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UBC Theses and Dissertations

Environmental impact statements : a study of content requirements and several assessment methods DeAngelis, Michael Vincent 1974

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ENVIRONMENTAL IMPACT STATEMENTS - A STUDY OF CONTENT REQUIREMENTS AND SEVERAL ASSESSMENT METHODS by MICHAEL VINCENT DEANGELIS B.Sc. C a l i f o r n i a State University at Sacramento, 1972 A THESIS SUBMITTED IN PARTIAL FULFILMENT OF THE REQUIREMENTS FOR THE DEGREE OF MASTER OF SCIENCE i n the School of Community and Regional Planning We accept t h i s thesis as conforming to the required standard THE UNIVERSITty OF BRITISH COLUMBIA September, 1974 In presenting th i s thes is in pa r t ia l fu l f i lment of the requirements for an advanced degree at the Univers i ty of B r i t i s h Columbia, I agree that the L ibrary sha l l make it f ree ly ava i lab le for reference and study. I fur ther agree that permission for extensive copying of th i s thesis for scho la r l y purposes may be granted by the Head of my Department or by h is representat ives . It is understood that copying or pub l i ca t ion of th i s thes is f o r f i n a n c i a l gain sha l l not be allowed without my wri t ten permission. DepartmeWP°of0F C O M M ™ 1 1 ? AND REGIONAL PLANNING The Univers i ty of B r i t i s h Columbia Vancouver 8, Canada Date SEPTKMBEK ABSTRACT Environmental impact statements (EIS) have been required i n the U.S. since the National Environmental P o l i c y Act was signed into law on January 1, 1970. Although no l e g a l requirement e x i s t s i n Canada, i n December of 1973 the f e d e r a l government announced a p o l i c y of preparing an EIS for a l l "major" projects having " s i g n i f i c a n t " e f f e c t on the envi-ronment . The evolution of the EIS requirement i n the U.S. indicates the major purpose of impact statements i s to produce information concerning the f u l l important consequences of a proposal to relevant government agencies, the intere s t e d p u b l i c and to decision-makers so that each per-son can reach a r a t i o n a l decision about the s o c i a l worth of the intended project. The ultimate objective of impact reports and a concomitant pu b l i c and government agency review process i s to f a c i l i t a t e more s o c i a l l y r a t i o n a l decisions about proposed pr o j e c t s . The methodology i n t h i s study involved developing a set of c r i t e r i a based upon the l i t e r a t u r e to determine whether an EIS has adequately pro-vided the kind of information i n a manner necessary to f u l f i l l i t s intended purpose. Five impact statements were c r i t i c a l l y reviewed and discussed i n l i g h t of several methods proposed f o r assessing environmental impact. The more important shortcomings i d e n t i f i e d i n the environmental reports were thereby i s o l a t e d and analyzed. The following general shortcomings were i d e n t i f i e d i n f i v e impact statements c r i t i c a l l y reviewed: 1) There was some d i f f i c u l t y i n comprehensively i d e n t i f y i n g a l l important s o c i o - c u l t u r a l and e c o l o g i c a l impacts 2 ) Not enough information was always provided so that the reader could value the importance of an i d e n t i f i e d impact 3) In some cases an adequate discussion of the curtailment of future b e n e f i c i a l uses of the environment was not completed 4 ) An analysis of a l t e r n a t i v e s was not completed adequately i n a l l impact reports 5) A l l impact reports had c h a r a c t e r i s t i c s which would hinder the communication of information to readers These shortcomings were generally discussed i n reference to d i f f e r -ent environmental assessment methods. Three basic conclusions r e s u l t e d : 1) A comprehensive c h e c k l i s t of impacts should be part of any impact evaluation method used by an agency i n order to ensure that a l l important consequences of proposals are i d e n t i f i e d . Networks are the most comprehensive type of c h e c k l i s t because they l i n k causal actions to primary, secondary and mu l t i p l e -order impacts. 2 ) Evaluation methods which mold economic, s o c i o - c u l t u r a l and e c o l o g i c a l impacts into common units f or comparison should not be u t i l i z e d as a basis for preparing an EIS. These methods judge the importance of each impact for the reader, which i s contrary to the main purpose of impact reports. 3) Most evaluation methods i d e n t i f i e d i n t h i s study do not provide guidance i n preparing the environmental impact report i t s e l f . These evaluation methods would not resolve at l e a s t three shortcomings of the impact statements c r i t i c a l l y reviewed. Therefore, the recommendations of t h i s study consist of EIS pre-paration guidelines that enable persons preparing the environmental impact report to avoid the shortcomings which were i d e n t i f i e d i n the t h e s i s . These guidelines r e l a t e to the following s i x points: 1) The purpose and scope of an EIS 2 ) Integrating impact reports into the planning process . 3) Recommendations concerning the development of impact check-l i s t s 4 ) An evaluation approach which defines impacts i n separate quantitative and c e r t a i n key q u a l i t a t i v e terms - i i i -Several general considerations and a method of summarizing an EIS i n order to f a c i l i t a t e impact communication A f l e x i b l e and general EIS format which l i s t s most of the important requirements of an impact report - iv -TABLE OF CONTENTS Page ABSTRACT ' .. .. • . ... i i LIST OF TABLES ....... . v i i i LIST OF FIGURES ix ACKNOWLEDGEMENTS .... . x i PART ONE CHAPTER ONE - BACKGROUND 2 INTRODUCTION 2 Organization of Thesis . ... .. 3 Assumptions and Limitations 4 THE EVOLUTION OF ENVIRONMENTAL IMPACT STATEMENTS 6 Early Project Evaluation Planning - Water Resources Planning v .. 6 Changing Social Values - The Environmental Movement 9 The Congressional Development of NEPA 13 The Rationale for Requiring Environmental Impact Statements. 15 The Existing EIS Process ., ..• I 7 Environmental Impact Assessments in Canada 19 CHAPTER TWO - ESTABLISHING CRITERIA FOR EVALUATING ENVIRONMENTAL IMPACT STATEMENTS . 24 INTRODUCTION . 24 What i s Environmental Impact? 25 The Role of the EIS in Decision-Making 28 CONTENT REQUIREMENTS FOR ENVIRONMENTAL IMPACT STATEMENTS .. 28 Existing EIS Requirements in the U.S 28 Environmental Impact Statements and the Courts 32 ESTABLISHING IMPROVED STANDARDS FOR IMPACT STATEMENTS . 34 Categories of Environmental Factors 35 Economic Efficiency . ... .. 35 The Problem of Assigning Importance to Environmental Impacts 39 Socio-Cultural Impacts • 43 Ecological Impacts 43 Distributional Consequences 44 Analysis of Alternatives 45 Relationship to Established Goals 46 Communication of Information 47 SUMMARY CONCLUSIONS .. 48 - v -CHAPTER THREE - THE STATE OF THE ART IN ENVIRONMENTAL IMPACT ASSESSMENT • • • 53 INTRODUCTION 53 LAND CAPABILITY OR SUITABILITY ANALYSIS 54 METHODS FOR IMPACT IDENTIFICATION ONLY •.. 57 Multiple Effects Networks 57 METHODS AGGREGATING IMPACTS INTO COMMON UNITS 58 U.S. Geological Survey Matrix 59 Energy Network Diagrams . .. 63 An Optimum Pathway Matrix Analysis Approach 64 Battelle Columbus Methods ..... 68 Effects Chains . .... 70 Computer Modelling For Environmental Impact 74 METHODS SEPARATING UNITS OF MEASURES AND QUALIFYING IMPACTS ... 76 U.S. Water Resources Council Principles and Standards 76 U.S. Atomic Energy Commission EIS Preparation Guidelines ... 78 DISCUSSION AND CONCLUSIONS 80 PART TWO CHAPTER FOUR - A CRITICAL REVIEW OF FIVE ENVIRONMENTAL IMPACT STATEMENTS ( • • . 84 - INTRODUCTION 84 THE SEVEN MILE HYDROPOWER PROJECT 85 Brief Description of Proposed Action and Environmental Setting 85 Non-Compliance With Criteria 89 THE COLSTRIP GENERATION AND TRANSMISSION PROJECT 95 Brief Description of Proposed Action and Environmental Setting 96 Non-Compliance With Criteria 99 THE NORTHWEST ALLOYS MAGNESIUM PLANT • 105 prief Description of Proposed Action and Environmental Setting .... 106 Non-Compliance With Criteria 109 THE PORTLAND INTERNATIONAL AIRPORT RUNWAY EXTENSION 112 Brief Description of Proposed Action and Environmental Setting . 113 Non-Compliance With Criteria 116 THE WASHINGTON STATE ROUTE 82 FREEWAY • .. 119 Brief Description of Proposed Action and Environmental Setting 119 Non-Compliance With Criteria 122 CONCLUSIONS • . 130 - v i -CHAPTER FIVE - RELATING IMPACT STATEMENT SHORTCOMINGS TO IMPACT ASSESSMENT METHODS .... • • • 133 INTRODUCTION .. ; 133 DISCUSSION ... ... 134 Comprehensive Identification of Socio-Cultural and Ecological Impacts 134 Importance Assignment j . . . . . 140 Short-Term Vs. Long-Term Discussion of Impacts ....... ....... 146 Alternative Analysis 147 Communication of Information 148 CONCLUSIONS 151 CHAPTER SIX - GENERAL GUIDELINES FOR PREPARING ENVIRONMENTAL IMPACT STATEMENTS .'. 153 BACKGROUND . 153 Purpose and Scope of the Impact Statement 153 Integrating Impact Statements in the Planning Process 154 EVALUATING ENVIRONMENTAL IMPACTS 158 Impact Identification 159 Information Collection 160 PREPARATION OF THE ENVIRONMENTAL IMPACT STATEMENT 167 General Considerations 167 Format of the EIS 169 CONCLUSION • .• . .. 179 LITERATURE CITED 181 IMPACT REPORTS CRITICALLY REVIEWED 187 OTHER REFERENCES 188 APPENDICES • ' .. 191 - v i i -LIST OF TABLES Table T i t l e Page IV-1 A checklist summary of non-compliance with c r i t e r i a 88 for the Seven Mile Impact Studies IV-2 Checklist summary of non-compliance with c r i t e r i a for 98 the Colstrip generation and transmission project EIS IV-3 Summary benefits of the proposed Colstrip thermal 103 power development IV-4 Summary costs of the proposed Colstrip thermal power 104 development IV-5 Checklist summary of non-compliance with c r i t e r i a for 108 the Northwest Alloys Magnesium Plant EIS IV-6 Checklist summary of non-compliance with c r i t e r i a for 115 the Portland International Airport Runway Extension EIS IV- 7 Checklist summary of non-compliance with c r i t e r i a for 121 the Washington State Route 82 Freeway EIS V- l An example of a possible esthetic component of the Envi- 143 ronmental Quality Account for a hydropower development as guided by the U.S. Water Resources Council Principles and Standards V— 2 Results of a practical application of the Battelle EES 144 (early approach) to a proposed hydropower development VI- 1 A summary sheet including some economic, socio-cultural 170 and ecological impacts which could result from a proposed hydropower development VI-;-2 A proposed method of summarizing an analysis of alterna- 171 tives and three hypothetical alternative examples - v i i i -LIST OF FIGURES Figure T i t l e Page II- l An arrangement of the wide scope of potential envi- 27 ronmental impacts III- l A flow chart showing the recommended integration of an 60 environmental impact statement i n the process of planning an action III-2 A reduced matrix for a phosphate mining lease indicating 62 the magnitude and importance of actions on environmental elements III-3 Mean and confidence intervals for the evaluation of eight 67 highway route alignments III-4 The hierarchical structure of the Battelle Columbus envi- 68 ronmental evaluation system III-5 A scale to convert measurement of dissolved oxygen to an 68 environmental quality value III-6 An example of an environmental assessment tree used to 71 determine a component's environmental quality value III-7 A schematic example of a "chain of effects" resulting from 73 a change in a real world state III- 8 A matrix display of some factors to be considered in 81 selecting a methodology for use in environmental impact assessment IV- 1 The general study area for the Seven Mile Project EIS 87 IV-2 Location and general study area of the Colstrip thermal 97 power EIS IV-3 Location of the proposed Magnesium Plant at Addy, Wash. 107 IV-4 General location of the Portland International Airport 114 IV- 5 Location of the proposed interstate freeway section near 120 Prosser, Washington V- l A l i s t of nine methods for environmental impact assessment 135 and the technique used for impact identification - -ix -A reduced action/condition matrix with some p o t e n t i a l impacts of a proposed magnesium plant and mining operation Integrating p o l i c y and project impact statements into the planning/decision-making process ACKNOWLEDGEMENT S Dr. William Rees and Professor Irving K. Fox provided helpful gui-dance and advice throughout this study. I am grateful for the comments they offered and the time they devoted to this thesis. My wife Leda completed the graphics and some of the preliminary typing i n this study. In a more subtle but meaningful way she also helped by being patient during the many hours I spent working on this thesis. x i -PART ONE 1 chapter one background INTRODUCTION Since the U.S. National Environmental Policy Act (NEPA) was signed into law on January 1st, 1970 more than 4000 environmental impact statements have been completed by federal agencies and f i l e d with the Council on Environmental Quality (U.S. Council on Environmental Quality, 1973a). Although the sheer number of impact statements completed by public agencies seems impressive, the vague nature of the EIS requirement (see Appendix A, section 102(2) (c) or page 28) has affected the quality of environmental reports being produced in the U.S. In a review of 76 environmental impact statements completed for proposed highway projects, Sullivan and Montgomery (1971) cite numerous examples of the inadequacy of these reports*, concluding that solid environmental data at the local level is supplanted by opinions, gener-a l i t i e s and assurances. The nebulous nature of section 102(2) (c) of NEPA and U.S. government recommendations for preparing environmental impact statements:has caused more than 150 adjudications in federal courts (Anderson, 1973). Further, Gillette (1972) has noted "... that j u d i c i a l rulings and consequent delays of pipelines, power plants, and dams have *For example, the results of this study of environmental impact statements showed that: 13 percent did'not mention the problem of air pollution, 34 percent failed to consider the issue of community disruption, 44 percent did not discuss the disposition of citizen comments, 58 percent did not consider problems related to increased urbanization, etc. - 2 -- 3 -been based on what the courts found to be cursory, slanted, or otherwise inadequate environmental impact statements." The ultimate goal of t h i s thesis i s to contribute to the state of the art i n developing an environmental impact statement that w i l l serve adequately to .disclose the consequences of a proposed action. I t i s hoped that such an o p t i m i s t i c goal can be more or l e s s reached by achieving the following objectives: 1) to review and analyze a sample of t y p i c a l major project evaluations (environmental impact statements); 2) to analyze and assess some of the p r a c t i c a l advantages and disadvantages of several methods which have recently been advanced for evaluating the environmental impact of a proposed action; 3) through a synthesis of the previous two obj e c t i v e s , to derive a l i s t of general requirements f o r environmental impact statements. ORGANIZATION OF THESIS The t h e s i s i s divided into two main parts. The f i r s t chapter provides the background for the remainder of the thesis and defines the r a t i o n a l e f o r re q u i r i n g environmental impact statements by h i s t o r i c a l l y t r a c i n g a number of circumstances which are believed to be responsible for t h i s component of the National Environmental P o l i c y Act i n the U.S. Both changing s o c i a l values as exemplified by the "environmental movement" and the concomitant r e a l i z a t i o n of the l i m i t e d u t i l i t y of benefit/cost analysis as an information t o o l f o r decision-makers are discussed i n t h i s chapter as two main causes of the environmental impact statement requirement. The purpose of Chapter Two i s to e s t a b l i s h a set of standards which a l l environmental impact statements should meet. These standards are - 4 -l a t e r used as c r i t e r i a to review several recently completed environmental impact statements. The t h i r d chapter completes the f i r s t part of the thesis by provid-ing a d e s c r i p t i v e review of methods which have been developed to assess the consequences of a proposed project. No attempt i s made i n t h i s chapter to c r i t i c a l l y discuss these procedures. Chapters Four, Five and Six comprise the second part of t h i s t h e s i s . Chapter Four c r i t i c a l l y reviews several environmental impact statements according to the c r i t e r i a established i n chapter two. Chapter Five then generally discusses the environmental impact evaluation methods described i n chapter three i n r e l a t i o n to the shortcomings of the impact statements c r i t i c a l l y reviewed. The f i n a l chapter concludes the thesis by l i s t i n g recommendations which might help improve the state of the art i n preparing environmental impact statements. ASSUMPTIONS AND LIMITATIONS There are a number of assumptions and l i m i t a t i o n s which e x i s t as part of t h i s thesis and should therefore be mentioned i n order to define f a i r l y the foundation upon which the analysis and subsequent conclusions have been b u i l t . The c r i t e r i a established i n t h i s study f o r evaluating environmental impact statements are based upon two underlying assumptions. These assumptions r e f l e c t the r a t i o n a l i z e d but the subjective views of the wri t e r ; that i s , a rather o p t i m i s t i c outlook e x i s t s i n t h i s study concerning the r o l e of impact statements i n d i s c l o s i n g the f u l l environmental e f f e c t s of a proposed action. Although presently the energy c r i s i s has taken some - 5 -of the importance out of the growing role of impact statements in the U.S., jud i c i a l review of the requirements of NEPA since 1970 has strengthened and increased the significance of the EIS as a mandatory information generation requirement for decision-making. Therefore, i t is assumed that the environmental impact statement i s an important tool for decision-makers which requires a comprehensive consideration of the important environmental consequences of a proposed action in order to achieve the role of the EIS set forth in this thesis. Conversely, i t i s realized that the degree of detail necessary in identifying the impacts of an action changes depending upon the magnitude and importance of the project. As a result, the set of cr i t e r i a used i n this study are established to be practical and equitable standards which a l l environmental impact statements could feasibly meet. Consequently, a second assumption i s that these standards can be attained by entities preparing impact statements according to the existing EIS process in the U.S. and within the present p o l i t i c a l milieu. Both the EIS process and p o l i t i c a l circumstances can affect the quality of an impact report, but i t i s f e l t that i f an EIS does not meet the c r i t e r i a established then the preparing agency is not taking f u l l responsibility in achieving the purposes of this requirement. As in many other studies this thesis was also limited in the amount of time and other resources which could be devoted to i t . Nevertheless, a vigorous attempt has been made to achieve the original objectives of this thesis. Due to the extremely broad scope of this study during a time when considerable work has been and continues to be produced concerning this subject, two additional limitations are an inherent part of this thesis. - 6 -F i r s t , only a few EIS's have been c r i t i c a l l y evaluated according to the c r i t e r i a established in chapter two. Since a s t a t i s t i c a l l y reliable sample was not taken, the adequacy of environmental statements presently being produced is not determined in this study. Second, the environmental impact assessment methods described in chapter three were not thoroughly tested to define their pros and cons. Rather, only a few methods were incompletely tested in order to yield general conclusions which were considered in preparing the f i n a l chapter of recommendations. THE EVOLUTION OF ENVIRONMENTAL IMPACT STATEMENTS EARLY PROJECT EVALUATION PROCEDURES — WATER RESOURCES PLANNING An examination of early U.S. Water Resources Planning shows the historical development of procedures which attempt to evaluate whether a proposed project socially merits public investment. The predominance of benefit/cost analysis indicates the economic emphasis prevalent during this time. Although the idea of benefit/cost analysis can be traced back into the nineteenth century, the f i r s t requirement of i t s use was in the Flood Control Act of 1936 which established the criterion that "the benefits to whomsoever they may accrue (be) in excess of the estimated costs" (Pearce, 1971). Since this Act did not establish detailed guidelines for preparing a benefit/cost analysis, public agencies responsible for water resources development initiated separate procedures for implementation of this require-ment. The confusion which resulted eventually led to the "Green Book" of 1950 (later revised in 1958) which was completed by a special interagency subcommittee established to develop c r i t e r i a for benefit/cost measurement - 7 -(Marglin, 1967). Despite t h i s report, evaluation standards were not implemented u n t i l the U.S. Bureau of the Budget (1952) issued a memorandum i n i t i a t i n g procedures through which water resource project plans would be reviewed. Probably the f i r s t attempts re q u i r i n g the consideration of non-economic e f f e c t s involved with a proposed action was, s u r p r i s i n g l y , during the same year as the Flood Control Act i n i t i a t e d benefit/cost analysis as a project evaluation device. G i l b e r t White (1972) has mentioned both the establishment of an agency review process of proposed federal actions and the development of a s p e c i a l study team as experiences i n Water Resources Planning which led to the early consideration of environmental e f f e c t s . In 1936 President Roosevelt required that a l l U.S. fede r a l agencies under-taking projects i n land drainage or water storage report t h e i r upcoming programs to the National Resources Committee and provide an opportunity for c r i t i c a l comment to a l l interested public agencies. This requirement was intended to force agencies to take into account the e f f e c t s of proposed projects on w i l d l i f e , f i s h e r i e s and pu b l i c health. Although the procedure i s somewhat s i m i l a r to the e x i s t i n g strategy of EIS review, i t was required much l a t e r i n the decision-making process and resu l t e d i n a f u t i l e planning e f f o r t . In 1944 a more f r u i t f u l review process was developed when the revised Flood Control Act was signed into law. This trend of agency review continued i n 1946 with the implementation of an amendment to the F i s h and W i l d l i f e Coordination Act. This amendment required that any agency authorizing a water project "consider" the e f f e c t s of the action on w i l d -l i f e resources by contacting the responsible f e d e r a l and state f i s h and - 8 -w i l d l i f e e n t i t i e s . Any reports and recommendations submitted by these conservation agencies were required to be included as part of the o v e r a l l report on the water project. Perhaps the most intensive early e f f o r t i n d i s c l o s i n g the f u l l environmental e f f e c t s of an action was by an inter-governmental team for the Grand Coulee Dam project on the Columbia River. This j o i n t i n v e s t i g a -t i o n eventually disclosed 27 d i f f e r e n t problems associated with the project, but was not i n i t i a t e d u n t i l a f t e r construction had already begun. The studies were completed i n 1945 and established the basis for planning subsidiary a c t i v i t i e s r e l a t e d to the Grand Coulee Dam. Unfortunately, the i n v e s t i g a t i o n did not set the stage for further development of studies of s i m i l a r scope i n future water resource plans and programs (White, 1972). Up to t h i s point, i t has only been mentioned that the treatment of non-economic factors i n Water Resource projects was l e f t to a governmental review process or to a s p e c i a l l y assigned inter-governmental team. Although i t was r e a l i z e d that unquantifiable e f f e c t s of a proposed action can also be important, the tendency at that time was to formulate an economic approach to i t s valuation i n order to integrate i t into a benefit/cost r a t i o . The "Green Book" of 1950 (U.S. Subcommittee on Benefits and Costs, 1950) recommended that "Project e f f e c t s should be evaluated i n monetary terms to the maximum extent p r a c t i c a b l e . 1 1 On the other hand, the f u t i l i t y of t h i s e f f o r t f or many factors of the environment was also recognized by s t i p u l a t i n g that these "i n t a n g i b l e e f f e c t s w i l l need to be considered on a q u a l i t a t i v e b a s i s . " I t was not u n t i l 1962 that a decision-making foundation f o r consideration of the f u l l environmental e f f e c t s of water resources projects - 9 -was established when President Kennedy approved a statement of "Policies, Standards and Procedures in the Formulation, Evaluation, and Review of Plans for Use and Development of Water and Related Land Resources" (U.S. Water Resources Council, 1962) to be utilized by those agencies responsible for Water Resources Planning. This document (commonly known as Senate Document 97) has since been supplemented and revised several times by the Water Resources Council. At present, federal water resources planning util i z e s a method that includes a system of accounts which was devised in order to f a c i l i t a t e evaluation of alternative plans and projects in relation to national economic development, environmental quality, regional develop-ment and social well-being (U.S. Water Resources Council, 1973). CHANGING SOCIAL VALUES — THE ENVIRONMENTAL QUALITY MOVEMENT It has been hypothesized that the existing ecologic c r i s i s arose from a traditionally Western Judeo-Christian attitude of arrogance toward nature (White, 1967). Although others disagree with this sharp distinction between Western and Eastern attitudes (Tuan, 1968), the recent change in West-ern public sentiment towards the environment has caused i t s protection to become a major social issue in North America. Lynton Caldwell (1970) contends that public responsibility for environmental quality in the U.S. evolved from the three sociopolitical developments of conservation, public health and public aesthetics. Each of these social movements was separate in origin and hist o r i c a l l y matured into increased government influence in a l l three of these concerns. These developments eventually led to major government responsibilities in other areas of environmental protection. The underlying reasons why government entities are ju s t i f i e d in - 10 -having responsibility for environmental protection i s due to the public nature of environmental effects and the unperceived f i n a l results of individuals acting in their own behalf. Whereas an environmental conscience or "land ethic" developed and held by a l l individuals is the most ideal solution to environmental pollution, the long period of time i t takes social ethics to develop naturally delegates responsibility to government agencies (Leopold, 1949). The public nature of environmental effects and the often adverse social consequences of a person acting to maximize individual gain is probably best illustrated in an ar t i c l e by Garrett Hardin (1968) which describes a hypothetical scenario of a group of herdsmen sharing a common pasture. Since a rational individual tends to maximize personal benefits in comparison to personal costs, a herdsman w i l l add an additional animal to the pasture because he feels that the monetary gains he individually receives from selling the animal are greater than the overgrazing cost which is distributed to a l l herdsmen sharing the pasture. If a l l herdsmen behave in a similar rational manner they w i l l each add f i r s t one animal, then another and another until the carrying capacity of the f i e l d i s surpassed and ruin befalls each person. This analogy of the "Tragedy of the Commons" is a l l too evident when considering present-day pollution problems and provides the rationale for government responsibility in achieving and maintaining environmental quality. Changing social values have also indicated that there i s an increased desire among the public to influence decisions. This has been especially true in environmental quality issues. During the late 1960's and early 1970's a considerable number of environmental organizations were founded for educational and p o l i t i c a l purposes. Some of these newer organizations - 11 -include the Friends of the Earth, Zero Population Growth and the John Muir Society which each seek to represent their members in environmental controversies. Membership in large, established organizations also grew rapidly during this same time period. The five largest U.S. national environmental organizations — the National Wildlife Federation, the National Audobon Society, the Sierra Club, the Izaak Walton League of America and the Wilderness Society — grew in memberships by almost 33% in a period of only one year ending June 1, 1971 (U.S. Council on Environmental Quality, 1971a). As exemplified by the major focus of the environmental movement, increased participation in decision-making is desired by members of the public. In a publication which attempts to distinguish the role of perceptions and attitudes in natural resource policy making, Sewell (1970) mentions: The desire for more direct involvement in the decision-making process is also based upon the ethical consideration that people have a right to be at least consulted on decisions that affect them, and especially those which involve the expenditure of public funds or which impinge upon an individual's rights. More and more planning decisions, especially those concerned with environmen-t a l quality, are of this type in the resources management f i e l d . The increasing amount of public protest relating to the process of decision-making in this connection re-flects the dissatisfaction with the present means for expressing public views, (p. 125) As the environmental movement grew in strength during the late 1960's, environmental interest groups began to wield more p o l i c i t a l power. In the early 1970's approximately 126 Congressmen publicly identified themselves as a conservationist bloc (Wheeler, 1972). The results of this p o l i t i c a l power emerged as an increasing number of laws were passed -12 -by Congress to meet the challenge of improving the many diverse factors which contribute to environmental quality. The Congressional Research Service of the Library of Congress recognized 121 of 695 federal b i l l s signed into law during the f i s c a l year of 1970/71 as "environment oriented" (U.S. Council on Environmental Quality, 1971a). The basic subject of this thesis is one component of what is probably the most significant environmental law passed in the U.S. during this era of social reform. The essence of the National Environmental Policy Act of 1969 revolves around the following three factors: 1) The establishment of a national policy toward the environment with six broad goals to direct the federal government to achieve environmental quality. 2) The requirement that a l l federal agencies take environmental factors into account through a systematic interdisciplinary approach which includes the preparation of an environmental impact statement on proposals for legislation and a l l other federal actions significantly affecting the quality of the environment. 3) The establishment of the Council of Environ-mental Quality whose function i s to advise the President on environmental policy issues, inform Congress and the public of major environmental matters and to coordinate and assist federal agencies in f u l f i l l i n g the requirements of NEPA. The evolution of this law in Congress during 1969 might indicate that, contrary to the focus of this chapter, the environmental impact statement requirement in NEPA was not meant to be an important component of this Act. - 13 -THE CONGRESSIONAL DEVELOPMENT OF NEPA NEPA was not the f i r s t U.S. l e g i s l a t i v e proposal to e s t a b l i s h a national p o l i c y toward the environment. In 1959 "The Resources and Conservation Act" proposed a statement of nationa l p o l i c y concerning conservation, natural resources and the environment and also recommended the formation of a group of environmental advisors at a l e v e l s i m i l a r to the NEPA-established Council on Environmental Quality (Anderson, 1972). Although t h i s b i l l and subsequent s i m i l a r attempts during the mid-1960's were defeated, increasing p u b l i c support f o r the environmental movement induced two l e g i s l a t i v e publications during 1968 which l a i d the remaining groundwork f or NEPA. These reports (U.S. Subcommittee on Science, Research and Development of the House Committee on Science and Astronautics, 1968 and U.S. J o i n t House-Senate Colloquium, 1968) noted a lack of consideration of environmental factors i n governmental decision-making and also developed a p o t e n t i a l n a t i o n a l p o l i c y on the environment (Anderson, 1973). NEPA i n i t s f i n a l form was a c t u a l l y the product of several p o l i t i c a l compromises and a j o i n t Senate-House conference i n 1969. This conference was held because s i m i l a r b i l l s were introduced and passed i n the House of Representatives and the Senate at approximately the same time and then forwarded to the other branch of l e g i s l a t u r e f o r approval. Congressman D i n g e l l introduced the b i l l approved i n the House while Senator Jackson authorized a b i l l which eventually became NEPA. I t i s i n t e r e s t i n g to note that neither b i l l i n i t s i n i t i a l form included the EIS mandate f o r Federal agencies. Congressman Di n g e l l ' s proposal was merely another amend-ment to the F i s h and W i l d l i f e Coordination Act which would have created the Council on Environmental Quality (C.E.Q.) and established a terse - 14 -environmental policy statement. Senator Jackson's proposal would have established the C.E.Q. and provided the authority to the Department of the Interior for further environmental research, but did not mention a policy or "action forcing" provision although i t was known that he had made earlier attempts to organize support among his colleagues for an environmental policy. It has been mentioned that the reason Senator Jackson introduced such a simplified b i l l was to ensure that the proposal be sent to his Committee on Interior and Insular Affairs for revision rather than to Senator Muskie's Subcommittee on Air and Water Pollution (Anderson, 1973). This seems to be a li k e l y reason because of Senator Jackson's previous activities and also because of the testimony at the subsequent Senate Committee hearings of Lynton Caldwell, who often worked with Jackson and his staff (Andrews, 1972), which noted that a l l federal agencies should have responsibilities in environmental protection. . This testimony eventually led to the inclusion within this b i l l of the requirement of an environmental impact "finding" by the federal o f f i c i a l responsible for an action. This proposal and Congressman Dingell's b i l l were passed in their respective branch of Congress which set the stage for a House conference to coordinate this legislation. The resultant NEPA is very similar to Senator Jackson's modified proposal but included a slightly weakened national environmental policy and a strengthened impact statement requirement that was intended to force federal agencies to comply with this policy. It i s the establishment of this policy which can be considered a culmination of changing social values, while the implementation of the "action forcing" provision might best be viewed as the realization of the f u t i l i t y of a statement of desired national goals without the consideration - 15 -of sufficient and adequate information in the decision-making process. THE RATIONALE FOR REQUIRING ENVIRONMENTAL IMPACT STATEMENTS The previous discussion was intended to outline the circumstances important in influencing the rationale and evolution of the environmental impact statement requirement. A descriptive review of certain historical aspects of water resources planning shows an increasing dissatisfaction with the standard project analysis tool during this time because i t did not comprehensively identify a l l of the significant benefits and costs involved with the action. This realization induced several different attempts in water resources planning to resolve this problem. F i r s t , a review process with other government entities having expertise or interest in the project was implemented in order to identify objections to the proposal. It was f e l t that through such a process the diverse interests reflected by other agencies in government would define and communicate the adverse effects which were not adequately appraised during project planning. A second alternative attempted in water resources planning was to assemble an interdisciplinary team to evaluate problems associated with the action. Theoretically this would accomplish the same objective as the previous method but was economically feasible for only large projects because of the high degree of financing necessary for support. A third evaluative adjustment attempted in Water Resources Planning was to develop methods for molding non-economic effects into monetary values which could then be introduced into a traditional benefit/cost analysis. The results of this f i n a l endeavour was the development of a broad monetary and non-monetary benefit/cost analysis organized in a system of accounts comprised of - 16 -national economic efficiency, regional development, environmental quality and social well-being. The environmental movement of the 1960's and 70's focused on increasing government responsibility in pollution control. Powerful public support of environmental interest groups played an important part in the magnitude of this influence. The establishment of a national policy toward the environment was one major step in actions aimed at controlling environ-mental degradation in the U.S. In order to put teeth into this policy and to ensure that unquantifiable environmental amenities be given adequate consideration in decision-making along with economic factors, a major change in the federal decision-making process was implemented as one requirement of NEPA. As a result of i t s historical evolution, the main purpose of an environmental statement as defined by the U.S. Environmental Protection Agency (Harris, 1972) is to: ... disclose the environmental consequences of a proposed action, thus alerting the agency decision-maker, the public and ultimately Con-gress and the President to the environmental risks involved. An important and intended consequence of this i s to build into a Federal agency's decision-making process a continuing consciousness of environmental considerations. This, in turn, insures to the fullest extent possible that the agency direct i t s policies, plans and programs so as to meet national environmental goals. The means through which an environmental impact statement is to be produced is by an interdisciplinary agency impact evaluation team and an extensive public and government review process which includes open hearings i f the action i s deemed of significant importance to the public. Since i t is somewhat misleading in an analysis to separate a product from the - 17 -process which yields i t , a brief description of the existing EIS process in the U.S. w i l l be completed before attempting to establish environmental impact statement standards in chapter two. THE EXISTING EIS PROCESS The environmental impact statement process i n i t i a l l y begins with the requirement that a federal agency involved in a proposed "action" must prepare an environmental assessment report. An "action" i s defined as any recommendations or favorable reports relating to legislation (including for appropriations), any projects supported in whole or in part through federal contracts, grants or any other funding assistance, and any policy, regulations or procedure making (U.S. Council on Environmental Quality, 1973b). This environmental assessment report i s not considered an EIS. It i s prepared only for the purpose of determining whether an environmental impact statement is necessary to prepare. In Section 102(2) (c) of NEPA i t is required that an environmental impact statement be prepared for "... proposals for legislation and other maj or federal actions significantly affecting the quality of the human environment" (emphasis added). Thus, the decision of whether to prepare an EIS completely hinges upon the definition of the terms "major" and "significant". During the i n i t i a l 1 1/4 years NEPA was in effect, more than 30 court cases concerned the applicability of the EIS requirement to federal actions (Green, 1972). Revised guidelines established by the Council on Environmental Quality (1973b) mention that an EIS should be prepared for a l l actions "... the environmental impact of which i s li k e l y to be highly controversial and that the agency consider the induced - 18 -and o v e r a l l cumulative impacts of the action before defining i t s s i g n i f i c a n c e . The guidelines also mention the following three descriptors of what "major" actions can be considered " s i g n i f i c a n t : " 1) actions which degrade the q u a l i t y of the environment; 2) actions c u r t a i l i n g the range of b e n e f i c i a l uses of the environment; 3) actions which serve short-term to the d i s -advantage of long-term environmental goals. Obviously a precise d e f i n i t i o n of which actions require an EIS i s improbable i n a l l respects. As a r e s u l t , some d i s c r e t i o n remains with the agency proposing the action. Many fede r a l agencies have now developed t h e i r own guidelines for d i s t i n g u i s h i n g actions of s i g n i f i c a n t consequence which require the preparation of an EIS. If i t i s decided from the environmental assessment report and agency guidelines that an EIS i s not required, the agency can proceed with the proposed action merely by sending a negative declaration form to a l l interested agencies, i n d i v i d u a l s and i n t e r e s t groups. If the action i s considered s i g n i f i c a n t , the agency must prepare a d r a f t EIS. A f t e r completion of the d r a f t , i t i s required that copies be made a v a i l a b l e to f e d e r a l , state and l o c a l agencies, and that the p u b l i c be permitted to comment on i t . It i s at t h i s point i n the process that p u b l i c meetings are held by the lead agency, explaining both the proposed action and the draft EIS. It i s then required that no administrative action be taken concerning the project for 90 days. Based on the r e s u l t s of the public meeting and the written comments received, the agency prepares a f i n a l EIS. - 19 -The f i n a l EIS must also include a discussion of the comments received from private individuals, special interest groups and other public agencies. ENVIRONMENTAL IMPACT ASSESSMENTS IN CANADA Although not established as a legal requirement, environmental impact assessments in Canada have been completed for many large projects having significant impact on the environment in the past several years. Perhaps one of the most ambitious Canadian impact study attempts began in 1970 as part of an overall project by the Environmental Protection Board aimed at understanding and devising methods to mitigate the environmental effects of constructing and operating a natural gas pipeline through the Yukon and Northwest Territories. Conversely, environmentally significant actions such as the James Bay Hydropower Project have been planned, yet have not benefited from the findings which would have resulted i f a detailed environmental impact statement was prepared early in the planning/ decision-making process. Maasland et. a l . (1974) suggest that this lack of wholehearted support of government agencies to an impact assessment process has hindered meeting the f u l l potential for making socially rational decisions concerning proposed actions. In Canada, increasing concern has been expressed lately about the establishment of a required environmental impact statement process for government projects. A recent workshop on environmental impact assessments in Canada concluded that, although a standard format of environmental impact statement should not be required, a legal framework for requiring environ-mental impact assessments should be established (Environmental Protection Board, 1973). A major difference from the EIS process in the U.S. which - 20 -has been recommended in Canada (Environmental Protection Board, 1973 and Maasland et. a l , 1974) is the establishment of review boards to identify when an environmental impact statement should be prepared for a specific action. These review boards could exist at the federal and provincial levels of government, and have the potential to (Maasland, et. a l , 1974): 1) establish guidelines for environmental impact assessments; 2) review and evaluate impact reports; 3) f a c i l i t a t e public participation by making statements available to interested citizens and establishing procedures for public input; 4) provide from an environmental outlook recommendations concerning the project to approving agencies. In June of 1972, the federal government began the f i r s t step of a more formal impact statement requirement. At this time i t was announced that a l l federal government projects would be screened interdepartmentally for potential pollution effects. On December 20, 1973, the cabinet announced that this screening process would be expanded into an Environmental Assess-ment and Review Program to be administered by the Department of Environment. Recently, Environment Canada has announced procedures to implement this new policy (Canada Department of Environment, 1974). Thesewprocedures^would begin with a federal department or agency deciding whether an upcoming action has enough environmental impact to warrant a Preliminary Environmental Assess-ment Statement. If i t is decided by "sound judgement" that the proposal has "practically no environmental impact", then no preliminary assessment or contact with the Department of Environment is required. If the Preliminary Environmental Assessment Statement is necessary, i t must be - 21 -submitted to a Screening and Coordinating Committee that presently e x i s t s within Environment Canada. This preliminary environmental assessment statement must include the following seven points (Canada Department of Environment): 1) a desc r i p t i o n of the proposed action and i t s purpose; 2) an assessment of the e x i s t i n g conditions of the natural environment, the renewable resources and the s o c i a l and economic conditions i n the area surrounding the proposed action; 3) an estimate of the impact of the proposed action on the natural environment, the renewable resources and the s o c i a l and economic conditions; 4) proposed design, construction and operating procedures for the protection or enhancement of the environment; 5) an assessment of the long-term secondary impact of the proposed action - a r i s i n g from implementation; 6) a l t e r n a t i v e solutions considered; 7) an opinion as to whether the project can be c l a s s i f i e d as "major or having s i g n i f i c a n t impact" on the natural environment, renewable resources and on the human environment, or, on the other hand, as minor or not having s i g n i f i c a n t impact (pp. 6,7) In the event that the proponent decides through t h i s assessment that the project i s minor or with i n s i g n i f i c a n t impact and i f the Screening and Coordinating Committee agrees with t h i s conclusion, then the process ends and the project i s allowed to progress without delay. I f the opposite conclusion i s reached by the proponent or the Screening and Coordinating Committee disagrees or expresses doubt with t h i s d e c i s i o n , the preliminary assessment w i l l be passed to the newly established "Environmental Assess-ment Panel" which i s comprised of members of Environment Canada and one member of the proposing e n t i t y . This panel has the following f i v e functions - 22 -(Canada Department of Environment, 1974): 1) defining requirements in respect of general "base l i n e " environmental conditions for areas in which proposed actions are contemplated; 2) giving advice and guidelines to proponents undertaking environmental assessments; 3) reviewing those preliminary environmental assessment statements referred to i t by the Screening and Coordi-nating Committee and advising on what, i f any, future action is required; 4) managing, on behalf of the Minister of the Environment, the preparation and review of formal, detailed environ-mental assessments and prediction statements; 5) assisting the proponent in the incorporation of environ-mental design and procedures to implement i t s findings. (P- 8) If the project i s "major" or has "significant" impact a more formal and comprehensive environmental assessment statement must be prepared under the direction of the new panel. Based upon this more comprehensive environmental assessment statement, the panel can recommend that the proposal not be undertaken, request further studies or recommend alter-native solutions to problems, approve the action based on the adoption of "existing regulations, codes or guidelines", or simply approve the project. The f i n a l decision about the project in relation to these re-commendations remains with the proposing entity. In some cases, provincial interests can be represented on the existing panel or a special panel including members of the public with expertise in some f i e l d can be established for review purposes. This impact assessment and review process also allows for public hearings i f decided by the panel. It also requires that, unless "in the unusual event that ... the usefulness of the - 23 -proposed action or the environment i t s e l f may be jeopardized by premature disc l o s u r e " , copies' of a l l preliminary and formal environmental assessment statements be made a v a i l a b l e to the public (Canada Department of Environ-ment, 1974). chapter two establishing criteria for evaluating environmental impact statements INTRODUCTION Developing requirements that pertain to a l l possible actions which may require an EIS i s a d i f f i c u l t but worthy task. These require-ments must be general enough to address a wide range of actions presently meriting an environmental evaluation, whether the development of small campground near an urbanized area or the proposed construction of a serie s of large dams along a n a t u r a l , free-flowing watershed. Conversely, EIS requirements must be s p e c i f i c enough f o r meaningful use i n evaluating whether an impact statement has achieved i t s purpose. I t i s also r e a l i z e d i n t h i s respect that the r e l a t i v e magnitude and importance of an action influences the extent to which i t i s economically f e a s i b l e to i d e n t i f y the complex chain of p o t e n t i a l e f f e c t s (see discussion below defining environ-mental impact). The requirements set f o r t h i n t h i s chapter are based upon the purposes of an EIS, a d e f i n i t i o n of the term "environmental impact", e x i s t i n g general requirements established by the U.S. Council on Environ-mental Quality and several court decisions r e l a t i n g to NEPA. A f i n a l summary conclusion w i l l then concisely organize the previous discussion into a l i s t of c r i t e r i a which w i l l be used l a t e r i n t h i s thesis to evaluate the adequacy of several impact statements. - 2U -- 25 -WHAT IS ENVIRONMENTAL IMPACT? The foundation for developing requirements for environmental statements i s a very broad definition of the term "environment" i t s e l f . Often, the meaning of the terms environment and ecology have been confused with one another. The following distinction has already been made between these two terms (Bromley, et a l , 1971): Environment may be defined as the aggregate of a l l external conditions and influences affecting the l i f e and development of an organism; the key is the refer-ence to a specific organism such as man, a fish species, etc. Ecology is the study of mutual relation-ships between organisms and their environment. Hence, "environmental quality" or "environmental impacts" is usually associated with direct reference to man. (p. 32) This broad definition of "environment" has generally been supported by ju d i c i a l rulings. In Daly v. Volpe (U.S. Court of Appeals, 1972a) i t was rules for a highway project that an environmental impact statement does not comply with NEPA unless i t also l i s t s a l l the relevant economic costs involved with the proposed action. Another case (U.S. District Court, 1971a) ruled that an EIS concerning a proposed dam was not adequate until zoological studies were completed in the area affected by the action. In addition to these court rulings a number of federal intra-departmental EIS preparation guidelines have further interpreted NEPA's undefined "human environment" as also including existing social and cultural features (U.S. Army Corps of Engineers, 1972; U.S. Dept. of the Navy, 1970; et a l . ) . As a result, the expression 'environmental impact' has a meaning wide in scope, referring to the economic, ecological and socio/ cultural external conditions affected by a proposed action. A hierarchical T 26 -ordering of a wide range of potential environmental effects i s given in Figure One. Not only are the prospective environmental effects of an action extremely broad in character, but the relationships that exist between different components of the environment make i t impossible to completely identify a l l of the potential impacts. Environmental impacts result in secondary effects which further result in tertiary impacts (Sorensen, 1972). For example, i t may seem that the effects of developing a mount-ainous area for winter skiing are rather obvious. Some of these more conspicuous impacts include the effects of construction on soils and vegetation, and the resultant multiple-order consequences on wildli f e and water quality nearby. Also, in addition to these primary, physical and biological effects, the action may also result in economic and other more subtle impacts such as an improved economy in nearby towns, induced secondary commercial development which accompanies such growth, an i n -creased local permanent and transient population, and even the possibility of attracting other entrepreneurs in the development of recreational homesites. Not only does each of these related effects have multiple-order economic impacts, but each effect also has i t s own i n i t i a l and secondary physical, biological and social implications. Therefore, i t can be easily realized that the analysis of environmental impact does not merely involve calculating a simple cause and effect relationship, but i t also involves following a complex chain of cause/immediate effects/conse-quential effects/induced effects, etc., interconnections that can often result in what seems to be a never-ending stream of environmental impacts. ENVIRONMENTAL IMPACTS Ecology Species End Populations Terrestrial Browsers and grazers Crops Natural vegetation Pest species Upland game birds Aquatic Commercial fisheries Natural vegetation Pest species Sport fish Waterfowl Habitats and Communities Terrestrial Food web index Land use Rare and endangered species Spc.ies diversity Aquatic Food web index Rare and endangered species River characteristics Species diversity Ecosystems Descriptive only Environmental Quality | |- Aesthetics Water Pollution Basin hydrologic loss BOD Dissolved oxygen Fecal coliforms Inorganic carbon Inorganic nitrogen Inorganic phosphate Pesticides pH Stream flow variation Temperature Total dissolved solids Toxic substances Turbidity IL Air Pollution Carbon monoxide Hydrocarbons Nitrogen oxides Particulate matter Photochemical oxidants Sulfur oxides Other Land Pollution Land Use Soil erosion Noise Pollution Noise Land Geological surface material Relief and topographic character Width and alignment Air Odor and visual Sounds Water Appearance of water Land and water interface Odor and floating materials Water surface area Wooded and geological shoreline Biota Animals - domestic Animals - wild Diversity of vegetation types Variety within vegetation types Man-made Objects Man-made objects Composite Composite effect Unique composition Human Interest Ed u ca tion /Scien tific Archeological Ecological Geological Hydrological Historical Architecture and styles Events Persons Religions and cultures "Western Frontier" Cultures Indians Other ethnic groups Religious groups Mood/Atmosphere Awe-inspiration Isolation/solitude Mystery "Oneness" with nature Life Patterns Employment opportunities Housing Social interactions FIGURE I I - l . An arrangement of the wide scope of potential environmental impacts (fxom U.S. Army Corps of Engineers, 1972 and Dee et. a l , 1972} - 28 -Hence, what must basically be decided i s what environmental impacts should be included in an EIS. As discussed earlier in chapter one, this is presently a function of government agency guidelines, the size and importance of an action and a variable amount of discretion on the part of the entity undertaking the project. THE ROLE OF THE EIS IN DECISION-MAKING Clearly, the previous discussions indicate that ah EIS should be broad in scope, communicating the expected economic, socio/cultural, phy-sica l and biological consequences of the action/s to the public and decision-makers. It must be assumed at this point that decisions w i l l be made which reflect the information that has been generated in the EIS and the values expressed by the public. U.S. courts have recognized this necessity by mentioning that a "weighing" or "balancing" of economic or other benefits against environmental costs for each federal decision is an important mandate of NEPA (U.S. Court of Appeals, 1971a). CONTENT REQUIREMENTS FOR ENVIRONMENTAL IMPACT STATEMENTS EXISTING EIS REQUIREMENTS IN THE U.S. In order to simplify review and retain a certain degree of objectivity, the EIS requirements in the U.S. follow a standardized format which has been established by the Council on Environmental Quality and based upon the general requirements of NEPA. The National Environ-mental Policy Act of (Section 102(a) (c)) 1969 required that environmental impact statements discuss the following five general areas of concern: (i) the environmental impact of the proposed action; - 29 -(i i ) any adverse environmental effects which cannot be avoided should the proposal be implemented; ( i i i ) alternatives to the proposed action; (iv) the relationship between local short-term uses of man's environment and the maintenance and enhancement of long-term productivity; and (v) any irreversible and irretrievable commitments of resources which would be involved with the proposed action should i t be implemented. The Council on Environmental Quality established guidelines for a l l federal departments, agencies and establishments in order to implement the general requirements of NEPA. Most federal departments and agencies within these departments have also developed their own guidelines within the framework provided by the C.E.Q. which are often based upon the normal actions taken by the entity that apply to NEPA requirements. Since i t i s important i n this study to describe the existing required contents of an EIS in the U.S., the following few pages w i l l be a summary of the Council on Environmental Quality's May 2, 1973* guidelines that recommend certain content considerations. Description of Proposed Action Data included in the i n i t i a l section of the report should describe the action in such a way that reviewing agencies and the public can come to their own conclusion about the potential effects of the proposed project. Thus, the information included in the body of the statement should be non-*Since this thesis has been prepared i t has come to the attention of the author that the U.S. Council on Environmental Quality has revised their guidelines on August 1, 1973. - 30 -technical and perhaps supplemented by maps and diagrams when appropriate. Description of the Environmental Setting A description of the existing area affected by the action is a necessary part of an environmental statement. This section should be brief rather than detailed, although the amount of detail is dependent on the magnitude of the action and the amount of the information required at that level of decision-making (planning, f e a s i b i l i t y , design, etc.). The guidelines especially mention that accurate population and growth data, including an identification of assumptions from which jus t i f i c a t i o n for the project exists, should be included in this part of an EIS. Environmental Impact of the Proposed Action It is required that an agency consider the positive and negative national and international effects of the proposed action in this section of an environmental statement. The "nature, scale and location of the proposed actions" and the relative salience of i t s effects are the c r i t e r i a which help decide the degree of emphasis placed on explaining the potential impacts in an EIS. The following (adapted) l i s t i s included in the guide-lines to il l u s t r a t e factors of the environment which might deserve con-sideration in this section: 1) Air 6) Psychological Health and 2) Energy Well-being 3) Hazardous Substances 7) Transportation 4) Land Use and Management 8) Urban Factors 5) Noise 9) Water 10) Wildlife Not only primary but also secondary environmental impacts should be included in an EIS. Based upon court rulings since NEPA was implemented, - 31 -the revised guidelines also stressed the point that often the immediate effects of a proposed project are not as significant as the action's "induced" impacts, and thus the latter type of effects also should be considered in an environmental statement. Alternatives to the Proposed Action The revised guidelines of the Council on Environmental Quality have introduced the recommendations from a number of court decisions con-cerning the consideration of alternatives in an EIS. These guidelines mention that the environmental benefits and costs of a l l "reasonable" alternative actions should be identified "... in order not to foreclose prematurely options which might have less detrimental effects." The alternatives considered should not be limited only to those which can be undertaken by the proposing agency, and the analysis of each alternative should be a "rigorous exploration and objective evaluation" of i t s en-vironmental impacts. Examples of alternatives which might deserve consideration include":' the alternative of no action or postponement pending further study; alternatives of a completely different character which achieve similar objectives as the proposed project; and alternatives related to different designs or changed components of the existing proposal which would result in different environmental effects. This analysis of alternatives should be detailed enough to identify the tradeoffs that exist between options. Unavoidable Adverse Effects This section should be a brief summary of the detrimental impacts - 32 -which cannot be avoided i f the proposed action were to be implemented. Examples of such unavoidable adverse effects are "water or a i r pollution, undesirable land use patterns, damages to l i f e systems, urban congestion, threats to health," or other impacts contrary to the environmental goals setforth in NEPA. It is also mentioned that for purposes of contrast a discussion of impact mitigation measures which are part of the proposed action be included in this section. The Relationship Between Short-Term Environmental Uses and the Maintenance  and Enhancement of Long-Term Productivity Although this requirement does not refer to specific time periods, i t i s necessary that an impact statement briefly define the differences in the proposal between "short-term gains at the expense of long-term loses, or vice versa." Irreversible or Irretrievable Commitments of Resources The basic distinction made between this section and the previous requirement i s that this part of an impact statement should identify the "range of potential uses of the environment" which are irreversibly elimi-nated due to the unavoidable adverse effects of the intended action. The term "resources" is defined not only as economic factors but also as natural and cultural resources. ENVIRONMENTAL IMPACT STATEMENTS AND THE COURTS The rapid and growing case law associated with the National En-vironmental Policy Act has been quite remarkable since, in a l i t t l e more than three years there has been at least 150 court cases attempting to - 33 -further define this law (Anderson, 1973). . Only a few of these adjudica-tions w i l l be discussed because the majority of cases are related to problems that have since been resolved by the Council on Environmental Quality's revised 1973 guidelines or related to agency non-compliance with the requirement that environmental statements be prepared for a l l major federal actions significantly affecting the quality of the human environ-ment. As of April, 1972, only 5 of 64 cases before the courts relating to NEPA were in reference to the content of environmental impact statements (Young and Henson, 1973). Perhaps the most important ruling of the courts was briefly dis-cussed earlier concerning the broad definition of the term "environment." An environmental impact statement must consider a l l components of the "human environment" including physical, biological, economic and socio-cultural factors. In Environmental Defense Fund v. The U.S. Army Corps of Engineers (U.S. District Court, 1971a), the court mentioned that the en-vironmental statement concerning a proposed dam should have described the relevant existing food chains and ecologically v i t a l species in the affected area in order to later determine the diversity and relative bio-logical s t a b i l i t y of the area. The court also mentioned definite questions which were l e f t unanswered in the report relating to specific adverse consequences which could be potentially caused by the existence of the dam and to possibly induced population changes which also have related envi-ronmental effects. Conversely, the courts have also ruled that in many situations specific factors such as species names and specific archaelogical sites need not be mentioned in an EIS (U.S. District Court, 1971b). - 34 -Adjudications i n court have mentioned the need to consider d i f f e r e n t opinions i n valuing environmental e f f e c t s . This has been defined i n the Gillham Dam case (U.S. D i s t r i c t Court, 1971a) to require that a f i n a l EIS include the viewpoints of a l l members i n society regard-le s s of t h e i r t e c h n i c a l expertise or membership i n an organized group. In the Committee for Nuclear R e s p o n s i b i l i t y v. Seaborg (U.S. Court of Appeals, 1971) t h i s r e q u i s i t e to consider the opposing opinions of others was moderated to ensure that the q u a l i t y of information generated i n an EIS remains high. However, t h i s case also required that a l l "responsible" views must be included i n an impact statement and that s c i e n t i f i c opinion be considered as follows: ...The court i s not to r u l e on the r e l a t i v e merits of competing s c i e n t i f i c opinion. Its function i s only to assure that the statement sets f o r t h the opposing s c i e n t i f i c opinion and does not take the a r b i t r a r y and impermissable approach of omitting from the statement, and hence from the focus that the statement was intended to provide for the d e c i -ding o f f i c i a l s , any reference whatever to the existence of responsible s c i e n t i f i c opinions con-cerning possible adverse environmental e f f e c t s . ESTABLISHING IMPROVED STANDARDS FOR IMPACT STATEMENTS The Council on Environmental Quality's revised EIS guidelines contain content recommendations which d e f i n i t e l y should be included i n a l l environmental statements. It i s the opinion of the author that these r e -commendations could be improved to provide more guidance to e n t i t i e s responsible for preparing environmental statements because many important areas of concern i n an EIS are presently addressed by the guidelines at a l e v e l of generality that makes these suggestions somewhat unclear. General - 35 -suggestions are appropriate concerning a description of the proposed action and perhaps environmental setting, but such recommendations are not as helpful as could be in relation to the type of environmental effects which should be considered and the evaluation of identified impacts. By rearranging these established guidelines, providing more specific recom-mendations in certain areas and proposing the addition of a few other requisites which could improve the quality of environmental statements, a modified set of EIS standards is suggested. CATEGORIES OF ENVIRONMENTAL FACTORS For obvious reasons, i t i s necessary and appropriate that an environmental statement i n i t i a l l y include a description of the proposal and an inventory of the relevant, affected area of the action. In relation to considering the actual environmental effects of a proposal i t might be helpful to f a c i l i t a t e this analysis by suggesting general comprehensive areas of environmental concern. This w i l l not only help organize the format of the statement but w i l l also help direct consideration of a more comprehensive view of the term 'environment.' It has been chosen to disaggregate 'environment' into three separate parts. These groupings were chosen because they are easy to understand and also because they are each relatively distinct from one another in that different disciplines of knowledge can be isolated within each category. These three categories are economic efficiency, socio-cultural impacts, and ecological impacts. ECONOMIC EFFICIENCY In the past, the economic efficiency of a proposal has been - 36 -perhaps the most intensively considered consequence of public and private actions. As mentioned in chapter one, benefit/cost analysis has been required for federal water resources projects in the U.S. since the Flood Control Act of 1936 and i t s use continues to this day as the best planning tool to compute the economic efficiency of a large public project. It has been stressed throughout this chapter that the purpose of an EIS and a broad definition of the term 'environmental impact' requires that such a report also include a complete disclosure of the economic efficiency of the action. In Environmental Defense Fund v. Armstrong, the opinion was stated that a benefit/cost analysis is not needed in an impact statement. A basic reasoning behind this opinion is the well-founded fear that many agencies are dominated by economic interests which might result in the development of impact statements used to just-i f y social and ecological costs by an impressive and complicated analysis of monetary gains. On the contrary, i t is the opinion of the author that delegating the EIS to a role of 'just another report' of specific scope would only make the decision-making process more cumbersome and not really function to generate the information about an action in single, concise statement so that the public and decision-makers can reach an informed, rational judgement about the proposal. In Lathan v. Volpe a U.S. Dist-r i c t Court (1972a) agreed with this viewpoint by ruling that a benefit/ cost analysis i s a very legitimate component of an EIS. A similar opinion was also expressed in the Gillham Dan case. Consequently, i t i s fe l t that the review process, the establishment of EIS standards and other factors can combine to place an economic analysis in an impact statement on more equal terms with socio-cultural and ecological - 37 -considerations. It is also important that a l l major assumptions in the economic analysis be disclosed in an EIS so that the reader realizes the foundation are projected impacts. Perhaps the most important action in analyzing the economic efficiency of a project is in taking a proper accounting stance. This concept is probably best explained as an entity's outlook toward the benefits and costs of a proposed action. For example, the economic benefit/cost ratio of a federal water project to a local politician i s different than to the nation as a whole since his local viewpoint (accounting stance) emanates from his constituency. As a result each level of government has i t s own accounting stance concerning the i n c i -dence of these economic effects (Howe, 1971). Although i t may seem that the analysis of economic efficiency in an impact statement should address i t s e l f to the government level/s (i.e., local, Provincial or State, Federal) financing the action, problems can arise i f adverse economic effects extend beyond the jurisdiction of the government financing action. Thus, an economic analysis in an EIS should take an accounting stance that is most relevant to the prospective action. In many cases these monetary impacts have to be considered at a national or even inter-national level. Although i t is not meant to include guidelines for preparation of benefit/cost analysis in this paper, since i t is urged that this method of analysis be used in considering the economic efficiency of a project in an EIS, a few simple points concerning benefit and cost cal-culation w i l l be mentioned. F i r s t , the benefits and costs of an action should be measured as the difference between the outcomes in the affected - 38 -areas with and without the project. Second, i f the market is running smoothly (e.g., f u l l employment, competitive market prices, etc.) the proper measure of a benefit is by the calculated willingness to pay for the benefit through actual or simulated market prices. Similarly, i f the market is running smoothly a l l economic costs should be measured by the opportunities foregone in u t i l i z i n g resources (e.g., labor, capital) for the intended project rather than for the most productive of the other potential use of resources (Knetsch, Havemen, et a l . , 1969). Third, care should be taken i f i t is decided to value secondary benefits or costs. It has been recommended that i f a national accounting stance is taken and the resources of the economy are f u l l y employed and mobile there i s no need to value secondary economic effects because these benefits and costs w i l l likely offset one another (Howe, 1971). Fourth, risk and uncertainty must be taken into account in a benefit/cost analysis. Risk can be considered the probability distribution of some effect while un-certainty implies ignorance of even a range of probability (Pearce, 1971). Hence, risk and uncertainty must be treated differently before values are assigned in a benefit/cost analysis. The f i f t h and f i n a l comment about benefit/cost analysis is that the period of economic l i f e of the project and the social discount rate should be chosen according to standardized methods. For example, the Water Resources Council in the U.S. determines a discount rate every June for use in federal water projects and also recommends that the period of economic analysis used in water resources planning is generally considered either the useful l i f e of the action or the time period when further discounting has l i t t l e or no affect on the analysis (U.S. Water Resources Council, 1973). THE PROBLEM OF ASSIGNING IMPORTANCE TO ENVIRONMENTAL IMPACTS The remaining two categories of environmental factors are d i f -ferent from the economic efficiency criterion in that individual impacts within each cannot be consistently reduced to a common denominator for valuation such as money. The value of an environmental effect can be determined in two ways. Fi r s t , a quantitative assessment of the poten-t i a l impact can be used as a value of that consequence. In benefit/cost analysis economic efficiency value of an action i s quantitatively ex-pressed in a ratio of monetary terms. Although the importance value of money i s different to everyone, i t is commonly accepted that i f the monetary benefits of an action exceed i t s monetary costs (or, depending upon the existence of a ratio criterion such as 1.2/1.) the project can be considered economically efficient i f the analysis has been correctly completed. When considering ecological and socio-cultural effects i t i s d i f f i c u l t to define the social worth of an action because there is no common unit for comparison. Nevertheless, these environmental impacts can be quantitatively estimated on their own terms (e.g., number of species affected, number of families displaced, etc.) to show the mag-nitude of the project effects. Albeit such quantitative assessments are not readily comparable among one another, these estimates do identify the extensiveness of an impact and hence assign some value to that effect. The second manner in which value can be assigned to environ-mental impacts i s through a qualitative description of the expected - 40 -consequences. I t might.be stated, for example, that trout have more s o c i a l importance than carp because of the commonly known r e l a t i v e value people place upon each species. However, a clear s o c i a l p r e f e r -ence cannot be distinguished between many other environmental e f f e c t s such as economic cost and health and safety. As a r e s u l t , i t i s recom-mended that, i n conjunction with quantitative estimates and q u a l i f y i n g descriptions (when a p p l i c a b l e ) , the following four considerations should be used to help i d e n t i f y to persons reading an EIS the s o c i a l importance of an environmental impact: 1) the r i s k or uncertainty of impact; 2) the r e l a t i o n s h i p between p o t e n t i a l m i t i g a t i o n measures and unavoidable adverse e f f e c t s ; 3) an i d e n t i f i c a t i o n of d i f f e r e n t responsible opinions held i n society concerning the consequences of the impact; 4) the r e l a t i o n s h i p between short-term resource uses and long-term adverse e f f e c t s . As mentioned e a r l i e r concerning benefit/cost a n a l y s i s , r i s k and uncertainty i s necessary i n an EIS to i d e n t i f y the r e l a t i v e p r o b a b i l i t y of e f f e c t occurrence. When uncertainty occurs i n preparing an EIS, a decision must be made whether to undertake studies to reduce the uncer-t a i n t i e s or to merely acknowledge i n the impact statement that c e r t a i n consequences of the action are not known. No consensus i n U.S. Courts has been reached concerning which a l t e r n a t i v e i s best f o r d i f f e r e n t actions anddimpacts, but at the very l e a s t i t has been required that uncertainties be i d e n t i f i e d i n an EIS (U.S. D i s t r i c t Court, 1971a). S i m i l a r l y , when the r i s k of an e f f e c t occurrence i s known, including the p r o b a b i l i t y f i g u r e i n the statement can help value the p o t e n t i a l - 41 -impact for the reader. Identifying in an impact statement the relationship between mitigation measures and unavoidable adverse effects provides a broad open view of an entity's previously implicit economic valuation of the impacts of an intended action. This could ideally be accomplished by l i s t i n g a l l significant environmental impacts, the cost of reducing the intensity of each effect, whether and by how much each adverse effect is being reduced, and a distinction between the impacts which cannot be avoided or reduced in intensity. The judgements made in evaluating an environmental impact should be recognized in an EIS. It is extremely simple to provide a biased qualitative view of the value of an effect, but i t is much more meaning-f u l to give a range of values society would assign to this impact. As mentioned earlier, the courts have also recognized the necessity of considering different and opposing opinions concerning the eventual impact of an action on an environmental factor (U.S. Court of Appeals, 1971). By including a range of viewpoints in an impact report, the reader i s aided to use his own judgement in reaching an informed deci-sion concerning the proposal. The Council on Environmental Quality's revised 1973 guidelines make very l i t t l e distinction between "irreversible commitments of re-sources" and "the relationship between short-term uses and long-term productivity" (see p. 29 and 30). The vague nature of the difference between these two EIS requirements is exemplified by EIS recommenda-tions developed by the U.S. Environmental Protection Agency in 1973. In reference to "the relationship between short-term ... etc." the - 42 -E.P.A. recommendations state that "... the desirability of agency actions shall be weighed to guard against short-sighted foreclosure of options or needs. Special attention shall be given to effects which narrow the range of beneficial uses of the environment ... ." On the contrary, the Council on Environmental Quality recommend that in the "irreversible or irretrievable commitments ..." section that the agency identify"... the extent to which the action irreversibly curtails the range of potential uses of the environment." The E.P.A. also restates approximately the same suggestion for this latter section. As a result of the vague distinction that is made between these two sections there seems to be no reason why they should be isolated from one another, although the importance is recognized of including a discussion of the long-term impacts and curtailment of future options in an environmental statement. It is also helpful in an EIS that the time span for each effect be identified and that a brief discussion be completed concerning the total consequences of an action on the diversity of future human uses of the environment (e.g., the effect on renewable and non-renewable resources, etc.). The discussion of long-term effhcts should also i n -clude the potential inducement consequences of an intended action. The previous five factors have been described in an attempt to help value the predicted tangible and intangible environmental conse-quences of a proposal. Although these considerations do not establish a common unit for comparing beneficial and adverse impacts, information is provided to persons reading the EIS in order to f a c i l i t a t e individual decisions about each impact and thus the entire action. - 43 -SOCIO-CULTURAL IMPACTS A second category of environmental impacts can be isolated into social and cultural disciplines of knowledge. It is somewhat d i f f i c u l t to conceive of physical or biological impacts as being separate from social effects because a l l environmental impacts included in an EIS affect humans in one way or another. Since the object of this analysis is to simplify the process of preparing an environmental report, these categories reflect environmental impacts at the stage immediately pre-ceding the f i n a l effect on human beings. Hence, these environmental categories include primary, secondary and multiple-order impacts that can be isolated from each other f a c i l i t a t e identification and inclusion in an EIS, but in toto these impacts are connected and interrelated with one another. ECOEOGICAL IMPACTS Ecological effects can be further subdivided into natural phy-si c a l and natural biological impacts. Natural physical features which must be considered include land form, non-renewable resources, s o i l s , water, climate and air. The effects of a proposed action on the plants, animals and microscopic organisms in an: area should be disclosed in an environmental statement. These impacts can be quantified by l i s t i n g numbers of or-ganisms by species and also qualified by describing i t s uniqueness, endangered status, or human importance. Further valuation of the action's biological impacts should, as in the preceding socioicultural category, be accomplished by the four factors previously discussed. - 44 -One danger in categorizing environmental impacts under separate headings is that the individual results are isolated away from the affected area as a whole so that i t i s d i f f i c u l t to perceive the total consequences. Indeed, a catalyst to many environmental problems has been a fragmented, single-purpose approach to i t s solution. The science of ecology has especially addressed i t s e l f to identifying interrelation-ships that exist between organisms and their environment. This inter-dependence between livi n g and non-living systems suggests that, when applicable, several ecological concepts deserve discussion in an EIS. These important concepts concern system interrelationships (physical/ biotic, man/nature), food chains, biogeochemical cycling, energy flow, limiting factors and systems diversity in the areas affected by the intended project. DISTRIBUTIONAL CONSEQUENCES The results of an action are the distribution of beneficial and adverse effects to different people, groups and areas. Individual judgements as to the relative social worth of an action might be f a c i l i -tated by identifying the incidence of these environmental benefits and costs on different groups and regions. In a publication identifying issues in need of consideration in Public Water Resources Planning, Bromley et. a l . (1971) mention the necessity of considering distribution consequences in project evaluation. The traditional view that benefits and costs have meaning only in relation to a specified objective is perhaps best replaced by the notion that benefits and costs have meaning only in relation to specified individuals who perceive such impacts. Obviously i t - 45 -is impossible to be concerned with "benefits and costs" to each individual so the problem can be altered slightly to discuss individuals in their multiple roles as taxpayers, recreationists, labor suppliers, entrepreneurs, consumers, etc. When considering location-specific impacts — say within a project region — i t is useful to articu-late project impacts by specific groups upon which these effects impinge. ... (p.34) Thus, in order for an EIS to appropriately "disclose the environmental consequences" of a proposed action to the public and decision-makers i t is necessary that the distribution of economic, socio-cultural, physical and biological benefits and costs to groups and areas be included in the statement. ANALYSIS OF ALTERNATIVES In order to optimize the net benefits which accrue to society, i t i s necessary that an environmental statement analyze the beneficial and adverse environmental consequences of a range of choices which have similar ultimate objectives as the proposed action. This consideration was included directly in NEPA (Section 102(a) ( c ) ( i i i ) and Section 102 (2) (d)) and has since been strengthened by court decisions (U?S. Court of Appeals, 1972b; U.S. District Court, 1972b, et a l . ) . Indeed, the importance of an adequate description of alternatives has been mentioned in the courts as one of two main parts of an EIS that are the object of jud i c i a l review when determining whether an EIS complies with NEPA (Anderson, 1973). As a result, the revised C.E.Q. guidelines have ex-panded these recommendations on alternatives evaluation to include a broad range of potential choices including the choice of "no action". It should be further noted, however, that the consideration of - 46 -alternatives should be broad in scope rather than exhaustive because of the almost interminable number of choices available to achieve most objectives. Nevertheless, in Natural Resources Defence Council v. Morton a U.S. Court of Appeals (1972b) required that alternatives be analyzed to the extent that the reader i s able to make a reasoned choice between options. This analysis is best accomplished in an EIS by iden-tifying the trade-offs between alternative options and the proposed project for the reader. RELATIONSHIP TO ESTABLISHED GOALS A major purpose of formal community and regional planning or-ganizations i s to synthesize the needs and aspirations of local citizens into goals, objectives and policies to be utilized in the future planning of the area. This purpose is usually accomplished through public hear-ings, questionnaires and/or a variety of other means of s o l i c i t i n g citizen input. Since the awareness of the public is often dulled by the complexities of modern l i f e , i t cannot be expected that an adequate public response w i l l occur for a l l of the smaller, seemingly less signi-ficant actions requiring environmental impact statements. The existing EIS process in the U.S. attempts to modify this influence not only through public hearings but also by allowing review of impact statements by planning and other agencies. However, this review presently exists too late in the planning process; such a consideration of the established goals and objectives of the region should begin to take place from the very inception of the action. Assuming that goals and objectives reflect a local area's needs - 47 -and desires, i f such a formal local expression of the future exists in an area i t is recommended that an EIS discuss the relationship of the proposed action to these goals and objectives. Sorensen and Moss (1973) have further mentioned the use of existing local plans in f a c i l i -tating environmental impact evaluation: An effective procedure for evaluation is to deter-mine what w i l l be the degree of convergence of a proposed project's impact with regional planning programs and elements. Where a community has already identified and expressed i t s collective goals in a community plan, then the impact state-ment can be evaluated in terms of i t s relationship to the existing planning program. (p. 26) COMMUNICATION OF INFORMATION Since the purpose of an EIS is to generate information to the general public and decision-makers whereby each individual can reach an informed rational decision concerning an action, i t is quite apparent that the information must be communicated in a simple straightforward manner. The Council on Environmental Quality guidelines (1973) have recognized the importance of a non-technical, concise impact report by stating that "agencies should make every effort to convey the required information succinctly in a form easily understood, both by members of the public and by public decision-makers... ." In order to help persons judge the social worth of an action, the rationale for proposing the project and a summary should also be included in an EIS. A concise logically organized EIS that is written in informal language compre-hensible to the ordinary layman w i l l enhance public participation and rational decision-making by bearing the pertinent facts and, hopefully, - 48 -reducing major disagreements to only value judgements rather than ignorance. SUMMARY CONCLUSIONS The purpose of an environmental impact statement i s to generate information concerning the total consequences of a proposed action in order to f a c i l i t a t e a l l interested persons and decision-makers to indi-vidually reach a decision about the proposal. The decision-making process then prescribes that meaningful debate and dialogue concerning the action take place between the public and the proposing entity u n t i l an acceptable decision i s made. The unclear nature of the environmental impact statement re-quirement and similarly vague early 1971 Council on Environmental Quality guidelines induced a large number of adjudications in court. Based upon the results of these court cases, the role of environmental impact statements in decision-making, and the revised 1973 C..E.Q. guidelines, the following recommendations are outlined as standards which a l l envi-ronmental impact statements should meet. I. Project Description and Environmental Inventory Whereas the foundation for planning an action i s knowledge of the environment within which i t i s involved, the importance of an adequate EIS as a planning/decision-making tool is also based upon a thorough knowledge of the proposed project and existing environ-mental conditions in the area(s) affected by the action. It i s necessary that an environmental impact statement include the follow-- 49 -ing three considerations: A. A d e s c r i p t i o n of a l l project actions r e l a t i n g to the proposal which w i l l r e s u l t i n environmental impacts. B. A c a r e f u l d e l i n e a t i o n of the study area which w i l l be affected by the a c t i o n ( s ) . C. A discussion of the environmental components which w i l l l i k e l y be a f f e c t e d by the proposal. I I . Economic E f f i c i e n c y One component of the human environment that deserves thorough treatment i n an EIS i s an action's economic e f f i c i e n c y through measurement of benefits and costs. A. A l l assumptions which provide the basis for the economic analysis should be l i s t e d . B. Standardized consensus benefit/cost analysis procedures should be followed. I I I . Socio-Cultural Impacts If an intended action has important e f f e c t s on e x i s t i n g and f u t u r future s o c i o - c u l t u r a l environmental f a c t o r s , i t should be thorough-l y described q u a n t i t a t i v e l y (when pertinent) and q u a l i t a t i v e l y . The following considerations should also be included i n an EIS to help the reader assign importance to s o c i o - c u l t u r a l impacts. A. A d e s c r i p t i o n of the r i s k or uncertainty of each impact. B. An i d e n t i f i c a t i o n of the r e l a t i o n s h i p between p o t e n t i a l m i t i g a t i o n measures and unavoidable adverse e f f e c t s . C. A s p e c i f i c a t i o n of the range of responsible opinions i n society concerning a l l impacts. D. A d e f i n i t i o n of the time span of each s i g n i f i c a n t impact. E. When relevant to the s p e c i f i c impact, a d d i t i o n a l q u a l i -t a t i v e measures should be used. - 50 -IV. Ecological Effects The impact of an action on the natural physical (e.g., land form, non-renewable resources, so i l s , water, climate and air) and natural biological environment (i.e., flora, fauna, microorganisms) must be included in an EIS. In order to avoid unanticipated consequences due to a compartmentalized approach to impact analysis, a systems view of potential environmental effects i s encouraged by consider-ation of ecological concepts such as systems interrelationships, food chains, biogeochemical cycling, energy flow, limiting factors, and systems diversity. A l l Important ecological impacts must be comprehensively characterized in an impact statement quantitatively (if relevant) and identified qualitatively. To f a c i l i t a t e the reader in valuing a l l described impacts, the five considerations listed under socio-cultural impacts should also be uti l i z e d in describing the ecological effects of a proposed project. V. Distribution Consequences The real importance of an intended action to interested i n d i v i -duals reading an EIS i s not just from a complete description of the f u l l environmental consequences, but also from the incidence of these benefits and costs to groups (e.g., taxpayers, environmental-i s t s , entrepreneurs, recreationists, etc.) and regions (local, regional, national, etc.). As a result, the distribution of the beneficial and adverse consequences of an action should be des-cribed in an EIS. - 51 -VI. Short-Term Resource Uses Vs. Long-Term Effects In order to help avoid the often myopic tendencies of man, an environmental impact statement should include a separate discussion contrasting the important short-term effects of the proposed pro-ject with the long-term consequences. This discussion should especially refer to the curtailment of future beneficial uses of the human environment (e.g., renewable and non-renewable resources) and any important inducement effects caused by the proposed action. VII. Analysis of Alternatives If certain objectives are necessary to be achieved by society, i t is essential that these objectives be accomplished by the alter-native which has the least social cost in relation to the greatest social benefits. The alternatives considered should be broad in scope reflecting the different interests in society, and evaluated to the extent that the person reading the EIS can make a reasoned choice between options. This evaluation should indicate the major tradeoffs between the alternatives and the proposed action. The alternative of "no action" should also be considered. VIII. Relationship to Established Goals The existence of goals and objectives in an area that truly re-flects the aspirations of local citizen needs and desires about their region or community's future requires that an EIS discuss the relationship of an intended action to these goals and object-ives . - 52 -IX. Communication of Information In order to communicate the f u l l environmental consequences of an action to a l l interested persons, an EIS should display this information in a succinct, non-technical form that i s easily understandable to the common layman. Both the rationale for the project and a summary of impacts should also be included in an EIS. These recommended c r i t e r i a are proposed realizing that different government actions inherently require varying intensities of effort in disclosing the beneficial and adverse consequences of an intended action. The detail required in an EIS is ultimately the judgement of an agency decision-maker, although consideration should be given to the relative magnitude of an action, i t s monetary cost and whether the action is of a controversial nature or not. Regardless of the effort expended in com-pleting an EIS, i t is f e l t that consistent adherence to these recommended standards w i l l enhance achievement of an impact statement's intended purpose of informing a l l interested persons and decision-makers of the f u l l environmental consequences of a proposed action. chapter three the state of the art in environmental impact assessment INTRODUCTION In recent years a number of different procedures, have been deve-loped to help assess the potential environmental impact of a proposed project. Most of these methods have been devised by government agencies, educational institutions and private research consultants a l l in response to the need for a systematic procedure to f u l f i l l the "action forcing" requirements of the U.S. National Environmental Policy Act of 1969. Other methods devised to predict the consequences of a proposed action were actually developed before NEPA became law. The purpose of this chapter is to complete a descriptive review of different procedures which have been established or could be of signi-ficant use to identify the environmental impact of a proposed action. Since many of these methods are very similar or are specifically confined to a narrow aspect of environmental analysis, this descriptive review w i l l not discuss a l l procedures that could be used to evaluate environmental impact. Rather, i t is intended to select and.review the more important methods or procedures which have been developed to identify the least damaging alternative or to evaluate the environmental impact of a pros-pective project. Hence, name thods of narrow scope such as the evaluation of landscape aesthetics w i l l not be described in this chapter. It was f e l t that this chapter would not be complete without a brief discussion of two methods for undertaking a land capability/ - 5"3 -/ - 5 4 -suitability analysis. These two broad approaches provide a general view of methods intended to prevent or reduce land use environmental impacts. The remainder of this chapter describes methods designed to be used for specific actions rather than just for broad land-use environmental impacts. These remaining methods have a certain focus that stresses impact identification, evaluating impacts through the development of common units, and evaluating impacts through separate measures and qua-l i f y i n g phrases which also provides f i t t i n g categories for this descrip-tive review. LAND CAPABILITY OR SUITABILITY ANALYSIS In essence, an environmental capability or su i t a b i l i t y analysis is completed when the natural features of an area are surveyed to pro-vide information which is evaluated by established c r i t e r i a to determine the quality of the land for a different use or uses. It i s based on the premise that "nature is process, that i t is interacting, that i t responds to laws, representing values and opportunities for human use with certain limitations and even prohibitions to certain of these" (McHarg, 1969). Such an analysis could be used in an impact statement to indicate the compatibility of an action with the environment and also to assess the most suitable locations for different prospective land uses. A number of approaches presently exist for undertaking a capability or su i t a b i l i t y analysis. Probably the two most notable methods have been developed by G. Angus H i l l s in The Ecological Basis For Land Use Planning and by Ian L. McHarg in Design With Nature. Both techniques w i l l be briefly described in this section. - 55 -The f i r s t step of H i l l s method is a logical disaggregation of a large land site into increasingly smaller areas based upon the recogni-tion of homogeneous sub-units of landscape. The general land type classification i s based upon micro-landform and climatic features while the more specific site type areas are distinguished by gradients in parameters such as s o i l moisture, s o i l depth and micro-climatic condi-tions. At the more specific site type unit of land, classes are assigned for a certain land use (either agriculture, forestry, recreation and wildlife) based upon the inherent capability of the land to produce according to that specified use (eg, number of recreation days, crop yields, etc.). The classes for a specific area can. then be aggregated into a rating for a larger section of land by combining numerical valuations for each class based upon the extensiveness of a class within the larger section of land and an assigned weighting factor. Thus, the ratings are useful to planners regardless of whether detailed or more all-inclusive information i s required. In addition to capability ratings, s u i t a b i l i t i e s can also be appraised according to the potential of the land area to reach i t s level of capability through management practices. Further, a third rating can be assigned based on the f e a s i b i l i t y of the land to be developed for the specified type of use under existing or future socio-economic conditions. A more complete outline of this approach is included in Appendix C, table 1. The McHarg method of "ecological determinism" is similar to H i l l s approach in that both desirable and limiting characteristics are - 5 6 -defined for each type of land use, but differs in the complexity and number of steps required to complete the procedure. The McHarg technique is easier to understand and u t i l i z e , yet this characteristic may also mean that the method produces less systematic results. There i s also a detailed inventory and mapping of beneficial and adverse features of the environment. A f i n a l aspect of the McHarg method which should be men-tioned i s the use of transparent maps darkened in varying tones of gray to indicate limiting characteristics and desirable features of an exist-ing environmental condition for a specific land use. By superimposing maps of environmental conditions, the resultant clear or darkly toned areas (depending upon whether dark areas are limiting or favorable envi-ronmental characteristics) indicate desirable locations for the land use evaluated. Thus, each environmental condition is a criterion used to evaluate the suitability of a land use in an area. Through the use of a single color which is toned on a transparent map to indicate desirable and undesirable locations for a specific land use, a l l land uses in the region can be compared through the overlay technique to identify areas highly suitable for a specific use, areas suitable for compatible uses, and also areas of conflict. Case studies u t i l i z i n g this method have indicated that there are relatively few conflicting uses requiring fur-ther study. A l i s t of c r i t e r i a used by McHarg to evaluate the suitabi-l i t y of a land area for conservation, passive recreation, active recreation, residential development and industrial and commercial development is included in Appendix C, table 2. - 57 -METHODS OF IMPACT IDENTIFICATION ONLY After NEPA was signed into law on January 1, 1970 most federal agencies developed guidelines to implement the "action forcing" require-ments in this law. In several of these guidelines (notably, U.S. Dept. of the Army, 1972, and U.S. Dept. of the Navy, 1970) attempts were made to develop a checklist of environmental impacts that could occur from actions undertaken by the agency (see Appendix D, Table 1). Only one type of checklist w i l l be described in this section, since most other impact identification methods are only one part of broader evaluation approaches. These evaluation approaches w i l l be discussed in later sections of this chapter. MULTIPLE EFFECTS NETWORKS One of the major problems with some methods to evaluate envi-ronmental impact is that they do not provide the assessor with a comprehensive grasp of the multiple-order effects that result from an action (e.g. see U.S.G.S. matrix) (Sorenson and Moss, 1973). The in-tensity of this problem has been reduced through the development of networks f i r s t by Travelers Research Corporation (1969) and later re-fined by the California Resources Agency (1972) and published by Jens C. Sorenson (1971). These networks or stepped matrices link land uses and causal actions with existing environmental conditions and primary, secondary and consequential impacts (see Appendix D, Figure 1). For example, a use of land such as crop farming results i n actions such as f e r t i l i z a t i o n which can lead to the changed environmental condition of - 58 -increased nutrients in the ground water. A secondary impact resulting from these increased nutrients leaching into the aquifer i s n i t r i f i c a -tion of the ground water which, in turn, can result in a tertiary effect of a public health hazard in infant methemoglobinemia or "blue baby." These networks or stepped matrices are developed to comprehensively include a l l multiple-order impacts which result from the actions i n -herent in a land area. At present, a complex system of networks is being completed for use in identifying the potential impacts of land uses and actions on the coastal zone in California. Objectives are to program and store this detailed information on computer so that i t can be revised and corrected when necessary, and also for convenient retrieval by persons preparing impact statements when a pertinent l i s t i n g of potential impacts is needed for a specific type of action. Although this network procedure was i n -tended for mainly impact identification purposes rather than evaluation (Sorenson and Moss, 1973), this method has been modified so that an impact assessor can distinguish the probability or importance of the occurrence of an effect (Midgley, 1972). Further, networks have been arranged in an outline format as an impact checklist to review highway and housing pro-jects (Sorensen et. a l . , 1973) and also used as a one-page summary of large, detailed impact statements (see Appendix D, Figure 2) (Daniel, Mann, Johnson, & Mendenhall, 1973). METHODS AGGREGATING IMPACTS INTO COMMON UNITS The quest for a common denominator between economic and biolo-gical factors to f a c i l i t a t e decision-making began long ago in water - 59 -resources planning through benefit/cost analysis methods. This search continues to this day with methods to consider in non-monetary yet common measures the economic, social and ecological consequences of a proposed action. Although the basic reason why these methods are advanced for environmental impact evaluation is to provide decisions-makers with an explicit definition of an action's f e a s i b i l i t y , methods u t i l i z i n g common denominators are also recommended because they provide commensurable figures which clearly identifies tradeoffs between bene-f i c i a l and adverse impacts, and likewise provides a distinct comparison between differing environmental effects and between alternative design and location choices. In this section six common unit methods w i l l be described. U.S. GEOLOGICAL SURVEY MATRIX Probably the best known procedure for evaluating environmental impact was developed by the U.S. Geological Survey during 1971 (Leopold, et a l . , 1971). This publication l i s t s the following four basic items comprising an EIS which are based upon a recommended sequence of events in planning an action (see Figure III-l) : 1) An analysis of the need for the proposal; 2) An environmental inventory of the region potentially affected by the action; 3) An explanation of the pertinent engineering details and alternatives to the action; and 4) An assessment of the probable environmental impacts of the action and f i n a l rationale for the proposal. The main thrust of the procedure developed by the U.S.G.S. • concerns the fourth item. For purposes of environmental assessment, an - 60 -A ) A. Statement of objective 0 0 B ) 8. Technologic possibilities for achieving objective © © C4 } C. Proposed actions and alternatives D. Environmental characteri-zation report prior to initiation of action © E. Alternative engineering plans F. Identification of impact and analysis of magnitude and importance of impact. G5 ) G. Assessment of impact H ) H. Recommendations I I I - l . A flow chart showing the recommended integration of an environmental impact statement in the process of planning an action (Leopold et. al., 1971). - 61 -action/condition matrix was developed to help identify the prospective general impacts of a wide range of potential actions (see Appendix E, Figure 1). This large matrix is actually a checklist of 100 actions on the horizontal axis and 88 environmental conditions lis t e d vertically totalling 8800 cells. This method is ut i l i z e d by marking the inter-actions between a project's actions and environmental conditions or impacts on the matrix with a slash which divides the c e l l into two parts (see Figure III-2). Each impact is then assessed according to i t s magnitude and importance which is identified in each part of a l l marked cells by a number between one (low) and ten (high). Magnitude is defined for this purpose as the "degree, extensiveness or scale" of impact while importance might best be termed the significance or weight attributed to the effect. Thus, in most cases magnitude can be deter-mined from factual information and importance can be identified through subjective judgements. An important feature of this procedure is the separation of value judgements from fact. Also, the method can be re-vised into providing more detailed information by devising sub-matrices with specific data about an action (eg, Mineral Processing can be sub-divided into the specific actions of sulfuric acid use and acidity of yard runoff) or environmental condition (eg Atmospheric Quality can be subdivided into the specific conditions of particulates, sulphur oxides, nitrous oxides, etc.). This procedure has been used many times to help evaluate the environmental consequences of a proposed project. In Canada, a joint Federal-Provincial Task Force (1971) modified the evaluation part of the - 62 -ENVIRONMENTAL CONDITIONS WATER QUALITY ATMOSPHERIC QUALITY EROSION DEPOSITION, SEDIMENTATION SHRUBS GRASSES AQUATIC PLANTS FISH CAMPING & HIKING SCENIC VIEWS & VISITORS WILDERNESS QUALITIES RARE & UNIQUE SPECIES HEALTH & SAFETY co Z o H H C_> <! CO o Z M 9 H CO O S5 O tJ CO CO Z z CJ M W w H o Z <J CO o Z hJ H H H w Q M H CO H H H < CO PH CO M Pi > w O CO PQ Z O < CJ •J O H u3 XC RO NT •J CO w PH CO CO o o PS1 SH M z w z W H s M q M O CO CO & CO EH < S3 S3 CO PH w O i J ON IG LA UR IN RU & PI M 53 H CO S H w co 6 2 I? KEY magnitude importance FIGURE III-2. A reduced matrix f o r a phosphate mining lease i n d i c a t i n g the magnitude and importance of actions on environmental elements (adapted from Leopold et a l , 1971)^ - 63 -procedure but utilized the matrix and a simple assessment of each c e l l for the proposed James Bay Hydropower Development. The procedure has also been adapted by the Oregon State Highways Department to define the effects of constructing and operating highways and related f a c i l i t i e s . ENERGY NETWORK DIAGRAMS Defining economic, social and ecological impacts in common units would greatly simplify the evaluation of the consequences of a proposed action. One approach which has been recommended for this purpose is to develop energy network diagrams for the system(s) to be affected by a proposed action (Odum, 1972). This method of describing natural and man-made systems uses kilocalories as a common denominator to measure energy flows and storages (see Appendix E, Figure 2 and Figure 3 for an explanation of energy diagram language). In addition to the more com-monly accepted representation of a natural ecosystem in energy terms, Odum (1971) notes that such a portrayal can be used for economic and social systems since the ut i l i z a t i o n of energy is also the fundamental basis of man-oriented systems. Indeed, Odum states that even money can be changed into kilocalories by relating the total amount of money in a human system to the total amount of work completed by individuals com-prising the system. The f i r s t step in quantifying the environmental impacts of a proposal is to complete a physical inventory and a simplified network diagram of the energy flows and storages in the system(s). Secondly, an estimate of the change in energy flow and storages due to the action (or forcing functions) w i l l yield a prediction of the system(s) i f the - 64 -proposal i s implemented. The difference in total energy flow and storage with and without the proposed action is i t s environmental impact in quan-titative terms. The environmental impact statement can be written with reference to the changed energy flow and storages of system components that are indicated on the network diagram. Although this method s t i l l does not value the "importance" of impacts, the following four c r i t e r i a can be used to define systems which require protection (Wetterqvist, Odum, et a l . , 1972): 1) Natural and man-made systems of high energy value in an existing state; 2) Systems highly sensitive to intrusions; 3) Systems which have a high value or importance in maintaining other systems; 4) Systems which have a high cost of development and maintenance i f the action is undertaken. AN OPTIMUM PATHWAY MATRIX ANALYSIS APPROACH An interdisciplinary group from the Institute of Ecology at the University of Georgia (Zieman, et a l . , 1971) developed an approach to evaluating the least social cost location of a proposed highway route. In the case study using this method, eight potential alignments were assessed according to 56 environmental conditions (see Appendix E, Table 1) aggregated into the following four groups: 1) Group E — Economic and Highway Engineering considerations; 2) Group L — Environmental and Land Use considerations; 3) Group R — Recreation considerations; 4) Group S — Social and Human considerations. Since the i n i t i a l construction impacts of a highway are different - 65 -from i t s long-term impact, two relative weights were assigned to each of the 56 conditions indicating the long and short-term importance of each potential consequence of an action. In addition to these two different weights, long-term impacts were valued as ten times more important than short-term effects. The magnitude of a condition change for each alter-native route was also considered by a quantitative valuation of the impact (eg, acres of agricultural land removed for right of way, number of families displaced, etc.). The magnitude of effect on each existing environmental condition was then scaled by relating a l l alternative routes to the highway alignment which would have the most extensive im-pact. For example, route F would remove 325 agricultural acres for right-of-way which is higher than any other alternative. Route F is given a magnitude value of 1. which route G, which displaces 313 acres, is assigned a value of .96 (or 313/325). Similarly the remaining alter-natives would be scaled in relation to route F to define their propor-tional magnitude for this environmental impact. In order to keep numerical totals within reasonable bounds the weighting factors were also scaled. Consequently, each alternative highway had a scaled magnitude figure and a scaled importance figure for each environmental condition. Multiplying these two figures and summing a l l 56 values results in a numerical value indicating the environmental impact of the route. The realization of the potential for a wide margin of error in evaluating impacts prompted the group to develop a technique to improve the validity of their results. This technique utilized a computer pro-gram to calculate and sum the effect of each alternative route on each environmental condition, and then repeat the calculations 20 times using - 66 -values that varied by as much as 50% for every impact. Sta t i s t i c a l techniques were also used through the computer to calculate the mean, the standard deviation and a 95% confidence interval for each highway alignment. Figure III-3 indicates that, according to this case study, routes T-l and G-l are the best choice among eight potential highway routes. BATTELLE COLUMBUS METHODS  Earlier Approach In a contract with the U.S. Bureau of Reclamation, Battelle Columbus Laboratories developed an "Environmental Evaluation System" (EES) for Water Resources Planning. The method i s used to quantitative-ly assess the environmental consequences of water resources projects in order to identify the tradeoffs between the beneficial and adverse effects of an action, and to measure the difference in impacts of alter-native water resources developments. A hierarchical arrangement of environmental impacts into categories, components and ultimately into 79 parameters (see Figure.III - 4 ) that are used to define and evaluate ef-fects into a numerical total of environmental impact units (EIU). For example, one of four Battelle categories i s Environmental Pollution" which i s divided into the four components of "Water Pollution", "Air Pollution," "Land Pollution" and "Noise Pollution." One of fourteen parameters disaggregated from the component "Water Pollution" i s "In-organic Nitrogen." The Battelle method also incorporates a warning system whereby minor or major "red flags" are identified to signal para-meters that reflect "fragile" areas of the environment or parameters - 67 -FIGURE III-3. M e a n and confidence intervals for the evaluation of eight highway route alignments (from Zieman et. a l . , 1971). - 6 8 -TOTALITY OF ENVIRONMENTAL IMPACTS . GENERAL Level 1 ENVIRONMENTAL CATEGORIES INTERMEDIATE Level 2 ENVIRONMENTAL COMPONENTS ...^........ i i r j i i i A A ENVIRONMENTAL PARAMETERS U U U U U U U U ••••••• • • • ENVIRONMENTAL PARAMETERS MOST SPECIFIC (DATA) Level 4. ENVIRONMENTAL MEASUREMENTS FIGOBE III-4. The h i e r a r c h i c a l structure of the B a t t e l l e Columbus environmental evaluation system (from Dee, et a l , 1973) 1.0* E-t 0.8-D Oi. IS-3 2 s H > W 0.6| 0.4 0.2 iiiiiiiiiiiiiijiiiiiisjiisili^ 8 30 MG/L FIGURE 111-5* A scale to convert measurement of dissolved oxygen to an environmental quality value (from Dee, et a l , 1972). - 69 -which need further study before quantitative values can be assigned. Two quantitative values are m u l t i p l i e d together to comprise each parameter's numerical f i g u r e i n environmental impact units. The environmental q u a l i t y value of a parameter i s obtained through estimates or f a c t u a l data which i s compared on a scale (see Figure III-5) to de-termine a fi g u r e between 0 (very bad environmental quality) and 1.0 (very good environmental q u a l i t y ) . The l e v e l of a parameter measure or estimate which i s a "very good" or "very bad" environmental q u a l i t y i s to be determined f o r each water resources project by an i n t e r d i s c i p l i n a r y team. The second quantitative value used to determine the environmental impact units of a parameter i s through a weighting system which assigns 1000 importance weights among parameters i s again through an i n t e r -d i s c i p l i n a r y team. Merely by summing the t o t a l EIU from estimates of the future environment with and also without the proposed project pro-vides numerical values which i n d i c a t e the predicted environmental impact (see Appendix E, Figure 4). Later Approach Since most environmental impact statements are prepared by a government agency s t a f f and not through an i n t e r d i s c i p l i n a r y team, B a t t e l l e revised i t s e a r l i e r method i n a contract with the Environmental Protection Agency so that the procedure could be used for t y p i c a l water q u a l i t y management plans re q u i r i n g an EIS. There are three basic d i f f e r -ences from the e a r l i e r approach. The most obvious d i f f e r e n c e i s that t h i s newer approach does not assign common units to the parameter l e v e l s i n the h i e r a r c h i c a l system. Instead, common unit values are assigned for - 70 -importance and Environmental Quality at the more general environmental component level defined earlier in the hierarchical system. Another change from the earlier method i s the establishment of a fixed weighting system by assigning only 100 importance units to the 19 environmental components. An interdisciplinary research team used a "ranked pairwise comparison" technique to assign these weights. Through this technique a l l 19 components were f i r s t ranked by using c r i t e r i a . Contiguous com-ponents were then compared according to difference in importance in order to assign the weights. This "ranked pairwise comparison" technique was repeated several times by providing the group with information about the previous run, unt i l a f i n a l scaled weighting system was developed. The third difference from the earlier Battelle approach is the use of environmental assessment trees to determine each component1s environ-mental quality (see Figure III-6). As in assigning importance values to environmental components, a fixed method i s again used to assign a range from one to four for a l l parameter values which comprise an envi-ronmental component. A pre-determined index i s used to transform the measured or estimated value of a parameter to a specific range. After defining the correct range of parameter A on the appropriate environ-mental assessment tree, an arrow w i l l lead to successive parameters which, when defined, w i l l f i n a l l y result in the identification of an environ-mental quality value between 0 and 1.0 for the component (see Appendix E, Figure 5). EFFECTS CHAINS A methodology developed at Cornell University (Bereano, et a l . , 1.0 0.9 0.8 0.7 0.6 Environmental Quality 0.5 (EQ) 0.4 0.3 0.2 0.1 0 Range 2 Range 2 Parameter B Range 1 I Parameter A Range 1 Range 2 Parameter C Range 1 1.0 0.9 0.8 • 0.7 0.6 Environmental 0.5 Quality (EQ) 0.4 -i 0.3 0.2 0.1 0 FIGURE I I I - 6 . An example of an environmental assessment tree used to determine a component's environmental quality value (from Dee et a l , 1973). 1972) merged ideas from both the Sorensen and Leopold et al . procedures previously described to evaluate alternative Canadian and Alaskan pipe-line routes from Prudhoe Bay. "Effects chains" were devised as a rational method to choose variables to be included in a matrix which would serve to summarize an impact statement and make explicit a l l eval-uation judgements about potential alternatives. An effects chain i s described as merely a flow chart tracing the specific actions of a project to the primary impacts, induced effects and resultant multiple-order consequences which result (see Figure 1II-7). Since impacts do not necessarily reach an endpoint, c r i t e r i a were estab-lished to help decide the terminus of the effects chain. After effects chains were completed for each alternative pipeline route, a l l endpoints were organized horizontally as variables across a matrix for comparison against vertically l i s t e d alternatives. In this case study an effects chain was developed for each of five alternative routes and also for the choice of "no action." This methodology also devised a method to quantitatively evaluate each environmental impact by assigning a numerical probability and a u t i l i t y figure. Probability is defined as the percentage likelihood of an effect occurrence at each link along the chain (see Appendix E, F i -gure 6). The probability of the 'f i n a l ' effect on a matrix variable is therefore dependent upon the likelihood of a l l previous impacts occurring. The probability figures for a l l ' f i n a l ' effects are intered in the upper portion of each relevant c e l l in the matrix. U t i l i t y i s considered the relative significance of a 'f i n a l ' effect to society by comparing the same impact between the different alternatives. Consequently, i f impact A (INCREASED NUTRIENTS? (INCREASED SOIL ^ P 0 S S I B L E EUTRO-* 0/ bf iJ , E R 0 S I 0 N ) P H I C A T I 0 N B ° C & M E R . (ALTERED DRAINAGE PATTERNS) / EffCCt /Secondary Effect \ (BYPASS AQUIFER RECHARGE <jf^^D w a t e r  /'%imaV^, ^ 2 . Tertiary £ffed--- * ^al Effect ^ s v ^ S T U R B A N C E I N PHYSICAL LANDSCAPE) Effect" GRAVEL PIT FOR Secondary Effect———- . . . . . . a ' P A ™ / CONSTRUCTION MATERIALS) * J . * / / / « . / (BUILD HIGHWAY ,> (UNDESIRABLE VIEW IN NATURAL * LANDSCAPE) (DIVERT TRAFFIC FROM (DECREASED SPENDING IN EXISTING (LOSS OF INCOME TO LOCAL ^ ^ t. ESTABLISHED PATTERNS) COMMERCIAL AREAS) POPULATIONS) Effect 3. Secondary Effect—— FIGURE III-7. A schematic example of a "chain of e f f e c t s " r e s u l t i n g from a change i n a r e a l world state (adapted from Bereano et. a l , 1972). . - 74 -from alternative one is appraised as being twice as important as this same impact from alternative two, the u t i l i t y value w i l l reflect this judgement. A linear preference scale ranging from -10 to +10 was used in this case study of alternative pipeline routes. U t i l i t y values for a l l variables were li s t e d in the lower portion of each pertinent c e l l in the matrix (see Appendix E, Figure 7). A jury system of voting and then discussion to resolve conflicts was used to determine the u t i l i t y values in the matrix. The f i n a l step in this methodology was to apply a deci-sion criterion of minimizing the "weighted value" of an alternative. The "weighted value" was defined by summing the products of each varia-ble's u t i l i t y and probability value. For example, the variable "impact on tree species" was given a 100% probability of occurrence and a -3 u t i l i t y value for the Canadian pipeline route. The product results in a -3 combined value for this variable. By summing the combined value of a l l variables, a "weighted value" was attained for the Canadian pipeline route which was compared to the weighted values of the other alternative. COMPUTER MODELLING FOR ENVIRONMENTAL IMPACT The University of Wisconsin at Madison has developed a Regional Environmental Management Allocation Process (REMAP) which has been used to assess the environmental consequences of alternative highway route locations (Krauskopk and Bunde, 1972). This method includes four distinct steps. The i n i t i a l step of this procedure is the development of a data  bank for the study area. The data collected and stored includes natural - 75 -and man-made environmental conditions defined in an objective manner (eg. s o i l data by type rather than s u i t a b i l i t y ) . A second step in this method is to develop, through an inter-disciplinary team, a l i s t of general factors or determinants which com-prise the basic c r i t e r i a used to evaluate the fe a s i b i l i t y of each poten-t i a l highway route alignment. In this case study, ten determinants which reflected economic, engineering, social, cultural, and ecological factors were defined. Next, a linear model is then constructed for each deter-minant which links data-variables into a number of components that comprise the model. The interdisciplinary team assigns weights to variables and components in the form of coefficients, based upon import-ance and extensiveness of the variable within a data c e l l . Although not specifically described, a "normalization process" is used to establish a common numerical base for a l l variables and components. The third stage results in computer print-outs for alternative route locations based upon the importance assigned to each determinant. By subjectively valueing each determinant differently, alternative high-way alignments were located in the case study through a "Line Finder" computer program. This program locates the least cost corridor after integrating a l l determinants and their values. The f i n a l step of this method is to write an impact statement for the decision-making process. The information developed in the pre-vious three steps and the data stored in the computer provides a found-ation for the EIS. It is recommended that an impact statement be written for each different alternative so that the decision-maker can - 76 -choose the most desirable alternative. Specific data can also be pro-vided in terms of the percentage of different types of land affected by the route (eg, recreation, agricultural, etc.) and also the extensiveness of the impact on different natural resources (eg, swamps, minor rivers, lowland forest, etc.). METHODS SEPARATING UNITS OF MEASURE AND QUALIFYING IMPACTS Many have argued against converting economic, social and ecolo-gical impacts into comparable numerical figures because of hidden sub-jective judgements which can distort the true implications of impacts and can conceal them from public identification and discussion (Sorensen and Moss, 1973 and Kusler, 1972). The two methods reviewed in this section attempt to numerically value impacts when possible and otherwise distinguish in descriptive terms the value of a predicted effect. No attempt is made to resolve the incommensurable nature of the many different types of environmental impacts, rationalizing that individual judgements can be made from a quantitative and qualitative description of the environmental consequences of a proposed action. U.S. WATER RESOURCES COUNCIL PRINCIPLES AND STANDARDS The evolution of procedures used in the U.S. to assess the consequences of proposed water resources projects before deciding whether the project merits public investment has led to the existing "Principles and Standards for Planning Water and Related Land Resources" (1973). The foundation of this procedure is an information display and a planning process which are intended to guide water and land resources planning to - 77 -s t r i v e toward meeting the two general objectives of contributing to nation a l economic development and enhancing environmental q u a l i t y . The information display developed by the U.S. Water Resources Council provides data for public review concerning the proposed action and d i f f e r e n t a l t e r n a t i v e choices that are f e a s i b l e to undertake. This information i s organized i n t o a system of accounts which l i s t the bene-f i c i a l and adverse conditions i n the affected area(s) with and without the proposed action. A separate account d i r e c t l y considers each of the established objectives f o r planning water and land resources. The ac-count r e l a t i n g to n a t i o n a l economic e f f i c i e n c y i s intended to reveal the monetary f e a s i b i l i t y of the investment at a n a t i o n a l l e v e l while the environmental q u a l i t y account displays the e x i s t i n g and p o t e n t i a l l y im-pacted q u a l i t y of n a t u r a l , c u l t u r a l and e c o l o g i c a l systems i n the affected area(s). Also included i n t h i s information display i s a separate account for regional development and an account for s o c i a l well-being. The account concerning regional development assesses the proposed plan i n r e l a t i o n to the relevant planning region(s) (eg. l o c a l , r i v e r basin, s t a t e s ) , and the s o c i a l well-being account emphasizes the incidence of impacts on persons and groups based upon changes i n income, employment and other s o c i a l f a c t o r s . Each of the four accounts i s f u r t h e r subdivided into categories. C r i t e r i a have also been developed which can be valued to assess the a l t e r n a t i v e s (see Appendix F, Table 1). A l l monetary e f f e c t s are valued q u a n t i t a t i v e l y while non-monetary impacts are described both numerically and q u a l i t a t i v e l y . The planning process which produces the information display and - 78 -fa c i l i t a t e s making an equitable decision concerning the proposed action consists of the following six basic steps (U.S. Water Resources Council, 1973): 1) Specify components of the objectives relevant to the planning setting; 2 2) Evaluate resource capabilities and expected conditions without any plan; 3) Formulate alternative plans to achieve varying levels of contributions to the specified components of the objectives; 4) Analyze the differences among alternative plans to show tradeoffs among the specified components of the obj ect ives; 5) Review and reconsider, i f necessary, the specified components for the planning setting and formulate additional alternative plans as approriate; and 6) Select a recommended plan from among the alternatives based upon an evaluation of the tradeoffs between the objectives of national economic development and en-vironmental quality. The ultimate objective of this planning process and system of accounts is to f a c i l i t a t e selecting the alternative which best contributes to "pro-mote the quality of l i f e " in the region and nation as a whole. U.S. ATOMIC ENERGY COMMISSION EIS PREPARATION GUIDELINES Since the significant Calvert C l i f f s court decision ruled that the procedures used by the Atomic Energy Commission in assessing environ-mental factors before licensing nuclear power plants did not comply with NEPA, the commission has developed new procedures (1973) for evaluating environmental impact which are intended to produce a statement of the broad monetary/non-monetary consequences of a proposed action. This new method actually leads to an expanded benefit/cost analysis developed - 79 -according to a standardized twelve-chapter format. The focus of the procedure can be divided into two significant parts. The purpose one part i s to guide the preparation of impact statements to complete an analysis of alternative site and site/plant-type choices which exist as feasible courses of action. This analysis must indicate that the pro-posed f a c i l i t y i s the cost-effective alternative, evaluated through a quantitative and qualitative description of the "economic, social and other environmental factors, and any institutional (governmental, etc.) constraints." The second important part of an impact statement produced by this method i s to "weigh" the f u l l economic, social and environmental benefits and costs of the proposed action. This is to be accomplished in quantitative and qualitative terms throughout the text of an EIS and summarized in a table which l i s t s for a l l adverse consequences the number of units affected ( i f possible), the extensiveness of each impact and the page reference for discussion in the text (see Appendix F, Tables 2 and 3 ) . The procedure developed by the Atomic Energy Commission also requires disclosure of the incidence of impacts on population groups, any unavoidable or adverse effects, the time span of impacts, the i r r e t r i e -vable commitments of resources, the potential and adopted mitigation measures taken, and a discussion of both the baseline inventory data completed during the early stages of project planning and the monitoring programs to be undertaken during construction and operation of the f a c i -l i t y . Perhaps the most useful aspect of this procedure is the guidance provided through an extensive checklist of the potential environmental impacts of constructing and operating a nuclear power plan. - 80 -DISCUSSION AND CONCLUSION At present, no consensus exists concerning which method i s best-suited for the purpose of evaluating the environmental consequences of a proposed action. Through this brief survey i t i s easy to under-stand why. The methods are d i f f i c u l t to understand due to their complexity, some were devised specifically for a single purpose, and a l l evaluation methods reviewed in this chapter rely upon subjective judgements at some stage in their application. Although not a l l proce-dures that exist to evaluate environmental impact were descriptively reviewed in this chapter, i t i s f e l t that a cross-section of the most feasible and well-known approaches to this relatively new "art" have been described. The environmental impact assessment methods described in this chapter are different in many ways from one another. Most methods were developed for a specific type of project such as water resources projects, nuclear power plants and highway projects while other evaluation ap-proaches serve a wider use. Many methods were intended for use only to evaluate alternatives. As discussed in chapter two of this thesis, the evaluation of alternatives i s a significant part of an EIS, but i t does not comprise the entire assessment. Some impact assessment methods discussed in this chapter require the use of an interdisciplinary team or specific s k i l l s and knowledge is needed to apply the procedure. In order to provide a broad view of these different methods and their diverse characteristics, Figure III-8 was developed to il l u s t r a t e the varying characteristics which can influence the selection of a method - 8 1 -CAPABILITY/SUITABILITY ANALYSIS MULTIPLE EFFECTS NETWORKS U . S . G . S . MATRIX ENERGY NETWORK DIAGRAMS OPTIMUM PATHWAY MATRIX APPROACH EARLY METHOD BATTELLE COLUMBUS LATER METHOD EFFECTS CHAINS . COMPUTER MODELLING- ENV. IMPACT U.S. WATER RESOURCES COUNCIL U.S. ATOMIC ENERGY COMMISSION Q O ac EH W CO o 2 Q O S3 EH H CO O D CU D CU W i-l W CU I-H M U EH H D CO S w CO D a z H l-H &, H U CO H . w EH 2 « O fa Q fa Q 2 O U u H fa H EH 2 fa Q EH O CO H Q H > cn 2 o H EH g g W EH U < CO w Q H 1 A. X X X X X X X X X X X X X X X x x • x X X X X X X X CO a H EH < w EH < CU S o u o EH hH 2 hH D fa fa CO D CO EH 2 fa S § H D O I £ 3 8 H EH CM CO H fa fa a H D O CO fa a H « CM FIGURE III-8. A matrix display of some factors to be considered in selecting a methodology for use in environmental impact evaluation. - 82 -for use i n impact assessment. These diverse c h a r a c t e r i s t i c s i n d i c a t e the d i f f i c u l t y that would be encountered i n any attempt to c r i t i c a l l y review the usefulness of each method. As a r e s u l t , these methods w i l l be only generally assessed l a t e r i n t h i s thesis according to the four basic types defined i n t h i s chapter. These four types are: 1) C a p a b i l i t y / S u i t a b i l i t y analysis methods; 2) Methods for impact i d e n t i f i c a t i o n only; 3) Evaluation methods which aggregate impacts into common un i t s ; 4) Evaluation methods which separate units of measure and q u a l i f i e s impacts. PART TWO - 83 -chapter four a critical review of five environmental Impact statements INTRODUCTION The theoretical purpose of an environmental impact statement is to inform the reader of the total consequences of a project in order to f a c i l i t a t e a rational decision about the proposal. In Chapter Two, nine general c r i t e r i a were established to test whether a EIS is written satis-factorily to meet this purpose. These nine c r i t e r i a w i l l be used in this chapter to judge the adequacy of five impact statements. Since this study established standards for a l l impact statements, the environmental reports c r i t i c a l l y evaluated in this chapter were chosen to represent different major actions which obviously require an EIS. One impact statement was chosen for a hydropower development, a power genera-tion plant with coal mining operation and transmission lines, an airport runway extension, a magnesium mining operation and processing plant, and a highway. Although these case studies do not provide a s t a t i s t i c a l l y 0 reliable sample from which a definitive conclusion can be reached about the adequacy of impact statements presently being produced, this critique uses environmental reports prepared at least two years later than those selected for other c r i t i c a l reviews known to the author (notably, Sullivan and Montgomery, 1972; Kreith, 1973; and Kennedy and Hanshaw, 1974). A l l environmental reports chosen for this chapter were prepared after August 1973. - 8U -- 85 -Each of the environmental impact statements to be c r i t i c a l l y reviewed in this chapter w i l l be discussed in two basic parts. F i r s t , a brief description of the proposed project and environmental setting w i l l be completed to provide a general view of the situation the impact report attempted to assess. Second, the relevant c r i t e r i a which have not been adequately considered in the EIS w i l l be discussed. The criticisms w i l l only relate to the more important weaknesses of the impact report, and w i l l be illustrated by specific examples. It might be helpful in this chapter to refer back to the outline of the c r i t e r i a established in Chapter Two for this review purpose (pp. 49, 50, 51). THE SEVEN MILE HYDROPOWER PROJECT The environmental impact statement (as broadly defined in this thesis) for this B.C. Hydro and Power Authority Project was actually completed in two separate studies which w i l l betboth reviewed in this part of the chapter. One study, entitled "Environmental Impact Report, Seven Mile Project" (1973) was prepared by Envirocon and Pearse Bowden Consultants. The terms of reference submitted by B.C. Hydro and Power Authority limited the study to mainly ecological and recreational con-siderations. A second study, "The Social and Economic Impacts of the Proposed Seven Mile Hydro-Electric Project," was completed by B.C. Research in May of 1974. BRIEF DESCRIPTION OF PROPOSED ACTION AND ENVIRONMENTAL SETTING The proposed Seven Mile Project i s located on the Pend d'Oreille River within the Columbia River Basin near the Washington and British - 86 -Columbia border (see Figure 1V-1) about eight miles southeast of T r a i l , B.C. The proposed concrete gravity dam would u t i l i z e approximately 200 feet of head to produce 3,100 million kilowatt-hours per year in the 750 magawatt power plant. Since the river i s in a steep valley, the reservoir to be created by the dam w i l l be long and narrow, inundating approximately 800 acres of land along nine miles of river. The section of the Pend d'Oreille River which would be affected by the project is a free-flowing, turbulent watercourse within a scienic valley. The vegetation in the valley is typical for this area of south-eastern B.C., including mainly Douglas Fir (Pseudotsuga menziesii) and also Lodgepole Pine (Pinus contorta) Cedar (Thuja plicata), Hemlock r(Tsuga spp.) and other common trees and shrubs. Most of the vegetation in the area to be affected by the project is in an early successional stage with only two small stands of trees which offer any commercial value. Within this mostly mature forest there are many open areas where grasses and forbs are well-developed. These open areas at low elevation provide an important winter range for a large population (estimated at 1700 deer and small numbers of elk and moose) of wild ungulates. The river i t s e l f i s usually s i l t y due to mine tailings released upstream, and supports only small populations of trout but much larger numbers of "rough" fish. The recreational value of the affected physical area is derived from hunting, hiking and aesthetic viewing. /The small towns and communities which would be affected by the project are T r a i l , Fruitvale, Moutrose, Warfield, Rossland, Castlegar, Nelson and Salmo. The economy of this region is based on extractive - 87 -- r i m / FIGURE IV-1. General study area of the proposed Seven Mile Hydropower Project<Envirocon Ltd., et. a l . , 1973). - 8 8 -ENVIRONMENTAL INVENTORY * Description of Actions * Description of Setting Affected Delineation of "Affected" Area ECONOMIC EFFICIENCY * Li s t of Assumptions Use of Standardized Approach SOCIO-CULTURAL IMPACTS * Comprehensive Identification Quantitative Assessment Importance Assignment^-ECOLOGICAL IMPACTS <* Comprehensive Identification Quantitative Assessment Importance Assignment^" DISTRIBUTION CONSEQUENCES Identified to Groups ( Identified to Areas SHORT-TERM VS. LONG-TERM EFFECTS * Discussion of Future Uses Curtailed ANALYSIS OF ALTERNATIVES * Choice of "No Action" Included * Range of Choices Included Tradeoffs Identified * RELATIONSHIP TO ESTABLISHED TO ESTABLISHED GOALS * Project Related to Citizen Goals * COMMUNICATION OF INFORMATION * Project Rationale Included * Report Logically Organized and "Objective" * Report Succinct, Non-Technical Summary Included TABLE IV - 1 . Checklist summary of non-compliance with c r i t e r i a for the Seven Mile impact studies. ^ -Indicates an inadequate discussion of requisite i n environmental impact statements. i ! On page 39 four considerations i n conjunction with quantitative predictions j were developed to f a c i l i t a t e the reader of an EIS i n assigning importance to inroads. - 89 -mining and logging, resource processing plants, and the supporting service industry. NON-COMPLIANCE WITH CRITERIA Criterion I_ — Project Description and Environmental Inventory The two impact studies for the Seven Mile project completed a description of the proposed project and environmental setting, but in the Envirocon report there was very l i t t l e mention of the construction aspects of the proposed dam. Construction activities such as blasting, roadbuilding and gravel mining ban cause important long-term ecological effects which should be described in an impact report. Criterion II — Economic Efficiency An analysis of the economic efficiency of the proposed Seven Mile Hydropower Project was not disclosed within either impact study. The only reference to the economic f e a s i b i l i t y of the project noted that the proposal was assessed as having the greatest potential for power production per acre of reservoir of a l l remaining latent hydropower sites in British Columbia. This brief reference to the project's economic efficiency was made in both impact studies, but no evidence was disclosed about how this conclusion was reached. Criterion III — Socio-Cultural Impacts Based upon the impact report completed by B.C. Research, i t i s fe l t that some apparent social and cultural impacts of the Seven Mile Hydropower project were not disclosed. The report concentrated mainly on the social and physical services which would be affected during construe-- 90 -tion of the dam, and failed to identify some of the more "intangible" yet important socio-cultural consequences. For example, community co-hesion and l i f e style are socio-cultural impacts which were not mentioned in the B.C. Research report. Community cohesion has been defined as a "unifying force" within a social setting leading to "patterns of inter-relationships, common institutions, commonly agreed-upon ways of behaving and a common identity" (U.S. Army Corps of Engineers, 1974). Life style might be termed the daily activities and habits of a person(s) which are affected by an aggregate of existing environmental conditions. Although these two "intangible" socio-cultural factors are not readily quanti-fiable nor easily understood, they are significant impacts which should have been qualitatively described in the Seven Mile Project impact report, especially since i t was mentioned that three small communities in the Seven Mile Project area w i l l experience most of the peak influx of over 400 construction workers looking for short-term residence for their families. Other adverse socio-cultural impacts which were not discussed in the B.C. Research Report include aesthetic effects and impact on ethnic groups. It i s d i f f i c u l t to ascertain whether these potential impacts were omitted from consideration, whether they were found not applicable for this- particular project, or whether they were defined as i n s i g n i f i -cant for discussion in the text. It would seem that aesthetic impacts were omitted from discussion, especially in reference to construction impacts. For example, i t was mentioned that a gravel truck would li k e l y pass a certain point on an existing public road for two consecutive years - 91 -at approximately four minute intervals for eight hours a day during five days a week. These trucks w i l l follow an existing road part of the way and continue on a new road to the dam site and w i l l pass within 1/2 mile from residential homes in an existing community. It was not mentioned in the report whether there were any homes near the gravel site or exist-ing public highway. It is lik e l y that noise and perhaps dust w i l l cause significant aesthetic displeasure to any nearby residences. Criterion IV — Ecological Impacts As in the identification of socioieuibtural effects, there are several apparent impacts which were not discussed in the Seven Mile Project environmental studies. It was mentioned earlier under Criterion I that the report completed by Envirocon did not describe the construction activities associated with the proposed Seven Mile Dam project. Likewise, construction impacts on the natural physical and natural biological en-vironment were not even mentioned. An example of a potentially signi-ficant construction impact for this project i s the development of a gravel pit near the construction site to obtain materials for the dam. The socio-cultural impact report mentioned that during normal working hours and days a loaded gravel truck w i l l pass any one point in the road to the dam site on the average of every seven and one-half minutes. This frequency w i l l occur for two consecutive years and w i l l decrease^to approximate 20 minute intervals for two following years. a^Thus1; ;.a gravel pit of considerable size w i l l be developed which could lead to important long-term aesthetic, drainage, erosion and other multiple-order impacts. Other possible impacts which were omitted from discussion are - 92 -the blockage of s i l t d e p o s i t i o n downstream due to the existence of the dam, decreased downstream oxygen l e v e l s and changed water temperature i n the r i v e r from the e l i m i n a t i o n of nine miles of t u r b u l e n t f l o w i n g stream, and the e f f e c t of the proposed r e s e r v o i r on groundwater l e v e l s i n nearby r e s i d e n t i a l areas. A l l of these impacts have p o t e n t i a l con-sequences which may be important i n the area a f f e c t e d by the Seven M i l e P r o j e c t . C r i t e r i o n VI — Short-Term Resource Uses vs. Long-Term E f f e c t s As mentioned i n Chapter Two, i t i s d i f f i c u l t to decide whether a proposed a c t i o n m e r its p u b l i c investment without b a l a n c i n g the long-term consequences w i t h the short-term e f f e c t s . This i n c l u d e s a d i s -cussion of the resource options a v a i l a b l e to f u t u r e generations which would be f o r e c l o s e d by a proposed p r o j e c t (eg, use of renewable and non-renewable resources). To f u l f i l l t h i s requirement adequately would be to i n c l u d e a separate d i s c u s s i o n i n an environmental r e p o r t of short-term g e n e f i c i a l and adverse e f f e c t s compared to the important long-term b e n e f i c i a l and adverse e f f e c t s . Thus, the reader w i l l be helped i n a s s i g n i n g importance to the impacts and w i l l l i k e w i s e be b e t t e r able to judge the s o c i a l worth of the e n t i r e p r o j e c t . Although the time span of impacts was g e n e r a l l y defined i n the Seven M i l e P r o j e c t impact s t u d i e s , no separate d i s c u s s i o n attempting to juxtapose these d i f f e r i n g types of impacts was included. C r i t e r i o n V I I — A n a l y s i s of A l t e r n a t i v e s No a l t e r n a t i v e s were discussed i n the environmental impact - 93 -studies for the proposed Seven Mile Project. Criterion VIII — Relationship to Established Goals The B.C. Research socio-economic impact study discussed the im-pact of the proposed project on existing physical services in the two nearby regional d i s t r i c t s , but no reference was made in either study to any formal planning reports or any public participation related to the project, or goals and objectives of the citizens established locally or regionally. Criterion IX — Communication of Information As mentioned several times in this thesis, the purpose of an environmental impact statement is to communicate the total consequences of the proposed project to the reader. The existence of two separate impact studies for the Seven Mile Hydropower Project makes i t d i f f i c u l t for an interested person to determine the relevant information so that he can individually judge the proposal. The communication of information to the reader i s made even more d i f f i c u l t due to the overlapping scope of information covered in the two impact studies. For example, the re-port completed by Envirocon economically evaluated the potential adverse recreation impact of the proposal, although existing recreational oppor-tunities are actually a social condition. B.C. Research completed a report entitled "The Social and Economic Impacts of the proposed Seven Mile Hydro-Electric Project" which discussed recreation impacts but not in economic terms. Such an evaluation of impacts in two overlapping reports is confusing to the reader and could actually serve to conceal - 94 -some important potential consequences from public view. The overlapping scope of these reports is not the fault of the authors because they were guided by the terms of reference from B.C. Hydro which are included in Appendix G. As can also be seen in these terms of reference, the lack of compliance with some of the c r i t e r i a discussed earlier cannot be attributed to Envirocon & Pearse Bowden or to B.C. Research. An important problem with these impact studies i s that they lacked a complete disclosure of the project's beneficial consequences. Since no real economic efficiency analysis was included, i t i s d i f f i c u l t to reach a rational judgement about the social worth of the proposal i f only negative consequences are disclosed. In this respect, i t is f e l t that an impact report should provide an unbiased account of a l l the significant beneficial and adverse consequences of the proposed project so that the reader can "weigh" these impacts to reach an informed, rational decision. Detailed reports can also communicate information in a mislead-ing manner. For example, a beneficial social impact which was described by the B.C. Research socio-economic study was the short-term input to local economies during construction of the project due to increased employment and subsequent increased spending in the region. In general, the increased local expenditures are a benefit, but i t i s f e l t that the B.C. Research report quantified this effect in a misleading way. By quantifying this impact in dollars, i t over-emphasized the real benefits which are increased income to local residents. A considerable amount of the quantified total of increased expenditures within the region would be disbursed by local retailers for supplies and other additional - 95 -expenses, which therefore cannot really be considered a monetary "bene-f i t " to these local residents. Although the B.C. Research report also quantified this benefit more accurately in increased regional employment in local r e t a i l , wholesale and manufacturing staffs, quantifying i n -creased expenditures regionally and referring to i t as a benefit dis-guises and over-emphasizes the real benefit which is increased income. This problem would have been avoided i f a benefit/cost analysis was completed for the project according to standardized methods. A f i n a l , relatively minor criticism concerning the communication of information to persons reading these studies i s that the basic i n -ventory of socio-cultural and ecological conditions was often integrated with the prediction of impacts. Although this may not seem to be a problem, about half of the pages in most environmental impact statements, out of necessity, discuss the existing environmental conditions in the area(s) affected by the proposed project. It is more d i f f i c u l t for the reader of the report to identify and understand a l l of the impacts i f interspersed within numerous pages of boring inventory information. It would be more informative to the reader i f impact statements describe as much of the environmental setting as possible in a separate section of the text. COLSTRIP GENERATION AND TRANSMISSION PROJECT The $800,000 assessment of this electrical plant and transmission line project by Westinghouse Environmental Systems has a scope that is actually broader than an environmental impact statement. It is a total planning analysis which not only considers environmental impacts but also - 96 -includes an intensive analysis of site and route location choices, alter-native designs, broad social issues and public viewpoints relating to the proposal, and monitoring programs. As stated in the introduction of the environmental impact report, i t was prepared as "... a source docu-ment designed to present the findings to the state and federal reviewing agencies and to provide society with the data necessary for consideration of the project's environmental effects." The report complies with the U.S. National Environmental Policy Act of 1969 and with the Montana U t i l i t y Siting Act of 1973. BRIEF DESCRIPTION OF THE PROPOSED ACTION AND ENVIRONMENTAL SETTING The proposed project consists of a coal mining operation', thermal power plant complex and a transmission line system with two substations. In the 37 year l i f e of the proposed plant, approximately 296 million tons of low sulphur coal w i l l be strip-mined within 10 miles of the proposed plant site. The electrical generation plant w i l l consist of four steam turbine generators which have the capacity to supply 2060 megawatts of water. Cooling water for the plant w i l l be transported 29 miles from the Yellowstone River in two underground steel pipelines. The power generated by the plant w i l l be conveyed by dual 500 kv transmission lines extending approximately 430 miles across Montana where i t w i l l connect to an existing 500 kv. system. The plant w i l l be located in southeastern Montana near the small community of Colstrip (see Figure IV-2) approximately 100 miles east of Billings. The region in the vi c i n i t y of the plant i s sparsely populated with only a few small towns within a 50 mile radius of the project. The CANADA * P L A N T S I T E FIGURE IW2. Location and general study area of the C o l s t r i p Thermal Power Development (Westinghouse Environmental Systems, 1973)* - 98 -ENVIRONMENTAL INVENTORY Desc r i p t i o n of Actions D e s c r i p t i o n of Setting A f f e c t e d Delineation of "Affected" Area ECONOMIC EFFICIENCY L i s t of Assumptions Use of Standardized Approach SOCIO-CULTURAL IMPACTS Comprehensive I d e n t i f i c a t i o n Quantitative Assessment Importance Assignment^ ECOLOGICAL IMPACTS Comprehensive I d e n t i f i c a t i o n Quantitative Assessment Importance Assignment^ DISTRIBUTION CONSEQUENCES I d e n t i f i e d to Groups I d e n t i f i e d to Areas SHORT-TERM VS. LONG-TERM EFFECTS * Discussion of Future Uses C u r t a i l e d * ANALYSIS OF ALTERNATIVES * Choice of "No Action" Included * Range of Choices Included * Tradeoffs I d e n t i f i e d * RELATIONSHIP TO ESTABLISHED TO ESTABLISHED GOALS Project Related to C i t i z e n Goals COMMUNICATION OF INFORMATION * Project Rationale Included Report L o g i c a l l y Organized and "Objective" * Report Succinct, Non-Technical ^ Summary Included TABLE IV - 2 . Checklist summary of non-compliance with c r i t e r i a f o r the C o l s t r i p generation and transmission project EIS. Indicates an inadequate d i s c u s s i o n of r e q u i s i t e i n environmental impact statements. On page 39 four considerations i n conjunction with q u a n t i t a t i v e p r e d i c t i o n s were developed to f a c i l i t a t e the reader of an EIS i n assigning importance to - 99 -natural environment in this Region is mostly rolling prairie with some isolated mountains and a harsh climate. This grassland region also i n -cludes Ponderosa Pine (Pinus. ponderosa) trees at higher elevations, and supports populations of Deer, Antelope, some waterfowl and other r e s i -dent game birds. The study area for the transmission route is diverse since i t comprises, a 36,000 square mile section of Montana, including rolling grassland prairies, scenic mountain ranges, wide valleys and numerous rivers and streams. NON-COMPLIANCE WITH CRITERIA Criterion VI — Short-Term Resource Uses vs. Long-Term Effects The Colstrip environmental impact report adequately defined the time span of significant effects, but did not include a separate discussion contrasting significant short-term impacts with potential long-term implications. For example, the use of 260 million tons of coal during the 37 year l i f e of the plant constitutes a significant depletion of a non-renewable resource. The numerous potential uses of f o s s i l - f u e l resources today directs that consideration be given in an EIS concerning whether thermal power production is the highest and best use of coal for present and future generations. No discussion of alternative uses of coal was completed, and the entire report followed the underlying premise that " u t i l i t i e s must meet the future demand of users." Thus, the report assumed that, based upon an analysis of hydropower, nuclear and other f o s s i l fuel powered plant choices, meet-ing this demand through a coal-fired plant was the best possible use of this, non-renewable resource. Related to this criticism of the impact - 100 -report i s a rather cursory consideration of the "no a c t i o n " a l t e r n a t i v e , which was discarded without analysis due to the "adverse socio-economic consequences" which would r e s u l t i n the Northwest U.S. from not meeting projected future demands:. C r i t e r i o n VII — Analysis of A l t e r n a t i v e s Several a l t e r n a t i v e s i t e / r o u t e locations and design choices were thoroughly assessed according to sophisticated environmental plan-ning methods but, as mentioned e a r l i e r , there was not an analysis of the "no a c t i o n " a l t e r n a t i v e or an assessment of alternate e l e c t r i c a l energy demand projections. The eight pound weight and 11 x 16 inch format of t h i s volume provides an appearance of comprehensiveness which i s perhaps why the lack of analysis of the basic EIS requirement of "no a c t i o n " i s so s t r i k i n g . An apparenti-alternative which, was not assessed thoroughly i n the EIS i s l o c a t i n g the plant i n western Montana and transporting the coal to t h i s s i t e . I t was mentioned i n the report that over two-thirds of the e l e c t r i c a l energy generated by the plant would be transmitted to western Montana to hook-up with the Bonneville Power Authority 500 kv. l i n e s . Despite the amount of energy to be sent west, the analysis of whether i t should be transported i n the form of coal or e l e c t r i c i t y considered only the monetary costs involved and d i d not adequately com-municate the basic tradeoff of d i f f e r e n t environmental impacts of l o c a t i n g the plant s i t e i n western Montana (the need for 430 miles of 500 kv. lines, would be eliminated) at the increased economic costs of coal transport. - 101 -Criterion IX — Communication of Information The most important criticism of the Colstrip environmental im-pact report is that the great size of this impressive volume restricts a l l but the most persevering reader from assimilating the relevant i n -formation from the report to reach a rational judgement about the proposal. Even attempting to find a particular aspect of the proposal is; d i f f i c u l t in thisr, volume since the table of contents totals 11 sheets in length. Although the report may qualify as a "source document," i t is doubtful that decision-makers or many other interested persons in society w i l l be able to absorb the vast amount of data included in the report. Yet, the report did include a major summary of the project's environmental impacts. If this summary is meant to inform the reader of the important consequences of the Colstrip Project, two major pro-blems arise. F i r s t , the summary does not include a l l of the major impacts of the project. For example, many regional socio-cultural impacts which, to this author, seem significant were not discussed in the summary. The prospective appearance of the "boom and bust" towns in the region from project construction and the subsequent effects on existing residents in the regions were not mentioned in the summary of social and economic impacts. Instead, regional and statewide economic benefits were described in a subjective manner, and the adverse regional socioeconomic impacts, were mentioned merely as. the monetary costs of "... new and expanded school f a c i l i t i e s and programs, law enforcement personnel and equipment, road and highway improvements..." etc. The second problem with, the summary of this volume is that i t gives the im-pression that i t was written merely to j u s t i f y the proposed project. - 102 -This i s most evident from the q u a l i f y i n g statements which were often used to i d e n t i f y adverse impact. For example, the summary of environ-mental costs begins with the sentence "state and federal regulations applicable to a i r , land and water w i l l be met and the environmental impact of the plant and transmission l i n e w i l l be minor, as shown i n Tables 1. 7-2 and 1. 7-3." This table (see Table IV-3 and IV-4) pro-vides quantitative figures which have very l i t t l e meaning to the reader, and i f anything, seem to i n d i c a t e impacts that would be s i g n i f i c a n t to many persons. A d e s c r i p t i o n of the v i s u a l impact of the transmission lines: begins with the sentence "Although, the l i n e w i l l impinge unavoid-ably on the view of people i n some areas, every attempt has been made i n s e l e c t i n g the route to minimize the number of viewers, and the same e f f o r t w i l l be made i n l o c a t i n g the c e n t e r l i n e . " Another q u a l i f y i n g statement concerning radio reception near the transmission l i n e s men-tions that "During inclement weather, e s p e c i a l l y during r a i n or snow, reception very near the l i n e may not be e n t i r e l y s a t i s f a c t o r y . However, atmospheric noise alone would probably cause a problem under such weather conditions" (end of paragraph). The p r i o r comments concerning the Westinghouse Report serving to j u s t i f y the C o l s t r i p project rather than attempting to o b j e c t i v e l y i d e n t i f y the environmental impact leads one to suspect whether the volume was prepared f o r any decision-making purpose. I t i s also true that Westinghouse was f i r s t engaged i n January of 1973 to undertake t h i s report, at a time when two of the four C o l s t r i p turbine generators were - 103 -E S T I M A T E D B E N E F I T S O F T H E C O L S T R I P P R O J E C T Benefits Delivered Products: Total power generating capacity, Mw Value of total electrical power annually, S10 6 Power delivered to Hot Springs terminal, Mw Employment: Construction labor force—Power plant employees, maximum 1658 Transmission line employees 360 Operational labor force—Direct employees 820 Indirect employees 1400 Income: Total construction labor personal income, S10 3 196 Total annual direct operational labor personal income. S10 6 9.4 Total personal income over plant economic lifetime, S10 6 —Direct operational 345 —Indirect 557 Tax Revenues: Total annual tax revenues, S10 6 17.4 Total tax revenues over plant economic lifetime, S10 6 648 Present Value of Benefits:* Electrical power purchased, S10 9 1.3 Personal income. S10 6 376 Tax revenues, S 10 s 172 Economic benefits over economic plant lifetime. 2060 133 1350 TABLE IV-3. Summary benefits of the proposed Colstrip thermal power development (Westinghouse Environmental Systems, 1973). - 1 0 4 -COST SUMMARY FOR POWER PLANT Economic Costs Capital costs.(UoiiS 1. 2, 3 and 4) Dollars S54O.000.0OO Environmental Costs AirQualify. Including Background Level: Annual maximum ground-level concentration SOs. /ig/m* NO?, tig/m* Particulates, ^g/m 1 One-hour maximum ground-level concentration SOs. fig/m3 Maximum exposure of off-site locations to ground fog, hr Terrestrial Impact: Total cropland disturbed or converted to other use, acres Other land disturbed or converted to other use. acres Strip-mined and reclaimed, acres Land converted to aquatic habitat and recreation area (surge pond), acres Aquatic Impact: Maximum water use rate, cfs Biological and physical impacts 11.9. 14.0 15.2 643 37 332 . 602 11.000 150 59 Negligible C O S T S U M M A R Y FOR COLSTRIP TO HOT SPRINGS TRANSMISSION LINE Economic Costs Capital costs,! includes stations and access roads) Dollars Annual electrical loss penalty, dollars/year 5120,517.315 6,980.000 Environmental Costs Terrestrial Impact: Wildlife, miles of range crossed* 2.034 Soil erosion, acres 865 Total cropland disturbed or converted to other use. acres 290 Other land disturbed or converted to oiher use, acres 394 Aesthetic Impact: Residences within 1 mile of corridor, number 205 Total annual viewing time from highways, man-hours 867,787 Scenic Impact: Mites in areas of scenic hills and mountains 10 Miies in other scenic areas 41 'Greater than 426 miles because many areas contain several species. TABLE IV-4. Summary costs of the,-proposed Colstrip thermal power development.(Westinghouse Environmental Systems, 1 9 7 3 ) . -105 -already under construction.* Despite construction already occurring, considerable detail in the Westinghouse environmental impact statement was devoted to selecting a site for the plant according to ecological and economic c r i t e r i a . Consequently, the author of this critique be-lieves that the principal benefit of this detailed volume was in deve-loping mitigation measures for environmental impacts. A commendable report was, completed in this respect. NORTHWEST ALLOYS MAGNESIUM PLANT The environmental impact statement for the proposed Northwest Alloys Magnesium Plant at Addy, Washington was prepared by the Washington State Department of Ecology in compliance with the National Environmental Policy Act and the Washington State Environmental Policy Act. In essence, the proposed magnesium plant posed a major step toward increased pros-perity in an indigent area of Washington at the price of potentially significant a i r , water and land quality impacts. This controversial project prompted more than 150 written comments from private citizens, interest groups and public agencies which were both for and against the proposal. The controversy over the plant i s a microcosm of the existing growth vs. no-growth issue in western society today. The environmental impact report attempts to assess the consequences of this proposal to fa c i l i t a t e public scrutiny, government agency review and subsequent decisions about the social worth of the proposal. ft A less impressive impact statement had been prepared at an earlier date for construction approval of the project. - 106 -BRIEF DESCRIPTION OF PROPOSED PROJECT AND ENVIRONMENTAL SETTING The proposed project by Northwest A l l o y s , Inc. (a subsidiary of the Aluminum Company of America) e n t a i l s a mining operation and a pro-cessing plant which would produce magnesium and s i l i c o n products. E x i s t -ing plans f o r the mining a c t i v i t i e s include the development of s i x open p i t dolomite and quartzite mines within 13 miles of the plant s i t e . The plant w i l l u t i l i z e between 400,000 and 650,000 tons of both dolomite and qua r t z i t e annually, large amounts of groundwater and approximately 950,000 megawatt hours of e l e c t r i c a l energy per year to produce peak t o t a l s of about 79,800 annual tons of magnesium and s i l i c o n products. The proposed plant would be located near the small community of Addy i n Stevens County of northeastern Washington. The population of the e n t i r e county is: approximately 18,000 people, and the economy of the region is. based on a g r i c u l t u r e , the lumber industry and supporting ser-vices.. The community of Addy i s nestled near two mountains i n the scenic and pastoral C o l v i l l e River V a l l e y . Forest vegetation i n the elevations above the a g r i c u l t u r a l v a l l e y includes the dominant species of Ponderosa Pine (Pinus ponderosa) and Douglas F i r (Pseudotsuga menziesii) and the v a l l e y e x i s t s as an important wintering area f o r large populations of deer. The climate i n the v a l l e y i s dry (13-27 inches per year), but cold i n Winter (frequent temperatures below 0°) and warm i n Summer (frequent high temperature above 90°). A i r c i r c u l a t i o n i n the v a l l e y is, very poor. - 107 -FIGURE IV-3. Location of the proposed magnesium plant at Addy (from Washington State Department of Ecology, 1973). - 108 -ENVIRONMENTAL INVENTORY Description of Actions Description of Setting Affected Delineation of "Affected" Area ECONOMIC EFFICIENCY List of Assumptions Use of Standardized Approach SOCIO-CULTURAL IMPACTS * Comprehensive Identification * Quantitative Assessment * Importance Assignment'- * ECOLOGICAL IMPACTS * Comprehensive Identification Quantitative Assessment . Importance Assignment'- * DISTRIBUTION CONSEQUENCES Identified to Groups Identified to Areas SHORT-TERM VS. LONG-TERM EFFECTS Discussion of Future Uses Curtailed ANALYSIS OF ALTERNATIVES Choice of "No Action" Included Range of Choices Included Tradeoffs Identified RELATIONSHIP TO ESTABLISHED TO ESTABLISHED GOALS Project Related to Citizen Goals COMMUNICATION OF INFORMATION * Project Rationale Included Report Logically Organized and "Objective" Report Succinct, Non-Technical Summary Included * TABLE IV-5. Checklist summary of non-compliance with criteria for the Northwest Alloys Magnesium Plant EIS. fc Indicates an inadequate discussion of requisite in environmental impact statements. ''On page 39 four considerations in conjunction with quantitative predictions were developed to facilitate the reader of an EIS in assigning importance to impacts. —109 -NON-COMPLIANCE WITH CRITERIA  C r i t e r i o n II — Economic E f f i c i e n c y Although, an economic e f f i c i e n c y analysis was not completed f o r t h i s proposed magnesium plant, such an analysis should not be expected since public funds are not being allocated toward t h i s p r o ject. C r i t e r i o n I I I — Socio-Cultural Impacts The Impact statements for the Northwest A l l o y s Magnesium Plant at Addy d i d not quantify or adequately describe some s o c i a l impacts. For example, the impact on community and s o c i a l services was described merely as caused by increased population i n the county which would r e -s u l t i n e i t h e r a decline i n q u a l i t y of the services or inducing addi-t i o n a l expenditures i n order to keep pace with demand. No projections were made concerning the degree of expansion i n p o l i c e , f i r e p r o t e ction, schools, roads, water and sewer l i n e s , and medical f a c i l i t i e s , nor did the statement assess the l i k e l i h o o d of each service r e q u i r i n g expansion. Likewise, there was no q u a n t i f i c a t i o n of the increased l o c a l taxes which could r e s u l t from the increased services required due to the predicted addition of 3000 to 5000 persons i n the county induced by the proposed project. A s o c i a l impact which was not considered i n the report concerns the e f f e c t of the project on housing i n the region. The only mention of t h i s r e s i d e n t i a l growth i n the EIS stated that "... small towns, v i l l a g e s and i s o l a t e d farms:, w i l l gradually change as towns and suburbs expand." The EIS would be more comprehensive i n r e l a t i o n to s o c i a l impacts i f i t described the reasons why no housing shortage would occur ( i f t h i s i s - 110 -the reason why i t was not discussed i n the EIS) or attempt to i d e n t i f y the p o t e n t i a l extensiveness or r i s k of such an occurrence. Other s o c i o -c u l t u r a l e f f e c t s which were not discussed i n t h i s impact report concern impacts, on ethnic groups or e x i s t i n g welfare services i n the area. A f i n a l c r i t i c i s m concerning the treatment of s o c i o - c u l t u r a l impacts i n the report i s that no mention was made of any possible mea-sures: which could reduce the i n t e n s i t y of adverse e f f e c t s . Since the region which would be affected by the project i s described as being "... r u r a l , serene, scenic, t r a n q u i l and n a t u r a l , " an example of possible m i t i g a t i o n measure i s the development of a co n t r o l l e d growth plan for the quaint v i l l a g e of Addy and environs which would help preserve t h i s aes-t h e t i c s e t t i n g . Another possible m i t i g a t i o n action would be the forma-t i o n of a c i t i z e n committee i n the County to recommend steps to a l l e v i a t e future problems, as: they a r i s e due to the expected rapid growth induced by the plant. Although, an impact report serves a primary function i n f a c i l i t a t i n g s o c i a l l y responsible decisions, i t should also serve an a u x i l i a r y use of suggesting possible methods to lessen problems. C r i t e r i o n IV — E c o l o g i c a l Impacts The only important c r i t i c i s m concerning the treatment of ecolo-g i c a l impacts i n the EIS prepared by the Washington State Department of Ecology is, that i t d i d not adequately discuss p o t e n t i a l m i t i g a t i o n or compensation measures,. For example, the impact report states that mostly a l l of the s u l f u r dioxide produced from plant operations w i l l be emitted into the atmosphere, probably r e s u l t i n g i n l e v e l s which exceed state regulations during t y p i c a l c l i m a t i c conditions i n the region. - I l l -Af t e r the EIS described t h i s and other a i r q u a l i t y impacts, there was no discussion of d i f f e r e n t methods of a i r p o l l u t i o n control devices which could reduce t h i s impact to acceptable l e v e l s . Devices such as srubbers u t i l i z i n g an a l k a l i n e s o l u t i o n can reduce sulphur dioxide l e v e l s con-siderably. M i t i g a t i o n and compensation measures might also have been suggested concerning noise impacts, water p o l l u t i o n , aesthetic impacts, and the elimination of deer habitat. The f i n a l EIS f o r t h i s proposed magnesium plant at Addy also included a l l written responses concerning the d r a f t statement from govern-ment agencies, i n t e r e s t groups and pr i v a t e c i t i z e n s . Some of these com-ments noted a few: minor shortcomings with t h i s part of the d r a f t , and mostly re f e r r e d to misleading statements or an omission of data that would have made the impact d e s c r i p t i o n more meaningful to the reader. One enlightening comment was from a s c i e n t i s t at Washington State Univer-s i t y who stated that the EIS, i n discussing the project impact on the e x i s t i n g supply of energy i n the s t a t e , should also have assessed the e f f i c i e n c y of the magnesium processing operating i n u t i l i z i n g e l e c t r i c a l and other energy resources. Several months following t h i s comment the state of Washington suffered s i g n i f i c a n t energy shortages. Other r e s -ponses to the d r a f t statement noted that the EIS should have discussed more f u l l y the v i s u a l impacts of a i r p o l l u t i o n , p o t e n t i a l leakage from a sl a g pond into ground water supplies, the cumulative e f f e c t of p r o j e c t -induced actions on f i s h , and w i l d l i f e and several assumptions concerning a i r p o l l u t i o n estimates. ---112 -C r i t e r i o n IX — Communication of Information In general, the EIS f o r the proposed Northwest A l l o y s Magnesium Plant i d e n t i f i e d the f u l l environmental e f f e c t s of the proposal i n a non-technical, l o g i c a l l y organized report. Although t h i s report can he considered reasonably concise, the diverse nature of impacts asso-ciated with, the proposal l e d to a d r a f t EIS over 300 pages i n length. Despite the s i z e of t h i s report, neither the d r a f t or f i n a l EIS i n c l u -ded a separate summary sect i o n , although the conclusions d i d b r i e f l y describe a l l s i g n i f i c a n t environmental impacts of the proposed plant. This is. an important drawback of t h i s EIS since every attempt should be madeftoccommunicate the consequences of a proposal to decision-makers and the p u b l i c . Thus, a summary section should be included i n a l l impact statements i n order to refresh the memory of those who have a l -ready read the EIS and to inform persons unwilling or unable to read through to the conclusions of these often lengthy reports. PORTLAND INTERNATIONAL AIRPORT RUNWAY EXTENSION The environmental impact statement f o r the Portland Interna-t i o n a l A i r p o r t runway extension was completed by Haworth and Anderson Planning Consultants to f u l f i l l requirements of the National Environ-mental P o l i c y Act of 1969. The proposal has a c o n t r o v e r s i a l h i s t o r y which began i n 1968 when f e a s i b i l i t y studies were undertaken for a major expansion of the crowded Portland International A i r p o r t . This e a r l y expansion attempt included an ambitious dredge and f i l l operation i n the Columbia River f o r the construction of new runways, and other - 113 -actions which led to a challenge in the courts from five environmental groups that the plans: required congressional approval. The expansion plans were expected to Be delayed in the courts at least u n t i l 1978. This: prompted airport planners to propose, in the interim, an easterly extension of the south runway so that the airport would be capable of handling the modern "jumbo" cargo and passenger planes. This newer proposal was in 1973 and thus: an environmental impact statement was required under NEPA. This EIS was extensively c r i t i c i z e d by government agencies, and interest groups leading to information concerning other possible alternatives, and eventually in July of 1973 to a cancellation of both this newer proposal and the earlier expansion plans. Finally, Haworth and Anderson, Inc. were hired to prepare an EIS on the feasible future alternatives for the Portland International Airport. BRIEF DESCRIPTION OF PROPOSED PROJECT AND ENVIRONMENTAL SETTING Four feasible alternatives were defined for the airport. One alternative was the "no project" option, and the remaining three alter-natives included the following different lengths and directions of the south, runway: Plan I — 2200 f t . west extension Plan II — 2200 f t . west and 700 f t . east extension Plan III — 2200 f t . east extension The airport i s located on the south floodplain of the Columbia River northeast of downtown Portland and southeast of Vancouver, Wash-ington (see Figure IV-4). The elevation of the airport is only 20 feet above the mean level of the Columbia River, but is protected by levees - 114 -FIGURE IV-4. General l o c a t i o n of the Portland International Airport (from Haworth and Anderson, 1973). - 115 -ENVIRONMENTAL INVENTORY Description of Actions Description of Setting Affected Delineation of "Affected" Area ECONOMIC EFFICIENCY * List of Assumptions * Use of Standardized Approach SOCIO-CULTURAL IMPACTS * Comprehensive Identification Quantitative Assessment * Importance Assignment'- * ECOLOGICAL IMPACTS Comprehensive Identification Quantitative Assessment Importance Assignment'-DISTRIBUTION CONSEQUENCES Identified to Groups Identified to Areas SHORT-TERM VS. LONG-TERM EFFECTS Discussion of Future Uses Curtailed ANALYSIS OF ALTERNATIVES Choice of "No Action" Included Range of Choices Included Tradeoffs Identified RELATIONSHIP TO ESTABLISHED TO ESTABLISHED GOALS Project Related to Citizen Goals COMMUNICATION OF INFORMATION * Project Rationale Included Report Logically Organized and "Objective" Report Succinct, Non-Technical * Summary Included TABLE IV -6 . Checklist summary of non-compliance with criteria for the Portland International Airport Runway Extension EIS * Indicates an inadequate discussion of requisite in environmental impact statements. 1 • • On page 39 four considerations in conjunction with quantitative predictions were developed to facilitate the reader of an EIS in assigning importance to impacts. - 116 -and regulated flows upstream. Vegetation i s sparse in the immediate vi c i n i t y due to the sandy, al l u v i a l deposits of the Columbia River. At present, considerable residential development exists immediately south and north of the proposed airport, while residential housing i s more scattered in the east and west. NON-COMPLIANCE WITH CRITERIA  Criterion II — Economic Efficiency An economic efficiency analysis should l i s t the assumptions upon which benefits and costs are estimated. The EIS for the Portland Inter-national Airport runway extension completed a detailed economic efficiency analysis but did not identify to the reader the assumptions which were part of the assessment. An ill u s t r a t i o n of this criticism concerns the analysis of the economic impact of project construction. This analysis quantified these construction impacts in number of persons employed, total payroll and value of output (eg, construction supply purchases, household expenditures of workers, etc.) as calculated from an input/ output table for the state of Oregon. This results in what seems to be significant economic benefits from project construction, but the analysis did not mention that i t assumed the workers would be either unemployed or from out-of-state during the time of construction. It is more li k e l y that only a portion of those working on construction of the project w i l l actually result in beneficial economic impacts to the state of Oregon. Criterion III - Socio-Cultural Impacts In describing environmental impacts in a report, i t is necessary that the magnitude of effect be defined to help the reader value that - 117 -consequence. An important s o c i a l impact of an a i r p o r t which was ex-t e n s i v e l y analyzed i n the EIS i s noise from a r r i v i n g and departing a i r -c r a f t . This, impact was quantified i n NEF (noise exposure forecasts) figures and contours were even i l l u s t r a t e d on a rough land-use map of the area surrounding the a i r p o r t , but the text never mentioned the numher of homes affected by adverse noise exposure or the t o t a l monetary value of those residences. Consequently, the text d i d i n d i c a t e that r e s i d e n t i a l areas are adversely affected by the a i r p o r t , but persons reading the EIS have very l i t t l e understanding of the extensiveness of this, s o c i a l impact or the f i n a n c i a l costs of purchasing these homes to relocate the families;. Further, the EIS did not even consider land purchases: i n these impacted r e s i d e n t i a l areas as a compensation measure to reduce the magnitude of harmful noise and exposure l e v e l s . C r i t e r i o n IX — Communication of Information The greatest weakness of the EIS for the Portland International A i r p o r t ' s runway extension i s that the consequences of the proposal were not presented i n a form e a s i l y understandable to the ordinary layman. Rather than one major c h a r a c t e r i s t i c , i t i s more a s e r i e s of small factors that caused the EIS to be so nebulous. F i r s t , the EIS was too large f o r most persons to read. Although only one important impact was i d e n t i f i e d , the e n t i r e report consisted of over.250 pages of s i n g l e -spaced type. The analysis, of a i r p o l l u t i o n impacts comprised 30 pages and concluded that "the d i f f e r e n t i a t i o n i n a i r q u a l i t y and a i r q u a l i t y impaction between no south, runway extension and any type of south runway extension i s almost non-existent." At times, the EIS would digress into - 118 -i n s i g n i f i c a n t d e t a i l s . For example, a f t e r a lengthy d e s c r i p t i o n of e x i s t i n g drainage patterns at the a i r p o r t , the report discussed recent engineering work such as "The i n s t a l l a t i o n of approximately 990 feet of 78-inch, storm'sewer pipe has occurred to the east, where the new embank-ment covers the previously e x i s t i n g drainage between the end of the run-way and 82nd Avenue. As such, the work completed w i l l not s i g n i f i c a n t l y a l t e r the e x i s t i n g drainage pattern at PIA (Portland International A i r -port) , and most of i t was associated with the f i l l i n g and grading project, which i s not a subject of t h i s EIR." On several other-occasions the EIS would discuss s i m i l a r i n s i g n i f i c a n t d e t a i l s . A second f a c t o r , which contributed to a vague EIS i s that many times i t would discuss impacts or aspects r e l a t e d to the project i n an unclear manner. In describing a l t e r n a t i v e runway extension choices, the EIS noted that Plan I affected 0.3 acres, of p r i v a t e land and, one paragraph l a t e r , that Plan I I a f f e c t -ed 120 square feet of p r i v a t e land. At times, the EIS used undefined te c h n i c a l terms such as " i s o p l e t h contours" and " a i r c r a f t n a c e l l e s . " In the economic a n a l y s i s , employment, p a y r o l l and "value of output" were the three factors quantified to show the impact of the proposed project. Value of output was described as the goods and services produced at the a i r p o r t , but i t was never described to the reader how the service of an a i r p o r t employee was c a l c u l a t e d , except by footnoting several sources. Thus, a combination of lack of conciseness and c l a r i t y r e s u l t s i n an EIS that is: f r u s t r a t i n g to.read and d i f f i c u l t f o r a person to understand f u l l y the consequences of the proposed project. - 119 -WASHINGTON STATE ROUTE 82 FREEWAY For major highway projects i n the U.S., environmental impact statements are usually prepared for small segments of a proposal i n both the l o c a t i o n and design stages of planning. Impact statements are pre-pared for small segments because each state usually applies for fe d e r a l funding f o r parts, of projects i n order to spread an a l l o c a t e d amount of f i n a n c i a l support throughout the state. Thus, i t i s d i f f i c u l t to obtain an EIS f o r an e n t i r e highway. The environmental impact statement reviewed i n this; section i s a draft f o r the design planning stage of Interstate 82 between Ellenshurg, Washington and Pendleton, Oregon. The EIS was pre-pared by the Washington State: Department of Highways to f u l f i l l the requirements of NEPA and to q u a l i f y f or f e d e r a l funding. I t i s the i n i t i a l impact statement for t h i s part of Interstate 82, although e a r l y planning work was completed that pre-dates NEPA. BRIEF DESCRIPTION OF PROPOSED PROJECT AND ENVIRONMENTAL SETTING The proposed project i s the construction of approximately f i v e miles of freeway near the small town of Prosser, Washington (see Figure IV-5). The proposed freeway section w i l l cross the Yakima River and also b i s e c t the Prosser Game Reserve. The reserve e x i s t s as a r e s t i n g area f o r resident and migratory game and waterfowl. The climate i n the region i s dry and cold i n Winter (minimum temperature below zero on two to f i v e nights annually) and dry and hot i n the Summer (maximum temperature exceeds 100° on eight to twelve days annually). Due to this; harsh climate, there i s r e l a t i v e l y sparse native vegetation i n the Prosser area. Much of the land use i n the region i s - 120 -FIGURE IV -5. Location of the proposed i n t e r s t a t e freeway sect near Prosser, Washington (Washington State Dept. Highways, 1974). - 121 -ENVIRONMENTAL INVENTORY * Description of Actions * Description of Setting Affected Delineation of "Affected" Area ECONOMIC EFFICIENCY * List of Assumptions Use of Standardized Approach SOCIO-CULTURAL IMPACTS * Comprehensive Identification Quantitative Assessment Importance Assignment^- * ECOLOGICAL IMPACTS * Comprehensive Identification * Quantitative Assessment * Importance Assignment^- * DISTRIBUTION CONSEQUENCES ' * Identified to Groups * Identified to Areas * SHORT-TERM VS. LONG-TERM EFFECTS * Discussion of Future Uses Curtailed * ANALYSIS OF ALTERNATIVES * Choice of "No Action" Included Range of Choices Included Tradeoffs Identified * RELATIONSHIP TO ESTABLISHED TO ESTABLISHED GOALS Project Related to Citizen Goals COMMUNICATION OF INFORMATION * Project Rationale Included * Report Logically Organized and "Objective" * Report Succinct, Non-Technical * Summary Included TABLE IV-7. Checklist summary of non-compliance with criteria for the Washington State Route 82 Freeway EIS. * Indicates an inadequate discussion of requisite in environmental impact statements. 1 On page 39 four considerations in conjunction with quantitative predictions were developed to facilitate the reader of an EIS in assigning importance to impacts. - 122 -in irrigated and dryland farming, while the natural areas are typified by bunchgrass, cheatgrass, and sagebrush vegetative species. Deer, waterfowl, game birds and small mammals li v e throughout the region during different times of the year. The small town of Prosser has a population of 2,954 (1970) and is. mainly a supply center for the agricultural region. NON-COMPLIANCE WITH CRITERIA Criterion 1 — Project Description and Environmental Inventory In describing the proposal, no mention was made of the cons-truction activities involved with the project. This section of the EIS only discussed the alignment of the proposed highway in relation to existing roads or other physical characteristics, the projected future t r a f f i c of the highway, and i t s different engineering specifications. In particular, this section of the ElSsshould have also mentioned where the gravel and borrow sites are to be located and the number of men and equipment to be used during construction. It i s important that the project description in an EIS should discuss a l l aspects of the proposal which could result in environmental impacts. Criterion II — Economic Efficiency One purpose for requiring this consideration in an EIS is to provide the reader with the rationale for the project rather than just a discussion of the adverse consequences. This w i l l f a c i l i t a t e persons reading the report to compare the project's positive and negative impacts and decide whether i t merits, public investment. Yet, some projects which yield, social benefits are not meaningfully analyzed in monetary benefits - 123 -and costs. Proposed freeway developments are an example of government projects which, cannot he f a i r l y assessed economically in a benefit/cost ratio because the usual reasons for proposing highway projects are not easily quantified in monetary terms readily comparable with construction costs. Although an impact statement for such projects do not necessari-ly require a monetary benefit/cost analysis, a l l important economic impacts, should b.e quantified and the rationale for the project should be described. These requirements were not f u l f i l l e d in this EIS. Criterion III — Socio-Cultural Impacts The impact statement prepared by the Washington State Department of Highways did not adequately assess the socio-cultural consequences of the proposed freeway development. It was deficient in a comprehensive identification of impacts, discussion of mitigation and compensation measures, and definition of impact risk or uncertainty. An i l l u s t r a t i o n of the lack of comprehensiveness in this EIS concerns the apparent omis-sion in identifying some potential construction impacts of the freeway project. It was. stated in the EIS that short—term economic benefits to the town of Prosser w i l l result from construction of Interstate 82, but the number of workers in the prospective labor force was not defined, nor was the local vs. migrant distribution of potential laborers, whether the housing supply can meet the two-year population influx, and whether there would be an economic down-turn after construction i s completed. Other socio-cultural impacts which may have been ignored concerns the impact of the proposed freeway on existing archaeological remains and ethnic groups. - 124 -i The discussion of business losses i n the town of Prosser due to the freeway a t t r a c t i n g t r a f f i c away from the o l d highway which passed through downtown exemplifies the omission of inducement consequences of the p r o j e c t , m i t i g a t i o n and compensation measures, and r i s k and un-c e r t a i n t y of impact. A f t e r quantifying the number of commercial es-tablishments i n t h i s area of Prosser, the impact was defined merely as "Some i n i t i a l l o s s of business may be experienced... ." No m i t i g a t i o n / compensation measures or risk/uncertainty was defined i n r e l a t i o n to these service stations and restaurants i n the downtown area. Induce-ment consequences were also ignored even though i t i s commonly known that often some commercial establishments w i l l leave an old highway l o c a t i o n i n town to locate at the main freeway interchange outside of town. This could r e s u l t i n a weakened downtown core and an i n i t i a l stage of sprawl for a small community. C r i t e r i o n IV — E c o l o g i c a l Impacts The e c o l o g i c a l impacts of Interstate 82 were not comprehen-s i v e l y d i s c l o s e d , m i t i g a t i o n measures were not i d e n t i f i e d f o r a l l relevant impacts, and consequences of the project were not meaningfully quantified i n many cases. For example, "borrow" s i t e s were mentioned i n the EIS as necessary for construction of the freeway but t h e i r l o c a t i o n was. not i d e n t i f i e d , the number of borrow s i t e s and approxi-mate amount of material required was not mentioned, and reclamation techniques to be used ( i f any) a f t e r these s i t e s have been exploited were not discussed. I t was stated only that "Contractor(s) w i l l be required to s e l e c t sources with Department of Natural Resources - 125 -regulations." The environmental impact statement also did not discuss the p o t e n t i a l l o s s of animals from c o l l i s i o n s with autos even though the proposed freeway bi s e c t s a state game reserve. Furthermore, the EIS did not discuss p o t e n t i a l health and aesthetic e f f e c t s of a i r p o l l u t i o n on humans despite mentioning future pollutant increases due to greater t r a f f i c volumes on the freeway and also defining the possible e f f e c t s on vegetation. C r i t e r i o n V_ — D i s t r i b u t i o n Consequences Since the incidence of environmental impacts has s p e c i a l mean-ing and s i g n i f i c a n c e i n r e l a t i o n to groups and areas, an EIS should include a discussion of the d i s t r i b u t i o n a l consequences of the proposal i n order to inform interested persons and f a c i l i t a t e r a t i o n a l d ecisions. The EIS for the proposed freeway did not attempt to contrast the i n c i -dence of important benefits with major costs i n order to define the in t e r e s t group and regional vs. state (or national) perspective of impacts.. C r i t e r i o n VI — Short-Term Resource Uses vs. Long-Term E f f e c t s The e f f e c t of a proposal on non-renewable resources and a con-s i d e r a t i o n of the prospective inducement consequences should be d i s -cussed i n an EIS. The EIS for Interstate 82 near Prosser, Washington did include a separate discussion of the long and short-term conse-quences, of the project but d i d not mention some important considerations. For example, construction of a freeway designed f o r "80 mph." speeds can induce Increased consumption of o i l and gasoline, a non-renewable - 126 -•a A resource i n questionable future supply i n the U.S. The establishment of a new freeway also induces commercial growth around interchanges which c l e a r l y has some adverse community planning implications. These two inducement impacts were not discussed i n the EIS. C r i t e r i o n VII — Analysis of Alt e r n a t i v e s The important tradeoffs between each a l t e r n a t i v e and the pro-posed freeway were not i d e n t i f i e d i n the EIS. An i l l u s t r a t i o n of t h i s c r i t i c i s m concerns the assessment of a proposed south route f o r the f r e e -way which, would bypass the state game reserve. Rather than discussing the major tradeoffs, that e x i s t , only a l i s t i n g of the reasons why t h i s route was omitted from further consideration was included i n the EIS. In this: d iscussion, i t was. not even mentioned that the south route would have l e s s impact on animals i n the region than the intended freeway c o r r i d o r . C r i t e r i o n IX — Communication of Information Four basic shortcomings i n the EIS for Interstate 82 e x i s t s which, hinder the communication of information to persons reading the document. F i r s t , the report i n many cases d i d not r e a l l y define im-pacts. Instead, the EIS abounds with assurances and descriptions of methods to reduce impacts which are never a c t u a l l y defined. This c r i t i -cism i s i l l u s t r a t e d i n the section of the EIS describing water p o l l u t i o n impacts. Rather than s t a t i n g that there w i l l be s i l t a t i o n of streams caused by construction of the pro j e c t , the impact report merely states " s o i l s disturbed during construction w i l l be reseeded to provide ero-sion c o n t r o l . " The paragraph following t h i s statement mentions that - 127 -there w i l l be some minor s i l t a t i o n of the Yakima River from bridge construction, but the reader i s l a t e r assured that " A l l construction a c t i v i t i e s i n this: area w i l l meet the requirements of the Department of Game, Department of F i s h e r i e s , and the Department of Ecology." A f t e r another assurance that " . . . f u e l s , o i l s or other harmful substances are not released into the drainage and r i v e r systems," a two page excerpt of e x i s t i n g government requirements for road and bridge construction and a l i s t of precautionary actions concludes t h i s water p o l l u t i o n section of the report. A second shortcoming of the report i n r e l a t i o n to information communication was b r i e f l y mentioned i n the discussion of C r i t e r i o n I I . This c r i t i c i s m i s that the impact statement for Interstate 82 near Prosser does not e x p l i c i t l y define the r a t i o n a l e f o r the action. In a 1-1/2 page section of the EIS e n t i t l e d "Purpose of the P r o j e c t , " i t i s mentioned that the proposed highway i s to help f u l f i l l the Federal Aid Highway Act of 1956 which authorized f e d e r a l funding for 40,000 miles of Interstate highway i n the U.S. i n order to connect major c i t i e s and i n d u s t r i a l areas, serve the needs of commerce and l o c a l t r a f f i c , aid the n a t i o n a l defence, and to provide "optimum safe operating conditions for present and future t r a f f i c volumes." The EIS then stated that "... the purpose of t h i s project is: to implement the construction of S.R. 82 i n such a manner as. to provide: 1. A transportation system that o f f e r s both safety and e f f i c i e n c y to long distance t r a v e l , while supple-menting the l o c a l road system to maintain e f f i c i e n t l o c a l t r a v e l and s e r v i c e . - 128 -2. The highest obtainable safety for vehicular t r a v e l , r e s u l t i n g i n reduced accidents and death on t h i s s t a t e highway. 3. Greater economy i n transportation costs for pro-ducts , a v i t a l element i n U.S. - foreign trade competition. 4. Construction r e l a t e d economic b e n e f i t s to the l o c a l area through employment and business. 5. A l l of the l i s t e d objectives i n a way that minimizes adverse impact upon the natural and human environ-ment of the region." Despite t h i s discussion of "purpose" the need or r a t i o n a l e for the high-way i s s t i l l vague. In a l a t e r part of the EIS i t i s mentioned that the older two-lane highway i n 1971 had a t o t a l average d a i l y t r a f f i c of approximately 27% to 51% of what i s expected on the new freeway i n 1992. It was not defined whether the e x i s t i n g or future t r a f f i c loads were too great for the old highway, or the reasons why t h i s t r a f f i c i s to increase at the l e v e l forecasted i n 1992. Consequently, a major c r i t i c i s m of t h i s EIS i s that i t does, not c l e a r l y provide the reader with the reasons why the proj ect is. needed or found d e s i r a b l e , so that he can mentally "balance" b e n e f i c i a l and adverse consequences to reach a r a t i o n a l d e c i -sion about the proposal. A t h i r d drawback of the EIS i n r e l a t i o n to impact communication concerns the i n c l u s i o n of undefined terms or phrases i n the report. For example, the analysis of a i r p o l l u t i o n was completed by a scenario of a possible "worst case condition." The reader i s informed that "The 'worst case' condition i s defined as a P a s q u i l l s t a b i l i t y category F and a wind speed of 5 miles per hour." No further d e f i n i t i o n i s provided. S i m i l a r l y , the discussion of noise Impacts r e f e r s repeatedly to "^50 and ^10 noise -129 -levels" which are not defined in the report. Other undefined words and phrases could be cited. Fourth, the environmental.impact statement also includes some questionable assertions about impacts. In the assessment of freeway impact on wil d l i f e in the Prosser Game Reserve, the report estimates that "A one-third loss (of wildlife) w i l l mean that hunter harvests w i l l be reduced by 6,000 ducks, 75 pheasants, and 37 quail annually" (paren-thesis with words are added). One page later in the EIS i t i s stated that "Habitat loss w i l l , however, s t i l l cause a slight loss to wildl i f e in numbers only." The summary of the impact statement also l i g h t l y regards this impact by stating that "This project may also reduce the holding capacity of wi l d l i f e within the existing Prosser Game Reserve." Obviously, a freeway bisecting a game reserve causing a one-third loss of w i l d l i f e i s a more significant impact than the uncertainty indicated by the word "may" or the minor importance described by the phrase "slight loss." Another questionable assertion in the EIS concerns the assessment of the economic consequences of the proposed freeway in the town of Prosser. After stating that "some i n i t i a l loss may be experi-enced" by several gass stations and restaurants near the old highway in downtown, the EIS balances this loss by mentioning that "Some busi-nesses in Prosser may experience gains by removing the through travelers from the downtown area and enhancing the city shopping area." Defining impacts through misstatements and subjective viewpoints leads one to believe that the EIS was prepared to jus t i f y the project, appease the public and merely f u l f i l l a distasteful but required task. The prepara-- 130 -t i o n of impact reports for small segments of a proposed i n t e r s t a t e f r e e -way further supports the opinion that, at best, t h i s EIS served only to i d e n t i f y some miti g a t i o n measures f or the proposed project. CONCLUSIONS The main objective of c r i t i c a l l y reviewing f i v e environmental impact statements i n t h i s chapter was to i d e n t i f y t h e i r shortcomings i n order to l a t e r define whether the use of any impact evaluations methods would have prevented these problems. In reviewing the impact statements, i t was r e a l i z e d that some of the EIS standards established i n Chapter Two could not be adequately used as c r i t e r i a to t e s t environmental reports. For example, c r i t e r i o n VIII (Relationship To Established Goals) was not very h e l p f u l i n the c r i t i c a l review since the author of t h i s thesis had no knowledge of any planning studies i n the areas where the proposed projects are to be undertaken. Thus, an EIS was assessed as meeting t h i s c r i t e r i o n merely i f i t mentioned anything about c i t i z e n viewpoints or p a r t i c i p a t i o n i n project planning. Another requirement f o r an EIS con-cerns an i d e n t i f i c a t i o n of the range of responsible opinions f o r every impact to help the reader assign importance to each e f f e c t . Since the author i s not f a m i l i a r with, l o c a l opinions about each project, no assess-ment of EIS compliance could be determined f o r t h i s requirement. Despite these limitations:, the c r i t i c a l review has i d e n t i f i e d f i v e d i f f e r e n t shortcomings apparent i n the environmental impact reports. F i r s t , the environmental reports have some d i f f i c u l t y i n com-prehensively i d e n t i f y i n g a l l of the important s o c i o - c u l t u r a l and ecolo-- 131 -g i c a l impacts of the proposed action ( s ) . At l e a s t three of the impact reports reviewed i n t h i s chapter have omitted s i g n i f i c a n t p o t e n t i a l consequences of the proposal. I f these impacts were found by the author of the EIS as: not s i g n i f i c a n t f o r the project, a reasoning f o r t h i s judgement should s t i l l be provided i n the report. A second shortcoming apparent from t h i s c r i t i c a l review i s that the methods mentioned i n t h i s thesis to help the reader of an EIS assign importance to environmental impacts were not u t i l i z e d i n a l l of the reports. At l e a s t three EIS's d i d not i d e n t i f y r i s k s or uncertainty, relevant quantitative f i g u r e s , or mitigation/compensation measures i n the assessment of project consequences. T h i r d l y , an adequate discussion of the prospective curtailment of future b e n e f i c i a l uses of the human environment was not completed i n three of the f i v e environmental reports. Two of these EIS's were pre-pared i n the U.S. where i t i s an e x p l i c i t requirement i n NEPA to discuss both "the r e l a t i o n s h i p between l o c a l short-term uses of man's environment and the maintenance and enhancement of long-term p r o d u c t i v i t y . . . " and also a l l " i r r e v e r s i b l e and i r r e t r i e v a b l e commitments of resources." A fourth drawback evident from the review environmental impact statements i n t h i s chapter i s that an analysis of a l t e r n a t i v e s was not completed adequately i n three reports. The most s a l i e n t problem was that the a l t e r n a t i v e s were not evaluated to i d e n t i f y the important trade-o f f s i n comparison to the proposed project. Instead, two impact reports merely defined the reasons, why the alternatives, were omitted from further consideration. One EIS d i d not even consider a l t e r n a t i v e s to the proposed - 132 -project, and another omitted the "no action" choice. An environmental impact report must communicate the relevant information about the consequences of the proposed project i f the report is to f u l f i l l i t s intended purpose. Yet a l l five EIS's reviewed in this chapter had characteristics that would hinder the effectiveness of the reports in impact communication. This exists as the most important problem of the impact statement reviewed in this chapter. Two adverse qualities: which were most prominent are verbosity and lack of cla r i t y . Long detailed discussions: of factors of minor importance erode the com-prehension of an interested reader just as a lack of clarity w i l l frustrate any person reading the EIS. Other communication problems with the impact reports, concern a lack of organization, subjectiveness, and the omission of the project rationale so that the reader cannot i n t e l l i -gently judge the social worth of the proposal. These five basic criticisms exist as problems with environmental impact statements. The environmental impact evaluation methods descrip-tively reviewed in Chapter Three w i l l be assessed in Chapter Five to define the degree to which these procedures are able to resolve these five identified problems. chapter five relating impact statement shortcomings to impact assessment methods INTRODUCTION . In Chapter Three various impact assessment methods were divided into four basic types. Capability/suitability analysis methods mainly assess the potential of land for different uses rather than evaluate the environmental impacts of a specific action. As a result, the McHarg and H i l l s approaches w i l l not be used in this chapter even though the infor-mation generated by these methods is useful in an impact analysis. Methods developed only for identifying environmental impacts do not evaluate the consequences of a proposed project and, thus, are relevant to just one of the five shortcomings of impact statements c r i t i c a l l y reviewed in Chapter Four. Therefore, the remainder of this chapter w i l l discuss mainly two different types of impact evaluation. One type of evaluation aggregates  impacts into common units while the other type separates impacts into individual quantitative units with qualitative descriptions.. These two types of evaluation methods w i l l be illustrated in this chapter by an application of the Battelle Columbus environmental evaluation system (EES) and of the U.S. Water Resources Council Principles and Standards to one major consequence of the proposed Seven Mile Hydropower Develop-ment . 133 -- 134 -DISCUSSION COMPREHENSIVE IDENTIFICATION OF SOCIO-CULTURAL AND ECOLOGICAL IMPACTS Five basic techniques e x i s t for i d e n t i f y i n g environmental impacts. These f i v e techniques are l i s t e d i n Figure V - l i n r e l a t i o n to nine environ-mental assessment methods described i n Chapter Three. Only the l o g i c a l deduction procedure of defining relevant environmental impacts i s not a c h e c k l i s t . The l o g i c a l deduction technique follows a s e r i e s of steps from general causal factors or categories to s p e c i f i c impacts or environ-mental conditions. I t i s a c t u a l l y a process which r e s u l t s i n a l i s t of impacts t a i l o r e d for each project. For example, i n computer modelling for environmental impact (Krauskopf and Bunde, 1972) ten l i n e a r models were constructed which disaggregated general economic, engineering, socio-c u l t u r a l and e c o l o g i c a l categories for a highway into linked components and s p e c i f i c data v a r i a b l e s . This method does not define whether the construct-ion of each model i s dependent upon de t a i l e d information about features of the proposed highway or conditions of the environment. The degree to which any method u t i l i z i n g a l o g i c a l deduction technique to i d e n t i f y impacts r e l i e s upon s p e c i f i c c h a r a c t e r i s t i c s of the project or the s p e c i f i c environ-mental s e t t i n g would determine i t s usefulness.. If the method requires such s p e c i f i c information early i n the deduction process, much of the technique w i l l have to be repeated i n each impact assessment for a l l future projects. Although each a p p l i c a t i o n for a type of action (e.g., highways, dams, p i p e l i n e s , etc.) w i l l r e f i n e the process to improve comprehensive-ness and avoid unneeded r e p e t i t i o n , i t seems much l e s s time-consuming to - 135 -S3 O M S3 c j H S3 W P H <J Pi o PH w & s EH W S3 X 1 1 PH H O S3 ^ h-l S3 EH S3 O CO O h-l M M H O l-H H O S3 1—1 P3 M l-H P O H <d § PH co cj O Q M I-I C J H4 EH — l-H C J S3 <3 PH O C J l-H M h-l PH H C J PH C J O M H <d l-H CO W ENVIRONMENTAL IMPACT ASSESSMENT METHODS MULTIPLE EFFECTS NETWORKS USGS METHOD ENERGY NETWORK DIAGRAMS OPTIMUM PATHWAY MATRIX APPROACH EARLY METHOD BATTELLE COLUMBUS LATER METHOD EFFECTS CHAINS COMPUTER MODELLING ENV. IMPACT U.S. WATER RESOURCES COUNCIL U.S. ATOMIC ENERGY COMMISSION X X X X X X X X X X FIGURE V " i . A l i s t of nine methods for environmental impact assessment and the technique used for impact i d e n t i f i c a t i o n . - 136 -develop a thorough c h e c k l i s t for each type of act i o n . Such a c h e c k l i s t would not depend upon exact d e t a i l s of the project and could be repeatedly used to i d e n t i f y relevant environmental impacts. Also, a c h e c k l i s t can be updated p e r i o d i c a l l y to help assure comprehensiveness. The d i f f e r e n t c h e c k l i s t s can also be distinguished from one another i n r e l a t i o n to usefulness. Networks (see Appendix D, ,Table.>1) are theore-t i c a l l y the most comprehensive c h e c k l i s t due to the l o g i c a l d isplay format based upon the r e a l i s t i c succession of events beginning with a land use which leads to causal actions r e s u l t i n g i n primary, secondary and multiple order impacts. Another advantage over other c h e c k l i s t s i s that i t provides the impact assessor with an understanding of the interconnections between the objectives of a project and i t s diverse e c o l o g i c a l and s o c i o - c u l t u r a l consequences. This feature i s e s p e c i a l l y u s e f u l because i t can help i n the development of measures which reduce the i n t e n s i t y of environmental impacts. The major drawback of networks i s that i t i s much more d i f f i c u l t and time consuming to develop o r i g i n a l l y than other more simple c h e c k l i s t s . In order to define further the usefulness of these impact i d e n t i -f i c a t i o n techniques, each kind of c h e c k l i s t w i l l be applied b r i e f l y , when relevant, to one of the projects f or which impact statements were reviewed i n the previous chapter. Since the author of t h i s study lacks d e t a i l e d information about each project and environmental s e t t i n g , many impacts i d e n t i f i e d may not be applicable to the p a r t i c u l a r project. However, the main purpose of such a test should s t i l l be served by t r y i n g to determine the p r a c t i c a l usefulness and degree of comprehensive impact i d e n t i f i c a t i o n of each c h e c k l i s t type i n r e l a t i o n to the shortcomings of another EIS. - 137 -Action/Condition Matrix Figure V-2 shows a reduced action/condition matrix with some po-t e n t i a l important impacts of the Notthwest A l l o y s Magnesium Plant i d e n t i -i f i e d . The reduced matrix was developed d i r e c t l y from the larger USGS matrix shown i n Appendix E, Figure 1 a f t e r a cursory a p p l i c a t i o n to the project based upon information i n the EIS. Two basic conclusions r e s u l t from the use of t h i s matrix. F i r s t , the matrix i s confusing and very cumbersome to use. This i s not only due to i t s great s i z e but also because the a c t i o n / s i n g l e e f f e c t format of the matrix i s u n r e a l i s t i c and leads to d i f f i c u l t y i n determining sequential impacts and causes. For example, a chain of impacts from s t r i p mining might begin i n i t i a l l y with surface ex-cavation a l t e r i n g drainage patterns leading to s o i l erosion which can introduce increased t u r b i d i t y and organics i n a stream r e s u l t i n g i n a l g a l blooms, possible impacts on f i s h , v i s u a l a esthetics, etc. The simple action/condition matrix does not follow any r e a l i s t i c sequence. To define t h i s chain of impacts on the USGS matrix, the two actions "surface excava-t i o n " and " a l t e r a t i o n of drainage" must be separately i d e n t i f i e d on the matrix. I t i s only through p r i o r knowledge of the assessor that secondary and multiple order impacts r e s u l t i n g from changed environmental conditions w i l l be i d e n t i f i e d . A second conclusion concerning the use,of t h i s matrix Is that im-pacts are i d e n t i f i e d at a general l e v e l that, i n some cases, cannot be measured to indic a t e extensiveness. For example, water q u a l i t y impacts are only determined through predictions of various parameters such as mean dissolved oxygen l e v e l s , mean phosphorous concentrations, etc. Conse-quently, to define magnitude c l e a r l y i t i s necessary that impacts be iden-t i f i e d at a s p e c i f i c l e v e l that can be r e a d i l y measured. This, of course, - 138 -w CO > a o z CO < o CJ > cu Z o H CO H o z z Q CU o o CO H H H EH CO M O a rt CO rt fa PQ H >j CJ a H EH o cj D ed z H H rt a z . J EH H X W m < M AN H 1-H S fa CJ CO D IL o EH 2 KH o a z Q rt a CO a CO H H z H Z EH z D CM Q fa Cd EH rt CO H rt rt O EH a rt CO fa a fa H > CJ w hH O z X Z o Z CO a rt Z o rt o fa O O z U H o u EH H H z M < X i j « H Z EH Q EH o EH < fa •H CM rt rt H rt CJ H cd CJ N U EH Z w Cd D z » H H rt H EH H u Q < iJ rt H u tJ CO fa 2 2 co EH < 2 H M w rt D co fa rt • J U n u Q 9 a rt 2 z EH H P rt rt O 2 z M D ca H fa rt ed EH EH 2 < D H PQ CO 5 s 2 2 EH fa CO CO ENVIRONMENTAL CONDITIONS MINERAL RESOURCES SOILS X LANDFORM X x UNIQUE PHYSICAL FEATURES X x UNDERGROUND WATER x WATER QUALITY X WATER RECHARGE X AIR QUALITY GRASS X X CROPS X X BIRDS X X LAND ANIMALS x x AGRICULTURE X X MINING AND QUARRYING HUNTING X CAMPING, HIKING x x PICNICKING X X SCENIC VIEWS AND VISTAS X OPEN SPACE QUALITIES X ; CULTURAL PATTERNS EMPLOYMENT TRANSPORTATION NETWORK UTILITY NETWORKS X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X X FIGURE' V-2. A reduced cause/effect matrix with, some potential impacts of a proposed magnesium plant and mining operations. - 139 -cannot be usefully accomplished in a l l cases with the USGS matrix because i t attempts to include a l l possible actions of man and a l l possible envi-ronmental conditions in one display. Simple Impact Lists Simple environmental impact l i s t s are illustrated in the Appendix (see Appendix C, Table 2; Appendix D, Table 1; and Appendix F, Tables 1, 2 and 3). Some l i s t s are relatively short and address impacts at a general level (e.g., biological impacts rather than impact on trees, shrubs, grasses, mammals, etc.) such as the array of the U.S. Water Resources Council while other checklists such as the tabulation system of the U.S. Atomic Energy Commission are extensive and more specific. It i s apparent that a compre-hensive checklist at a specific level i s more useful in expli c i t l y identi-fying impacts and, in most cases, these specific impacts also can be clearly measured to indicate extensiveness. The disadvantages of simple impact l i s t s are easily seen in that i t does not help the assessor connect causes with impacts nor does i t resolve the problem in the USGS matrix of defining multiple-order impacts. The advantages of simple impact l i s t s are the ease in development for specific types of projects, and they can also be readily utilized and easily understood. Hierarchical Lists If the Battelle hierarchical checklist for water resources planning (Figure II-l) had been applied to the proposed Seven Mile Project, i t would have resolved some of the impact identification problems with the studies reviewed i n Chapter Four. For example, many socio-cultural impacts - 140 -such as s o c i a l i n t e r a c t i o n , i s o l a t i o n / s o l i t u d e and oneness with nature are included and defined i n the B a t t e l l e system. This would have prevented the omission of some "i n t a n g i b l e " impacts, a basic c r i t i c i s m of the Seven Mile socio-economic study. Conversely, the lack of interconnection be-tween parameters on the h i e r a r c h i c a l c h e c k l i s t makes i t d i f f i c u l t for the assessor to define t e r t i a r y consequences which r e s u l t from lower-order impacts. M u l t i p l e E f f e c t s Networks Sorensen and Pepper (1973) developed a multiple e f f e c t s network (see Appendix G, Figure 1) for proposed highways and other developments i n a c h e c k l i s t format to be used by a regional planning agency i n reviewing environmental impact statements. I f t h i s network was used to determine the consequences of Interstate 82 i n eastern Washington, many of the impacts omitted from discussion i n the EIS such as induced sprawl near interchanges, loss of p o t e n t i a l archaeological s i t e s and the many impacts r e s u l t i n g from the development of borrow p i t s would have been i d e n t i f i e d . On the other hand, the i n f l u x of workers i n a small community causing adverse housing and s e r v i c i n g requirements and the l o c a l economic down-turn af t e r construc-ion was not i d e n t i f i e d as p o t e n t i a l impacts on the network c h e c k l i s t . The probable reason why these impacts were not included i n the network i s be-cause i t was developed f o r the mostly urbanized San Francisco Bay area, which would seem to preclude the occurrence of such impacts. IMPORTANCE ASSIGNMENT A second shortcoming of the impact statements reviewed i n the - 141 -previous chapter i s that adequate information was not provided to f a c i l i -tate the reader i n assigning importance to each impact. The two basic philosophies of environmental impact evaluation already defined i n t h i s thesis assign importance to impacts i n a d i f f e r e n t manner. The methods which aggregate impacts into common units u t i l i z e quantitative figures to define the s i g n i f i c a n c e of impacts, while the evaluation methods which separate impacts into i n d i v i d u a l quantitative units and q u a l i f y i n g terms use d e s c r i p t i v e words and incommensurable f i g u r e s . In i d e n t i f y i n g the t h e o r e t i c a l purpose of environmental impact statements and developing c r i t e r i a to evaluate an EIS, the author has been i m p l i c i t l y biased against the aggregate methods of developing common units f or economic, s o c i o - c u l -t u r a l and e c o l o g i c a l e f f e c t s . Despite t h i s i m p l i c i t bias i n the t h e s i s , sound reasoning e x i s t s that changing diverse impacts into common units are the r e s u l t of hidden subjective judgements, and also tends to disguise the implications of many environmental consequences (Sorensen and Moss, 1973). This reasoning i s most important i n l i g h t of the t h e o r e t i c a l pur-pose of impact reports, which i s to communicate information to the reader about the t o t a l consequences of a project so that the i n d i v i d u a l can reach a r a t i o n a l d e c i s i o n . In order to i l l u s t r a t e the differences between the two types of evaluation methods, the B a t t e l l e Columbus Environmental Evalu-a t i o n System (EES) (Dee et. a l . , 1972) and the U.S. Water Resources Council P r i n c i p l e s and Standards (1973) have been p a r t i a l l y applied to the proposed Seven M i l e Hydropower project. Since a major consequence noted i n the Seven M i l e EIS by Envirocon i s sightseeing and game viewing losses, only the esthetic aspect of each analysis has been completed. Lack of data r e s t r i c t e d a complete.application of these two d i f f e r e n t impact evaluation - 142 -procedures and, i n some cases, estimates were necessary i n order to apply these two methods. I t should also be mentioned that the B a t t e l l e EES was applied to the project only by the suithor, and not by an i n t e r d i s c i -p l i n a r y team as required by the method. Results Tables V - l and V-2 i l l u s t r a t e the possible esthetic impact evalu-a t i o n of the Seven M i l e Hydropower project according to these two methods. Two basic r e s u l t s i n r e l a t i o n to importance assignment can be c i t e d from these examples. F i r s t , neither method completely resolves the problems i n importance assignment that were indicated from the EIS reviews completed i n Chapter Four. The U.S. Water Resources Council procedure functions to provide information so that the reader can judge the importance of an impact but i t does not require that r i s k or uncertainty, m i t i g a t i o n measures or time span of impacts be included i n the evaluation. Although these considerations are not required, the method has the p o t e n t i a l to accom-odate these f a c t o r s . I t i s apparent by the quantitative values and t o t a l s l i s t e d i n Table V—2, the the B a t t e l l e EES method judges the importance of impacts f o r the reader through decisions made by an i n t e r d i s c i p l i n a r y team. Unless public i n t e r e s t s can be somehow integrated into the many judgements required to complete the B a t t e l l e procedure, r e l y i n g upon t h i s sheet as the basis for an impact report i s contrary to the c i t i z e n p a r t i c i p a t i o n function i n decision-making which was a primary force behind NEPA arid the EIS require-ment. I t i s doubtful whether public p a r t i c i p a t i o n could be adequately used to develop the value functions and importance u n i t s i n the B a t t e l l e EES, and the i n t e r d i s c i p l i n a r y team i s not a sui t a b l e substitute for public p a r t i c i -pation. Since the f i v e other methods which mold economic, s o c i o - c u l t u r a l -143 -ENVIRONMENTAL QUALITY ACCOUNT (incomplete) WITH PROJECT BENEFICIAL ADVERSE 1. Inundate 800 Acres Of Open And Green Space In Valley Along i River Bed, 9 Miles Long And 1/4 Mile Wide Within 10 Miles Of i Several Small Towns 2. Inundate 9 Miles Of One Of Last Free-Flowing White Water River Sections In Southeastern B.C., Of Medium Quality Water And Rocky Shoreline With Surrounding Coniferous/Shrub/Meadow Land 3. Reduced Game Viewing Attraction Because Flooding 20% Of Ungulate Winter Range In Valley Will Result In Reduced Populations Of Between 125-400 Deer TABLE V - l . An example of a possible esthetics component of the Environ-mental Quality Account for a hydropower development as guided by the U.S. Water Resources Council Principles and Standards (1973) . Create Lake With 870 Surface Acres. 20 Miles Of Shoreline, With Good Quality Water (due to settling of suspended solids) And Fair Access Enhance Remaining Winter Range To Mitigate Deer Population Losses - 144 -Esthetics Land Value in EIU With Without Net Red Project Project Change Flags (C) Geologic surface material 6 1.2 -.6 (16) Relief and topographic character Q.fi 11.2 -1 .6 minor (10) Width and alignment -7-^0- -1.0 minor (32) Subtotal I 16 .2 I 19 .4 1 -372 I" Air (3) Odor and visual (2) Sounds (5) . ' Subtotal Water (10) Appearance of water (16) Land and water interface (6) Odor and floating materials (10) Water surface area (10) Wooded and geologic shoreline (52) Subtotal Biota (5) Animals — domestic (5) Animals — wild (9) Diversity of vegetation types (5) Variety within vegetation types (24) Subtotal Man-made Objects (10) Man-made objects (10) Subtotal Composition (15) Composite effect (15) Unique composition (30) Subtotal <153) Esthetics Total 9.4 O.L n 1 .? -.fi I 3.0 I 3.61 - .6 T 3.0 7.0 -4.0 major 14.4 16.0 -1.6 A n fin n 5 0 1 0 +4.o 7.0 fi.O -1.0 I 3 5 . 4 I 3 8 . 0 1 - 2 . 6 L 3.5 3.5 0 • V S 4.S -1 .0 R 1 7.9 +.q 1.5 1 .5 0 I 16.6 [ 16.71 -0.1~T I 8 . 0 1 1 0 . 0 1 - 2 . 0 | |  I « n I m . n l - ? . n I 1 fi 0 10.5 -4.5 major n q.n -fv .n ma i n r 9 n 1Q.S - 1 0 . 5 I 88.2 I 107.21-19.0 1 ~ l TABLE "yV2. Results of a p r a c t i c a l application of the B a t t e l l e EES (early approach) to a proposed hydropower development. - 145 -and ecological impacts into common units also require similar interdis-ciplinary or personal judgements, these procedures likewise descriminate against public participation i n decision-making. On the other hand, me-thods such as the U.S. Water Resources Council Principles and Standards provide information in a form to the reader so that he can judge the value of impacts, serving to f a c i l i t a t e individual decisions and a public par-ticipation process. In relation to helping the reader assign importance to impacts, this practical application to the Seven Mile Project also shows that both methods can disguise the subjective views of the impact assessor. The U.S. i Water Resources Council method describes impacts through statements which, depending upon the words and phrases chosen, can introduce bias in the display system. The guidelines for using this method cite examples of beneficial and adverse effects on environmental quality which are not parallel i n description. In Table V - l , a beneficial impact i s described by the verb "create" while a parallel adverse effect i s assessed by the verb "inundate". Although this i s a very minor example of bias, more objective counterparts would be "gain of" and "loss of" which would more f a i r l y define impacts to the reader. Rather than a description through words and phrases, the Battelle Columbus approach uses numbers and a fixed scale (see figure III-5) for transforming impacts into common units. The mere existence of these numbers and a mathematical approach to impact assessment automatically prohibits many persons from understanding assump-tions and questioning conslusions. As a result, i t would be much easier for an agency or interdisciplinary team preparing an environmental assess-ment to disguise biases and j u s t i f y a proposal. - 146 -SHORT-TERM VS. LONG-TERM DISCUSSION OF IMPACTS Most of the environmental impact assessment methods described i n Chapter Three stress an evaluation framework and do not provide guidance i n the actual preparation of the statement of environmental impact. There-fo r e , the preparation of an EIS using these methods must follow the guide-l i n e s developed by the U.S. Council on Environmental Quality (1973b) (Ap-pendix B, and pp. 28-31) which are based on the f i v e r e q u i s i t e s included i n NEPA (Appendix A and pp. 28). The CEQ guidelines define two separate discussions i n an EIS that should' i n d i c a t e the tradeoffs between "short-term gains at the expense of long-term losses or v i c e versa" and also that the "range of p o t e n t i a l uses of the environment" be i d e n t i f i e d . These two considerations, which are vaguely stated as requirements (IV) and (V) of section 102(2) (c) i n NEPA, formed the basis for c r i t e r i o n VI i n t h i s t h e s i s . Although these two EIS requirements e x i s t i n the U.S., two of the three impact reports which did not meet t h i s c r i t e r i o n were prepared to comply with NEPA. The possible reason why these U.S. impact statements are d e f i c i e n t i n t h i s respect i s because the two NEPA require-ments are vague and unclear, and the U.S. Council on Environmental Quality guidelines do not e x p l i c i t l y define them. Ortolano (1973) has also men-tioned that these two NEPA requirements are "so obscure that c l a r i f i c a t i o n must be provided before they can be expected to y i e l d the kind of informa-t i o n that w i l l be useful i n decision-making". Of the methods described i n Chapter Three, only the U.S. Atomic Energy Commission preparation guidelines have made a strong e f f o r t to d i r e c t impact statements to meet t h i s c r i t e r i o n . The U.S. Water Resources Council P r i n c i p l e s and Standards (1973) and the l a t e r B a t t e l l e method (1973) - 147 -have also br i e f l y directed environmental reports toward meeting this c r i -terion, but not in adequate detail or in a manner to c l a r i f y the vague requirements of NEPA. The only other impact evaluation method which takes into account the long-term consequences of impacts i s the Optimum Pathway Matrix Analysis Approach to the Environmental Decision-Making Process (Zieman, et. a l . , 1971). This method merely weights a l l long-term effects (defined in this method as 10-20 years) i n common units as ten times more important than short—term impacts. ALTERNATIVE ANALYSIS The most significant problem with the analysis of alternatives in the five impact statements reviewed i s that the important tradeoffs between each choice and the proposed project were not defined. As menrr. tioned in the discussion of the previous shortcoming, this consideration in an impact report should also result from preparation guidelines which were not included as part of most impact evaluation procedures reviewed in this thesis. The U.S. Council on Environmental Quality Guidelines (1973b) requires this consideration in an EIS by stating that the analysis of alternatives "...be sufficiently detailed to permit comparative evaluation of the environmental benefits, ciosts and risks of the proposed action and each reasonable alternative...". Evaluation methods which aggregate impacts into common units pro-vide a basis for ex p l i c i t l y defining tradeoffs between alternatives. As exemplified by the Battelle procedure in Table V-2, the quantitative d i f -ferences :between the "no action" alternative and the proposed project i s shown in totals for the entire analysis, totals for each hierarchical - 148 -category (e.g., esthetics i s one of four B a t t e l l e categories), and numer-i c a l f igures for each of 78 parameters. Other a l t e r n a t i v e s can also be compared i n the same manner. The remaining s i x common un i t methods also e x p l i c i t l y state that a basic purpose of the assessment i s to sele c t the best possible a l t e r n a t i v e , and each of these methods assesses s p e c i f i c impacts i n quantitative measures to e x p l i c i t l y define tradeoffs. Evaluation methods which separate impacts into i n d i v i d u a l quanti-t a t i v e and d e s c r i p t i v e terms are not as e x p l i c i t i n i n d i c a t i n g the most desirable of several a l t e r n a t i v e s due to the use of incommensurable mea-sures which cannot be totaled for comparison. Despite t h i s minor d i f f e r -ence i n comparison to common unit methods, tradeoffs between a l t e r n a t i v e s can s t i l l be c l e a r l y defined i n q u a n t i t a t i v e / q u a l i t a t i v e terms through t h i s type of impact evaluation. Appendix F, Table 2 i l l u s t r a t e s the U.S. Atomic Energy Commission framework for comparing a l t e r n a t i v e s . COMMUNICATION OF INFORMATION As previously pointed out i n the discussion of two e a r l i e r EIS shortcomings, guidelines for preparing the environmental impact statement i t s e l f also can be most h e l p f u l i n d i r e c t i n g an EIS to communicate i n f o r -mation i n a manner that i s comprehensible to the common layman. Guidelines can stress the t h e o r e t i c a l purpose of an imp-act report which provides a basis f o r requ i r i n g an EIS to o b j e c t i v e l y define the project r a t i o n a l e . By defining the proper place i n the planning process f o r the EIS, the pro-., blem of impact reports attempting to j u s t i f y a d e c i s i o n already made can be circumvented. Guidelines can also recommend a f l e x i b l e format to those proposing an EIS that can help produce c l e a r , concise reports. The USGS Matrix Procedure, the l a t e r B a t t e l l e Method, the U.S. Water Resources Coun-eil - 149 -Principles and Standards, and the U.S. Atomic Energy Commission Preparar-tion Guide are the only methods which provide any direction in EIS prep-aration. The U.S. Water Resources Council Principles and Standards empha-size the public decision-making function of an impact report and, in gen-eral, provides enough guidance so that an EIS w i l l communicate to the reader the f u l l consequences of the proposed action and i t s alternatives. The U.S. Atomic Energy Commission preparation procedures do not identify the purpose of impact reports and, due to the detailed 12 chapter EIS format described, w i l l l i k e l y direct the development of voluminous environ-mental impact statements. However, a most redeeming factor included in these guidelines i s a tabulation procedure (Appendix F, Tables 2 and 3) which, in effect, i s a concise and comprehensive summary of environmental impacts. Both the USGS procedure and the Battelle method provide l i t t l e or no guidance in f a c i l i t a t i n g an EIS to communicate information to the lay reader, although both methods do attempt to integrate the EIS in the de-cision-making process. The remaining environmental impact evaluation pro-cedures must rely upon the U.S. Council on Environmental Quality guidelines (pp. 27-31) for the preparation of an EIS. Other than the five basic EIS requirements in NEPA, and a description of the project and environmental setting, these guidelines do not provide a framework or format for an im-pact evaluation document. The philosophical basis utilized by the two different types of impact evaluation methods also influences how well the information gene-rated i s communicated to persons interested in the proposed action. As mentioned earlier, methods which transform diverse impacts into common units judge the importance of an impact for the reader. These methods also u t i l i z e commensurable figures which have no meaning by themselves. - 150 -These two characteristics of the common unit type of evaluation methods can incorrectly communicate information and can also f a i l to identify the consequences of a project to persons interested in the proposal. For example, in the Battelle method illustrated in Table V-2, the "appearance of water" parameter was assessed in environmental impact units (EIU) without the action as +7.0 and with the action as +3.0 resulting i n a net change of -4.0. This -4.0 has very l i t t l e meaning to the persons • reading the evaluation unless i t i s contrasted with the parameter "water surface area" which has a net change of +4.0. Thus, an equal tradeoff is judged by this evaluation for the reader. To many persons, the exisr tence of a lake may not fu l l y compensate for the loss of a free-flowing section of river. On the contrary, methods which quantitatively evaluate impacts in separate units and include a qualitative description w i l l l i s t this impact as "inundate nine miles of one of the last free-flowing white water rivers i n . . . " and "create lake with 870 surface acres, 20 miles of shoreline...". Consequently, this type of evaluation method i l l u s -trated by the U.S. Water Resources Council approach in Table V-l provides information so that the reader can judge the value of the tradeoffs. - 151 -CONCLUSIONS This general discussion supplemented by some s p e c i f i c examples leads to three main conclusions about methods developed f o r environmental impact assessment i n r e l a t i o n to the main problems with impact reports reviewed i n the preceding chapter of t h i s t h e s i s . F i r s t , i n order to i d e n t i f y f u l l y s o c i o - c u l t u r a l and e c o l o g i c a l impacts, an impact evaluation procedure to be used by an agency should include a comprehensive c h e c k l i s t of p o t e n t i a l consequences at a s p e c i f i c l e v e l that, when pertinent, can be measured i n units meaningful to the lay reader. Since innumerable environmental e f f e c t s can>result from d i f f e r e n t developments, i n order for a c h e c k l i s t to be comprehensive i t must be prepared f o r s p e c i f i c kinds of projects. . The most comprehensive form of c h e c k l i s t i s a network which l i n k s the sequence of events from a land use to causal actions and primary, secondary and multiple order e f f e c t s . At present, there i s no i d e a l method for evaluating environmental impact. Perhaps an i d e a l method f or a l l kinds of actions and circumstances w i l l never be developed, but onetype of evaluation method which has been co n t i n u a l l y proposed can be distinguished as undesirable f o r use as the basis for anclenvironmental impact statement. A second conclusion of t h i s chapter i s that, due to the information generation function of an EIS to f a c i l i t a t e a government agency and public review of the project for d e c i -sion-making, methods which mold economic, s o c i o - c u l t u r a l iand e c o l o g i c a l impacts into common units are undesirable because the value judgements of few persons are used to assign the importance of each environmental impact for the p u b l i c , government agencies and decision-makers. As discussed e a r l i e r , t h i s type of evaluation can also communicate information that i s - 152 -misleading for many persons. A third conclusion of this chapter i s that most of these impact evaluation procedures do not provide guidance in the preparation of the environmental report. Guidelines can direct the preparation of an EIS so that information about the f u l l consequences of the proposed action can be communicated in a manner comprehensible to the common layman, de-fined as the most significant problem with the five impact statements c r i t i c a l l y reviewed in Chapter Four. Guidelines can also include require-ments which direct an adequate treatment of "short-term vs. long-term effects" and an adequate "analysis of alternatives" in an EIS. As a re-sult, i f an impact evaluation method i s to f u l f i l l i t s ultimate purpose, i t should also provide guidance in the preparation of the environmental report. chapter six general guidelines for preparing environmental impact statements BACKGROUND The case studies of impact statements and discussion of d i f -ferent environmental assessment methods provides a foundation f o r r e -commending general guidelines f o r preparing environmental impact statements.* These guidelines c l o s e l y follow the c r i t e r i a established, i n Chapter Two and are di r e c t e d by the purpose the environmental impact statement i s intended to serve. The guidelines prescribe an impact evaluation method that separates impacts into i n d i v i d u a l quantitative measures and q u a l i f y i n g terms. PURPOSE AND SCOPE OF THE IMPACT STATEMENT The ultimate objective of an environmental impact statement i s to f a c i l i t a t e s o c i a l l y responsible decisions about a proposed project. To achieve t h i s o b j e c t i v e , an EIS serves as an information t o o l to be used by the p u b l i c and by decision-makers so that each person can reach an i n d i v i d u a l , r a t i o n a l decisiqn about the proposal. A process of public p a r t i c i p a t i o n is; also necessary to s o l i c i t opinions about the proposal i n *Many of these recommendations were submitted by the author i n August of 1974 to B.C. Hydro and Power'Authority i n a report e n t i t l e d , "Environ-mental Impact Reports: The Proposed Role, Scope and Content Requirements at B.C. Hydro and Power Authority". - 153 -- 154 -order to help the decision-maker(s) judge the social worth of the project. Since an EIS i s actually a f e a s i b i l i t y document of the proposed project, i t must include information of a wide scope about the total consequences of a l l associated project actions. This includes both bene-f i c i a l and adverse impacts which can be meaningfully aggregated into economic, socio-cultural and ecological categories. INTEGRATING IMPACT STATEMENTS IN THE PLANNING PROCESS An environmental impact statement should be integrated in a planning/decision-making process which util i z e s the information generation purpose of the document to i t s fullest advantage. In this respect, not only can the EIS f a c i l i t a t e a public and government agency review of specific projects but i t can also help define long-term objectives, policies and programs which best reflect the values that exist in society. Figure VI-1 generally illustrates the integration of environmental reports in an overall planning/decision-making process. "This hypothetical plan-ning process includes the following eight basic steps. I. I n i t i a l Statement of Policies and Information Report This very general plan should describe the future objectives of the public entity, forecast alternative demands for the service, commodity or f a c i l i t y provided by the agency (eg. e l e c t r i c i t y demand projections, demand for new highways, etc.) and alternative programs for meeting these different future demands. A general economic, social and ecological impact assessment of these alternative demands and potential programs should then be completed in order to define the recommended courses of - 155 -PROJECT 1 A DRAFT STATEMENT OP PROPOSED JOBJECTIVES POLI-CIES AND PROGRAMS DRAFT ENVIRON-MENTAL • IMPACT REPORT pOVERNMENT AGENCY] AND PUBLIC REVIEW I ~ PINAL STATEMENT OF PROPOSED bBJECTIVES POLI-CIES AND PROGRAMS zzznzzz : PROJECT 2 FINAL ENVIRON-MENTAL IMPACT REPORT ENGINEERING STUDIES) OF ALTERNATIVES FEASIBILITY STUPIES| (ECONOMIC, SOCIAL AND ECOLOGICAL) PRELIMINARY DESIGN DRAFT ENVIRONMENTAL IMPACT REPORT GOVERNMENT AGENCY AND PUBLIC REVIEW FINAL DESIGN AND (FINAL ENVIRONMENTAL IMPACT REPORT LICENSES, APPROVALS| AND CONSTRUCTION AUTHORIZATION (ENGINEERING STUDIEi OP ALTERNATIVES (ENGINEERING STUDIES OF ALTERNATIVES (FEASIBILITY STUDIEi (ECONOMIC, SOCIAL AND ECOLOGICAL) FIGURE VI-1. Integrating policy and project impact statements into the planning/decision-making process. - 156 -action of the agency. This policy impact assessment should be prepared as, an information report which, "objectively" communicates the predicted future consequences of the long range plan to government agencies and the public. II. Public and Government Review The public and relevant government agencies should have access to the evaluation of long-term objectives, policies and programs and be provided with, adequate time to comment before the general plan and EIS are revised. Public information meetings should also be held in an effort to s o l i c i t viewpoints from interested citizens. III. Final Statement of Policies and Final Policy EIS Based upon the review of public and government agency responses, a f i n a l statement of objectives, policies and future programs should be completed. A f i n a l policy EIS on this long-term plan w i l l l i k e l y be a revision of the previous impact statement and should include a discussion of both, the public meetings and the written comments received from govern-ment agencies and the public. The long-term plan developed through this procedure should also be revised periodically in the future to reflect social values and conditions which are constantly changing. IV. Specific Projects — Engineering Studies In many cases, the result of the f i n a l statement of long-range policies i s a sequence of projects which strive toward meeting the approved objectives developed from an earlier public and government review process. The following five steps should be repeated for each - 157 -intended project which comprise the long-term program. F i r s t , engineer-ing studies of p o t e n t i a l s i t e locations and designs should be completed fo r each proposed project. V. Development of I n i t i a l Environmental Impact Statement Before the i n i t i a l EIS i s written, a study of the economic, s o c i a l and e c o l o g i c a l f e a s i b i l i t y of the d i f f e r e n t a l t e r n a t i v e s must be completed. I t i s not necessary that these three factors be evaluated i n i t i a l l y i n great d e t a i l because i t might be found more e f f i c i e n t to eliminate some a l t e r n a t i v e s merely on obvious economic, s o c i a l and eco-l o g i c a l considerations. This should somewhat reduce the number of a l t e r n a t i v e s i t e l o c a t i o n s and preliminary designs before the d r a f t i s completed. VI. Public and Government Review^ In order for a p u b l i c project to r e f l e c t a "weighing" of pre-valent s o c i e t a l values, three conditions must be met. F i r s t , the public and pertinent government agencies must be given access to the i n i t i a l EIS. This means, that they must have knowledge that such an information report e x i s t s and where the document can be e i t h e r obtained or read. Second, anyone interested i n the proposal must be given an opportunity  to respond to both the report and the prospective ac t i o n . In t h i s res-pect , adequate time should be provided between the i n i t i a l release of the document and any authorization or approvals concerning the proposal. In the U.S., at l e a s t 90 days must pass between the i n i t i a l release of a dr a f t impact statement and any authorization or approval of the pro-- 158 -posal. In many cases., p u b l i c information meetings should be held to acquaint the pu b l i c with the project and to provide an opportunity to interested persons to comment on the project. The t h i r d condition necessary to f u l f i l l the prescribed objective of the EIS i s to f u l l y "consider" a l l public and government agency comments concerning the proposal. T h i s condition should be s a t i s f i e d through steps seven and eight i n t h i s hypothetical planning process. VII. F i n a l EIS and Design The f i n a l design should be a produce of the e n t i r e planning process. A l l "responsible" comments received from intere s t e d persons, i n t e r e s t groups: and public agencies should be discussed i n the f i n a l EIS. An action which would i n d i c a t e that p u b l i c comments were "considered" i n planning the proposal would be to include a l l written comments i n the appendix of the f i n a l impact statement. VIII. Decision Concerning the Proposal It i s the r e s p o n s i b i l i t y of the decision-maker(s) to "weight" a l l of the information generated by the impact statement and the opinions expressed by a l l persons and other government agencies i n reaching a judgement about the proposal. EVALUATING ENVIRONMENTAL IMPACTS Evaluating the environmental impact of a proposed project should be undertaken i n a manner which best meets the intended purpose of the document i t s e l f . For t h i s reason, the evaluation should separate environ-- 159 -mental impacts into i n d i v i d u a l quantitative figures and q u a l i t a t i v e terms, so that the information i s a v a i l a b l e f o r preparation of the EIS i n a form which w i l l help the reader decide the importance of each impact. Any impact evaluation consists of f i r s t i d e n t i f y i n g the poten- " t i a l impacts of a proposal and its. a l t e r n a t i v e s , and then c o l l e c t i n g information about each, e f f e c t f o r l a t e r d e s c r i p t i o n i n the EIS. The I d e n t i f i c a t i o n of impacts, and c o l l e c t i o n of information should be d i r -ected toward the consequences of the proposed ..project, i t s associated a c t i v i t i e s and a l t e r n a t i v e s to the project as l a t e r defined i n the format recommendations of these guidelines. IMPACT IDENTIFICATION Other than the general considerations, mentioned i n the magnitude measures section of these guidelines (pg.162), no l i s t i n g of environ-mental impacts w i l l be provided in.these suggestions f o r EIS preparation. The overwhelming number of environmental impacts that can r e s u l t from the many d i f f e r e n t types, of actions i n varying places p r o h i b i t s the development of any one u s e f u l c h e c k l i s t f o r a l l pr o j e c t s . As a r e s u l t , i t i s recommended that a l l e n t i t i e s which normally prepare impact s t a t e -ments develop c h e c k l i s t s of the p o t e n t i a l environmental impacts of t h e i r actions at a s p e c i f i c l e v e l (eg, dissolved oxygen, water temperatures, t u r b i d i t y , etc. rather than j u s t water quali t y ) that, when possibl e , are measurable i n terms: of magnitude. In order to better r e l a t e cause and e f f e c t , i t might be best to develop a c h e c k l i s t for each d i f f e r e n t action commonly undertaken by an agency. For example, Highways Department should - 160 -construct a checklist of impacts for highway construction, highway operation, reststops, bridges, etc. The development and periodic up-dating of such checklists w i l l ensure that a l l potential consequences for different types of actions are considered before the preparation of an EIS. The most comprehensive type of checklist i s a network which links causal actions to primary, secondary and multiple-order impacts. The information for a network can also be stored on computer for easy updating and retrieval. The only major disadvantage of networks i s that they are time consuming and d i f f i c u l t originally to prepare correctly. It would also be helpful to include on a checklist, where pertinent, possible units of measure for each potential impact in order to help the assessor define magnitude. Another aid for EIS preparation would be to include hints or guidance to possible mitigation measures for each impact on the checklist. INFORMATION COLLECTION I n i t i a l l y , basic information must be obtained before further assessment i s completed and the EIS is prepared. Prior to identifying the relevant impacts, of the project and i t s alternatives, an inventory of a l l socio-cultural and ecological conditions in the potentially "affected" area that are relevant to the proposed project must be com-pleted. This inventory should be sufficient enough to estimate the future environmental conditions i f the proposed project was not imple-mented. Based upon this inventory, other information must be collected for later inclusion in the EIS so that the reader i s objectively helped - 161 -i n making a judgement about the proposed project. Information about the following s i x d i f f e r e n t considerations for each impact must be obtained: 1) Magnitude measures; 2) Risk or uncertainty; 3) P o t e n t i a l m i t i g a t i o n measures and unavoidable adverse impacts; 4) Range of "responsible" opinions i n society; 5) Incidence on groups and areas; 6) Time span of impact. I. Measures of Magnitude Most economic, s o c i o - c u l t u r a l and e c o l o g i c a l impacts of a pro-posal can be measured i n some way to show the extensiveness of an impact. Economic e f f i c i e n c y i s the only category of impacts which can be f a i r l y assessed i n common u n i t s . When public funds are to be al l o c a t e d toward a project and the important benefits of the project are economic, a benefit/cost analysis i s a useful method of defi n i n g the e f f i c i e n c y of the investment. Through, the use of common monetary f i g u r e s , a r a t i o i s developed through benefit/cost analysis which indicates the economic f e a s i b i l i t y of the proposal. I f the r a t i o i s greater than unity, the economic benefits exceed the economic costs. A c r i t e r i o n for acceptance of d i f f e r e n t types of projects can also be developed such as a 1.2/1.0 benefit to cost r a t i o . At present, standardized guidelines have been developed i n Canada (Sewell, et. a l . , 1965) and i n the U.S. (U.S. Water Resources Council, 1973). These guidelines provide d i r e c t i o n concerning acceptable techniques to measure monetary benefits and costs, the view-- 162 -point or accounting stance of the analysis, procedures of considering risk of impact in the analysis, and how to determine the economic l i f e of the project and the social discount rate. Social and cultural impacts can be quantified in some manner to define magnitude, but these numerical figures are not readily compa-rable with one another since they may be in dollar terms, days, acres, people, etc. Nevertheless, such quantitative information w i l l identify the extensiveness of the impact which i s of important use in EIS prepa-ration. The following i s a non-comprehensive l i s t of conditions and possible quantitative measures which can help indicate the social and cultural consequences in areas affected by a proposed action. CONDITIONS Population Employment Housing Recreation Areas Transportation Physical Services Institutions Ethnic Groups Archaeological Remains Historical Areas MEASURES OF MAGNITUDE number of people number of jobs, income generated number of single-family and multiple family homes, monetary value of homes number of acres, acreage, annual user-days , economic value number of highways and roads, total length, economic value number of commercial services by types, hospitals, schools, etc. number of organizations, agencies, laws, regulations, established customs, etc. number of groups, populations number of sites, acreage number of areas, acreage, structures - 163 -S c i e n t i f i c Interest number of areas, acreage Areas Noise number of people and homes af f e c t e d , d e c i b e l predictions Odors number of people and homes affected V i s u a l Aesthetics number of people a f f e c t e d , miles of view disturbed It i s apparent that the measures l i s t e d above are not s u f f i c i e n t to adequately value s o c i a l and c u l t u r a l e f f e c t s , and i n many cases d i f -ferent measures may be applicable to a c e r t a i n impact. For example, merely by mentioning the number of people affected and the miles of view disturbed by proposed transmission l i n e s does not adequately assess i t s impact. The impact can be further quantified by i d e n t i f y i n g the number of poles and l i n e s , the value of the property impacted, the number of road and stream crossing and the number of ridges or summits crossed. As i n s o c i a l and c u l t u r a l impacts, e c o l o g i c a l impacts cannot be f a i r l y q u a n t i f i e d i n common u n i t s . Yet, i n many cases i t i s important during the information c o l l e c t i o n stage of evaluation to define e c o l o g i c a l impacts i n quantitative units to in d i c a t e magnitude or sc a l e . For example, the following i s a l i s t of e c o l o g i c a l conditions and some measures of magnitude which could be used i n an EIS. CONDITIONS MEASURES OF MAGNITUDE Land form amount of earth displaced Minerals number of types, amount of each type Soils: number of types, amount of each type - 164 -Water Air Climate Drainage Patterns Sediment Deposition Flood Cycles Plants: Animals Microorganisms amount of dissolved oxygen, depth of vision, fecal coliforms, nitrogen, phosphates solids, temperature, PH measures, etc. amount of CO, NO , SO , hydrocarbons, particulates, etc. x mean temperatures, amount of r a i n f a l l , fog-free days, etc. number and size of streams displaced, amount of s o i l eroded, etc. amount of sediment deposited annually time periods number and species number and species Relative abundance and species II. Risk or Uncertainty of Impacts An i n i t i a l consideration which should be defined in the inform-ation collection stage of impact evaluation is the identification of risk or probability of impact occurrence. An impact such as ambient sulfur oxides level being surpassed due to the potential air pollutant emissions of a thermal power plant during certain meteorological conditions may be a very important impact unless the probability of occurrence i s very low. In most cases;, i t w i l l be d i f f i c u l t to provide a precise risk figure but possible to give some range in probability such as 25-50% or otherwise. In many other cases, there may be considerable uncertainty about an impact and no risk figure can be given. When this occurs, a reasoning why the impact i s uncertain should be stated just as a l l assumptions about a pro-babil i t y figure should be revealed. - 165 -I I I . P o t e n t i a l M i t i g a t i o n Measures or Unavoidable Adverse E f f e c t s An i d e n t i f i c a t i o n of impacts that can be mitigated or impacts that have an unavoidable i n t e n s i t y i s another consideration which should he i d e n t i f i e d during the information c o l l e c t i o n stage of evaluation. This: w i l l communicate to the reader whether and by hownmuch the i n t e n s i t y of a prospective impact can be reduced. Decisions concerning the amount of money al l o c a t e d to reduce an environmental impact w i l l consequently be revealed to public scrutiny. For example, i f i t i s decided f o r a proposed f o s s i l - f u e l e l e c t r i c a l power generation plant that wet scrubbers as. a p o l l u t i o n control device were not worth the amount of money i t would cost i n comparison to the a i r p o l l u t i o n i t would mitigate, t h i s require-ment for the EIS would reveal t h i s decision f or public review. The i d e n t i f i c a t i o n of unavoidable impacts (either t e c h n i c a l l y or because i t i s economically unfeasible to mitigate w i l l help the reader assign im-portance to the various environmental impacts. An example of a technic-a l l y unavoidable adverse e f f e c t would be the blocking of normally large amounts of downstream s i l t deposition by a dam. IV. Range of Responsible Opinions i n Society The problem of developing an unbiased EIS i s d i f f i c u l t to solve. One addition to an EIS which can help the reader evaluate e f f e c t s and also improve the o b j e c t i v i t y of the report i s to spec i f y f or environmental impacts a range of responsible opinions that e x i s t i n socie t y concerning the importance of the e f f e c t ( s ) . During the information c o l l e c t i o n stage of the environmental evaluation, when there i s doubt about the i m p l i c a -tions, of an impact then the d i f f e r e n t responsible opinions i n society - 166 -should be i d e n t i f i e d f o r l a t e r incorporation into the EIS. For example, d i f f e r i n g s c i e n t i f i c opinions e x i s t concerning the consequences of humans exposed to increased amounts of low-level r a d i a t i o n f o r long periods of time. Both s c i e n t i f i c opinions should be included i n an EIS discussing the p o t e n t i a l impacts of a nuclear-powered e l e c t r i c a l genera-t i o n plant. V. Incidence of Impacts A most important consideration that must be defined during impact assessment concerns the d i s t r i b u t i o n of b e n e f i c i a l and adverse conse-quences.. The incidence of a l l economic, s o c i o - c u l t u r a l and e c o l o g i c a l impact i s d i f f e r e n t for persons, groups, and areas which provides a hasic reasoning f o r varying opinions about a proposed project. Although the d i s t r i b u t i o n of impacts cannot be r e a l i s t i c a l l y i d e n t i f i e d i n r e l a t i o n to s p e c i f i c persons and places i n an EIS, the incidence of e f f e c t s can be i d e n t i f i e d at a more general l e v e l r e f l e c t e d by ethnic groups, d i f f e r e n t i n t e r e s t s (e.g. conservationists, entrepreneurs, r e c r e a t i o n i s t s , tax-payers, i n d u s t r i a l i s t s , etc.) and areas (e.g. neighbourhoods, towns, regional d i s t r i c t s , e t c . ) . For example, r e c r e a t i o n i s t s are adversely aff e c t e d to a greater extent than i n d u s t r i a l i s t s due to the flooding of a popular canoe r i v e r from a dam. This more s p e c i f i c d i s t r i b u t i o n of an impact should be i d e n t i f i e d j u s t as any adverse consequences (e.g. e f f e c t s r e s u l t i n g from the construction and existence of a dam) which often occur r e g i o n a l l y and l o c a l l y should be revealed i n j u x t a p o s i t i o n to the broader benefits which usually accrue to major urbanized regions or to the province as a whole. Through an i d e n t i f i c a t i o n of the i n c i -- 167 -dence of impacts, s p a t i a l l y and on groups of people, important informa-t i o n w i l l he obtained for l a t e r i n t e g r a t i o n i n the EIS. Time Span of Impacts A major focus of long range planning i s to avoid the often myopic tendencies of man. By defi n i n g i n an evaluation the time span of a l l impacts, information w i l l he a v a i l a h l e f o r the EIS to i n d i c a t e the long-term consequences and the d i v e r s i t y of future uses of the environ-ment which might be c u r t a i l e d by the proposed project. This considera-t i o n should also i d e n t i f y a l l important inducement e f f e c t s and any i r r e v e r s i b l e commitments of resources (renewable and non-renewable resources). An example of inducement consequences i s the dispersed urban growth prompted i n l a t e r years from the construction of a freeway near an urbanized region. This adverse impact of urban sprawl was not assessed i n past planning of freeways and highways, but i n order to f a c i l i t a t e more r a t i o n a l decisions i n the future such inducement conse-quences should be defined i n the environmental evaluation and included i n the EIS. PREPARATION OF THE ENVIRONMENTAL IMPACT STATEMENT GENERAL CONSIDERATIONS The purpose of preparing the environmental impact statement i s to provide information to the reader i n order to f a c i l i t a t e an i n d i v i -dual, r a t i o n a l d ecision about the s o c i a l worth of the proposed project. This requires that the EIS be l o g i c a l l y organized, " o b j e c t i v e l y prepared," succinct and non-technical. An example of a l o g i c a l format c o n s i s t i n g - 168 -of general requirements which should be included i n a l l impact s t a t e -ments i s included i n the following section. A p e r f e c t l y "objective" EIS i s probably impossible to a t t a i n b.ut i s , nonetheless, necessary to s t r i v e toward i f an impact statement is. to function as an information document so that more s o c i a l l y respon-s i b l e decisions can be made. In preparing the EIS, q u a l i f y i n g phrases should he avoided, and a l l descriptions of b e n e f i c i a l and adverse e f f e c t s should be p a r a l l e l i n meaning. For example, reduced anadromous f i s h populations; should not be defined as "Due to the planned construction of a f i s h hatchery, salmon population losses should be reduced consider-ably." Thus;, compensation actions should not be used to cloud the d e s c r i p t i o n of environmental impacts. Also, p a r a l l e l d e s c r i p t i v e phrases should be used such as "gain of" and "loss of", " b e n e f i t " and "cost", "reduced" and "increased", etc., to more f a i r l y describe consequences to the reader. A succinct and non-technical EIS w i l l be achieved i f the report i s thoughtfully prepared for the common layman. Most environmental impacts do not require a t e c h n i c a l explanation even though i t may be necessary during the evaluation to undertake s c i e n t i f i c studies. More tec h n i c a l a u x i l i a r y information can be included i n the appendix of the report i n instances where the d e t a i l e d assumptions and a n a l y t i c a l methods should be a v a i l a b l e for reference to readers. A succinct EIS requires that unimportant details, and side-issues be avoided i n discussion. In order to f a c i l i t a t e a succinct communication of information to the reader, a summary of both the project's environmental impacts and the - 169 -analysis of a l t e r n a t i v e s should be included i n the EIS. A proposed method of summarizing the EIS i s included i n the format recommendations of this, framework. These general considerations which are necessary f o r EIS to communicate information to the reader cannot be s p e c i f i c a l l y d i r e c t e d i n guidelines so that the resultant impact statements comply with these considerations. It should also be mentioned that an impact statement must not be so simply written to the extent that meanings are l o s t . Consequently, considerable d i s c r e t i o n remains with the persons preparing the impact statement i n reference to the degree of conciseness and lack of d e t a i l . FORMAT OF THE EIS I. Summary Sheets In order to make a complete e f f o r t i n communicating information to a l l interested persons, Tables VI-1 and VI-2 have been developed as summary sheets to be included i n the beginning of an EIS. Some possible impacts and part of an a l t e r n a t i v e analysis f o r a hypothetical hydro-power development i l l u s t r a t e the use of these summary sheets. The summary sheets are self-explanatory since they c l e a r l y include the s i g n i f i c a n t considerations which f a c i l i t a t e a person i n assigning importance to an environmental impact. I I . Description of the Proposed Action The d e s c r i p t i o n of the proposed project should not be extensive, but should b r i e f l y include the following f i v e points: QUANTIFICATION IMPACTS ECONOMIC 1) Electricity sales 2) Payroll Input to local economies 3) Construction and operation costs k) Recreation loss 5) etc. . . 6) etc. . . SCCIO/CULTURAL 1) Business Recession after construction 2) Relocation of families 3) Housing shortage U) etc. . . 5) etc. . . 6) etc. . . ECOLOGICAL 1) Elimination of free-flowing section of river 2) Loss of deer 3) Loss of fish It) etc. . . 5) etc. . . 6) etc. . . BENEFICIAL ADVERSE From $ to $ From to Presently non-quantifiable ! 16 homes I Peak shortage of I 500-700 homes j 7 miles 25r l lO deer 100-700 trout KEY ' Certain Highly probable Probable Improbable uncertain 100J& : Over 8556 Over 5056 Under 50$ Risk is unknown Excellent Fair None Avoidable impact Partially avoidable Unavoidable Impact Probability of impact occurrence without implementing mitigation measures QUALIFICATION . PROBABILITY* TIME SPAN OF IMPACT MITIGATION POTENTIAL IMPACT DISTRIBUTION Certain kC years Provincial Certain 6 years Local towns Highly probable 6 years and 40 years None Provincial Highly probable Long-term Fair Regional Certain 5-15 years- Fair Local towns Certain Short- term None Individuals Certain 6 years Excellent Local towns Certain Long-term Rone Regional/Provincial fit Interest groups Certain Long-term Fair Regionsl/Provinc ia1 & interest groups Certain Long-term Fair Regional/Provincial & interest groups TABLE VI-1 . A summary sheet including some economic, soeio/cultural and ecological impacts, which could result from a proposed hydro-power development. ALTERNATIVES TO THE PROPOSED ACTION SIGNIFICANT TRADEOFFS WHEN COMPARED TO PROPOSED PROJECT No Project Lower Dam Height Economic Socio/Cultural Ecological Beneficial Adverse | 3eneficial Adverse I Beneficial Adverse 1) Project.costs of $ can be utilized else-whe-e in the B.C. onomy. 2) etc. . . 1) Project costs of $ can lie utilized else-where in the B.C. economy. 2) etc. . . jl) Foregone bene-fits of $ • in electricity sales. 2) Multiplier onomic impacts |provinc'ialIy of .to $ |and regionally of $; to $ 3) Costs assoc-iated with the accellerated planning and development of substitute Iproject B. k) etc. . . 1) Foregone bene-fits of $ in electricity sales. 2) Multiplier economic impacts provincially or $ to $ and regionally of $_ to $ . 3) Costs assoc-iated with the laccellerated planning and |development of substitute project B. U) etc. 1) Lack of comm-unity impact associated with the construction -of the project. 2) Lack of re-adjustment impact associated with project after construction. 3) No displace-ment of 25 families. 1) Economic stim-ulation of the local economy due to project con-struction would not occur. 1) Lesser degree of community impact assoc-iated with the construction of the project. 2) Lesser degree of readjustment impacts assoc-iated with projectl after construction) 3) No displacement) of 8 families. Il) No f looding of 3U0 acres of (ungulate winter, [range. L) Less economic -stimulation o f the l o c a l economy lue to project onstruction Would not occur. Il) ICO acres less tngulate .wintering) rea inundated. I h-1 I—1 I TABLE VI-2. A proposed method of summarizing an analysis of alternatives and three hypothetical alternative examples. ALTERNATIVES TO THE PROPOSED ACTION SIGNIFICANT TRADEOFFS WHEN. COMPARED TO * PROPOSED PROJECT Economic Socio/Cultural Ecological Beneficial Adverse Beneficial Adverse Beneficial Adverse. Dam location 3 miles upstream from present proposed site None l) Foregone bene-fits of $ in electricity sales resulting in a lower benefit /cost ratio. 1) Preservation of additional 3 miles salmon spawning beds resulting in an average annual figure of 200 additional comm-ercial-size fish. 2) etc. . . 1) Flooding of additional 20 acres (360 total) of ungulate winter range. - 173 -1) A discussion of the h i s t o r i c a l background to the proposal leading to the r a t i o n a l e and objectives of the project; 2) A general d e s c r i p t i o n of the t e c h n i c a l aspects and s p e c i a l requirements of the action (e.g. an explana-t i o n of how a thermal power plant operates, foundation requirements, e t c . ) ; 3) The precise l o c a t i o n of the p r o j e c t , preferably on a map; 4) An i d e n t i f i c a t i o n of past public p a r t i c i p a t i o n which has. occurred and future input which w i l l be s o l i c i t e d ; 5) A discussion of the r e l a t i o n s h i p of the project with e x i s t i n g i n s t i t u t i o n s ( i . e . laws, regulations p o l i c i e s , important customs and public organizations, e t c . ) . I I I . Description of the Environmental Setting A d e s c r i p t i o n of the environmental s e t t i n g i s a necessary and often lengthy part of an impact report. The extensiveness of t h i s section depends upon the thoroughness that i s intended for the EIS, a l -though i n a l l cases the inventory should describe the e x i s t i n g environ-mental conditions, which may be affected by the a c t i o n . A decision concerning the amount of resources to be a l l o c a t e d toward preparing a "thorough" EIS should be based on three considerations. These three considerations are the magnitude of the p o t e n t i a l project e f f e c t s , the amount of resources devoted to the p r o j e c t , and whether the action i s of a c o n t r o v e r s i a l nature or not. Regardless of the comprehensiveness decided for the EIS, the d e s c r i p t i o n of environmental s e t t i n g i n the report can be divided into natural features (e.g. topography, geology, s o i l s , water, a i r , f l o r a , fauna, natural processess, etc.) and human-oriented features (e.g. - 174 -population, employment, housing, transportation, recreation areas, com-mercial s e r v i c e s , i n d u s t r i a l areas, e t c . ) . Special reference should be made i n t h i s section to unique and v i t a l n atural and human-oriented environmental conditions. Both a quantitative and q u a l i t a t i v e d e s c r i p -t i o n of environmental features should be completed to be used as a benchmark to compare the predicted future s e t t i n g both with and without the proposed project. Furthermore, a map with an accurate deli n e a t i o n of the boundaries of the study area should be included i n t h i s section. IV. The Environmental Impact of the Proposal 1) Economic e f f i c i e n c y . The economic e f f i c i e n c y of the pro-posed project i s one important factor i n deciding whether an intended project merits public investment. As mentioned e a r l i e r , i n many cases, a benefit/cost analysis according to standardized procedures i s the best method for defining economic e f f i c i e n c y . In other instances, an objective d e s c r i p t i o n of the economic r a t i o n a l e for the proposal should be completed. Whenever an economic analysis i s included i n the EIS, a l l assumptions should be revealed to the reader. 2) S o c i o - c u l t u r a l impacts. A l l p o t e n t i a l s o c i a l and c u l t u r a l impacts should be described according to the following f i v e considerations: A) Quantitative p r e d i c t i o n of each impact (when appro-pr i a t e ) ; B) Risk or uncertainty of impact; C) Time span of impact (when appropriate); D) An i d e n t i f i c a t i o n of mi t i g a t i o n measures or whether the i n t e n s i t y of the impact i s unavoidable; - 175 -E) A s p e c i f i c a t i o n of the range of responsible opinions i n society concerning an impact (only when appropriate). A reasoning should be included i n the EIS for a l l possible im-pacts which are found i n the evaluation to be not applicable to the proposed p r o j e c t . For many impacts i t w i l l also be necessary to q u a l i -t a t i v e l y describe impacts through d e s c r i p t i v e words. 3) E c o l o g i c a l impacts. E c o l o g i c a l impacts include a l l natural ph y s i c a l and natural b i o l o g i c a l e f f e c t s . As i n s o c i o - c u l t u r a l impacts, the f i v e evaluation considerations l i s t e d above should be used to help describe e c o l o g i c a l impacts f o r the reader. In many cases, these evalua-t i o n considerations are not adequate to define f o r the reader the im-p l i c a t i o n s of e f f e c t s . For example, merely by mentioning the amount of CO, NO or SO released into the atmosphere for d i f f e r e n t time periods does not adequately assess the a i r p o l l u t i o n impacts from a f o s s i l - f u e l e d e l e c t r i c a l genera-t i o n plant. This impact should be further q u a l i f i e d with a discussion of the r e l a t i o n s h i p of the prospective emissions with e x i s t i n g a i r q u a l i t y standards i n B.C. and elsewhere. The discussion should also note the multiple-order consequences of these pollutants on the v i s u a l character of the region, the plant and animal l i f e nearby, on human health, and other relevant conditions which could be affected by these emissions. 4) D i s t r i b u t i o n of impacts. A separate section of an EIS should be devoted to describing the d i s t r i b u t i o n of project impacts. Impact d i s t r i b u t i o n should be defined both s p a t i a l l y ( i . e . p r o v i n c i a l and nat i o n a l vs.. regional and l o c a l incidence) and also to ethnic and s p e c i a l - 176 -in t e r e s t groups. 5) The r e l a t i o n s h i p between short-term and long-term e f f e c t s . In this, section of the EIS, a comparison should be made between the s i g n i f i c a n t short-term b e n e f i c i a l and adverse e f f e c t s , and the long-term consequences of the proposal. This section should also b r i e f l y discuss the d i v e r s i t y of future uses of the environment which may be reduced due to the proposal. 6) The r e l a t i o n s h i p of the proposal to pu b l i c goals and ob-j e c t i v e s . When the c i t i z e n s of a community or region have formed a set of goals and objectives through some formal planning procedure, the r e l a t i o n s h i p of the proposed project to these public aspirations should be described i n the EIS. S i m i l a r l y , any relevant questionnaires, surveys, public meetings., workshops, etc. which have been undertaken to help de-f i n e the needs and desires of the public affected by the proposal should also be contrasted to the prospective consequences of the proposal. V. A l t e r n a t i v e s to the Proposed Action It i s e s s e n t i a l i n planning that the proposed project i s chosen to maximize the net benefits accruing to soc i e t y . In order f o r the best project to be proposed, i t i s necessary that the b e n e f i c i a l and adverse e f f e c t s of a range of a l t e r n a t i v e s be evaluated. The premise underlying a l t e r n a t i v e " a n a l y s i s i s that the generation of information to d e c i s i o n -makers and the pu b l i c about the consequences of a l t e r n a t i v e opportunities w i l l r e s u l t i n more s o c i a l l y responsible decisions (U.S. National Academy of Sciences, 1968). Based upon the U.S. guidelines (1973b) recently revised due to court decisions on impact statements, a l t e r n a t i v e s which - 177 -should be considered in this evaluation are: 1) The choice of "no action"; 2) Alternative designs and locations which achieve similar objectives as the proposal; 3) Alternatives of a different type which achieve similar objectives as the proposal. This evaluation of alternatives should be substantial enough to indicate the important tradeoffs between each potential choice and the proposed project. Due to the broad definition of potential alternatives mentioned above i t may seem that a multitude of choices are possible concerning almost any proposal. It would be an almost unfeasible task to try to evaluate the positive and negative aspects of numerous alternatives, and attempt to communicate this overwhelming amount of data to the interested public and decision-makers. This problem might best be resolved through the following two considerations. F i r s t , an environmental report on the long-term objectives, policies and programs of a public entity would eliminate many broad alternatives from treatment in an EIS for a specific action. For example, i f a long range plan was developed according to the planning process mentioned in an earlier part of these guidelines, future programs would be established to the extent that many alternatives would be eliminated from consideration in EIS's for specific projects. If an ele c t r i c a l u t i l i t y agency decided through this planning process leading to a long-range plan that hydropower i s the only publicly accept-able alternative for e l e c t r i c i t y generation, then nuclear and f o s s i l -fueled power alternatives need not be considered in the impact report for - 178 -a s p e c i f i c dam proposal. Of course, the EIR on the long-range plan should thoroughly discuss the pros and cons of a l l relevant power gene-r a t i o n sources to help develop through public s c r u t i n y some consensus on the future e l e c t r i c a l energy programs of the public u t i l i t y organiza-t i o n . Through the development of such a long-range plan, there i s no need i n an EIR f o r a s p e c i f i c project to r a i s e issues already resolved through a p u b l i c p a r t i c i p a t i o n process. A second consideration which can help reduce the large number of p o t e n t i a l a l t e r n a t i v e s to a proposal i s to develop choices only i n reference to the d i f f e r e n t objectives of the public (U.S. National Aca-demy of Science, 1968). The objectives and goals of the public are often stated i n community and regional plans, and can also be developed through communication with a c t i v e i n t e r e s t groups. This method of reducing the number of choices f o r evaluation w i l l l i k e l y develop an a l t e r n a t i v e that maximizes e f f i c i e n c y , an a l t e r n a t i v e with a goal to achieve income d i s t r i b u t i o n and an a l t e r n a t i v e that optimizes environmental q u a l i t y . Other intere s t e d sectors i n society should likewise be represented with an evaluation of the a l t e r n a t i v e that r e f l e c t s t h e i r o bjectives. I t has also been recommended (U.S. National Academy of Sciences, 1968) that compromise a l t e r n a t i v e s between objectives be included i n the a n a l y s i s . Since a large number of a l t e r n a t i v e s may s t i l l r e s u l t , judgement w i l l have to be used to screen p o t e n t i a l choices to a manageable t o t a l . VI. A Discussion of Public and Agency Responses to the Proposal ( f i n a l EIS only) A discussion of a l l c i t i z e n information meetings and a l l public government agency comments on the d r a f t should be included i n the f i n a l - 179 -EIS to help resolve differences and further explain the r a t i o n a l e f o r c e r t a i n key judgements. CONCLUSION These guidelines f o r the evaluation and preparation of environ-mental impact statements were developed b a s i c a l l y from the simple purpose the document i s intended to serve. The c r i t i c a l review of f i v e impact statements, and discussion of impact evaluation methods e a r l i e r i n t h i s thesis have provided information about environmental report and assessment weaknesses which were e s p e c i a l l y addressed i n these guidelines. Yet, knowledge that the e x i s t i n g state of a r t i n impact assessment i s s t i l l i n a developing stage and the r e a l i z a t i o n of the numerous d i f f e r e n t types of actions and conditions a f f e c t i n g the preparation of impact statements leads the author to strongly doubt whether the guidelines recommended i n t h i s thesis are a panacea for EIS problems. Instead, the information generation function of an EIS prescribes that any impact evaluation and statement preparation procedure adopted by public agencies be f l e x i b l e i n order to serve the needs of those decision-makers, i n t e r e s t groups, government agencies and intere s t e d members of the public that w i l l be reviewing future impact reports. As a r e s u l t , i t i s recommended that the guidelines, i n t h i s thesis be used as a general framework for develo-ping s p e c i f i c agency procedures f o r environmental evaluations and EIS preparation. These s p e c i f i c agency procedures should be i n i t i a l l y developed through a review and comment process of those government agencies, i n t e r e s t groups and p r i v a t e persons who w i l l be reading the future impact statements. 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Policy and Procedure Memorandum, Transmittal 257. Wash., D.C. University of California, Davis. 1971. Workshop in Environmental Impact  Analysis, Summary. Division of Environmental Studies, Davis, Calif. Virginia Highway Research Council. 1971. A Manual For Conducting Environ- mental Impact Studies. NTIS Publication No. PB-210 222, Spring-f i e l d , Va. Warner, Maurice L. and Edward H. Preston. 1974. A Review Of Environmental  Impact Assessment Methodologies. Prepared for the Office of Re-search and Development, U.S. Environmental Protection Agency, Wash., D.C. Washington State Department of Ecology. 1972. Guidelines For Implementation  of the State Environmental Policy Act of 1971. Olympia, Wash. Zube, Erwin H. 1970. "Evaluating the Visual and Cultural Landscape", Journal  of Soil and Water Conservation. Vol. 25, No. 4, pp. 137-141. - 191 -APPENDIX A THE U.S. NATIONAL ENVIRONMENTAL POLICY ACT OF 1969 - 192 -Public Law 91-190 91st Congress, S. 1075 January 1, 1970 2to&Ct 8 3 s tat . 8S2 To establish a national policy for the environment, to provide for the establish-ment of a Council on Environmental Quality, and for other purposes. Be it enacted by the Senate and Home of Representatives of the United States of America in Congress assembled, That this Act may National Eh-be cited as the "National Environmental Policy Act of 1969"'. vironmental PURPOSE Polioy Aot of 1969. SEC, 2. The purposes of this Act are: To declare a national policy which will encourage productive and enjoyable harmony between man and his environment; to promote efforts which will prevent or elimi-nate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the eco-logical systems and natural resources important to the Nation; and to establish a Council on Environmental Quality. T ITLE I DECLARATION OF NATIONAL ENVIRONMENTAL POLICY SEC. 101. (a) The Congress, recognizing the profound impact of Polioiss and man's activity on the interrelations of all components of the natural e°al». environment, particularly the profound influences of population growth, high-density urbanization, industrial expansion, resource exploitation, and new and expanding technological advances and recognizing further the critical importance of restoring and maintain-ing environmental quality to the overall welfare and development of man, declares that it is the continuing policy of the Federal Govern-ment, in cooperation with State and local governments, and other con-cerned public and private organizations, to use all practicable means and measures, including financial and technical assistance, in a man-ner calculated to 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. (b) In order to carry out the policy set forth in this Act, it is the continuing responsibility of the Federal Government to use all prac-ticable means, consistent with other essential considerations of national policy, to improve and coordinate Federal plans, functions, programs, and resources tq.the end that the Nation may— (1) fulfill the responsibilities of each generation as trustee of the environment for succeeding generations; (2) assure for all Americans safe, healthful, productive, and esthetically and culturally pleasing surroundings; (3) attain the widest range of beneficial uses of the environ-ment without degradation, risk to health or safety, or other unde-sirable and unintended consequences; (4) preserve important historic, cultural, and natural aspects of our national heritage, and maintain, wherever possible, an environment which supports diversity and variety of individual choice; (5) achieve a balance between population and resource use which will permit high standards oi living and a wide sharing of life's amenities; and - 193 -83 STAT. 653 Pub. Law 91-190 January 1, 1970 Administration. Copies of state-ments, eto.javail-ability. . 81 Stat. 54. (6) enhance the quality of renewable resources and approach the maximum attainable recycling of depletable resources. (c) The Congress recognizes that each person should enjoy a health-ful environment and that each person has a responsibility to contribute to the preservation and enhancement of the environment. SEC. 102. The Congress authorizes and directs that, to the fullest extent possible: (1) the policies, regulations, and public laws of the United States shjtll be interpreted and administered in accordance with the policies set forth in this Act, and (2) all agencies of the Fed-eral Government shall— (A) utilize a systematic, interdisciplinary approach which will insure the integrated use of the natural and social sciences and the environmental design arts in planning and in decisionmaking which may have an impact on man's environment; (B) identify and develop methods and procedures, in con-sultation with'the Council on Environmental Quality established by title II of this Act, which will insure that presently unquali-fied environmental amenities and values may be given appropriate consideration in decisionmaking along with economic and tech-nical considerations; (C) include in every recommendation or report on proposals for legislation and other major Federal actions significantly af-fecting the quality of the human environment, a detailed state-ment by the responsible official on— (i) the environmental impact of the proposed action, (ii) any adverse environmental effects which cannot be avoided should the proposal be implemented, (iii) alternatives to the proposed action, (iv) the relationship between local short-term uses of man;s environment and the maintenance and enhancement of long-term productivity, and (v) any irreversible and irretrievable commitments of re-sources which would be involved in the proposed action should it be implemented. Prior to making any detailed statement, the responsible Federal official shall consult with and obtain the comments of any Fed-eral agency which has jurisdiction by law or special expertise with respect to any environmental impact involved. Copies of such statement and the comments and views of the appropriate Federal, State, and local agencies, which are authorized to develop and en-force environmental standards, shall be made available to the President, the Council on Environmental Quality and to the pub-lic as provided by section 552 of title 5. United States Code, and shall accompany the proposal through the existing agency review processes; (D) study, develop, and describe appropriate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available re-sources; (E) recognize the worldwide and long-range character of en-vironmental problems and, where consistent with the foreign policy of the L nited States, lend appropriate support to initiatives, resolutions, and programs designed to maximize international cooperation in anticipating and preventing a decline in the quality of mankind's world environment; (F) make available to States, counties, municipalities, institu-tions, and individuals, advice and information useful in restoring, maintaining, and enhancing the quality of the environment; - 194 -January 1, 1970 Pub. Law 91-190 83 STAT. 854, (G) init iate and uti l ize ecological information in the p lanning and development of resource-oriented projects; and ( H ) assist the Counc i l on Env i ronmenta l Q u a l i t y established by t i t le I I of this A c t . Sec . 103. A l l agencies of the Federal Government shall review Review, their present statutory authority , administrative regulations, and cur-rent policies and procedures for the purpose of determining whether there are any deficiencies or inconsistencies therein which prohibit f u l l compliance wi th the purposes and provisions of this A c t and shal l propose to the President not later than J u l y 1,1971, such measures as may be necessary to b r ing their authority and policies into conform-ity wi th the intent, purposes, and procedures set for th in this A c t . Sec . 104. Noth ing in Section 102 or 103 shall in any way affect the specific statutory obligations of any Federal agency (1) to comply w i th criteria or standards of environmental qual i ty , (2) to coordinate or consult wi th any other Federal or State agency, or (3) to act, or refrain f rom acting contingent upon the recommendations or certif i -cation of anyother Federal or State agency. Sec . 105. The policies and goals set forth in this A c t are supplemen-tary to those set for th in exist ing authorizations of Federal agencies. TITLE II COUNCIL ON ENVIRONMENT Al. QUALITY Sec . 201. The President shall transmit to the Congress annually Report to beginning J u l y 1, 1970, an Env i ronmental Qua l i t y Report (herein- con fess , after referred to as the "report") which shall set forth (1) the status and condition of the major natura l , manmade, or altered environ-mental classes of the Nat ion , inc luding, but not l imited to, the a i r , the aquatic, inc luding marinej estuarine, and fresh water, and the terrestrial environment, inc luding, but not l imited to, the forest, d ry -land , wetland, range, urban, suburban, and rura l environment j (2) current and foreseeable trends in the quality , management and ut i l i za -tion of such environments and the effects of those trends on the social , economic, and other requirements of the N a t i o n ; (3) the adequacy o i available natural resources for fu l f i l l i ng human and economic require-ments of the Nat ion i n the l ight of expected population pressures; (4 ) a review of the programs and activities ( inc luding regulatory ac-tivit ies) of the Federal Governmentj the State and local governments, and nongovernmental entities or indiv iduals, w i th part icular reference to their effect on the environment and on the conservation, develop-ment and ut i l i zat ion of natural resources; and (5) a program for remedying the deficiencies of exist ing programs and activities, to-gether with recommendations for legislation. Sec. 202. There is created in the Executive Office of the President Counoil on a Counci l on Env i ronmental Qua l i t y (hereinafter referred to as the Environmental "Counc i l " ) . The Counci l shal l be composed of three members who shal l Quality, be appointed by the President to serve at his pleasure, by and w i th the advice and consent of the Senate. The President shall designate one of the members of the Counci l to serve as Cha i rman. E a c h mem-ber shall be a person who, as a result of his t ra in ing , experience, and attainments, is exceptionally well qualified to analyze and interpret environmental trends and information of a l l k i n d s : to appraise pro-grams and activities of the Federal Government in the l ight of the pol icy set fo r th in t it le I of this A c t ; to be conscious of and responsive to the scientific, economic, social, esthetic, and cul tural needs and i n -terests of the N a t i o n ; and to formulate and recommend national policies to promote the improvement of the qual i ty of the environment - 195 -Pub. Law 91-190 January 1, 1970 63 STAT. 855 Sec. 203. The Council may employ such officers and employees as may be necessary to carry out its functions under this Act. In addition, the Council may employ and fix the compensation of such experts ana consultants as may be necessary for the carrying out of its functions under this Act, in "accordance with section 3109 oftitle 5, United States 80 Stat. 416. Code (but without regard to the last sentence thereof). Duties and Sec. 204. It shall be the duty and function of the Council— funotions. (1) to assist and advise the President in the preparation of the Environmental Quality Report required by section 201; (2) to gather timely and authoritative information concerning the conditions and trends in the quality of the environment both current and prospective, to analyze and interpret such informa-tion for the purpose of determining whether such conditions and trends are interfering, or are likely to interfere, with the achieve-ment of the policy set forth in title I of this Act, and to compile and submit to the President studies relating to such conditions and trends; (3) to review and appraise the various programs and activities of the Federal Government in the light of the policy set forth in title I of this Act for the purpose of determining the extent to which such programs and activities are contributing to the achievement of such policy, and to make recommendations to the President with respect thereto; (4) to develop and recommend to the President national poli-cies to foster and promote the improvement of environmental quality to meet the conservation, social, economic, health, and other requirements and goals of the Nation; (5) to conduct investigations, studies, surveys, research, and analyses relating to ecological svstems and environmental quality; (6) to document and define changes in the natural environment, including the plant and animal systems, and to accumulate neces-sary data and other information for a continuing analysis of these changes or trends and an interpretation of their underlying causes; (7) to report at least once each year to the President on the state and condition of the environment; and (8) to make and furnish such studies, reports thereon, and recommendations with respect to matters of policy and legisla-tion as the President may request Sec. 205. In exercising its powers, functions,, and duties under this Act, the Council shall— (1) consult with the Citizens'Advisory Committee on Environ-mental Quality established by Executive Order numbered 11472, 34 f . R. 8693. dated May 29, 1969, and with such representatives of science, industry, agriculture, labor, conservation organizations, State and local governments and other groups, as it deems advisable; and (2) utilize, to the fullest extent possible, the services, facilities, and information (including statistical information) of public and private agencies and organizations, and individuals, in order that duplication of effort and expense may be avoided, thus assuring that the Council's activities will not unnecessarily overlap or con-flict with similar activities authorized by law and performed by established agencies. - 196 -January 1, 1970 Pub. Law 91-190 83 STAT 856 Tenure and comDensation. 60 Stat. 460, 461. Sec. 206. Members of the Council shall serve full time and the Chairman of the Council shall be compensated at the rate provided for Level II of the Executive Schedule Pay Rates (5 U.S.C. 5313). The other members of the Council shall be compensated at the rate provided for Level IV or the Executive Schedule Pay Rates (5 U.S.C.6315). Seo. 207. There are authorized to be appropriated to carry out the Appropriations, provisions of this Act not to exceed $300,000 for fiscal year 1970, $700,000 for fiscal year 1971, and $1,000,000 for each fiscal year thereafter. Approved January 1, 1970. 81 Stat. 638. LEGISLATIVE HISTORY! HOUSE REPORTS! No. 91-378, 91-378, pt. 2,aooompanying H. R. 12549 (Comm. on Merohant Marine 4 Fisheries) and 91-765 (Cotmu of Conference). SENATE REPORT No. 91-296 (Comm. on Interior 4 Insular Affairs). CONGRESSIONAL RECORD, Vol. 115 (1969) I July 10i Considered and passed Senate. Sept.23i Considered and passed House, amended, in lieu of H. R, 12549. Oot. 8i Senate disagreed to House amendments) agreed to oonferenoe. Deo. 20i Senate agreed to oonferenoe report. Deo. 22i House agreed to oonferenoe report. • '0 *7.ttt - 197 -APPENDIX B GUIDELINES FOR THE PREPARATION OF ENVIRONMENTAL IMPACT STATEMENTS DEVELOPED BY THE U.S. COUNCIL ON ENVIRONMENTAL QUALITY - 198 -10856 COUNCIL ON ENVIRONMENTAL QUALITY [40 CFR Ch. V] PREPARATION OF ENVIRONMENTAL IMPACT STATEMENTS Proposed Guidelines The Council on Environmental Quality tnvites comments and suggestions from Interested parties with respect to the fol-lowing proposed revisions of the Coun-cil's guidelines on the preparation of en-vironmental "impact statements pursu-ant to section 102(2) (C) of the National Environmental Policy Act (NEPA) (42 XJJB.C. section 4332(2) (c)). The present guidelines, dated April 23,1971, are avail-able from the Council and appear at 36 FR 7724-7729. Comments should be sent to the Coun-cil on Environmental Quality, 722 Jack-son Place NW., Washington, D.C. 20006, on or before June 18,1973. After consideration of the comments and views of interested parties, the Council will make appropriate revisions and will codify these guidelines in final form In-the Code of Federal Regulations, establishing a new chapter 5 to title 40 of that Code. The proposed revisions and a section-by-section commentary follow: 1. Purpose and authority.—(a) This directive provides guidelines to Federal departments, agencies, and establish-ments for preparing detailed environ-mental statements on proposals for legislation and other major Federal ac-tions significantly affecting the quality of the human environment as required by section 102(2) (C) of the National En-vironmental Policy Act (Public Law 91-190, 42 US.C. sections 4321 et seq.) (hereafter "the Act"). Underlying the preparation of such environmental statements is the mandate of both the Act and Executive Order 11514 (35 FR 4247), of March 5, 1970, that all Federal agencies, to the fullest extent possible, direct their policies, plans, and programs so as to meet national environmental goals to encourage productive and enjoy-able harmony between man and his en-vironment, to promote efforts preventing or eliminating damage to the environ-ment and biosphere and stimulating the health and welfare of man, and to enrich the understanding of the ecological sys-tems and natural resources important to the Nation. The objective of section 102 (2) (C) of the Act and of these guide-lines is to build into the agency de-cisionmaking process, beginning at the earliest possible point, an appropriate and careful consideration of the environ-mental aspects of proposed action and to assist agencies in implementing the policies as well as the letter of the Act. This directive also provides guidance to Federal, State, and local agencies and the public in commenting on statements prepared under these guidelines. (b) Pursuant to section 204(3) of the Act the Council is assigned the duty and function of reviewing and appraising the programs and activities of the Federal PROPOSED RULES Government, In the light of the Act's policy, for the purpose of determining the extent to which such programs and acti-vities are contributing to the achieve-ment of such policy, and to make recom-mendations to the President with respect thereto. Section 102(2) (B) of the Act directs all Federal agencies to identify and develop methods and procedures, in consultation with the Council, to insure that unquantified environmental values be given appropriate consideration in decisionmaking along with economic and technical considerations; section 102(2) (C) of the Act directs that copies of all environmental impact statements be filed with the Council; and section 102(2) (H) directs all Federal agencies to assist the Council in the performance of its functions. These provisions have been supplemented in sections 3 (h) and (i) of Executive Order 11514 by directions that the Council issue guidelines to Fed-eral agencies for preparation of environ-mental impact statements and such other instructions to agencies and re-quests for reports and information as may be required to carry out the Council's responsibilities under the Act. 2. Policy.—As early as possible and In all cases prior to agency decision con-cerning recommendations or favorable reports on proposals for: (i) Legislation significantly affecting the quality of the human environment (see sees. 5(i) and 12, infra) (hereafter "legislative ac-tions") , and (ii) all other major Fed-eral actions significantly affecting the quality of the human environment (hereafter "administrative actions"). Federal agencies will, in consultation with other appropriate Federal, State, and local agencies, assess in detail the potential environmental impact. Initial assessments of the environmental im-pacts of proposed action should be under-taken concurrently with initial techni-cal and economic studies and, where re-quired, a draft environmental impact statement prepared and circulated for comment in time to accompany the pro-posal through the existing agency re-view processes for such action. In this process. Federal agencies shall: (i) Pro-vide for circulation of draft environ-mental statements to other Federal, State, and local agencies and for their availability to the public in accordance with the provisions of these guidelines; (ii) consider the comments of the agen-cies and the public; and (iii) issue final environmental impact statements re-sponsive to the comments received. The purpose of this assessment and consul-tation process is to provide agencies and other decisionmakers as well as members of the public with an under-standing of the potential environmental effects of proposed actions, to avoid or minimize adverse effects wherever pos-sible, and to restore or enhance environ-mental quality to the fullest extent prac-ticable. In particular, agencies should use the environmental impact statement process to explore alternative actions that will avoid or minimize adverse im-pacts and to evaluate both the long- and short-range implications of proposed actions to man, his physical and social surroundings, and to nature. Agenpies should consider the results of their en-vironmental assessments along with their assessments of the net economic, tech-nical, and other benefits of proposed actions and use all practicable means, consistent with other essential consid-erations of national policy, to avoid or minimize - undesirable consequences for the environment. 3. Agency and OMB procedures.—(a) Pursuant to section 2(f) of Executive Order 11514, the heads of Federal agen-cies have been directed to proceed with measures required by section 102(2) (C) of the Act. Previous guidelines of the Council on Environmental Quality di-rected each agency to establish its own formal procedures for: (1) Identifying those agency actions requiring environ-mental statements, the appropriate time prior to decision for the consultations re-quired by section 102(2) (C) and the agency review process for which environ-mental statements are to be available, (2) obtaining information required in their preparation, (3) designating the officials who are to be responsible for the statements, (4) consulting with and tak-ing account of the comments of appro-priate Federal, State, and local agencies, incl idiftg obtaining the comment of the Ad. .linistrator bf the Environmental Protection Agency when required under section 309 of the Clean Air Act, as amended, and (5) meeting the require-ments of section 2(b) of Executive Order 11514 for providing timely public infor-mation on Federal plans and programs with environmental impact. Each agency shall review the procedures it has estab-lished pursuant to the above directives and shall revise them, in consultation with the Council on Environmental Qual-ity, as may be necessary in order to re-spond to requirements imposed by these revised guidelines as well as by such previous directives. After such con-sultation, proposed revisions of such agency procedures shall be published in the Federal Register no later than 90 days after the date that these guidelines are published in final form. A minimum 45-day period for public comment shall be provided, fol-lowed by publication of final procedures no later than 45 days after the conclusion of the comment period. Each agency shall submit seven copies of all such pro-cedures to the Council on Environmental Quality. Any future revision of such agency procedures shall similarly be pro-posed and adopted only after prior con-sultation with the Council and, in the case of substantial revision, opportunity for public comment. (b) Each Federal agency should con-sult, with the assistance of the Council on Environmental Quality arid the Of-fice of Management and Budget if de^  sired, with other appropriate Federal agencies in the development and revi-sion of the above procedures so as to achieve consistency in dealing with similar activities and to assure effective f S U A l REGISTER, VOL 38, NO. 14—WEDNESDAY, MAY i, 197J - 199 — PROPOSED RULES coordination among agencies in their review oi proposed activities. Where ap-plicable, State and local review of such agency procedures should be conducted pursuant to procedures established by Office of Management and Budget Cir -cular No. A-85. For those revised agency procedures subject to O M B Circular No. A-85 a 30-day extension in the public comment period provided for in section 3(a) is granted. (c) Existing mechanisms for obtain-ing the views of Federal, State, and local agencies on proposed Federal actions should be utilized to the maximum ex-tent practicable in dealing with environ-mental matters. The Office of Manage-ment and Budget will issue instructions, as necessary, to take full advantage of such existing mechanisms. 4. Federal agencies included; effect of the Act cm existing agency mandates.— Section 102(2) (C) of the Act applies to all agencies of the Federal Government. Section 102 of the Act provides that "to the fullest extent possible: (1) The policies, regulations, and public laws of the United States shall be interpreted and administered in accordance with the policies set forth in this Act," and sec-tion 105 of the Act provides that "the policies and goals set forth in this Act are supplementary to those set forth in existing authorizations of Federal agen-cies." This means that each agency shall interpret the provisions of the Act as a • supplement to its existing authority and as a mandate to view traditional poli-cies and missions in the light of the Act's national environmental objectives. In accordance with this purpose, agencies should continue to review their policies, procedures, and regulations and to re-vise them as necessary to insure full compliance with the purposes and pro-visions of the Act. The phrase "to the fullest extent possible" in section 102 is meant to make clear that each agency of the Federal Government shall com-ply with that section unless existing law applicable to the agency's operations ex-pressly prohibits or makes compliance impossible. 5. Actions included.—"Actions" in -clude but are not limited to: (i) Recommendations or favorable reports relating to legislation including requests for appropriations. The require-ment for following the section 102(2) (C) procedure as elaborated in these guide-lines applies to both (i) agency recom-mendations on their own proposals for legislation (see section 12 infra); and (ii) agency reports on legislation initi-ated elsewhere. In the latter case only the agency which has primary responsi-bility for the subject matter involved will prepare an environmental statement. (ii) New and continuing projects and program. activities: directly undertaken by Federal agencies; or supported in whole or in part through Federal con-tracts, grants/subsidies, loans, or other forms of funding assistance (except where such assistance is solely in the form of general revenue sharing funds, distributed under the State and Local Fiscal Assistance Act of 1972, 31 UJS.C. FEDERAL section 1221 et seq. with no Federal agency control over the subsequent use of such funds); or involving a Federal lease, permit, license, certificate or other entitlement for use; (iii) The making, modification, or es-tablishment of regulations, rules, pro-cedures, and policy. 6. Identifying major actions signifi-cantly affecting the environment.—(a) The statutory clause "major Federal ac-tions significantly affecting the quality of the human environment" is to be con-strued by agencies with a view to the overall, cumulative impact of the action proposed (and of further actions con-templated). Such actions may be local-ized in their impact, but if there is poten-tial that the environment may be sigr nificantly affected, the statement is to be prepared. Proposed major actions, the environmental impact of which is likely to be highly controversial, should be cov-ered in all cases. In considering what constitutes major action significantly af-fecting the environment, agencies should bear in mind that the effect of many Federal decisions about a project or com-plex of projects can be individually l im-ited but cumulatively considerable. This can occur when one or more agencies over a period of years puts into a project individually minor but collectively major resources, when one decision involving a limited amount of money is a prece-dent for action in much larger cases or represents a decision in principle about a future major course of action, or when several Government agencies individu-ally make decisions about partial aspects of a major action. In all such cases, an environmental statement should be pre-pared if it is reasonable to anticipate a cumulatively significant impact on the environment from Federal action. The Council on Environmental Quality, on the basis of a written assessment of the impacts involved, is available to assist agencies in determining whether specific actions require impact statements. (b) Section 101(b) of the Act indi -cates the broad range of aspects of the environment to be surveyed in any as-sessment of significant effect. The Act also indicates that adverse significant effect. The Act also indicates that ad -verse significant effects include those that degrade the quality of the envi-ronment, curtail the range of bene-ficial uses of the environment, and serve short-term, to the disadvantage of long-term, environmental goals. Sig-nificant effects can also include actions which may have both. beneficial and detrimental effects, even if on balance the agency believes that the effect will be beneficial. Significant effects also in -clude secondary effects, as described more fully, for example in sec. 8(a) (ii) (B), infra. The significance of a proposed action may also vary with the setting, with the result that an action that would have little impact in an urban area may be significant in a rural setting or vice versa. While a precise definition of en-vironmental "significance," valid in all contexts, is not possible, effects to be considered in assessing significance i n -REGISTER, VOL. 38, NO. 84—WEDNESDAY, MAY elude, but are not limited, to those out-lined in appendix n of these guidelines. (c) Each of the provisions of the Act, except section 102(2) (C), applies to all Federal agency actions. Section 102(2) (C) requires the preparation of a de-tailed environmental impact statement in the case of "major Federal ac-tions significantly affecting the qual-ity of the human environment." The identification of major actions signifi-cantly affecting the environment is the responsibility of each Federal agency, to be carried out against the background of its own particular operations. The ac-tion must be (i) a "major" action, (ii) which is a "Federal action," (ill) which has a "significant" effect, and (iv) which involves the "quality of the human en -vironment." The words "major" and ' "significantly" are intended to imply thresholds of importance and impact that must be met before a statement is required. The action causing the impact must also be one where there is suffi-cient Federal control and responsibility to constitute "Federal action" in con-trast to cases where such Federal control and responsibility are not present as, for example, when Federal funds are dis-tributed in the form of general revenue sharing to be used by State and local governments (see sec. 5(H) supra). Finally, the action must be one that significantly affects the quality of the human environment either by directly affecting human beings or by indirectly affecting human beings through adverse effects on the environment. Each agency should review the typical classes of ac-tions that it undertakes and, In consul-tation with the Council on Environ-mental Quality, should develop specific criteria and methods for identifying those actions likely to require environ-mental statements and those actions likely not to require environmental statements. Normally this will involve: (i) Making an initial assessment of the environmental impacts typically as-sociated with principal types of agency action; (ii) Identifying on the basis of this assessment, types of actions which normally do, and types of actions which normally do not, require statements; (iii) With respect to remaining actions that may require statements depending on the circumstances, and those actions determined under the preceding para-graph (ii) as likely to require state-ments, identifying: (1) What basic i n -formation needs to be gathered; (2) how and when such information is to be as-sembled and analvzed; and (3) on what bases environmental assessments and decisions to prepare impact statements will be made. Agencies may either i n -clude this guidance in the procedures is-sued pursuant to section 3(a) of these guidelines, or issue such guidance as supplemental instructions to aid rele-vant agency personnel in implementing the impact statement process. Pursuant to section 15 of these guidelines, agencies 2, 1973 - 200 -shall report to the Council by Decem-ber 1, 1973, on the progress made in de-veloping such substantive guidance. (d) In determining when statements are required, agencies should give care-ful attention to identifying and defining the scope of the action which would most appropriately serve as the subject of the statement. In many cases, broad program statements will be desirable, assessing the environmental effects of a number of individual actions on a given geographi-cal area (e.g., coal leases), or environ-mental Impacts that are generic or com-mon to a series of agencv actions (e.g., harbor maintenance dredging), or the overall impact of a large-scale program or chain of contemplated projects (e.g., major lengths of highway as opposed to small segments), or the environmental implications of research activities that have reached a stage of investment or commitment to implementation likely to determine subsequent development or restrict later alternatives. Subsequent statements on major individual actions should be necessary only where such actions have significant environmental impacts not adequately evaluated in the program statement. 7. Procedures for preparing draft en-vironmental statements; hearings.—(a) In accord with the policy of the Act and Executive Order 11514 agencies have a responsibility to develop procedures to Insure the fullest practicable provision of timely public information and under-standing of Federal plans and programs with environmental impact in order to obtain the views of interested parties. In furtherance of this policy, agency proce-dures should include an aporopriate earlv notice system for informing the public of the decision to prepare a draft environ-mental statement on proposed adminis-trative actions (and for soliciting com-ments that may be helpful in preparing the statement) as soon as is practicable after the -decision to prepare the state-ment is made. In this connection, agen-cies should: (i) Maintain a list of ad-ministrative actions for which environ-mental statements are being prepared; (ii) revise the list at regular intervals specified in the agency's procedures de-veloped pursuant to section 3(a) of these guidelines; and (iii) make the list avail-able for public inspection on request. (b) Each environmental imoaet state-ment shall be prepared and circulated In draft form for comment in accordance with the provisions of these guidelines. (Where an agency has an established practice of declining to favor aa alter-native until public comments on a pro-posed action have been received, the draft environmental statement may in-dicate that two or more alternatives are under consideration.) Comments re-ceived shall be carefully evaluated and considered in the decision process. A final statement with substantive comments attached shall then be issued and cir-culated In accordance with aoplicable provisions of sections 10,11, or 12 of this directive. It is important that draft envi-ronmental statements be prepared and PROPOSED RULES circulated for comment and furnished to the Council as early as possible in the agency review process in order to permit agency decisionmakers and outside re-viewers to give meaningful consideration to the environmental issues involved. In particular, agencies should keep in mind that such statements are to serve as the means of assessing the environmental impact of proposed agency actions, rather than as a justification for decisions al -ready made. This means that draft state-ments on administrative actions should be prepared and circulated for comment prior to the first significant point of de-cision in the agency review process. For major categories of agency action, this point should be identified in the proce-dures issued pursuant to section 3(a). (c) Where more than one agency di-rectly sponsors an action, or is directly involved through funding, licenses, or permits, to the maximum extent possible one statement should serve as the means of compliance with section 102(2) (C) for all Federal action involved. Agencies in such cases should consider the possi-bility of joint preparation of a statement by all agencies concerned, or designa-tion of a single "lead agency" to as-sume supervisory responsibility for prep-aration of the statement. Where a lead agency prepares the statement, the other agencies involved should provide assist-ance with respect to their areas of juris-diction and expertise. In either case, the statement should contain an environ-mental assessment of the full range of Federal actions involved, should reflect the views of all participating agencies, and should be prepared before major or irreversible actions have been taken by any of the participating agencies: Fac-tors relevant in determining an appro-priate lead agency include the time se-quence in which the agencies become in-volved, the magnitude of their respective involvement, and their relative expertise with respect to the project's environ-mental effects. As necessary, the Council on Environmental Quality will assist in resolving questions of responsibility for statement preparation in the case of multiagency actions. (d) Where an agency relies on an ap-plicant to submit initial environmental information, the agency should assist the applicant by outlining the types of infor-mation required. In all cases, the agency should make its own evaluation of the environmental issues and take respon-sibility for the scope and content of draft and final environmental statements. (e) Agency procedures developed pur-suant to section 3(a) of these guidelines shall include provision for public hear-ings on actions with environmental im-pact whenever anpropriate. and for pro-viding the public with relevant infor-mation, including information on alter-native courses of action. In deciding whether a public hearing is appropriate, an agency should consider: (i) The magnitude of the proposal in terms of economic costs, the geographic area in-volved, and the uniqueness or size of commitment of the resources Involved; (il) the degree of Interest In the pro-posal, as evidenced by requests from the public and from Federal, State and local authorities that a hearing be held; (ill) the complexity of the issue and the like-lihood that information will be presented at the hearing which will be of .assist-ance to the agency in fulfilling its re-sponsibilities under the Act; (iv) the extent to which public involvement al-ready has been achieved through other means, such as earlier public hearings, meetings with citizen representatives, and/or written comments on the pro-posed action. Agency procedures should also indicate as explicitly as possible those types of agency decisions or ac-tions which utilize hearings as part of the normal agency review process, either as a result of statutory requirement or agency practice. Agencies should make any draft environmental statement available to the public at least 15 days prior to the time of such hearings. ' 8. Content of environmental state-ments.—(a) The following points are to be covered: (i) A description of the proposed action and of the environment affected. Includ-ing information, summary technical data, and maps and diagrams where relevant, adequate to permit an assess-ment of potential environmental impact by commenting agencies and the public. Highly technical and specialized analyses and data should be avoided in the body of the draft impact statement. Such ma-terials should be attached as appendices or footnoted with adequate bibliographic references. The statement should also succinctly describe the environment of the area affected as it exists prior to a proposed action. The amount of detail provided in such descriptions should be commensurate with the extent and ex-pected impact of the action, and with the amount of information required at the particular level of decisionmaking (planning, feasibility, design, etc.). In order to insure accurate descriptions and environmental assessments, site visits should be made where feasible. Agencies should also take care to identify, as appropriate, population and growth characteristics of the affected area and any population and growth assumptions used to justify the project or program or to determine secondary population and growth Impacts resulting from the proposed action and its alternatives (see par. (ii)(B), infra). In discussing these population aspects, agencies should give consideration to using the rates of growth in the region of the project con-tained in the projection compiled for the Water Resources Council by the Office of Business Economics of the De-partment of Commerce and the Eco-nomic Research Service of the Depart-ment of Agriculture (the OBERS pro-jection). In any event it is essential that the sources of. data used be identified. (ii) The probable Impact of the pro-posed action on the environment. (A) This requires agencies to assess the positive and negative effects of the KDERAl REGISTER, VOL. 38, NO. 84—WEDNESDAY, MAY J, 1973 - 201 - . PROPOSED RULES 10859 proposed action as it affects both the national and international environment. The attention given to different environ-mental factors will vary according to the nature, scale, and location of proposed actions. Among factors to consider should bo the potential effect of the action on such aspects of the environment as those listed in appendix H, of these guidelines. Primary attention should be given in the statement to discussing those factors most evidently impacted by the proposed action. (B) Secondary, as well as primary consequences for the environment should be included in the analysis. Many major Federal actions, in particular those that involve the construction or licensing of infrastructure investments (e.g., high-ways, airports, sewer systems, water re-source projects, etc.), stimulate or induce secondary effects in the form of asso-ciated investments and changed patterns of social and economic activities. Such secondary effects, through their impacts on existing community facilities and ac-tivities and through inducing new facil-ities and activities, may often be even more substantial than the primary effects of the original action itself. For example, the effects of the proposed ac-tion on population and growth may be among the more significant secondary effects. Such population and growth im-pacts should be estimated if expected to be significant (using data identified as indicated in section 8(a) (i), supra) and an assessment made of the effect of any possible change in population patterns or growth upon the resource base, in-cluding land use, water, and public serv-ices, of the area in question. (iii) Alternatives to the proposed ac-tion, including, where relevant, those not within the existing authority of the re-sponsible agency. (Section 102(2) (D) of the Act requires the responsible agency to "study, develop, and describe appro-priate alternatives to recommended courses of action in any proposal which involves unresolved conflicts concerning alternative uses of available resources"). A rigorous exploration and objective evaluation of the environmental impacts of all reasonable alternative*actions, par-ticularly those that might, avoid some or all of the adverse environmental effects, is essential. Sufficient analysis of such alternatives and their environmental costs and impact on the environment should accompany the proposed action through the agency review process in order not to foreclose prematurely op-tions which might have less detrimental effects. Examples of such alternatives in-clude: The alternative of taking no ac-tion or of postponing action pending further study; alternatives requiring ac-tions of a significantly different nature which would provide similar benefits with different environmental impacts (e.g., nonstructural alternatives to flood con-trol programs, or mass transit alterna-tives to highway construction) ; alterna-tives related to different designs or details of the proposed action which would present different environmental impacts (e.g., cooling ponds vs. cool-ing towers for a powerplant or alterna-tives that will significantly conserve energy). In each case, the analysis should be sufficiently detailed to permit com-parative evaluation of the environmental benefits, costs and risks of the proposed action and each reasonable alternative, provided, however, that where an exist-ing impact statement already contains such an analysis, its treatment of alter-natives may be incorporated. (iv) Any probable adverse environ-mental effects which cannot be avoided (such as water or air pollution, unde-sirable land use patterns, damage to life systems, urban congestion, threats to health, or other consequences adverse to the environmental goals set out in sec-tion 101(b) of the Act). This should be a brief section summarizing in one place those effects discussed in paragraph (ii) that are adverse and unavoidable under the proposed action. Included for pur-poses of contrast should be a clear state-ment of how other adverse effects dis-cussed in paragraph (ii) will be miti-gated to prevent apparent unavoidable consequences. (v) The relationship between local short-term uses of man's environment and the maintenance and enhancement of long-term productivity. This section should contain a brief discussion of the extent to which the proposed action in-volves tradeoffs between short-term en-vironmental gains at the expense of long-term losses, or vice versa. In this context short term and long term do not refer to any fixed time periods, but should be viewed ln terms of the envi-ronmentally significant consequences of the proposed action. (vi) Any irreversible and irretrievable commitments of resources that would be involved in the proposed action should it be Implemented. This requires the agency to identify from its survey of unavoid-able impacts in paragraph (iv) the ex-tent to which the action irreversibly cur-tails the range of potential uses of the environment. Agencies should avoid con-struing the term "resources" to mean only the labor and materials devoted to an action. "Resources" also means the natural and cultural resources commit-ted to loss or destruction by the action. (b) In developing the above points, agencies should make every effort to convey the required information suc-cinctly in a form easily understood, both by members of the public and by public decisionmakers, giving attention to the substance of the information conveyed rather than to the particular form, or length, or detail of the statement. Each of the above points, for example, need not always occupy a distinct section of the statement if it is otherwise ade-quately covered in discussing the impact of the proposed action and its alterna-tives—which items should normally ,be the focus of the statement. Draft state-ments should indicate at appropriate points in the text any underlying stud-ies, reports, and other information ob-tained and considered by the agency ln preparing the statement Including any cost-benefit analyses prepared by the agency. In the case of documents not likely to be easily accessible (such as In-ternal studies or reports), the agency should indicate how such information may be obtained. If such information Is attached to the statement, care should be taken to Insure that the statement remains an essentially self contained in-strument, capable of being understood by the reader without the need for undue cross reference. (c) Each environmental statement should be prepared in accordance with the precept in section 102(2) (A) of the Act that all agencies of the Federal Government, "utilize a systematic, in-terdisciplinary approach which will in-sure the integrated use of the natural and social sciences and the environmen-tal design arts in planning and decision-making which may have an impact on man's environment." Agencies should at-tempt to have relevant disciplines rep-resented on their own staffs; where this is not feasible they should make appro-priate use of relevant Federal, State, and local, agencies or the professional services of universities and outside con-sultants. The interdisciplinary approach should not be limited to the prepara-tion of. the environmental impact state-ment, but should also be used ln the early planning stages of the proposed action. Early application of such an ap-proach should help assure a systematic evaluation of reasonable alternative courses of action and their potential social, economic, and environmental consequences. (d) Appendix I prescribes the form of the summary sheet which should accom-pany each draft and final environmental statement. 9. Review of draft environmental im-pact statements by appropriate Federal, Federal-State, State, and local agencies and by public.—(a) Federal agency re-view.—In general. A Federal agency considering an action requiring an envi-ronmental statement should consult with, and (on the basis of a draft envi-ronmental statement for which the agency takes responsibility) obtain the comment on the environmental impact of the action of Federal and Federal-State agencies with jurisdiction by law or special expertise with respect to any environmental impact involved. These Federal and Federal-State agencies and their relevant areas of expertise include those identified in appendix n to these guidelines. It is recommended that the listed departments and agencies establish contact points, which may be regional offices, for providing comments on the environmental statements. The require-ment in section 102(2) (C) to obtain comment from Federal agencies having jurisdiction or special expertise ls in addition to any specific statutory obli-gation of any Federal agency to coordi-nate or consult with any other Federal or State agency. Agencies should, for FEDERAL REGISTER, VOL. 38, NO. 84—WEDNESDAY, MAY 3, 1973 - 202 -10860 example, be alert to consultation require-ments of the Pish and Wildlife Coordi-nation Act, 16 U.S.C. sections 661 et seq., and the National Historic Preservation Act of 1966, 16 U.S.C. sections 470 et seq. To the extent possible, statements or findings concerning environmental im-pact required by such other statutes, as in the case of section 4(f) of the Depart-ment of Transportation Act of 1966. 49 U.S.C. section 1653(f), or section 106 of the National Historic Preservation Act of 1966, should be combined with com-pliance with the environmental impact statement requirements of section 102 (2) (C) of the Act to yield a single doc-ument which meets all applicable re-quirements. The Advisory Council on Historic Preservation, the Department of Transportation, and the Department of the Interior, in consultation with the Council on Environmental Quality, will Issue any necessary supplementing in-structions for furnishing information or findings not forthcoming under the en-vironmental impact statement process. (b) EPA review under Clean Air Act.— Section 309 of the Clean Air Act. as amended (42 U.S.C. sec. 1857h-7), pro-vides that the Administrator of the En-vironmental Protection Agency shall comment In writing on the environ-mental impact of any matter relating to his duties and responsibilities, and shall refer to the Council on Environ-mental Quality any matter that the Ad-ministrator determines is unsatisfactory from the standpoint of public health or welfare1 or environmental quality. Ac-cordingly, wherever an agency action re-lated to air or water quality, noise abate-ment and control, pesticide regulation, solid waste disposal, generally applicable environmental radiation criteria and standards, or other provision of the au-thority of the Administrator is involved, Federal agencies are required to submit such proposed actions to the Administra-tor for review and comment in writing. In all cases where EPA determines that proposed agency action is environ-mentally unsatisfactory, or where EPA determines that an environmental state-ment Is so inadequate that such a de-termination cannot be made. EPA shall notify the Council on Environmental Quality as soon as practicable. The Ad-ministrator's comments shall constitute his comments for the purposes of both section 309 of the Clean Air Act and sec-tion 102(2) (C) of the National Environ-mental Policy Act. (c) State and local review.—Office of Management and Budget Circular No. A-95 (Revised) through its system of State and areawide clearinghouses pro-vides a means for securing the views of State and local environmental agencies, which can assist in the preparation and review of environmental impact state-ments. Current instructions for obtain-ing the views of such agencies are contained in the joint OMB-CEQ memo-randum attached to these guidelines as appendix UJ. A current listing of clear-inghouses is issued periodically by the Office of Management and Budget. PROPOSED RULES (d) Public review.—Agency procedures should make provision for facilitating the comment of public and private organiza-tions and individuals by announcing the availability of draft environmental state-ments and by making copies available to organizations and individuals that have requested an opportunity to comment. Agencies should devise methods for pub-licizing the existence of draft statements, for example, by publication in local news-papers or by maintaining a list of groups known to be interested in the agency's activities and directly notifying such groups of the existence of a draft state-ment, or sending them a copy, as soon as it has been prepared. (e) Responsibilities of commenting entities.—Agencies and members of the public submitting comments on proposed actions on the basis of draft environ-mental impact statements should en-deavor to make comments as specific, substantive, and factual as possible with-out undue attention to matters of form in the impact statement. Emphasis should be placed primarily on the assessment of the environmental impacts of the pro-posed action, and the acceptability of those Impacts on the quality of the en-vironment, particularly as contrasted with the impacts of reasonable alterna-tives to the action. Commenting entities may recommend modifications to the proposed action and/or new alternatives that will avoid or minimize environ-mental impacts. (f) Agencies seeking comment may establish time limits of not less than 45 days for reply, after which it may be pre-sumed, unless the agency or party con-sulted requests a specified extension of time, that the agency or party consulted has no comment to make. Agencies seek-ing comment should endeavor to comply with requests for extensions of time of up to 15 days. 10. Preparation and circulation of final environmental impact statements.—(a) Agencies should make every effort to discover and discuss all major points of view on the environmental effects of the proposed action and its alternatives in the draft statement itself. However, where opposing professional views and responsible opinion have been over-looked in the draft statement and are brought to the agency's attention through the commenting process, the agency should review the environmental effects of the action in light of those views and should make a meaningful reference in the final statement to the existence of any responsible opposing view not adequately discussed in the draft statement, indicating the agency's response to the issues raised. All sub-stantive comments received on the draft (or summaries thereof where response has been exceptionally voluminous) should be attached to the final statement, whether or not each such comment is thought to merit individual discussion by the agency in the text of the state-ment. (b) Copies of final statements, with comments attached, shall be sent to all Federal, State, and local agencies and private organizations that made sub-stantive comments on the draft state-ment and to individuals who requested a copy of the final statement. Where the number of comments on a draft state-ment is such that distribution of the final statement to all commenting en-tities appears impracticable, the agency shall consult with the Council concern-ing alternative arrangements for dis-tribution of the statement. 11. Distribution of statements to Coun-cil on Environmental Quality; minimum priods for review and advance availabil-ity; availability to public.—(a) As soon as they have been prepared, 10 copies of draft environmental statements, 5 copies of all comments made thereon (to be forwarded to the Council by the entity making comment at the time comment is forwarded to the responsible agency), and 10 copies of the final text of en-vironmental statements (together with the substance of all comments received • thereon by the responsible agency from Federal, State, and local agencies and, from private private organizations and individuals) shall be supplied to the Council on Environmental Quality in the Executive Office of the President (this will serve to meet the statutory require-ment to make environmental statements available to the President). At the same time that copies are sent to the Council, copies of final statements should also be sent to relevant commenting entities as set forth in section 10(b) of these guidelines. (b) To'the maximum extent practi-cable no administrative action subject to section 102(2) (C) is to be taken sooner than 90 days after a draft environmental statement has been circulated for com-ment, furnished to the Council and, ex-cept where advance public disclosure will result in significantly increased costs of procurement to the Government, made available to the public pursuant to these guidelines; neither should such adminis-trative action be taken sooner than 30 days after the final text of an environ-mental statement (together with com-ments) has been made available to the Council, commenting agencies, and the public. If the final text of an environ-mental statement is filed within 90 days after a draft statement has been circu-lated for comment, furnished to the Council and made public pursuant to this section of these guidelines, the 30-day period and 90-day period may run con-currently to the extent that they overlap. An agency may supplement or amend a draft or final environmental statement. In such cases the agency should consult with the Council on Enviromental Qual-ity with respect to the possible need for or desirability of recirculation of the statement for the appropriate period. (c) The Council will publish weekly In the Federal Register lists of environ--mental statements received during the preceding week that are available for public comment. The date of receipt by the Council, as noted In the Federal Reg-xstr publication, shall be the date from FEDERAL REGISTER, VOL. 38, NO. 84—WEDNESDAY, MAY J, 1973 PROPOSED RULES which the minimum periods for review and advance availability of statements shall be calculated. • (d) The Council', publication of no-tice of the availability of statements is in addition to the agency's responsibility, as described in section 9(d) of these guidelines, to insure the fullest practica-ble provision of timely public informa-tion concerning the existence and avail-ability of environmental statements. The agency responsible for the environmental statement is also responsible for making the statement, the comments received, and any underlying documents available to the public pursuant to the provisions of the Freedom of Information Act (5 U.S.C., sec. 552), without regard to the exclusion of intragency or interagency memoranda when such memoranda transmit comments of Federal agencies on the environmental impact of the pro-posed action pursuant to section 9 of these guidelines. Agency procedures pre-pared pursuant to section 3(a) of these guidelines shall implement these public information requirements and shall in-clude arrangements for availability of environmental statements and comments at the head and appropriate regional offices of the responsible agency and at appropriate State, regional, and metro-politan clearinghouses unless the Gov-ernor of the State involved designates some other point for receipt of this in-formation. Notice of such designation of an alternate point for receipt of this in-formation shall be included in the Office •of Management and Budget listing of clearinghouses referred to in section 9(c). <e) Where emergency circumstances make it necessary to take an action with significant environmental impact with-out observing the provisions of these guidelines concerning minimum periods for agency review and advance availabil-ity of environmental statements, the Federal agency proposing to take the ac-tion should consult with the Council on Environmental Quality about alternative arrangements. Similarly where there are overriding considerations of expense to the government or impaired program ef-fectiveness, the responsible agency should consult with the Council concern-ing appropriate modifications of the minimum periods. (f) In order to assist the Council on Environmental Quality in fulfilling its responsibilities under the Act and under .Executive Order 11514, all agencies shall (as required by Section 102(2) (H) of the Act and section 3(i) of Executive Order 11514) be responsive to requests by the Council for reports and other informa-tion dealing with issues arising in con-nection with the implementation of the Act. In particular, agencies shall be re-sponsive to requests by the Council for either the preparation and circulation of environmental statements or, in the al-ternative, if the responsible agency deter-mines that an environmental statement is not required, for an environmental assessment and a publicly available rec-ord briefly setting forth the reasons for that determination. In no case, how-ever, shall the Council's silence or failure to request action with respect to an environmental statement be construed as bearing in any way on the question of the legal requirement for or the adequacy of such statements under the Act. 12. Legislative actions.—(a) The Council on Environmental Quality and the Office of Management and Budget will cooperate in giving guidance as needed to assist.agencies in identifying legislative items believed to have en-vironmental significance. Efforts shall be made to identify types of repetitive legis-lation requiring environmental impact statements (such as certain types of bills affecting transportation policy or annual construction authorizations) to assure preparation of impact statements prior to submission of such legislative pro-posals to the Office of Management and Budget. (b) With respect to recommendations or reports on proposals for legislation to which section 102(2) (C) applies, the final text of the environmental state-ment and comments thereon should be available to the Congress and to the pub-lic for consideration in connection with the proposed legislation or report. In cases where the scheduling of congres-sional hearings on recommendations or reports on proposals for legislation which the Federal agency has forwarded to the Congress does not allow adequate time for the completion of a final text of an environmental statement (together with comments), a draft environmental state-ment may be furnished to the Congress and made available to the public pend-ing transmittal of the comments as re-ceived and the final text. 13. Application of section 102(2) (C) procedure to existing projects and pro-grams.—The section 102(2) (C) proce-dure shall be applied to further major Federal actions having a significant effect on the environment even though they arise from projects or programs initiated prior to enactment of the Act on January 1, 1970. While the status of the work and degree of completion may be considered in determining whether to proceed with the project, it is essential that the environmental impacts of pro-ceeding are reassessed pursuant to the Act's policies and procedures and, if the project or program is continued, that further incremental major actions be shaped so as to minimize adverse en-vironmental consequences. It is also im-portant in further action that account be taken of environmental consequences not fully evaluated at the outset of the project or program. 14. Supplementary guidelines, evalua-tions of procedures.—(a) The Council on Environmental Quality after exam-ining environmental statements and agency procedures with respect to such statements will issue such supplements to these guidelines as are necessary. (b) Agencies will continue to assess their experience in the implementation of the section 102(2) (C) provisions of the Act and in conforming with these guidelines and report thereon to the Council on Environmental Quality by December 1, 1973. Such reports should include an identification of the problem areas and suggestions for revision or clarification of these guidelines to achieve effective coordination of views on environmental aspects (and alterna-tives, where appropriate) of proposed actions without imposing unproductive administrative procedures. Such reports shall also indicate what progress the agency has made in developing substan-tive criteria and guidance for making en-vironmental assessments as required by section 6(c) of this directive and by sec-tion 102(2) (B) of the Act. 15. Effective date.—The revisions of these guidelines shall apply to all draft and final impact statements filed with the Council more than 90 days after the publication of this directive in final form in the FEDERAL REGISTER. R U S S E L L E. TRAIN, Chairman. APPENDIX I (Check one) ( ) Draft. ( ) Final Environmental Statement. Name of Responsible Federal Agency (with name of operating division where appropri-ate). 1. Name of Action. (Check one) ( ) Administrative Action. ( ) Legislative Action. 2. Brief description of action Indicating what States (and counties) particularly affected. 3. Summary of environmental Impact and adverse environmental effects.' 4. List alternatives considered. 5. a. (For draft statements) List all Fed-eral, State, and local agencies from which comments have been requested. b. (For final statements) List all Federal, State, and local agencies and other sources from which written comments have been received. 6. Dates draft statement and final state-ment made available to Council on Environ-mental Quality and public. APPENDIX II—FEDERAL AGENCIES AND FEDERAL STATE AGENCIES 1 WITH JOTUSDICTION BY LAW OR SPECIAL EXPERTISE TO COMMENT ON VASIOOS TTPES OP ENVIRONMENTAL IMPACTS Am Air Quality and Air Pollution Control Department of Agriculture-^ Forest Service (effects on vegetation). Atomic Energy Commission (radioactive substances). Department of Health, Education, and Wel-fare (Health aspects). Environmental Protection Agency— Air Pollution Control Office. Department of the Interior— Bureau of Mines (fossil and gaseous fuel combustion). Bureau of Sport Fisheries and Wildlife (wildlife). National Aeronautics and Space Administra-tion (remote sensing, aircraft emissions). 'River Basin Commissions (Delaware, Great Lakes. Missouri. New England, Ohio, Pacific Northwest, Sourts-Bed-Balny, Sus-quehanna, Upper Mississippi) and similar Federal-State agencies should be consulted on actions affecting the environment of their specific geographic Jurisdictions. FEDERAL REGISTER, VOL. 38, NO. 84—WEDNESDAY, MAY 3, 1973 - 204 -10862 Deportment of Transportation—. Assistant Secretary for Systems Develop-ment and Technology (auto emissions). Coast Guard (vessel emissions). Federal Aviation Administration (alrcralt emissions). Weather Modification Department of Commerce— National Oceanic and Atmospheric Ad-ministration. Department of Defense— Department of the Air Force. Department of the Interior— Bureau of Reclamation. Water Resources Council. ENERGY Energy Conservation Department of the Interior— Office of Energy Conservation. Department of Commerce— National Bureau of Standards (energy ef-ficiency) . Department of Housing and Urban Develop-ment— Federal Housing Administration (energy conservation in housing standards). General Services Administration (energy conservation In design and operation of buildings). Environmental Aspects of Electric Energy Generation and Transmission Atomic Energy Commission (nuclear power). Environmental Protection Agency-Water Quality Office. Air Pollution Control Office. Department of Agriculture— Rural Electrification Administration (rural areas). Department of Defense— Army Corps of Engineers (hydro-facllltles). Federal Power Commission (hydro-facllltles and transmission lines). Department of Housing and Urban Develop-ment (urban areas). Department of the Interior—(facilities on Government lands). National Aeronautics and Space Administra-tion (solar). Water Resources Council. River Basins Commissions (as geographically appropriate). Natural Gas Energy Development, Transmission and Generation Federal Power Commission (natural gas pro-duction, transmission and supply). Department of the Interior— Geological Survey. Bureau of Mines. HAZARDOUS SUBSTANCES Toxic Materials Atomic Energy Commission (radioactive sub-stances) . Department of Commerce— National Oceanic and Atmospheric Admin-istration. Department of Health, Education, and Wel-fare (Health aspects). Environmental Protection Agency: Department of Agriculture— Agricultural Research Service. Consumer and Marketing Service.. Department of Defense. Department of the Interior-Bureau of Sport Fisheries and Wildlife. Pesticides Department of Agriculture— Agricultural Research Service (biological controls, food and fiber production). Consumer and Marketing Service. Forest Service., PROPOSED RULES Department of Commerce-National Marine Fisheries Service. National Oceanic and Atmospheric Admin-istration. Environmental Protection Agency— Office of Pesticides. Department of the Interior— Bureau of Sport Fisheries and Wildlife (effects on fish and wildlife). Bureau of Land Management. Department of Health, Education, and Wel-fare (Health aspects). Herbicides Department of Agriculture— Agricultural Research Service. Forest Service. Environmental Protection Agency— Office of Pesticides. Department of Health, Education, and Wel-fare (Health aspects). Department of the Interior— Bureau of Sport Fisheries and Wildlife. Bureau of Land Management. Bureau of Reclamation. Transportation and Handling of Hazardous Materials Department of Commerce— Maritime Administration. National Marine Fisheries Service. National Oceanic and Atmospheric Admin-istration (impact on marine life). Department of Defense— Armed Services Explosive Safety Board. Army Corps of Engineers (navigable water-ways) . Department of Health, Education, and Wel-fare-Office of the Surgeon General (Health as-pects). Department of Transportation— Federal Highway Administration. Bureau of Motor Carrier Safety. Coast Guard. Federal Railroad Administration. Federal Aviation Administration. Assistant Secretary for Systems Develop-ment and Technology. Office of Hazardous Materials. Office of Pipeline Safety. Environmental Protection Agency (hazardous substances). Atomic Energy Commission (radioactive substances). LAND TJSK AND MANAGEMENT Esthetics' Coastal Areas: Wetlands, Estuaries, Water-fowl Refuges, and Beaches Department of Agriculture—• Forest Service. Department of Commerce— National Marine Fisheries Service (Impact on marine life). National Oceanic and Atmospheric Admin-istration (Impact on marine life). Department of Transportation.— Coast Guard (bridges, navigation). Department of Defense— Army Corps of Engineers (beaches, dredge and fill permits, Refuse Act permits). Department of the Interior— Bureau of Sport Fisheries and Wildlife. National Park Service. VS. Geological Survey (coastal geology). Bureau of Outdoor Recreation (beaches). Department of Agriculture— Boll Conservation Service (soli stability, hydrology). • Numerous agencies have developed spe-cific methods of assessing esthetics In rela-tion to their area of responsibility. Environmental Protection Agency-Water Quality Office. National Aeronautics and Space Administra-tion (remote sensing). Water Resources Council. River Basin Commissions (as geographically appropriate). Historic and Archeological Sites Department of the Interior— National Park Service. Advisory Council on Historic Preservation. Department of Housing and Urban Develop-ment (urban areas). Flood Plains and Watersheds Department of Agriculture— Agricultural Stabilization and Research Service. Soli Conservation Service. Forest Service. Department of the Interior— Bureau of Outdoor Recreation. Bureau of Reclamation. Bureau of Sport Fisheries and Wildlife. Bureau of Land Measurement. VS. Geological Survey. Department of Housing and Urban Develop-ment (urban areas). Department of Defense-Army Corps of Engineers. Water Resources Council. River Basins Commissions (as geographically appropriate). Mineral Land Reclamation Appalachian Regional Commission. Department of Agriculture— Forest Service. Department of the Interior— Bureau of Mines. Bureau of Outdoor Recreation. Bureau of Sport Fisheries and Wildlife. Bureau of Land Management. VS. Geological Survey. Tennessee Valley Authority. Parks, Forests, and Outdoor Recreation Department of Agriculture— Forest Service. Soil Conservation Service. Department of the Interior-Bureau of Land Management. National Park Service. Bureau of Outdoor Recreation. Bureau of Sport Fisheries and Wildlife. Department of Defense— Army Corps of Engineers. Department of Housing and Urban Develop-ment (urban areas). Water Resources Council. River Basins Commissions (as geographically appropriate). Soil and Plant Life, Sedimentation, Erosion and Hydrologic Conditions Department of Agriculture— Soli Conservation Service. Agricultural Research Service. Forest Service. Department of Defense-Army Corps of Engineers (dredging, aquatic plants). Department of Commerce— National Oceanic and Atmospheric Admin-istration. Department of the Interior— Bureau of Land Management. Bureau of Sport Fisheries and. Wildlife. Geological Survey. Bureau of Reclamation. Water Resources Council. River Basins commissions (as geographically appropriate). NOISX Hoise Control and Abatement Department of Health, Education, and Wel-fare (Health aspects). FEDERAL REGISTER, VOL 33, NO. 34—WEDNESDAY, MAY 3, 1973 - 205 -rKOPOSED RULES Department of Commerce-National Bureau of Standards. Department of Transportation— Assistant Secretary for Systems Develop-ment and Technology. Federal Aviation Administration (Office of Noise Abatement). Environmental Protection Agency (Office of Noise). Department of Housing and Urban Develop-ment (urban land use aspects, building materials standards). National Aeronautics and Space Administra-tion (aircraft noise abatement and con-trol). PHYSIOLOGICAL HEALTH AND HUMAN WELL BEING Chemical Contamination of Food Products Department of Agriculture— Consumer and Marketing Service. Department of Health, Education, and Wel-fare (health aspects). Environmental Protection Agency— Office of Pesticides (economic poisons). Food Additives and Food Sanitation Department of Health. Education, and Wel-fare (Health aspects). Environmental Protection Agency— Office of Pesticides (economic.poisons, e.g., pesticide residues). Department of Agriculture— Consumer and Marketing Service (meat and poultry products). Microbiological Contamination Department of Health, Education, and Wel-fare (Health aspects). Radiation and Radiological Health Department of Commerce— National Bureau of Standards. Atomic Energy Commission. Environmental Protection Agency— Office of Radiation. Department of the Interior— Bureau of Mines (uranium mines). Sanitation and Waste Systems Atomic Energy Commission (radioactive waste). Department of Health, Education, and Wel-fare—(Health aspects). Department of Defense— Army Corps of Engineers. Environmental Protection Agency— Solid Waste Office. Water Quality Office. Department of Transportation— U.S. Coast Guard (ship sanitation). Department of the Interior— Bureau of Mines (mineral waste and re-cycling, mine acid wastes, urban solid wastes). Bureau of Land Management (solid wastes on public lands). Office of Saline Water (demlnerallzatlon of liquid wastes). Water Resources Council. River Basins Commissions (as geograph-ically appropriate). Shellfish Sanitation Department of Commerce— National Marine Fisheries Service. National Oceanic and Atmospheric Admin-istration. Department of Health. Education, and Wel-fare (Health aspects). Environmental Protection Agency— Office of Water Quality. TRANSPORTATION Air Quality Environmental Protection Agency— Air Pollution Control Office. Department of Transportation— Federal Aviation Administration. Department of the Interior— Bureau of Outdoor Recreation. Bureau of Sport Fisheries and Wildlife. Department of Commerce— National Oceanic and Atmospheric Admin-istration (meteorological conditions). National Aeronautics and Space Administra-tion (aviation). Water Quality Environmental Protection Agency— Office of Water Quality. Department of the Interior— Bureau of Sport Fisheries and Wildlife. Department of Commerce— National Oceanic and Atmospheric Admin-istration (impact on marine life and ocean monitoring). Department of Defense— Army Corps of Engineers. Department of Transportation— Coast Guard. Water Resources Council. ! URBAN Congestion in Urban Areas, Housing and Building Displacement Department of Transportation— Federal Highway Administration. Office of Economic Opportunity. Department of Housing and Urban Develop-ment. Department of the Interior— Bureau of Outdoor Recreation. Enuironmental Effects With Special Impact in Low-Income Neighborhoods Department of the Interior— National Park Service. Office of Economic Opportunity. Department of Housing and Urban Develop-ment (urban areas). Department of Commerce (economic develop-ment areas). Economic Development Administration. Department of Transportation— Urban Mass Transportation Administration. Water Resources Council. River Basins Commissions (as geographically appropriate). Rodent Control Department of Health, Education, and Wel-fare (health aspects). Department of Housing and Urban Develop-ment (urban areas). Urban Planning! Department of Transportation— Federal Highway Administration. Department of Housing and Urban Develop-ment. Environmental Protection Agency. Department of the Interior— Geological Survey. Bureau of Outdoor Recreation. Department of Commerce— Economic Development Administration. Water Resources Council. River Basins Commissions (as geographically appropriate). WATER Water Quality and Water Pollution Control Department of Agriculture-Soil Conservation Service. Forest Service. Atomic Energy Commission (Radioactive substances). Department of the Interior— Bureau of Reclamation. Bureau of Land Management. Bureau of Sports Fisheries and Wildlife. Bureau of Outdoor Recreation. Geological Survey. Office of Saline Water. Environmental Protection Agency-Water Quality Office. Department of Health, Education, and Wel-fare (Health aspects). Department of Defense— Army Corps of Engineers. Department of the Navy (ship pollution control). National Aeronautics and Space Administra-tion (remote sensing). Department of Transportation— Coast Guard (oU spills, ship sanitation). Department of Commerce— National Oceanic and Atmospheric Admin-istration Water Resources Council. River Basins Commissions (as geograph-ically appropriate). Marine Pollution Department of Commerce— National Oceanic and Atmospheric Admin-istration. Department of Transportation— Coast Guard. Department of Defense-Army Corps of Engineers. Office of Oceanographer of the Navy. Water Resources Council. River Basins Commissions (as geographically appropriate). River and Canal Regulation and Stream Channelization Department of Agriculture— SoU Conservation Service. Department of Defense— Army Corps of Engineers. Department of the Interior— Bureau of Reclamation. Geological Survey. Bureau of Sport Fisheries and WUdllfe. Department of Transportation— Coast Guard. Water Resources CouncU. River Basins Commissions (as geographically appropriate). WILDLIFE Environmental Protection Agency. Department of Agriculture— Forest Service. SoU Conservation Service. Department of the Interior*— Bureau of Sport Fisheries and Wildlife. Bureau of Land Management. Bureau of Outdoor Recreation. . Water Resources CouncU. River Basins Commissions (as geographically appropriate). FEDERAL AGENCY AND FEDERAL-STATE AGENCY Orncts FOR RECEIVING AND COORDINATING COMMENTS UPON ENVIRONMENTAL IMPACT STATEMENTS ADVISORY COUNCIL ON HISTORIC PRESERVATION Office of the Executive Director, suite 618, 801 19th Street NW., Washington, D.C. 20006, 343-8607. DEPARTMENT OF AGRICULTURE Office of the Secretary, Washington, D.C. 20250. 447-7803. APPALACHIAN REGIONAL COMMISSION Office of the Alternate Federal Co-Chairman, 1666 Connecticut Avenue NW., Washington, D.C. 20235. 967-1103. DEPARTMENT OF T H E ARMY (CORPS OF ENGINEERS) Executive Director of Civil Works, 'Office of the Chief of Engineers, Washington, D,C. 20314. 693-7168. ATOMIC ENERGY COMMISSION For nonregulatory matters: Director, Office of Environmental Affairs. Washington, D.C. 20545, 873-6391. Ko. 84—Ft. II 2 FEDERAL REGISTER, VOL. 38, NO. 84—WEDNESDAY, MAY 3, 1973 - 206 -10864 For regulatory matters: Office of the Assist-ant Director for Regulation, Washington, : D.O. 20546, 973-7531. DEPARTMENT OF COMMERCE Office of the Deputy Assistant Secretary for Environmental Affairs, Washington, D.C. 30330, 967-4335. DEPARTMENT OP DEFENSE Office of the Assistant Secretary for Defense (Health and Environment), Room 3E172, the Pentagon, Washington, D.C. 20301, 697-3111; DELAWARE SZVEB BASIN COMMISSION Office of the Secretary, P.O. Box 360, Trenton, NJ. 08603, 609-883-9600. ENVIRONMENTAL PROTECTION AGENCY * Director, Office of Federal Activities, Environ-mental Protection Agency, 401 M Street NW., Washington, D.C. 20460, 755-0777. FEDERAL POWER COMMISSION Commission's Advisor on Environmental Quality, 441 O Street NW., Washington, D.C. 20426, 386-6084. » Contact the Office of Federal Activities for environmental statements concerning legisla-tion, regulations, national program proposals or other major policy Issues. For all other EPA consultation, contact the Regional Administrator ln whose area the proposed action (e.g., highway or water re-source construction projects) will take place. The Regional Administrators will coordinate the EPA review. Addresses of the Regional Administrators, and the areas covered by their regions are as follows: Regional Administrator I, Room 2303, John F. Kennedy Federal Building, Boston, Mass. 02203, 617-223-7210; Connecticut, Maine, Massachusetts, New Hampshire, Rhode Is-land, Vermont. Regional Administrator n, Room 908,26 Fed-eral Plaza, New York, N.Y. 10007, 212-264-3625; New Jersey, New York, Puerto Rico, Virgin Islands. Regional Administrator IH, Curtis Building, Sixth Floor, Sixth and Walnut Streets, Philadelphia, Pa. 19106, 215-697-9801; Delaware, Maryland, Pennsylvania, Vir-ginia, West Virginia, District of Columbia. Regional Administrator IV, Suite 300, 1421 Peachtree Street NE., Atlanta, Ga. 30309, 404-526-5727; Alabama, Florida, Georgia, Kentucky, Mississippi. North Carolina, South Carolina. Tennessee. Regional Administrator V. 1 North Wacker Drive, Chicago, 111. 60606, 312-353-6250; Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin. Regional Administrator VI, 1600 Patterson Street, Suite 1100. Dallas. Tex. 75201, 214-749-1962; Arkansas. Louisiana, New Mex-ico, Texas, Oklahoma. Regional Administrator VII, 1735 Baltimore Avenue, Kansas City. Mo. 64108. 816-374-6493; Iowa, Kansas, Missouri, Nebraska. Regional Administrator VLTI, Suite 900, Lin-coln Tower, 1860 Lincoln Street, Denver, Colo. 80203, 303-837-3895; Colorado, Mon-tana, North Dakota, South Dakota, Utah, Wyoming. Regional Administrator IX, 100 California Street, San Francisco, Calif. 94111, 415-656-2320: Arizona, California. Hawaii, Ne-vada, American Samoa, Guam. Trust Ter-ritories of Pacific Islands, Wake Island. Regional Administrator X, 1200 Sixth Ave-nue. Seattle, Wash. 98101, 206-442-1220; Alaska, Idaho. Oregon, Washington. PROPOSED RULES GENERAL SERVICES ADMINISTRATION Office of Environmental Affairs, Office of the Commissioner, Public Buildings Service, Washington. D.C. 20405, 343-4193. GREAT L A K E S BASIN COMMISSION Office of the Chairman, 3475 Summit Road, Ann Arbor, Mich. 48106, 313-769-7431. DEPARTMENT OF H E A L T H , EDUCATION, AND WELFARE Office of Environmental Affairs, Office of the Assistant Secretary for Community and Field Services, Washington, D.C. 20202, 963-5896. DEPARTMENT OP HOTTSINO AND OBBAN DEVELOPMENT 4 Director, Office of Community and Environ-mental Standards, room 7206, Washington, D.C. 20410, 755-5977. DEPARTMENT OF T H E INTERIOR Office of the Deputy Assistant Secretary for Programs, .Washington, D.C. 20240, 343-6181. MISSOURI RIVER BASINS COMMISSION Office of the Chairman, 10050 Regency Cir-\ cle, Omaha, Nebr. 68114, 402-397-6714. I NATIONAL CAPITAL PLANNING COMMISSION Office of the Executive Director, Washington, D.C. 20576, 3B2-1163. NEW ENGLAND RIVER BASINS COMMISSION Office of the Chairman, 55 Court Street, Bos-ton, Mass. 02108. 617-223-6244. . contact the Director with regard to en-vironmental impacts of legislation, policy statements, program regulations and proce-dures, and precedent-making project deci-sions. For all other HUD consultation, con-tact the HUD Regional Administrator ln whose Jurisdiction the project lies, aa fol-lows: Regional Administrator I, Environmental Clearance Officer, room 405, John F. Ken-nedy Federal Building, Boston, Mass. 02203, 617-223-4066. Regional Administrator II, Environmental Clearance Officer, 26 Federal Plaza, New York, N.Y. 10007, 212-264-8068. Regional Administrator III, Environmental Clearance Officer, Curtis Building, Sixth and Walnut Streets, Philadelphia, Pa. 19106, 216-597-2560. Regional Administrator IV, Environmental Clearance Officer, Peachtree-Seventh Build-ing, Atlanta, Ga. 30323, 404-626-5585. Regional Administrator V, Environmental Clearance Officer, 360 North Michigan Ave-nue, Chicago, III. 60601, 312-353-6680. Regional Administrator VI, Environmental Clearance Officer. Federal Office Building, 819 Taylor Street, Fort Worth. Tex. 76102. 817-334-2867. Regional Administrator VII, Environmental Clearance Officer, 911 Walnut Street, Kan-sas City. Mo. 64108, 816-374-2661. Regional Administrator VIH, Environmental Clearance Officer, Samsonlte Building, 1051 South Broadway, Denver, Colo. 80209, 303-837-4061. Regional Administrator IX, Environmental Clearance Officer, 450 Golden Gate Avenue, P.O. Box 36003, San Francisco, Calif., 94102, 416-656-4752. Regional Administrator X, Environmental Clearance Officer, room 226, Arcade Plaza Building, Seattle. Wash. 98101, 206-583-6415. OFFICE OF ECONOMIC O P P O l l O N l T l Office of the Director, 1200 19th Street NW, Washington. D.C. 20506, 254-6000. ' OHIO RIVER BASIN COMMISSION ' Office of the Chairman, 36 East 4th Street, suite 208-20, Cincinnati, Ohio 45303, 813-684-3831. PACIFIC NORTHWEST RIVER BASINS COMMISSION Office of the Chairman, l Columbia River, Vancouver, Wash. 98660. 206-695-3606. B0UBI3-RED-RAINY RIVER BASINS COMMISSION Office of the Chairman, suite 6. Professional Building, Holiday Mall, Moprhead, Minn. 66560, 701-237-6227. DEPARTMENT OF R A T S Office of the Special Assistant to the Sec-retary for Environmental Affairs, Washing-ton, D.C. 20520, 632-7964. SUSQUEHANA RIVER BASIN COMMISSION Office of the Water Resources Coordinator, Department of Environmental Resources, 106 South Office, Building, Harrisburg, Pa. 17120. 717-787-2315. TENNESSEE VALLEY AUTHORITY Office of the Director of Environmental Re-search and Development, 720 Edney Build-ing, Chattanooga, Tenn. 37401, 616-766-3003. DEPARTMENT OF TRANSPORTATION Office of the Assistant Secretary for Environ-ment, Safety, and Consumer Affairs, Wash-ington, D.C. 30690, 426-4474. DEPARTMENT OF TREASURY Office of Assistant Secretary for Administra-tion, Washington, D.C. 20220, 964-6391. UPPER MISSISSIPPI RIVES BASIN COMMISSION Office of the Chairman, Federal Office Build-ing. Fort Snelllng. Twin Cities, Minn. 55111, 613-735-4690. WATER RESOURCES COUNCIL Office of the Associate Director, 3120 L Street NW., suite 800. Washington, D.C. 30037, 254-6443. APPENDIX HI—STATE AND LOCAL AGENCY REVIEW or IMPACT STATEMENTS 1. OBM Circular No. A-95 through Its sys-tem of clearinghouses provides a means for securing the views of State and local en-vironmental agencies, which can assist ln the preparation of Impact statements. Under A-95, review of the proposed project ln the case of federally assisted projects (part I of A-S5) generally takes place prior to the prep-aration of the Impact statement. Therefore, comments on the environmental - effects of the proposed project that are secured during this stage of the A-95 process represent In-puts to thj environmental impact statement. 2. In the case of direct Federal develop-ment (part n of A-95), Federal agencies are required to consult with clearinghouses at the earliest practicable time ln the planning of the project or activity. Where such con-sultation occurs prior to completion of the draft impact statement, comments relating to the environmental effects of the proposed action would also represent Inputs to the en-vironmental Impact statement. 3. In either case, whatever comments are made on environmental effects of proposed Federal or federally assisted projects by clear-inghouses, or by State and local environ-FEDERAl. IEOISTR. VOL 38, NO. 84—WEDNESDAY, MAY X 1W1 PROP RULES mental agencies through clearinghouses, In the course of the A-95 review shoald be at-tached to the draft impact statement when It is circulated for review. Copies of the state-ment should be sent to the agencies making such comments. Whether those agencies then elect to comment again on the basis of the draft Impact statement Is a matter to be left to the discretion of the commenting agency depending on its resources, the significance of the project, and the extent to which its earlier comments were considered in pre-paring the draft statement. 4. The clearinghouses may also be used, by mutual agreement, for securing reviews of the draft environmental Impact statement. However, the Federal agency may wisb to deal directly with appropriate State or local agen-cies in the review of impact statements be-cause the clearinghouses may be unwilling or unable to handle this phase of the process. In some cases, the Governor may have des-ignated a specific agency, other than the clearinghouse, for securing reviews of Im-pact statements. In any case, the clearing-houses should be sent copies of the impact statement. 6. To aid clearinghouses In coordinating State and local comments, draft statements should include copies of State and local agency comments made earlier under the A-95 process and should Indicate on the sum-mary sheet those other agencies from which comments have been requested, as specified in appendix I of the CEQ guidelines. SXCTIOM-BT-SECTION COMMENT AND EXPLANA-TION or MAJOR PROPOSED REVISIONS 1. Purpose and authority.—This section remains basically unchanged, except for minor stylistic revisions and expanded refer-ence In subsection (a) (purpose) to national goals described In section 2 of NEPA. In addi-tion a new subsection (b) has been added making explicit the basis of the Council's role tn the NEPA process. The former reference to EPA's Implementa-tion of section 309 of the Clean Air Act Is replaced with a more general reference to all commenting entitles in order to reflect more accurately the matters covered by the new directive. 2. Policy.—This section reenforces the former emphasis on early consideration of environmental Issues in agency planning, and explains In general terms the function of the environmental Impact statement process m meeting this objective. The emphasis on early preparation of statements accords with the directive In section 102(2) (C) of the Act that such statements "accompany the pro-posal through the existing agency review process." It also accords with results of re-view sessions held last July by the Council with major Federal agencies following issu-ance of the GAO Report on Improvements Needed in Federal Efforts to Implement NEPA. , 3. Agency and OMB Procedures.—(a) (Re-quirement for Agency Procedures],—This subsection reaffirms the previous direction to agencies to develop their own NEPA proce-dures and requires further revision as neces-sary to reflect new changes in the CEQ guide-lines. New provisions also require agencies to consult with CEQ In developing or revising procedures and to notice significant proposed revisions for public comment. (b) {Consultation with other agencies].— This subsection retains the previous recom-mendation for consultation with other agen-cies in developing or revising NEPA pro-cedures and incorporates and clarifies the previous reference (former sec. 3(c)) to OMB Circular A-85 as the means tea ob-taining State and local review of such pro-cedures. (c) [Use of existing mechanisms].—This Is former section 3(d), essentially unchanged. 4. Federal agencies included; effect of Act on existing agency mandates.—This section adds additional language to former section 4 to emphasize that NEPA expands the tra-ditional mandates of agencies covered by the Act—a view that is fully supported both by the legislative history of the Act, see, e.g.. Hearings on S. 1075, S. 237, and S. 1752 Before Senate Committee on Interior and Insular Affairs. 91st Cong., 1st Sess. 206 (1969); 115 Cong. Rec. (part 30) 40416 (1969) (remarks of Senator Jackson), and by early and con-sistent Judicial opinion. See, e.g., Calvert Cliffs v. AEC, 2 ERC 1779. 1780-81 (D.C. Cir. 1971); Zabel v. Tabb, 1 ERC 1449, 1457-59 (5th Cir. 1970). 5. Actions included.—The nonapplicabllity of the Impact statement process to general revenue sharing is confirmed. The former section 5(d) of the CEQ guide-lines, exempting all of EPA's environmental protective regulatory activities from the re-quirements of section 102(2) (C), has been deleted In recognition of the fact that new section 511(c) of the Federal Water Pollu-tion Control Act Amendments of 1972 now specifically addresses this Issue, requiring EPA to prepare impact statements In some cases, and exempting EPA from the require-ment in other cases. This general matter will be addressed In EPA's NEPA procedures is-sued pursuant to section 3(a) of these guide-lines. 6. Identifying "major," environmentally "significant" actions.—This new section com-bines parts of the existing guidelines with new directives for interpreting and applying these key words of the Act. (a) General guidance from previous sec-tion 5(b) is Included here about the statu-tory criteria for determining when an EIS is required. (The discussion of the "lead agency" concept has been moved to the fol-lowing section (sec. 7(c)).) (b) More specific guidance is included here concerning factors to consider in assessing "significance." Specific cross-reference is made to appendix II which contains a list of typical kinds of environmental impact to consider in making this assessment In-cluding a new reference to "energy conser-vation." (c) This subsection Indicates that each agency should supplement the general CEQ criteria with specific criteria, and review its typical actions to determine those that will require statements and those that will not. With respect to remaining actions and ac-tions likely to require statements, agencies are to develop guidance, indicating for par-ticular kinds of projects how environmental Impact is to be determined. The emphasis on agency responsibility to develop such cri-teria for making environmental assessments accords with longstanding CEQ policy and with provisions contained in recommenda-tion No. 1 of the CEQ's memorandum of May 16. 1972. See 3 Environmental Reporter 83 ("Current Developments," May 19. 1972). (d) This subsection emphasizes the use-fulness and desirability of program or over-view statements. In accord with recommenda-tion No. 9 of the CEQ May 16 memo, 3 ER 87. 7. Procedures for preparing draft EIS's.— This is a new section, discussing procedural aspects of preparing draft statements. (a) Because the decision whether or not to prepare an impact statement is a crucial point In the 102 process, this subsection adds new provisions for making public the decision when it Is made. The "notice of Intent" de-vice was previously recommended In the May 16 memo (see Rec. No. S, 3 ER 85-86). .(b) This subsection provides a general overview of the 102 process from draft through final, emphasizing again the Impor-tance of early preparation pursuant to the policy of section 2. (c) The "lead agency" concept Is clarified here, and the desirability of Joint statements is emphasized in accordance with Recom-mendation No. 8 of the May 16 memo, 3 ER 86-87 (attached, app. A), and with similar recommendations made both by agencies and environmental organizations.' The section also makes clear that where a "lead agency" prepares the statement, input from other participating agencies should still be secured. Finally, additional factors relevant to selec-tion oi a lead agency are specified. (d) This subsection responds to the deci-sion in Greene County Planning Board V. FPC. 3 ERC 1595 (2d Cir.. 1972). prohibiting the use of applicant EIS's. Some flexibility is preserved, however, to permit the use (after review) of Initial information furnished by an applicant In the form of an EIS. (e) This Is a revision and codification of what appears in sections 6(d) and 10(e) of the existing guidelines, with some additional general guidance about when to hold hear-ings. Agencies are also asked to identify In their procedures contexts in which hearings are normally held as part of the review proc-ess. The final clause of the former section 10(|e) has, been deleted In response to the decision in Greene County, supra. 8. Content of EIS's. (a) The points to be covered have been reorganized and new lan-guage has been added: (1) Emphasizing the need for a comprehensive but comprehensible description of the proposed action and the existing environment and for accurate pop-ulation data. Identified by source, in making assessments of population Impact; (2) Illus-trating the range of environmental values which agencies should keep in mind in eval-uating proposals, and indicating that the ef-fect on the international environment Is also to be assessed where relevant; and (3) discussing the kinds of secondary effects to which agencies should be alert In making environmental assessments. Additional language in the discussion of alternatives (sec. 8(a) (ill),) reflects the de-cision in XRDC v. Morton, 3 ERC 1558 (D.C. Cir. 1972) and Recommendation No. 4 In the CEQ May 16 memo. 3 ER 83-84. (b) This subsection emphasizes the im-portance of substance over form in the con-tent of EIS's. and stresses the primary EIS function of serving as a full disclosure docu-ment. The reference to incorporation of un-derlying documents is from Recommendation No. 6 of the May 16 memo, 3 ER 86. (c) This is former section 6(c), with ad-ditional language clarifying the act's refer-ence to use of an "interdisciplinary" approach. 9. Review of draft EIS's.—(a) Review by Federal agencies is discussed here, incorpo-rating parts of former section 7 with minor revisions, and adding a discussion of the re-lationship of section 102(2) (C) to other Federal statutes requiring consultation and coordination. The deletion of the clause In the first sentence of former section 7 Is re-sponsive to the decision in Greene County, supra. The list of relevant commenting agen-cies has been moved to the appendix. (b) This subsection relates EPA review of EIS's under section 309 of the Clean Air Act to the EIS process generally and requires prompt notification of the Council where statements are rated Inadequate or projects are determined to be environmentally unsatisfactory. (c) Procedures for securing State and local review are referenced here to the recent Joint CEQ-OMB memorandum. This joint memo-mUAL REGISTER, VOL 38, NO. 84—WEDNESDAY, MAY », 1973 - 208 -randum has been attached to the guidelines as an appendix, thus allowing modification as necessary without necessitating full revision of the CEQ guidelines. This subsection re-places former section 9 of the guidelines. (d) A new subsection ls added discussing arrangements for securing public review of statements. The discussion reflects Recom-mendation No. 7 of the May 16 memo, 3 ER 86. (e) This subsection ls new, providing gen-eral guidance for commenting entitles. (f) The time limits for review have been expanded to 45 days for all commenting en-tities. Under present guidelines, agencies must allow 45 days for comment by EPA ln any event, so that there seems little reason not to make this commenting period uniform. 10. Preparation and circulation of final statements.—(a), (b) These subsections In-corporate Recommendation No. 3 of the May 16 memo, 3 ER 84-85. 11. Distribution of statements; minimum periods for review and advance availability.— (a), (b) These subsections Include relevant portions of former section 10(b). retaining r K U r - U S E D RULES provisions concerning1 number of copies to file with CEQ and waiting periods prior to action. Additional language at the end of subsection (b) draws attention to the pos-sibility of amending and recirculating state-ments, as further discussed ln the Council's "Third Annual Report," chapter 7, pages 238-239. (c) This subsection indicates how time pe-riods are to be calculated. The periods for review and advance availability of statements run from the date of receipt of the EIS by CEQ, as per Recommendation No. 7 of the May 16 memo, 3 ER 86. (d) , (e) Substantially unchanged. (f) This subsection describes ln general terms the Council's role ln the EIS process, Including the Council's authority to require agencies to prepare either an EIS or. If the responsible agency has determined an EIS ls not required, a publicly available record of the reasons for that determination. 12. Legislative actions.—(a) This general language concerning application of section 102 ln the legislative process corresponds to agreements reached between CEQ and OMB last fall after the July agency review sessions to followup the QAO report. (b) Former section 10(c). 13. Application to existing projects and programs.—This section has been slightly revised to make clear that the act applies to major actions yet to be taken on environ-mentally significant projects, even though such projects were begun prior to passage of the act. This view ls now supported by over-whelming Judicial precedent, see, e.g., Jica-rilla Apache Tribe v. Morton, 4 ERC 1933 (9th Cir., Jan. 2, 1973); EDF v. TV A, 4 ERC 1850 (6th Clr., Dec. 13, 1972) (Tellico Dam case), and is consistent with the Intent of the for-mer section 11 of the CEQ guidelines. -14. Supplementary guidelines and evalua-tions.—This section ls former section 12, with a new sentence ln subsection (b) re-quiring agencies to report on their progress ln developing substantive guidance for mak-ing environmental assessments. 15. Effective date.—The amended guide-lines will apply to all draft and final Im-pact statements filed with the CouncU more than 90 days after the publication of the revised guidelines ln final form. [FR Doc.73-8576 Filed 5-1-73;8:45 am] FEDERAL REGISTER, VOL. 38, NO. 84—WEDNESDAY, MAY 2, 1973 - 209 -APPENDIX C LAND CAPABILITY OR SUITABILITY ANALYSIS - 210 -TABLE 1 An Outline Of The Method Proposed By G. Angus H i l l s (from Belknap and Furtado, 1967) - 211 -OUTLINE OF ANALYSIS PROCEDURE: G. Angus Hills A. Given a Total Site . 7 , The total site for analysis is subdivided into smaller units of phy-siographic differentiation based on a gradient scale of climate and landform features. 1. Site regions, on the basis of broad climatic similarities. 2. Landtypes and watertypes, by isolating areas of differing land-form, geologic composition and water content within the site region. (Watertypes are not classified here. ) 3. Physiographic site classes, by isolating areas within the land-types on the basis of local climate consideration. 4. Physiographic site types, by differentiation of micro-landform variation within the site classes. B. A Possible Range of General Land Uses is Determined and Physical  Requirements for Each are Identified 1. Specific land-use activities appropriate to each of the general use categories (Agriculture, Wildlife, Forestry and Recrea-tion) are identified. 2. If specific activity requirements cannot be determined on the basis of site types, a physiographic site phase is added to the hierarchy to isolate other significant qualities. C. Use Potential is Ranked at Two Area Levels, Under Various Man- agement Conditions, and Using Separate "Value Scales 1. At the Local Level: Site types and phases are evaluated for natural groupings of activities related to the features within the unit on the basis of assumed levels of physiographic limits to production according to the following: - 212 -G . Angus Hills D I A G R A M M A T I C O U T L I N E O F A N A L Y S I S P R O C E D U R E T O T A L S I T E USE.CAPABILITIES CUD UM3 UED HUMEl jjll U S E S U I T A B I L I T Y LXn LXO LTD LTT] rrm jiji - 213 -a. Use Capability, ranked on an A-to-G scale of seven values based on the inherent potential at the highest observed level of physiographic production under optimum management conditions. b. Use Suitability, or the degree to which a unit, i n its pres-ent condition, can respond to specific management practices. c. Use Feasibility, the present likelihood or potential of a unit for development under specified socio-economic conditions. 2. At the Community Level: Patterns of site types and phases with s i m i l a r landform characteristics are regrouped into land- scape units (16-square-mile minimum) and land units (a portion of a landscape unit with special significance for some specific use) to provide a basis for comparative evaluation of feasible uses. The following are again ranked before making a recom-mendation: a. Use Capability, s i m i l a r to C. 1. a. , but on a l-to-7 scale. b. Use Suitability: see C. l.b. c. Use Feasibility: see C. 1. c. D. Recommended Use The land-use activity with the highest feasibility ranking i n a land-scape unit i s recommended as a major or co-major use. E. Multiple-Use Regions Maps are prepared showing recommended multiple major and co-major uses for each landscape unit. -214 -TABLE 2 Criteria Developed By McHarg (1969) To Evaluate The Suitability Of Land For Different Uses - 215 -ECOLOGICAL FACTOR RANKING CRITERIA PHENOMENA RANK I II III CLIMATE AIR POLLUTION TIDAL INUNDATION GEOLOGY FEATURES OF UNIQUE. SCIENTIFIC AND EDUCA-TIONAL VALUE INCIDENCE MAX m mm INCIDENCE MAX •» um SCARCITY MAX •» MIN VALUE FOR LAND USE C | P | A | R I I FtoaMJna 2 Unit of GUaation 3 lnu>t» Tnal FOUNDATION CONDITIONS COMPRESSIVE STRENGTH 1 MAX m mn J Oi PHYSIOGRAPHY FEATURES OF UNIQUE. SCARCITY SCIENTIFIC AND EDUCA- MAX • HI* TIONAL VALUE Sarpanuna SMa 2 Buriad VaHaya 3 O n Pin 4 Graaeinti U M i M S a a * fclnWaj— within Outliar LAND FEATURES OF SCENIC VALUE WATER FEATURES OF SCENIC VALUE RIPARIAN LANDS OF WATER FEATURES DISTINCTIVE MOST » LEAST DISTINCTIVE MOST » LEAST VULNERABILITY MOST a» LEAST Sarpantina Ridaa Beadl • Shore Rioie BEACHES ALONG THE BAY VULNERABILITY MOST e» LEAST SURFACE DRAINAGE SLOPE HYDROLOGY MARINE Commercial Craft PROPORTION OF SURFACE Martian* WATER TO LAND AREA MOST e» UAST GRADIENT HIGH a» LOW S-2** 1 ThaR 2 Kin Van KuO 3 Arthur KU 1 ThtNaman 2 Kill Van Hull 2 Arflw Kin •rsearn/ewaar r*-c% Ptossurv Craft NAVIGABLE CHANNELS The DEEPEST e» SHALLOWEST FREE EXPANSE OF WATER RanunBa, Freeh K a T l . LARGEST » SMALLEST FRESH WATER Active recreation (swimming. EXPANSE OF WATER paddling, model-boat sailing. LARGEST *> SMALLEST ate.) Stream-sice recreation SCENIC (fishing, trails, etcl MOST •> UAST WATERSHEDS FOR STREAM SCENIC STREAMS QUALITY PROTECTION MOST e» LEAST 1 OhrbacfiLaka 4 I 5 1 rtanurbarund intermittent Nonurbanued tntenninant SamMrbantzsd LMaximl AQUIFERS AQUIFER RECHARGE ZONES YIELD HIGHEST V LOWEST IMPORTANT AQUIFERS MOST a> LEAST CryaalUne C O N S E R V A T I O N ; PtPASSIVE RECREATION; A:ACTIVE RECREATION: R:RESIOENTIAL DEVELOPMENT; l:COMMERClAL SL INDUSTRIAL DEVELOPMENT - 216 * ECOLOGICAL FACTOR RANKING CRITERIA PEDOLOGY SOIL DRAINAGE FOUNDATION CONDITIONS EROSION VEGETATION EXISTING FOREST FOREST TYPE EXISTING MARSHES WILDLIFE EXISTING HABITATS INTERTIDAL SPECIES WATER-ASSOCIATED SPECIES FIELD AND FOREST SPECIES PHENOMENA RANK I II III IV VALUE FOR LAND USE C l P I A I R I I PERMEABILITY AS INDICATED BY THE HEIGHT OF WATER TABLE MOST a. LEAST COMPRESSIVE STRENGTH ANO STABILITY MOST a. LEAST SUSCEPTIBILITY MOST. •» LEAST Grandly tt GnMadyanJ or silt loams Grtyatty andy to fint t Sandy lam 2 Gram 3 Saachaanck 1 AHuvajfll 2 Swamp Muck 1 Tidal n an StocanI0-2H%) Othara 12%-lOVon on a/anrily land I Grevauyssnd orsrtt kaaii or sill kuma 1 O t M h / B QUALITY •EST B> F00RE5T SCARCITY MOST a> LEAST QUALITY IEST a> >OOREST SCARCITY MOST s» LEAST ENVIRONMENTAL QUALITY 1 BASED ON INTENSITY OF SHORE ACTIVITY LEAST MOST ACTIVITY ACTIVITY ENVIRONMENTAL QUALITY BASED ON THE DEGREE OF URBANIZATION MOM FULLY URBANIZED URBANIZED FOREST QUALITY BEST » POOR EST URBAN-RELATED SPECIES PRESENCE OF TREES ABUNDANT a» ABSENT • LAND USE FEATURES OF UNIQUE. EDUCATIONAL. AND HISTORICAL VALUE IMPORTANCE MOST t» LEAST FEATURES OF SCENIC DISTINCTIVE VALUE MOST a> LEAST EXISTING AND POTENTIAL AVAILABILITY RECREATION RESOURCES MOST a. LEAST 1 AmboyRoad Araawrth 2 TottanvHIa atxindanca ConfSfinof ' of landmarks Tha Voi Bnkja 1 axrjdraj pubiieopi 2 E»aa*aj C:CONSERVATION; P:PASSIVE RECREATION; A:ACTIVE RECREATION; R:RESIDENTIAL DEVELOPMENT; C^OMMERCIAL & INDUSTRIAL DEVELOPMENT - 217 -APPENDIX D IDENTIFICATION ONLY METHODS PROPOSED FOR USE IN ENVIRONMENTAL ASSESSMENTS - 218 -TABLE 1 A Checklist Of Possible Environmental Effects From A Transportation Project (from L i t t l e , 1971) o POTENTIAL ENVIRONMENTAL IMPACTS OF A TRANSPORTATION PROJECT (by category of bnpect and the e^Hkance of mfce ones et varkws stages of tfte project) Poesntial SlfnlBcanct' rt Stage ofi Pos*«tie*tte *^«ca»W « stage of. a. Public Health b. Und Us* 1 Alt Quality Impacfj a, Public H«ith b. Land Use ft. Water Quality Impact, a. Groundwater (1) Flow and water tab HI attaratlon 12) Interaction with turf act drainage b. Surface Watar (1) Shoreline and bottom attaratlon (21 Effects of fMing and dredging 13) Oralnaga and flood CTwatTteristlca e. Quality aspects 11) Effect of affluent loadings 12) Implication of other actions auch a* • disturbance of benthic layers • alteration of currents • changes in flow regime • saline intrusion In ground water |3) Land use Ml Public health 4. Soil Erosion Impacts a. Economic and Land-use' b. Pollution and Siltation b. Eoologk Impacts a. Flora b. Fauna (other than man) t. Econornk Impacts a. Land Use (1) In immediate area of pro fact (2) In local |urisdlction served or traversed (3) In region 1. "x" denotes an Impoce Category b. Tax Beat (1) Lots through dtaplac (21 Gain through increased valuta C. Eirtptoyment (I) Access to existing opoortunHtaa (21 Creation of new fobs (3) Displacement from )obe d. Housing and PuNIc Services (1) Demand for new Mrvicea (2) Alteration in ax Ming services a. Income f. Damage to aconomicairy vsfaebse aalseal resources 7.. •ock>Political Impacts a. Datriaga to, or use of, (1) Cultural resources (2) Scientific resouron (3) Historic resources (4) Recreation areas b. Life style and activities (1) Increased mobility (2) Disruption of comrnurrfty a. Perception of cmtTbenefit by cohattv* groups (1) Racial 12) Ethnic (3) Income claaj d Personal safety Aesthetic and Visual Impacts a. Scenic resources b. Urban design c Norse d. Air Quality a. Water Quality I ho M I which couWoerjrjeWv«aawet}aanag - 220 -FIGURE 1 An Example Of One Of The Networks Or Stepped Matrices Developed By Sorensen (1971) A] M A T R I X R E S I D E N T I A L , C O M M E R C I A L , A G R I C U L T U R A L . USES :<ESIDEN'TIAL DEVELOPMENT COMMERCIAL SERVICES CROP FARMS RA.NCKINC AND DAIRY INC FORESTRY. POSSIBLE ADVERSE IMPACT i CONSEQUENT CONDITION a 101.1 IdrNMl fra«* u t u (loo* lot* u w n . 101.2.1 l i l w U t i at l M t M M cliff • i « U » . 101.2.1 Mdwca Milan* 1* aat«nntna taatan. 101.J.) l a c r M i t . rr«qo*m<7 . t l u af Ha«-aa. 101.1.4 laicraaMa ISN ( acU g«llf areata* 101.1.1 DKIIWMI fltt*hlM of pwlUltwc* freaj 102.1.1 OatTaaaaa a.»aol»aa aT?ian awMlf. 101.1.) Ceocamrata ••4laaot luhora. 101.1.* fajva IlaculallaA >t»atraa*». 102.1.) Q_aa(a MllaUy-101.1.* l/»a(r*aa Mit aaaat I l a a . 101.1.1 nova aboil flan praaaiara lata ••taart. 101.2.1 DaciMaa a*.trl«*t awpel* to tout t l •Tita.. EFFECT CORRECTIVE ACTION or 6 ) CONTROL MECHANISMS REFERENCES INDEX 101.1.1.1 l*tf*fll d t f f i t f M l . r u a aiUMlaa. — A 130.1 101.1.1.1 Itparll caatta (la*! alala a*^loa-« .c . 4 X>1.1 102.1.1.1 Ba4t-ra coaatal a->iaa> aallltj ta aMLaUlata a* 1 luteal a*-*.*. 0 1 M . 1 . M - M - • •- • - • D ISO.J.J 102.2.1.1 t i l tatloa aortal It* •( afeallftah V*4l. 102.1.1.1 Ituraatve rn l . t la* lata <tr7 l«a*U. a J'0.1 102.2.4.1 rtova iWLmiit laa aaa) a boal lata afatraa*. 101.2.4.1 Mit latraatatm af rraaawatar atjatfata. 102.1.1.1 Piaaatle* af aMl If las. a**,, 101.1.«.l to..** atatlt ara-aWtltlt*. tataWaall lavMi af •»*< Ira. - 222 -FIGURE 2 A Stepped Matrix Used As A Summary Of An Environmental Impact Statement (from Daniel, Mann, Johnson and Mendenhall, 1972) PROJECT CLEMENTS I. tMMdUtt I*ef.*«-w*il1 < t t r * « t t . »r*trt*t«ant plint) 1. ftJt.ro t>provaa«nu (paviag, ttrntlur- ccntruction, gtwlto utility Intt.llltiOrn, « « . ) itiptrtitT toairp on iniy - (mime I. O'-Will (Sitrr* Mfiioectina) *. PttRrion R*rrdi-r»f*) S- Trwtiinq Comptni iwusm lourm ON >iiis..-.?yB*L 4. m-1 rcraiUoa 'J^^. ALTERED ELEMENTS •ttTIICRl t av I B0!T'[ MT sot i 'ubiurfaca Nat*r adj*c**t Land lit* *JBtaltr OralMH aiwj Irriiattao Hllllty Facltttlw Trantporutioa Sritatn | SOtlO-EroajHK IWlMWffHT C*vU-a»nt Oopertiwltlat « -> IU i *ad lafati CAUSAL FACTORS * * • o u u I "DIM Of IRHNKTIQa •OSIt|« IWttT (MDC ft RHINtD 1->ACI Figure 7 IMPACT MATRIX FRUIT/CHURCH INDUSTRIAL PARK fKMAKIV PF CHARM -i'uqr«dini| of indtrttnil -Wind rroilon •Reduced InMltritloA dut to Impcmtiblc lurfact, •InduMriil dt>• Ioniant • Incrxtad truck traffic -Conitrwctiot) traffic -I»«r»ii»d traffic f lo* -attraction of aava I ocaailt -IntrMttd milovnrnt by nUt lna Iftdaltry-, attraction of nn aafiloiart f •nruultwril l i t t le chirnir -L«detrrT.irw/«) o t l l « b l 11ty of-unit io. I itroHatarvd ooinola uporttjing of •djtcfit urban cnanctar - h i r c ^ H wi l t l*<rrl - Incrtiad runoff -Bettor runoff control •Full ttr.it* (.ptdn It* -Tt*nor.r» ola IncrtatO •\r*rt*\t4 traffic 'Traffic coo troll - 224 -APPENDIX E COMMON UNIT METHODS PROPOSED TO EVALUATE ENVIRONMENTAL IMPACT - 225 -FIGURE 1 A Matrix Proposed For I d e n t i f y i n g And Evaluating The Environmental Impact Of A Prospective Action (from Leopold, et. a l . , 1971) - 227 -{FIGURE 2 An Energy Network Diagram Of A g r i c u l t u r e In F l o r i d a Cfrom Lugo, Odum, et. a l , 1971) - 229 -FIGURE 3 An Explanation Of Some Symbols Used In Energy Network Diagrams (from Lugo, Odum, e t . . a l . , 1971) - 230 -The Energy Language In order to study and understand ecosystems, wi th respect to t h e i r s t r u c t u r e s , func t ions , geographical p o s i t i o n s , s i m i l a r i t i e s and d i f -f e r e n c e s , one must f i r s t d e s c r i b e the system as i t e x i s t s . Descr ip t ions , i . e . , models, a re convenient ly descr ibed u s i n g ifhe energy symbol no ta -t ions d iscussed by Odum (1967 and 1971). Figure; (2) shows the symbols and t h e i r meaning. T h e i r mathematical c h a r a c t e r i s t i c s are descr ibed thoroughly in the p r e v i o u s l y c i t e d re fe rences . Once each o f the energy symbols is understood, the next step is to learn to read the l inked symbols as they desc r ibe a p a r t i c u l a r system or subsystem. Figure 2. - The Energy Languag2 Symbols a . PASSIVE STORAGE symbol showing • l o c a t i o n in a system f o r passive storage such as moving potatoes . * , v # M i T D i r r ' n t o a grocery s t o r e o r fuel , N P U T ^ ^ O U T P U T mtoa.Lnk. No new po tent ia l energy Ts generated and some work must be done in the process of moving the p o t e n t i a l energy in and out o f the storage by some other u n i t . CONTROL f FACTOR WORKGATE module at which a f low of energy (control factor) make poss ib le another flow of energy ( input -output ) . This act ion may be as simple as a person turning a va lve , or i t may be the i n t e r -act ion of a l i m i t i n g f e r t i l i z e r in photo-synthes is . SELF-MAINTAINING CONSUMER POPULATION, symbol represents a combination of " a c t i v e storage" and a " m u l t i p l i e r " by which potent ia l energy stored in one or more s i t e s in a subsystem is fed back to do work on the success-f u l processing and work of that u n i t . PURE ENERGY RECEPTOR symbol'represents the recep :ion of pure wave energy such as sound, l i g h t , and water waves. In th i s module energy interacts with some c y c l i n g mater ial producing an energy-act ivated s t t t e , which then returns to i t s deactivated state passing energy on to the next step in a chain of p ro -cesses. The k i n e t i c s of t h i s module was f i r s t discovered in a react ion of an enzyme with i t s substrate and i s c a l l e d a Michaelis-Menton react ion . PLANT POPULATION symbol is a combination of a "consumer u n i t " and a "pure energy receptor . " Energy captured by a c y c l i n g receptor unit is passed to s e l f - m a i n t a i n i n unit that a lso keeps the cyc l ing receptor machinery working, and returns necessary mater ials to i t . The green plant i s an example. - 233 -TABLE 1 A List Of 56 Environmental Conditions Used To Evaluate The Least Social Cost Location Of A Proposed Highway (Zieman, et a l , 1971) - 234 -R e l a t i v e Weights # . ; I n i t i a l Long-term Land Removed f o r R.O.W. (Ac res ) : 1 Pine - 3 - 1 0 2 Mixed - 4 - 1 0 3 Hardwood • - 7 - 1 0 4 A g r i c u l t u r a l • - 3 - 1 0 5 Id le + 5 + 8 6 Water 7 - 4 7 Swamp 4 - 4 8 Mined Land • + 8 +10 9 Urban - 6 +10 10 Water Suppl ies A f f e c t e d - 2 0 11 Unique Areas - 2 - 2 12 Streams Crossed 2 - 2 13 Small Abridgements — 2 - 2 Major Br idges : 14 Across Main Body Number • - 5 - 5 15 of Lake Length ( f t . ) - 5 - 5 16 Across other than Number - 3 - 3 17 Main Body Length ( f t . ) — 3 - 3 18 Composite S o i l L i m i t a t i o n s — 4 - 3 19 Max. Sediment P o s s i b l e • -6 - 3 20 Min . Sediment Expected. - 8 - 3 21 Area to be Paved — 2 - 2 2 Area A f fec ted by No ise : (miles ) : 22 Some 7 1 " 4 23 Great 7 1 - 7 24 T o t a l System Cost ($x l0 6 ) 20 0 25 Annual Costs ($xl06) 0 - 2 0 26 T o t a l Excavation/System (Yds.xlO ) 2 0 27 Annual Road User Costs ($x l0 6 ) 10 - 1 0 28 Benef i t/Cost Rat io 10 - 1 0 29 In te rs ta te Highway Mileage — 2 - 2 30 Taxable Land Removed (Acres) — 8 1 - 8 31 P u b l i c Land Removed (Acres) 8 I - 8 32 T o t a l Family Displacements 20 1 0 Nearby Residences A f f e c t e d (Noise) : 33 Daytime A c t i v i t y (Some) - 2 - 2 34 Disturbance (Great) — 5 - 5 35 N ight - t ime Sleep (Some) - 4 - 4 36 Disturbance (Great) 10 - 1 0 - 235 -Relativ e Weights I n i t i a l Long-term 37 Churches Affected 38 By Noise 39 Schools Affected 40 By Noise Lives Saved/Route: 41 Short Term 42 Long Term (Some) (Great) (Some) (Great) (1981) (1993) 43 Number Interchanges Secondary -Growth Impact: 44 Potential for Development 45 Suitability for Development 46 Water Quality 47 Visual Disturbance 48 Hunting and Game 49 Natural Character Loss 50 Safe Access 51 Impact on Planned Reservoir Use Pattern 52 Driving for Pleasure Composite Noise Effect: 53 Camping 54 Picnic Recreational Land Loss: 55 Present 56 Potential - 2 - 5 - 3 -10 +50 0 + 2 0 0 5 2 4 4 6 1 2 - 3 - 2 5 0 - 2 - 5 - 3 -10 0 +50 + 6 +25 +25 2 2 1 4 6 2 .1 - 3 - 2 0 3 - 236 -FIGURE 4 The Battelle Columbus Hierarchical System And Check Sheet Used To Compute, Environmental Impact Units (from Dee, et a l , 1972) ENVIRONMENTAL EVALUATION SYSTEM Sample Form Evaluation Taam Project Location ftofoct Name Data* of Evaluation _ Sta Evaluated Prepared lor Buraau of Reclamation by Battelle-Columbus January 31. 1973 Contract 14O6-0 7182 Eootogy Environrnental Pollution Specie* and Population* Terreiu-lal | M | Browser* and g/erer* (Ml Cropa | M | Natural vegetation (141 Pest specie* 114) Upland gem* birds Aquatic (14) Commercial fisheries (141 Natural vegeution (141 Part species (141 Sport llih (141 Waterfowl (1401 Subtotal Value in EIU Red Flap WIOi Pro fact Without Project Net Change H a b i t a t s and Communities Terrestrial (13) (13) (13) (14) Aquatic (13) (13) (12) (14) 1100) Food web Index Land use Rare and endangered species Specie* diversity Food web index Rare and endangered specle* Rivar cherecteriftica Spade* diversity Subtotal Oescriptivv only (340) Ecology Total Water Pollution 130) Basin hydrotogic loal (751 BOO 1311 Dissolved oxygen 1181 Fecal coliforms 1231 Inorgsnic carbon (2SI Inorganic nilrogtn (281 Inorgsnic phosphate (161 Pesticides (181 pH (28) Stream flow variation (281 Temperature (251 Total dissolved solids 1141 Toxic substances (20) Turbidity (3181 Subtotal Air Pollution 15) Carbon monoxide (SI Hydrocarbons (10) Nitrogen oxides (121 Paniculate matter IS) Photochemical oxidanti (10) Sulfur oxides (SI Other 152) Subtotal Value in EIU Red Flegs With -Project Without Proiect Net Change Land Pollution (14) Und usa (14) Soil erosion Noise Pollution Esthetics Biota IB) (61 IS) IS) U n d Value m EIU W.th W.thout Nat Red P»OJ4KM Project Change Flags (6) Geologic surface mj tar i»l 1101 Relief and topographic character (101 Width and alignment (4) Noise [_ (4J SubtoUl Q (40?) Envircv.mental Pollution Total ["* (31 Odor and visual 12) Sounds (10) Appearance of water (16) Land and water interface (6) Odor end floating materials (10) Water surface area (10) Wooded and geologic shoreline (S3) Subtotal i i ~r Animals - domestic Animals - wild Diversity of vegetation types Variety within vegetation typs (24) Subtotal M a n ^ m d e O b j e c t s (10) Men made ubjecti (10) Subtotal Composition (IS) Composite effect (IB) Unique composition J 1. 130) (153) Subtotal Esthetic* Total I I I I I I E d u c a t i o n a l / S c i e n t i f i c P a c k a g e s (13) (13) (111 1111 148) Archeological Ecological Geological Hydrological SubtoUl V. lu. in EIU Red Flags With Project Without Project Net Change H i s t o r i c a l P a c k a g e s (SS) Architecture and styles Events Persons Religions and cultures" "Western Frontier" Subtotal I I Cultures 114) 17) (7) 128) Indians Other ethnic groups Religious groups Subtotal Mood/Atmosphere 111) (HI (41 (III Awe i n s p i r a t i o n I s u l a t M t n / s n l i t u u a My stay "OteneW* with nature Subtotal L i t e Patterns (13) Employment opportunities (13) Housing (11) Social Interection* 137) SubtoUl (2061 Human Interest Toul I. foology II. Environmental Pollution III. Inhetlea IV. Murrain Inttrttt TOTAL To With r» «!•»-» la) Rating* Wlrt'iii l*.»|e>-l fiiui ' N.I 1 ' loopa rioeje ErwnVwrrtentai Impact Units • Importance Unto Importanaa Unlta • Invtonmental Qualify - 238 -FIGURE 5 The Battelle Columbus Environmental Assessment Tree Technique For The Environmental Component "Biochemical Water Quality (from Dee, et. a l ; , 1973) «*•»». I *  rtCAL COUFONM HANUt J. • DISSOLVED OXVGEN FICAL COltr-ORM INORGANIC NiTROQfN j I^AGL 3. 2 t V rC INORGANIC PHOSPHATE FECAL COL (FORK HANOI 2. 2 o> 1 ]4: FECAL COL I FOAM D I S S O L V E D O X Y G E N I RANGE 2 or t 4 INORGANIC NITROGEN rC r St 4 or J |  FECAL COLIFOflM INORGANIC NITROGEN I RANGE 2 m 1 4 DlSSOLVEO OXYGEN FICAL COLIFORM I ' r R A N G E 3 o> 1 L t — c I* CECAL COLI FOAM INORGANIC PHOSPHATE RANGE ] FLANGE |  ] FECAL COl I FORM I 4 or >  FECAL COL I FORM INOROAMC NITROGEN R A N G E J » i RANGE 2 or \ Tr I MORGAN )C NITROGEN FECAL COL I FORM INORGANIC PMOSPHATt I R A N G E 2 or 1 14: INORGANIC PHOSPHATE DISSOLVED OXYGEN RANGE 4 or 1 I CECAL COL I FORM R A N O E 2 or 1 4 RANGE 4 or S I FECAL COL I FOAM I RANGE 2 •> t 4: FECAL COIIFORM RAN Ql l i INORGANIC NITROGEN | HANOI 7 <* 1 RANGE 4 •# a I FICAL COLIPORM RANG! 7 m 1 { R A N G E 2 or I 4 L CECAL COl I FORM DISSOLVED OXVOEN RANOE 4 or 1 | DISSOLVED OXYGEN RANGE 2 er 1 I NOR OA NIC NITROGEN 4 WANQE 4 o, 3 I INORGANIC NITROGEN INORGANIC PHOSPHATE j RANGE 2 Of 1 RANGE 4 ) « > 4 FtCAl COL IF OR M INORGANIC PHOSPHATE aiKKvtooavaiM 1 At »CX>ftM «A lM1*BOAM4in •**•« »«»A»MU« ^ A J V R 1 « 4 N ! j r M A U » I • OO • 0 i • • on • f < I • oo AAt«J( ' « * - I H * M.AM*t>*l«1_f«a/V I >OK • » : t l « I Oft) • * : » m INOHCANlC NlttUXlIN IMCANIC PIM1SPMAH MTO*MlAMC MJim»IM >ICA( COLHORM - 240 -FIGURE 6 The Probabilities Of Linked Impacts Occurring Along One Segment Of An Effects Chain Prepared For Alaskan And Canadian Pipeline Routes From Prudhoe Bay, Alaska (Bereano, et a l , 1972) - 241 -- 242 -FIGURE 7 One Part Of A Matrix Of Horizontal Parameters Developed From "Effects Chains" And Alternative Pipeline Routes From Prudhoe Bay Listed Vertically. The Impacts On The Matrix Are Valued According To Probability And U t i l i t y (from Bereano, et a l , 1972) SOCIAL  N Alaska Canada Deferral (c* I) h Corridor I-Corridor Deferral M&m - 244 -FIGURE 8 The Weighted Value Of Impacts For Various Alternatives Listed On The Matrix (Bereano, et a l , 1972) SOCIAL Alaska Canada Deferral (oil) /•Corridor l-Corridor Dekrmim& ECOLOGICAL ^ T ^-Q, A c3 -*J 5 I S til 0.00 4 •V V V §»>r.T tn ©> *^ t\J S S tsT -*1 A ?3 *^ £4. t $ . 3 too 'Sl noo •ICQ •sod 0.00 - 246 -APPENDIX F METHODS WHICH SEPARATE IMPACTS INTO INDIVIDUAL QUANTITATIVE UNITS AND QUALIFYING DESCRIPTIONS - 247 -TABLE 1 A List Of General Factors To Be Considered Under Each Of The Four Display Accounts Developed By The U.S. Water Resources Council (adapted from U.S. Water Resources Council, 1973) - 248 -BENEFICIAL EFFECTS ON NATIONAL ECONOMIC DEVELOPMENT A. The Value of Increased Outputs of Goods and Services From a Plan B. The Value of Output Resulting From External Economies Caused by a Plan ADVERSE EFFECTS ON NATIONAL ECONOMIC DEVELOPMENT A. Resources Required of Displaced to Produce F i n a l or Intermediate Goods and Services B. Decreases i n Output Resulting From External Diseconomies BENEFICIAL AND ADVERSE EFFECTS ON ENVIRONMENTAL QUALITY A. Open and Green Space B. Wild and Scenic Rivers C. Lakes D. Beaches and Shores E. Mountains and Wilderness Areas F. Estuaries G. Other Areas of Natural Beauty H. Archaeological Resources I. H i s t o r i c a l Resources J . B i o l o g i c a l Resources K. Geological Resources L. E c o l o g i c a l Systems M. Water Quality N. A i r Quality - 249 -O. Land Quality BENEFICIAL AND ADVERSE EFFECTS ON REGIONAL DEVELOPMENT A. Regional Income B. Regional Employment C. Population D i s t r i b u t i o n D. Regional Economic Base and S t a b i l i t y E. Environmental Conditions of Special Regional Concern BENEFICIAL AND ADVERSE EFFECTS ON SOCIAL WELL-BEING A. E f f e c t s on Real Incomes B. E f f e c t s on Security of L i f e , Health and Safety C. Educational, C u l t u r a l and Recreational Opportunities D. E f f e c t s on Emergency Preparedness - 250 -TABLE 2 An Example Of The Tabulation System Of The U.S. Atomic Energy Commission To Be Used For Communicating The Environmental Impacts Of A l t e r n a t i v e Nuclear Plant Design Systems (1973) BASIC TABULATION TO BE USED IN COMPARING ALTERNATIVE PLANT SYSTEMS ALTERNATIVES A B C ' D INCREMENTAL GENERATING COST Present Worth Annualized CAPACITY FACTOR ENVIRONMENTAL COSTS* UNITS Magnitude Page Magnitude Page Magnitude Page Magnitude Page 1. NATURAL SURFACE WATER BODY 1.1 Impingement or entrapment by cooling mater intake structure 1.1.1 Flth 1.2 Patiage through or retention In cooling systems 1.2.1 Phytoplankton and zooplankton 1.2.2 Fish 1.3 Discharge area and thermal plume 1.3.1 Water quality, excess heat 1.3.2 Water quality, oxygen availability 1.3.3 Fish, nonmigretory 1.3.4 Fish, migratory 1.3.5 Wildlife (including birds, aquatic and amphibious mammals, and reptiles) 1.4 Chemical effluents 1.4.1 Water quality, chemical 1.4.2 Fish 1.4.3 Wildlife (Including birds, aquatic and amphibious mammals, and reptiles) 1.4.4 People 1.6 Radionuclides discharged to watar body 1.6.1 Aquatic organisms 1.5.2 People, external 1.5.3 People, ingestion 1.6 Consumptive use 1.6.1 People 1.8.2 Agriculture 13.3 Industry > • See Table 3 for definition oi en vii on mental com. For each plant system, certain of the tabulated costs will be applicable and others will not. - 252 -TABLES 3 An Example Of The Tabulation System Of The U.S. Atomic Energy Commission To Be Used For Communicating The T o t a l Costs Of A Nuclear Power F a c i l i t y (1973) - 253 -COST DESCRIPTION OF PROPOSED FACILITY AND TRANSMISSION HOOK-UP (All monetized costs expressed in terms of their present and annualized values) Generating Cott Present Worth Annualized Transmission and Hook-up Cott Present Worth Annualized Environmental Costs (see Table 3) UNITS MAGNITUDE PAGE 1. NATURAL SURFACE WATER BODY 1.1 Impingement or entrapment by cooling water "intake structure 1.1.1 Fish 1.2 Passage through or retention in cooling fn/stttns 1.2.1 Phytoplankton and zcoplenkton 1.2.2 Fish 1.3 Discharge area and trwrmal ptona 1.3.1 Water quality, axcenlfaaat 1.3.2 Water quality, oxyrjen availability 1.3.3 Fish, nonrnigratory 1.3.4 Fish, migratory 1.3.5 Wildlife (including birds, aquatic and amphibious mammals, and reptiles} 1.4 Chemical effluents 1.4.1 Water quality, dmtikM AA2 Fish 1.4.3 Wildlife (including birds, aquatic and arTajthlbfeu* mammals, and reptiles) 1.4.4 People 1.5 Radionuclides discharged to Mter body 1.S.1 Aqu8tic organism* 13.2 People, external 1.5.3 People, inpastion 1.6 Consumptive uas 1.6.1 People 1.6.2 Agriculture 1.6.3 Industry 1.7 Plant construction (including site piepaf atton) 1.7.1 Water quality, physical 1.7.2 Water quality, dtwitlud 13 Other impact! 1.9 Combined or in wracthre rrffeeB 1.10 Net affect - 254 -APPENDIX G TERMS OF REFERENCE FOR THE PROPOSED SEVEN MILE PROJECT ECOLOGICAL AND SOCIO-ECONOMIC STUDIES - 255 -PROJECT: VE 1065 B.C. HYDRO AND POWER AUTHORITY  SEVEN MILE PROJECT VANCOUVER B.C. PROJECT REPORT: VE 1065/1 DATE: OCTOBER 1973 ENVIRONMENTAL IMPACT STUDY 1. PURPOSE OF REPORT Pearse-Bowden Economic Consultants L t d and Envirocon L t d were commissioned t o study the long-range environmental impacts of the development of h y d r o - e l e c t r i c generating f a c i l i t i e s on the Pend d ' O r e i l l e R i v e r . The terms of re f e r e n c e were e s t a b l i s h e d as f o l l o w s : 1. I d e n t i f y and study the i n d i v i d u a l impacts of the proposed p r o j e c t . 2. Study the impact of the access road on deer. 3. Suggest m i t i g a t i o n p o s s i b i l i t i e s . 4. Provide a comprehensive r e p o r t f o r submission t o government agencies and environmental o r g a n i z a t i o n s . Although the terms of r e f e r e n c e impose few r e s t r i c t i o n s , i t i s important t o note the n a t u r a l l i m i t a t i o n s which are imposed on a l l environmental s t u d i e s . The c u r r e n t s t a t e of knowledge does not permit complete understanding of the f u n c t i o n a l r e l a t i o n -ships w i t h i n ecosystems, so i t i s not p o s s i b l e t o p r e d i c t or evaluate a l l p o t e n t i a l consequences of anv environttiPTTr-ai m a n i p u l a t i o n . - 256 -TERMS OF REFERENCE FOR SEVEN MILE SOCIAL IMPACT STUDIES  Study Procedure The regional d i s t r i c t s of Kootenay Boundary and Central Kootenay, and the municipalities of T r a i l and Castlegar and the general public of the area have been informed of this intended study and that they w i l l be consulted. Participation of and input from local representatives of senior governments and of local governments and other organizations should therefore be sought. B.C. Hydro w i l l wish to announce locally the assignment of this study i n advance of f i e l d work. The report i s to be submitted in draft form for discussion with B.C. Hydro prior to f i n a l production. The finished report i s to be made available by B.C. Hydro to the public. The study and report i n draft form should be completed by May 15, 1974, unless otherwise agreed. A requirement of the study i s that use be made of the local knowledge and expertise i n community planning of Mr. J.A. DeJong, Chairman of the Department of Regional and Community Planning, Selkirk College. Scope The Bcope of the social impact studies i s as follows: 1. (a) Study and report on social and economic impact of the construction of the Seven Mile hydro project on the surrounding communities and regions.. (b) Studies to consider not only the short term conditions resulting from injection of the work force and i t s payroll on the community but also the long term effect on the community of the aftermath of construction when the transient population has l e f t . - 257 -I t i s expected that when s i g n i f i c a n t impact i s to be a n t i c i p a t e d , consideration w i l l be given to the e f f e c t on such matters as: - population growth and d i s t r i b u t i o n - community services i n c l u d i n g r e t a i l s tores, maintenance and r e p a i r services - employment - community rec r e a t i o n f a c i l i t i e s - community health, welfare and education services - p h y s i c a l resources of the community i n c l u d i n g land, housing, roads, water, sewer and e l e c t r i c services - l o c a l industry - other matters which become evident before or during the study. Recommend means of m i t i g a t i n g the unfavourable impacts and maximizing the favourable aspects of construction of the Seven Mile project on the surrounding communities and regions. Study and report on the opportunities f o r tourism a r i s i n g from the Seven Mile development and recommend i n general terms any f a c i l i t i e s which B.C. Hydro might reasonably provide to enhance tourism, both during and following construction. (A separate study to develop a long term r e c r e a t i o n a l concept at the Seven Mile r e s e r v o i r i s being undertaken by B.C. Hydro's Environmental Consultants, Envirocon and Pearse Bowden Consultants, Ltd.) - 258 -APPENDIX H PART OF A NETWORK CHECKLIST OF ENVIRONMENTAL IMPACTS FOR HIGHWAYS (Sorensen and Pepper, 1973) - 259 -C A T E G O R Y : V I I . RELATIONSHIP OF PROJECT TO VISUAL CONDITIOHS ^^^^^v,^^v,^v,^^v.%^^^^^^^wAv/f/.(>•*•^^v.,.*.^swA•.•.v C O N D I T I O N C H A N G E : A G E N C Y R E S P O N S I B I L I T Y F E D E R A L S T A T E - L O C A L embnnsmrnta (highway •bore grade) b e n u elevated highway (on structures) fences end barriere landscaping • Block vievlines along visual corridors (valleya. streea courses, streets).. Sever visual continufty of open space network. Fragmentation of open space expanse. Degrade aesthetic qualities. Isolate open space areas from connection vith larger open space systems. Fragment Image of community or neighborhood as a discrete cohesive unit. Disorientation or confusion of visitor or resident. Block or reduce viev from residential areas or commercial operations that benefit from viev. Decreased residential and commercial property values and rents. Decreased patronage to commercial operations. Reduce affiliation to community by residents blocked off by highway. • Block vlevlines to landmarks ln community from residential areas, recreational areas and commercial operations that benefit from view. Decrease residential and commercial property values. Decrease patronage to commercial operations. •Elevated or above—grade highway out of scale with adjacent urban development. Bighvay doninant element in viev of community or neighborhood. Scale of bighvay overpower a scale of community or neighbor-hood Decrease property values. Unattractive contrast between scales. HUD, BOR pPR, HCD.RPD, ABAC, OPR. AO, OOC, HFC, EOC HUD, HEW, SBA, BOR blUS, FHWA HCD, COC, AO, DPR AO, DPR, HCD 1 vehicle movement •Visual distraction from pursuit of recreational, residential or commercial activities. •Visual disturbance of vlldlife on adjoining lands. Abandonment of habitat, or Inhibit reproduction. Elimination or reduction of rare or endangered apeclea of regional significance. Significant reduction in population of species of sport, spectator, commercial, educational or scientific values of regional significance. Force vildllfe out of portion of range, creating concentration of wildlife with consequent overuse and degradation of habitat. Elimination or reduction of rare or endangered apeclea of regional algnlflcance. Significant reduction in population of species of sport, spectator, commercial, educational or scientific values of regional algnlflcance. Alteration of reproduction cycles and habitats. Alteration of area food chain. nlghtllghtlng vehicle reflections vehicle lights •Displeasing glare visible ln recreational areas or residential areas, BOR, BUS pSFtf, EPA, BPS, BOR DPR, BCD, COC, HPD IDFG, B C D C , OPR, ,RPD , DPR BOR, HUD DPR, HCD, HPD 

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