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Considering Cumulative Effects Under Nepa

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  • 1. Considering Cumulative Effects Under the National Environmental Policy Act Council on Environmental Quality January 1997
  • 2. PREFACE This handbook presents the results of research and consultations by the Council on Environmental Quality (CEQ) concerning the consideration of cumulative effects in analyses prepared under the National Environmental Policy Act (NEPA). It introduces the NEPA practitioner and other interested parties to the complex issue of cumulative effects, outlines general principles, presents useful steps, and provides information on methods of cumulative effects analysis and data sources. The handbook does not establish new requirements for such analyses. It is not and should not be viewed as formal CEQ guidance on this matter, nor are the recommendations in the handbook intended to be legally binding. ... 111
  • 3. EXECUTIVE SUMMARY The Council on Environmental Quality’s action on the environment. Analyzing cumula- (CEQ) regulations (40 CFR $$ 1500 - 1508) tive effects is more challenging, primarily be- implementing the procedural provisions of the cause of the difficulty of defining the geographic National Environmental Policy Act (NEPA) of (spatial) and time (temporal) boundaries. For 1969, as amended (42 U.S.C. $$ 4321 et seq.), example, if the boundaries are defined too define cumulative effects as broadly, the analysis becomes unwieldy; if they are defined too narrowly, significant issues may the impact on the environment which results be missed, and decision makers will be incom- from the incremental impact of the action pletely informed about the consequences of their when added to other past, present, and actions. reasonably foreseeable future actions regardless of what agency (Federal or non- The process of analyzing cumulative effects Federal) or person undertakes such other can be thought of as enhancing the traditional actions (40 CFR ~ 1508.7). components of an environmental impact assess- Although the regulations touch on every aspect ment: (1) scoping, (2) describing the affected of environmental impact analysis, very little has environment, and (3) determining the environ- been said about cumulative effects. As a result, mental consequences. Generally it is also critical federal agencies have independently developed to incorporate cumulative effects analysis into procedures and methods to analyze the cumula- the development of alternatives for an EA or EIS. tive effects of their actions on environmental Only by reevaluating and modifying alternatives resources, with mixed results. in light of the projected cumulative effects can adverse consequences be effectively avoided or The CEQ’S “Considering Cumulative Effects minimized. Considering cumulative effects is Under the National Environmental Policy Act” also essential to developing appropriate mitiga- provides a framework for advancing envir- tion and monitoring its effectiveness. onmental impact analysis by addressing cumu- lative effects in either an environmental assess- In many ways, scoping is the key to analyzing ment (EA) or an environmental impact statement cumulative effects; it provides the best oppor- (EIS). The handbook presents practical methods tunity for identi&ing important cumulative for addressing coincident effects (adverse or effects issues, setting appropriate boundaries for beneficial) on specific resources, ecosystems, and analysis, and identifying relevant past, present, human communities of all related activities, not and future actions. Scoping allows the NEPA just the proposed project or alternatives that practitioner to “count what counts.” By evalu- initiate the assessment process. ating resource impact zones and the life cycle of effects rather than projects, the analyst can pro- In their environmental analyses, federal perly bound the cumulative effects analysis. agencies routinely address the direct and (to a Scoping can also facilitate the interagency coop- lesser extent) indirect effects of the proposed eration needed to identi& agency plans and other v
  • 4. actions whose effects might overlap those of the the success of mitigation measures is critical. proposed action. Adaptive management provides the opportunity to combine monitoring and decision making in a When the analyst describes the affected en- way that will better ensure protection of the vironment, he or she is setting the environmental environment and attainment of societal goals. baseline and thresholds of environmental change that are important for analyzing cumulative Successfully analyzing cumulative effects effects. Recently developed indicators of ecolog- ultimately depends on the careful application of ical integrity (e.g., index of biotic integrity for individual methods, techniques, and tools to the fish) and landscape condition (e.g., fragmentation environmental impact assessment at hand. of habitat patches) can be used as benchmarks of There is a close relationship between impact accumulated change over time. In addition, assessment and environmental planning, and remote sensing and geographic information many of the methods developed for each are system (GIS) technologies provide improved applicable to cumulative effects analysis. The means to analyze historical change in indicators unique requirements of cumulative effects anal- of the condition of resources, ecosystems, and ysis (i.e., the focus on resource sustainability and human communities, as well as the relevant the expanded geographic and time boundaries) stress factors. Many dispersed local information must be addressed by developing an appropriate sources and emerging regional data collection conceptual model. To do this, a suite of primary programs are now available to describe the cum- methods can be used: questionnaires, interviews, ulative effects of a proposed action. and panels; checklists; matrices; networks and system diagrams; modeling; trends analysis; and Determining the cumulative environmental overlay mapping and GIS. As with project- consequences of an action requires delineating specific effects, tables and matrices can be used the cause-and-effect relationships between the to evaluate cumulative effects (and have been multiple actions and the resources, ecosystems, modified specifically to do so). Special methods and human communities of concern. Analysts are also available to address the unique aspects must tease from the complex networks of possible of cumulative effects, including carrying capacity interactions those that substantially affect the analysis, ecosystem analysis, economic impact resources. Then, they must describe the re- analysis, and social impact analysis. sponse of the resource to this environmental change using modeling, trends analysis, and This handbook was developed by reviewing scenario building when uncertainties are great. the literature and interviewing practitioners of The significance of cumulative effects depend on environmental impact assessment. Most agen- how they compare with the environmental base- cies that have recently developed their own line and relevant resource thresholds (such as guidelines for analyzing cumulative effects recog- regulatory standards). Most often, the historical nize cumulative effects analysis as an integral context surrounding the resource is critical to part of the NEPA process, not a separate effort. developing these baselines and thresholds and to This handbook is not formal guidance nor is it supporting both imminent and future decision- exhaustive or definitive; it should assist practi- making, tioners in developing their own study-specific approaches. CEQ expects that the handbook Undoubtedly, the consequences of human (and similar agency guidelines) will be updated activities will vary from those that were pre- periodically to reflect additional experience and dicted and mitigated. This will be even more new methods, thereby, constantly improving the problematic because of cumulative effects; there- state of cumulative effects analysis. fore, monitoring the accuracy of predictions and vi
  • 5. new methods, thereby, constantly improving the designing mitigation, Table E-1 illustrates how state of cumulative effects analysis. the principles of cumulative effects analysis can be the focus of each component of the NEPA The handbook begins with an introduction to process. Chapter 5 discusses the methods, tech- the cumulative effects problem and its relevance niques, and tnols needed to develop a study- to the NEPA process. The introduction defines specific methodology and actually implement eight general principles of cumulative effects cumulative effects analysis. Appendix A provides analysis and lays out ten specific steps that the summaries of 11 of these methods. NEPA practitioner can use tQanalyze cumulative effects. The next three chapters parallel the Cumulative effects analysis is an emerging environmental impact assessment process and discipline in which the NEPA practitioner can be discuss analyzing cumulative effects while (1) overwhelmed by the details of the scoping and scoping, (2) describing the affected environment, analytical phases. The continuing challenge of and (3) determining environmental conse- cumulative effects analysis is to focus on impor- quences. Each component in the NEPA process tant cumulative issues, recognizing that a better is the logical place to complete necessary steps in decision, rather than a perfect cumulative effects cumulative effects analysis, but practitioners analysis, is the goal of NEPA and environmental should remember that analyzing for cumulative impact assessment professionals. effects is an iterative process. Specifically, the results of cumulative effects analysis can and should contribute to refining alternatives and Table E-1. Incorporating pdnclples of cumulative effects analysis (CEA) into the components of environmental Impact assessment (EIA) EIA Components CEA Principles jcoping q Include pad, present, and future actions. q include all federal, nonfederal, and private actions. q Focus on each affected resource, ecosystem, and human community. q Focus on truly meaningful effects. Describing the Affected Environment q Focus on each affected resource, ecosystem, and human community. q Use natural boundaries. determining the Environmental Consequences q Address additive, countervailing, and synergistic effects. q Look beyond the life of the action. q Address the sustainability of resources, ecosystems, and human communities. vii

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