional
Classification level
Project Manager/Biologist
Socloeconotnlst
Biologist
Biologist
Biologist
Environmental Scientist
Statistician/Project Manager
Other Technical Specialist
Computer Spec 1 a 1 1 st
Other Technical Specialist
Biologist
Environmental Scientist
Environmental Scientist
4
3
1
3
2
2
2
3
3
2
2
2
2
Baseline data collection
Proj ect
management Documentation Field
179 49
17
10 40
35 50
10 40
10 40
80
40
40
40
257 249 170
Tasks
Computer processing
SAS
dBase Uploading programming
33 2
19
2 8
5
22 5 15
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Table 2. Estimate of Cost for Pilot Phase Report
Personnel
Jim Williamson
Jim Williamson
Andrew Freeman
Denis Borum
Steve Me Comas
Terry Grist
Kathy Harrigan
Ann Witzig
Fariba Koshnivassan
George Wilkie
Levan Phan
Seth Ausubel
Cecil Cross
Barbara Menking
TOTAL
ODCs
Total 0.0. Ceiling
Pilot Phase
Remaining
Hourly rate
$34.63
44.93
28.37
20.43
27.81
27.81
25.29
25.29
19.40
33.01
19.40
25.29
25.86
25.86
Number of hours
49
179
17
50
85
50
50
8
19
10
5
40
40
40
Total labor cost
$ 1,696.87
8,042.47
482.29
1,021.50
2,363.85
1,375.00
1,264.50
2,225.52
368.60
330.10
97.00
1,011.60
1,034.40
1,034.40
$22,348.10
$ 1,496.29
$79,443.94
22,348.10
$57,095.84
Pilot Phase: 28%
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3.0 FINDINGS
3.1 PRESENTATION OF DATA
The data collected according to the methodology in the manual is
presented in several different formats. To save space, these printouts are
listed in Appendix A. The programs to date include:
o A SAS listing of all data entered onto the evaluation forms
(EVALUATION FORM Data List)
o A SAS listing of questions 1 through 6, sorted by parameter, location,
and environmental issue (Print. Test)
o A SAS listing of the predicted environmental impacts, sorted by para-
meter, location, and environmental issue (Print. Test 2)
o A SAS listing of the facility number, grant number, and baseline
conditions, sorted by parameter, location, and environmental issue
(Print. Test 4)
o A SAS listing of the facility number, grant number, and predicted
impact for end of planning period, sorted by parameter, location, and
environmental issue (Print. Test 5)
o A SAS listing of the facility number, grant number, and predicted
impact for the current year, sorted by parameter, location, and
environmental issue (Print. Test 6)
o A SAS listing of the facility number, grant number, and actual current
conditions, sorted by parameter, location, and environmental issue
(Print. Test 7)
o A SAS listing of facility number, grant number, data base for actual
conditions, and summary code, sorted by parameter, location, and
environmental issue (Print. Test 8)
o A SAS listing of facility number, grant number, and summary paragraph,
sorted by parameter, location, and environmental issue (Print. Test
9).
3.2 PROBLEMS ENCOUNTERED DURING THE EVALUATION PROCESS
The overall purpose of this pilot phase project was to identify potential
problems encountered during the evaluation process, and to provide recommend-
ations for completing the remaining 55 project investigations. The evaluation
process has subsequently been divided into four major tasks to facilitate
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problem identification and review: baseline data collection, field data
collection, data transcription and computer processing, and overall review of
the Manual for Evaluating Predicted and Actual Impacts of Construction Grants
Projects.
3.2.1 Baseline Data Collection
The GIGS Listing of Basin Projects:
- Is not consistently accurate in its listing of projects in the basin
- Does not necessarily represent all projects constructed or under
construction
- Lists NEPA actions on projects which may have been amended
substantially prior to construction where the Grant No. cannot be
relied upon to give positive identification to a project.
Of the list of 15 projects, one project (Summit Township-C262899) is
located in Mason County on the Shoreline of Lake Michigan some 150 to
200 miles away from the Saginaw River Basin. This leads one to
question whether or not there are Saginaw River Basin projects which
are listed in the wrong river basin or not listed at all. A brief
review of MDNR's MPL shows the following projects which may have had
NEPA actions taken:
Name Grant Number
Saginaw Co./Saginaw Twp. 263396
Saginaw Co./Richland Twp. 263104
Clare 262942
Midland 263416
Saginaw, City of 262723
Flushing 263115
Ithaca 263102
Bay Co./Portsmouth Twp. 263326
Saginaw Co./Zilwaukee, Carrollton 262723
Saginaw Co./Frankenmuth 262723
Saginaw Co./Buena Vista 262723
Wheeler Twp. 263324
North Star Twp. 263369
Clare Co./Hayes Twp. 262802
Midland Twp. 262917
Projects completed before 1984 would not be listed in the MPL so the
list could be longer. Upgrade of the City of Flint WWTP would be an
example.
- GIGS Transaction Number 92 represents "Percent WWT Construction
Complete." The code of "CP" is defined as "100% completion of the
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physical construction." This information appears inaccurate and
misleading. Of the 14 Saginaw River Basin projects, 9 were coded CP
while the remainder were supposed to be greater than 80% complete. In
fact, Genesee Co./Fenton-C262710, Genesee Co./Atlas-Goodrich-C262919,
Oakley-C262878 and Vassar-C262851 were found to have never started
construction.
Based on reviews of facilities plans at the offices of MDNR, even the
least complex projects may have had several facilities plans and/or
amended facilities plans prepared. In some cases, amendments
resulting in major alterations in a project have occurred after the
NEPA document was issued. Due to the manner in which records are kept
at both the MDNR and EPA, there appears to be no clear audit trail
between project inception and project conclusion; NEPA documents do
not clearly identify the facilities planning documents upon which they
are based. This would allow one to at least review the specific
project document(s) associated with a NEPA action.
Since major changes to a project can occur at several points between
issuance of the NEPA decision and the completion of construction
(i.e., prior to design, during design, during construction) there is
no certainty (other than through careful comparison of the NEPA docu-
ment/Facilities Plan project descriptions with the constructed
project) that the completed project observed during field data collec-
tion is the same NEPA project upon which impact predictions were
based.
Until preparation of the interim report, it was assumed by all
contractor staff that although the name of a project may be ambiguous
(i.e., 3 Genesee County projects listed), the specific project NEPA
documents could be positively identified by the EPA Project Number
(also called Grant Number). This apparently was not the case. In the
case of Genesee County-C262709, MDNR identified this project as
Burton/Davison. A Negative Declaration was obtained and a facilities
plan was reviewed. Each project identified by the listed grant
number. A field data collection visit was carried out and construc-
tion of the project was confirmed. Quite by accident, it was dis-
covered that another Genesee County project has the same number; that
being Expansion and Upgrading of the Anthony Ragnone WWTP. A check of
the EID Review Code and Date (GICS Column Ml) indicated a FNSI was
issued on 8/29/84, the date of the WWTP project FNSI. Thus, the GICS
listed project originally thought to be the Burton/Davison project
which had been completed, was later confirmed to be the WWTP upgrade
project, which is shown to be 91% complete but which, in fact, has
only begun construction.
Finally, other information provided on the GICS listing is at times
inaccurate. For example, the list shows construction start codes and
dates in column MO. Construction start dates occur before the FNSI
issuance date in eleven projects (extremely unlikely). At least 3 of
those projects were never constructed.
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In summary, the information provided on the GICS listing is not
completely reliable, and possibly incomplete. Reliance on GICS as a
major tool for project identification and baseline data gathering must
be done cautiously with an understanding of it's potential problem
areas.
Although the initial data collector was provided ample time for review
of the Manual and prototype reports, and had discussions with the
project manager regarding the task, results indicated that more
explicit and comprehensive instructions were required for review of
the NEPA documents and completion of the evaluation forms in order to
promote comprehensiveness and uniformity in the approach.
It was not initially clear from the Delivery Order that baseline data C
collection was to specifically include review of project facilities ,
plans. Task 3 states that EPA in-house NEPA documents are to be
supplemented, when necessary, with other related documents. The
phrase "when necessary" was initially interpreted to mean "in the
event NEPA documents were not available in EPA files". Thus, the MDNR
was contacted prior to the site visits regarding the Negative
Declarations not available form EPA. These were forwarded from the
State promptly, thus, a special trip to the MDNR was deemed
unnecessary. In addition, each field team was instructed to review
facilities plans or other NEPA related documents for additional
baseline information if they were readily available from their
contacts.
3.2.2 Field Data Collection
During discussions between SAIC staff and EPA, it was once stated by
EPA that the baseline data collection and field data collection should
be provided by different persons in order not to bias the field data
collection effort. Thus, in order not to bias the field data
collectors, it was thought that EPA intended them to work independent
of the baseline data collection. The program was set up in this
manner.
Approximately one week prior to field data collection another
discussion with EPA revealed that this was not intended; that it was
intended that the field data collectors have the baseline data
evaluation forms to work from. This caused some scheduling problems
at SAIC but the baseline data were completed based on the Negative
Declarations obtained and were sent the field data collection team
leaders for review prior to the site visits. In addition, copies of
the Negative Declarations were also sent, because with the baseline
data sheets alone, the teams would still have no idea what the project
consisted of, where construction took place or what type of impacts to
look for.
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Additional Comments;
- Little or no baseline data was available for evaluating the planning
area before construction. The facilities plans sometimes contain a
very general description of the site. The Negative Declarations some-
times allude to existing conditions, i.e., "the intent of the project
is to alleviate groundwater contamination or improve surface water
quality." These statements indicate a general degradation of water
quality.
o Sometimes, qualitative impacts of significance can be made such as
stating no groundwater or well contamination from sludge application
has occurred since the Health Department has received no complaints.
Similarly, assumptions can be made such as speculating that odor
problems have not increased since septic tanks are no longer in
operation.
'
Although the field data collectors had ample time to review the /
Delivery Order, (the Manual and the Prototype Reports) and to discuss
the task with the project manager, results indicate the need for a set
of very comprehensive and specific procedures in order to obtain con-
sistency and uniformity in the data collection effort and in the
completion of evaluation forms, between projects and between
individual teams.
Field Team Comments-Problem Areas Encountered During Site Investigations
The principle problem encountered during the field investigation stemmed
from the lack of quantified impacts as reported in the NEPA documents (Nega-
tive Declarations). Many of the impacts were presented in very general terms
("possible induced growth", "enhanced water quality"). This resulted in a
dilemma for the site survey team: Should the investigations perform a similar
qualitative evaluation or should they try to interpret a quantitative response
to the "qualitatively" identified impact? The method resulted in a "reinven-
tion of the wheel," so to speak, whereby the investigators would seek water
sampling data for periods prior to and after the project was performed. This
enabled the field crew to assess current conditions to determine indeed if
"enhanced water quality" resulted from the project.
3.2.3 Data Transcription and Processing
Several problems were encountered during the transcription of data onto
the evaluation form, the subsequent sorting of the data as requested in the
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D.O., uploading to the mainframe, and finally adjusting the data format to an
acceptable SAS format.
Data Transcription
o Consistency in data entry (i.e., by the research teams) is a serious (f)L,
problem. Project name, needs number, grant number, site location, 0
etc., were all completed in a different manner by each individual.
o Item 5 on the Evaluation Form is too vague. The order of the data
(i.e., State, river basin, county, etc.) is not specified, nor is the
exact phrase for each (i.e., State could be a 2 letter code, river
basin could be the river basin number).
o Item 5 should be separated into several distinct variables:
River Basin Code
State Code
County Code
Township
Hydrologic Code
This would permit sorting by these variables.
o Latitude/longitude for the exact plant location should be included.
o Issue and Parameter names were not entered in any consistent manner.
This complicates data sorting and possible merging.
o Item 9-Source of NEPA document data, needs to be lengthened for
adequate data entry.
o Item 10-Baseline Conditions: The reviewers often extended their
narrative paragraphs past the limit of 230 character spaces. The year
variable needs 4 spaces.
o Item 16-Regulations in Effect: This was not clear in the Manual as to
what EPA was looking for, or why, following conversations with EPA.
o Title and Location of Narrative Report needs either greater space or
more specific information for the available space.
Data Processing
«
o Uploading - The uploading of the data from the dBase III format to the
mainframe required splitting the data into character lengths of 130
characters. This required more time and program complexity than
expected.
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SAS Formatting and Printing - The creation of SAS data sets required
several hours of programming to design a suitable format statement.
In printing the data, only 100 characters at a time can be listed for
a single variable. This implies that the paragraphs for items 8, 10,
11, 12, 13, and 15 should only contain 100 spaces for data descrip-
tion. Additional information will be truncated and not printed. To
print all of the 230 character spaces, the paragraphs were arbitrarily
split at 100 and reprinted as 2 variables.
Data Analysis
The analysis of this data is hampered by the lack of consistency in data
entry, the imprecision of the variables (Ex. item 5), and the use of
paragraphs for storing information.
o Sorting - Data is sorted by the first character in a variable, there-
fore, variables such as item 5 are not useful for a sorting parameter.
o The program cannot sort as indicated in the D.O., by river basin,
State, and latitudinal/longitudinal coordinates. The D.O. also
requests sorting the data by all items on the evaluation form. This
can physically be done, but it would not produce a usuable result.
For example, the paragraphs would only be sorted by the first
letter(s) in the paragraph.
o The extreme length of the single observations (i.e., one evaluation
form equals one observation) requires breaking up the data into many
separate components for analysis. This is especially bothersome with
the paragraphs. The printing of this data is subsequently a messy
output.
—.--
The evaluation form at the present time is really more suited to word
processing use than mainframe or microcomputer usage. If the form is
only to be printed out verbatum, then a Lexitron Word Processor is far
more cost-effective than the awkward programming and limited analysis
possible at the present time.
3.2.4 Manual Review
The Manual for Evaluating Predicted and Actual Impacts of Construction
Grants Projects provide an adequate first cut at compiling the information
necessary to begin an environmental analysis. Some general comments
concerning the Manual's ease of use, clarity, and scope are provided to aid
further discussions towards future revisions or addendums:
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o The Issues chapters are somewhat long and, particularly in the case of
water quality, mislead the reader into thinking that an extensive
analysis is required.
o The language should be more specific and direct. The use of the
phrase "may be necessary", is misleading. Is it or isn't it necessary
to retrieve the data in question?
o Types of analysis suitable for each issue should be outlined or
references cited; it is not clear where the evaluation process is
heading.
o The Data Base Report (Appendix A) is useful, but should these sources
of data always be contacted for each project? This would require a
fair amount of time and effort.
o The Data Base Management Appendix is inadequate and needs extensive
revisions. Obviously, that is part of the objective of this review
process.
o There is some difficulty in categorizing topics under the 12 issues.
Best judgment was used in deciding how secondary impacts, parameters
of issues, and interrelated issues should be categorized. Should
groundwater or well contamina££aa-aad^potential odor problems be
grouped as parameters of^ Solid WasteOwhen land application is the
practice? Or should theyTjr^ttffted-as an "Interrelated Issue"?
o The Manual appears to have beea_desjLgjned for, the^evaluation of larger
nroiects or it at least makes provisions for those types of evalu-
ations. This is why it is difficult to follow the procedures for
cTnal l<»i-,,p.niaj^Mi.fc:g. Many nf1" MJP issues are not relevant and much of the
data which is available and necessary to evaluate larger projects is
not available for the type we have been studying.
o Some difficulty was experienced in using one form to include data from
more than one literature source. The form does not really lend itself
to referencing several documents or quoting information from these.
o There is a general lack of quantitative data to base the evaluations
orH Present conditions were -Ql^e.ffln.t^ilire hasqd on the subjective ""*
opinions and observations of the contacted officials.
o No one issue was found harder to evaluate than others. The provided
information was the determining factor in the difficulty encountered.
o The Manual is unrealistic in terms of information availability and the
time required for data gathering, etc. The time required to follow
the manual point to point would be excessive.
0 Determining the latitudeigand^Longlt_ude of the plan of study area is
both time consuming and an apparent waste of effort in contrast to the
other requirements.
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The physical environment anc
are difficult to follow.
inadequate when one cons!
fnergy issues as presented in the manual
found the physical environment chapter as
the typical POTW.
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4.0 COMPARISONS
4.1 TRENDS
4.2 DIFFERENCES
This analysis will be provided in the final report.
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5.0 CONCLUSIONS AND RECOMMENDATIONS
5.1 BASELINE AND FIELD DATA COLLECTION
o GICS listing - che GIGS printout should be verified for accuracy for
all proposed projects. Project identification should involve both the
Grants number and the Needs number. Other projects not on the GICS
system should be Identified through State files.
o Baseline data collection should be guided with more specific criteria
and goals than stated in the Manual. The data requirements (i.e.,
data sources and contacts) should be clearly stated from the start.
o Baseline data collectors should also be available to participate in
the field investigations. The results of the initial data collection
should be provided to the field teams for verification and/or for
identification of additional unexpected information.
o Therefore, it is recommended that a set of very comprehensive and
specific procedures be developed to guide baseline data collection and
field investigation.
5.2 DATA TRANSCRIPTION
o Very specific guidance must be developed for completing the Evaluation
forms. Consistency in responses and concise descriptions will
alleviate many difficulties.
o Item 5 on the Evaluation should be divided into several variables:
River Basin Code, State Code, County Code (FIP's code), Township,
Hydrologic Code, and possibly even the STORE! code.
o Although it is not possible to use the latitude/longitude polygon, a.
single entry for the project's latitude and longitude may allow for
sorting by this variable - a FIP's code for county might provide an
adequate sorting variable.
o Several items need to be lengthened and standardized responses
developed, for example, data base reference.
o Paragraphs must be subdivided into 100 character spaces to alleviate
inaccurate counting and promote concise, terse responses.
Comments on the use of paragraphs for data analysis:
o Following the paragraph containing the predicted environmental
impact, provide a series of questions requiring only a terse
response (i.e., yes/no, check-off, etc.)
For example:
Was the project carried out? Y/N
If yes, did it have the expected results? Y/N
5-1
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If no, why not:
- Name about 8 (or so) broad categories with a 9th cateogry for
OTHER (provide a comment field for OTHER).
- Ask for the remaining information:
reviewers name
plant superintendent/manager
date of review
etc.
- Baseline and Actual Conditions paragraph could be subdivided
into specific topics, and then coded for yes/no, etc., type
responses.
5-2
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APPENDIX A
Field Investigation Reports and Narrative Reports
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APPENDIX B
SAS Data Listings
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