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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.  California  State University  a t 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 R e g i o n a l P l a n n i n g  We a c c e p t t h i s t h e s i s as conforming t o t h e required  THE  standard  UNIVERSITty OF BRITISH COLUMBIA September, 1974  In p r e s e n t i n g t h i s  thesis  in p a r t i a l  fulfilment  of  an advanced degree at the U n i v e r s i t y of B r i t i s h the L i b r a r y I further for  available  Columbia,  for  r e f e r e n c e and copying o f  thesis for  It  financial  i s understood that  copying or  this  that  study. thesis  DepartmeWP°of C O M M ™ 0 F  1 1  ? AND REGIONAL PLANNING  The U n i v e r s i t y o f B r i t i s h Vancouver 8, Canada  SEPTKMBEK  publication  gain s h a l l not be allowed without my  written permission.  Date  I agree  for  purposes may be granted by the Head of my Department or  representatives.  this  freely  agree t h a t permission for e x t e n s i v e  scholarly  by h i s of  s h a l l make it  the requirements  Columbia  ABSTRACT  E n v i r o n m e n t a l impact statements U.S.  (EIS) have been r e q u i r e d i n the  s i n c e the N a t i o n a l E n v i r o n m e n t a l P o l i c y A c t was  January 1, 1970. December of 1973  s i g n e d i n t o law  on  A l t h o u g h no l e g a l requirement e x i s t s i n Canada, i n the f e d e r a l government announced a p o l i c y of p r e p a r i n g  an EIS f o r a l l "major" p r o j e c t s h a v i n g " s i g n i f i c a n t " e f f e c t on the e n v i ronment . The e v o l u t i o n of the EIS requirement i n the U.S.  indicates  the  major purpose o f impact statements i s to produce i n f o r m a t i o n c o n c e r n i n g the f u l l important consequences of a p r o p o s a l to r e l e v a n t government a g e n c i e s , the i n t e r e s t e d p u b l i c and to d e c i s i o n - m a k e r s so t h a t each p e r son can r e a c h a r a t i o n a l d e c i s i o n about project.  the s o c i a l worth of the i n t e n d e d  The u l t i m a t e o b j e c t i v e o f impact r e p o r t s and a concomitant  p u b l i c and government agency review p r o c e s s 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 d e c i s i o n s about proposed  projects.  The methodology i n t h i s study i n v o l v e d d e v e l o p i n g a s e t o f  criteria  based upon the l i t e r a t u r e t o determine whether an EIS has a d e q u a t e l y p r o v i d e d the k i n d of i n f o r m a t i o n i n a manner n e c e s s a r y to f u l f i l l purpose.  F i v e impact  statements were c r i t i c a l l y  i t s intended  reviewed and d i s c u s s e d  i n l i g h t o f s e v e r a l methods proposed f o r a s s e s s i n g e n v i r o n m e n t a l impact. The more important shortcomings i d e n t i f i e d i n the e n v i r o n m e n t a l r e p o r t s were thereby i s o l a t e d and a n a l y z e d . The f o l l o w i n g g e n e r a l shortcomings were i d e n t i f i e d i n f i v e statements c r i t i c a l l y 1)  impact  reviewed:  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 i n f o r m a t i o n was always p r o v i d e d so t h a t the r e a d e r c o u l d v a l u e the importance of an i d e n t i f i e d impact  3)  In some cases an adequate d i s c u s s i o n of the c u r t a i l m e n t o f f u t u r e b e n e f i c i a l uses o f the environment was not completed  4)  An a n a l y s i s o f a l t e r n a t i v e s was a l l impact r e p o r t s  5)  A l l impact r e p o r t s had c h a r a c t e r i s t i c s which would h i n d e r the communication of i n f o r m a t i o n to r e a d e r s  not completed a d e q u a t e l y i n  These shortcomings were g e n e r a l l y d i s c u s s e d i n r e f e r e n c e to d i f f e r ent e n v i r o n m e n t a l assessment  methods.  Three b a s i c c o n c l u s i o n s r e s u l t e d :  1)  A comprehensive c h e c k l i s t o f impacts s h o u l d be p a r t o f any impact e v a l u a t i o n method used by an agency i n o r d e r to ensure t h a t a l l important consequences o f p r o p o s a l s 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 c a u s a l a c t i o n s to p r i m a r y , secondary and m u l t i p l e o r d e r impacts.  2)  E v a l u a t i o n 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 i n t o common u n i t s f o r comparison s h o u l d not be u t i l i z e d as a b a s i s f o r p r e p a r i n g an EIS. These methods judge the importance of each impact f o r the r e a d e r , which i s c o n t r a r y to the main purpose of impact r e p o r t s .  3)  Most e v a l u a t i o n methods i d e n t i f i e d i n t h i s study do n o t p r o v i d e guidance i n p r e p a r i n g the e n v i r o n m e n t a l impact r e p o r t i t s e l f . These e v a l u a t i o n methods would not r e s o l v e a t l e a s t t h r e e shortcomings o f the impact statements c r i t i c a l l y reviewed.  T h e r e f o r e , the recommendations o f t h i s study c o n s i s t o f EIS p r e p a r a t i o n g u i d e l i n e s t h a t enable persons p r e p a r i n g the e n v i r o n m e n t a l  impact  r e p o r t t o a v o i d the shortcomings which were i d e n t i f i e d i n the t h e s i s . g u i d e l i n e s r e l a t e to the f o l l o w i n g s i x p o i n t s : 1)  The purpose and scope o f an EIS  2)  I n t e g r a t i n g impact r e p o r t s i n t o the p l a n n i n g p r o c e s s  . 3)  4)  Recommendations c o n c e r n i n g the development lists  o f impact  check-  An e v a l u a t i o n approach which d e f i n e s impacts i n s e p a r a t e q u a n t i t a t i v e and c e r t a i n key q u a l i t a t i v e terms  - iii  -  These  S e v e r a l g e n e r a l c o n s i d e r a t i o n s and a method of summarizing an EIS i n o r d e r t o f a c i l i t a t e impact communication A f l e x i b l e and g e n e r a l EIS format which l i s t s most of the important requirements of an impact r e p o r t  - iv -  TABLE OF CONTENTS  ABSTRACT LIST OF TABLES LIST OF FIGURES ACKNOWLEDGEMENTS  '  .. ..  • . ... .......  ....  . .  Page i i viii ix xi  PART ONE CHAPTER ONE - BACKGROUND  2  INTRODUCTION Organization of Thesis . ... .. Assumptions and Limitations THE EVOLUTION OF ENVIRONMENTAL IMPACT STATEMENTS Early Project Evaluation Planning - Water Resources Planning v .. Changing Social Values - The Environmental Movement The Congressional Development of NEPA The Rationale for Requiring Environmental Impact Statements. The Existing EIS Process ., ..• Environmental Impact Assessments i n Canada  CHAPTER TWO - ESTABLISHING CRITERIA FOR EVALUATING ENVIRONMENTAL IMPACT STATEMENTS . INTRODUCTION . What i s Environmental Impact? The Role of the EIS i n Decision-Making CONTENT REQUIREMENTS FOR ENVIRONMENTAL IMPACT STATEMENTS E x i s t i n g EIS Requirements i n the U.S Environmental Impact Statements and the Courts ESTABLISHING IMPROVED STANDARDS FOR IMPACT STATEMENTS Categories of Environmental Factors Economic E f f i c i e n c y . ... The Problem of Assigning Importance to Environmental Impacts Socio-Cultural Impacts Ecological Impacts D i s t r i b u t i o n a l Consequences Analysis of Alternatives Relationship to Established Goals Communication of Information SUMMARY CONCLUSIONS  - v -  2 3 4 6 6 9 13 15 I 19 7  24  ..  . .. •  ..  24 25 28 28 28 32 34 35 35 39 43 43 44 45 46 47 48  CHAPTER THREE - THE STATE OF THE ART IN ENVIRONMENTAL IMPACT ASSESSMENT • •  •  53  INTRODUCTION LAND CAPABILITY OR SUITABILITY ANALYSIS METHODS FOR IMPACT IDENTIFICATION ONLY •.. M u l t i p l e Effects Networks METHODS AGGREGATING IMPACTS INTO COMMON UNITS U.S. Geological Survey Matrix Energy Network Diagrams . .. An Optimum Pathway Matrix Analysis Approach B a t t e l l e Columbus Methods ..... E f f e c t s Chains . .... Computer Modelling For Environmental Impact METHODS SEPARATING UNITS OF MEASURES AND QUALIFYING IMPACTS ... U.S. Water Resources Council P r i n c i p l e s and Standards U.S. Atomic Energy Commission EIS Preparation Guidelines ... DISCUSSION AND CONCLUSIONS  53 54 57 57 58 59 63 64 68 70 74 76 76 78 80  PART TWO CHAPTER FOUR - A CRITICAL REVIEW OF FIVE ENVIRONMENTAL IMPACT STATEMENTS • • (  -  INTRODUCTION THE SEVEN MILE HYDROPOWER PROJECT Brief Description of Proposed Action and Environmental Setting Non-Compliance With C r i t e r i a THE COLSTRIP GENERATION AND TRANSMISSION PROJECT Brief Description of Proposed Action and Environmental Setting Non-Compliance With C r i t e r i a THE NORTHWEST ALLOYS MAGNESIUM PLANT • p r i e f Description of Proposed Action and Environmental Setting Non-Compliance With C r i t e r i a THE PORTLAND INTERNATIONAL AIRPORT RUNWAY EXTENSION Brief Description of Proposed Action and Environmental Setting Non-Compliance With C r i t e r i a THE WASHINGTON STATE ROUTE 82 FREEWAY • Brief Description of Proposed Action and Environmental Setting Non-Compliance With C r i t e r i a CONCLUSIONS •  - vi -  .  84 84 85 85 89 95 96 99 105  ....  .  106 109 112  ..  113 116 119  .  119 122 130  CHAPTER FIVE - RELATING IMPACT STATEMENT SHORTCOMINGS TO IMPACT ASSESSMENT METHODS .... •• • INTRODUCTION .. DISCUSSION Comprehensive I d e n t i f i c a t i o n of Socio-Cultural Ecological Impacts Importance Assignment Short-Term Vs. Long-Term Discussion of Impacts Alternative Analysis Communication of Information CONCLUSIONS  ; ... and  ...  j ..... ....... .......  CHAPTER SIX - GENERAL GUIDELINES FOR PREPARING ENVIRONMENTAL IMPACT STATEMENTS .'. BACKGROUND . Purpose and Scope of the Impact Statement Integrating Impact Statements i n the Planning Process EVALUATING ENVIRONMENTAL IMPACTS Impact I d e n t i f i c a t i o n Information C o l l e c t i o n PREPARATION OF THE ENVIRONMENTAL IMPACT STATEMENT General Considerations Format of the EIS CONCLUSION • .•  133 133 134 134 140 146 147 148 151  153  . ..  153 153 154 158 159 160 167 167 169 179  LITERATURE CITED  181  IMPACT REPORTS CRITICALLY REVIEWED  187  OTHER REFERENCES  188  APPENDICES  •  '  ..  -  vii-  191  LIST OF TABLES  Table  Title  Page  IV-1  A checklist summary of non-compliance with c r i t e r i a for the Seven Mile Impact Studies  88  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  98  IV-3  Summary benefits of the proposed C o l s t r i p thermal power development  103  IV-4  Summary costs of the proposed C o l s t r i p thermal power development  104  IV-5  Checklist summary of non-compliance with c r i t e r i a for the Northwest A l l o y s Magnesium Plant EIS  108  IV-6  Checklist summary of non-compliance with c r i t e r i a for the Portland International Airport Runway Extension EIS  115  IV- 7  Checklist summary of non-compliance with c r i t e r i a for the Washington State Route 82 Freeway EIS  121  V- l  An example of a possible esthetic component of the Environmental Quality Account for a hydropower development as guided by the U.S. Water Resources Council P r i n c i p l e s and Standards  143  V— 2  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  144  VI- 1  A summary sheet including some economic, s o c i o - c u l t u r a l and ecological impacts which could r e s u l t from a proposed hydropower development  170  VI-;-2  A proposed method of summarizing an analysis of alternatives and three hypothetical alternative examples  171  - viii -  LIST OF FIGURES  Figure  Title  Page  II-l  An arrangement of the wide scope of potential environmental impacts  27  III- l  A flow chart showing the recommended integration of an environmental impact statement i n the process of planning an action  60  III-2  A reduced matrix for a phosphate mining lease indicating the magnitude and importance of actions on environmental elements  62  III-3  Mean and confidence i n t e r v a l s for the evaluation of eight highway route alignments  67  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  68  III-5  A scale to convert measurement of dissolved oxygen to an environmental quality value  68  III-6  An example of an environmental assessment tree used to determine a component's environmental quality value  71  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  73  III-8  A matrix display of some factors to be considered i n selecting a methodology for use i n environmental impact assessment  81  IV- 1  The general study area for the Seven M i l e Project EIS  87  IV-2  Location and general study area of the C o l s t r i p thermal power EIS  97  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 Prosser, Washington  120  V- l  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  135  - -ix -  A reduced a c t i o n / c o n d i t i o n m a t r i x w i t h some p o t e n t i a l impacts of a proposed magnesium p l a n t and mining operation I n t e g r a t i n g p o l i c y and p r o j e c t impact statements i n t o the p l a n n i n g / d e c i s i o n - m a k i n g p r o c e s s  ACKNOWLEDGEMENT S  Dr. William Rees and Professor Irving K. Fox provided h e l p f u l guidance and advice throughout this study.  I am grateful f o r the comments  they offered and the time they devoted to this t h e s i s . My wife Leda completed typing i n this study.  the graphics and some of the preliminary  In a more subtle but meaningful way she also helped  by being patient during the many hours I spent working on t h i s thesis.  xi -  PART O N E  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 i n the U.S. In a review of 76 environmental impact statements completed f o r proposed highway projects, Sullivan and Montgomery (1971) c i t e numerous examples of the inadequacy of these reports*, concluding that s o l i d environmental data at the l o c a l l e v e l i s supplanted by opinions, genera l i t i e s and assurances. NEPA and U.S.  The nebulous nature of section 102(2) (c) of  government recommendations for preparing environmental impact  statements:has caused more than 150 adjudications i n federal courts (Anderson, 1973).  Further, G i l l e t t e (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 t h i s study of environmental impact statements showed that: 13 percent did'not mention the problem of a i r p o l l u t i o n , 34 percent f a i l e d to consider the issue of community disruption, 44 percent did not discuss the d i s p o s i t i o n of c i t i z e n comments, 58 percent did not consider problems related to increased urbanization, etc.  - 2 -  -  3  -  been based on what the c o u r t s found to be c u r s o r y , s l a n t e d , or o t h e r w i s e inadequate environmental impact  statements."  The u l t i m a t e g o a l o f t h i s t h e s i s i s to c o n t r i b u t e t o the s t a t e o f the  a r t i n d e v e l o p i n g an e n v i r o n m e n t a l impact statement t h a t w i l l s e r v e  a d e q u a t e l y to . d i s c l o s e the consequences o f a proposed a c t i o n .  It i s  hoped t h a t such an o p t i m i s t i c g o a l can be more or l e s s reached by the  following  achieving  objectives:  1)  t o review and a n a l y z e a sample of t y p i c a l major p r o j e c t e v a l u a t i o n s (environmental impact s t a t e m e n t s ) ;  2)  to a n a l y z e and a s s e s s some o f the p r a c t i c a l advantages and d i s a d v a n t a g e s o f s e v e r a l methods which have r e c e n t l y been advanced f o r e v a l u a t i n g the e n v i r o n m e n t a l impact o f a proposed a c t i o n ;  3)  through a s y n t h e s i s o f the p r e v i o u s two o b j e c t i v e s , to d e r i v e a l i s t o f g e n e r a l r e q u i r e m e n t s f o r e n v i r o n m e n t a l impact statements.  ORGANIZATION OF THESIS The t h e s i s i s d i v i d e d i n t o two main p a r t s .  The f i r s t  chapter  p r o v i d e s the background f o r the remainder of the t h e s i s and d e f i n e s the r a t i o n a l e f o r r e q u i r i n g environmental impact statements by  historically  t r a c i n g a number of c i r c u m s t a n c e s which are b e l i e v e d to be r e s p o n s i b l e f o r t h i s component o f the N a t i o n a l E n v i r o n m e n t a l P o l i c y A c t i n the U.S.  Both  changing s o c i a l v a l u e s as e x e m p l i f i e d by the "environmental movement" and the  concomitant r e a l i z a t i o n o f the l i m i t e d u t i l i t y  of b e n e f i t / c o s t  analysis  as an i n f o r m a t i o n t o o l f o r d e c i s i o n - m a k e r s are d i s c u s s e d i n t h i s chapter as two main causes o f the e n v i r o n m e n t a l impact statement The purpose o f Chapter Two  requirement.  i s to e s t a b l i s h a s e t of standards  which a l l e n v i r o n m e n t a l impact statements s h o u l d meet.  These s t a n d a r d s are  -  4 -  l a t e r used as c r i t e r i a t o review s e v e r a l r e c e n t l y completed impact  environmental  statements. The t h i r d chapter completes t h e f i r s t p a r t o f t h e t h e s i s by p r o v i d -  i n g a d e s c r i p t i v e review o f methods which have been developed to a s s e s s t h e consequences  o f a proposed p r o j e c t .  No attempt i s made i n t h i s c h a p t e r t o  c r i t i c a l l y d i s c u s s these p r o c e d u r e s . Chapters Four, F i v e and S i x comprise the second p a r t o f t h i s Chapter Four c r i t i c a l l y reviews s e v e r a l e n v i r o n m e n t a l impact a c c o r d i n g t o t h e c r i t e r i a e s t a b l i s h e d i n chapter two.  thesis.  statements  Chapter F i v e then  g e n e r a l l y d i s c u s s e s the environmental impact e v a l u a t i o n methods d e s c r i b e d i n c h a p t e r t h r e e i n r e l a t i o n to the shortcomings o f t h e impact c r i t i c a l l y reviewed.  statements  The f i n a l c h a p t e r concludes t h e t h e s i s by l i s t i n g  recommendations which might h e l p improve environmental impact  the state of the a r t i n preparing  statements.  ASSUMPTIONS AND LIMITATIONS There a r e a number o f assumptions  and l i m i t a t i o n s which e x i s t  as p a r t o f t h i s t h e s i s and s h o u l d t h e r e f o r e be mentioned  i n order to define  f a i r l y t h e f o u n d a t i o n upon which t h e a n a l y s i s and subsequent c o n c l u s i o n s have been b u i l t . The c r i t e r i a e s t a b l i s h e d i n t h i s study f o r e v a l u a t i n g e n v i r o n m e n t a l impact statements a r e based upon two u n d e r l y i n g assumptions. assumptions  reflect  These  the r a t i o n a l i z e d but t h e s u b j e c t i v e views o f t h e  w r i t e r ; t h a t i s , a r a t h e r o p t i m i s t i c o u t l o o k e x i s t s i n t h i s study c o n c e r n i n g the r o l e o f impact statements i n d i s c l o s i n g t h e f u l l e n v i r o n m e n t a l e f f e c t s of a proposed a c t i o n .  A l t h o u g h p r e s e n t l y the energy c r i s i s has taken some  - 5 -  of the importance out of the growing r o l e of impact statements i n the U.S., j u d 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 i s assumed that the  environmental impact statement i s an important tool for decision-makers which requires a comprehensive consequences set  consideration of the important environmental  of a proposed action i n order to achieve the r o l e of the EIS  forth i n this thesis.  Conversely, i t i s r e a l i z e d that the degree of  d e t a i l necessary i n i d e n t i f y i n g the impacts of an action changes depending upon the magnitude and importance of the project.  As a r e s u l t , the set of  c r i t e r i a used i n t h i s study are established to be p r a c t i c a l and equitable standards which a l l environmental impact statements could f e a s i b l y meet. Consequently, a second assumption i s that these standards can be attained by e n t i t i e s preparing impact statements according to the existing EIS process i n 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 i s not taking f u l l r e s p o n s i b i l i t y i n achieving the purposes of t h i s requirement. As i n many other studies this thesis was also limited i n the amount of time and other resources which could be devoted to i t .  Nevertheless,  a vigorous attempt has been made to achieve the o r i g i n a l objectives of this thesis.  Due to the extremely broad scope of t h i s study during a time when  considerable work has been and continues to be produced concerning t h i s subject, two additional l i m i t a t i o n s are an inherent part of t h i s 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 i n chapter two.  Since a s t a t i s t i c a l l y r e l i a b l e  sample was not taken, the adequacy of environmental statements presently being produced i s not determined i n t h i s study.  Second, the environmental  impact assessment methods described i n chapter three were not thoroughly tested to define their pros and cons.  Rather, only a few methods were  incompletely tested i n order to y i e l d general conclusions which were considered i n 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 h i s t o r i c a l development of procedures which attempt to evaluate whether a proposed project s o c i a l l y 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 i n the Flood Control Act of 1936 which established the c r i t e r i o n that "the benefits to whomsoever they may accrue (be) i n 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 i n i t i a t e d separate procedures f o r implementation of t h i s requirement. 1950  The confusion which resulted eventually led to the "Green Book" of (later revised i n 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 -  ( M a r g l i n , 1967).  Despite  t h i s r e p o r t , e v a l u a t i o n standards were n o t  implemented u n t i l t h e U.S. Bureau o f t h e Budget  (1952) i s s u e d a memorandum  i n i t i a t i n g procedures through which water r e s o u r c e  p r o j e c t p l a n s would be  reviewed. Probably the f i r s t  attempts r e q u i r i n g t h e c o n s i d e r a t i o n of non-  economic e f f e c t s i n v o l v e d w i t h  a proposed a c t i o n was, s u r p r i s i n g l y , d u r i n g  the same year as the F l o o d C o n t r o l A c t i n i t i a t e d b e n e f i t / c o s t a n a l y s i s as a project evaluation device. establishment  G i l b e r t White (1972) has mentioned both t h e  o f an agency review p r o c e s s  o f proposed f e d e r a l a c t i o n s and  the development o f a s p e c i a l study team as experiences  i n Water Resources  P l a n n i n g which l e d t o t h e e a r l y c o n s i d e r a t i o n o f e n v i r o n m e n t a l e f f e c t s . In 1936 P r e s i d e n t R o o s e v e l t  r e q u i r e d t h a t a l l U.S. f e d e r a l a g e n c i e s under-  t a k i n g p r o j e c t s i n l a n d d r a i n a g e o r water s t o r a g e  r e p o r t t h e i r upcoming  programs t o t h e N a t i o n a l Resources Committee and p r o v i d e  an o p p o r t u n i t y  f o r c r i t i c a l comment t o a l l i n t e r e s t e d p u b l i c a g e n c i e s .  This  was i n t e n d e d  requirement  t o f o r c e a g e n c i e s to take i n t o account t h e e f f e c t s o f proposed  p r o j e c t s on w i l d l i f e , f i s h e r i e s and p u b l i c h e a l t h .  A l t h o u g h the procedure  i s somewhat s i m i l a r t o t h e e x i s t i n g s t r a t e g y o f EIS review, i t was r e q u i r e d much l a t e r i n t h e d e c i s i o n - m a k i n g p r o c e s s effort.  I n 1944 a more f r u i t f u l review p r o c e s s  r e v i s e d F l o o d C o n t r o l A c t was s i g n e d continued  and r e s u l t e d i n a f u t i l e  i n 1946 w i t h  W i l d l i f e Coordination  i n t o law.  planning  was developed when t h e T h i s t r e n d o f agency review  t h e implementation o f an amendment t o the F i s h and Act.  T h i s amendment r e q u i r e d t h a t any agency  a u t h o r i z i n g a water p r o j e c t " c o n s i d e r " t h e e f f e c t s o f t h e a c t i o n on w i l d l i f e resources  by c o n t a c t i n g t h e r e s p o n s i b l e f e d e r a l and s t a t e f i s h and  -  wildlife entities. conservation  8 -  Any r e p o r t s and recommendations submitted by these  agencies were r e q u i r e d t o be i n c l u d e d as p a r t o f t h e o v e r a l l  r e p o r t on t h e water p r o j e c t . Perhaps the most i n t e n s i v e e a r l y 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 o f an a c t i o n was by an i n t e r - g o v e r n m e n t a l team f o r the Grand Coulee Dam p r o j e c t on the Columbia R i v e r . tion eventually  This j o i n t  investiga-  d i s c l o s e d 27 d i f f e r e n t problems a s s o c i a t e d w i t h t h e p r o j e c t ,  but was n o t i n i t i a t e d u n t i l a f t e r c o n s t r u c t i o n had a l r e a d y begun. s t u d i e s were completed i n 1945 and e s t a b l i s h e d t h e b a s i s f o r s u b s i d i a r y a c t i v i t i e s r e l a t e d t o t h e Grand Coulee Dam.  The  planning  Unfortunately,  the i n v e s t i g a t i o n d i d n o t s e t t h e stage f o r f u r t h e r development o f s t u d i e s of s i m i l a r scope i n f u t u r e water r e s o u r c e Up  plans  and programs (White, 1972).  to t h i s p o i n t , i t has o n l y been mentioned t h a t t h e treatment  of non-economic f a c t o r s i n Water Resource p r o j e c t s was l e f t review process or to a s p e c i a l l y assigned i t was r e a l i z e d t h a t u n q u a n t i f i a b l e be  t o a governmental  i n t e r - g o v e r n m e n t a l team.  Although  e f f e c t s o f a proposed a c t i o n can a l s o  important, t h e tendency a t t h a t time was t o f o r m u l a t e an economic  approach t o i t s v a l u a t i o n i n order ratio. 1950)  to integrate i t into a benefit/cost  The "Green Book" o f 1950 (U.S. Subcommittee on B e n e f i t s and C o s t s , recommended t h a t " P r o j e c t e f f e c t s should  terms t o the maximum extent  practicable.  1 1  be e v a l u a t e d  i n monetary  On t h e o t h e r hand, t h e f u t i l i t y  of t h i s e f f o r t f o r many f a c t o r s o f t h e environment was a l s o r e c o g n i z e d by s t i p u l a t i n g t h a t these " i n t a n g i b l e e f f e c t s w i l l need t o be c o n s i d e r e d  on  a qualitative basis." I t was not u n t i l 1962 t h a t a d e c i s i o n - m a k i n g f o u n d a t i o n f o r consideration of the f u l l  e n v i r o n m e n t a l e f f e c t s o f water r e s o u r c e s  projects  - 9 -  was established when President Kennedy approved a statement of " P o l i c i e s , Standards and Procedures i n the Formulation, Evaluation, and Review of Plans f o r Use and Development of Water and Related Land Resources"  (U.S.  Water Resources Council, 1962) to be u t i l i z e d 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  u t i l i z e s a method that includes a system of accounts which was devised i n order to f a c i l i t a t e evaluation of alternative plans and projects i n r e l a t i o n to national economic development,  environmental q u a l i t y , regional develop-  ment and s o c i a l 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 t r a d i t i o n a l l y Western Judeo-Christian attitude of arrogance toward nature (White, 1967).  Although others disagree with this sharp d i s t i n c t i o n  between Western and Eastern attitudes (Tuan, 1968), the recent change i n Western public sentiment towards the environment has caused i t s protection to become a major s o c i a l issue i n North America.  Lynton Caldwell (1970)  contends that public r e s p o n s i b i l i t y for environmental quality i n the U.S. evolved from the three s o c i o p o l i t i c a l developments of conservation, public health and public aesthetics.  Each of these s o c i a l movements was separate  i n o r i g i n and h i s t o r i c a l l y matured into increased government influence i n a l l three of these concerns.  These developments  eventually led to major  government r e s p o n s i b i l i t i e s i n other areas of environmental protection. The underlying reasons why government e n t i t i e s are j u s t i f i e d i n  - 10 -  having r e s p o n s i b i l i t y 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 i n their own behalf.  Whereas an environmental conscience  or "land e t h i c " developed and held by a l l individuals i s the most i d e a l solution to environmental p o l l u t i o n , the long period of time i t takes s o c i a l ethics to develop naturally delegates r e s p o n s i b i l i t y to government agencies (Leopold, 1949).  The public nature of environmental effects and the often  adverse s o c i a l consequences  of a person acting to maximize i n d i v i d u a l gain  i s probably best i l l u s t r a t e d i n an a r 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 r a t i o n a l individual tends to maximize personal benefits  i n 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 i n d i v i d u a l l y receives from s e l l i n g the animal are greater than the overgrazing cost which i s distributed to a l l herdsmen sharing the pasture.  I f a l l herdsmen behave  i n a similar r a t i o n a l manner they w i l l each add f i r s t one animal, then another and another u n t i l the carrying capacity of the f i e l d i s surpassed and ruin b e f a l l s each person.  This analogy of the "Tragedy of the Commons"  i s a l l too evident when considering present-day p o l l u t i o n problems and provides the rationale f o r government r e s p o n s i b i l i t y i n achieving and maintaining environmental quality. Changing s o c i a l values have also indicated that there i s an increased desire among the public to influence decisions. true i n environmental quality issues.  This has been e s p e c i a l l y  During the l a t e 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 controversies.  t h e i r members i n environmental  Membership i n large, established organizations also grew  rapidly during t h i s same time period. environmental organizations —  The f i v e largest U.S.  national  the National W i l d l i f e Federation,  the  National Audobon Society, the Sierra Club, the Izaak Walton League of America and the Wilderness Society —  grew i n memberships by almost  i n a period of only one year ending June 1, 1971 Environmental Quality, 1971a).  (U.S.  33%  Council on  As exemplified by the major focus of  the environmental movement, increased p a r t i c i p a t i o n i n decision-making i s desired by members of the public. distinguish the role of perceptions  In a publication which attempts to and attitudes i n natural  resource  policy making, Sewell (1970) mentions: The desire for more d i r e c t involvement i n the decision-making process i s also based upon the e t h i c a l consideration that people have a right to be at l e a s t consulted on decisions that a f f e c t them, and e s p e c i a l l y those which involve the expenditure of public funds or which impinge upon an i n d i v i d u a l ' s r i g h t s . More and more planning decisions, especially those concerned with environment a l q u a l i t y , are of this type i n the resources management f i e l d . The increasing amount of public protest r e l a t i n g to the process of decision-making i n this connection ref l e c t s the d i s s a t i s f a c t i o n with the present means for expressing public views, (p. 125) As the environmental movement grew i n strength during the l a t e 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 p u b l i c l y i d e n t i f i e d themselves as a conservationist bloc (Wheeler, 1972).  The r e s u l t s of  t h i s 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 t h i s thesis i s one component of what i s probably the most s i g n i f i c a n t environmental law passed i n the U.S. during this era of s o c i a l 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 s i x 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 i n t e r d i s c i p l i n a r y approach which includes the preparation of an environmental impact statement on proposals f o r l e g i s l a t i o n and a l l other federal actions s i g n i f i c a n t l y affecting the quality of the environment.  3)  The establishment of the Council of Environmental 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 a s s i s t federal agencies i n f u l f i l l i n g the requirements of NEPA.  The evolution of t h i s law i n Congress during 1969 might indicate that, contrary to the focus of this chapter, the environmental impact statement requirement i n NEPA was not meant to be an important component of this Act.  - 13 -  THE CONGRESSIONAL DEVELOPMENT OF NEPA NEPA was n o t t h e f i r s t n a t i o n a l p o l i c y toward  U.S. l e g i s l a t i v e p r o p o s a l t o e s t a b l i s h a  the environment.  C o n s e r v a t i o n A c t " proposed  I n 1959 "The Resources and  a statement o f n a t i o n a l p o l i c y c o n c e r n i n g  c o n s e r v a t i o n , n a t u r a l r e s o u r c e s and the environment the f o r m a t i o n o f a group  and a l s o recommended  of environmental advisors at a l e v e l s i m i l a r to  the N E P A - e s t a b l i s h e d C o u n c i l on E n v i r o n m e n t a l Q u a l i t y Although t h i s b i l l  and subsequent  (Anderson,  1972).  s i m i l a r attempts d u r i n g t h e mid-1960's  were d e f e a t e d , i n c r e a s i n g p u b l i c support f o r t h e environmental movement induced two l e g i s l a t i v e p u b l i c a t i o n s d u r i n g 1968 which l a i d t h e remaining groundwork f o r NEPA.  These r e p o r t s (U.S. Subcommittee on S c i e n c e , Research  and Development o f t h e House Committee on S c i e n c e and A s t r o n a u t i c s , 1968 and U.S. J o i n t House-Senate C o l l o q u i u m , 1968) noted a l a c k o f c o n s i d e r a t i o n of  environmental f a c t o r s i n governmental  d e c i s i o n - m a k i n g and a l s o  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 t h e environment NEPA i n i t s f i n a l political  (Anderson,  developed  1973).  form was a c t u a l l y the product o f s e v e r a l  compromises and a j o i n t  c o n f e r e n c e was h e l d because  Senate-House c o n f e r e n c e i n 1969.  This  s i m i l a r b i l l s were i n t r o d u c e d and passed i n  the House o f R e p r e s e n t a t i v e s and t h e Senate a t a p p r o x i m a t e l y the same time and then forwarded t o t h e o t h e r branch o f l e g i s l a t u r e f o r a p p r o v a l . Congressman D i n g e l l i n t r o d u c e d t h e b i l l  approved  i n the House w h i l e Senator  Jackson a u t h o r i z e d a b i l l which e v e n t u a l l y became NEPA. to n o t e t h a t n e i t h e r b i l l Federal agencies.  in its initial  It i s interesting  form i n c l u d e d t h e EIS mandate f o r  Congressman D i n g e l l ' s p r o p o s a l was merely  another amend-  ment t o t h e F i s h and W i l d l i f e C o o r d i n a t i o n A c t which would have c r e a t e d t h e C o u n c i l on Environmental Q u a l i t y  (C.E.Q.) and e s t a b l i s h e d a t e r s e  - 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 f o r further environmental research, but did not mention a  policy or "action f o r c i n g " provision although i t was known that he had made e a r l i e r attempts to organize support among h i s colleagues for an environmental policy.  I t has been mentioned that the reason Senator Jackson introduced  such a s i m p l i f i e d b i l l was to ensure that the proposal be sent to h i s Committee on Interior and Insular A f f a i r s for r e v i s i o n rather than to Senator Muskie's Subcommittee on A i r and Water P o l l u t i o n (Anderson, 1973). This seems to be a l i k e l y reason because of Senator Jackson's previous a c t i v i t i e s and also because of the testimony at the subsequent  Senate  Committee hearings of Lynton Caldwell, who often worked with Jackson and his  s t a f f (Andrews, 1972), which noted that a l l federal agencies should  have r e s p o n s i b i l i t i e s i n environmental protection. . This testimony eventually led to the inclusion within this b i l l of the requirement of an environmental impact " f i n d i n g " 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 i n  their respective branch of Congress which set the stage f o r a House conference to coordinate this l e g i s l a t i o n .  The resultant NEPA i s very  similar to Senator Jackson's modified proposal but included a s l i g h t l y weakened national environmental policy and a strengthened impact statement requirement that was intended to force federal agencies to comply with t h i s policy.  It i s the establishment of t h i s policy which can be considered  a culmination of changing s o c i a l values, while the implementation of the "action f o r c i n g " provision might best be viewed as the r e a l i z a t i o n of the f u t i l i t y of a statement of desired national goals without the consideration  - 15  -  of s u f f i c i e n t and adequate information i n the decision-making process. THE RATIONALE FOR REQUIRING ENVIRONMENTAL IMPACT STATEMENTS The previous discussion was  intended to outline the circumstances  important i n influencing the rationale and evolution of the environmental impact statement requirement.  A descriptive review of certain h i s t o r i c a l  aspects of water resources planning shows an increasing d i s s a t i s f a c t i o n with the standard project analysis tool during this time because i t did not comprehensively  i d e n t i f y a l l of the s i g n i f i c a n t benefits and costs  involved with the action.  This r e a l i z a t i o n induced several d i f f e r e n t  attempts i n water resources planning to resolve this problem.  First, a  review process with other government e n t i t i e s having expertise or interest in the project was proposal.  implemented i n order to i d e n t i f y objections to the  It was f e l t that through such a process the diverse interests  r e f l e c t e d by other agencies i n government would define and communicate the adverse effects which were not adequately appraised during project planning. A second alternative attempted  i n water resources planning was to assemble  an i n t e r d i s c i p l i n a r y team to evaluate problems associated with the action. Theoretically this would accomplish the same objective as the previous method but was  economically f e a s i b l e for only large projects because of  the high degree of financing necessary f o r support. adjustment  attempted  A t h i r d evaluative  i n Water Resources Planning was to develop methods f o r  molding non-economic effects into monetary values which could then be introduced into a t r a d i t i o n a l benefit/cost analysis.  The r e s u l t s of t h i s  f i n a l endeavour was the development o f a broad monetary and non-monetary benefit/cost analysis organized i n a system of accounts comprised of  - 16 -  national economic e f f i c i e n c y , regional development, environmental quality and s o c i a l well-being. The environmental movement of the 1960's and 70's focused on increasing government r e s p o n s i b i l i t y i n p o l l u t i o n control.  Powerful public  support of environmental interest groups played an important part i n the magnitude of this influence.  The establishment of a national policy toward  the environment was one major step i n actions aimed at c o n t r o l l i n g environmental degradation i n the U.S.  In order to put teeth into this p o l i c y and  to ensure that unquantifiable environmental amenities be given adequate consideration i n decision-making along with economic factors, a major change i n the federal decision-making process was implemented as one requirement of NEPA.  As a result of i t s h i s t o r i c a l evolution, the main  purpose of an environmental statement as defined by the U.S.  Environmental  Protection Agency (Harris, 1972) i s to: ... disclose the environmental consequences of a proposed action, thus a l e r t i n g the agency decision-maker, the public and ultimately Congress and the President to the environmental r i s k s involved. An important and intended consequence of this i s to b u i l d into a Federal agency's decision-making process a continuing consciousness of environmental considerations. This, i n turn, insures to the f u l l e s t extent possible that the agency direct i t s p o l i c i e s , plans and programs so as to meet national environmental goals. The means through which an environmental impact statement i s to be produced i s by an i n t e r d i s c i p l i n a r y agency impact evaluation team and an extensive public and government review process which includes open hearings i f the action i s deemed of s i g n i f i c a n t importance to the public.  Since i t  i s somewhat misleading i n an analysis to separate a product from the  - 17 -  process which y i e l d s i t , a b r i e f description of the e x i s t i n g EIS process i n the U.S. w i l l be completed before attempting to e s t a b l i s h environmental impact statement standards i n 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 i n a proposed "action" must prepare an environmental assessment report.  An "action" i s defined  as any recommendations or favorable reports r e l a t i n g to l e g i s l a t i o n (including for appropriations), any projects supported i n whole or i n part through federal contracts, grants or any other funding assistance, and any p o l i c y , regulations or procedure making (U.S. Council on Environmental Quality, 1973b). not considered an EIS.  This environmental assessment report i s  I t i s prepared only f o r the purpose of determining  whether an environmental impact statement i s necessary to prepare. In Section 102(2) (c) of NEPA i t i s required that an environmental impact statement be prepared for "... proposals for l e g i s l a t i o n and other maj or federal actions s i g n i f i c a n t l y a f f e c t i n g the quality of the human environment"  (emphasis added).  Thus, the decision of whether to prepare  an EIS completely hinges upon the d e f i n i t i o n of the terms "major" and "significant".  During the i n i t i a l 1 1/4 years NEPA was i n e f f e c t , more  than 30 court cases concerned the a p p l i c a b i l i t y 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 l i k e l y to be highly controversial  and that the agency consider the induced  - 18  and  -  o v e r a l l c u m u l a t i v e impacts of the a c t i o n b e f o r e  significance.  The  defining i t s  g u i d e l i n e s a l s o mention the f o l l o w i n g t h r e e  of what "major" a c t i o n s can be  considered  "significant:"  1)  a c t i o n s which degrade the q u a l i t y of environment;  2)  a c t i o n s 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)  a c t i o n s which serve s h o r t - t e r m to the d i s advantage o f long-term e n v i r o n m e n t a l g o a l s .  Obviously  the  a p r e c i s e d e f i n i t i o n of which a c t i o n s r e q u i r e an EIS  i n a l l respects.  As  descriptors  i s improbable  a r e s u l t , some d i s c r e t i o n remains w i t h the agency  p r o p o s i n g the a c t i o n .  Many f e d e r a l a g e n c i e s have now  developed t h e i r  own  g u i d e l i n e s f o r d i s t i n g u i s h i n g a c t i o n s of s i g n i f i c a n t consequence which r e q u i r e the p r e p a r a t i o n  o f an  I f i t i s decided  EIS.  from the environmental assessment r e p o r t  agency g u i d e l i n e s t h a t an EIS  i s not  r e q u i r e d , the agency can proceed w i t h  the proposed a c t i o n merely by s e n d i n g a n e g a t i v e i n t e r e s t e d agencies, considered  i n d i v i d u a l s and  and  d e c l a r a t i o n form to a l l  i n t e r e s t groups.  I f the a c t i o n i s  s i g n i f i c a n t , the agency must p r e p a r e a d r a f t EIS.  After  c o m p l e t i o n of the d r a f t , i t i s r e q u i r e d t h a t c o p i e s be made a v a i l a b l e to f e d e r a l , s t a t e and comment on i t .  l o c a l agencies,  and  t h a t the p u b l i c be p e r m i t t e d  I t i s a t t h i s p o i n t i n the p r o c e s s t h a t p u b l i c meetings  are h e l d by  the l e a d agency, e x p l a i n i n g b o t h the proposed a c t i o n and  d r a f t EIS.  I t i s then r e q u i r e d  concerning meeting and  to  t h a t no  the p r o j e c t f o r 90 days.  a d m i n i s t r a t i v e a c t i o n be  Based on the r e s u l t s of the  the  taken public  the w r i t t e n comments r e c e i v e d , the agency p r e p a r e s 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 i n d i v i d u a l s , s p e c i a l i n t e r e s t groups and other public agencies. ENVIRONMENTAL IMPACT ASSESSMENTS IN CANADA Although not established as a l e g a l requirement, environmental impact assessments i n Canada have been completed for many large projects having s i g n i f i c a n t impact on the environment i n the past several years. Perhaps one of the most ambitious Canadian impact study attempts began i n 1970 as part of an o v e r a l l project by the Environmental Protection Board aimed at understanding and devising methods to mitigate the environmental effects of constructing and operating a natural gas p i p e l i n e through the Yukon and Northwest T e r r i t o r i e s .  Conversely, environmentally s i g n i f i c a n t  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 i n 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 s o c i a l l y r a t i o n a l decisions concerning proposed actions. In Canada, increasing concern has been expressed l a t e l y about the establishment of a required environmental impact statement process f o r government projects.  A recent workshop on environmental impact  assessments  i n Canada concluded that, although a standard format of environmental impact statement should not be required, a l e g a l framework f o r requiring environmental impact assessments should be established (Environmental Protection Board, 1973).  A major difference from the EIS process i n the U.S. which  - 20 -  has been recommended i n Canada (Environmental Protection Board, 1973 and Maasland et. a l , 1974) i s the establishment of review boards to i d e n t i f y when an environmental impact statement should be prepared for a s p e c i f i c action.  These review boards could exist at the federal and p r o v i n c i a l  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 p a r t i c i p a t i o n by making statements available to interested c i t i z e n s 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 p o l l u t i o n e f f e c t s .  On December 20, 1973, the cabinet announced  that this screening process would be expanded into an Environmental Assessment 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 Assessment Statement.  If i t i s decided by "sound judgement" that the proposal  has " p r a c t i c a l l y no environmental impact", then no preliminary assessment or contact with the Department of Environment i s required. Preliminary Environmental Assessment  If the  Statement i s necessary, i t must be  - 21 -  submitted t o a S c r e e n i n g and C o o r d i n a t i n g Committee t h a t p r e s e n t l y w i t h i n Environment  Canada.  This p r e l i m i n a r y environmental  statement must i n c l u d e t h e f o l l o w i n g seven p o i n t s  exists  assessment  (Canada Department o f  Environment): 1)  a d e s c r i p t i o n o f t h e proposed a c t i o n and i t s purpose;  2)  an assessment o f t h e e x i s t i n g c o n d i t i o n s o f t h e n a t u r a l environment, the renewable r e s o u r c e s and t h e s o c i a l and economic c o n d i t i o n s i n t h e a r e a s u r r o u n d i n g t h e proposed action;  3)  an e s t i m a t e o f t h e impact o f t h e proposed a c t i o n on the n a t u r a l environment, the renewable r e s o u r c e s and the s o c i a l and economic c o n d i t i o n s ;  4)  proposed d e s i g n , c o n s t r u c t i o n and o p e r a t i n g procedures f o r t h e p r o t e c t i o n o r enhancement o f t h e environment;  5)  an assessment o f the long-term secondary impact o f t h e proposed a c t i o n - 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 o p i n i o n as t o whether the p r o j e c t can be c l a s s i f i e d as "major o r h a v i n g s i g n i f i c a n t impact" on the n a t u r a l environment, renewable r e s o u r c e s and on the human environment, o r , on t h e o t h e r hand, as minor o r n o t h a v i n g s i g n i f i c a n t impact (pp. 6,7)  In t h e event t h a t the proponent  d e c i d e s through t h i s assessment  that the  p r o j e c t i s minor o r w i t h i n s i g n i f i c a n t impact and i f t h e S c r e e n i n g and C o o r d i n a t i n g Committee agrees w i t h t h i s c o n c l u s i o n , then t h e p r o c e s s ends and the p r o j e c t i s a l l o w e d t o p r o g r e s s w i t h o u t d e l a y . c o n c l u s i o n i s reached by the proponent  I f the opposite  o r the S c r e e n i n g and C o o r d i n a t i n g  Committee d i s a g r e e s o r expresses doubt w i t h t h i s d e c i s i o n , t h e p r e l i m i n a r y assessment  w i l l be passed t o t h e newly e s t a b l i s h e d "Environmental A s s e s s -  ment P a n e l " which  i s comprised o f members o f Environment  member o f t h e p r o p o s i n g e n t i t y .  Canada and one  T h i s p a n e l has the f o l l o w i n g f i v e  functions  - 22 -  (Canada Department of Environment,  1974):  1)  defining requirements i n respect of general "base l i n e " environmental conditions f o r areas i n 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 Coordinating Committee and advising on what, i f any, future action i s required;  4)  managing, on behalf of the Minister of the Environment, the preparation and review of formal, detailed environmental assessments and prediction statements;  5)  a s s i s t i n g the proponent i n the incorporation of environmental design and procedures to implement i t s findings. (P- 8)  If the project i s "major" or has " s i g n i f i c a n t " impact a more formal and comprehensive  environmental assessment  the d i r e c t i o n of the new panel. environmental assessment  statement must be prepared under  Based upon this more  comprehensive  statement, the panel can recommend that the  proposal not be undertaken, request further studies or recommend a l t e r 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 i n r e l a t i o n to these re-  commendations remains with the proposing entity.  In some cases, p r o v i n c i a l  interests can be represented on the existing panel or a special panel including members of the public with expertise i n some f i e l d can be established f o r review purposes.  This impact assessment  and review  process also allows for public hearings i f decided by the panel.  I t also  requires that, unless " i n the unusual event that ... the usefulness of the  - 23 -  proposed a c t i o n or the environment i t s e l f may  be j e o p a r d i z e d by premature  d i s c l o s u r e " , copies' o f a l l p r e l i m i n a r y and formal  e n v i r o n m e n t a l assessment  statements be made a v a i l a b l e to the p u b l i c (Canada Department ment, 1974).  of E n v i r o n -  chapter two establishing criteria for evaluating environmental impact statements INTRODUCTION  D e v e l o p i n g requirements t h a t p e r t a i n t o a l l p o s s i b l e which may r e q u i r e an EIS i s a d i f f i c u l t but worthy t a s k . ments must be g e n e r a l meriting  actions  These r e q u i r e -  enough t o address a wide range o f a c t i o n s  presently  an environmental e v a l u a t i o n , whether t h e development o f s m a l l  campground near an u r b a n i z e d of l a r g e dams along  a r e a o r t h e proposed c o n s t r u c t i o n o f a s e r i e s  a n a t u r a l , f r e e - f l o w i n g watershed.  C o n v e r s e l y , EIS  requirements must be s p e c i f i c enough f o r m e a n i n g f u l use i n e v a l u a t i n g whether an impact statement has achieved i n t h i s respect  i t s purpose.  I t i s also r e a l i z e d  t h a t the r e l a t i v e magnitude and importance o f an a c t i o n  i n f l u e n c e s t h e extent  to which i t i s e c o n o m i c a l l y  f e a s i b l e to i d e n t i f y the  complex c h a i n o f p o t e n t i a l e f f e c t s (see d i s c u s s i o n below d e f i n i n g mental  environ-  impact). The  requirements s e t f o r t h i n t h i s chapter a r e based upon the  purposes o f an E I S , a d e f i n i t i o n o f t h e term "environmental impact", e x i s t i n g general  requirements e s t a b l i s h e d by the U.S. C o u n c i l on E n v i r o n -  mental Q u a l i t y and s e v e r a l c o u r t d e c i s i o n s r e l a t i n g t o NEPA. summary c o n c l u s i o n w i l l into a l i s t evaluate  then c o n c i s e l y o r g a n i z e  the previous  A final discussion  o f 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 t h e s i s to  t h e adequacy of s e v e r a l impact  - 2U -  statements.  - 25 -  WHAT IS ENVIRONMENTAL IMPACT? The foundation for developing requirements for environmental statements i s a very broad d e f i n i t i o n of the term "environment"  itself.  Often, the meaning of the terms environment and ecology have been confused with one another.  The following d i s t i n c t i o n 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 i s the r e f e r ence to a s p e c i f i c organism such as man, a f i s h species, etc. Ecology i s the study of mutual r e l a t i o n ships between organisms and their environment. Hence, "environmental q u a l i t y " or "environmental impacts" i s usually associated with direct reference to man. (p. 32) This broad d e f i n i t i o n of "environment" has generally been supported by j u d i c i a l rulings.  In Daly v. Volpe (U.S. Court of Appeals, 1972a) i t was  rules f o r 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. D i s t r i c t Court,  1971a) ruled that an EIS concerning a proposed dam was not adequate u n t i l zoological studies were completed i n 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 s o c i a l and c u l t u r a l features (U.S. Army Corps of Engineers, 1972; U.S. Dept. of the Navy, 1970; et a l . ) .  As a r e s u l t , the expression 'environmental impact' has a  meaning wide i n scope, r e f e r r i n g to the economic, ecological and socio/ c u l t u r a l external conditions affected by a proposed action.  A hierarchical  T  26 -  ordering of a wide range of potential environmental effects i s given i n Figure One. Not only are the prospective environmental effects of an action extremely broad i n character, but the relationships that exist between d i f f e r e n t components of the environment make i t impossible to completely i d e n t i f y a l l of the potential impacts.  Environmental impacts result i n  secondary effects which further r e s u l t i n t e r t i a r y impacts (Sorensen, 1972).  For example, i t may seem that the effects of developing a mount-  ainous area for winter s k i i n g are rather obvious.  Some of these more  conspicuous impacts include the effects of construction on s o i l s and vegetation, and the resultant multiple-order consequences on w i l d l i f e and water quality nearby.  Also, i n addition to these primary, physical  and b i o l o g i c a l e f f e c t s , the action may also result i n economic and other more subtle impacts such as an improved economy i n nearby towns, induced secondary commercial development which accompanies  such growth, an i n -  creased l o c a l permanent and transient population, and even the p o s s i b i l i t y of a t t r a c t i n g other entrepreneurs i n the development homesites.  of recreational  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, b i o l o g i c a l and s o c i a l implications.  Therefore, i t  can be e a s i l y realized that the analysis of environmental impact does not merely involve calculating a simple cause and effect r e l a t i o n s h i p , but i t also involves following a complex chain of cause/immediate  effects/conse-  quential effects/induced e f f e c t s , etc., interconnections that can often r e s u l t i n what seems to be a never-ending stream of environmental impacts.  ENVIRONMENTAL IMPACTS Ecology  Environmental Quality | |- Aesthetics  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  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 Air Pollution Carbon monoxide Hydrocarbons Nitrogen oxides Particulate matter Photochemical oxidants Sulfur oxides Other Land Pollution Land Use Soil erosion Noise Pollution Noise  FIGURE I I - l .  IL Human Interest  Land Geological surface material Relief and topographic character Width and alignment  Ed u ca tion /Scien tific Archeological Ecological Geological Hydrological  Air Odor and visual Sounds  Historical Architecture and styles Events Persons Religions and cultures "Western Frontier"  Water Appearance of water Land and water interface Odor and floating materials Water surface area Wooded and geological shoreline  Cultures Indians Other ethnic groups Religious groups  Biota Animals - domestic Animals - wild Diversity of vegetation types Variety within vegetation types  Mood/Atmosphere Awe-inspiration Isolation/solitude Mystery "Oneness" with nature  Man-made Objects Man-made objects  Life Patterns Employment opportunities Housing Social interactions  Composite Composite effect Unique composition  An arrangement o f the wide scope of p o t e n t i a l environmental impacts (fxom U.S. Army Corps o f Engineers, 1972 and Dee e t . a l , 1972}  - 28 -  Hence, what must b a s i c a l l y be decided i s what environmental impacts should be included i n an EIS.  As discussed e a r l i e r i n chapter one, this  i s presently a function of government agency guidelines, the s i z e and importance of an action and a variable amount of d i s c r e t i o n on the part of the e n t i t y undertaking the project.  THE ROLE OF THE EIS IN DECISION-MAKING Clearly, the previous discussions indicate that ah EIS should be broad i n scope, communicating the expected economic, s o c i o / c u l t u r a l , phys i c a l and b i o l o g i c a l consequences of the action/s to the public and decision-makers.  I t must be assumed at this point that decisions w i l l be  made which r e f l e c t the information that has been generated i n 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 i s 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 r e t a i n a certain degree of o b j e c t i v i t y , the EIS requirements i n 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 f i v e general areas of concern: (i) the environmental impact of the proposed action;  - 29 -  (ii)  (iii) (iv)  (v)  any adverse environmental effects which cannot be avoided should the proposal be implemented; alternatives to the proposed action; the relationship between l o c a l short-term uses of man's environment and the maintenance and enhancement of long-term productivity; and any 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 which would be involved with the proposed action should i t be implemented.  The Council on Environmental Quality established guidelines f o r a l l federal departments, agencies and establishments the general requirements of NEPA.  i n order to implement  Most federal departments and agencies  within these departments have also developed t h e i r 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 t h i s study to describe the e x i s t i n g required contents of an EIS i n 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 i n the i n i t i a l section of the report should  describe  the action i n 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 i n 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 t h e i r 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 e x i s t i n g area affected by the action i s a necessary part of an environmental statement.  This section should be  b r i e f rather than detailed, although the amount of d e t a i l i s dependent on the magnitude of the action and the amount of the information required at that l e v e l of decision-making (planning, f e a s i b i l i t y , design, e t c . ) . The guidelines e s p e c i a l l y mention that accurate population and growth data, including an i d e n t i f i c a t i o n of assumptions from which j u s t i f i c a t i o n f o r the project e x i s t s , should be included i n t h i s part of an EIS.  Environmental Impact of the Proposed Action It i s required that an agency consider the p o s i t i v e and negative national and international effects of the proposed action i n this section of an environmental statement.  The "nature, scale and l o c a t i o n of the  proposed actions" and the r e l a t i v e 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 p o t e n t i a l impacts i n an EIS.  The following (adapted) l i s t i s included i n the guide-  l i n e s to i l l u s t r a t e factors of the environment which might deserve consideration i n this section: 1) 2) 3) 4) 5)  Air Energy Hazardous Substances Land Use and Management Noise  6) 7) 8) 9) 10)  Psychological Health and Well-being Transportation Urban Factors Water Wildlife  Not only primary but also secondary environmental impacts should be included i n 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 s i g n i f i c a n t as the action's "induced" impacts, and thus the l a t t e r type of e f f e c t s also should be considered i n 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 concerning the consideration of alternatives i n an EIS. These guidelines mention that the environmental benefits and costs of a l l "reasonable" alternative actions should be i d e n t i f i e d "... i n order not to foreclose prematurely options which might have less detrimental e f f e c t s . " The alternatives considered  should not be l i m i t e d only to those which can be  undertaken by the proposing agency, and the analysis of each a l t e r n a t i v e should be a "rigorous exploration and objective evaluation" of i t s environmental impacts.  Examples of alternatives which might deserve  consideration include":'  the alternative of no action or postponement  pending further study; alternatives of a completely d i f f e r e n t character which achieve s i m i l a r objectives as the proposed project; and alternatives related to d i f f e r e n t designs or changed components of the e x i s t i n g proposal which would r e s u l t i n d i f f e r e n t environmental e f f e c t s .  This analysis of  alternatives should be detailed enough to i d e n t i f y the tradeoffs that exist between options.  Unavoidable Adverse Effects This section should be a b r i e f 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 p o l l u t i o n , 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 i n NEPA.  I t i s also mentioned that for purposes of contrast a  discussion of impact mitigation measures which are part of the proposed action be included i n 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 s p e c i f i c time periods, i t i s necessary that an impact statement b r i e f l y define the differences i n the  proposal between "short-term gains at the expense of long-term loses,  or v i c e versa." I r r e v e r s i b l e or I r r e t r i e v a b l e Commitments of Resources The basic d i s t i n c t i o n made between this section and the previous requirement i s that this part of an impact statement should i d e n t i f y the "range of potential uses of the environment" which are i r r e v e r s i b l y e l i m i nated due to the unavoidable adverse e f f e c t s of the intended action.  The  term "resources" i s defined not only as economic factors but also as natural and c u l t u r a l resources. ENVIRONMENTAL IMPACT STATEMENTS AND THE COURTS The rapid and growing case law associated with the National Environmental Policy Act has been quite remarkable since, i n 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 adjudications 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 f o r a l l major federal actions s i g n i f i c a n t l y affecting the quality of the human environment.  As of A p r i l , 1972, only 5 of 64 cases before the courts r e l a t i n g  to NEPA were i n reference to the content of environmental impact statements (Young and Henson, 1973). Perhaps the most important r u l i n g of the courts was b r i e f l y d i s cussed e a r l i e r concerning the broad d e f i n i t i o n of the term  "environment."  An environmental impact statement must consider a l l components of the "human environment" including physical, b i o l o g i c a l , economic and socioc u l t u r a l factors.  In Environmental Defense Fund v. The U.S. Army Corps of  Engineers (U.S. D i s t r i c t Court, 1971a), the court mentioned that the environmental statement concerning a proposed dam should have described the relevant e x i s t i n g food chains and e c o l o g i c a l l y v i t a l species i n the affected area i n order to l a t e r determine the d i v e r s i t y and r e l a t i v e biol o g i c a l s t a b i l i t y of the area.  The court also mentioned d e f i n i t e questions  which were l e f t unanswered i n the report r e l a t i n g to s p e c i f i c adverse consequences which could be p o t e n t i a l l y caused by the existence of the dam and to possibly induced population changes which also have related environmental e f f e c t s .  Conversely, the courts have also ruled that i n many  situations s p e c i f i c factors such as species names and s p e c i f i c archaelogical s i t e s need not be mentioned i n an EIS (U.S. D i s t r i c t Court, 1971b).  - 34 -  Adjudications d i f f e r e n t opinions  i n c o u r t have mentioned the need to  i n v a l u i n g environmental e f f e c t s .  d e f i n e d i n the G i l l h a m Dam t h a t a f i n a l EIS  case (U.S.  D i s t r i c t Court,  i n c l u d e the v i e w p o i n t s  consider  T h i s has  been  1971a) to r e q u i r e  of a l l members i n s o c i e t y  l e s s of t h e i r t e c h n i c a l e x p e r t i s e or membership i n an o r g a n i z e d In the Committee f o r N u c l e a r R e s p o n s i b i l i t y v. Seaborg Appeals, 1971)  moderated to ensure t h a t the q u a l i t y of i n f o r m a t i o n  EIS  remains h i g h .  group.  Court of  t h i s r e q u i s i t e to c o n s i d e r the opposing o p i n i o n s  was  of  others  generated i n an  However, t h i s c a s e a l s o r e q u i r e d t h a t a l l " r e s p o n s i b l e "  views must be  i n c l u d e d i n an impact statement and  be  as  considered  (U.S.  regard-  that s c i e n t i f i c  opinion  follows:  ...The c o u r t i s not to r u l e on the r e l a t i v e m e r i t s of competing s c i e n t i f i c o p i n i o n . Its function i s o n l y to assure t h a t the statement s e t s f o r t h the o p p o s i n g s c i e n t i f i c o p i n i o n and does not take the a r b i t r a r y and impermissable approach of o m i t t i n g from the statement, and hence from the focus t h a t the statement was intended to p r o v i d e f o r the d e c i d i n g o f f i c i a l s , any r e f e r e n c e whatever to the e x i s t e n c e of r e s p o n s i b l e s c i e n t i f i c o p i n i o n s conc e r n i n g p o s s i b l e adverse environmental e f f e c t s .  ESTABLISHING IMPROVED STANDARDS FOR  The  IMPACT STATEMENTS  C o u n c i l on Environmental Q u a l i t y ' s r e v i s e d EIS  c o n t a i n content  recommendations which d e f i n i t e l y should be  e n v i r o n m e n t a l statements. commendations c o u l d be  a r e a s of concern i n an EIS  included i n a l l  I t i s the o p i n i o n of the author t h a t t h e s e r e -  improved to p r o v i d e more guidance to  responsible for preparing  guidelines  entities  environmental statements because many important are p r e s e n t l y addressed by  l e v e l of g e n e r a l i t y t h a t makes these s u g g e s t i o n s  the g u i d e l i n e s at a  somewhat u n c l e a r .  General  - 35 -  suggestions are appropriate concerning a description of the proposed action and perhaps environmental setting, but such recommendations are not as h e l p f u l as could be i n r e l a t i o n to the type of environmental effects which should be considered and the evaluation of i d e n t i f i e d impacts.  By  rearranging these established guidelines, providing more s p e c i f i c recommendations i n 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 i s 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 r e l a t i o n  to considering the actual environmental effects of a proposal i t might be h e l p f u l 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 d i r e c t 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 r e l a t i v e l y d i s t i n c t from one another i n that d i f f e r e n t d i s c i p l i n e s of knowledge can be isolated within each category.  These three categories are economic e f f i c i e n c y , socio-  c u l t u r a l impacts, and ecological impacts. ECONOMIC EFFICIENCY In the past, the economic e f f i c i e n c y of a proposal has been  - 36 -  perhaps the most intensively considered actions.  consequence of public and private  As mentioned i n chapter one, benefit/cost analysis has been  required for federal water resources projects i n the U.S. since the Flood Control Act of 1936 and i t s use continues to t h i s day as the best  planning  tool to compute the economic e f f i c i e n c y of a large public project. It has been stressed throughout this chapter that the purpose of an EIS and a broad d e f i n i t i o n of the term 'environmental impact' requires that such a report also include a complete disclosure of the economic e f f i c i e n c y of the action.  In Environmental Defense Fund v. Armstrong,  the opinion was stated that a benefit/cost analysis i s not needed i n an impact statement.  A basic reasoning behind this opinion i s the w e l l -  founded fear that many agencies are dominated by economic interests which might result i n the development of impact statements used to j u s t i f y s o c i a l and ecological costs by an impressive and complicated analysis of monetary gains.  On the contrary, i t i s the opinion of the author that  delegating the EIS to a r o l e of 'just another report' of s p e c i f i c scope would only make the decision-making process more cumbersome and not r e a l l y function to generate the information  about an action i n s i n g l e , concise  statement so that the public and decision-makers can reach an informed, r a t i o n a l judgement about the proposal.  In Lathan v. Volpe a U.S. D i s t -  r i c t Court (1972a) agreed with this viewpoint by r u l i n g that a benefit/ cost analysis i s a very legitimate component of an EIS. opinion was also expressed i n the Gillham Dan case.  A similar  Consequently, i t i s  f e l t that the review process, the establishment of EIS standards and other factors can combine to place an economic analysis i n an impact statement on more equal terms with s o c i o - c u l t u r a l and ecological  - 37 -  considerations.  It i s also important that a l l major assumptions i n the  economic analysis be disclosed i n an EIS so that the reader r e a l i z e s the foundation are projected  impacts.  Perhaps the most important action i n analyzing the economic e f f i c i e n c y of a project i s i n taking a proper accounting stance. concept i s probably best explained  This  as an entity's outlook toward the  benefits and costs of a proposed action.  For example, the economic  benefit/cost r a t i o of a federal water project to a l o c a l p o l i t i c i a n i s d i f f e r e n t than to the nation as a whole since h i s l o c a l viewpoint (accounting stance) emanates from his constituency. l e v e l of government has i t s own  As a r e s u l t each  accounting stance concerning the  dence of these economic effects (Howe, 1971).  Although i t may  inci-  seem that  the analysis of economic e f f i c i e n c y i n an impact statement should address i t s e l f to the government l e v e l / s ( i . e . , l o c a l , P r o v i n c i a l or  State,  Federal) financing the action, problems can arise i f adverse economic effects extend beyond the j u r i s d i c t i o n of the government financing action.  Thus, an economic analysis i n an EIS should take an accounting  stance that i s most relevant to the prospective  action.  In many cases  these monetary impacts have to be considered at a national or even i n t e r national l e v e l . Although i t i s not meant to include guidelines for  preparation  of benefit/cost analysis i n t h i s paper, since i t i s urged that t h i s method of analysis be used i n considering  the economic e f f i c i e n c y of a  project i n an EIS, a few simple points concerning benefit and cost c a l 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 i n the affected  - 38  areas with and without the project.  -  Second, i f the market i s running  smoothly (e.g., f u l l employment, competitive  market prices, etc.)  the  proper measure of a benefit i s by the calculated willingness to pay for the benefit through actual or simulated  market prices.  Similarly, i f  the market i s running smoothly a l l economic costs should be measured by the opportunities foregone i n u t i l i z i n g resources (e.g., labor, c a p i t a l ) 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 i s decided to value secondary benefits or costs. It has been recommended that i f a national accounting stance i s 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 costs w i l l l i k e l y o f f s e t one another (Howe, 1971).  and  Fourth, r i s k and  uncertainty must be taken into account i n a benefit/cost analysis. can be considered  Risk  the p r o b a b i l i t y d i s t r i b u t i o n of some e f f e c t while un-  certainty implies ignorance of even a range of p r o b a b i l i t y (Pearce, 1971).  Hence, r i s k and uncertainty must be treated d i f f e r e n t l y before  values are assigned i n a benefit/cost analysis.  The f i f t h and  final  comment about benefit/cost analysis i s that the period of economic l i f e of the project and the s o c i a l discount to standardized the U.S.  methods.  rate should be chosen according  For example, the Water Resources Council i n  determines a discount rate every June for use i n federal water  projects and also recommends that the period of economic analysis used i n water resources planning  i s 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 e f f i c i e n c y c r i t e r i o n i n that i n d i v i d u a l impacts within each cannot be consistently reduced to a common denominator f o r valuation such as money. determined i n two ways.  The value of an environmental effect can be F i 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 e f f i c i e n c y value of an action i s quantitatively expressed i n a r a t i o of monetary terms.  Although the importance value of  money i s different to everyone, i t i s commonly accepted that i f the monetary benefits of an action exceed i t s monetary costs (or, depending upon the existence of a r a t i o c r i t e r i o n such as 1.2/1.) the project can be considered economically e f f i c i e n t i f the analysis has been correctly completed.  When considering ecological and s o c i o - c u l t u r a l effects i t i s  d i f f i c u l t to define the s o c i a l worth of an action because there i s no common unit f o r 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 magnitude of the project effects.  A l b e i t such quantitative assessments  are  not readily comparable among one another, these estimates do i d e n t i f y  the  extensiveness of an impact and hence assign some value to that  effect. The second manner i n which value can be assigned to environmental impacts i s through a q u a l i t a t i v e description of the expected  - 40 -  consequences.  I t might.be s t a t e d , f o r example, t h a t t r o u t have more  s o c i a l importance than carp because  o f the commonly known r e l a t i v e  v a l u e p e o p l e p l a c e upon each s p e c i e s .  However, a c l e a r s o c i a l  prefer-  ence cannot be d i s t i n g u i s h e d between many o t h e r e n v i r o n m e n t a l e f f e c t s such as economic c o s t and h e a l t h and s a f e t y .  As a r e s u l t , i t i s recom-  mended t h a t , i n c o n j u n c t i o n w i t h q u a n t i t a t i v e e s t i m a t e s and descriptions  qualifying  (when a p p l i c a b l e ) , the f o l l o w i n g f o u r c o n s i d e r a t i o n s s h o u l d  be used to h e l p i d e n t i f y to persons r e a d i n g an EIS the s o c i a l of an environmental  importance  impact:  1)  the r i s k o r u n c e r t a i n t y 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 u n a v o i d a b l e 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 r e s p o n s i b l e o p i n i o n s h e l d i n s o c i e t y c o n c e r n i n g the consequences o f the impact;  4)  the r e l a t i o n s h i p between s h o r t - t e r m r e s o u r c e uses and long-term adverse e f f e c t s .  As mentioned  e a r l i e r concerning b e n e f i t / c o s t a n a l y s i s , r i s k  u n c e r t a i n t y i s n e c e s s a r y i n an EIS to i d e n t i f y the r e l a t i v e of e f f e c t o c c u r r e n c e .  and  probability  When u n c e r t a i n t y o c c u r s i n p r e p a r i n g an EIS, a  d e c i s i o n must be made whether to undertake s t u d i e s to reduce the uncert a i n t i e s or to merely acknowledge i n the impact statement t h a t consequences  of the a c t i o n are not known.  No consensus  i n U.S.  certain Courts  has been reached c o n c e r n i n g which a l t e r n a t i v e i s b e s t f o r d i f f e r e n t a c t i o n s anddimpacts,  but a t the v e r y l e a s t i t has been r e q u i r e d  u n c e r t a i n t i e s 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,  that  1971a).  S i m i l a r l y , when the r i s k o f an e f f e c t o c c u r r e n c e i s known, i n c l u d i n g the p r o b a b i l i t y f i g u r e i n the statement  can h e l p v a l u e the p o t e n t i a l  - 41 -  impact f o r the reader. Identifying i n an impact statement the relationship between mitigation measures and unavoidable adverse effects provides a broad open view of an entity's previously i m p l i c i t economic valuation of the impacts of an intended action.  This could i d e a l l y be accomplished by  l i s t i n g a l l s i g n i f i c a n t environmental impacts, the cost of reducing the intensity of each e f f e c t , whether and by how much each adverse e f f e c t i s being reduced, and a d i s t i n c t i o n between the impacts which cannot be avoided or reduced i n i n t e n s i t y . The judgements made i n evaluating an environmental impact should be recognized i n an EIS.  I t i s extremely simple to provide a biased  q u a l i t a t i v e view of the value of an e f f e c t , but i t i s much more meaningf u l to give a range of values society would assign to this impact.  As  mentioned e a r l i e r , the courts have also recognized the necessity of considering d i f f e r e n t 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 i n an impact report, the  reader i s aided to use h i s own judgement i n reaching an informed decision concerning the proposal. The Council on Environmental Quality's revised 1973 guidelines make very l i t t l e d i s t i n c t i o n between " i r r e v e r s i b l e commitments of r e 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 i s exemplified by EIS recommendations developed by the U.S. Environmental Protection Agency i n 1973. In reference to "the relationship between short-term ... etc." the  - 42  -  E.P.A. recommendations state that "... the d e s i r a b i l i t y of agency actions s h a l l be weighed to guard against short-sighted foreclosure of options or needs.  Special attention s h a l l be given to e f f e c t s which  narrow the range of b e n e f i c i a l uses of the environment ... ."  On  the  contrary, the Council on Environmental Quality recommend that i n the " i r r e v e r s i b l e or i r r e t r i e v a b l e commitments ..." section that the agency i d e n t i f y " . . . the extent to which the action i r r e v e r s i b l y c u r t a i l s the range of p o t e n t i a l uses of the environment." approximately the same suggestion  The E.P.A. also restates  for this l a t t e r section.  As a r e s u l t  of the vague d i s t i n c t i o n that i s made between these two sections there seems to be no reason why  they should be i s o l a t e d from one another,  although the importance i s recognized of including a discussion of the long-term impacts and curtailment of future options i n an environmental statement.  I t i s also h e l p f u l i n an EIS that the time span for each  effect be i d e n t i f i e d and that a b r i e f discussion be completed  concerning  the t o t a l consequences of an action on the d i v e r s i t y of future human uses of the environment (e.g., the e f f e c t on renewable and non-renewable resources, e t c . ) .  The discussion of long-term effhcts should also i n -  clude the p o t e n t i a l inducement consequences of an intended  action.  The previous f i v e factors have been described i n an attempt to help value the predicted tangible and intangible environmental consequences of a proposal.  Although these considerations do not e s t a b l i s h  a common unit for comparing b e n e f i c i a l and adverse impacts, information i s provided  to persons reading the EIS i n order to f a c i l i t a t e i n d i v i d u a l  decisions about each impact and thus the entire action.  - 43 -  SOCIO-CULTURAL IMPACTS A second category of environmental impacts can be isolated into s o c i a l and c u l t u r a l d i s c i p l i n e s of knowledge.  I t i s somewhat d i f f i c u l t  to conceive of physical or b i o l o g i c a l impacts as being separate from s o c i a l effects because a l l environmental impacts included i n an EIS a f f e c t humans i n one way or another.  Since the object of this analysis  i s to simplify the process of preparing an environmental report, these categories r e f l e c t environmental impacts at the stage immediately preceding 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 i d e n t i f i c a t i o n and i n c l u s i o n i n an EIS, but i n toto these impacts are connected and i n t e r r e l a t e d with one another. ECOEOGICAL IMPACTS Ecological effects can be further subdivided into natural phys i c a l and natural b i o l o g i c a l impacts.  Natural physical features which  must be considered include land form, non-renewable resources, s o i l s , water, climate and a i r . The effects of a proposed action on the plants, animals and microscopic organisms i n an: area should be disclosed i n an environmental statement.  These impacts can be quantified by l i s t i n g numbers of or-  ganisms by species and also q u a l i f i e d by describing i t s uniqueness, endangered status, or human importance.  Further valuation of the  action's b i o l o g i c a l impacts should, as i n the preceding s o c i o i c u l t u r a l category, be accomplished by the four factors previously discussed.  - 44 -  One danger i n categorizing environmental impacts under separate headings i s that the i n d i v i d u a l r e s u l t s are i s o l a t e d 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 t o t a l 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 i d e n t i f y i n g i n t e r r e l a t i o n ships that exist between organisms and their environment.  This i n t e r -  dependence between l i v i n g and non-living systems suggests that, when applicable, several ecological concepts deserve discussion i n an EIS. These important concepts concern system i n t e r r e l a t i o n s h i p s (physical/ b i o t i c , man/nature), food chains, biogeochemical c y c l i n g , energy flow, l i m i t i n g factors and systems d i v e r s i t y i n the areas affected by the intended  project.  DISTRIBUTIONAL CONSEQUENCES The r e s u l t s of an action are 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 e f f e c t s to d i f f e r e n t people, groups and areas.  Individual  judgements as to the r e l a t i v e s o c i a l worth of an action might be f a c i l i tated by i d e n t i f y i n g the incidence of these environmental benefits and costs on d i f f e r e n t groups and regions.  In a publication i d e n t i f y i n g  issues i n need of consideration i n Public Water Resources Planning, Bromley et. a l . (1971) mention the necessity of considering d i s t r i b u t i o n consequences i n project evaluation. The t r a d i t i o n a l view that benefits and costs have meaning only i n r e l a t i o n to a s p e c i f i e d objective i s perhaps best replaced by the notion that benefits and costs have meaning only i n r e l a t i o n to s p e c i f i e d individuals who perceive such impacts. Obviously i t  - 45 -  i s impossible to be concerned with "benefits and costs" to each i n d i v i d u a l so the problem can be altered s l i g h t l y to discuss individuals i n their multiple roles as taxpayers, r e c r e a t i o n i s t s , labor suppliers, entrepreneurs, consumers, etc. When considering l o c a t i o n - s p e c i f i c impacts — say within a project region — i t i s useful to a r t i c u l a t e project impacts by s p e c i f i c groups upon which these effects impinge. ... (p.34) Thus, i n order for an EIS to appropriately "disclose the environmental consequences" of a proposed action to the public and decision-makers i t i s necessary that the d i s t r i b u t i o n of economic, s o c i o - c u l t u r a l , physical and b i o l o g i c a l benefits and costs to groups and areas be included i n 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 b e n e f i c i a l and adverse environmental consequences of a range of choices which have similar ultimate objectives as the proposed action.  This consideration  was included d i r e c t l y i n 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. D i s t r i c t Court, 1972b, et a l . ) . Indeed, the importance of an adequate description of alternatives has been mentioned i n the courts as one of two main parts of an EIS that are the object of j u d i c i a l review when determining whether an EIS complies with NEPA (Anderson, 1973).  As a r e s u l t , the revised C.E.Q. guidelines have ex-  panded these recommendations on alternatives evaluation to include a broad range of p o t e n t i a l choices including the choice of "no action". It should be further noted, however, that the consideration of  - 46 -  alternatives should be broad i n scope rather than exhaustive because of the almost interminable number of choices available to achieve most objectives.  Nevertheless, i n 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 i s best accomplished i n an EIS by iden-  t i f y i n g the trade-offs between a l t e r n a t i v e options and the proposed project for the reader. RELATIONSHIP TO ESTABLISHED GOALS A major purpose of formal community and regional planning organizations i s to synthesize the needs and aspirations of l o c a l c i t i z e n s into goals, objectives and p o l i c i e s to be u t i l i z e d i n the future planning of the area.  This purpose i s 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 c i t i z e n input.  Since the awareness of the public i s 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 s i g n i f i c a n t actions requiring environmental impact statements.  The existing  EIS process i n 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 l a t e i n 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 r e f l e c t a l o c a l area's needs  - 47 -  and desires, i f such a formal l o c a l expression of the future exists i n an area i t i s 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 e x i s t i n g l o c a l plans i n f a c i l i tating environmental impact evaluation: An e f f e c t i v e procedure for evaluation i s to determine 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 i d e n t i f i e d and expressed i t s c o l l e c t i v e goals i n a community plan, then the impact statement can be evaluated i n terms of i t s r e l a t i o n s h i p to the existing planning program. (p. 26) COMMUNICATION OF INFORMATION Since the purpose of an EIS i s to generate information to the general public and decision-makers whereby each i n d i v i d u a l can reach an informed r a t i o n a l decision concerning  an action, i t i s quite apparent  that the information must be communicated i n 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 e f f o r t to convey the required information succinctly i n a form e a s i l y understood, both by members of the public and by public decision-makers... ."  In order to help persons  judge the s o c i a l worth of an action, the rationale for proposing the project and a summary should also be included i n an EIS.  A concise  l o g i c a l l y organized EIS that i s written i n informal language comprehensible to the ordinary layman w i l l enhance public p a r t i c i p a t i o n and r a t i o n a l 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 t o t a l consequences of a proposed action i n order to f a c i l i t a t e a l l interested persons and decision-makers to i n d i v i d u a l l y 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 r e quirement and s i m i l a r l y vague early 1971 Council on Environmental Quality guidelines induced a large number of adjudications i n court.  Based upon  the results of these court cases, the r o l e of environmental impact statements i n decision-making, and the revised 1973 C..E.Q. guidelines, the following recommendations are outlined as standards which a l l environmental 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 i s also based upon a thorough knowledge of the proposed project and existing environmental conditions i n the area(s) affected by the action.  It i s  necessary that an environmental impact statement include the follow-  - 49 -  ing  II.  three  considerations:  A.  A d e s c r i p t i o n of a l l p r o j e c t a c t i o n s r e l a t i n g to the p r o p o s a l which w i l l r e s u l t i n e n v i r o n m e n t a l impacts.  B.  A c a r e f u l d e l i n e a t i o n of the a f f e c t e d by the a c t i o n ( s ) .  C.  A d i s c u s s i o n o f the e n v i r o n m e n t a l components which w i l l l i k e l y be a f f e c t e d by the p r o p o s a l .  be  Economic E f f i c i e n c y One  component of the human environment t h a t deserves thorough  treatment i n an EIS  i s an a c t i o n ' s  measurement of b e n e f i t s and  III.  study a r e a which w i l l  economic e f f i c i e n c y through  costs.  A.  A l l assumptions which p r o v i d e the b a s i s f o r the a n a l y s i s s h o u l d be l i s t e d .  B.  S t a n d a r d i z e d consensus b e n e f i t / c o s t s h o u l d be f o l l o w e d .  Socio-Cultural  economic  a n a l y s i s procedures  Impacts  I f an i n t e n d e d a c t i o n has  important e f f e c t s on e x i s t i n g  f u t u r f u t u r e s o c i o - c u l t u r a l e n v i r o n m e n t a l f a c t o r s , i t s h o u l d be l y described The  q u a n t i t a t i v e l y (when p e r t i n e n t )  following considerations  help  the reader a s s i g n  s h o u l d a l s o be  and thorough-  and q u a l i t a t i v e l y . included  i n an EIS  to  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 o r u n c e r t a i n t y  o f 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 u n a v o i d a b l e 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 r e s p o n s i b l e i n s o c i e t y c o n c e r n i n g 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 r e l e v a n t 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.  opinions  - 50 -  IV.  Ecological Effects The impact of an action on the natural physical (e.g., land form, non-renewable resources, s o i l s , water, climate and a i r ) and natural b i o l o g i c a l environment be included i n an EIS.  ( i . e . , f l o r a , fauna, microorganisms) must 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 consideration of ecological concepts such as systems i n t e r r e l a t i o n s h i p s , food chains, biogeochemical c y c l i n g , energy flow, l i m i t i n g factors, and systems d i v e r s i t y .  A l l Important ecological impacts must be  comprehensively characterized i n an impact statement quantitatively ( i f relevant) and i d e n t i f i e d q u a l i t a t i v e l y .  To f a c i l i t a t e the  reader i n valuing a l l described impacts, the f i v e considerations l i s t e d under s o c i o - c u l t u r a l impacts should also be u t i l i z e d i n describing the ecological effects of a proposed project.  V.  D i s t r i b u t i o n Consequences The r e a l 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, environmentali s t s , entrepreneurs, r e c r e a t i o n i s t s , etc.) and regions ( l o c a l , regional, national, etc.).  As a r e s u l t , the d i s t r i b u t i o n of the  b e n e f i c i a l and adverse consequences of an action should be described i n an EIS.  -  VI.  51 -  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 j e c t with the long-term consequences.  e f f e c t s of the proposed proThis discussion should  especially r e f e r to the curtailment of future b e n e f i c i a l 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 i s e s s e n t i a l that these objectives be accomplished by the a l t e r native which has the least s o c i a l cost i n r e l a t i o n to the greatest s o c i a l benefits.  The alternatives considered  should be broad i n  scope r e f l e c t i n g the d i f f e r e n t interests i n 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 i n an area that t r u l y r e f l e c t s the aspirations of l o c a l c i t i z e n 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 objectives .  -  IX.  52 -  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 i n a succinct, non-technical form that i s e a s i l y understandable to the common layman.  Both the rationale for the  project and a summary of impacts should also be included i n an EIS. These recommended c r i t e r i a are proposed r e a l i z i n g that d i f f e r e n t government actions inherently require varying i n t e n s i t i e s of e f f o r t i n disclosing the b e n e f i c i a l and adverse consequences  of an intended action.  The d e t a i l required i n an EIS i s ultimately the judgement of an agency decision-maker, although consideration should be given to the r e l a t i v e magnitude of an action, i t s monetary cost and whether the action i s of a controversial nature or not.  Regardless of the e f f o r t expended i n com-  pleting an EIS, i t i s 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 developed to help assess the p o t e n t i a l environmental impact of a proposed project.  Most of these methods have been devised by government agencies,  educational i n s t i t u t i o n s and private research consultants a l l i n response to the need for a systematic procedure to f u l f i l l the "action f o r c i n g " 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 i s to complete a descriptive review of d i f f e r e n t procedures which have been established or could be of s i g n i ficant use to i d e n t i f y the environmental impact of a proposed action. Since many of these methods are very similar or are s p e c i f i c a l l y confined to a narrow aspect of environmental analysis, t h i s descriptive review w i l l not discuss a l l procedures that could be used to evaluate environmental impact.  Rather, i t i s intended to select and.review the more important  methods or procedures which have been developed to i d e n t i f y the least damaging alternative or to evaluate the environmental impact of a prospective project.  Hence, name thods of narrow scope such as the evaluation  of landscape aesthetics w i l l not be described i n this chapter. It was f e l t that this chapter would not be complete without a b r i e f discussion of two methods f o r undertaking a land c a p a b i l i t y /  - 5"3 -  /  s u i t a b i l i t y analysis.  -  54  -  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 s p e c i f i c actions rather than just f o r broad land-use environmental impacts.  These remaining methods have a certain focus that stresses  impact i d e n t i f i c a t i o n , evaluating impacts through the development of common units, and evaluating impacts through separate measures and qual i f y i n g phrases which also provides f i t t i n g categories for this descript i v e review. LAND CAPABILITY OR SUITABILITY ANALYSIS In essence, an environmental c a p a b i l i t y or s u i t a b i l i t y analysis i s completed when the natural features of an area are surveyed to provide information which i s evaluated by established c r i t e r i a to determine the quality of the land f o r a d i f f e r e n t use or uses.  I t i s based on the  premise that "nature i s process, that i t i s i n t e r a c t i n g , that i t responds to laws, representing values and opportunities f o r human use with certain l i m i t a t i o n s and even prohibitions to certain of these" (McHarg, 1969). Such an analysis could be used i n an impact statement to indicate the compatibility of an action with the environment and also to assess the most suitable locations for d i f f e r e n t prospective land uses.  A number  of approaches presently exist f o r undertaking a capability or s u 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 i n The Ecological Basis For Land Use Planning and by Ian L. McHarg i n Design With Nature. described i n this section.  Both techniques w i l l be b r i e f l y  -  55  -  The f i r s t step of H i l l s method i s a l o g i c a l disaggregation of a large land s i t e into increasingly smaller areas based upon the recognition of homogeneous sub-units of landscape.  The general land type  c l a s s i f i c a t i o n i s based upon micro-landform and c l i m a t i c features while the more s p e c i f i c s i t e type areas are distinguished by gradients i n parameters such as s o i l moisture, s o i l depth and micro-climatic conditions.  At the more s p e c i f i c s i t e type unit of land, classes are  for a certain land use  assigned  (either a g r i c u l t u r e , f o r e s t r y , recreation and  w i l d l i f e ) based upon the inherent capability of the land to produce according to that specified use  (eg, number of recreation days, crop  y i e l d s , etc.). The classes for a s p e c i f i c area can. then be aggregated into a rating for a larger section of land by combining numerical for each class based upon the extensiveness section of land and an assigned weighting  valuations  of a class within the larger  factor.  Thus, the ratings are  useful to planners regardless of whether detailed or more a l l - i n c l u s i v e information i s required. In addition to c a p a b i l i t y 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 l e v e l of capability through management practices.  Further, a t h i r d r a t i n g 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 e x i s t i n g or future socio-economic conditions. A more complete outline of this approach i s included i n Appendix C, table 1. The McHarg method of "ecological determinism" i s s i m i l a r to H i l l s approach i n that both desirable and l i m i t i n g c h a r a c t e r i s t i c s are  -  56  -  defined for each type of land use, but d i f f e r s i n the complexity and number of steps required to complete the procedure.  The McHarg technique  i s easier to understand and u t i l i z e , yet t h i s c h a r a c t e r i s t i c may also mean that the method produces less systematic  results.  There i s also a  detailed inventory and mapping of b e n e f i c i a l 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 i n varying tones of gray  to indicate l i m i t i n g c h a r a c t e r i s t i c s and desirable features of an e x i s t ing environmental condition for a s p e c i f i c land use.  By superimposing  maps of environmental conditions, the resultant clear or darkly toned areas (depending upon whether dark areas are l i m i t i n g or favorable  envi-  ronmental c h a r a c t e r i s t i c s ) indicate desirable locations for the land use evaluated.  Thus, each environmental condition i s a c r i t e r i o n used to  evaluate the s u i t a b i l i t y of a land use i n an area. a single color which i s toned on a transparent and undesirable  Through the use of  map to indicate desirable  locations for a s p e c i f i c land use, a l l land uses i n the  region can be compared through the overlay technique to i d e n t i f y areas highly suitable for a s p e c i f i c use, areas suitable for compatible uses, and also areas of c o n f l i c t .  Case studies u t i l i z i n g t h i s method have  indicated that there are r e l a t i v e l y few c o n f l i c t i n g uses requiring f u r ther study.  A l i s t of c r i t e r i a used by McHarg to evaluate the s u i t a b i -  l i t y of a land area for conservation,  passive recreation, active  recreation, r e s i d e n t i a l development and i n d u s t r i a l and commercial development i s included i n 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 f o r c i n g " requirements i n 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 i n this section, since most other impact i d e n t i f i c a t i o n methods are only one part of broader evaluation approaches.  These evaluation approaches w i l l be discussed i n l a t e r  sections of t h i s chapter.  MULTIPLE EFFECTS NETWORKS One of the major problems with some methods to evaluate environmental impact i s 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 i n -  tensity of this problem has been reduced through the development of networks f i r s t by Travelers Research Corporation (1969) and l a t e r r e fined by the C a l i f o r n i a Resources Agency (1972) and published by Jens C. Sorenson (1971).  These networks or stepped matrices l i n k 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 r e s u l t s 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 i n the ground water.  A secondary impact r e s u l t i n g  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, i n turn, can result i n a t e r t i a r y e f f e c t of a public health hazard i n 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 i n a land area. At present, a complex system of networks i s being completed f o r use i n i d e n t i f y i n g the potential impacts of land uses and actions on the coastal zone i n C a l i f o r n i a .  Objectives are to program and store this  detailed information on computer so that i t can be revised and corrected when necessary, and also f o r convenient r e t r i e v a l by persons preparing impact statements when a pertinent l i s t i n g of potential impacts i s needed for a s p e c i f i c type of action.  Although this network procedure was i n -  tended for mainly impact i d e n t i f i c a t i o n purposes rather than evaluation (Sorenson and Moss, 1973), this method has been modified so that an impact assessor can distinguish the p r o b a b i l i t y or importance of the occurrence of an e f f e c t (Midgley, 1972).  Further, networks have been arranged i n an  outline format as an impact checklist to review highway and housing proj e c t s (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 b i o l o g i c a l factors to f a c i l i t a t e decision-making began long ago i n water  - 59 -  resources planning through benefit/cost analysis methods.  This search  continues to this day with methods to consider i n non-monetary yet common measures the economic, s o c i a l and ecological consequences of a proposed action.  Although the basic reason why  these methods are  advanced for environmental impact evaluation i s to provide decisionsmakers with an e x p l i c i t d e f i n i t i o n 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 c l e a r l y i d e n t i f i e s tradeoffs between benef i c i a l and adverse impacts, and likewise provides a d i s t i n c t  comparison  between d i f f e r i n g environmental effects and between alternative design and location choices.  In this section s i x 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 I I I - l ) : 1)  An analysis of the need for the proposal;  2)  An environmental inventory of the region p o t e n t i a l l y affected by the action;  3)  An explanation of the pertinent engineering d e t a i l s 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 -  0 0 © A  )  A. Statement of objective  B  )  8. Technologic possibilities for achieving objective  ©  C4 }  C. Proposed actions and alternatives  D. Environmental characterization report prior to initiation of action  ©  E. Alternative engineering plans  F. Identification of impact and analysis of magnitude and importance of impact.  G5 )  H  III-l.  )  G. Assessment of impact  H. Recommendations  A flow chart showing the recommended integration of an environmental impact statement i n the process of planning an action (Leopold et. a l . , 1971).  - 61 -  action/condition matrix was  developed to help i d e n t i f y the prospective  general impacts of a wide range of potential actions (see Appendix E, Figure 1).  This large matrix i s actually a checklist of 100 actions on  the horizontal axis and 88 environmental conditions l i s t e d v e r t i c a l l y t o t a l l i n g 8800 c e l l s .  This method i s u t i l i z e d by marking the i n t e r -  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 i s then assessed according to  i t s magnitude and importance which i s i d e n t i f i e d i n each part of a l l marked c e l l s by a number between one  (low) and ten (high).  i s defined f o r this purpose as the "degree, extensiveness  Magnitude or s c a l e " of  impact while importance might best be termed the s i g n i f i c a n c e or weight attributed to the effect.  Thus, i n most cases magnitude can be deter-  mined from f a c t u a l information and importance can be i d e n t i f i e d through subjective judgements.  An important feature of this procedure i s the  separation of value judgements from fact.  Also, the method can be re-  vised into providing more detailed information by devising sub-matrices with s p e c i f i c data about an action (eg, Mineral Processing can be subdivided into the s p e c i f i c actions of s u l f u r i c acid use and a c i d i t y of yard runoff) or environmental condition (eg Atmospheric Quality can be subdivided into the s p e c i f i c conditions of p a r t i c u l a t e s , sulphur  oxides,  nitrous oxides, etc.). This procedure has been used many times to help evaluate environmental consequences of a proposed project.  the  In Canada, a j o i n t  Federal-Provincial Task Force (1971) modified the evaluation part of the  - 62 -  CO  o Z M  9  CO O S5  CO  PQ CO  H CO CO  &  s CO  •J co  Z o  SH  S3  H  IG  ENVIRONMENTAL CONDITIONS  1  ON  H  PS  H CO S3  <!  M  53  C_>  Z O M  H  H  < > <  H  CO CO  hJ Pi  O  u3  o z  o H  w q  CO  PH  EH  CO  M  Z H  <J H  w  PH  S  CO •J  o z  W  O  <  M  w  PH O  CJ  w  M  tJ  H  O  & w  CO iJ  PI  M  CJ  NT  Z M  H  z  RU  o Q  H  Z H  RO  w  O  IN  CO  w  XC  CO  W  UR  CO  LA  H  co  WATER QUALITY ATMOSPHERIC QUALITY EROSION DEPOSITION,  SEDIMENTATION  SHRUBS  6  2 I?  GRASSES AQUATIC  PLANTS  FISH CAMPING & HIKING SCENIC VIEWS & VISITORS WILDERNESS QUALITIES RARE & UNIQUE SPECIES HEALTH & SAFETY KEY magnitude  importance  FIGURE I I I - 2 .  A reduced m a t r i x f o r a phosphate m i n i n g l e a s e i n d i c a t i n g t h e magnitude and importance o f a c t i o n s on e n v i r o n m e n t a l elements (adapted from L e o p o l d e t a l , 1971)^  - 63 -  procedure but u t i l i z e d 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, s o c i a l and ecological impacts i n common units would greatly simplify the evaluation of the consequences of a proposed action.  One approach which has been recommended f o r this purpose i s to  develop energy network diagrams f o r the system(s) to be affected by a proposed action (Odum, 1972).  This method of describing natural and  man-made systems uses k i l o c a l o r i e s 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 i n energy terms, Odum (1971) notes that such a portrayal can be used for economic and s o c i a l systems since the u t i l i z a t i o n of energy i s also the fundamental basis of man-oriented systems.  Indeed, Odum states that even money can  be changed into k i l o c a l o r i e s by r e l a t i n g the t o t a l amount of money i n a human system to the t o t a l amount of work completed by individuals comp r i s i n g the system. The f i r s t step i n quantifying the environmental impacts of a proposal i s to complete a physical inventory and a s i m p l i f i e d network diagram of the energy flows and storages i n the system(s).  Secondly, an  estimate of the change i n energy flow and storages due to the action (or forcing functions) w i l l y i e l d a prediction of the system(s) i f the  - 64 -  proposal i s implemented.  The difference i n t o t a l energy flow and storage  with and without the proposed action i s i t s environmental impact i n quant i t a t i v e 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 i n an existing state;  2)  Systems highly sensitive to intrusions;  3)  Systems which have a high value or importance i n maintaining other systems;  4)  Systems which have a high cost of development and maintenance i f the action i s undertaken.  AN OPTIMUM PATHWAY MATRIX ANALYSIS APPROACH An i n t e r d i s c i p l i n a r y group from the Institute of Ecology at the University of Georgia (Zieman, et a l . , 1971) developed an approach to evaluating the least s o c i a l 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 d i f f e r e n t  - 65 -  from i t s long-term impact, two r e l a t i v e weights were assigned to each of the 56 conditions indicating the long and short-term importance of each p o t e n t i a l consequence of an action.  In addition to these two d i f f e r e n t  weights, long-term impacts were valued as ten times more important than short-term effects.  The magnitude of a condition change for each a l t e r -  native route was also considered by a quantitative valuation of the impact  (eg, acres of a g r i c u l t u r a l land removed for right of way, number  of families displaced, etc.).  The magnitude of effect on each existing  environmental condition was then scaled by r e l a t i n g a l l alternative routes to the highway alignment which would have the most extensive impact.  For example, route F would remove 325 a g r i c u l t u r a l acres f o r  right-of-way which i s higher than any other alternative.  Route F i s  given a magnitude value of 1. which route G, which displaces 313 acres, i s assigned a value of .96 (or 313/325).  Similarly the remaining a l t e r -  natives would be scaled i n r e l a t i o n to route F to define t h e i r proport i o n a l magnitude for this environmental impact.  In order to keep  numerical t o t a l s 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 i n a numerical value indicating the environmental impact of the route. The r e a l i z a t i o n of the potential for a wide margin of error i n evaluating impacts prompted the group to develop a technique to improve the v a l i d i t y of their r e s u l t s .  This technique u t i l i z e d 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.  Statistical  techniques were also used through the computer to calculate the mean, the standard deviation and a 95% confidence i n t e r v a l for each highway alignment.  Figure III-3 indicates that, according to t h i s 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, B a t t e l l e  Columbus Laboratories developed an "Environmental Evaluation System" (EES) for Water Resources Planning.  The method i s used to quantitative-  l y assess the environmental consequences  of water resources projects i n  order to i d e n t i f y the tradeoffs between the b e n e f i c i a l and adverse effects of an action, and to measure the difference i n impacts of a l t e r native water resources developments.  A h i e r a r c h i c a l arrangement of  environmental impacts into categories, components and ultimately into 79 parameters  (see F i g u r e . I I I - 4 ) that are used to define and evaluate e f -  fects into a numerical t o t a l of environmental impact units (EIU). For example, one of four B a t t e l l e categories i s Environmental P o l l u t i o n " which i s divided into the four components of "Water P o l l u t i o n " , " A i r P o l l u t i o n , " "Land P o l l u t i o n " and "Noise P o l l u t i o n . "  One of fourteen  parameters disaggregated from the component "Water P o l l u t i o n " i s "Inorganic Nitrogen."  The B a t t e l l e method also incorporates a warning  system whereby minor or major "red f l a g s " are i d e n t i f i e d to signal parameters that r e f l e c t " f r a g i l e " areas of the environment or parameters  - 67 -  FIGURE  III-3.  and confidence intervals for the evaluation of eight highway route alignments (from Zieman et. a l . , 1971).  M e a n  -  68 -  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 ENVIRONMENTAL PARAMETERS  U  U  U  U  MOST SPECIFIC (DATA) Level 4. ENVIRONMENTAL MEASUREMENTS  FIGOBE I I I - 4 .  U  U  U  ••••••• •  The h i e r a r c h i c a l  U  •  structure o f the B a t t e l l e  •  Columbus  e n v i r o n m e n t a l e v a l u a t i o n system (from Dee, e t a l , 1973)  1.0*  0.8E-t  D Oi.  IS3  0.6|  0.4  2  s  H >  0.2  W  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 f u r t h e r study b e f o r e q u a n t i t a t i v e v a l u e s can be a s s i g n e d . Two q u a n t i t a t i v e v a l u e s a r e m u l t i p l i e d t o g e t h e r t o comprise each parameter's  n u m e r i c a l f i g u r e i n environmental impact u n i t s .  e n v i r o n m e n t a l q u a l i t y v a l u e o f a parameter  The  i s o b t a i n e d through e s t i m a t e s  or f a c t u a l d a t a which i s compared on a s c a l e  (see F i g u r e I I I - 5 ) t o de-  termine a f i g u r e between 0 (very bad environmental q u a l i t y ) and 1.0 (very good environmental q u a l i t y ) .  The l e v e l o f a parameter  measure o r  e s t i m a t e which i s a " v e r y good" or " v e r y b a d " environmental q u a l i t y i s to be determined team.  f o r each water r e s o u r c e s p r o j e c t by an i n t e r d i s c i p l i n a r y  The second q u a n t i t a t i v e v a l u e used t o determine  impact u n i t s o f a parameter 1000  i s through a w e i g h t i n g system which a s s i g n s  importance weights among parameters  d i s c i p l i n a r y team.  the environmental  i s a g a i n through an i n t e r -  Merely by summing t h e t o t a l EIU from e s t i m a t e s o f  the f u t u r e environment  w i t h and a l s o w i t h o u t t h e proposed p r o j e c t p r o -  v i d e s n u m e r i c a l v a l u e s which i n d i c a t e t h e p r e d i c t e d e n v i r o n m e n t a l  impact  (see Appendix E, F i g u r e 4 ) .  Later  Approach S i n c e most e n v i r o n m e n t a l impact  statements a r e p r e p a r e d by a  government agency s t a f f and n o t 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 r e v i s e d i t s e a r l i e r method i n a c o n t r a c t w i t h t h e E n v i r o n m e n t a l P r o t e c t i o n Agency so t h a t t h e procedure c o u l d be used f o r t y p i c a l water q u a l i t y management p l a n s r e q u i r i n g an EIS. ences from t h e e a r l i e r approach.  There a r e t h r e e b a s i c  The most obvious d i f f e r e n c e i s t h a t  t h i s newer approach does not a s s i g n common u n i t s t o t h e parameter i n t h e h i e r a r c h i c a l system.  differ-  levels  I n s t e a d , common u n i t v a l u e s a r e a s s i g n e d f o r  - 70 -  importance and Environmental Quality at the more general environmental component l e v e l defined e a r l i e r i n the h i e r a r c h i c a l system.  Another  change from the e a r l i e r method i s the establishment of a fixed weighting system by assigning only 100 importance units to the 19 environmental components.  An i n t e r d i s c i p l i n a r y 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 i n importance i n order to assign the weights.  This "ranked pairwise comparison" technique  was repeated several times by providing the group with information about the previous run, u n t i l a f i n a l scaled weighting system was developed. The t h i r d difference from the e a r l i e r B a t t e l l e approach i s the use of environmental assessment trees to determine each component s environ1  mental quality (see Figure III-6).  As i n 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 environmental component.  A pre-determined index i s used to transform the  measured or estimated value of a parameter to a s p e c i f i c range.  After  defining the correct range of parameter A on the appropriate environmental 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 r e s u l t i n the i d e n t i f i c a t i o n of an environmental 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  1.0 0.9  Parameter B  0.8 0.7 0.6 Environmental Quality (EQ)  0.5  0.9  Range 2  Range 1  Parameter A  0.5  0.1 0  FIGURE I I I - 6 .  Environmental Quality (EQ)  0.4  0.4  0.2  I 0.7 0.6  Range 2  Range 1  0.3  0.8 •  Range 2 Parameter C Range 1  -i 0.3 0.2 0.1 0  An example of an environmental assessment tree used to determine a component's environmental q u a l i t y value (from Dee et a l , 1973).  1972)  merged ideas from both the Sorensen and Leopold et a l . procedures  previously  described to evaluate alternative Canadian and Alaskan pipe-  l i n e routes from Prudhoe Bay.  "Effects chains" were devised as a  r a t i o n a l method to choose variables to be included  i n a matrix which  would serve to summarize an impact statement and make e x p l i c i t a l l evaluation judgements about potential  alternatives.  An effects chain i s described as merely a flow chart tracing the s p e c i f i c 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 established 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 v e r t i c a l l y l i s t e d alternatives.  In t h i s case study an effects  chain was developed for each of f i v e alternative routes and also for the choice of "no action." This methodology also devised a method to quantitatively evaluate each environmental impact by assigning u t i l i t y figure.  a numerical probability and a  Probability i s defined as the percentage l i k e l i h o o d of  an effect occurrence at each l i n k along the chain (see Appendix E, F i gure 6).  The probability of the ' f i n a l ' effect on a matrix variable i s  therefore dependent upon the l i k e l i h o o d of a l l previous impacts  occurring.  The p r o b a b i l i t y figures for a l l ' f i n a l ' effects are intered i n the upper portion of each relevant  c e l l i n the matrix.  U t i l i t y i s considered the  r e l a t i v e significance of a ' f i n a l ' effect to society by comparing the same impact between the d i f f e r e n t alternatives.  Consequently, i f impact A  (INCREASED NUTRIENTS? (INCREASED SOIL *  0/  bf  ,  iJ  E  (ALTERED DRAINAGE PATTERNS)  (BUILD HIGHWAY ,>  '%i V^,  S  I  0  N  )  P  H  I  C  A  T  S I B L E EUTROI  0  ^s ^  S T U R B A N C E  v  GRAVEL P I T FOR CONSTRUCTION MATERIALS)  I N  N  B ° C & M  E  R  .  EffCCt f^^  <j  (BYPASS AQUIFER RECHARGE  ^ 2 . Tertiary £ffed---  ma  Effect  0  P 0 S  /  /Secondary Effect \ /  R  ^  PHYSICAL LANDSCAPE)  Secondary Effect———-  D w a t e r  * ^al Effect"  ......a'  *  J  .  *  PA™/ ///«./  (UNDESIRABLE VIEW IN NATURAL * LANDSCAPE)  (DIVERT TRAFFIC FROM ^ ^ . ESTABLISHED PATTERNS) t  Effect  FIGURE I I I - 7 .  (DECREASED SPENDING IN EXISTING COMMERCIAL AREAS)  (LOSS OF INCOME TO LOCAL POPULATIONS)  3. Secondary Effect——  A s c h e m a t i c example o f a " c h a i n o f 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 e t . a l ,  1972). .  - 74 -  from alternative one i s 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 r e f l e c t this judgement. A l i n e a r preference scale ranging from -10 to +10 was used i n this case study of alternative pipeline routes. variables were l i s t e d  U t i l i t y values f o r a l l  i n the lower portion of each pertinent c e l l i n  the matrix (see Appendix E, Figure 7).  A jury system of voting and then  discussion to resolve c o n f l i c t s was used to determine the u t i l i t y values i n the matrix.  The f i n a l step i n this methodology was  to apply a deci-  sion c r i t e r i o n of minimizing the "weighted value" of an alternative. The "weighted value" was defined by summing the products of each v a r i a ble's u t i l i t y and p r o b a b i l i t y value.  For example, the v a r i a b l e "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. a -3 combined value for this variable.  The product results i n  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 A l l o c a t i o n Process (REMAP) which has been used to assess the environmental consequences of alternative highway route locations (Krauskopk and Bunde, 1972).  This method includes four d i s t i n c t  steps. The i n i t i a l step of this procedure i s the development of a data bank f o r the study area.  The data collected and stored includes natural  - 75 -  and man-made environmental conditions defined i n 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 i n this method i s to develop, through an i n t e r d i s c i p l i n a r y team, a l i s t of general factors or determinants which comp r i s e the basic c r i t e r i a used to evaluate the f e a s i b i l i t y of each potent i a l highway route alignment.  In this case study, ten determinants which  r e f l e c t e d economic, engineering, s o c i a l , c u l t u r a l , and ecological factors were defined.  Next, a l i n e a r model i s then constructed for each deter-  minant which l i n k s data-variables into a number of components that comprise the model.  The i n t e r d i s c i p l i n a r y team assigns weights to  variables and components i n the form of c o e f f i c i e n t s , based upon importance and extensiveness of the variable within a data c e l l .  Although not  s p e c i f i c a l l y described, a "normalization process" i s used to e s t a b l i s h a common numerical base for a l l variables and components. The t h i r d stage results i n computer print-outs for alternative route locations based upon the importance assigned to each determinant. By subjectively valueing each determinant d i f f e r e n t l y , alternative highway alignments were located i n 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 i s to write an impact statement for  the decision-making process.  The information developed i n the pre-  vious three steps and the data stored i n the computer provides a foundation for the EIS.  I t i s recommended that an impact statement be  written for each d i f f e r e n t alternative so that the decision-maker can  - 76 -  choose the most desirable alternative.  S p e c i f i c data can also be pro-  vided i n terms of the percentage of d i f f e r e n t types of land affected by the route (eg, recreation, a g r i c u l t u r a l , etc.) and also the extensiveness of the impact on d i f f e r e n t natural resources (eg, swamps, minor r i v e r s , lowland forest, etc.). METHODS SEPARATING UNITS OF MEASURE AND QUALIFYING IMPACTS Many have argued against converting economic, s o c i a l and ecolog i c a l impacts into comparable numerical figures because of hidden subj e c t i v e judgements which can d i s t o r t the true implications of impacts and can conceal them from public i d e n t i f i c a t i o n and discussion (Sorensen and Moss, 1973 and Kusler, 1972).  The two methods reviewed i n this  section attempt to numerically value impacts when possible and otherwise distinguish i n descriptive terms the value of a predicted e f f e c t .  No  attempt i s made to resolve the incommensurable nature of the many d i f f e r e n t types of environmental impacts, r a t i o n a l i z i n g that i n d i v i d u a l judgements can be made from a quantitative and q u a l i t a t i v e description of the environmental consequences  of a proposed action.  U.S. WATER RESOURCES COUNCIL PRINCIPLES AND STANDARDS The evolution of procedures used i n 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 i s 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  g e n e r a l o b j e c t i v e s of c o n t r i b u t i n g to  n a t i o n a l economic development and The  -  enhancing environmental  i n f o r m a t i o n d i s p l a y developed  C o u n c i l p r o v i d e s d a t a f o r p u b l i c review and  by the U.S.  concerning  quality.  Water Resources  the proposed a c t i o n  d i f f e r e n t a l t e r n a t i v e c h o i c e s t h a t are f e a s i b l e to undertake.  information i s organized ficial  and  adverse  i n t o a system o f accounts  which l i s t  the bene-  c o n d i t i o n s i n the a f f e c t e d a r e a ( s ) w i t h and  the proposed a c t i o n .  A s e p a r a t e account d i r e c t l y  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 i n t e n d e d  environmental pacted  The  affected area(s).  to r e v e a l the  at a n a t i o n a l l e v e l while  the im-  e c o l o g i c a l systems i n the  Also included i n t h i s information d i s p l a y i s a  s e p a r a t e account f o r r e g i o n a l development and The  the ac-  q u a l i t y account d i s p l a y s the e x i s t i n g and p o t e n t i a l l y  q u a l i t y of n a t u r a l , c u l t u r a l and  well-being.  without  c o n s i d e r s each of  e s t a b l i s h e d o b j e c t i v e s f o r p l a n n i n g water and l a n d r e s o u r c e s .  monetary f e a s i b i l i t y of the investment  This  account c o n c e r n i n g  an account f o r s o c i a l  r e g i o n a l development a s s e s s e s  proposed p l a n i n r e l a t i o n to the r e l e v a n t p l a n n i n g r e g i o n ( s ) r i v e r b a s i n , s t a t e s ) , and  (eg.  the local,  the s o c i a l w e l l - b e i n g account emphasizes  the  i n c i d e n c e of impacts on persons and groups based upon changes i n income, employment and o t h e r s o c i a l  factors.  Each of the f o u r accounts C r i t e r i a have a l s o been developed alternatives  i s f u r t h e r subdivided into categories. which can be v a l u e d to a s s e s s  (see Appendix F, T a b l e 1 ) .  A l l monetary e f f e c t s a r e  q u a n t i t a t i v e l y w h i l e non-monetary impacts a r e d e s c r i b e d both and  the valued  numerically  qualitatively. The p l a n n i n g process which produces the i n f o r m a t i o n d i s p l a y and  - 78 -  f a c i l i t a t e s making an equitable decision concerning  the proposed action  consists of the following s i x basic steps (U.S. Water Resources Council, 1973): 1) 2 2)  Specify components of the objectives relevant to the planning s e t t i n g ; Evaluate resource c a p a b i l i t i e s and expected conditions without any plan;  3)  Formulate a l t e r n a t i v e plans to achieve varying l e v e l s of contributions to the specified components of the objectives;  4)  Analyze the differences among alternative plans to show tradeoffs among the s p e c i f i e d components of the obj ect ives;  5)  Review and reconsider, i f necessary, the s p e c i f i e d 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 environmental quality.  The ultimate objective of this planning process and system of accounts i s to f a c i l i t a t e selecting the alternative which best contributes to "promote the quality of l i f e " i n the region and nation as a whole. U.S.  ATOMIC ENERGY COMMISSION EIS PREPARATION GUIDELINES Since the s i g n i f i c a n t Calvert C l i f f s court decision ruled that  the procedures used by the Atomic Energy Commission i n assessing  environ-  mental factors before l i c e n s i n g 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  method actually leads to an expanded benefit/cost analysis developed  new  - 79 -  according to a standardized twelve-chapter format. procedure can be divided into two s i g n i f i c a n t parts.  The focus of the The purpose one  part i s to guide the preparation of impact statements to complete an analysis of alternative s i t e and site/plant-type choices which exist as f e a s i b l e courses of action.  This analysis must indicate that the pro-  posed f a c i l i t y i s the cost-effective a l t e r n a t i v e , evaluated through a quantitative and q u a l i t a t i v e description of the "economic, s o c i a l and other environmental factors, and any i n s t i t u t i o n a l (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, s o c i a l and environmental benefits and costs of the proposed action.  This i s to be accomplished  i n quantitative and q u a l i t a t i v e terms throughout the text of an EIS and summarized i n 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 i n 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 e f f e c t s , 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 lity.  Perhaps the most useful aspect of t h i s procedure i s 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 of a proposed action. stand why.  consequences  Through this b r i e f survey i t i s easy to under-  The methods are d i f f i c u l t to understand due to their  complexity, some were devised s p e c i f i c a l l y for a single purpose, and a l l evaluation methods reviewed i n this chapter r e l y upon subjective judgements at some stage i n their application.  Although not a l l proce-  dures that exist to evaluate environmental impact were d e s c r i p t i v e l y reviewed i n this chapter, i t i s f e l t that a cross-section of the most f e a s i b l e and well-known approaches to this r e l a t i v e l y new " a r t " have been described. The environmental impact assessment methods described i n this chapter are d i f f e r e n t i n many ways from one another.  Most methods were  developed for a s p e c i f i c type of project such as water resources projects, nuclear power plants and highway projects while other evaluation approaches serve a wider use. evaluate alternatives.  Many methods were intended f o r use only to  As discussed i n chapter two of this thesis, the  evaluation of alternatives i s a s i g n i f i c a n t part of an EIS, but i t does not comprise the entire assessment.  Some impact assessment methods  discussed i n this chapter require the use of an i n t e r d i s c i p l i n a r y team or s p e c i f i c s k i l l s and knowledge i s needed to apply the procedure.  In  order to provide a broad view of these d i f f e r e n t methods and t h e i r diverse c h a r a c t e r i s t i c s , Figure III-8 was developed to i l l u s t r a t e the varying c h a r a c t e r i s t i c s which can influence the selection of a method  -  -  81  a  w  CO  CO  D  a z Q O  S3 EH  ac EH  H  w  &, H U CO H .  EH  W  2 D  CU  W  I-H  CAPABILITY/SUITABILITY  H  fa H EH  2 fa  EH  2 « O  D  Q  CU  W i-l  U  EH  H CO  D S  W  EH U  fa Q 2  <  CO  w  Q H >  O U  Q H  1  cn  A.  ANALYSIS  MULTIPLE EFFECTS NETWORKS  X  U . S . G . S . MATRIX  X  X  ENERGY NETWORK DIAGRAMS  X  X  X  X  OPTIMUM PATHWAY MATRIX APPROACH  X  EARLY METHOD  X  BATTELLE COLUMBUS  X  X  COMPUTER MODELLING- ENV. IMPACT U . S . WATER RESOURCES COUNCIL U . S . ATOMIC ENERGY COMMISSION FIGURE III-8.  fa  CU  uo o S  EH  hH  2  CO EH  fa  S  a  2 fa  § H  £  H  hH  CO  D  D  D  OI  D fa fa  H  O CO  3  fa a «  CM  X  x• x  x  EFFECTS CHAINS .  CO H  X  X  LATER METHOD  CM  <  CO  H  CU  M  H EH  g  EH O  fa  o g  Q  H  CO  o  2  u  w  CO O  H EH  <  l-H  Q O  8  H EH  X  X  X  X  X  X  X  X  A matrix display of some factors to be considered in selecting a methodology for use i n environmental impact evaluation.  - 82 -  for  use i n impact assessment.  the d i f f i c u l t y  These d i v e r s e c h a r a c t e r i s t i c s i n d i c a t e  t h a t would be encountered i n any attempt to c r i t i c a l l y  review the u s e f u l n e s s  of each method.  be o n l y g e n e r a l l y assessed  As a r e s u l t , these methods w i l l  l a t e r i n t h i s thesis according  b a s i c types d e f i n e d i n t h i s chapter.  to the f o u r  These f o u r types a r e :  1)  C a p a b i l i t y / S u i t a b i l i t y a n a l y s i s methods;  2)  Methods f o r impact i d e n t i f i c a t i o n  3)  E v a l u a t i o n methods which aggregate impacts i n t o common u n i t s ;  4)  E v a l u a t i o n methods which s e p a r a t e and q u a l i f i e s impacts.  only;  u n i t s o f measure  PART TWO  - 83 -  chapter four a critical review of five environmental Impact statements INTRODUCTION The theoretical purpose of an environmental impact statement i s to inform the reader of the t o t a l consequences of a project i n order to f a c i l i t a t e a r a t i o n a l decision about the proposal.  In Chapter Two, nine  general c r i t e r i a were established to test whether a EIS i s written s a t i s f a c t o r i l y to meet t h i s purpose.  These nine c r i t e r i a w i l l be used i n t h i s  chapter to judge the adequacy of f i v e 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 i n this chapter were chosen to represent d i f f e r e n t major actions which obviously require an EIS.  One  impact statement was chosen for a hydropower development, a power generation plant with coal mining operation and transmission l i n e s , 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  r e l i a b l e sample from which a d e f i n i t i v e conclusion can be reached about the adequacy of impact statements presently being produced, this c r i t i q u e uses environmental reports prepared at least two years l a t e r than those selected f o r 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).  All  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 i n this chapter w i l l be discussed i n two basic parts.  First,  a b r i e f description of the proposed project and environmental setting w i l l be completed to provide a general view of the s i t u a t i o n the impact report attempted to assess.  Second, the relevant c r i t e r i a which have not  been adequately considered i n the EIS w i l l be discussed.  The c r i t i c i s m s  w i l l only r e l a t e to the more important weaknesses of the impact report, and w i l l be i l l u s t r a t e d by s p e c i f i c examples.  I t might be h e l p f u l i n  this chapter to refer back to the outline of the c r i t e r i a established i n Chapter Two for this review purpose (pp. 49, 50, 51). THE SEVEN MILE HYDROPOWER PROJECT The environmental impact statement (as broadly defined i n this thesis) f o r this B.C. Hydro and Power Authority Project was actually completed i n two separate studies which w i l l betboth reviewed i n this part of the chapter.  One study, e n t i t l e d "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 considerations.  A second study, "The Social and Economic Impacts of the  Proposed Seven Mile Hydro-Electric Project," was completed by B.C. Research i n May of 1974.  BRIEF DESCRIPTION OF PROPOSED ACTION AND ENVIRONMENTAL SETTING The proposed Seven Mile Project i s located on the Pend d ' O r e i l l e River within the Columbia River Basin near the Washington and B r i t i s h  - 86 -  Columbia border (see Figure 1V-1) B.C.  about eight miles southeast of T r a i l ,  The proposed concrete gravity dam would u t i l i z e approximately  feet of head to produce 3,100 magawatt power plant.  200  m i l l i o n kilowatt-hours per year i n the  750  Since the r i v e r i s i n a steep v a l l e y , 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 r i v e r . The section of the Pend d ' O r e i l l e River which would be affected by the project i s a free-flowing, turbulent watercourse within a s c i e n i c valley.  The vegetation i n the valley i s t y p i c a l for t h i s area of south-  eastern B.C.,  including mainly Douglas F i r (Pseudotsuga menziesii) and  also Lodgepole Pine (Pinus contorta) Cedar (Thuja p l i c a t a ) , Hemlock r  (Tsuga spp.) and other common trees and shrubs.  Most of the vegetation  i n the area to be affected by the project i s i n an early successional stage with only two small stands of trees which o f f e r 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 f o r a large population (estimated at 1700 deer and small numbers of elk and moose) of wild ungulates.  The  r i v e r i t s e l f i s usually s i l t y due to mine t a i l i n g s released upstream, and supports only small populations of trout but much larger numbers of "rough" f i s h .  The recreational value of the affected physical area i s  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 i s based on extractive  - 87  -  -  FIGURE  r i m /  IV-1. General study area of the proposed Seven M i l e Hydropower Project<Envirocon L t d . , e t . a l . , 1973).  -  88  -  ENVIRONMENTAL INVENTORY Description of Actions Description of Setting Affected Delineation of "Affected" Area  * *  ECONOMIC EFFICIENCY L i 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 I V - 1 . Checklist summary of non-compliance with c r i t e r i a for the Seven Mile impact studies.  ^ i  -  Indicates an inadequate discussion of requisite i n environmental impact statements.  ! 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 C r i t e r i o n I_ —  Project Description and Environmental Inventory  The two impact studies f o r the Seven Mile project completed a description of the proposed project and environmental s e t t i n g , but i n the Envirocon  report there was very l i t t l e mention of the construction  aspects of the proposed dam.  Construction a c t i v i t i e s such as b l a s t i n g ,  roadbuilding and gravel mining ban cause important long-term e c o l o g i c a l effects which should be described i n an impact report.  Criterion II —  Economic E f f i c i e n c y  An analysis of the economic e f f i c i e n c y 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 p o t e n t i a l for power production per acre of reservoir of a l l remaining latent hydropower s i t e s i n B r i t i s h Columbia.  This b r i e f reference to the project's economic  e f f i c i e n c y was made i n both impact studies, but no evidence was disclosed about how this conclusion was reached.  C r i t e r i o n III —  Socio-Cultural Impacts  Based upon the impact report completed by B.C. Research, i t i s f e l t that some apparent s o c i a l and c u l t u r a l impacts of the Seven Mile Hydropower project were not disclosed.  The report concentrated  mainly on  the s o c i a l and physical services which would be affected during  construe-  - 90 -  tion of the dam, and f a i l e d to i d e n t i f y some of the more "intangible" yet important s o c i o - c u l t u r a l consequences.  For example, community co-  hesion and l i f e s t y l e are s o c i o - c u l t u r a l impacts which were not mentioned i n the B.C. Research report.  Community cohesion has been defined as a  "unifying force" within a s o c i a l s e t t i n g leading to "patterns of i n t e r relationships, common i n s t i t u t i o n s , commonly agreed-upon ways of behaving and a common i d e n t i t y " (U.S. Army Corps of Engineers, 1974).  Life style  might be termed the daily a c t i v i t i e s and habits of a person(s) which are affected by an aggregate of e x i s t i n g environmental conditions.  Although  these two "intangible" s o c i o - c u l t u r a l factors are not r e a d i l y quantif i a b l e nor e a s i l y understood, they are s i g n i f i c a n t impacts which should have been q u a l i t a t i v e l y described i n the Seven Mile Project impact report, especially since i t was mentioned that three small communities i n the Seven Mile Project area w i l l experience most of the peak i n f l u x of over 400  construction workers looking for short-term  residence for t h e i r  families. Other adverse s o c i o - c u l t u r a l impacts which were not discussed i n the B.C. Research Report include aesthetic e f f e c t s and impact on ethnic groups.  I t i s d i f f i c u l t to ascertain whether these p o t e n t i a l impacts  were omitted from consideration, whether they were found not applicable for this- p a r t i c u l a r project, or whether they were defined as i n s i g n i f i cant for discussion i n the text.  I t would seem that aesthetic impacts  were omitted from discussion, e s p e c i a l l y i n reference to construction impacts.  For example, i t was mentioned that a gravel truck would l i k e l y  pass a certain point on an e x i s t i n g public road for two consecutive  years  - 91 -  at approximately four minute intervals for eight hours a day during f i v e 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 s i t e and w i l l pass within 1/2 mile from r e s i d e n t i a l homes i n an existing community.  I t was not mentioned  i n the report whether there were any homes near the gravel s i t e or e x i s t ing public highway.  I t i s l i k e l y that noise and perhaps dust w i l l cause  s i g n i f i c a n t aesthetic displeasure to any nearby residences. C r i t e r i o n IV —  Ecological Impacts  As i n the i d e n t i f i c a t i o n of socioieuibtural e f f e c t s , there are several apparent impacts which were not discussed i n the Seven Mile Project environmental studies.  I t was mentioned e a r l i e r under C r i t e r i o n  I that the report completed by Envirocon did not describe the construction a c t i v i t i e s associated with the proposed Seven Mile Dam project.  Likewise,  construction impacts on the natural physical and natural b i o l o g i c a l environment were not even mentioned.  An example of a p o t e n t i a l l y s i g n i -  f i c a n t construction impact for this project i s the development of a gravel p i t near the construction s i t e to obtain materials for the dam.  The  s o c i o - c u l t u r a l impact report mentioned that during normal working hours and days a loaded gravel truck w i l l pass any one point i n the road to the dam s i t e on the average of every seven and one-half minutes. frequency w i l l occur f o r two consecutive years and w i l l  This  decrease^to  approximate 20 minute intervals for two following years. a^Thus ; ;.a gravel 1  p i t 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 -  t h e b l o c k a g e of s i l t d e p o s i t i o n downstream due to the e x i s t e n c e of the dam,  d e c r e a s e d downstream oxygen l e v e l s and changed water  temperature  i n t h e r i v e r from t h e e l i m i n a t i o n o f n i n e m i l e s o f t u r b u l e n t f l o w i n g s t r e a m , and the e f f e c t of t h e proposed r e s e r v o i r on groundwater i n nearby r e s i d e n t i a l a r e a s .  levels  A l l of t h e s e impacts have p o t e n t i a l  con-  sequences which may be i m p o r t a n t i n the a r e a a f f e c t e d by t h e Seven M i l e Project. C r i t e r i o n VI —  Short-Term Resource Uses v s . 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 t o d e c i d e whether  a proposed a c t i o n m e r i t s p u b l i c investment w i t h o u t b a l a n c i n g t h e l o n g term consequences w i t h t h e s h o r t - t e r m e f f e c t s .  This includes a d i s -  c u s s i o n of t h e r e s o u r c e o p t i o n s a v a i l a b l e t o f u t u r e g e n e r a t i o n s w h i c h would be f o r e c l o s e d by a proposed p r o j e c t (eg, use o f renewable and nonrenewable r e s o u r c e s ) .  To f u l f i l l t h i s requirement a d e q u a t e l y would be t o  i n c l u d e a s e p a r a t e d i s c u s s i o n i n an e n v i r o n m e n t a l r e p o r t of s h o r t - t e r m g e n e f i c i a l and a d v e r s e e f f e c t s compared t o t h e i m p o r t a n t l o n g - t e r m b e n e f i c i a l and adverse e f f e c t s .  Thus, t h e r e a d e r w i l l be h e l p e d i n  a s s i g n i n g importance t o the impacts and w i l l l i k e w i s e be b e t t e r a b l e t o judge t h e s o c i a l w o r t h o f t h e e n t i r e p r o j e c t . impacts was  A l t h o u g h the time span of  g e n e r a l l y d e f i n e d i n the Seven M i l e P r o j e c t impact  studies,  no s e p a r a t e d i s c u s s i o n a t t e m p t i n g t o j u x t a p o s e t h e s e d i f f e r i n g t y p e s of impacts was  included.  Criterion VII —  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 d i s c u s s e d i n t h e e n v i r o n m e n t a l impact  -  93 -  studies f o r the proposed Seven Mile Project. C r i t e r i o n VIII —  Relationship to Established Goals  The B.C. Research socio-economic impact study discussed the impact of the proposed project on e x i s t i n g physical services i n the two nearby regional d i s t r i c t s , but no reference was made i n either study to any formal planning reports or any public p a r t i c i p a t i o n related to the project, or goals and objectives of the c i t i z e n s established l o c a l l y or regionally. C r i t e r i o n IX —  Communication of Information  As mentioned several times i n t h i s thesis, the purpose of an environmental impact statement i s to communicate the t o t a l consequences of the proposed project to the reader.  The existence of two separate  impact studies f o r 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 i n d i v i d u a l l y 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 i n the two impact studies.  For example, the r e -  port completed by Envirocon  the p o t e n t i a l adverse  economically  evaluated  recreation impact of the proposal, although e x i s t i n g recreational opport u n i t i e s are actually a s o c i a l condition.  B.C. Research completed a  report e n t i t l e d "The Social and Economic Impacts of the proposed Seven Mile Hydro-Electric Project" which discussed recreation impacts but not i n economic terms.  Such an evaluation of impacts i n two overlapping  reports i s confusing to the reader and could actually serve to conceal  - 94 -  some important  p o t e n t i a l consequences from public view.  The overlapping  scope of these reports i s not the fault of the authors because they were guided by the terms of reference from B.C. Hydro which are included i n Appendix G.  As can also be seen i n these terms of reference, the lack  of compliance with some of the c r i t e r i a discussed e a r l i e r 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 b e n e f i c i a l consequences. Since no r e a l economic e f f i c i e n c y analysis was included, i t i s d i f f i c u l t to reach a r a t i o n a l judgement about the s o c i a l worth of the proposal i f only negative consequences are disclosed.  In this respect, i t i s f e l t  that an impact report should provide an unbiased account of a l l the s i g n i f i c a n t b e n e f i c i a l and adverse consequences of the proposed project so that the reader can "weigh" these impacts to reach an informed, r a t i o n a l decision. Detailed reports can also communicate information i n a misleading manner.  For example, a b e n e f i c i a l s o c i a l impact which was described  by the B.C. Research socio-economic study was the short-term input to l o c a l economies during construction of the project due to increased employment and subsequent increased spending i n the region. the increased l o c a l expenditures B.C.  In general,  are a benefit, but i t i s f e l t that the  Research report quantified this effect i n a misleading way.  By  quantifying this impact i n d o l l a r s , i t over-emphasized the r e a l benefits which are increased income to l o c a l residents.  A considerable amount of  the quantified t o t a l of increased expenditures within the region would be disbursed by l o c a l r e t a i l e r s for supplies and other a d d i t i o n a l  - 95 -  expenses, which therefore cannot r e a l l y be considered a monetary "benef i t " to these l o c a l residents.  Although the B.C. Research report also  quantified this benefit more accurately i n increased regional employment i n l o c a l r e t a i l , wholesale and manufacturing s t a f f s , quantifying i n creased expenditures regionally and r e f e r r i n g to i t as a benefit d i s guises and over-emphasizes  the r e a l benefit which i s 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 , r e l a t i v e l y minor c r i t i c i s m concerning the  communication  of information to persons reading these studies i s that the basic i n ventory of s o c i o - c u l t u r a l 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 i n most environmental impact statements, out  of necessity, discuss the existing environmental conditions i n the  area(s) affected by the proposed project.  I t i s more d i f f i c u l t for the  reader of the report to i d e n t i f y 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 i n a separate section of the text.  COLSTRIP GENERATION AND TRANSMISSION PROJECT  The $800,000 assessment of this e l e c t r i c a l plant and transmission l i n e project by Westinghouse  Environmental Systems has a scope that i s  actually broader than an environmental impact statement.  It i s a total  planning analysis which not only considers environmental impacts but also  - 96 -  includes an intensive analysis of s i t e and route l o c a t i o n choices, a l t e r native designs, broad s o c i a l issues and public viewpoints r e l a t i n g to the proposal, and monitoring programs.  As stated i n the introduction of  the environmental impact report, i t was prepared as "... a source document 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 e f f e c t s . " U.S.  The report complies with the  National Environmental Policy Act of 1969 and with the Montana  U t i l i t y S i t i n g 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 l i n e system with two substations. In the 37 year l i f e of the proposed plant, approximately  296 m i l l i o n tons  of low sulphur coal w i l l be strip-mined within 10 miles of the proposed plant s i t e .  The e l e c t r i c a l 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 i n two underground s t e e l p i p e l i n e s .  The power  generated by the plant w i l l be conveyed by dual 500 kv transmission l i n e s 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 i n southeastern Montana near the small community of C o l s t r i p (see Figure IV-2) approximately Billings.  100 miles east of  The region i n the v i 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  * PLANT  SITE  FIGURE I W 2 .  L o c a t i o n and g e n e r a l s t u d y a r e a o f t h e C o l s t r i p Thermal Power (Westinghouse E n v i r o n m e n t a l Systems,  1973)*  Development  - 98 -  ENVIRONMENTAL INVENTORY Description of Actions Description of Setting Affected Delineation of "Affected" Area ECONOMIC EFFICIENCY L i s t o f Assumptions Use o f S t a n d a r d i z e d Approach SOCIO-CULTURAL IMPACTS Comprehensive I d e n t i f i c a t i o n Q u a n t i t a t i v e Assessment Importance Assignment^ ECOLOGICAL IMPACTS Comprehensive I d e n t i f i c a t i o n Q u a n t i t a t i v e Assessment Importance Assignment^ DISTRIBUTION CONSEQUENCES I d e n t i f i e d t o Groups I d e n t i f i e d t o Areas SHORT-TERM VS. LONG-TERM EFFECTS D i s c u s s i o n o f F u t u r e Uses C u r t a i l e d  * *  ANALYSIS OF ALTERNATIVES C h o i c e o f "No A c t i o n " I n c l u d e d Range o f C h o i c e s I n c l u d e d 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 P r o j e c t Rationale Included Report L o g i c a l l y O r g a n i z e d and " O b j e c t i v e " Report S u c c i n c t , N o n - T e c h n i c a l Summary I n c l u d e d  TABLE I V - 2 .  * * ^  C h e c k l i s t summary o f non-compliance w i t h c r i t e r i a f o r t h e C o l s t r i p g e n e r a t i o n and t r a n s m i s s i o n p r o j e c t E I S .  I n d i c a t e s an inadequate d i s c u s s i o n o f r e q u i s i t e i n e n v i r o n m e n t a l impact statements. On page 39 f o u r c o n s i d e r a t i o n s i n c o n j u n c t i o n w i t h 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 t o f a c i l i t a t e t h e r e a d e r o f an EIS i n a s s i g n i n g importance t o  - 99  -  natural environment i n this Region i s mostly r o l l i n g p r a i r i e 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 dent game b i r d s .  resi-  The study area for the transmission route i s diverse  since i t comprises, a 36,000 square mile section of Montana, including r o l l i n g grassland p r a i r i e s , scenic mountain ranges, wide valleys and numerous r i v e r s and streams.  NON-COMPLIANCE WITH CRITERIA 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 C o l s t r i p environmental impact report adequately defined the time span of s i g n i f i c a n t e f f e c t s , but did not include a separate discussion contrasting s i g n i f i c a n t short-term long-term implications.  impacts with p o t e n t i a l  For example, the use of 260 m i l l i o n tons of  coal during the 37 year l i f e of the plant constitutes a s i g n i f i c a n t depletion of a non-renewable resource. f o s s i l - f u e l resources EIS concerning  The numerous p o t e n t i a l uses of  today d i r e c t s that consideration be given i n an  whether thermal power production  i s the highest  best use of coal for present and future generations. a l t e r n a t i v e uses of coal was  and  No discussion of  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 f u e l powered plant choices, meeting t h i s demand through a c o a l - f i r e d plant was of this, non-renewable resource.  the best possible use  Related to this c r i t i c i s m of the impact  - 100  report i s a rather cursory w h i c h was  -  c o n s i d e r a t i o n of the "no  d i s c a r d e d w i t h o u t a n a l y s i s due  action" alternative,  to the "adverse socio-economic  consequences" which would r e s u l t i n the Northwest U.S. projected  meeting  f u t u r e demands:.  C r i t e r i o n VII —  A n a l y s i s of A l t e r n a t i v e s  S e v e r a l a l t e r n a t i v e s i t e / r o u t e l o c a t i o n s and were t h o r o u g h l y a s s e s s e d a c c o r d i n g n i n g methods but, "no  from not  design  choices  to s o p h i s t i c a t e d e n v i r o n m e n t a l  as mentioned e a r l i e r , t h e r e was  not an a n a l y s i s of  a c t i o n " a l t e r n a t i v e or an assessment of a l t e r n a t e e l e c t r i c a l  energy  The  t h i s volume p r o v i d e s  an appearance of comprehensiveness which i s perhaps  so  the l a c k of a n a l y s i s of the b a s i c EIS  11 x 16  the  demand p r o j e c t i o n s .  why  e i g h t pound weight and  plan-  i n c h format of  requirement o f "no  action" i s  striking. An a p p a r e n t i - a l t e r n a t i v e which, was  the EIS  not  assessed thoroughly i n  i s l o c a t i n g the p l a n t i n western Montana and  c o a l to t h i s s i t e .  I t was  transporting  mentioned i n the r e p o r t t h a t o v e r  o f the e l e c t r i c a l energy generated by  the p l a n t would be  the  two-thirds  transmitted  western Montana to hook-up w i t h the B o n n e v i l l e Power A u t h o r i t y 500 lines.  Despite  kv.  the amount of energy to be sent west, the a n a l y s i s of  whether i t s h o u l d considered  to  be t r a n s p o r t e d  i n the form o f c o a l or  o n l y the monetary c o s t s i n v o l v e d and  d i d not  electricity a d e q u a t e l y com-  municate the b a s i c t r a d e o f f o f d i f f e r e n t e n v i r o n m e n t a l impacts of l o c a t i n g the p l a n t s i t e i n western Montana (the need f o r 430 500 coal  kv.  l i n e s , would be  transport.  eliminated)  at the i n c r e a s e d  miles  of  economic c o s t s  of  - 101  C r i t e r i o n IX —  -  Communication of Information  The most important c r i t i c i s m of the C o l s t r i p environmental impact report i s that the great s i z e of this impressive volume r e s t r i c t s a l l but the most persevering reader from assimilating the relevant i n formation  from the report to reach a r a t i o n a l judgement about the  proposal.  Even attempting to f i n d a p a r t i c u l a r aspect of the  proposal  is; d i f f i c u l t i n thisr, volume since the table of contents t o t a l s 11 sheets in length.  Although the report may  q u a l i f y as a "source document," i t  i s doubtful that decision-makers or many other interested persons i n society w i l l be able to absorb the vast amount of data included i n the report.  Yet, the report did include a major summary of the project's  environmental impacts.  I f this summary i s meant to inform the reader  of the important consequences of the C o l s t r i p Project, two major problems a r i s e .  F i r s t , the summary does not include a l l of the major  impacts of the project.  For example, many regional s o c i o - c u l t u r a l  impacts which, to this author, seem s i g n i f i c a n t were not discussed i n the summary.  The prospective appearance of the "boom and bust" towns  i n the region from project construction and the subsequent e f f e c t s on existing residents i n the regions were not mentioned i n the summary of s o c i a l and economic impacts.  Instead, regional and statewide economic  benefits were described i n 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 i s that i t gives the pression that i t was written merely to j u s t i f y the proposed project.  im-  - 102  -  T h i s i s most e v i d e n t from the q u a l i f y i n g statements which were o f t e n used to i d e n t i f y adverse impact.  For example, the summary o f e n v i r o n -  mental c o s t s b e g i n s w i t h the sentence " s t a t e and f e d e r a l a p p l i c a b l e to a i r , l a n d and water w i l l be met  regulations  and the e n v i r o n m e n t a l  impact o f the p l a n t and t r a n s m i s s i o n l i n e w i l l be minor, as shown i n T a b l e s 1. 7-2  and 1. 7-3."  This table  (see T a b l e IV-3 and IV-4)  pro-  v i d e s q u a n t i t a t i v e f i g u r e s which have v e r y l i t t l e meaning t o the r e a d e r , and i f a n y t h i n g , seem t o i n d i c a t e impacts t h a t would be s i g n i f i c a n t to many p e r s o n s .  A d e s c r i p t i o n o f the v i s u a l impact o f the t r a n s m i s s i o n  l i n e s : b e g i n s w i t h the sentence "Although, the l i n e w i l l impinge  unavoid-  a b l y on the v i e w o f p e o p l e i n some a r e a s , every attempt has been made i n s e l e c t i n g the r o u t e t o minimize the number o f v i e w e r s , 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  qualifying  statement c o n c e r n i n g r a d i o r e c e p t i o n near the t r a n s m i s s i o n l i n e s ment i o n s t h a t "During i n c l e m e n t weather, r e c e p t i o n v e r y near the l i n e may  e s p e c i a l l y d u r i n g r a i n or snow,  not be e n t i r e l y s a t i s f a c t o r y .  atmospheric n o i s e a l o n e would p r o b a b l y cause a problem under conditions"  However,  such weather  (end o f p a r a g r a p h ) .  The p r i o r comments c o n c e r n i n g the Westinghouse  Report  serving  to j u s t i f y the C o l s t r i p p r o j e c t r a t h e r than a t t e m p t i n g t o o b j e c t i v e l y i d e n t i f y the e n v i r o n m e n t a l impact l e a d s one to suspect whether the volume was  prepared f o r any d e c i s i o n - m a k i n g purpose.  Westinghouse  was  first  I t i s also true that  engaged i n January o f 1973  t o undertake  this  r e p o r t , a t a time when two o f the f o u r C o l s t r i p t u r b i n e g e n e r a t o r s were  - 103 -  ESTIMATED BENEFITS OF THE COLSTRIP PROJECT Benefits Delivered Products: Total power generating capacity, Mw Value of total electrical power annually, S 1 0 Power delivered to Hot Springs terminal, Mw  2060 133  6  1350  Employment: Construction labor force—Power plant employees, maximum Transmission line employees  1658 360  Operational labor force—Direct employees Indirect employees  820 1400  Income: Total construction labor personal income, S10 Total annual direct operational labor personal income. S10 Total personal income over plant economic lifetime, S 1 0 —Direct operational —Indirect 3  6  196 9.4  6  Tax Revenues: Total annual tax revenues, S 1 0 Total tax revenues over plant economic lifetime, S10 6  Present Value of Benefits:* Electrical power purchased, S10 Personal income. S10 Tax revenues, S 10  9  6  s  6  345 557 17.4 648 1.3 376 172  Economic benefits over economic plant lifetime.  TABLE IV-3. Summary benefits of the proposed Colstrip thermal power development (Westinghouse Environmental Systems, 1973).  - 104 -  C O S T S U M M A R Y FOR POWER P L A N T 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*  11.9.  NO?, tig/m*  14.0  Particulates, ^g/m One-hour maximum ground-level concentration SOs. fig/m  15.2  1  643  3  Maximum exposure of off-site locations to ground fog, hr  37  Terrestrial Impact: Total cropland disturbed or converted to other use, acres  332  .  Other land disturbed or converted to other use. acres  602  Strip-mined and reclaimed, acres  11.000  Land converted to aquatic habitat and recreation area (surge pond), acres  150  Aquatic Impact: Maximum water use rate, cfs  59  Biological and physical impacts  Negligible  C O S T S U M M A R Y FOR COLSTRIP TO H O T SPRINGS T R A N S M I S S I O N LINE Economic Costs Capital costs,! includes stations and access roads) Dollars  5120,517.315  Annual electrical loss penalty, dollars/year  6,980.000  Environmental Costs Terrestrial Impact: Wildlife, miles of range crossed* Soil erosion, acres  2.034 865  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 Total annual viewing time from highways, man-hours  205 867,787  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 d e t a i l i n the Westinghouse  environmental impact statement  was devoted to selecting a s i t e for the plant according to ecological and economic c r i t e r i a .  Consequently, the author of this c r i t i q u e be-  lieves that the p r i n c i p a l benefit of this detailed volume was i n developing mitigation measures for environmental impacts.  A commendable  report was, completed i n 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 i n 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 prosperity i n an indigent area of Washington at the price of p o t e n t i a l l y s i g n i f i c a n t a i r , water and land quality impacts.  This controversial  project prompted more than 150 written comments from private c i t i z e n s , 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 i n western society today.  The environmental  impact report attempts to assess the consequences of t h i s proposal to f a c i l i t a t e public scrutiny, government agency review and subsequent decisions about the s o c i a l worth of the proposal. ft A less impressive impact statement had been prepared at an e a r l i e r date for construction approval of the project.  - 106 -  BRIEF DESCRIPTION OF PROPOSED PROJECT AND ENVIRONMENTAL SETTING The proposed p r o j e c t by Northwest A l l o y s , I n c . (a s u b s i d i a r y o f the  Aluminum Company o f America) e n t a i l s a m i n i n g o p e r a t i o n and a p r o -  c e s s i n g p l a n t which would produce magnesium and s i l i c o n p r o d u c t s . ing  p l a n s f o r the m i n i n g a c t i v i t i e s  i n c l u d e t h e development  Exist-  o f s i x open  p i t d o l o m i t e and q u a r t z i t e mines w i t h i n 13 m i l e s o f t h e p l a n t s i t e .  The  p l a n t w i l l u t i l i z e between 400,000 and 650,000 tons o f b o t h d o l o m i t e and q u a r t z i t e a n n u a l l y , l a r g e amounts o f groundwater 950,000 megawatt hours o f e l e c t r i c a l  and a p p r o x i m a t e l y  energy p e r y e a r t o produce peak  t o t a l s o f about 79,800 annual tons o f magnesium and s i l i c o n p r o d u c t s . The proposed p l a n t would be l o c a t e d near t h e s m a l l community o f Addy i n Stevens County o f n o r t h e a s t e r n Washington. the  The p o p u l a t i o n o f  e n t i r e county i s : a p p r o x i m a t e l y 18,000 p e o p l e , and t h e economy o f t h e  r e g i o n i s . based on a g r i c u l t u r e , t h e lumber vices..  i n d u s t r y and s u p p o r t i n g s e r -  The community o f Addy i s n e s t l e d near two mountains  and p a s t o r a l C o l v i l l e  River Valley.  i n the scenic  Forest vegetation i n the elevations  above t h e a g r i c u l t u r a l v a l l e y i n c l u d e s t h e dominant  s p e c i e s o f Ponderosa  P i n e (Pinus ponderosa) and Douglas F i r (Pseudotsuga m e n z i e s i i ) and the v a l l e y e x i s t s as an important w i n t e r i n g a r e a f o r l a r g e p o p u l a t i o n s o f deer.  The c l i m a t e i n the v a l l e y i s d r y (13-27 i n c h e s p e r y e a r ) , b u t  c o l d i n Winter  (frequent temperatures below 0°) and warm i n Summer  (frequent h i g h temperature above 9 0 ° ) . is, v e r y poor.  A i r c i r c u l a t i o n i n the v a l l e y  - 107 -  FIGURE IV-3.  L o c a t i o n o f the proposed magnesium p l a n t a t Addy Washington S t a t e Department of E c o l o g y , 1973).  (from  - 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 i n environmental impact statements.  ''On page 39 four considerations i n conjunction with quantitative predictions were developed to facilitate the reader of an EIS i n assigning importance to impacts.  —109  -  NON-COMPLIANCE WITH CRITERIA Criterion 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 a n a l y s i s was  not completed f o r  t h i s proposed magnesium p l a n t , s u c h an a n a l y s i s s h o u l d not be expected s i n c e p u b l i c funds a r e n o t b e i n g a l l o c a t e d toward t h i s  Criterion III —  Socio-Cultural  project.  Impacts  The Impact statements f o r the Northwest  A l l o y s Magnesium P l a n t  at Addy d i d n o t q u a n t i f y o r a d e q u a t e l y d e s c r i b e some s o c i a l For  impacts.  example, the impact on community and s o c i a l s e r v i c e s was  described  merely as caused by i n c r e a s e d p o p u l a t i o n i n the county which would r e s u l t i n e i t h e r a d e c l i n e i n q u a l i t y o f the s e r v i c e s o r i n d u c i n g a d d i t i o n a l e x p e n d i t u r e s i n o r d e r to keep pace w i t h demand.  No  projections  were made c o n c e r n i n g the degree o f expansion i n p o l i c e , f i r e  protection,  s c h o o l s , r o a d s , water and sewer l i n e s , and m e d i c a l f a c i l i t i e s , nor d i d the  statement a s s e s s the l i k e l i h o o d o f each s e r v i c e r e q u i r i n g  expansion.  L i k e w i s e , t h e r e was no q u a n t i f i c a t i o n o f the i n c r e a s e d l o c a l taxes which c o u l d r e s u l t from the i n c r e a s e d s e r v i c e s r e q u i r e d due to t h e p r e d i c t e d a d d i t i o n o f 3000 to 5000 persons i n the county induced by the proposed project. A s o c i a l impact which was not c o n s i d e r e d i n the r e p o r t the  e f f e c t o f the p r o j e c t on housing i n the r e g i o n .  concerns  The o n l y mention o f  t h i s r e s i d e n t i a l growth i n the EIS s t a t e d t h a t "... s m a l l towns, v i l l a g e s and i s o l a t e d farms:, w i l l  g r a d u a l l y change as towns and suburbs expand."  The EIS would be more comprehensive d e s c r i b e d the reasons why  i n r e l a t i o n t o s o c i a l impacts i f i t  no h o u s i n g s h o r t a g e would o c c u r ( i f t h i s i s  - 110 -  the reason why i t was n o t d i s c u s s e d  i n t h e EIS)  o r attempt t o i d e n t i f y  the p o t e n t i a l e x t e n s i v e n e s s o r r i s k o f such an o c c u r r e n c e . c u l t u r a l e f f e c t s which were n o t d i s c u s s e d  i n t h i s impact r e p o r t  impacts, on e t h n i c groups o r e x i s t i n g w e l f a r e A f i n a l c r i t i c i s m concerning  Other s o c i o concern  s e r v i c e s i n the area.  the treatment o f s o c i o - c u l t u r a l  impacts i n t h e r e p o r t i s t h a t no mention was made o f any p o s s i b l e measures: which c o u l d reduce the i n t e n s i t y o f adverse e f f e c t s . r e g i o n which would be a f f e c t e d by t h e p r o j e c t i s d e s c r i b e d "...  Since t h e as b e i n g  r u r a l , serene, s c e n i c , t r a n q u i l and n a t u r a l , " an example o f p o s s i b l e  m i t i g a t i o n measure i s t h e development o f a c o n t r o l l e d growth p l a n f o r t h e quaint  v i l l a g e o f Addy and e n v i r o n s  thetic setting.  which would h e l p p r e s e r v e t h i s  aes-  Another p o s s i b l e m i t i g a t i o n a c t i o n would be t h e forma-  t i o n o f a c i t i z e n committee i n the County t o recommend s t e p s  to a l l e v i a t e  f u t u r e problems, as: t h e y a r i s e due t o t h e expected r a p i d growth induced by t h e p l a n t . facilitating  Although, an impact r e p o r t s e r v e s  s o c i a l l y r e s p o n s i b l e d e c i s i o n s , i t should  a u x i l i a r y use o f s u g g e s t i n g  C r i t e r i o n IV — The  a primary f u n c t i o n i n a l s o s e r v e an  p o s s i b l e methods t o l e s s e n problems.  E c o l o g i c a l Impacts  o n l y important c r i t i c i s m c o n c e r n i n g  t h e treatment o f e c o l o -  g i c a l impacts i n t h e EIS p r e p a r e d by t h e Washington S t a t e Department o f 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,.  F o r example, t h e impact r e p o r t s t a t e s  that  m o s t l y a l l o f t h e s u l f u r d i o x i d e produced from p l a n t o p e r a t i o n s emitted  w i l l be  i n t o t h e atmosphere, p r o b a b l y 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.  - Ill -  A f t e r the EIS d e s c r i b e d t h i s and o t h e r a i r q u a l i t y impacts, t h e r e was  no  d i s c u s s i o n o f d i f f e r e n t methods o f a i r p o l l u t i o n c o n t r o l d e v i c e s which c o u l d reduce t h i s impact to a c c e p t a b l e l e v e l s . utilizing  D e v i c e s such as s r u b b e r s  an a l k a l i n e s o l u t i o n can reduce s u l p h u r d i o x i d e l e v e l s  siderably.  con-  M i t i g a t i o n and compensation measures might a l s o have been  suggested c o n c e r n i n g n o i s e impacts, water p o l l u t i o n , a e s t h e t i c impacts, and the e l i m i n a t i o n o f deer h a b i t a t . The f i n a l EIS f o r t h i s proposed magnesium p l a n t a t Addy a l s o i n c l u d e d a l l w r i t t e n responses c o n c e r n i n g the d r a f t statement from government a g e n c i e s , i n t e r e s t groups and p r i v a t e c i t i z e n s .  Some of t h e s e com-  ments noted a few: minor shortcomings w i t h t h i s p a r t o f the d r a f t ,  and  mostly r e f e r r e d to m i s l e a d i n g statements o r an o m i s s i o n o f d a t a t h a t would have made the impact d e s c r i p t i o n more m e a n i n g f u l to the r e a d e r . One  e n l i g h t e n i n g comment was  s i t y who  from a s c i e n t i s t  at Washington  State Univer-  s t a t e d t h a t the EIS, i n d i s c u s s i n g the p r o j e c t impact on the  e x i s t i n g s u p p l y of energy i n the s t a t e , s h o u l d a l s o have a s s e s s e d the e f f i c i e n c y o f the magnesium p r o c e s s i n g o p e r a t i n g i n u t i l i z i n g and o t h e r energy r e s o u r c e s . s t a t e o f Washington  electrical  S e v e r a l months f o l l o w i n g t h i s comment the  s u f f e r e d s i g n i f i c a n t energy s h o r t a g e s .  Other  res-  ponses to the d r a f t statement noted t h a t the EIS s h o u l d have d i s c u s s e d more f u l l y the v i s u a l impacts o f a i r p o l l u t i o n , p o t e n t i a l leakage from a s l a g pond i n t o ground water s u p p l i e s , the c u m u l a t i v e e f f e c t of p r o j e c t induced a c t i o n s on f i s h , and w i l d l i f e and s e v e r a l assumptions c o n c e r n i n g 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 o f I n f o r m a t i o n  In g e n e r a l , the EIS f o r the proposed Northwest A l l o y s Magnesium P l a n t i d e n t i f i e d t h e 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 r e p o r t can  he c o n s i d e r e d r e a s o n a b l y c o n c i s e , t h e d i v e r s e n a t u r e o f impacts  asso-  c i a t e d with, t h e p r o p o s a l l e d t o a d r a f t EIS over 300 pages i n l e n g t h . D e s p i t e t h e s i z e o f t h i s r e p o r t , n e i t h e r the d r a f t o r f i n a l EIS i n c l u ded a s e p a r a t e summary s e c t i o n , a l t h o u g h t h e c o n c l u s i o n s d i d b r i e f l y d e s c r i b e a l l s i g n i f i c a n t environmental T h i s is. an important  impacts  o f t h e proposed p l a n t .  drawback o f t h i s EIS s i n c e every attempt s h o u l d be  madeftoccommunicate t h e consequences o f a p r o p o s a l t o and  the p u b l i c .  impact ready  statements  decision-makers  Thus, a summary s e c t i o n s h o u l d be i n c l u d e d i n a l l i n o r d e r t o r e f r e s h t h e memory o f those who have a l -  read t h e EIS and t o i n f o r m persons  u n w i l l i n g o r unable  t o read  t h r o u g h t o t h e c o n c l u s i o n s o f these o f t e n l e n g t h y r e p o r t s .  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 e x t e n s i o n was completed by Haworth and Anderson Planning Consultants to f u l f i l l mental P o l i c y A c t o f 1969.  requirements  of the N a t i o n a l Environ-  The p r o p o s a l 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 s t u d i e s were undertaken f o r a major expansion  o f t h e crowded P o r t l a n d I n t e r n a t i o n a l A i r p o r t .  expansion  attempt i n c l u d e d an ambitious  dredge and f i l l  This early operation i n  the Columbia R i v e r f o r the c o n s t r u c t i o n o f new runways, and o t h e r  - 113 -  actions which l e d to a challenge i n the courts from f i v e groups that the plans: required congressional approval.  environmental The expansion  plans were expected to Be delayed i n the courts at least u n t i l 1978. This: prompted airport planners to propose, i n 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. proposal was i n 1973 and thus: an environmental required under NEPA.  This newer  impact statement was  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 i n July of 1973 to a cancellation of both this newer proposal and the e a r l i e r expansion plans.  Finally,  Haworth and Anderson, Inc. were hired to prepare an EIS on the f e a s i b l e future alternatives for the Portland International A i r p o r t .  BRIEF DESCRIPTION OF PROPOSED PROJECT AND ENVIRONMENTAL SETTING Four f e a s i b l e alternatives were defined f o r the a i r p o r t .  One  alternative was the "no project" option, and the remaining three a l t e r natives included the following d i f f e r e n t lengths and d i r e c t i o n s of the south, runway: Plan  I —  Plan I I — Plan I I I —  2200 f t . west extension 2200 f t . west and 700 f t . east extension 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, Washington (see Figure IV-4).  The elevation of the airport i s only 20 feet  above the mean l e v e l of the Columbia River, but i s protected by levees  - 114 -  FIGURE IV-4.  G e n e r a l l o c a t i o n o f the P o r t l a n d I n t e r n a t i o n a l (from Haworth and Anderson, 1973).  Airport  - 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 I V - 6 . Checklist summary of non-compliance with criteria for the Portland International Airport Runway Extension EIS  *  Indicates an inadequate discussion of requisite i n environmental impact statements.  1  •  •  On page 39 four considerations i n conjunction with quantitative predictions were developed to facilitate the reader of an EIS i n assigning importance to impacts.  - 116 -  and regulated flows upstream.  Vegetation  i s sparse i n the immediate  v i c i n i t y due to the sandy, a l l u v i a l deposits of the Columbia River.  At  present, considerable r e s i d e n t i a l development exists immediately south and north of the proposed a i r p o r t , while r e s i d e n t i a l housing i s more scattered i n the east and west. 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  An economic e f f i c i e n c y 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 e f f i c i e n c y analysis but did not i d e n t i f y to the reader the assumptions which were part of the assessment.  An i l l u s t r a t i o n of this c r i t i c i s m concerns the  analysis of the economic impact of project construction.  This analysis  quantified these construction impacts i n number of persons employed, t o t a l p a y r o l l 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 r e s u l t s i n what seems to be  s i g n i f i c a n t 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.  I t i s more l i k e l y  that only a portion of those working on construction of the project w i l l actually r e s u l t i n b e n e f i c i a l economic impacts to the state of Oregon.  C r i t e r i o n III - Socio-Cultural Impacts In describing environmental impacts i n a report, i t i s necessary that the magnitude of e f f e c t be defined to help the reader value that  - 117  consequence.  -  An important s o c i a l impact o f an a i r p o r t which was  ex-  t e n s i v e l y a n a l y z e d i n the EIS i s n o i s e from a r r i v i n g and d e p a r t i n g a i r craft.  This, impact was  q u a n t i f i e d i n NEF  ( n o i s e exposure  forecasts)  f i g u r e s and contours were even i l l u s t r a t e d on a rough l a n d - u s e map the a r e a s u r r o u n d i n g the a i r p o r t , but the t e x t never mentioned  of  the  numher o f homes a f f e c t e d by adverse n o i s e exposure o r the t o t a l monetary v a l u e o f those r e s i d e n c e s .  Consequently, the t e x t d i d i n d i c a t e  r e s i d e n t i a l areas a r e a d v e r s e l y a f f e c t e d by the a i r p o r t , but  that  persons  r e a d i n g the EIS have v e r y l i t t l e u n d e r s t a n d i n g o f the e x t e n s i v e n e s s o f this, s o c i a l impact or the f i n a n c i a l c o s t s o f p u r c h a s i n g these homes to r e l o c a t e the f a m i l i e s ; .  F u r t h e r , the EIS d i d not even c o n s i d e r l a n d  purchases: i n t h e s e impacted r e s i d e n t i a l areas as a compensation to reduce the magnitude o f h a r m f u l n o i s e and exposure C r i t e r i o n IX —  measure  levels.  Communication o f I n f o r m a t i o n  The g r e a t e s t weakness o f the EIS f o r the P o r t l a n d I n t e r n a t i o n a l A i r p o r t ' s runway e x t e n s i o n i s t h a t the consequences  o f the p r o p o s a l were  n o t p r e s e n t e d i n a form e a s i l y u n d e r s t a n d a b l e to the o r d i n a r y 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 o f s m a l l f a c t o r s t h a t caused the EIS to be so n e b u l o u s . l a r g e f o r most persons to r e a d .  F i r s t , the EIS was  too  A l t h o u g h o n l y one important impact  was  i d e n t i f i e d , t h e e n t i r e r e p o r t c o n s i s t e d o f over.250 pages o f s i n g l e spaced t y p e .  The a n a l y s i s , o f a i r p o l l u t i o n impacts comprised  30 pages  and c o n c l u d e d t h a t "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 i m p a c t i o n between no south, runway e x t e n s i o n and any type o f south runway e x t e n s i o n i s almost n o n - e x i s t e n t . "  At t i m e s , the EIS would d i g r e s s  into  - 118  insignificant details.  For example, a f t e r a l e n g t h y  e x i s t i n g drainage patterns engineering  -  d e s c r i p t i o n of  at the a i r p o r t , the r e p o r t d i s c u s s e d  work such as "The  i n s t a l l a t i o n of a p p r o x i m a t e l y 990  78-inch, storm'sewer p i p e has  occurred  and  82nd Avenue.  As  s u c h , the work completed w i l l not  a l t e r the e x i s t i n g d r a i n a g e p a t t e r n at PIA p o r t ) , and most o f i t was w h i c h i s not  a subject  On  to a vague EIS  grading  one  square f e e t o f p r i v a t e l a n d .  project, the  EIS  impacts  In d e s c r i b i n g  c h o i c e s , the EIS noted t h a t P l a n  acres, of p r i v a t e l a n d and,  ed 120  significantly  i s t h a t many times i t would d i s c u s s  a l t e r n a t i v e runway e x t e n s i o n  run-  A second f a c t o r , which  or a s p e c t s r e l a t e d to the p r o j e c t i n an u n c l e a r manner.  0.3  of the  several other-occasions  would d i s c u s s 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 . contributed  embank-  (Portland International A i r -  a s s o c i a t e d w i t h the f i l l i n g and  of t h i s EIR."  f e e t of  to the e a s t , where the new  ment covers the p r e v i o u s l y e x i s t i n g d r a i n a g e between the end way  recent  I affected  paragraph l a t e r , t h a t P l a n I I  affect-  At t i m e s , the EIS used u n d e f i n e d  t e c h n i c a l terms such as " i s o p l e t h c o n t o u r s "  and  "aircraft nacelles."  In the economic a n a l y s i s , employment, p a y r o l l and  "value  of o u t p u t " were  the t h r e e f a c t o r s q u a n t i f i e d to show the impact of the proposed p r o j e c t . V a l u e o f output was  described  a i r p o r t , but  never d e s c r i b e d  i t was  a i r p o r t employee was  as the goods and  to the r e a d e r how  c a l c u l a t e d , except by  Thus, a combination of l a c k of c o n c i s e n e s s t h a t is: f r u s t r a t i n g t o . r e a d  and  s e r v i c e s produced at  difficult  the s e r v i c e of  footnoting several and  an  sources.  c l a r i t y r e s u l t s i n an  f o r a person to understand  f u l l y the consequences of the proposed p r o j e c t .  the  EIS  - 119  -  WASHINGTON STATE ROUTE 82 FREEWAY  For major highway p r o j e c t s i n the U.S., statements  a r e u s u a l l y prepared  environmental  impact  f o r s m a l l segments of a p r o p o s a l i n b o t h  the l o c a t i o n and d e s i g n stages of p l a n n i n g .  Impact statements  are  pre-  pared f o r s m a l l segments because each s t a t e u s u a l l y a p p l i e s f o r f e d e r a l f u n d i n g f o r parts, of p r o j e c t s i n o r d e r 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 s t a t e .  an EIS f o r an e n t i r e highway.  The  Thus, i t i s d i f f i c u l t  environmental  impact  to o b t a i n  statement  reviewed  i n this; s e c t i o n i s a d r a f t f o r the d e s i g n p l a n n i n g s t a g e o f I n t e r s t a t e 82 between E l l e n s h u r g , Washington and P e n d l e t o n , Oregon.  The  EIS was  pared by the Washington State: Department o f Highways to f u l f i l l requirements initial  of NEPA and  impact  statement  p l a n n i n g work was  to q u a l i f y f o r f e d e r a l f u n d i n g .  pre-  the  I t i s the  f o r t h i s p a r t of I n t e r s t a t e 82, a l t h o u g h  early  completed t h a t p r e - d a t e s NEPA.  BRIEF DESCRIPTION OF PROPOSED PROJECT AND  ENVIRONMENTAL SETTING  The proposed p r o j e c t i s the c o n s t r u c t i o n of a p p r o x i m a t e l y  five  m i l e s of freeway near the s m a l l town of P r o s s e r , Washington (see F i g u r e IV-5).  The proposed freeway s e c t i o n w i l l c r o s s the Yakima R i v e r and a l s o  b i s e c t the P r o s s e r Game Reserve.  The  f o r r e s i d e n t and m i g r a t o r y game and The  r e s e r v e e x i s t s as a r e s t i n g  waterfowl.  c l i m a t e i n the r e g i o n i s d r y and  temperature below zero on two  c o l d i n Winter  (minimum  to f i v e n i g h t s a n n u a l l y ) and d r y and  i n the Summer (maximum temperature exceeds 100° on e i g h t to twelve annually).  Due  area  hot days  to this; h a r s h c l i m a t e , t h e r e i s r e l a t i v e l y s p a r s e n a t i v e  v e g e t a t i o n i n the P r o s s e r a r e a .  Much of the l a n d use i n the r e g i o n i s  - 120  FIGURE  IV  -5.  -  L o c a t i o n of the proposed i n t e r s t a t e freeway s e c t near P r o s s e r , Washington (Washington S t a t e 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.  * 1  * * * *  Checklist summary of non-compliance with criteria for the Washington State Route 82 Freeway EIS.  Indicates an inadequate discussion of requisite i n environmental impact statements.  On page 39 four considerations i n conjunction with quantitative predictions were developed to facilitate the reader of an EIS in assigning importance to impacts.  - 122 -  in i r r i g a t e d and dryland farming, while the natural areas are t y p i f i e d by bunchgrass, cheatgrass,  and sagebrush vegetative species.  Deer,  waterfowl, game birds and small mammals l i v e throughout the region during d i f f e r e n t times of the year. The small town of Prosser has a population of 2,954 (1970) and is. mainly a supply center for the a g r i c u l t u r a l region. NON-COMPLIANCE WITH CRITERIA Criterion 1 —  Project Description and Environmental Inventory  In describing the proposal, no mention was made of the construction a c t i v i t i e s involved with the project.  This section of the EIS  only discussed the alignment of the proposed highway i n r e l a t i o n to existing roads or other physical c h a r a c t e r i s t i c s , the projected future t r a f f i c of the highway, and i t s d i f f e r e n t engineering s p e c i f i c a t i o n s . In p a r t i c u l a r , this section of the ElSsshould have also mentioned where the gravel and borrow s i t e s are to be located and the number of men and equipment to be used during construction.  I t i s important that the  project description i n an EIS should discuss a l l aspects of the proposal which could r e s u l t i n environmental impacts.  Criterion II —  Economic E f f i c i e n c y  One purpose for requiring t h i s consideration i n an EIS i s 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 p o s i t i v e and negative and decide whether i t merits, public investment. yield, s o c i a l benefits are not meaningfully  impacts  Yet, some projects which  analyzed  i n 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 i n a benefit/cost r a t i o because the usual reasons for proposing highway projects are not e a s i l y quantified i n monetary terms r e a d i l y comparable with construction costs.  Although an impact statement for such projects do not necessari-  l y 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.  Criterion III —  These requirements were not f u l f i l l e d i n this EIS.  Socio-Cultural Impacts  The impact statement prepared by the Washington  State Department  of Highways did not adequately assess the s o c i o - c u l t u r a l consequences of the proposed freeway development.  I t was d e f i c i e n t i n a comprehensive  i d e n t i f i c a t i o n of impacts, discussion of mitigation and compensation measures, and d e f i n i t i o n of impact r i s k or uncertainty.  An i l l u s t r a t i o n  of the lack of comprehensiveness i n t h i s EIS concerns the apparent omission i n i d e n t i f y i n g some p o t e n t i a l construction impacts of the freeway project.  It was. stated i n the EIS that short—term economic benefits  to the town of Prosser w i l l r e s u l t from construction of Interstate 82, but the number of workers i n the prospective labor force was not defined, nor was the l o c a l vs. migrant d i s t r i b u t i o n of p o t e n t i a l laborers, whether the housing supply can meet the two-year population i n f l u x , and whether there would be an economic down-turn a f t e r construction i s completed.  Other s o c i o - c u l t u r a l impacts which may have been ignored  concerns the impact of the proposed freeway on e x i s t i n g archaeological remains and ethnic groups.  - 124  -  i  The  d i s c u s s i o n of b u s i n e s s  l o s s e s i n the town of P r o s s e r 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 e x e m p l i f i e s the o m i s s i o n the p r o j e c t , m i t i g a t i o n and c e r t a i n t y o f impact. tablishments  of inducement consequences of  compensation measures, and  un-  A f t e r q u a n t i f y i n g the number o f commercial  i n t h i s a r e a of P r o s s e r , t h e impact was  "Some i n i t i a l  r i s k and  l o s s of b u s i n e s s may  be e x p e r i e n c e d . . .  compensation measures o r r i s k / u n c e r t a i n t y was  es-  d e f i n e d merely as ."  No m i t i g a t i o n /  defined i n r e l a t i o n  these s e r v i c e s t a t i o n s and r e s t a u r a n t s i n the downtown a r e a .  to  Induce-  ment consequences were a l s o i g n o r e d even though i t i s commonly known t h a t o f t e n some commercial e s t a b l i s h m e n t s  will  l e a v e an o l d highway  l o c a t i o n i n town to l o c a t e at the main freeway i n t e r c h a n g e o u t s i d e of town.  T h i s c o u l d r e s u l t i n a weakened downtown c o r e and  s t a g e of sprawl  f o r a s m a l l community.  C r i t e r i o n IV —  E c o l o g i c a l Impacts  The  an  e c o l o g i c a l impacts of I n t e r s t a t e 82 were not  initial  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 r e l e v a n t impacts, and  consequences of the p r o j e c t were not  q u a n t i f i e d i n many c a s e s . i n the EIS as n e c e s s a r y l o c a t i o n was. not  For example, "borrow" s i t e s were mentioned  f o r c o n s t r u c t i o n of the freeway but  i d e n t i f i e d , the number of borrow s i t e s and  mate amount of m a t e r i a l r e q u i r e d was techniques  meaningfully  to be used  were not d i s c u s s e d .  ( i f any) I t was  not mentioned, and  their approxi-  reclamation  a f t e r these s i t e s have been e x p l o i t e d  stated only that "Contractor(s) w i l l  r e q u i r e d to s e l e c t sources w i t h Department of N a t u r a l Resources  be  - 125 -  regulations."  The e n v i r o n m e n t a l impact statement a l s o d i d n o t d i s c u s s  the  p o t e n t i a l l o s s o f animals from c o l l i s i o n s w i t h autos even though  the  proposed freeway b i s e c t s a s t a t e game r e s e r v e .  Furthermore, t h e  EIS d i d n o t d i s c u s s p o t e n t i a l h e a l t h and a e s t h e t i c e f f e c t s o f a i r p o l l u t i o n on humans d e s p i t e m e n t i o n i n g f u t u r e p o l l u t a n t i n c r e a s e s due to  g r e a t e r t r a f f i c volumes on t h e freeway and a l s o d e f i n i n g the p o s s i b l e  e f f e c t s on v e g e t a t i o n .  C r i t e r i o n V_ —  Distribution  Consequences  S i n c e t h e i n c i d e n c e o f e n v i r o n m e n t a l impacts has s p e c i a l meaning  and s i g n i f i c a n c e i n r e l a t i o n t o groups and a r e a s , an EIS s h o u l d  i n c l u d e a d i s c u s s i o n o f t h e d i s t r i b u t i o n a l consequences o f t h e p r o p o s a l i n o r d e r t o i n f o r m i n t e r e s t e d persons and f a c i l i t a t e  rational  decisions.  The EIS f o r t h e proposed freeway d i d n o t attempt t o c o n t r a s t t h e i n c i dence o f important b e n e f i t s w i t h major c o s t s i n o r d e r t o d e f i n e t h e i n t e r e s t group and r e g i o n a l v s . s t a t e  (or n a t i o n a l ) p e r s p e c t i v e o f  impacts..  C r i t e r i o n VI —  Short-Term Resource Uses v s . Long-Term E f f e c t s  The e f f e c t o f a p r o p o s a l on non-renewable  r e s o u r c e s and a con-  s i d e r a t i o n o f t h e p r o s p e c t i v e inducement consequences s h o u l d be d i s cussed i n an E I S . did  The EIS f o r I n t e r s t a t e 82 near P r o s s e r ,  Washington  i n c l u d e a s e p a r a t e d i s c u s s i o n o f t h e l o n g and s h o r t - t e r m c o n s e -  quences, o f t h e p r o j e c t b u t d i d n o t mention some important c o n s i d e r a t i o n s . For  example,  c o n s t r u c t i o n o f a freeway d e s i g n e d f o r "80 mph."  speeds  can  i n d u c e I n c r e a s e d consumption o f o i l and g a s o l i n e , a non-renewable  - 126 -  •a  A  resource  i n questionable  f u t u r e supply  i n t h e U.S.  The e s t a b l i s h m e n t  a new freeway a l s o induces commercial growth around i n t e r c h a n g e s c l e a r l y has some adverse community p l a n n i n g inducement impacts were n o t d i s c u s s e d Criterion VII — The  implications.  which  These two  i n the EIS.  Analysis of Alternatives  important t r a d e o f f s between each a l t e r n a t i v e and t h e p r o -  posed freeway were n o t i d e n t i f i e d i n t h e EIS.  An i l l u s t r a t i o n o f t h i s  c r i t i c i s m concerns t h e assessment o f a proposed s o u t h r o u t e way  of  which, would bypass t h e s t a t e game r e s e r v e .  f o r the f r e e -  Rather than d i s c u s s i n g  t h e major t r a d e o f f s , t h a t e x i s t , o n l y a l i s t i n g o f t h e reasons why t h i s r o u t e was o m i t t e d from f u r t h e r c o n s i d e r a t i o n was i n c l u d e d  i n the EIS.  In t h i s : d i s c u s s i o n , i t was. n o t even mentioned t h a t t h e s o u t h r o u t e would have l e s s impact on animals i n t h e r e g i o n than t h e i n t e n d e d  freeway  corridor.  C r i t e r i o n IX —  Communication o f I n f o r m a t i o n  Four b a s i c shortcomings i n t h e EIS f o r I n t e r s t a t e 82 e x i s t s which, h i n d e r document. pacts.  t h e communication o f i n f o r m a t i o n  t o persons r e a d i n g t h e  F i r s t , t h e r e p o r t i n many cases d i d n o t r e a l l y d e f i n e im-  Instead,  t h e EIS abounds w i t h assurances and d e s c r i p t i o n s o f  methods t o reduce impacts which a r e never a c t u a l l y d e f i n e d .  This  criti-  c i s m i s i l l u s t r a t e d i n t h e s e c t i o n o f t h e EIS d e s c r i b i n g water p o l l u t i o n impacts.  Rather t h a n s t a t i n g t h a t t h e r e w i l l be s i l t a t i o n o f streams  caused by c o n s t r u c t i o n o f the p r o j e c t , t h e impact r e p o r t merely " s o i l s disturbed during sion c o n t r o l . "  c o n s t r u c t i o n w i l l be reseeded to p r o v i d e  states ero-  The p a r a g r a p h f o l l o w i n g t h i s statement mentions t h a t  - 127  t h e r e w i l l be  -  some minor s i l t a t i o n of the Yakima R i v e r from  c o n s t r u c t i o n , but  bridge  the r e a d e r i s l a t e r a s s u r e d t h a t " A l l c o n s t r u c t i o n  a c t i v i t i e s i n this: area w i l l meet the requirements of the Department o f Game, Department of F i s h e r i e s , and  the Department o f E c o l o g y . "  After  another assurance t h a t " . . . f u e l s , o i l s o r o t h e r h a r m f u l substances not  r e l e a s e d i n t o the d r a i n a g e and  r i v e r systems," a two  of e x i s t i n g government requirements f o r road and and  a list  of p r e c a u t i o n a r y  s e c t i o n of the  bridge  page  are  excerpt  construction  a c t i o n s c o n c l u d e s t h i s water p o l l u t i o n  report.  A second shortcoming o f the r e p o r t i n r e l a t i o n to communication was  information  b r i e f l y mentioned i n the d i s c u s s i o n o f C r i t e r i o n I I .  T h i s c r i t i c i s m i s t h a t the impact statement f o r I n t e r s t a t e 82 near Prosser 1-1/2  does not  e x p l i c i t l y d e f i n e the r a t i o n a l e f o r the a c t i o n .  page s e c t i o n o f 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 t h a t the proposed highway i s to h e l p Highway A c t o f 1956  which a u t h o r i z e d  of I n t e r s t a t e highway i n the U.S. i n d u s t r i a l areas,  present  and  fulfill  f e d e r a l funding  i n order  to provide  the F e d e r a l  The  EIS  1.  the  conditions  for  then s t a t e d t h a t "...  the  purpose o f t h i s p r o j e c t i s : to implement the c o n s t r u c t i o n of S.R. s u c h a manner as. to  and  l o c a l t r a f f i c , aid  "optimum s a f e o p e r a t i n g  f u t u r e t r a f f i c volumes."  Aid  f o r 40,000 m i l e s  to connect major c i t i e s  s e r v e the needs of commerce and  n a t i o n a l d e f e n c e , and  In a  82  provide:  A t r a n s p o r t a t i o n system t h a t o f f e r s b o t h s a f e t y and e f f i c i e n c y to l o n g d i s t a n c e t r a v e l , w h i l e s u p p l e menting the l o c a l road system to m a i n t a i n 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 .  in  - 128  Despite way  2.  The h i g h e s t o b t a i n a b l e s a f e t y f o r v e h i c u l a r r e s u l t i n g i n reduced a c c i d e n t s and death on s t a t e highway.  3.  G r e a t e r economy i n t r a n s p o r t a t i o n c o s t s f o r p r o d u c t s , a v i t a l element i n U.S. - f o r e i g n t r a d e competition.  4.  C o n s t r u c t i o n r e l a t e d economic b e n e f i t s to the a r e a through employment and b u s i n e s s .  5.  A l l of the l i s t e d o b j e c t i v e s i n a way t h a t minimizes adverse impact upon the n a t u r a l and human e n v i r o n ment of the r e g i o n . "  In a l a t e r p a r t of the EIS  o l d e r two-lane highway i n 1971 a p p r o x i m a t e l y 27%  great  travel, this  local  t h i s d i s c u s s i o n of "purpose" the need or r a t i o n a l e f o r the  i s s t i l l vague.  I t was  -  not  had  high-  i t i s mentioned t h a t  a t o t a l average d a i l y t r a f f i c  to 51% o f what i s expected on the new  the  of  freeway i n  1992.  d e f i n e d whether the e x i s t i n g o r f u t u r e t r a f f i c l o a d s were too  f o r the o l d highway, o r the reasons why  at the l e v e l f o r e c a s t e d  i n 1992.  EIS  c l e a r l y provide  i s t h a t i t does, not  t h i s t r a f f i c i s to  Consequently, a major c r i t i c i s m of the r e a d e r w i t h the reasons  the p r o j e c t is. needed o r found d e s i r a b l e , so t h a t he " b a l a n c e " b e n e f i c i a l and s i o n about the  increase  can  this why  mentally  adverse consequences to r e a c h a r a t i o n a l d e c i -  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 o f u n d e f i n e d terms o r phrases i n the r e p o r t . example, the a n a l y s i s o f a i r p o l l u t i o n was p o s s i b l e "worst case c o n d i t i o n . " case' c o n d i t i o n i s defined speed o f 5 m i l e s per hour."  The  completed by a s c e n a r i o of  r e a d e r i s informed t h a t "The  as a P a s q u i l l s t a b i l i t y No  For  c a t e g o r y F and  f u r t h e r d e f i n i t i o n i s provided.  the d i s c u s s i o n of n o i s e Impacts r e f e r s r e p e a t e d l y  to ^"50  and  ^10  a  'worst a wind  Similarly, noise  -129  -  l e v e l s " which are not defined i n the report.  Other undefined words and  phrases could be c i t e d . Fourth, the environmental.impact statement also includes some questionable assertions about impacts.  In the assessment of freeway  impact on w i l d l i f e i n the Prosser Game Reserve, the report estimates that "A one-third loss (of w i l d l i f e ) w i l l mean that hunter harvests w i l l be reduced by 6,000 ducks, 75 pheasants, and 37 q u a i l annually" (parenthesis with words are added).  One page l a t e r i n the EIS i t i s stated  that "Habitat loss w i l l , however, s t i l l cause a s l i g h t loss to w i l d l i f e in numbers only."  The summary of the impact statement also l i g h t l y  regards t h i s impact by stating that "This project may also reduce the holding capacity of w i 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 s i g n i f i c a n t impact than the uncertainty indicated  by the word "may" or the minor importance described by the phrase "slight loss."  Another questionable assertion i n the EIS concerns the  assessment of the economic consequences of the proposed freeway i n 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 o l d highway in downtown, the EIS balances t h i s loss by mentioning that "Some b u s i nesses i n Prosser may experience gains by removing the through travelers from the downtown area and enhancing the c i t y shopping area."  Defining  impacts through misstatements and subjective viewpoints leads one to believe that the EIS was prepared to j u s t i f y the project, appease the public and merely f u l f i l l a d i s t a s t e f u l but required task.  The prepara-  - 130 -  t i o n o f impact r e p o r t s f o r s m a l l segments o f a proposed i n t e r s t a t e  free-  way f u r t h e r s u p p o r t s t h e o p i n i o n t h a t , a t b e s t , t h i s EIS s e r v e d o n l y t o i d e n t i f y some m i t i g a t i o n measures f o r t h e proposed  project.  CONCLUSIONS  The main o b j e c t i v e o f c r i t i c a l l y r e v i e w i n g f i v e e n v i r o n m e n t a l impact statements i n t h i s c h a p t e r was t o i d e n t i f y t h e i r shortcomings i n o r d e r t o l a t e r d e f i n e whether t h e use o f any impact e v a l u a t i o n s methods would have p r e v e n t e d t h e s e problems. i t was r e a l i z e d  I n r e v i e w i n g t h e impact  statements,  t h a t some o f t h e EIS standards e s t a b l i s h e d i n Chapter Two  c o u l d n o t be a d e q u a t e l y used as c r i t e r i a t o t e s t e n v i r o n m e n t a l r e p o r t s . For  example, c r i t e r i o n V I I I ( R e l a t i o n s h i p To E s t a b l i s h e d G o a l s ) was n o t  very h e l p f u l  i n t h e c r i t i c a l r e v i e w s i n c e t h e a u t h o r o f t h i s t h e s i s had  no knowledge o f any p l a n n i n g s t u d i e s i n t h e a r e a s where t h e proposed p r o j e c t s a r e t o be undertaken.  Thus, an EIS was a s s e s s e d as meeting  this  c r i t e r i o n merely i f i t mentioned a n y t h i n g about c i t i z e n v i e w p o i n t s o r participation  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 o f t h e range o f r e s p o n s i b l e o p i n i o n s f o r every impact t o h e l p t h e r e a d e r a s s i g n importance t o each e f f e c t .  Since the  author i s n o t f a m i l i a r with, l o c a l o p i n i o n s about each p r o j e c t , no a s s e s s ment o f EIS compliance c o u l d be determined f o r t h i s requirement. these l i m i t a t i o n s : , t h e c r i t i c a l review has i d e n t i f i e d f i v e shortcomings apparent i n t h e e n v i r o n m e n t a l impact  Despite  different  reports.  F i r s t , t h e e n v i r o n m e n t a l r e p o r t s have some d i f f i c u l t y i n comprehensively identifying  a l l o f t h e important s o c i o - c u l t u r a l  and e c o l o -  - 131 -  g i c a l impacts o f t h e proposed a c t i o n ( s ) .  A t l e a s t t h r e e o f t h e impact  r e p o r t s reviewed i n t h i s c h a p t e r have o m i t t e d s i g n i f i c a n t consequences  of the proposal.  potential  I f these impacts were found by t h e author  o f t h e EIS as: n o t s i g n i f i c a n t f o r t h e p r o j e c t , a r e a s o n i n g f o r t h i s judgement s h o u l d s t i l l be p r o v i d e d i n t h e r e p o r t . A second shortcoming apparent from t h i s c r i t i c a l review i s t h a t the methods mentioned  i n t h i s t h e s i s t o h e l p t h e r e a d e r o f an EIS a s s i g n  importance t o e n v i r o n m e n t a l impacts were n o t u t i l i z e d reports.  i n a l l of the  A t l e a s t t h r e e EIS's d i d n o t i d e n t i f y r i s k s o r u n c e r t a i n t y ,  r e l e v a n t q u a n t i t a t i v e f i g u r e s , o r m i t i g a t i o n / c o m p e n s a t i o n measures i n t h e assessment  of project  consequences.  T h i r d l y , an adequate  discussion of the prospective curtailment  o f f u t u r e b e n e f i c i a l uses o f t h e human environment was n o t completed i n three of the f i v e environmental r e p o r t s .  Two o f these EIS's were p r e -  pared i n t h e U.S. where i t i s an e x p l i c i t requirement i n NEPA t o d i s c u s s b o t h " t h e r e l a t i o n s h i p between l o c a l s h o r t - t e r m uses o f man's  environment  and t h e maintenance and enhancement o f long-term p r o d u c t i v i t y . . . " and a l s o 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 o f r e s o u r c e s . " A f o u r t h drawback e v i d e n t from t h e review e n v i r o n m e n t a l impact statements i n t h i s c h a p t e r i s t h a t an a n a l y s i s o f a l t e r n a t i v e s was n o t completed  adequately i n three r e p o r t s .  The most s a l i e n t problem was  t h a t t h e a l t e r n a t i v e s were n o t e v a l u a t e d t o i d e n t i f y t h e important t r a d e o f f s i n comparison  t o the proposed p r o j e c t .  I n s t e a d , two impact  merely d e f i n e d t h e reasons, why t h e a l t e r n a t i v e s , were o m i t t e d from consideration.  reports further  One EIS d i d n o t even c o n s i d e r a l t e r n a t i v e s t o t h e 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 i s to f u l f i l l i t s intended purpose.  Yet a l l f i v e EIS's reviewed i n t h i s  chapter had c h a r a c t e r i s t i c s that would hinder the effectiveness of the reports i n impact communication.  This exists as the most important  problem of the impact statement reviewed i n this chapter.  Two adverse  qualities: which were most prominent are verbosity and lack of c l a r i t y . Long detailed discussions: of factors of minor importance erode the comprehension of an interested reader just as a lack of c l a r i t y 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 s o c i a l worth of the proposal. These f i v e basic c r i t i c i s m s e x i s t as problems with environmental impact statements.  The environmental impact evaluation methods descrip-  t i v e l y reviewed i n Chapter Three w i l l be assessed i n Chapter Five to define the degree to which these procedures are able to resolve these f i v e i d e n t i f i e d 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.  C a p a b i l i t y / s u i t a b i l i t y analysis methods mainly  assess the p o t e n t i a l of land for d i f f e r e n t uses rather than evaluate the environmental impacts of a s p e c i f i c action.  As a r e s u l t , the McHarg and  H i l l s approaches w i l l not be used i n t h i s chapter even though the i n f o r mation generated by these methods i s useful i n an impact analysis.  Methods  developed only for i d e n t i f y i n g environmental impacts do not evaluate the consequences of a proposed project and, thus, are relevant to just one of the  f i v e shortcomings of impact statements c r i t i c a l l y reviewed i n Chapter  Four.  Therefore, the remainder of t h i s chapter w i l l discuss mainly two  d i f f e r e n t types of impact evaluation.  One type of evaluation aggregates  impacts into common units while the other type separates impacts into individual quantitative units with q u a l i t a t i v e descriptions.. These two types of evaluation methods w i l l be i l l u s t r a t e d i n this chapter by an application of the B a t t e l l e Columbus environmental evaluation system (EES) and of the U.S. Water Resources Council P r i n c i p l e s and Standards to one major consequence of the proposed Seven Mile Hydropower Development .  133 -  - 134  -  DISCUSSION  COMPREHENSIVE IDENTIFICATION OF SOCIO-CULTURAL AND  ECOLOGICAL IMPACTS  F i v e b a s i c t e c h n i q u e s e x i s t f o r i d e n t i f y i n g environmental impacts. These f i v e t e c h n i q u e s are l i s t e d mental assessment  i n F i g u r e V - l i n r e l a t i o n to n i n e e n v i r o n -  methods d e s c r i b e d i n Chapter Three.  Only the l o g i c a l  d e d u c t i o n procedure of d e f i n i n g r e l e v a n t environmental impacts i s not a checklist.  The l o g i c a l d e d u c t i o n t e c h n i q u e f o l l o w s a s e r i e s o f s t e p s  from g e n e r a l c a u s a l f a c t o r s or c a t e g o r i e s to s p e c i f i c impacts or e n v i r o n mental c o n d i t i o n s . impacts t a i l o r e d  I t i s a c t u a l l y a p r o c e s s which r e s u l t s i n a l i s t  f o r each p r o j e c t .  f o r e n v i r o n m e n t a l impact  F o r example, i n computer m o d e l l i n g  (Krauskopf and Bunde, 1972)  t e n l i n e a r models  were c o n s t r u c t e d which d i s a g g r e g a t e d g e n e r a l economic,  engineering, socio-  c u l t u r a l and e c o l o g i c a l c a t e g o r i e s f o r a highway i n t o l i n k e d s p e c i f i c data v a r i a b l e s .  of  components and  T h i s method does not d e f i n e whether the c o n s t r u c t -  i o n o f each model i s dependent  upon d e t a i l e d  i n f o r m a t i o n about  t h e proposed highway o r c o n d i t i o n s of the environment.  f e a t u r e s of  The degree to which  any method u t i l i z i n g a l o g i c a l d e d u c t i o n t e c h n i q u e 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 p r o j e c t o r t h e s p e c i f i c e n v i r o n mental s e t t i n g would determine i t s u s e f u l n e s s . . I f the method r e q u i r e s such s p e c i f i c i n f o r m a t i o n e a r l y i n the d e d u c t i o n p r o c e s s , much of the t e c h n i q u e w i l l have to be r e p e a t e d i n each impact assessment projects.  A l t h o u g h each a p p l i c a t i o n f o r a type o f a c t i o n  dams, p i p e l i n e s , e t c . ) w i l l r e f i n e the p r o c e s s to improve  for a l l future  (e.g., highways, comprehensive-  ness and a v o i d 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 cj H  S3  W P  X 1 1 PH  H  H <J  ^ S3  Pi  O M H  PH  P  o  w  &  MULTIPLE EFFECTS NETWORKS USGS METHOD  S3  s  W S3  h-l H O P3  § O  PH  O Q  — S3  <3  M H CJ  CJ O  <d  EH CO  O  1—1  O  h-l  S3  CJ  EH  ENVIRONMENTAL IMPACT ASSESSMENT METHODS  O  l-H CJ  h-l  l-H  M  O  S3 M  l-H l-H  H co M  <d cj I-I  H4  EH CJ  PH  l-H M CO  PH PH H  W  X X  ENERGY NETWORK DIAGRAMS  X  OPTIMUM PATHWAY MATRIX APPROACH  X  EARLY METHOD  X  LATER METHOD  X  BATTELLE COLUMBUS  EFFECTS CHAINS  X  COMPUTER MODELLING ENV. IMPACT  X  U.S. WATER RESOURCES COUNCIL  X  U.S. ATOMIC ENERGY COMMISSION  X  FIGURE V " i .  A list  o f n i n e methods f o r e n v i r o n m e n t a l impact  and t h e t e c h n i q u e used f o r impact  assessment  identification.  - 136  -  develop a thorough c h e c k l i s t f o r each type of a c t 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 o f the p r o j e c t and c o u l d be r e p e a t e d l y used t o i d e n t i f y r e l e v a n t environmental impacts. be updated p e r i o d i c a l l y t o h e l p a s s u r e  Also, a checklist  comprehensiveness.  The d i f f e r e n t c h e c k l i s t s can a l s o be d i s t i n g u i s h e d from one i n r e l a t i o n to u s e f u l n e s s .  c h e c k l i s t due to the l o g i c a l d i s p l a y  s u c c e s s i o n o f events b e g i n n i n g w i t h a l a n d  which l e a d s t o c a u s a l a c t i o n s r e s u l t i n g i n p r i m a r y , secondary and o r d e r impacts.  another  Networks (see Appendix D, ,Table.>1) a r e t h e o r e -  t i c a l l y the most comprehensive based upon the r e a l i s t i c  can  Another advantage  format use  multiple  over o t h e r c h e c k l i s t s i s t h a t i t p r o v i d e s  the impact a s s e s s o r w i t h an u n d e r s t a n d i n g of the i n t e r c o n n e c t i o n s between the o b j e c t i v e s o f a p r o j e c t and i t s d i v e r s e e c o l o g i c a l and consequences. the development impacts.  T h i s f e a t u r e i s e s p e c i a l l y u s e f u l because  socio-cultural  i t can h e l p i n  of measures which reduce the i n t e n s i t y o f e n v i r o n m e n t a l  The major drawback of networks  i s t h a t i t i s much more d i f f i c u l t  and time consuming t o develop o r i g i n a l l y than o t h e r more simple c h e c k l i s t s . In o r d e r to d e f i n e f u r t h e r the u s e f u l n e s s o f these impact  identi-  f i c a t i o n t e c h n i q u e s , each k i n d of c h e c k l i s t w i l l be a p p l i e d b r i e f l y , when r e l e v a n t , to one of the p r o j e c t s f o r which impact statements were reviewed i n the p r e v i o u s c h a p t e r . i n f o r m a t i o n about i d e n t i f i e d may  S i n c e the author of t h i s study l a c k s  detailed  each p r o j e c t and environmental s e t t i n g , many impacts  not be a p p l i c a b l e to the p a r t i c u l a r p r o j e c t .  However, the  main purpose of such a t e s t should s t i l l be s e r v e d by t r y i n g to determine the p r a c t i c a l u s e f u l n e s s and degree of comprehensive  impact  identification  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  F i g u r e V-2 shows a reduced a c t i o n / c o n d i t i o n m a t r i x w i t h t e n t i a l important  some po-  impacts o f t h e Notthwest A l l o y s Magnesium P l a n t  identi-  i  fied.  The reduced m a t r i x was developed d i r e c t l y from t h e l a r g e r USGS  matrix  shown i n Appendix E, F i g u r e 1 a f t e r a c u r s o r y a p p l i c a t i o n t o the  p r o j e c t based upon i n f o r m a t i o n i n t h e EIS. from t h e use o f t h i s m a t r i x .  Two b a s i c c o n c l u s i o n s  F i r s t , the m a t r i x  result  i s c o n f u s i n g and v e r y  cumbersome to u s e . T h i s i s n o t o n l y due to i t s g r e a t s i z e b u t a l s o because the a c t i o n / s i n g l e e f f e c t format of t h e m a t r i x d i f f i c u l t y i n determining  s e q u e n t i a l impacts and c a u s e s .  c h a i n o f impacts from s t r i p mining might b e g i n c a v a t i o n a l t e r i n g drainage  i s u n r e a l i s t i c and l e a d s t o F o r example, a  i n i t i a l l y w i t h s u r f a c e ex-  p a t t e r n s l e a d i n g t o s o i l e r o s i o n which c a n  i n t r o d u c e i n c r e a s e d t u r b i d i t y and o r g a n i c s  i n a stream r e s u l t i n g i n a l g a l  blooms, p o s s i b l e impacts on f i s h , v i s u a l a e s t h e t i c s , e t c . a c t i o n / c o n d i t i o n matrix  does not f o l l o w any r e a l i s t i c  t h i s c h a i n o f impacts on t h e USGS m a t r i x ,  The simple  sequence.  To d e f i n e  t h e two a c t i o n s " s u r f a c e excava-  t i o n " and " a l t e r a t i o n o f d r a i n a g e " must be s e p a r a t e l y i d e n t i f i e d on the matrix.  I t i s o n l y through p r i o r knowledge o f t h e a s s e s s o r  that  secondary  and m u l t i p l e o r d e r impacts r e s u l t i n g from changed e n v i r o n m e n t a l c o n d i t i o n s w i l l be i d e n t i f i e d . A second c o n c l u s i o n c o n c e r n i n g  t h e use,of t h i s m a t r i x  I s t h a t im-  p a c t s a r e i d e n t i f i e d a t a g e n e r a l l e v e l t h a t , i n some c a s e s , cannot be measured t o i n d i c a t e e x t e n s i v e n e s s .  F o r example, water q u a l i t y impacts  a r e o n l y determined through p r e d i c t i o n s o f v a r i o u s parameters such as mean d i s s o l v e d oxygen l e v e l s , mean phosphorous c o n c e n t r a t i o n s , e t c . quently, tified  to d e f i n e magnitude c l e a r l y i t i s n e c e s s a r y  Conse-  t h a t impacts be i d e n -  a t a s p e c i f i c l e v e l t h a t can be r e a d i l y measured.  T h i s , of course,  - 138 -  w CO  > a CO CJ  o  < >  o cu CO o z z CU o o CO H H H  o  Z  H Q  2 CM  O  a  cj zH  1-H  KH  CO H  a Q  faZ  O o Z  O PQ  AN  rt fa EH o H m rt < M  O  Cd fa EH  H a CO a  z  EH  aH  D .J S  faCJ  o a H EH z  zH  CO  rtCHO  >j ed  CJ a H  CO D Q  o EH O rt a C EH z D rtrt fa O z X o fa EH H  zH  EH  IL  H  M  z  Z  rtCO H rtCJ CO hH > Z w rt o rt H U  X  W  a  o uH  Z EH Q z MEH < X i j CM o < CJ fa•H « rt H H CJ N cd rt rt Z w Cd H U EH D z H rtH EH H u Q < iJ rtH » CO u tJ H 2 2 co EH < 2 fa M w rtD co • J U fart n u Q 9 a M 2 rt rt z EH H P EH EH O D ca H farted 2 z 2 < D H PQ CO 5 s 2 2 EH faCO CO H EH  rt  ENVIRONMENTAL CONDITIONS MINERAL RESOURCES SOILS LANDFORM UNIQUE PHYSICAL FEATURES UNDERGROUND WATER WATER QUALITY WATER RECHARGE AIR QUALITY GRASS CROPS BIRDS LAND ANIMALS AGRICULTURE MINING AND QUARRYING HUNTING CAMPING, HIKING PICNICKING SCENIC VIEWS AND VISTAS OPEN SPACE QUALITIES CULTURAL PATTERNS EMPLOYMENT TRANSPORTATION NETWORK UTILITY NETWORKS  FIGURE' V-2.  X X X X Xx X X X Xx 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 xx 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  A reduced cause/effect matrix with, some p o t e n t i a l impacts of a proposed magnesium plant and mining operations.  - 139 -  cannot be u s e f u l l y accomplished i n 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 environmental conditions i n one display.  Simple Impact L i s t s  Simple environmental impact l i s t s are i l l u s t r a t e d i n 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 r e l a t i v e l y short and address impacts at a general  l e v e l (e.g., b i o l o g i c a l 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 s p e c i f i c .  I t i s apparent that a compre-  hensive checklist at a s p e c i f i c l e v e l i s more useful i n e x p l i c i t l y i d e n t i fying impacts and, i n most cases, these s p e c i f i c impacts also can be c l e a r l y measured to indicate extensiveness. The disadvantages of simple impact l i s t s are e a s i l y seen i n that i t does not help the assessor connect causes with impacts nor does i t resolve the problem i n the USGS matrix of defining multiple-order impacts. i n development  The advantages of simple impact l i s t s are the ease  for s p e c i f i c types of projects, and they can also be r e a d i l y  u t i l i z e d and e a s i l y understood.  Hierarchical L i s t s  If the B a t t e l l e h i e r a r c h i c a l checklist for water resources planning (Figure I I - l )  had been applied to the proposed Seven Mile Project, i t  would have resolved some of the impact i d e n t i f i c a t i o n problems with the studies reviewed i n Chapter Four.  For example, many s o c i o - c u l t u r a l impacts  - 140 -  such as s o c i a l i n t e r a c t i o n , are  i s o l a t i o n / s o l i t u d e and oneness w i t h n a t u r e  i n c l u d e d and d e f i n e d i n the B a t t e l l e system.  the o m i s s i o n o f some " i n t a n g i b l e " M i l e socio-economic tween parameters  study.  T h i s would have prevented  impacts, a b a s i c c r i t i c i s m o f the Seven  C o n v e r s e l y , t h e l a c k o f i n t e r c o n n e c t i o n be-  on t h e 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  a s s e s s o r t o d e f i n e t e r t i a r y consequences  f o r the  which r e s u l t from l o w e r - o r d e r  impacts.  Multiple Effects  Networks  Sorensen and Pepper (1973) developed a m u l t i p l e e f f e c t s network (see Appendix G, F i g u r e 1) f o r proposed highways and o t h e r developments in a checklist  format to be used by a r e g i o n a l p l a n n i n g agency i n r e v i e w i n g  environmental impact the consequences  statements.  I f t h i s network was used t o determine  o f I n t e r s t a t e 82 i n e a s t e r n Washington, many o f t h e impacts  omitted from d i s c u s s i o n i n t h e EIS such as induced sprawl near i n t e r c h a n g e s , l o s s of p o t e n t i a l  a r c h a e o l o g i c a l s i t e s and t h e many impacts r e s u l t i n g  the development o f borrow p i t s would have been i d e n t i f i e d .  from  On the o t h e r  hand, t h e i n f l u x o f workers i n a s m a l l community c a u s i n g adverse housing and  servicing  requirements and t h e l o c a l economic down-turn a f t e r c o n s t r u c -  i o n was n o t i d e n t i f i e d as p o t e n t i a l  impacts on t h e network c h e c k l i s t .  The  p r o b a b l e r e a s o n why these impacts were n o t i n c l u d e d i n the network i s because i t was developed f o r t h e m o s t l y u r b a n i z e d San F r a n c i s c o Bay a r e a , which would seem t o p r e c l u d e t h e o c c u r r e n c e o f such  impacts.  IMPORTANCE ASSIGNMENT  A second shortcoming o f t h e impact  statements reviewed  i n the  - 141 -  p r e v i o u s c h a p t e r i s t h a t adequate  i n f o r m a t i o n was not p r o v i d e d t o f a c i l i -  t a t e t h e r e a d e r i n a s s i g n i n g importance t o each impact.  The two b a s i c  p h i l o s o p h i e s o f environmental impact e v a l u a t i o n a l r e a d y d e f i n e d i n t h i s t h e s i s a s s i g n importance t o impacts i n a d i f f e r e n t manner.  The methods  which aggregate impacts i n t o common u n i t s u t i l i z e q u a n t i t a t i v e f i g u r e s t o d e f i n e t h e s i g n i f i c a n c e o f impacts, w h i l e t h e e v a l u a t i o n methods which s e p a r a t e impacts i n t o i n d i v i d u a l q u a n t i t a t i v e u n i t s and q u a l i f y i n g use d e s c r i p t i v e words and incommensurable f i g u r e s .  terms  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 d e v e l o p i n g c r i t e r i a t o e v a l u a t e an EIS, t h e author has been i m p l i c i t l y b i a s e d a g a i n s t the aggregate methods o f d e v e l o p i n g common u n i t s f o r economic, t u r a l and e c o l o g i c a l e f f e c t s .  socio-cul-  D e s p i t e t h i s i m p l i c i t b i a s i n the t h e s i s ,  sound r e a s o n i n g e x i s t s t h a t changing d i v e r s e impacts i n t o common u n i t s a r e t h e r e s u l t o f hidden s u b j e c t i v e judgements,  and a l s o tends t o d i s g u i s e  the i m p l i c a t i o n s o f many e n v i r o n m e n t a l consequences 1973).  (Sorensen and Moss,  T h i s r e a s o n i n g i s most important i n l i g h t o f t h e t h e o r e t i c a l  pur-  pose o f impact r e p o r t s , which i s t o communicate i n f o r m a t i o n to t h e r e a d e r about t h e t o t a l consequences a rational decision. two  o f a p r o j e c t so t h a t t h e i n d i v i d u a l can r e a c h  I n o r d e r t o i l l u s t r a t e t h e d i f f e r e n c e s between t h e  types o f e v a l u a t i o n methods, the B a t t e l l e Columbus E n v i r o n m e n t a l E v a l u -  a t i o n System (EES)  (Dee e t . a l . , 1972) and t h e U.S. Water Resources  P r i n c i p l e s and Standards  Council  (1973) have been p a r t i a l l y a p p l i e d t o the proposed  Seven M i l e Hydropower p r o j e c t .  S i n c e a major consequence  noted i n t h e  Seven M i l e EIS by E n v i r o c o n i s s i g h t s e e i n g and game v i e w i n g l o s s e s , o n l y the e s t h e t i c a s p e c t o f each a n a l y s i s has been completed.  Lack o f d a t a  r e s t r i c t e d a c o m p l e t e . a p p l i c a t i o n o f t h e s e two d i f f e r e n t impact  evaluation  - 142 -  p r o c e d u r e s and, i n some c a s e s , these two methods.  I t should  e s t i m a t e s were n e c e s s a r y i n order  t o apply  a l s o be mentioned t h a t t h e B a t t e l l e EES  was a p p l i e d to t h e p r o j e c t o n l y 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 r e q u i r e d by the method.  Results  T a b l e s V - l and V-2 i l l u s t r a t e t h e p o s s i b l e e s t h e t i c impact a t i o n o f t h e Seven M i l e Hydropower p r o j e c t a c c o r d i n g  t o these two methods.  Two b a s i c r e s u l t s i n r e l a t i o n t o importance assignment can be c i t e d t h e s e examples.  evalu-  from  F i r s t , n e i t h e r method c o m p l e t e l y r e s o l v e s t h e problems  i n importance assignment t h a t were i n d i c a t e d from t h e EIS reviews completed i n Chapter F o u r . provide  The U.S. Water Resources C o u n c i l procedure f u n c t i o n s t o  information  so t h a t the r e a d e r can judge the importance o f an  impact but i t does not r e q u i r e t h a t r i s k or u n c e r t a i n t y , m i t i g a t i o n measures or time span o f impacts be i n c l u d e d considerations  A l t h o u g h these  a r e not r e q u i r e d , t h e method has t h e p o t e n t i a l t o accom-  odate t h e s e f a c t o r s . listed  i n the evaluation.  I t i s apparent by the q u a n t i t a t i v e v a l u e s  and t o t a l s  i n T a b l e V—2, the t h e B a t t e l l e EES method judges t h e importance o f  impacts f o r t h e r e a d e r through d e c i s i o n s made by an i n t e r d i s c i p l i n a r y team. U n l e s s p u b l i c i n t e r e s t s can be somehow i n t e g r a t e d i n t o t h e many judgements required  t o complete t h e B a t t e l l e p r o c e d u r e , r e l y i n g upon t h i s sheet as the  b a s i s f o r an impact r e p o r t i s c o n t r a r y  t o the c i t i z e n p a r t i c i p a t i o n f u n c t i o n  i n d e c i s i o n - m a k i n g which was a primary f o r c e behind NEPA arid t h e EIS r e q u i r e ment.  I t i s d o u b t f u l whether p u b l i c p a r t i c i p a t i o n c o u l d be a d e q u a t e l y used  to develop the v a l u e  f u n c t i o n s 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 n o t a s u i t a b l e s u b s t i t u t e f o r p u b l i c pation.  Since  partici-  t h e 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 Create Lake With 870 Surface Acres. 20 Miles Of Shoreline, With Good Quality Water (due to s e t t l i n g of suspended solids) And Fair Access  Enhance Remaining Winter Range To Mitigate Deer Population Losses  TABLE V - l .  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 A t t r a c t i o n Because Flooding 20% Of Ungulate Winter Range In Valley W i l l Result In Reduced Populations Of Between 125-400 Deer  An example of a possible esthetics component of the Environmental Quality Account for a hydropower development as guided by the U.S. Water Resources Council P r i n c i p l e s and Standards (1973) .  - 144 -  Esthetics  Land With Project (C)  Geologic surface material Relief and topographic character Width and alignment  (16) (10) (32)  Subtotal  Value in EIU Without Project  6  1.2  16.2  Red Flags  -.6  -1 .6 -7-^0- -1.0  Q.fi  I  Net Change  minor  11.2  I  1 -372  19.4  minor I"  Air (3) (2)  (5)  Odor and visual Sounds .'  Subtotal  9.4  3.0  I  I  n  1 .?  O.L  -.fi  3.61  -.6  T  Water (10) (16) (6) (10) (10)  3.0 14.4  Appearance of water Land and water interface Odor and floating materials Water surface area Wooded and geologic shoreline  (52)  Subtotal  7.0 16.0  An  fin  I  major  n  +4.o fi.O-1.0  5 0 7.0  1  35.4 I  0  -4.0 -1.6  38.01 - 2 . 6 L  Biota (5) (5) (9) (5)  Animals — domestic Animals — wild Diversity of vegetation types Variety within vegetation types  (24)  Subtotal  •  3.5  3.5  VS R 1  4.S 7.9 1 .5  1.5  0 -1 .0 +.q 0  I 16.6 [  16.71 -0.1~T  I  8.0 1  10.01 - 2 . 0 |  |  I  « n I  m.nl - ? . n  1  fi0  10.5  Man-made Objects (10)  Man-made objects  (10)  Subtotal  I  Composition (15) (15) (30) <153)  Composite effect Unique composition  n  Subtotal  9  q.n  n  -4.5 -fv.n  major  ma i n r  1Q.S - 1 0 . 5  Esthetics Total  I  88.2  I  107.21-19.0  1  ~ l  TABLE "yV2. Results of a p r a c t i c a l a p p l i c a t i o n 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 i n t e r d i s c i p l i n a r y or personal judgements,  these procedures likewise descriminate  against public p a r t i c i p a t i o n i n decision-making.  On the other hand, me-  thods such as the U.S. Water Resources Council P r i n c i p l e s and Standards provide information i n 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 i n d i v i d u a l decisions and a public part i c i p a t i o n process. In r e l a t i o n to helping the reader assign importance to impacts, this p r a c t i c a l 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 i n the display system.  The guidelines for using this method c i t e examples of  b e n e f i c i a l and adverse effects on environmental quality which are not p a r a l l e l i n description.  In Table V - l , a b e n e f i c i a l impact i s described  by the verb "create" while a p a r a l l e l adverse effect i s assessed by the verb "inundate".  Although t h i s i s a very minor example of b i a s , more  objective counterparts would be "gain of" and "loss of" which would more f a i r l y define impacts to the reader. words  Rather than a description through  and phrases, the B a t t e l l e 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 assumptions and questioning conslusions.  As a r e s u l t , i t would be much easier  for an agency or i n t e r d i s c i p l i n a r y team preparing an environmental assessment 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 d e s c r i b e d  in  Chapter Three s t r e s s an e v a l u a t i o n framework and do not p r o v i d e guidance i n the a c t u a l preparation f o r e , the p r e p a r a t i o n  o f the statement o f e n v i r o n m e n t a l impact.  of an EIS u s i n g  l i n e s developed by t h e U.S.  There-  t h e s e methods must f o l l o w the g u i d e -  C o u n c i l on E n v i r o n m e n t a l Q u a l i t y  (1973b) (Ap-  pendix B, and pp. 28-31) which a r e based on the f i v e r e q u i s i t e s i n c l u d e d i n NEPA (Appendix A and pp. 28). discussions  The CEQ  g u i d e l i n e s d e f i n e two  separate  i n an EIS t h a t should' i n d i c a t e the t r a d e o f f s between  term g a i n s a t the expense of long-term l o s s e s or v i c e v e r s a " and t h a t the "range of p o t e n t i a l uses of the environment" be  "shortalso  identified.  These two c o n s i d e r a t i o n s , which a r e v a g u e l y s t a t e d as requirements and  (V) of s e c t i o n 102(2) (c) i n NEPA, formed  (IV)  the b a s i s f o r c r i t e r i o n VI  in this thesis.  A l t h o u g h these two EIS requirements e x i s t i n the  two of the t h r e e  impact r e p o r t s which d i d not meet t h i s c r i t e r i o n were  prepared to comply w i t h NEPA.  The p o s s i b l e r e a s o n why  statements a r e d e f i c i e n t i n t h i s r e s p e c t ments a r e vague and u n c l e a r ,  and the U.S.  g u i d e l i n e s do not e x p l i c i t l y d e f i n e them.  i s because  t h e s e U.S.  impact  the two NEPA r e q u i r e -  C o u n c i l on E n v i r o n m e n t a l Q u a l i t y O r t o l a n o (1973) has a l s o men-  t i o n e d t h a t these two NEPA requirements are "so obscure t h a t must be p r o v i d e d  U.S.,  b e f o r e they can be expected to y i e l d  clarification  the k i n d of i n f o r m a -  t i o n t h a t w i l l be u s e f u l i n d e c i s i o n - m a k i n g " . Of the methods d e s c r i b e d Energy Commission p r e p a r a t i o n  i n Chapter Three, o n l y the U.S.  g u i d e l i n e s have made a s t r o n g  d i r e c t impact statements to meet t h i s c r i t e r i o n . C o u n c i l P r i n c i p l e s and Standards  The U.S.  Atomic  effort  to  Water Resources  (1973) and the l a t e r B a t t e l l e method  (1973)  - 147 -  have also b r i e f l y directed environmental reports toward meeting t h i s c r i t e r i o n , but not i n adequate d e t a i l or i n 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 e f f e c t s  (defined i n t h i s method as 10-20 years) i n common units as ten times more important than short—term impacts.  ALTERNATIVE ANALYSIS The most s i g n i f i c a n t problem with the analysis of alternatives i n the f i v e impact statements reviewed i s that the important tradeoffs between each choice and the proposed project were not defined.  As menrr.  tioned i n the discussion of the previous shortcoming, t h i s consideration i n an impact report should also r e s u l t from preparation guidelines which were not included as part of most impact evaluation procedures reviewed i n this thesis.  The U.S. Council on Environmental Quality Guidelines  (1973b)  requires t h i s consideration i n an EIS by stating that the analysis of alternatives "...be s u f f i c i e n t l y detailed to permit comparative evaluation of the environmental benefits, ciosts and r i s k s of the proposed action and each reasonable a l t e r n a t i v e . . . " . Evaluation methods which aggregate impacts into common units provide a basis for e x p l i c i t l y defining tradeoffs between a l t e r n a t i v e s . As exemplified by the B a t t e l l e procedure i n Table V-2, the quantitative d i f ferences between the "no action" a l t e r n a t i v e and the proposed project i s :  shown i n t o t a l s for the entire analysis, t o t a l s for each h i e r a r c h i c a l  - 148 -  category  (e.g., e s t h e t i c s i s one o f f o u r B a t t e l l e c a t e g o r i e s ) ,  i c a l f i g u r e s f o r each o f 78 parameters. compared i n the same manner.  and numer-  Other a l t e r n a t i v e s can a l s o be  The remaining s i x common u n i t methods a l s o  e x p l i c i t l y s t a t e that a b a s i c purpose o f t h e assessment i s t o s e l e c t t h e b e s t p o s s i b l e a l t e r n a t i v e , and each o f these methods a s s e s s e s s p e c i f i c impacts i n q u a n t i t a t i v e measures t o e x p l i c i t l y d e f i n e Evaluation  tradeoffs.  methods which s e p a r a t e impacts i n t o i n d i v i d u a l  t a t i v e and d e s c r i p t i v e terms a r e n o t as e x p l i c i t  quanti-  i n i n d i c a t i n g t h e most  d e s i r a b l e o f s e v e r a l a l t e r n a t i v e s due to the use o f incommensurable meas u r e s which cannot be t o t a l e d f o r comparison.  D e s p i t e t h i s minor  differ-  ence i n comparison t o common u n i t methods, t r a d e o f f s 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 d e f i n e d  type o f impact e v a l u a t i o n .  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 Appendix F, T a b l e 2 i l l u s t r a t e s t h e U.S. Atomic  Energy Commission framework f o r comparing a l t e r n a t i v e s .  COMMUNICATION OF INFORMATION  As  previously  pointed  shortcomings, g u i d e l i n e s  out i n t h e d i s c u s s i o n  for preparing  o f two e a r l i e r EIS  t h e e n v i r o n m e n t a l impact  statement  i t s e l f a l s o can be most h e l p f u l i n d i r e c t i n g an EIS t o communicate i n f o r m a t i o n i n a manner t h a t can  i s comprehensible to the common layman.  s t r e s s t h e t h e o r e t i c a l purpose o f an imp-act r e p o r t which p r o v i d e s a  b a s i s f o r r e q u i r i n g an EIS to o b j e c t i v e l y d e f i n e By d e f i n i n g  t h e proper p l a c e  blem o f impact r e p o r t s be  Guidelines  circumvented.  the project  rationale.  i n the p l a n n i n g p r o c e s s f o r t h e EIS,  a t t e m p t i n g to j u s t i f y a d e c i s i o n a l r e a d y  Guidelines  the pro-.,  made can  can a l s o recommend a f l e x i b l e format t o those  p r o p o s i n g an EIS t h a t can h e l p produce c l e a r , c o n c i s e  reports.  The USGS  M a t r i x P r o c e d u r e , t h e l a t e r B a t t e l l e Method, the U.S. Water Resources  Coun-eil  - 149 -  P r i n c i p l e s and Standards, and the U.S. Atomic Energy Commission Preparart i o n Guide are the only methods which provide any d i r e c t i o n i n EIS preparation.  The U.S. Water Resources Council P r i n c i p l e s and Standards empha-  size the public decision-making function of an impact report and, i n gene r a l , 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 a l t e r n a t i v e s . The U.S. Atomic Energy Commission preparation procedures do not i d e n t i f y 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 d i r e c t the development mental impact statements.  of voluminous environ-  However, a most redeeming factor included i n  these guidelines i s a tabulation procedure (Appendix F, Tables 2 and 3) which, i n e f f e c t , i s a concise and comprehensive impacts.  summary of environmental  Both the USGS procedure and the B a t t e l l e method provide l i t t l e  or no guidance i n 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 i n the decision-making process.  The remaining environmental impact evaluation pro-  cedures must r e l y upon the U.S. Council on Environmental Quality guidelines (pp. 27-31) for the preparation of an EIS.  Other than the f i v e basic EIS  requirements i n NEPA, and a description of the project and environmental setting, these guidelines do not provide a framework or format for an impact evaluation document. The philosophical basis u t i l i z e d by the two d i f f e r e n t types of impact evaluation methods also influences how well the information generated i s communicated to persons interested i n the proposed action.  As  mentioned e a r l i e r , 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 c h a r a c t e r i s t i c s of the common unit type of evaluation methods can i n c o r r e c t l y communicate information and can also f a i l to i d e n t i f y the consequences of a project to persons interested i n the proposal. For example, i n the B a t t e l l e method i l l u s t r a t e d i n Table V-2, the "appearance of water" parameter was assessed i n environmental impact units (EIU) without the action as +7.0 and with the action as +3.0 r e s u l t i n g 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. i s judged by this evaluation for the reader.  Thus, an equal tradeoff To many persons, the exisr  tence of a lake may not f u l l y compensate for the loss of a free-flowing section of r i v e r .  On the contrary, methods which quantitatively evaluate  impacts i n separate units and include a q u a l i t a t i v e description w i l l  list  this impact as "inundate nine miles of one of the l a s t free-flowing white water r i v e r s i n . . . " and "create lake with 870 surface acres, 20 miles of  shoreline...".  Consequently, this type of evaluation method  illus-  trated by the U.S. Water Resources Council approach i n Table V - l provides information so that the reader can judge the value of the tradeoffs.  - 151 -  CONCLUSIONS  T h i s g e n e r a l d i s c u s s i o n supplemented  by some s p e c i f i c  l e a d s t o t h r e e main c o n c l u s i o n s about methods developed impact assessment  f o r environmental  i n r e l a t i o n t o the main problems w i t h impact r e p o r t s  reviewed i n the p r e c e d i n g chapter o f t h i s t h e s i s . identify fully  examples  First,  i n order to  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  procedure t o be used by an agency should i n c l u d e a comprehensive of  p o t e n t i a l consequences  evaluation checklist  a t a s p e c i f i c l e v e l t h a t , when p e r t i n e n t , can  be measured i n u n i t s m e a n i n g f u l t o t h e l a y r e a d e r .  Since  innumerable  e n v i r o n m e n t a l e f f e c t s c a n > r e s u l t from d i f f e r e n t developments, a c h e c k l i s t t o be comprehensive  i n order f o r  i t must be prepared f o r s p e c i f i c k i n d s o f  p r o j e c t s . . The most comprehensive  form o f c h e c k l i s t  i s a network which  l i n k s t h e sequence o f events from a l a n d use t o c a u s a l a c t i o n s and p r i m a r y , secondary and m u l t i p l e o r d e r e f f e c t s . At impact.  p r e s e n t , t h e r e i s no i d e a l method f o r e v a l u a t i n g  Perhaps  environmental  an i d e a l method f o r a l l k i n d s o f a c t i o n s and c i r c u m s t a n c e s  w i l l never be developed, b u t onetype o f e v a l u a t i o n method which has been c o n t i n u a l l y proposed  can be d i s t i n g u i s h e d as u n d e s i r a b l e f o r use as t h e  b a s i s f o r anclenvironmental impact  statement.  A second c o n c l u s i o n o f t h i s  chapter i s t h a t , due t o the i n f o r m a t i o n g e n e r a t i o n f u n c t i o n o f an EIS t o facilitate  a government agency and p u b l i c review o f t h e p r o j e c t f o r d e c i -  sion-making, methods which mold economic, s o c i o - c u l t u r a l iand impacts i n t o common u n i t s a r e u n d e s i r a b l e because  ecological  t h e v a l u e judgements o f  few persons a r e used t o a s s i g n t h e importance o f each environmental for  t h e p u b l i c , government a g e n c i e s and d e c i s i o n - m a k e r s .  impact  As d i s c u s s e d  e a r l i e r , t h i s type of e v a l u a t i o n c a n a l s o communicate i n f o r m a t i o n t h a t i s  - 152 -  misleading for many persons. A t h i r d conclusion of t h i s chapter i s that most of these impact evaluation procedures do not provide guidance i n the preparation of the environmental report.  Guidelines can d i r e c t the preparation of an EIS  so that information about the f u l l consequences of the proposed action can be communicated i n a manner comprehensible to the common layman, defined as the most s i g n i f i c a n t problem with the f i v e impact statements c r i t i c a l l y reviewed i n Chapter Four.  Guidelines can also include require-  ments which d i r e c t an adequate treatment of "short-term vs. long-term e f f e c t s " and an adequate "analysis of a l t e r n a t i v e s " i n an EIS.  As a r e -  s u l t , 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 i n the preparation of the environmental report.  chapter six general guidelines for preparing environmental impact statements BACKGROUND  The case s t u d i e s o f impact statements and d i s c u s s i o n o f d i f f e r e n t e n v i r o n m e n t a l assessment methods p r o v i d e s a f o u n d a t i o n f o r r e commending g e n e r a l g u i d e l i n e s f o r p r e p a r i n g environmental impact statements.*  These g u i d e l i n e s c l o s e l y f o l l o w t h e c r i t e r i a  established,  i n Chapter Two and a r e d i r e c t e d by t h e purpose t h e e n v i r o n m e n t a l impact statement i s i n t e n d e d t o s e r v e .  The g u i d e l i n e s p r e s c r i b e an impact  e v a l u a t i o n method t h a t s e p a r a t e s impacts i n t o i n d i v i d u a l measures and q u a l i f y i n g  quantitative  terms.  PURPOSE AND SCOPE OF THE IMPACT STATEMENT The u l t i m a t e o b j e c t i v e o f an e n v i r o n m e n t a l impact statement i s to  f a c i l i t a t e s o c i a l l y r e s p o n s i b l e d e c i s i o n s about a proposed  project.  To a c h i e v e t h i s o b j e c t i v e , an EIS s e r v e s as an i n f o r m a t i o n t o o l t o be used by t h e p u b l i c and by d e c i s i o n - m a k e r s so t h a t each person can r e a c h an i n d i v i d u a l , r a t i o n a l d e c i s i q n about t h e p r o p o s a l .  A process o f p u b l i c  p a r t i c i p a t i o n is; a l s o n e c e s s a r y t o s o l i c i t o p i n i o n s about t h e p r o p o s a l i n  *Many o f t h e s e recommendations were submitted by t h e author i n August o f 1974 t o B.C. Hydro and Power'Authority i n a r e p o r t e n t i t l e d , " E n v i r o n mental Impact R e p o r t s : The Proposed R o l e , Scope and Content Requirements at B.C. Hydro and Power A u t h o r i t y " .  - 153 -  - 154  -  order to help the decision-maker(s) judge the s o c i a l worth of the project. Since an EIS i s a c t u a l l y 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 t o t a l 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, s o c i o - c u l t u r a l and ecological categories.  INTEGRATING IMPACT STATEMENTS IN THE PLANNING PROCESS An environmental impact statement should be integrated i n a planning/decision-making  process which u t i l i z e s the information  purpose of the document to i t s f u l l e s t advantage.  generation  In t h i s respect, not  only can the EIS f a c i l i t a t e a public and government agency review of s p e c i f i c projects but i t can also help define long-term objectives, p o l i c i e s and programs which best r e f l e c t the values that exist i n society. Figure VI-1 generally i l l u s t r a t e s the integration of environmental reports in an o v e r a l l 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 P o l i c i e s and Information  Report  This very general plan should describe the future objectives of the public e n t i t y , forecast a l t e r n a t i v e 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 d i f f e r e n t future demands.  A general economic, s o c i a l and ecological  impact assessment of these alternative demands and p o t e n t i a l programs should then be completed i n order to define the recommended courses of  - 155 -  A DRAFT STATEMENT OP PROPOSED JOBJECTIVES POLICIES AND PROGRAMS DRAFT ENVIRONMENTAL • IMPACT REPORT pOVERNMENT AGENCY] AND PUBLIC REVIEW I ~ PINAL STATEMENT OF PROPOSED bBJECTIVES POLICIES AND PROGRAMS  zzznzzz:  PROJECT 1  ENGINEERING STUDIES) OF ALTERNATIVES  PROJECT 2  (ENGINEERING STUDIEi OP ALTERNATIVES  FEASIBILITY STUPIES|  (FEASIBILITY STUDIEi  (ECONOMIC, SOCIAL  (ECONOMIC, SOCIAL  AND ECOLOGICAL)  AND ECOLOGICAL)  FINAL ENVIRONMENTAL IMPACT REPORT  (ENGINEERING STUDIES OF ALTERNATIVES  PRELIMINARY DESIGN  DRAFT ENVIRONMENTAL IMPACT REPORT  GOVERNMENT AGENCY AND PUBLIC REVIEW  FINAL DESIGN AND (FINAL ENVIRONMENTAL IMPACT REPORT  FIGURE VI-1. LICENSES, APPROVALS| AND CONSTRUCTION AUTHORIZATION  Integrating policy and project impact statements into the planning/decision-making process.  - 156  action of the agency.  -  This p o l i c y impact assessment should be prepared  as, an information report which, " o b j e c t i v e l y " 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, p o l i c i e s and programs and provided with, adequate time to comment before the general plan and are revised.  be  EIS  Public information meetings should also be held i n an  e f f o r t to s o l i c i t viewpoints from interested c i t i z e n s .  III.  F i n a l Statement of P o l i c i e s and F i n a l P o l i c y EIS Based upon the review of public and government agency responses,  a f i n a l statement of objectives, p o l i c i e s and future programs should completed.  be  A f i n a l p o l i c y EIS on this long-term plan w i l l l i k e l y be a  r e v i s i o n of the previous impact statement and should include a discussion of both, the public meetings and the written comments received from government agencies and the public.  The long-term plan developed through t h i s  procedure should also be revised p e r i o d i c a l l y i n the future to r e f l e c t s o c i a l values and conditions which are constantly changing.  IV.  S p e c i f i c Projects —  Engineering  Studies  In many cases, the r e s u l t of the f i n a l statement of long-range p o l i c i e s i s a sequence of projects which s t r i v e toward meeting the approved objectives developed from an e a r l i e r public and government review process.  The following f i v e steps should be repeated for each  - 157  -  i n t e n d e d p r o j e c t which comprise the long-term  program.  First,  ing  s t u d i e s of p o t e n t i a l s i t e l o c a t i o n s and d e s i g n s s h o u l d be  for  each proposed p r o j e c t .  V.  Development of I n i t i a l Environmental B e f o r e the i n i t i a l  engineercompleted  Impact Statement  EIS i s w r i t t e n , a study o f 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. initially  I t i s not n e c e s s a r y  t h a t these t h r e e f a c t o r s be  evaluated  i n g r e a t d e t a i l because i t might be found more e f f i c i e n t  e l i m i n a t e some a l t e r n a t i v e s merely on obvious l o g i c a l considerations.  economic, s o c i a l and  to eco-  T h i s s h o u l d 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 p r e l i m i n a r y d e s i g n s b e f o r e the d r a f t i s completed.  VI.  P u b l i c and Government Review^ In o r d e r f o r a p u b l i c p r o j e c t to r e f l e c t a "weighing"  v a l e n t s o c i e t a l v a l u e s , t h r e e c o n d i t i o n s must be met.  F i r s t , the p u b l i c  and p e r t i n e n t government agencies must be g i v e n access to the EIS.  of pre-  initial  T h i s means, t h a t they must have knowledge t h a t such an i n f o r m a t i o n  r e p o r t e x i s t s and where the document can be e i t h e r o b t a i n e d or r e a d . Second, anyone i n t e r e s t e d i n the p r o p o s a l must be g i v e n an o p p o r t u n i t y to  respond  to both the r e p o r t and the p r o s p e c t i v e a c t i o n .  pect , adequate time s h o u l d be p r o v i d e d between the i n i t i a l the document and any In the U.S.,  r e l e a s e of  a u t h o r i z a t i o n o r a p p r o v a l s c o n c e r n i n g the p r o p o s a l .  a t l e a s t 90 days must pass between the i n i t i a l  a d r a f t impact  In t h i s r e s -  statement  and any  r e l e a s e of  a u t h o r i z a t i o n o r a p p r o v a l of the p r o -  - 158 -  posal.  I n many cases., p u b l i c i n f o r m a t i o n meetings s h o u l d be h e l d t o  a c q u a i n t t h e p u b l i c w i t h t h e p r o j e c t and t o p r o v i d e an o p p o r t u n i t y t o i n t e r e s t e d persons necessary  t o comment on t h e p r o j e c t .  to f u l f i l l  The t h i r d c o n d i t i o n  t h e p r e s c r i b e d o b j e c t i v e o f t h e EIS i s t o f u l l y  " c o n s i d e r " a l l p u b l i c and government agency comments c o n c e r n i n g t h e proposal.  T h i s c o n d i t i o n s h o u l d be s a t i s f i e d through  eight i n t h i s hypothetical planning  VII.  s t e p s seven and  process.  F i n a l EIS and Design The  process.  f i n a l d e s i g n s h o u l d be a produce o f t h e e n t i r e p l a n n i n g  A l l " r e s p o n s i b l e " comments r e c e i v e d from i n t e r e s t e d  i n t e r e s t groups: and p u b l i c agencies  persons,  should be d i s c u s s e d i n t h e f i n a l E I S .  An a c t i o n which would i n d i c a t e t h a t p u b l i c comments were " c o n s i d e r e d " i n p l a n n i n g t h e p r o p o s a l would be to i n c l u d e a l l w r i t t e n comments i n t h e appendix o f t h e f i n a l impact  VIII.  D e c i s i o n Concerning  statement.  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) a l l o f t h e i n f o r m a t i o n generated expressed by a l l persons  by t h e impact  statement  and o t h e r government agencies  t o "weight"  and the o p i n i o n s  i n reaching a  judgement about t h e p r o p o s a l .  EVALUATING ENVIRONMENTAL  E v a l u a t i n g t h e environmental  impact  IMPACTS  o f a proposed p r o j e c t s h o u l d  be undertaken i n a manner which b e s t meets t h e i n t e n d e d purpose o f the document i t s e l f .  F o r t h i s r e a s o n , the e v a l u a t i o n should s e p a r a t e e n v i r o n -  - 159  -  mental impacts i n t o i n d i v i d u a l q u a n t i t a t i v e f i g u r e s and  qualitative  terms, so t h a t the i n f o r m a t i o n i s a v a i l a b l e f o r p r e p a r a t i o n of the EIS i n a form w h i c h w i l l h e l p the reader d e c i d e the importance o f each impact. Any tial  impact e v a l u a t i o n c o n s i s t s o f f i r s t  i d e n t i f y i n g the poten-  "  impacts o f a p r o p o s a l and i t s . a l t e r n a t i v e s , and then c o l l e c t i n g  i n f o r m a t i o n 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 E I S .  The  I d e n t i f i c a t i o n o f impacts, and c o l l e c t i o n o f i n f o r m a t i o n s h o u l d be e c t e d toward the consequences  dir-  o f the proposed ..project, i t s a s s o c i a t e d  a c t i v i t i e s and a l t e r n a t i v e s t o the p r o j e c t as l a t e r d e f i n e d i n the format recommendations o f these g u i d e l i n e s .  IMPACT IDENTIFICATION Other than the g e n e r a l c o n s i d e r a t i o n s , mentioned measures s e c t i o n o f these g u i d e l i n e s  i n the magnitude  (pg.162), no l i s t i n g o f e n v i r o n -  mental impacts w i l l be p r o v i d e d i n . t h e s e s u g g e s t i o n s f o r EIS The overwhelming  preparation.  number o f environmental impacts t h a t can r e s u l t  the many d i f f e r e n t types, o f a c t i o n s i n v a r y i n g p l a c e s p r o h i b i t s development it  o f any one u s e f u l c h e c k l i s t f o r a l l p r o j e c t s .  from the  As a r e s u l t ,  i s recommended t h a t a l l e n t i t i e s which n o r m a l l y p r e p a r e impact  state-  ments develop c h e c k l i s t s o f the p o t e n t i a l e n v i r o n m e n t a l impacts o f t h e i r actions at a s p e c i f i c l e v e l  (eg, d i s s o l v e d oxygen, water  t u r b i d i t y , e t c . r a t h e r than j u s t water measurable  i n terms: o f magnitude.  temperatures,  q u a l i t y ) t h a t , when p o s s i b l e , a r e  In o r d e r to b e t t e r r e l a t e cause and  e f f e c t , i t might be b e s t t o develop a c h e c k l i s t f o r each d i f f e r e n t commonly undertaken by an agency.  action  F o r example, Highways Department s h o u l d  - 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 p o t e n t i a l consequences for d i f f e r e n t types of actions are considered before the preparation of an EIS. The most comprehensive type of checklist i s a network which l i n k s causal actions to primary, secondary and multiple-order  impacts.  The information for a network can also be stored on computer for easy updating and r e t r i e v a l .  The only major disadvantage of networks i s that  they are time consuming and d i f f i c u l t o r i g i n a l l y to prepare c o r r e c t l y . It would also be h e l p f u l to include on a c h e c k l i s t , where pertinent, possible units of measure for each p o t e n t i a l impact i n order to help the assessor define magnitude.  Another a i d for EIS preparation would be  to include hints or guidance to possible mitigation measures for each impact on the c h e c k l i s t .  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 i s prepared.  P r i o r to i d e n t i f y i n g  the relevant impacts, of the project and i t s a l t e r n a t i v e s , an inventory of a l l s o c i o - c u l t u r a l and ecological conditions i n the p o t e n t i a l l y "affected" area that are relevant to the proposed project must be completed.  This inventory should be s u f f i c i e n t enough to estimate the  future environmental conditions i f the proposed project was not implemented.  Based upon t h i s inventory, other information must be c o l l e c t e d  for l a t e r i n c l u s i o n i n the EIS so that the reader i s objectively helped  - 161 -  i n making a judgement about t h e proposed p r o j e c t . following s i x d i f f e r e n t considerations  I.  I n f o r m a t i o n about t h e  f o r each impact must be o b t a i n e d :  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 u n a v o i d a b l e adverse impacts;  4)  Range o f " r e s p o n s i b l e " o p i n i o n s  5)  I n c i d e n c e on groups and a r e a s ;  6)  Time span o f impact.  i n society;  Measures o f 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 o f a p r o -  p o s a l can be measured i n some way t o show t h e e x t e n s i v e n e s s o f an impact. Economic e f f i c i e n c y i s t h e o n l y c a t e g o r y o f impacts which can be f a i r l y assessed i n common u n i t s .  When p u b l i c funds a r e t o be a l l o c a t e d toward  a p r o j e c t and t h e important b e n e f i t s o f t h e p r o j e c t a r e economic, a b e n e f i t / c o s t a n a l y s i s i s a u s e f u l method o f d e f i n i n g t h e e f f i c i e n c y o f the investment.  Through, the use o f common monetary f i g u r e s , a r a t i o i s  developed through b e n e f i t / c o s t a n a l y s i s which i n d i c a t e s t h e economic f e a s i b i l i t y o f the proposal.  I f the r a t i o i s greater  economic b e n e f i t s exceed t h e economic c o s t s .  than u n i t y , t h e  A c r i t e r i o n f o r acceptance  of d i f f e r e n t types o f p r o j e c t s can a l s o be developed such as a 1.2/1.0 b e n e f i t to cost r a t i o .  At present, standardized  developed i n Canada ( S e w e l l , Resources C o u n c i l , 1973).  g u i d e l i n e s have been  e t . a l . , 1965) and i n t h e U.S. (U.S.  Water  These g u i d e l i n e s p r o v i d e d i r e c t i o n c o n c e r n i n g  a c c e p t a b l e t e c h n i q u e s t o measure monetary b e n e f i t s and c o s t s , t h e v i e w -  - 162 -  point or accounting stance of the analysis, procedures of considering r i s k of impact i n the analysis, and how to determine the economic l i f e of the project and the s o c i a l discount  rate.  Social and c u l t u r a l impacts can be quantified i n some manner to define magnitude, but these numerical figures are not readily comparable with one another since they may be i n d o l l a r terms, days, acres, people, etc.  Nevertheless, such quantitative information w i l l i d e n t i f y  the extensiveness of the impact which i s of important use i n EIS preparation.  The following i s a non-comprehensive l i s t of conditions and  possible quantitative measures which can help indicate the s o c i a l and c u l t u r a l consequences i n areas affected by a proposed action.  CONDITIONS  MEASURES OF MAGNITUDE  Population  number of people  Employment  number of jobs, income generated  Housing  number of single-family and multiple family homes, monetary value of homes  Recreation  Areas  number of acres, acreage, annual userdays , economic value  Transportation  number of highways and roads, t o t a l length, economic value  Physical  number of commercial services by types, h o s p i t a l s , schools, e t c .  Services  Institutions  number of organizations, agencies, laws, regulations, established customs, e t c .  Ethnic Groups  number of groups,  Archaeological Remains  number of s i t e s , acreage  H i s t o r i c a l Areas  number of areas, acreage, structures  populations  - 163 -  S c i e n t i f i c Interest Areas  number o f a r e a s , acreage  Noise  number o f people and homes  affected,  decibel predictions Odors  number o f people and homes  Visual Aesthetics  number o f people a f f e c t e d , m i l e s o f view  affected  disturbed  I t i s apparent t h a t t h e measures l i s t e d above a r e not s u f f i c i e n t to a d e q u a t e l y v a l u e 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 f e r e n t measures may be a p p l i c a b l e t o a c e r t a i n impact.  dif-  F o r example,  merely b y m e n t i o n i n g t h e number o f p e o p l e a f f e c t e d and t h e m i l e s o f view d i s t u r b e d b y proposed t r a n s m i s s i o n l i n e s does n o t a d e q u a t e l y a s s e s s i t s impact.  The impact can be f u r t h e r q u a n t i f i e d by i d e n t i f y i n g t h e number  of p o l e s and l i n e s , t h e v a l u e o f t h e p r o p e r t y impacted, t h e number o f road and stream c r o s s i n g and t h e number o f r i d g e s o r summits c r o s s e d . 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 .  Y e t , i n many cases i t i s important  d u r i n g t h e i n f o r m a t i o n c o l l e c t i o n stage o f e v a l u a t i o n t o d e f i n e e c o l o g i c a l impacts i n q u a n t i t a t i v e u n i t s t o i n d i c a t e magnitude o r s c a l e . the f o l l o w i n g i s a l i s t  F o r example,  o f e c o l o g i c a l c o n d i t i o n s and some measures o f  magnitude w h i c h c o u l d be used i n an E I S . CONDITIONS  MEASURES OF MAGNITUDE  Land  amount o f e a r t h d i s p l a c e d  form  Minerals  number o f t y p e s , amount o f each  type  Soils:  number o f t y p e s , amount o f each  type  - 164 -  Water  amount of dissolved oxygen, depth of v i s i o n , f e c a l coliforms, nitrogen, phosphates s o l i d s , temperature, PH measures, e t c .  Air  amount of CO, NO , SO , hydrocarbons, p a r t i c u l a t e s , etc. x  II.  Climate  mean temperatures, amount of r a i n f a l l , fog-free days, e t c .  Drainage Patterns  number and size of streams displaced, amount of s o i l eroded, e t c .  Sediment Deposition  amount of sediment deposited annually  Flood Cycles  time periods  Plants:  number and species  Animals  number and species  Microorganisms  Relative abundance and species  Risk or Uncertainty of Impacts An i n i t i a l consideration which should be defined i n the inform-  ation c o l l e c t i o n stage of impact evaluation i s the i d e n t i f i c a t i o n of r i s k or p r o b a b i l i t y of impact occurrence.  An impact such as ambient sulfur  oxides l e v e l being surpassed due to the potential a i r pollutant emissions of a thermal power plant during certain meteorological conditions may be a very important impact unless the p r o b a b i l i t y 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 r i s k figure but possible to give some range i n p r o b a b i l i t y such as 25-50% or otherwise. In many other cases, there may be considerable uncertainty about an impact and no r i s k 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 prob a b i l i t y figure should be revealed.  - 165  III.  -  P o t e n t i a l M i t i g a t i o n Measures o r Unavoidable Adverse An i d e n t i f i c a t i o n o f impacts  Effects  t h a t can be m i t i g a t e d o r  impacts  t h a t have an u n a v o i d a b l e i n t e n s i t y i s another c o n s i d e r a t i o n which s h o u l d he i d e n t i f i e d d u r i n g the i n f o r m a t i o n c o l l e c t i o n stage o f e v a l u a t i o n . This: w i l l communicate to the r e a d e r whether and by hownmuch the of a p r o s p e c t i v e impact  can be reduced.  D e c i s i o n s c o n c e r n i n g the amount  of money a l l o c a t e d t o reduce an environmental be r e v e a l e d to p u b l i c s c r u t i n y . proposed  intensity  impact w i l l  consequently  F o r example, i f i t i s d e c i d e d f o r a  f o s s i l - f u e l e l e c t r i c a l power g e n e r a t i o n p l a n t t h a t wet  scrubbers  as. a p o l l u t i o n c o n t r o l d e v i c e were not worth the amount of money i t would c o s t i n comparison  to the a i r p o l l u t i o n i t would m i t i g a t e , t h i s  ment f o r the EIS would r e v e a l t h i s d e c i s i o n f o r p u b l i c review. i d e n t i f i c a t i o n o f u n a v o i d a b l e impacts  requireThe  ( e i t h e r t e c h n i c a l l y o r because i t  i s e c o n o m i c a l l y u n f e a s i b l e t o m i t i g a t e w i l l h e l p the r e a d e r a s s i g n imp o r t a n c e to the v a r i o u s environmental  impacts.  An example o f a t e c h n i c -  a l l y u n a v o i d a b l e adverse e f f e c t would be the b l o c k i n g o f n o r m a l l y amounts o f downstream s i l t  IV.  dam.  Range o f R e s p o n s i b l e O p i n i o n s i n S o c i e t y The problem  One  d e p o s i t i o n by a  large  o f d e v e l o p i n g an unbiased EIS i s d i f f i c u l t  to s o l v e .  a d d i t i o n t o an EIS which can h e l p the r e a d e r e v a l u a t e e f f e c t s  and  a l s o improve the o b j e c t i v i t y o f the r e p o r t i s t o s p e c i f y f o r e n v i r o n m e n t a l impacts a range o f r e s p o n s i b l e o p i n i o n s t h a t e x i s t i n s o c i e t y c o n c e r n i n g the importance  o f the e f f e c t ( s ) .  D u r i n g the i n f o r m a t i o n c o l l e c t i o n  of the environmental e v a l u a t i o n , when t h e r e i s doubt about tions, o f an impact  the  stage  implica-  then the d i f f e r e n t r e s p o n s i b l e o p i n i o n s i n s o c i e t y  - 166  -  should be i d e n t i f i e d f o r l a t e r i n c o r p o r a t i o n i n t o the EIS.  F o r example,  d i f f e r i n g s c i e n t i f i c o p i n i o n s e x i s t c o n c e r n i n g the consequences o f humans exposed to i n c r e a s e d amounts o f l o w - l e v e l r a d i a t i o n f o r l o n g p e r i o d s of time.  Both s c i e n t i f i c o p i n i o n s s h o u l d be i n c l u d e d i n an  d i s c u s s i n g 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  EIS  genera-  tion plant.  V.  I n c i d e n c e of Impacts A most important  assessment concerns quences.. impact  The  c o n s i d e r a t i o n t h a t must be d e f i n e d d u r i n g  the d i s t r i b u t i o n o f b e n e f i c i a l and  adverse  i n c i d e n c e of a l l economic, s o c i o - c u l t u r a l and  is different  f o r persons,  conse-  ecological  groups, and areas which p r o v i d e s a  h a s i c r e a s o n i n g f o r v a r y i n g o p i n i o n s about a proposed p r o j e c t . the d i s t r i b u t i o n o f impacts to s p e c i f i c persons  impact  cannot be r e a l i s t i c a l l y  identified  Although in relation  and p l a c e s i n an EIS, the i n c i d e n c e of e f f e c t s can  be  i d e n t i f i e d a t a more g e n e r a l l e v e l r e f l e c t e d by e t h n i c groups, d i f f e r e n t interests  (e.g. c o n s e r v a t i o n i s t s , e n t r e p r e n e u r s , r e c r e a t i o n i s t s ,  p a y e r s , i n d u s t r i a l i s t s , e t c . ) and areas regional d i s t r i c t s , etc.).  (e.g. neighbourhoods, towns,  F o r example, r e c r e a t i o n i s t s a r e a d v e r s e l y  a f f e c t e d to a g r e a t e r e x t e n t than i n d u s t r i a l i s t s due a p o p u l a r canoe r i v e r from a dam. an impact  to the f l o o d i n g o f  T h i s more s p e c i f i c d i s t r i b u t i o n of  s h o u l d be i d e n t i f i e d j u s t as any adverse  consequences  e f f e c t s r e s u l t i n g from the c o n s t r u c t i o n and e x i s t e n c e o f a dam) o f t e n occur r e g i o n a l l y and to the broader  tax-  (e.g. which  l o c a l l y s h o u l d be r e v e a l e d i n j u x t a p o s i t i o n  b e n e f i t s which u s u a l l y accrue to major u r b a n i z e d  o r to the p r o v i n c e as a whole.  Through an i d e n t i f i c a t i o n of the  regions inci-  - 167 -  dence o f impacts, s p a t i a l l y and on groups o f p e o p l e , important t i o n w i l l he o b t a i n e d  informa-  f o r l a t e r i n t e g r a t i o n i n the EIS.  Time Span o f Impacts A major focus o f l o n g range p l a n n i n g myopic t e n d e n c i e s all  o f man.  i s to avoid the o f t e n  By d e f i n i n g i n an e v a l u a t i o n t h e time span o f  impacts, i n f o r m a t i o n w i l l he a v a i l a h l e f o r t h e EIS t o i n d i c a t e t h e  l o n g - t e r m consequences and t h e d i v e r s i t y o f f u t u r e uses o f t h e e n v i r o n ment w h i c h might be c u r t a i l e d by t h e proposed p r o j e c t . t i o n should  considera-  a l s o 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 o f r e s o u r c e s resources).  (renewable and non-renewable  An example o f inducement consequences i s t h e d i s p e r s e d  urban growth prompted i n l a t e r y e a r s near an u r b a n i z e d assessed  This  region.  i n past planning  from t h e c o n s t r u c t i o n o f a freeway  T h i s adverse impact o f urban sprawl was n o t o f freeways and highways, b u t i n o r d e r t o  f a c i l i t a t e more r a t i o n a l d e c i s i o n s i n the f u t u r e such inducement consequences should be d e f i n e d i n t h e e n v i r o n m e n t a l e v a l u a t i o n and i n c l u d e d i n the E I S .  PREPARATION OF THE ENVIRONMENTAL  IMPACT STATEMENT  GENERAL CONSIDERATIONS The to p r o v i d e  purpose o f p r e p a r i n g  information  the e n v i r o n m e n t a l impact statement i s  t o t h e reader  i n order  t o f a c i l i t a t e an i n d i v i -  d u a l , r a t i o n a l d e c i s i o n about the s o c i a l worth o f t h e proposed p r o j e c t . T h i s r e q u i r e s t h a t t h e EIS be l o g i c a l l y o r g a n i z e d , s u c c i n c t and n o n - t e c h n i c a l .  " o b j e c t i v e l y prepared,"  An example o f a l o g i c a l format c o n s i s t i n g  - 168  -  of g e n e r a l requirements which should be i n c l u d e d i n a l l impact s t a t e ments i s i n c l u d e d i n the f o l l o w i n g s e c t i o n . A p e r f e c t l y " o b j e c t i v e " EIS b.ut i s , n o n e t h e l e s s ,  necessary  i s probably  impossible  to  attain  to s t r i v e toward i f an impact statement  is. to f u n c t i o n as an i n f o r m a t i o n document so t h a t more s o c i a l l y s i b l e d e c i s i o n s can be made. s h o u l d he a v o i d e d ,  and  In p r e p a r i n g  ably."  adverse e f f e c t s  For example, reduced anadromous  populations; should not be d e f i n e d as "Due of a f i s h hatchery,  the EIS, q u a l i f y i n g phrases  a l l d e s c r i p t i o n s o f b e n e f i c i a l and  should be p a r a l l e l i n meaning.  Thus;, compensation a c t i o n s should not be used to c l o u d  d e s c r i p t i o n of e n v i r o n m e n t a l impacts.  considerthe  Also, p a r a l l e l descriptive  phrases should be used such as " g a i n o f " and  consequences to the  fish  to the planned c o n s t r u c t i o n  salmon p o p u l a t i o n l o s s e s should be reduced  " c o s t " , "reduced" and  respon-  " l o s s o f " , " b e n e f i t " and  " i n c r e a s e d " , e t c . , to more f a i r l y  describe  reader.  A s u c c i n c t and n o n - t e c h n i c a l EIS w i l l be a c h i e v e d i s t h o u g h t f u l l y prepared  f o r the common layman.  i f the r e p o r t  Most e n v i r o n m e n t a l  impacts do not r e q u i r e a t e c h n i c a l e x p l a n a t i o n even though i t may  be  necessary  More  d u r i n g the e v a l u a t i o n to undertake s c i e n t i f i c s t u d i e s .  t e c h n i c a l a u x i l i a r y i n f o r m a t i o n can be i n c l u d e d i n the appendix of r e p o r t i n i n s t a n c e s where the d e t a i l e d assumptions and should be a v a i l a b l e f o r r e f e r e n c e to r e a d e r s . t h a t unimportant d e t a i l s , and  a n a l y t i c a l methods  A s u c c i n c t EIS  s i d e - i s s u e s be avoided  the  requires  i n discussion.  o r d e r to f a c i l i t a t e a s u c c i n c t communication of i n f o r m a t i o n to  In  the  r e a d e r , a summary o f both the p r o j e c t ' s e n v i r o n m e n t a l impacts and  the  - 169 -  a n a l y s i s o f a l t e r n a t i v e s should  be i n c l u d e d  method o f summarizing t h e EIS i s i n c l u d e d  i n t h e E I S . A proposed  i n the format recommendations  o f this, framework. These g e n e r a l communicate i n f o r m a t i o n  considerations  which a r e n e c e s s a r y f o r EIS t o  t o the reader cannot be s p e c i f i c a l l y  directed  i n g u i d e l i n e s so t h a t t h e r e s u l t a n t impact statements comply w i t h t h e s e considerations.  I t should  a l s o be mentioned t h a t an impact  must n o t be so simply w r i t t e n t o t h e extent Consequently, c o n s i d e r a b l e  t h a t meanings a r e l o s t .  d i s c r e t i o n remains w i t h t h e persons  the impact statement i n r e f e r e n c e of  statement  to t h e degree o f c o n c i s e n e s s  preparing and l a c k  detail.  FORMAT OF THE EIS I.  Summary  Sheets  In o r d e r  t o make a complete e f f o r t  i n communicating  information  to a l l i n t e r e s t e d p e r s o n s , T a b l e s VI-1 and VI-2 have been developed as summary sheets t o be i n c l u d e d i n t h e b e g i n n i n g o f an E I S .  Some p o s s i b l e  impacts and p a r t o f an a l t e r n a t i v e a n a l y s i s f o r a h y p o t h e t i c a l h y d r o power development i l l u s t r a t e t h e use o f these summary s h e e t s . s h e e t s a r e s e l f - e x p l a n a t o r y s i n c e they c l e a r l y  The summary  i n c l u d e the s i g n i f i c a n t  c o n s i d e r a t i o n s which f a c i l i t a t e a person i n a s s i g n i n g  importance t o an  e n v i r o n m e n t a l impact.  II.  D e s c r i p t i o n o f t h e Proposed A c t i o n The  but  should  d e s c r i p t i o n o f t h e proposed p r o j e c t should  b r i e f l y include the f o l l o w i n g f i v e  points:  n o t be  extensive,  QUANTIFICATION IMPACTS  BENEFICIAL  QUALIFICATION  ADVERSE  . PROBABILITY*  TIME SPAN OF IMPACT  MITIGATION POTENTIAL  IMPACT DISTRIBUTION  ECONOMIC 1) Electricity sales 2) Payroll Input to local economies 3) Construction and operation costs k) Recreation loss  From $ to $ From to  Certain  kC years  Provincial  Certain Highly probable Highly probable  6 years 6 years and 40 years  Local towns None  Provincial  Long-term  Fair  Regional  5) etc. . . 6) etc. . . SCCIO/CULTURAL 1) Business Recession after construction  Presently nonquantifiable  !  Certain  5-15 years-  Fair  Local towns  2) Relocation of families 3) Housing shortage  16 homes I Peak shortage of I 500-700 homes j  Certain  Short- term  None  Individuals  Certain  6 years  Excellent  Local towns  1) Elimination of free-flowing section of river 2) Loss of deer  7 miles 2 5 r l l O deer  Certain Certain  Long-term Long-term  Rone Fair  Regional/Provincial fit Interest groups Regionsl/Provinc ia1 & interest groups  3) Loss of fish  100-700 trout  Certain  Long-term  Fair  U) etc. . . 5) etc. . .  6) etc. . . ECOLOGICAL  Regional/Provincial & interest groups  It) etc. . . 5) etc. . .  6) etc. . .  TABLE  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  VI-1.  A summary sheet including some economic, soeio/cultural and ecological impacts, which could result from a proposed hydropower development.  ALTERNATIVES TO THE PROPOSED ACTION  SIGNIFICANT TRADEOFFS WHEN COMPARED TO PROPOSED PROJECT Beneficial  No Project  Economic  1) Project.costs of $ can be utilized elsewhe-e in the B.C. onomy. 2) etc. .  .  Adverse  jl) Foregone benefits of $  •  in electricity sales. 2) Multiplier onomic impacts |provinc'ialIy of .to $ |and regionally of $ to $ ;  3) Costs associated with the accellerated planning and development of substitute  Iproject  |  Socio/Cultural 3eneficial Adverse  1) Lack of community impact associated with the construction of the project. 2) Lack of readjustment impact associated with project after construction.  I  Ecological Beneficial Adverse  1) Economic stim- Il) No flooding of ulation of the 3U0 acres o f local economy due (ungulate winter, to project con[range. struction would not occur.  3) No displacement of 25 families.  I h-  1  B.  I—  1  I  k) etc. . . Lower Dam Height  1) Project costs of $ can lie utilized elsewhere in the B.C. economy. 2) etc. . .  1) Foregone benef i t s of $ in electricity sales.  1) Lesser degree L) Less economic of community stimulation o f impact assocthe l o c a l economy iated with the lue to project construction of onstruction the project. Would not occur.  Il) ICO acres less ngulate .wintering) rea inundated.  t  2) Multiplier economic impacts provincially or 2) Lesser degree $ to $ of readjustment and regionally of impacts assoc$_ to $ . iated with projectl after construction) 3) Costs associated with the 3) No displacement) laccellerated of 8 families. planning and |development of substitute project B. U) etc.  TABLE VI-2. A proposed method of summarizing an analysis of alternatives and three hypothetical alternative examples.  SIGNIFICANT TRADEOFFS WHEN. COMPARED TO * PROPOSED PROJECT  ALTERNATIVES TO THE PROPOSED ACTION Economic Beneficial Dam location 3 miles upstream from present proposed site  None  Adverse  l ) Foregone benef i t s of $ in electricity sales resulting in a lower benefit /cost ratio.  Socio/Cultural Adverse Beneficial  Ecological Beneficial Adverse. 1) Preservation of additional 3 miles salmon spawning beds resulting in an average annual figure of 200 additional commercial-size fish. 2) etc. . .  1) Flooding of additional 20 acres (360 total) of ungulate winter range.  - 173  III.  -  1)  A d i s c u s s i o n of the h i s t o r i c a l background to the p r o p o s a l l e a d i n g to the r a t i o n a l e and o b j e c t i v e s o f the p r o j e c t ;  2)  A g e n e r a l d e s c r i p t i o n of the t e c h n i c a l a s p e c t s and s p e c i a l requirements of the a c t i o n (e.g. an e x p l a n a t i o n of how a thermal power p l a n t o p e r a t e s , f o u n d a t i o n requirements, e t c . ) ;  3)  The p r e c i s e l o c a t i o n of the p r o j e c t , p r e f e r a b l y map;  4)  An i d e n t i f i c a t i o n o f p a s t p u b l i c p a r t i c i p a t i o n which has. o c c u r r e d and f u t u r e i n p u t which w i l l be s o l i c i t e d ;  5)  A d i s c u s s i o n o f the r e l a t i o n s h i p of the p r o j e c t w i t h e x i s t i n g i n s t i t u t i o n s ( i . e . laws, r e g u l a t i o n s p o l i c i e s , important customs and p u b l i c o r g a n i z a t i o n s , e t c . ) .  Description  o f the Environmental  on  a  Setting  A d e s c r i p t i o n of the e n v i r o n m e n t a l s e t t i n g i s a n e c e s s a r y o f t e n l e n g t h y p a r t o f an impact r e p o r t . s e c t i o n depends upon the though i n a l l cases the  The  thoroughness t h a t inventory  mental conditions, which may  be  extensiveness of t h i s  i s i n t e n d e d f o r the EIS, a l -  should describe  a f f e c t e d by  c o n c e r n i n g the amount of r e s o u r c e s to be  and  the e x i s t i n g  the a c t i o n .  A  environ-  decision  a l l o c a t e d toward p r e p a r i n g  "thorough" EIS  s h o u l d be based on t h r e e c o n s i d e r a t i o n s .  considerations  are  the magnitude of the p o t e n t i a l p r o j e c t  a  These t h r e e effects,  the  amount o f r e s o u r c e s devoted to the p r o j e c t , and whether the a c t i o n i s o f a c o n t r o v e r s i a l n a t u r e or  not.  R e g a r d l e s s of the comprehensiveness d e c i d e d f o r the EIS, d e s c r i p t i o n of e n v i r o n m e n t a l s e t t i n g i n the r e p o r t natural  features  (e.g.  can be d i v i d e d  the into  topography, geology, s o i l s , water, a i r , f l o r a ,  fauna, n a t u r a l processess, etc.)  and  human-oriented f e a t u r e s  (e.g.  - 174 -  population, mercial  employment, h o u s i n g , t r a n s p o r t a t i o n , r e c r e a t i o n a r e a s , com-  s e r v i c e s , i n d u s t r i a l areas, e t c . ) .  Special reference  s h o u l d be  made i n t h i s s e c t i o n t o unique and v i t a l n a t u r a l and human-oriented environmental c o n d i t i o n s .  Both a q u a n t i t a t i v e 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  s h o u l d be completed t o be used as a  benchmark t o compare t h e p r e d i c t e d the proposed p r o j e c t .  f u t u r e s e t t i n g b o t h w i t h and without  Furthermore, a map w i t h an a c c u r a t e d e l i n e a t i o n  of t h e b o u n d a r i e s o f t h e study a r e a s h o u l d be i n c l u d e d  IV.  i n this section.  The E n v i r o n m e n t a l Impact o f t h e P r o p o s a l 1)  Economic e f f i c i e n c y .  The economic e f f i c i e n c y o f t h e p r o -  posed p r o j e c t i s one important f a c t o r i n d e c i d i n g whether an i n t e n d e d p r o j e c t m e r i t s p u b l i c investment. a benefit/cost  analysis according  As mentioned e a r l i e r , i n many c a s e s , to standardized  method f o r d e f i n i n g economic e f f i c i e n c y .  procedures i s t h e b e s t  In o t h e r i n s t a n c e s ,  d e s c r i p t i o n o f t h e economic r a t i o n a l e f o r t h e p r o p o s a l Whenever an economic a n a l y s i s i s i n c l u d e d s h o u l d be r e v e a l e d 2)  i n t h e EIS,  an o b j e c t i v e  s h o u l d be completed. a l l assumptions  to the reader.  S o c i o - c u l t u r a l impacts.  impacts s h o u l d be d e s c r i b e d  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  according  to the following f i v e  p r e d i c t i o n o f each impact  considerations:  A)  Quantitative priate) ;  (when appro-  B)  Risk or uncertainty  o f impact;  C)  Time span o f impact  (when  D)  An i d e n t i f i c a t i o n o f m i t i g a t i o n measures o r whether the i n t e n s i t y o f t h e impact i s u n a v o i d a b l e ;  appropriate);  - 175 -  E)  A s p e c i f i c a t i o n o f t h e range o f r e s p o n s i b l e i n s o c i e t y concerning  A reasoning  an impact  opinions  (only when a p p r o p r i a t e ) .  should be i n c l u d e d i n t h e EIS f o r a l l p o s s i b l e i m -  p a c t s which a r e found i n t h e e v a l u a t i o n to be n o t a p p l i c a b l e t o the proposed p r o j e c t .  F o r many impacts i t w i l l a l s o be n e c e s s a r y to q u a l i -  t a t i v e l y d e s c r i b e 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 i n c l u d e a l l n a t u r a l  p h y s i c a l and n a t u r a l 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 e v a l u a t i o n c o n s i d e r a t i o n s l i s t e d above s h o u l d be used t o h e l p d e s c r i b e e c o l o g i c a l impacts f o r t h e r e a d e r . tion considerations  I n many c a s e s , t h e s e  a r e n o t adequate t o d e f i n e f o r t h e reader  evalua-  t h e im-  plications of effects. For example, merely by mentioning t h e amount o f CO, NO  o r SO  r e l e a s e d i n t o t h e atmosphere f o r d i f f e r e n t time p e r i o d s does n o t a d e q u a t e l y assess  t h e 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  tion plant.  genera-  T h i s impact s h o u l d be f u r t h e r q u a l i f i e d w i t h a d i s c u s s i o n  of t h e r e l a t i o n s h i p o f t h e p r o s p e c t i v e  emissions with  q u a l i t y s t a n d a r d s i n B.C. and elsewhere. note the multiple-order  existing a i r  The d i s c u s s i o n should  also  consequences o f these p o l l u t a n t s on t h e v i s u a l  c h a r a c t e r o f t h e r e g i o n , t h e p l a n t and animal l i f e nearby, on human h e a l t h , and o t h e r r e l e v a n t c o n d i t i o n s which c o u l d be a f f e c t e d by t h e s e emissions. 4)  D i s t r i b u t i o n o f impacts.  A separate  s e c t i o n o f an EIS should  be devoted t o d e s c r i b i n g t h e d i s t r i b u t i o n o f p r o j e c t impacts. d i s t r i b u t i o n should  be d e f i n e d both s p a t i a l l y  n a t i o n a l vs.. r e g i o n a l and l o c a l i n c i d e n c e )  Impact  ( i . e . p r o v i n c i a l and  and a l s o t o e t h n i c and s p e c i a l  - 176 -  interest  groups. 5)  The r e l a t i o n s h i p between s h o r t - t e r m  and l o n g - t e r m  effects.  In this, s e c t i o n o f t h e EIS, a comparison should be made between t h e 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 l o n g - t e r m  consequences o f t h e p r o p o s a l .  T h i s s e c t i o n should  also b r i e f l y  discuss  the d i v e r s i t y o f f u t u r e uses o f t h e environment which may be reduced due to t h e p r o p o s a l . 6) jectives.  The r e l a t i o n s h i p o f t h e p r o p o s a l  t o p u b l i c g o a l s and ob-  When t h e c i t i z e n s o f a community o r r e g i o n have formed a s e t  of g o a l s and o b j e c t i v e s through some formal p l a n n i n g p r o c e d u r e , t h e r e l a t i o n s h i p o f t h e proposed p r o j e c t t o these p u b l i c a s p i r a t i o n s should be d e s c r i b e d i n t h e E I S .  S i m i l a r l y , any r e l e v a n t q u e s t i o n n a i r e s ,  surveys,  p u b l i c meetings., workshops, e t c . which have been undertaken t o h e l p def i n e t h e needs and d e s i r e s o f t h e p u b l i c a f f e c t e d by t h e p r o p o s a l  should  a l s o be c o n t r a s t e d t o t h e p r o s p e c t i v e consequences o f t h e p r o p o s a l .  V.  A l t e r n a t i v e s t o t h e Proposed A c t i o n It i s e s s e n t i a l i n planning  t h a t the proposed p r o j e c t i s chosen  to maximize the n e t b e n e f i t s a c c r u i n g t o s o c i e t y . p r o j e c t t o be proposed, i t i s n e c e s s a r y  In o r d e r f o r t h e b e s t  t h a t t h e b e n e f i c i a l and adverse  e f f e c t s o f a range o f a l t e r n a t i v e s be e v a l u a t e d .  The premise u n d e r l y i n g  a l t e r n a t i v e " a n a l y s i s i s that the generation o f information to d e c i s i o n makers and t h e p u b l i c about t h e consequences o f a l t e r n a t i v e o p p o r t u n i t i e s w i l l r e s u l t i n more s o c i a l l y r e s p o n s i b l e d e c i s i o n s o f S c i e n c e s , 1968).  (U.S. N a t i o n a l Academy  Based upon t h e U.S. g u i d e l i n e s (1973b) r e c e n t l y  r e v i s e d due t o c o u r t d e c i s i o n s on impact statements, a l t e r n a t i v e s which  -  177  -  should be considered i n this evaluation  are:  1)  The choice of "no action";  2)  Alternative designs and locations which achieve s i m i l a r objectives as the proposal;  3)  Alternatives of a d i f f e r e n t type which achieve s i m i l a r objectives as the proposal.  This evaluation of alternatives should be substantial enough to indicate the important tradeoffs between each p o t e n t i a l choice and the proposed project. Due  to the broad d e f i n i t i o n of p o t e n t i a l alternatives mentioned  above i t may seem that a multitude of choices are possible concerning almost any proposal.  I t would be an almost unfeasible task to t r y to  evaluate the p o s i t i v e and negative aspects of numerous a l t e r n a t i v e s , and attempt to communicate t h i s 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, p o l i c i e s and programs of a public entity would eliminate many broad alternatives from treatment i n an EIS for a s p e c i f i c action.  For example, i f a long range plan was developed according to  the planning process mentioned i n an e a r l i e r part of these guidelines, future programs would be established to the extent that many alternatives would be eliminated  from consideration  i n EIS's for s p e c i f i c projects.  If an e l e c t r i c a l u t i l i t y agency decided through t h i s planning process leading to a long-range plan that hydropower i s the only p u b l i c l y acceptable a l t e r n a t i v e 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 i n the impact report f o r  - 178  a s p e c i f i c dam should  proposal.  -  Of c o u r s e , the EIR on the long-range p l a n  thoroughly discuss  the pros and  cons o f a l l r e l e v a n t power gene-  r a t i o n s o u r c e s to h e l p develop through p u b l i c s c r u t i n y some consensus on the f u t u r e e l e c t r i c a l energy programs o f the p u b l i c u t i l i t y tion.  organiza-  Through the development o f such a long-range p l a n , t h e r e  need i n an EIR  f o r a s p e c i f i c p r o j e c t to r a i s e i s s u e s a l r e a d y  i s no  resolved  through a p u b l i c p a r t i c i p a t i o n p r o c e s s . A second c o n s i d e r a t i o n which can h e l p reduce the l a r g e 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 p r o p o s a l reference  i s to develop c h o i c e s  to the d i f f e r e n t o b j e c t i v e s of the p u b l i c  demy of S c i e n c e ,  1968).  s t a t e d i n community and  The  o b j e c t i v e s and  r e g i o n a l p l a n s , and  communication w i t h a c t i v e i n t e r e s t groups. number o f c h o i c e s  (U.S.  only i n  National  Aca-  g o a l s of the p u b l i c are can a l s o be developed  often  through  T h i s method o f r e d u c i n g  the  f o r e v a l u a t i o n w i l l l i k e l y develop an a l t e r n a t i v e  t h a t maximizes e f f i c i e n c y , an a l t e r n a t i v e w i t h a g o a l to a c h i e v e 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 t h a t o p t i m i z e s  Other i n t e r e s t e d s e c t o r s i n s o c i e t y s h o u l d  environmental q u a l i t y .  l i k e w i s e be r e p r e s e n t e d  with  an e v a l u a t i o n o f the a l t e r n a t i v e t h a t r e f l e c t s t h e i r o b j e c t i v e s . a l s o been recommended  (U.S.  N a t i o n a l Academy of S c i e n c e s ,  1968)  It  has  that  compromise a l t e r n a t i v e s between o b j e c t i v e s be i n c l u d e d i n the a n a l y s i s . Since a l a r g e number o f a l t e r n a t i v e s may have to be used to s c r e e n  VI.  still  p o t e n t i a l choices  r e s u l t , judgement w i l l  to a manageable t o t a l .  A D i s c u s s i o n o f P u b l i c and Agency Responses to the P r o p o s a l EIS o n l y ) A d i s c u s s i o n of a l l c i t i z e n i n f o r m a t i o n meetings and  government agency comments on the d r a f t should  be  included  (final  a l l public  i n the  final  - 179  -  EIS to h e l p r e s o l v e d i f f e r e n c e s and f u r t h e r e x p l a i n the r a t i o n a l e f o r c e r t a i n key  judgements.  CONCLUSION  These g u i d e l i n e s f o r the e v a l u a t i o n and p r e p a r a t i o n o f e n v i r o n mental impact statements were developed b a s i c a l l y from the simple purpose the  document i s i n t e n d e d to s e r v e .  The c r i t i c a l review o f f i v e  impact  statements, and d i s c u s s i o n o f impact e v a l u a t i o n methods e a r l i e r i n t h i s t h e s i s have p r o v i d e d i n f o r m a t i o n about e n v i r o n m e n t a l r e p o r t and  assessment  weaknesses which were e s p e c i a l l y addressed i n t h e s e g u i d e l i n e s . knowledge t h a t the e x i s t i n g s t a t e of a r t i n impact assessment  Yet,  is still  in  a d e v e l o p i n g s t a g e and the r e a l i z a t i o n o f the numerous d i f f e r e n t  of  a c t i o n s and c o n d i t i o n s a f f e c t i n g the p r e p a r a t i o n o f impact  types  statements  l e a d s the author t o s t r o n g l y doubt whether the g u i d e l i n e s recommended i n t h i s t h e s i s a r e a panacea  f o r EIS problems.  I n s t e a d , the i n f o r m a t i o n  g e n e r a t i o n f u n c t i o n o f an EIS p r e s c r i b e s t h a t any impact e v a l u a t i o n statement p r e p a r a t i o n procedure adopted by p u b l i c a g e n c i e s be i n o r d e r to s e r v e the needs o f those d e c i s i o n - m a k e r s , i n t e r e s t  flexible groups,  government a g e n c i e s and i n t e r e s t e d members o f the p u b l i c t h a t w i l l r e v i e w i n g f u t u r e impact r e p o r t s . the  and  be  As a r e s u l t , i t i s recommended t h a t  g u i d e l i n e s , i n t h i s t h e s i s be used as a g e n e r a l framework f o r d e v e l o -  p i n g s p e c i f i c agency procedures f o r e n v i r o n m e n t a l e v a l u a t i o n s and preparation.  These s p e c i f i c agency procedures s h o u l d be  EIS  initially  developed through a r e v i e w and comment p r o c e s s o f those government a g e n c i e s , i n t e r e s t groups and p r i v a t e persons who f u t u r e impact statements.  Through  w i l l be r e a d i n g the  such a p r o c e s s , the impact  statements  - 180  -  produced by the p r o p o s i n g agency w i l l generate the i n f o r m a t i o n  that i s  needed by those i n t e r e s t e d persons to r e a c h an i n d i v i d u a l , r a t i o n a l d e c i s i o n about the s o c i a l worth o f the p r o j e c t .  These impact  can be l a t e r used as a t o o l to p e r i o d i c a l l y update EIS p r o c e d u r e s so t h a t  statements  preparation  f u t u r e impact r e p o r t s w i l l r e f l e c t the c o n t i n u a l l y  changing needs o f s o c i e t y .  - 181 -  LITERATURE CITED Anderson, Frederick R. 1973. 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F i n a l Environmental Impact Statement for the Proposed Northwest Alloys Magnesium Plant at Addy, Washington. Olympia, Wash. Washington State Dept. of Highways. 1974. Draft Environmental Impact Statement: for State Route 82 (Interstate 82) - Prosser V i c i n i t y . Report No. FHWA-WN-EIS-74-01-D, Olympia, Wash. Westinghouse Environmental Systems. 1973. Environmental Analysis of the C o l s t r i p Generation and Transmission Project. Prepared f o r Montana Power Company, Puget Sound Power & Light Company, Portland General E l e c t r i c Company, The Washington Water Power Company, and P a c i f i c Power & Light Company.  - 188  -  OTHER REFERENCES  American  S o c i e t y of C i v i l E n g i n e e r s . 1973. Environmental P o l i c y C o n s i d e r a t i o n s . Papers p r e s e n t e d a t t h e 1973 ASCE N a t i o n a l Meeting on Water Resources E n g i n e e r i n g , Wash., D.C.  A p p l e y a r d , D. and K. Lynch. 1967. " E s t h e t i c C r i t e r i a f o r Highway D e s i g n " , i n S t r a t e g i e s f o r the E v a l u a t i o n o f A l t e r n a t i v e T r a n s p o r t a t i o n . P l a n s . E d i t e d by E.N. Thomas and J . L . S c h o f e r , Northwestern T r a n s p o r t a t i o n Center Research Report. A t k i n s , W.G. 1971. S o c i a l , Economic and E n v i r o n m e n t a l F a c t o r s i n Highway D e c i s i o n - M a k i n g . Prepared f o r the Texas Highway Department and the FHWA by the Texas T r a n s p o r t a t i o n I n s t i t u t e . C a l i f o r n i a C o u n c i l of C i v i l E n g i n e e r s and Land S u r v e y o r s . 1972. t a l Impact A n a l y s i s . Sacramento, C a l i f .  Environmen-  Canadian M a n u f a c t u r e r s A s s o c i a t i o n . 1973. Proceedings of a Seminar on E n v i ronmental Impact Assessment. Held a t the R o y a l York H o t e l , T o r o n t o , Ontario. C a r t e r , E v e r e t t C , L o n n i e E. Haefner and Jerome VI: H a l l . 1972. An Informat i o n a l Report on Techniques f o r E v a l u a t i n g F a c t o r s R e l e v a n t t o D e c i s i o n - M a k i n g on Highway L o c a t i o n s . Department of C i v i l E n g i n e e r i n g , U n i v . of Maryland. 'j  Center For N a v a l A n a l y s e s , O f f i c e of Naval Research. 1972. Handbook o f J u d i c i a l D e c i s i o n s (through 20 October 1972) I n v o l v i n g E n v i r o n mental Impact Statements.. NTIS P u b l i c a t i o n No. AD-757 060, S p r i n g f i e l d , Va. C o n t i n u i n g E d u c a t i o n i n C i t y , R e g i o n a l and E n v i r o n m e n t a l P l a n n i n g . 1972. Improving the E n v i r o n m e n t a l Impact Assessment P r o c e s s . C o l l e g e of E n v i r o n m e n t a l D e s i g n , U n i v e r s i t y o f C a l i f o r n i a , B e r k e l e y . Detwyler, Thomas R. 1971. Man's Impact On Environment. Company, New York, N.Y.  McGraw-Hill  Book  D i t t o n , Robert B. and Thomas I.Goodale. 1972. Environmental Impact A n a l y s i s : P h i l o s o p h y and Methods. P r o c e e d i n g s o f t h e Conference on E n v i r o n mental Impact A n a l y s i s , Green Bay, W i s c o n s i n . F e i b u s h , Hans. 1973. "What You Should Know about NEPA, CEQA, and i n Western C o n s t r u c t i o n , March.  EIS"\  H i l l , M o r r i s . 1968. "A Goals Achievement M a t r i x For E v a l u a t i n g E n v i r o n m e n t a l P l a n s " , i n A.I.P. J o u r n a l . January.  - 189 -  Kennedy, William V. and Bruce B. Hanshaw. 1974. "The Effectiveness of Environmental Impact Statements", i n E k i s t i c s . No. 218, Jan., pp. 19-22. Kross, B.C. 1972. "Preparation Of An Environmental Impact Statement", i n Univ. of Colorado Law Review. Vol. 44, August, pp. 81-147. L i t t o n , R. Burton, J r . 1968. Forest Landscape Description and Inventories: A Basis For Planning and Design. Research Paper PSW-49, P a c i f i c Southwest Forest and Range Experiment Station, Forest Service, U.S. Dept. of Agriculture, Berkeley, C a l i f o r n i a . Olds, F.C. 1971. "Preparing the Environmental Statement", i n Power Engineering. Vol. 75, June, pp. 45-47. Ortolano, Leonard, and William W. H i l l . 1972. An Analysis of Environmental Statements For Corps of Engineers Water Projects. Prepared for the U.S. Army Engineer I n s t i t u t e for Water Resources, Alexandria, Va. Roberts, James A. 1973. "Just What Is An Environmental Impact Statement", i n Urban Land. May, pp. 9-15. Sacramento County Planning Dept., Environmental Impact Section. 1973. Procedures for Preparation and Processing of Environmental Impact Reports. Sacramento, C a l i f . S t e i n i t z , C. and P. Lewis. 1970. "A General System for Environmental Resource Analysis", Public Land Policy and the Environment: Part I l l - E n vironmental Quality and the Public Lands. Landscapes, Inc., Madison, Wisconsin. S t e i n i t z , C. 1970. "Landscape Resource Analysis, The State of the Art" , in Landscape Architecture Quarterly, F a l l . (  f  Tryzna, Thaddeus C. 1973. Environmental Impact Requirements i n the States. " Prepared for the U.S. Environmental Protection Agency by the Center for C a l i f o r n i a Public A f f a i r s . Wash., D.C. U.S.  Department of the Army, O f f i c e of the Chief of Engineers. 1973. Engineer Regulation No. 1105-2-507 — Guidelines For The Preparation And Coordination Of Environmental Statements. Wash., D.C.  U.S. Department of the Army, O f f i c e of the Chief of Engineers. 1973. Environmental Considerations i n Postal Construction, Regulation No. 1105-6-1. Wash., D.C. U.S.  Department of the Army, O f f i c e of the Chief of Engineers. 1972. Environmental Impact Assessments and Impact Statements, Regulation No. 1105-3-1. Wash., D.C.  - 190 -  U.S. Department of Housing and Urban Development. 1971. The National Environmental P o l i c y Act of 1969 — Region IX Implementation. C i r c u l a r No. SF 1390. IA, San Francisco, C a l i f . U.S. Department of the I n t e r i o r , Bureau of Land Management. 1972. Instruct i o n Memorandum No. 72-135 — Format For Environmental Analysis Record. Wash., D.C. U.S. Department of the I n t e r i o r , Bureau of Reclamation. 1972. Transmittal No. 376-5 — Guidelines For The Preparation Of Environmental Statements. Wash., D.C. U.S. Department of the Navy, O f f i c e of the Chief of Naval Operations. 1972. OPNAV Instruction 6240. 2C. Wash., D.C. U.S. Department of Transportation, Federal Highway Administration. 1972. Policy and Procedure Memorandum, Transmittal 257. Wash., D.C. University of C a l i f o r n i a , Davis. 1971. Workshop i n Environmental Impact Analysis, Summary. D i v i s i o n of Environmental Studies, Davis, Calif. V i r g i n i a Highway Research Council. 1971. A Manual For Conducting Environmental Impact Studies. NTIS Publication No. PB-210 222, Springf i e l d , Va. Warner, Maurice L. and Edward H. Preston. 1974. A Review Of Environmental Impact Assessment Methodologies. Prepared for the O f f i c e of Research and Development, U.S. Environmental Protection Agency, Wash., D.C. Washington State Department of Ecology. 1972. Guidelines For Implementation of the State Environmental P o l i c y Act of 1971. Olympia, Wash. Zube, Erwin H. 1970. "Evaluating the V i s u a l and Cultural Landscape", Journal of S o i l and Water Conservation. V o l . 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 t a t . 8S2  To establish a national policy for the environment, to provide for the establishment 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 Ehbe cited as the "National Environmental Policy Act of 1969"'. vironmental Polioy Aot of 1969. PURPOSE 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 eliminate damage to the environment and biosphere and stimulate the health and welfare of man; to enrich the understanding of the ecological systems and natural resources important to the Nation; and to establish a Council on Environmental Quality. TITLE 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 maintaining environmental quality to the overall welfare and development of man, declares that it is the continuing policy of the Federal Government, in cooperation with State and local governments, and other concerned public and private organizations, to use all practicable means and measures, includingfinancialand technical assistance, in a manner 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 practicable 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 environment without degradation, risk to health or safety, or other undesirable 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 -  Pub. Law 91-190  83 STAT. 653  January 1, 1970  (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 healthful environment and that each person has a responsibility to contribute to the preservation and enhancement of the environment. Administration. 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 Federal 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 consultation with'the Council on Environmental Quality established by title II of this Act, which will insure that presently unqualified environmental amenities and values may be given appropriate consideration in decisionmaking along with economic and technical considerations; (C) include in every recommendation or report on proposals for legislation and other major Federal actions significantly affecting the quality of the human environment, a detailed statement 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 resources 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 Federal agency which has jurisdiction by law or special expertise with Copies of staterespect to any environmental impact involved. Copies of such ments, eto.javail- statement and the comments and views of the appropriate Federal, ability. . State, and local agencies, which are authorized to develop and enforce environmental standards, shall be made available to the President, the Council on Environmental Quality and to the pub81 Stat. 54. 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 resources; (E) recognize the worldwide and long-range character of environmental 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, institutions, 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 ) initiate and utilize ecological i n f o r m a t i o n i n the p l a n n i n g and development of resource-oriented projects; a n d ( H ) assist the C o u n c i l on E n v i r o n m e n t a l Q u a l i t y established by title I I of this A c t . Sec. 103. A l l agencies of the F e d e r a l Government shall review Review, their present statutory authority, administrative regulations, and current policies a n d procedures f o r the purpose of determining whether there are a n y deficiencies o r inconsistencies therein which prohibit f u l l compliance w i t h the purposes and provisions of this A c t and shall propose to the President not later than J u l y 1,1971, such measures as m a y be necessary to b r i n g their authority and policies into c o n f o r m ity w i t h the intent, purposes, and procedures set f o r t h i n this A c t . Sec. 104. N o t h i n g i n Section 102 or 103 shall i n any way affect the specific statutory obligations of any Federal agency (1) to comply w i t h criteria or standards o f environmental q u a l i t y , (2) to coordinate or consult w i t h any other F e d e r a l or State agency, or (3) to act, o r r e f r a i n f r o m acting contingent upon the recommendations or certification of a n y o t h e r Federal o r State agency. Sec. 105. T h e policies and goals set forth i n this A c t are supplement a r y t o those set f o r t h i n e x i s t i n g authorizations o f F e d e r a l agencies.  TITLE II COUNCIL ON ENVIRONMENT Al. QUALITY  Sec. 201. T h e President shall transmit to the Congress annually Report to beginning J u l y 1, 1970, an E n v i r o n m e n t a l Q u a l i t y Report (herein- c o n f e s s , after referred to as the " r e p o r t " ) w h i c h shall set f o r t h (1) the status and condition o f the m a j o r n a t u r a l , manmade, o r altered environmental classes of the N a t i o n , i n c l u d i n g , but not l i m i t e d to, the a i r , the aquatic, i n c l u d i n g marinej estuarine, a n d fresh water, and the terrestrial environment, i n c l u d i n g , but not l i m i t e d to, the forest, d r y l a n d , wetland, range, urban, suburban, and r u r a l environment j (2) current and foreseeable trends i n the quality, management and u t i l i z a 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 n a t u r a l resources f o r f u l f i l l i n g h u m a n and economic requirements o f the N a t i o n i n the l i g h t of expected population pressures; ( 4 ) a review of the programs a n d activities ( i n c l u d i n g regulatory activities) of the F e d e r a l Governmentj the State and local governments, and nongovernmental entities or individuals, w i t h p a r t i c u l a r reference to their effect on the environment a n d on the conservation, development and u t i l i z a t i o n of natural resources; a n d (5) a program f o r remedying the deficiencies o f existing programs a n d activities, t o gether with recommendations f o r legislation. Sec. 202. T h e r e is created i n the Executive Office of the President Counoil on a C o u n c i l on E n v i r o n m e n t a l Q u a l i t y (hereinafter referred to as the Environmental " C o u n c i l " ) . T h e C o u n c i l shall be composed o f three members who shall Quality, be appointed b y the President to serve at h i s pleasure, by and w i t h the advice a n d consent of the Senate. T h e President shall designate one o f the members of the C o u n c i l to serve as C h a i r m a n . E a c h member shall be a person who, as a result o f h i s t r a i n i n g , experience, a n d attainments, is exceptionally well qualified to analyze a n d interpret environmental trends and i n f o r m a t i o n o f a l l k i n d s : to appraise programs and activities o f the Federal Government i n the light o f the policy set f o r t h i n title I o f this A c t ; to be conscious of and responsive to the scientific, economic, social, esthetic, and c u l t u r a l needs and i n terests of the N a t i o n ; a n d to formulate a n d recommend national policies to promote the improvement o f the q u a l i t y o f 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 information for the purpose of determining whether such conditions and trends are interfering, or are likely to interfere, with the achievement 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 policies 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 necessary 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 legislation 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 Environmental 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 conflict with similar activities authorized by law and performed by established agencies.  - 196 -  Pub. L a w 91-190  January 1, 1970  83 STAT 856  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 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. A p p r o v e d J a n u a r y 1, 1970.  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  Tenure and  comDensation.  60 Stat. 460, 461.  81 Stat. 638. Appropriations,  - 197 -  APPENDIX B  GUIDELINES FOR THE PREPARATION OF ENVIRONMENTAL IMPACT STATEMENTS DEVELOPED BY THE U.S. COUNCIL ON ENVIRONMENTAL QUALITY  10856  198 -  PROPOSED RULES  Government, In the light of the Act's short-range implications of proposed policy, for the purpose of determining the actions to man, his physical and social extent to which such programs and acti- surroundings, and to nature. Agenpies [40 CFR Ch. V] vities are contributing to the achieve- should consider the results of their enment of such policy, and to make recom- vironmental assessments along with their PREPARATION OF ENVIRONMENTAL mendations to the President with respect assessments of the net economic, techIMPACT STATEMENTS thereto. Section 102(2) (B) of the Act nical, and other benefits of proposed Proposed Guidelines directs all Federal agencies to identify actions and use all practicable means, The Council on Environmental Quality and develop methods and procedures, in consistent with other essential considtnvites comments and suggestions from consultation with the Council, to insure erations of national policy, to avoid or Interested parties with respect to the fol- that unquantified environmental values minimize - undesirable consequences for lowing proposed revisions of the Coun- be given appropriate consideration in the environment. cil's guidelines on the preparation of en- decisionmaking along with economic and 3. Agency and OMB procedures.—(a) vironmental "impact statements pursu- technical considerations; section 102(2) Pursuant to section 2(f) of Executive ant to section 102(2) (C) of the National (C) of the Act directs that copies of Order 11514, the heads of Federal agenEnvironmental Policy Act (NEPA) (42 all environmental impact statements be cies have been directed to proceed with XJJB.C. section 4332(2) (c)). The present filed with the Council; and section 102(2) measures required by section 102(2) (C) guidelines, dated April 23,1971, are avail- (H) directs all Federal agencies to of the Act. Previous guidelines of the able from the Council and appear at 36 assist the Council in the performance of Council on Environmental Quality diits functions. These provisions have been rected each agency to establish its own FR 7724-7729. Comments should be sent to the Coun- supplemented in sections 3 (h) and (i) formal procedures for: (1) Identifying cil on Environmental Quality, 722 Jack- of Executive Order 11514 by directions those agency actions requiring environson Place NW., Washington, D.C. 20006, that the Council issue guidelines to Fed- mental statements, the appropriate time eral agencies for preparation of environ- prior to decision for the consultations reon or before June 18,1973. After consideration of the comments mental impact statements and such quired by section 102(2) (C) and the and views of interested parties, the other instructions to agencies and re- agency review process for which environCouncil will make appropriate revisions quests for reports and information as mental statements are to be available, and will codify these guidelines in final may be required to carry out the Council's (2) obtaining information required in form In-the Code of Federal Regulations, responsibilities under the Act. their preparation, (3) designating the establishing a new chapter 5 to title 40 2. Policy.—As early as possible and In officials who are to be responsible for the of that Code. all cases prior to agency decision con- statements, (4) consulting with and takThe proposed revisions and a section- cerning recommendations or favorable ing account of the comments of approby-section commentary follow: reports on proposals for: (i) Legislation priate Federal, State, and local agencies, 1. Purpose and authority.—(a) This significantly affecting the quality of the incl idiftg obtaining the comment of the directive provides guidelines to Federal human environment (see sees. 5(i) and Ad. .linistrator bf the Environmental departments, agencies, and establish- 12, infra) (hereafter "legislative ac- Protection Agency when required under ments for preparing detailed environ- tions") , and (ii) all other major Fed- section 309 of the Clean Air Act, as mental statements on proposals for eral actions significantly affecting the amended, and (5) meeting the requirelegislation and other major Federal ac- quality of the human environment ments of section 2(b) of Executive Order tions significantly affecting the quality (hereafter "administrative actions"). 11514 for providing timely public inforof the human environment as required by Federal agencies will, in consultation mation on Federal plans and programs section 102(2) (C) of the National En- with other appropriate Federal, State, with environmental impact. Each agency vironmental Policy Act (Public Law and local agencies, assess in detail the shall review the procedures it has estab91-190, 42 US.C. sections 4321 et seq.) potential environmental impact. Initial lished pursuant to the above directives (hereafter "the Act"). Underlying the assessments of the environmental im- and shall revise them, in consultation preparation of such environmental pacts of proposed action should be under- with the Council on Environmental Qualstatements is the mandate of both the taken concurrently with initial techni- ity, as may be necessary in order to reAct and Executive Order 11514 (35 FR cal and economic studies and, where re- spond to requirements imposed by these 4247), of March 5, 1970, that all Federal quired, a draft environmental impact revised guidelines as well as by such agencies, to the fullest extent possible, statement prepared and circulated for previous directives. After such condirect their policies, plans, and programs comment in time to accompany the pro- sultation, proposed revisions of such so as to meet national environmental posal through the existing agency re- agency procedures shall be published goals to encourage productive and enjoy- view processes for such action. In this in the Federal Register no later able harmony between man and his en- process. Federal agencies shall: (i) Pro- than 90 days after the date that vironment, to promote efforts preventing vide for circulation of draft environ- these guidelines are published in final or eliminating damage to the environ- mental statements to other Federal, form. A minimum 45-day period for ment and biosphere and stimulating the State, and local agencies and for their public comment shall be provided, folhealth and welfare of man, and to enrich availability to the public in accordance lowed by publication of final procedures the understanding of the ecological sys- with the provisions of these guidelines; no later than 45 days after the conclusion tems and natural resources important to (ii) consider the comments of the agen- of the comment period. Each agency the Nation. The objective of section 102 cies and the public; and (iii) issue final shall submit seven copies of all such pro(2) (C) of the Act and of these guide- environmental impact statements re- cedures to the Council on Environmental lines is to build into the agency de- sponsive to the comments received. The Quality. Any future revision of such cisionmaking process, beginning at the purpose of this assessment and consul- agency procedures shall similarly be proearliest possible point, an appropriate tation process is to provide agencies posed and adopted only after prior conand careful consideration of the environ- and other decisionmakers as well as sultation with the Council and, in the mental aspects of proposed action and members of the public with an under- case of substantial revision, opportunity to assist agencies in implementing the standing of the potential environmental for public comment. policies as well as the letter of the Act. effects of proposed actions, to avoid or (b) Each Federal agency should conThis directive also provides guidance to minimize adverse effects wherever posFederal, State, and local agencies and sible, and to restore or enhance environ- sult, with the assistance of the Council the public in commenting on statements mental quality to the fullest extent prac- on Environmental Quality arid the Ofprepared under these guidelines. ticable. In particular, agencies should fice of Management and Budget if de^ sired, with other appropriate Federal (b) Pursuant to section 204(3) of the use the environmental impact statement agencies in the development and reviAct the Council is assigned the duty and process to explore alternative actions sion of the above procedures so as to function of reviewing and appraising the that will avoid or minimize adverse im- achieve consistency in dealing with programs and activities of the Federal pacts and to evaluate both the long- and similar activities and to assure effective  COUNCIL ON ENVIRONMENTAL QUALITY  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 a p plicable, State and local review of such agency procedures should be conducted pursuant to procedures established by Office of Management and Budget C i r cular No. A - 8 5 . For those revised agency procedures subject to O M B Circular No. A - 8 5 a 30-day extension i n the public comment period provided for in section 3(a) is granted. (c) Existing mechanisms for obtaining the views of Federal, State, and local agencies on proposed Federal actions should be utilized to the maximum extent practicable in dealing with environmental matters. T h e Office of Management 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 i n this Act," and section 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 agencies." 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 policies 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 revise them as necessary to insure full compliance with the purposes and provisions 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 comply with that section unless existing law applicable to the agency's operations expressly prohibits or makes compliance impossible. 5. Actions included.—"Actions" include but are not limited to: (i) Recommendations or favorable reports relating to legislation including requests for appropriations. The requirement for following the section 102(2) (C) procedure as elaborated in these guidelines applies to both (i) agency recommendations on their own proposals for legislation (see section 12 infra); and (ii) agency reports on legislation initiated elsewhere. In the latter case only the agency which has primary responsibility 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 contracts, 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.  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 establishment of regulations, rules, procedures, and policy. 6. Identifying major actions significantly affecting the environment.—(a) The statutory clause "major Federal a c tions significantly affecting the quality of the h u m a n environment" is to be c o n strued by agencies with a view to the overall, cumulative impact of the action proposed (and of further actions c o n templated). Such actions may be localized in their impact, but if there is potential 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 covered in all cases. In considering what constitutes major action significantly a f fecting the environment, agencies should bear in mind that the effect of many Federal decisions about a project or c o m plex of projects can be individually l i m 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 precedent for action in much larger cases or represents a decision in principle about a future major course of action, or when several Government agencies individually make decisions about partial aspects of a major action. In all such cases, an environmental statement should be prepared 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 i n d i cates the broad range of aspects of the environment to be surveyed in any assessment of significant effect. The Act also indicates that adverse significant effect. The Act also indicates that a d verse significant effects include those that degrade the quality of the environment, curtail the range of beneficial uses of the environment, and serve short-term, to the disadvantage of long-term, environmental goals. S i g nificant effects can also include actions which may have b o t h . beneficial and detrimental effects, even if on balance the agency believes that the effect will be beneficial. Significant effects also i n clude secondary effects, as described more fully, for example in sec. 8(a) (ii) (B), infra. T h e significance of a proposed action may also vary with the setting, with the result that an action that would have little impact in a n urban area may be significant in a rural setting or vice versa. While a precise definition of e n vironmental "significance," valid in all contexts, is not possible, effects to be considered i n assessing significance i n -  elude, but are not limited, to those outlined 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 detailed environmental impact statement in the case of "major Federal a c tions significantly affecting the quality of the human environment." T h e identification of major actions significantly affecting the environment is the responsibility of each Federal agency, to be carried out against the background of its own particular operations. T h e a c 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 h u m a n e n 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 sufficient Federal control and responsibility to constitute "Federal action" i n c o n trast to cases where such Federal control and responsibility are not present as, for example, when Federal funds are distributed 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. E a c h agency should review the typical classes of a c tions that it undertakes and, In consultation with the Council on E n v i r o n mental Quality, should develop specific criteria and methods for identifying those actions likely to require environmental statements and those actions likely not to require environmental statements. Normally this will involve: (i) Making an initial assessment of the environmental impacts typically associated 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) W i t h respect to remaining actions that may require statements depending on the circumstances, and those actions determined under the preceding p a r a graph (ii) as likely to require statements, identifying: (1) W h a t basic i n formation needs to be gathered; (2) how and when such information is to be a s 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 issued pursuant to section 3(a) of these guidelines, or issue such guidance as supplemental instructions to aid relevant agency personnel in implementing the impact statement process. Pursuant to section 15 of these guidelines, agencies  FEDERAL REGISTER, VOL. 38, NO. 84—WEDNESDAY, MAY 2, 1973  - 200 PROPOSED RULES  shall report to the Council by Decem- circulated for comment and furnished (il) the degree of Interest In the prober 1, 1973, on the progress made in de- to the Council as early as possible in the posal, as evidenced by requests from the veloping such substantive guidance. agency review process in order to permit public and from Federal, State and local (d) In determining when statements agency decisionmakers and outside re- authorities that a hearing be held; (ill) are required, agencies should give care- viewers to give meaningful consideration the complexity of the issue and the likeful attention to identifying and defining to the environmental issues involved. In lihood that information will be presented the scope of the action which would mostparticular, agencies should keep in mind at the hearing which will be of .assistappropriately serve as the subject of the that such statements are to serve as the ance to the agency in fulfilling its restatement. In many cases, broad program means of assessing the environmental sponsibilities under the Act; (iv) the statements will be desirable, assessing theimpact of proposed agency actions, rather extent to which public involvement alenvironmental effects of a number of than as a justification for decisions al - ready has been achieved through other individual actions on a given geographi- ready made. This means that draft state- means, such as earlier public hearings, cal area (e.g., coal leases), or environ- ments on administrative actions should meetings with citizen representatives, mental Impacts that are generic or com- be prepared and circulated for comment and/or written comments on the promon to a series of agencv actions (e.g., prior to thefirstsignificant point of de- posed action. Agency procedures should harbor maintenance dredging), or the cision in the agency review process. For also indicate as explicitly as possible overall impact of a large-scale program major categories of agency action, this those types of agency decisions or acor chain of contemplated projects (e.g., point should be identified in the proce- tions which utilize hearings as part of major lengths of highway as opposed to dures issued pursuant to section 3(a). the normal agency review process, either small segments), or the environmental (c) Where more than one agency di- as aresultof statutory requirement or implications of research activities that rectly sponsors an action, or is directly agency practice. Agencies should make have reached a stage of investment or involved through funding, licenses, or any draft environmental statement commitment to implementation likely to permits, to the maximum extent possible available to the public at least 15 days determine subsequent development or one statement should serve as the means prior to the time of such hearings. restrict later alternatives. Subsequent of compliance with section 102(2) (C) ' 8. Content of environmental statestatements on major individual actions for all Federal action involved. Agencies ments.—(a) The following points are to should be necessary only where such in such cases should consider the possi- be covered: actions have significant environmental bility of joint preparation of a statement (i) A description of the proposed action impacts not adequately evaluated in the by all agencies concerned, or designa- and of the environment affected. Includprogram statement. tion of a single "lead agency" to as- ing information, summary technical 7. Procedures for preparing draft en- sume supervisory responsibility for prep- data, and maps and diagrams where vironmental statements; hearings.—(a) aration of the statement. Where a lead relevant, adequate to permit an assessIn accord with the policy of the Act and agency prepares the statement, the other ment of potential environmental impact Executive Order 11514 agencies have agencies involved should provide assist- by commenting agencies and the public. a responsibility to develop procedures to ance with respect to their areas of juris- Highly technical and specialized analyses Insure the fullest practicable provision of diction and expertise. In either case, the and data should be avoided in the body timely public information and under- statement should contain an environ- of the draft impact statement. Such mastanding of Federal plans and programs mental assessment of the full range of terials should be attached as appendices with environmental impact in order to Federal actions involved, should reflect or footnoted with adequate bibliographic obtain the views of interested parties. In the views of all participating agencies, references. The statement should also furtherance of this policy, agency proce- and should be prepared before major or succinctly describe the environment of dures should include an aporopriate earlvirreversible actions have been taken by the area affected as it exists prior to a notice system for informing the public any of the participating agencies: Fac- proposed action. The amount of detail of the decision to prepare a draft environ- tors relevant in determining an appro- provided in such descriptions should be mental statement on proposed adminis- priate lead agency include the time se- commensurate with the extent and extrative actions (and for soliciting com- quence in which the agencies become in- pected impact of the action, and with ments that may be helpful in preparing volved, the magnitude of their respective the amount of information required at the statement) as soon as is practicable involvement, and their relative expertise the particular level of decisionmaking after the -decision to prepare the state- with respect to the project's environ- (planning, feasibility, design, etc.). In ment is made. In this connection, agen- mental effects. As necessary, the Council order to insure accurate descriptions cies should: (i) Maintain a list of ad- on Environmental Quality will assist in and environmental assessments, site ministrative actions for which environ- resolving questions of responsibility for visits should be made where feasible. mental statements are being prepared; statement preparation in the case of Agencies should also take care to identify, (ii) revise the list at regular intervals multiagency actions. as appropriate, population and growth specified in the agency's procedures de(d) Where an agency relies on an ap- characteristics of the affected area and veloped pursuant to section 3(a) of these plicant to submit initial environmental any population and growth assumptions guidelines; and (iii) make the list avail- information, the agency should assist the used to justify the project or program able for public inspection on request. applicant by outlining the types of infor- or to determine secondary population (b) Each environmental imoaet state- mation required. In all cases, the agency and growth Impacts resulting from the ment shall be prepared and circulated should make its own evaluation of the proposed action and its alternatives (see In draft form for comment in accordance environmental issues and take respon- par. (ii)(B), infra). In discussing these with the provisions of these guidelines. sibility for the scope and content of draft population aspects, agencies should give consideration to using the rates of (Where an agency has an established andfinalenvironmental statements. (e) Agency procedures developed pur- growth in the region of the project conpractice of declining to favor aa alternative until public comments on a pro- suant to section 3(a) of these guidelines tained in the projection compiled for posed action have been received, the shall include provision for public hear- the Water Resources Council by the draft environmental statement may in- ings on actions with environmental im- Office of Business Economics of the Dedicate that two or more alternatives are pact whenever anpropriate. and for pro- partment of Commerce and the Ecounder consideration.) Comments re- viding the public with relevant infor- nomic Research Service of the Departceived shall be carefully evaluated and mation, including information on alter- ment of Agriculture (the OBERS proconsidered in the decision process. A final native courses of action. In deciding jection). In any event it is essential statement with substantive comments whether a public hearing is appropriate, that the sources of. data used be attached shall then be issued and cir- an agency should consider: (i) The identified. culated In accordance with aoplicable magnitude of the proposal in terms of (ii) The probable Impact of the proprovisions of sections 10,11, or 12 of this economic costs, the geographic area in- posed action on the environment. directive. It is important that draft envi- volved, and the uniqueness or size of (A) This requires agencies to assess ronmental statements be prepared and commitment of the resources Involved; the positive and negative effects of the  KDERAl REGISTER, VOL. 38, NO. 84—WEDNESDAY, MAY J, 1973  - 201 - . PROPOSED RULES proposed action as it affects both the national and international environment. The attention given to different environmental 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., highways, airports, sewer systems, water resource projects, etc.), stimulate or induce secondary effects in the form of associated investments and changed patterns of social and economic activities. Such secondary effects, through their impacts on existing community facilities and activities and through inducing new facilities and activities, may often be even more substantial than the primary effects of the original action itself. For example, the effects of the proposed action on population and growth may be among the more significant secondary effects. Such population and growth impacts 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, including land use, water, and public services, of the area in question. (iii) Alternatives to the proposed action, including, where relevant, those not within the existing authority of the responsible agency. (Section 102(2) (D) of the Act requires the responsible agency to "study, develop, and describe appropriate 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, particularly 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 options which might have less detrimental effects. Examples of such alternatives include: The alternative of taking no action or of postponing action pending further study; alternatives requiring actions of a significantly different nature which would provide similar benefits with different environmental impacts (e.g., nonstructural alternatives to flood control programs, or mass transit alternatives to highway construction) ; alternatives related to different designs or details of the proposed action which would present different environmental  impacts (e.g., cooling ponds vs. cooling towers for a powerplant or alternatives that will significantly conserve energy). In each case, the analysis should be sufficiently detailed to permit comparative evaluation of the environmental benefits, costs and risks of the proposed action and each reasonable alternative, provided, however, that where an existing impact statement already contains such an analysis, its treatment of alternatives may be incorporated. (iv) Any probable adverse environmental effects which cannot be avoided (such as water or air pollution, undesirable land use patterns, damage to life systems, urban congestion, threats to health, or other consequences adverse to the environmental goals set out in section 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 purposes of contrast should be a clear statement of how other adverse effects discussed in paragraph (ii) will be mitigated 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 involves tradeoffs between short-term environmental 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 environmentally 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 unavoidable impacts in paragraph (iv) the extent to which the action irreversibly curtails the range of potential uses of the environment. Agencies should avoid construing the term "resources" to mean only the labor and materials devoted to an action. "Resources" also means the natural and cultural resources committed to loss or destruction by the action. (b) In developing the above points, 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 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 adequately covered in discussing the impact of the proposed action and its alternatives—which items should normally ,be the focus of the statement. Draft statements should indicate at appropriate points in the text any underlying studies, reports, and other information obtained and considered by the agency ln  10859 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 Internal 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 instrument, 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, interdisciplinary approach which will insure the integrated use of the natural and social sciences and the environmental design arts in planning and decisionmaking which may have an impact on man's environment." Agencies should attempt to have relevant disciplines represented on their own staffs; where this is not feasible they should make appropriate use of relevant Federal, State, and local, agencies or the professional services of universities and outside consultants. The interdisciplinary approach should not be limited to the preparation of. the environmental impact statement, but should also be used ln the early planning stages of the proposed action. Early application of such an approach 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 accompany each draft and final environmental statement.  9. Review of draft environmental impact 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 environmental statement should consult with, and (on the basis of a draft environmental statement for which the agency takes responsibility) obtain the comment on the environmental impact of the action of Federal and FederalState 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 requirement in section 102(2) (C) to obtain comment from Federal agencies having jurisdiction or special expertise ls in addition to any specific statutory obligation of any Federal agency to coordinate or consult with any other Federal  or State agency. Agencies should, for  FEDERAL REGISTER, VOL. 38, NO. 84—WEDNESDAY, MAY 3, 1973  - 202 -  10860  PROPOSED RULES  example, be alert to consultation require(d) Public review.—Agency procedures Federal, State, and local agencies and ments of the Pish and Wildlife Coordi- should make provision for facilitating the private organizations that made subnation Act, 16 U.S.C. sections 661 et seq., comment of public and private organiza- stantive comments on the draft stateand the National Historic Preservation tions and individuals by announcing the ment and to individuals who requested Act of 1966, 16 U.S.C. sections 470 et seq. availability of draft environmental state- a copy of the final statement. Where the To the extent possible, statements or ments and by making copies available to number of comments on a draft statefindings concerning environmental im- organizations and individuals that have ment is such that distribution of the pact required by such other statutes, as requested an opportunity to comment. final statement to all commenting enin the case of section 4(f) of the Depart- Agencies should devise methods for pub- tities appears impracticable, the agency ment of Transportation Act of 1966. 49 licizing the existence of draft statements, shall consult with the Council concernU.S.C. section 1653(f), or section 106 of for example, by publication in local news- ing alternative arrangements for disthe National Historic Preservation Act papers or by maintaining a list of groups tribution of the statement. of 1966, should be combined with com- known to be interested in the agency's 11. Distribution of statements to Counpliance with the environmental impact activities and directly notifying such cil on Environmental Quality; minimum statement requirements of section 102 groups of the existence of a draft state- priods for review and advance availabil(2) (C) of the Act to yield a single doc- ment, or sending them a copy, as soon as ity; availability to public.—(a) As soon ument which meets all applicable re- it has been prepared. as they have been prepared, 10 copies of quirements. The Advisory Council on (e) Responsibilities of commenting draft environmental statements, 5 copies Historic Preservation, the Department entities.—Agencies and members of the of all comments made thereon (to be of Transportation, and the Department public submitting comments on proposed forwarded to the Council by the entity of the Interior, in consultation with the actions on the basis of draft environ- making comment at the time comment Council on Environmental Quality, will mental impact statements should en- is forwarded to the responsible agency), Issue any necessary supplementing in- deavor to make comments as specific, and 10 copies of the final text of enstructions for furnishing information or substantive, and factual as possible with- vironmental statements (together with findings not forthcoming under the en- out undue attention to matters of form in the substance of all comments received • vironmental impact statement process. the impact statement. Emphasis should thereon by the responsible agency from (b) EPA review under Clean Air Act.— be placed primarily on the assessment Federal, State, and local agencies and, Section 309 of the Clean Air Act. as of the environmental impacts of the pro- from private private organizations and amended (42 U.S.C. sec. 1857h-7), pro- posed action, and the acceptability of individuals) shall be supplied to the vides that the Administrator of the En- those Impacts on the quality of the en- Council on Environmental Quality in the vironmental Protection Agency shall vironment, particularly as contrasted Executive Office of the President (this comment In writing on the environ- with the impacts of reasonable alterna- will serve to meet the statutory requiremental impact of any matter relating tives to the action. Commenting entities ment to make environmental statements to his duties and responsibilities, and may recommend modifications to the available to the President). At the same shall refer to the Council on Environ- proposed action and/or new alternatives time that copies are sent to the Council, mental Quality any matter that the Ad- that will avoid or minimize environ- copies of final statements should also ministrator determines is unsatisfactory mental impacts. be sent to relevant commenting entities from the standpoint of public health or (f) Agencies seeking comment may as set forth in section 10(b) of these welfare or environmental quality. Ac- establish time limits of not less than 45 guidelines. cordingly, wherever an agency action re- days for reply, after which it may be pre(b) To'the maximum extent practilated to air or water quality, noise abate- sumed, unless the agency or party con- cable no administrative action subject ment and control, pesticide regulation, sulted requests a specified extension of to section 102(2) (C) is to be taken sooner solid waste disposal, generally applicable time, that the agency or party consulted than 90 days after a draft environmental environmental radiation criteria and has no comment to make. Agencies seek- statement has been circulated for comstandards, or other provision of the au- ing comment should endeavor to comply ment, furnished to the Council and, exthority of the Administrator is involved, with requests for extensions of time of cept where advance public disclosure Federal agencies are required to submit up to 15 days. will result in significantly increased costs such proposed actions to the Administra10. Preparation and circulation of final of procurement to the Government, made tor for review and comment in writing. environmental impact statements.—(a) available to the public pursuant to these In all cases where EPA determines that Agencies should make every effort to guidelines; neither should such adminisproposed agency action is environ- discover and discuss all major points of trative action be taken sooner than 30 mentally unsatisfactory, or where EPA view on the environmental effects of days after the final text of an environdetermines that an environmental state- the proposed action and its alternatives mental statement (together with comment Is so inadequate that such a de- in the draft statement itself. However, ments) has been made available to the termination cannot be made. EPA shall where opposing professional views and Council, commenting agencies, and the notify the Council on Environmental responsible opinion have been over- public. If the final text of an environQuality as soon as practicable. The Ad- looked in the draft statement and are mental statement is filed within 90 days ministrator's comments shall constitute brought to the agency's attention after a draft statement has been circuhis comments for the purposes of both through the commenting process, the lated for comment, furnished to the section 309 of the Clean Air Act and sec- agency should review the environmental Council and made public pursuant to this tion 102(2) (C) of the National Environ- effects of the action in light of those section of these guidelines, the 30-day mental Policy Act. views and should make a meaningful period and 90-day period may run con(c) State and local review.—Office of reference in the final statement to the currently to the extent that they overlap. Management and Budget Circular No. existence of any responsible opposing An agency may supplement or amend a A-95 (Revised) through its system of view not adequately discussed in the draft or final environmental statement. State and areawide clearinghouses pro- draft statement, indicating the agency's In such cases the agency should consult vides a means for securing the views of response to the issues raised. All sub- with the Council on Enviromental QualState and local environmental agencies, stantive comments received on the draft ity with respect to the possible need for which can assist in the preparation and (or summaries thereof where response or desirability of recirculation of the review of environmental impact state- has been exceptionally voluminous) statement for the appropriate period. ments. Current instructions for obtain- should be attached to the final statement, (c) The Council will publish weekly In ing the views of such agencies are whether or not each such comment is contained in the joint OMB-CEQ memo- thought to merit individual discussion the Federal Register lists of environ-randum attached to these guidelines as by the agency in the text of the state- mental statements received during the preceding week that are available for appendix UJ. A current listing of clear- ment. public comment. The date of receipt by inghouses is issued periodically by the (b) Copies of final statements, with the Council, as noted In the Federal R e g Office of Management and Budget. comments attached, shall be sent to all xstr publication, shall be the date from 1  FEDERAL REGISTER, VOL. 38, NO. 84—WEDNESDAY, MAY J,  1973  PROPOSED RULES which the minimum periods for review that determination. In no case, how- guidelines and report thereon to the and advance availability of statements ever, shall the Council's silence or failure Council on Environmental Quality by to request action with respect to an December 1, 1973. Such reports should shall be calculated. • (d) The Council', publication of no- environmental statement be construed as include an identification of the problem tice of the availability of statements is bearing in any way on the question of areas and suggestions for revision or in addition to the agency's responsibility, the legal requirement for or the adequacy clarification of these guidelines to achieve effective coordination of views as described in section 9(d) of these of such statements under the Act. 12. Legislative actions.—(a) The on environmental aspects (and alternaguidelines, to insure the fullest practicable provision of timely public informa- Council on Environmental Quality and tives, where appropriate) of proposed tion concerning the existence and avail- the Office of Management and Budget actions without imposing unproductive ability of environmental statements. The will cooperate in giving guidance as administrative procedures. Such reports agency responsible for the environmental needed to assist.agencies in identifying shall also indicate what progress the statement is also responsible for making legislative items believed to have en- agency has made in developing substanthe statement, the comments received, vironmental significance. Efforts shall be tive criteria and guidance for making enand any underlying documents available made to identify types of repetitive legis- vironmental assessments as required by to the public pursuant to the provisions lation requiring environmental impact section 6(c) of this directive and by secof the Freedom of Information Act (5 statements (such as certain types of bills tion 102(2) (B) of the Act. U.S.C., sec. 552), without regard to the affecting transportation policy or annual 15. Effective date.—The revisions of exclusion of intragency or interagency construction authorizations) to assure these guidelines shall apply to all draft memoranda when such memoranda preparation of impact statements prior and final impact statements filed with transmit comments of Federal agencies to submission of such legislative proon the environmental impact of the pro- posals to the Office of Management and the Council more than 90 days after the publication of this directive in final form posed action pursuant to section 9 of Budget. these guidelines. Agency procedures pre(b) With respect to recommendations in the FEDERAL REGISTER. pared pursuant to section 3(a) of these or reports on proposals for legislation to R U S S E L L E. T R A I N , guidelines shall implement these public which section 102(2) (C) applies, the Chairman. information requirements and shall in- final text of the environmental stateAPPENDIX I clude arrangements for availability of ment and comments thereon should be (Check one) ( ) Draft. ( ) Final environmental statements and comments available to the Congress and to the pubStatement. at the head and appropriate regional lic for consideration in connection with Environmental Name of Responsible Federal Agency (with offices of the responsible agency and at the proposed legislation or report. In name of operating division where appropriappropriate State, regional, and metro- cases where the scheduling of congres- ate). politan clearinghouses unless the Gov- sional hearings on recommendations or 1. Name of Action. (Check one) ( ) ernor of the State involved designates reports on proposals for legislation which Administrative Action. ( ) Legislative Action. some other point for receipt of this in- the Federal agency has forwarded to the 2. Brief description of action Indicating formation. Notice of such designation of Congress does not allow adequate time an alternate point for receipt of this in- for the completion of a final text of an what States (and counties) particularly formation shall be included in the Office environmental statement (together with affected. 3. Summary of environmental Impact and •of Management and Budget listing of comments), a draft environmental state- adverse environmental effects.' clearinghouses referred to in section ment may be furnished to the Congress 4. List alternatives considered. 9(c). and made available to the public pend5. a. (For draft statements) List all Fed<e) Where emergency circumstances ing transmittal of the comments as re- eral, State, and local agencies from which comments have been requested. make it necessary to take an action with ceived and the final text. b. (For final statements) List all Federal, 13. Application of section 102(2) (C) significant environmental impact withState, and local agencies and other sources procedure to existing projects and proout observing the provisions of these from which written comments have been guidelines concerning minimum periods grams.—The section 102(2) (C) proce- received. dure shall be applied to further major for agency review and advance availabil6. Dates draft statement and final stateity of environmental statements, the Federal actions having a significant ment made available to Council on Environeffect on the environment even though mental Quality and public. Federal agency proposing to take the action should consult with the Council on they arise from projects or programs APPENDIX II—FEDERAL AGENCIES AND FEDERAL STATE AGENCIES WITH JOTUSDICTION BY Environmental Quality about alternative initiated prior to enactment of the Act LAW OR SPECIAL EXPERTISE TO COMMENT O N arrangements. Similarly where there are on January 1, 1970. While the status of the work and degree of completion may VASIOOS TTPES OP ENVIRONMENTAL IMPACTS overriding considerations of expense to the government or impaired program ef- be considered in determining whether to Am fectiveness, the responsible agency proceed with the project, it is essential Air Quality and Air Pollution Control should consult with the Council concern- that the environmental impacts of proing appropriate modifications of the ceeding are reassessed pursuant to the Department of Agriculture-^ Act's policies and procedures and, if the Forest Service (effects on vegetation). minimum periods. project or program is continued, that Atomic Energy Commission (radioactive (f) In order to assist the Council on substances). further incremental major actions be Environmental Quality in fulfilling its shaped so as to minimize adverse en- Department of Health, Education, and Welresponsibilities under the Act and under fare (Health aspects). vironmental consequences. It is also im.Executive Order 11514, all agencies shall Protection Agency— portant in further action that account Environmental Air Pollution Control Office. (as required by Section 102(2) (H) of the be taken of environmental consequences Department of the Interior— Act and section 3(i) of Executive Order not fully evaluated at the outset of the Bureau of Mines (fossil and gaseous fuel 11514) be responsive to requests by the project or program. combustion). Council for reports and other informaBureau of Sport Fisheries and Wildlife 14. Supplementary guidelines, evaluation dealing with issues arising in con(wildlife). nection with the implementation of the tions of procedures.—(a) The Council National Aeronautics and Space AdministraAct. In particular, agencies shall be re- on Environmental Quality after examtion (remote sensing, aircraft emissions). sponsive to requests by the Council for ining environmental statements and either the preparation and circulation of agency procedures with respect to such 'River Basin Commissions (Delaware, environmental statements or, in the al- statements will issue such supplements Great Lakes. Missouri. New England, Ohio, ternative, if the responsible agency deter- to these guidelines as are necessary. Pacific Northwest, Sourts-Bed-Balny, Sus(b) Agencies will continue to assess quehanna, Upper Mississippi) and similar mines that an environmental statement is not required, for an environmental their experience in the implementation Federal-State agencies should be consulted assessment and a publicly available rec- of the section 102(2) (C) provisions of on actions affecting the environment of their ord briefly setting forth the reasons for the Act and in conforming with these specific geographic Jurisdictions. 1  FEDERAL REGISTER, VOL. 38, NO. 84—WEDNESDAY, MAY 3, 1973  - 204 PROPOSED RULES  10862 Deportment of Transportation—. Assistant Secretary for Systems Development and Technology (auto emissions). Coast Guard (vessel emissions). Federal Aviation Administration (alrcralt emissions). Weather Modification  Department of Commerce— National Oceanic and Atmospheric Administration. 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 efficiency) . Department of Housing and Urban Development— 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 AgencyWater 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 Development (urban areas). Department of the Interior—(facilities on Government lands). National Aeronautics and Space Administration (solar). Water Resources Council. River Basins Commissions (as geographically appropriate). Natural Gas Energy Development, Transmission and Generation  Federal Power Commission (natural gas production, transmission and supply). Department of the Interior— Geological Survey. Bureau of Mines. HAZARDOUS SUBSTANCES  Toxic Materials  Atomic Energy Commission (radioactive substances) . Department of Commerce— National Oceanic and Atmospheric Administration. Department of Health, Education, and Welfare (Health aspects). Environmental Protection Agency: Department of Agriculture— Agricultural Research Service. Consumer and Marketing Service.. Department of Defense. Department of the InteriorBureau of Sport Fisheries and Wildlife. Pesticides  Department of Agriculture— Agricultural Research Service (biological controls, food and fiber production). Consumer and Marketing Service. Forest Service.,  Environmental Protection AgencyDepartment of CommerceWater Quality Office. National Marine Fisheries Service. National Oceanic and Atmospheric Admin- National Aeronautics and Space Administration (remote sensing). istration. Water Resources Council. Environmental Protection Agency— River Basin Commissions (as geographically Office of Pesticides. appropriate). Department of the Interior— Bureau of Sport Fisheries and Wildlife Historic and Archeological Sites (effects on fish and wildlife). Department of the Interior— Bureau of Land Management. National Park Service. Department of Health, Education, and WelAdvisory Council on Historic Preservation. fare (Health aspects). Department of Housing and Urban DevelopHerbicides ment (urban areas). Flood Plains and Watersheds Department of Agriculture— Agricultural Research Service. Department of Agriculture— Forest Service. Agricultural Stabilization and Research Environmental Protection Agency— Service. Office of Pesticides. Soli Conservation Service. Department of Health, Education, and WelForest Service. fare (Health aspects). Department of the Interior— Department of the Interior— Bureau of Outdoor Recreation. Bureau of Sport Fisheries and Wildlife. Bureau of Reclamation. Bureau of Land Management. Bureau of Sport Fisheries and Wildlife. Bureau of Reclamation. Bureau of Land Measurement. VS. Geological Survey. Transportation and Handling of Hazardous Department of Housing and Urban DevelopMaterials ment (urban areas). Department of Commerce— Department of DefenseMaritime Administration. Army Corps of Engineers. National Marine Fisheries Service. Water Resources Council. National Oceanic and Atmospheric Admin- River Basins Commissions (as geographically istration (impact on marine life). appropriate). Department of Defense— Mineral Land Reclamation Armed Services Explosive Safety Board. Army Corps of Engineers (navigable water- Appalachian Regional Commission. Department of Agriculture— ways) . Forest Service. Department of Health, Education, and WelDepartment of the Interior— fareBureau of Mines. Office of the Surgeon General (Health asBureau of Outdoor Recreation. pects). Bureau of Sport Fisheries and Wildlife. Department of Transportation— Bureau of Land Management. Federal Highway Administration. Bureau VS. Geological Survey. of Motor Carrier Safety. Tennessee Valley Authority. Coast Guard. Federal Railroad Administration. Parks, Forests, and Outdoor Recreation Federal Aviation Administration. Assistant Secretary for Systems Develop- Department of Agriculture— Forest Service. ment and Technology. Soil Conservation Service. Office of Hazardous Materials. Department of the InteriorOffice of Pipeline Safety. Bureau of Land Management. Environmental Protection Agency (hazardous National Park Service. substances). Bureau of Outdoor Recreation. Atomic Energy Commission (radioactive Bureau of Sport Fisheries and Wildlife. substances). Department of Defense— Army Corps of Engineers. LAND TJSK AND MANAGEMENT Department of Housing and Urban DevelopEsthetics' ment (urban areas). Water Resources Council. Coastal Areas: Wetlands, Estuaries, WaterRiver Basins Commissions (as geographically fowl Refuges, and Beaches appropriate). Department of Agriculture—• Soil and Plant Life, Sedimentation, Erosion Forest Service. and Hydrologic Conditions Department of Commerce— National Marine Fisheries Service (Impact Department of Agriculture— Soli Conservation Service. on marine life). Agricultural Research Service. National Oceanic and Atmospheric AdminForest Service. istration (Impact on marine life). Department of DefenseDepartment of Transportation.— Army Corps of Engineers (dredging, Coast Guard (bridges, navigation). aquatic plants). Department of Defense— Department of Commerce— Army Corps of Engineers (beaches, dredge National Oceanic and Atmospheric Adminand fill permits, Refuse Act permits). istration. Department of the Interior— Department of the Interior— Bureau of Sport Fisheries and Wildlife. Bureau of Land Management. National Park Service. Bureau of Sport Fisheries and. Wildlife. VS. Geological Survey (coastal geology). Geological Survey. Bureau of Outdoor Recreation (beaches). Bureau of Reclamation. Department of Agriculture— Water Resources Council. Boll Conservation Service (soli stability, River Basins commissions (as geographically appropriate). hydrology). NOISX • Numerous agencies have developed specific methods of assessing esthetics In relation to their area of responsibility.  Hoise Control and Abatement  Department of Health, Education, and Welfare (Health aspects).  FEDERAL REGISTER, VOL 33, NO. 34—WEDNESDAY, MAY 3, 1973  - 205 rKOPOSED RULES Department of CommerceNational Bureau of Standards. Department of Transportation— Assistant Secretary for Systems Development and Technology. Federal Aviation Administration (Office of Noise Abatement). Environmental Protection Agency (Office of Noise). Department of Housing and Urban Development (urban land use aspects, building materials standards). National Aeronautics and Space Administration (aircraft noise abatement and control). PHYSIOLOGICAL HEALTH AND H U M A N WELL BEING  Chemical Contamination of Food Products  Department of Agriculture— Consumer and Marketing Service. Department of Health, Education, and Welfare (health aspects). Environmental Protection Agency— Office of Pesticides (economic poisons). Food Additives and Food Sanitation  Department of Health. Education, and Welfare (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).  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 Administration (meteorological conditions). National Aeronautics and Space Administration (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 Administration (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 Development. Department of the Interior— Bureau of Outdoor Recreation.  Environmental Protection AgencyWater Quality Office. Department of Health, Education, and Welfare (Health aspects). Department of Defense— Army Corps of Engineers. Department of the Navy (ship pollution control). National Aeronautics and Space Administration (remote sensing). Department of Transportation— Coast Guard (oU spills, ship sanitation). Department of Commerce— National Oceanic and Atmospheric Administration Water Resources Council. River Basins Commissions (as geographically appropriate). Marine Pollution  Department of Commerce— National Oceanic and Atmospheric Administration. Department of Transportation— Coast Guard. Department of DefenseArmy 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— Enuironmental Effects With Special Impact Army Corps of Engineers. Department of Health, Education, and Welin Low-Income Neighborhoods Department of the Interior— fare (Health aspects). Bureau of Reclamation. Department of the Interior— Radiation and Radiological Health Geological Survey. National Park Service. Bureau of Sport Fisheries and WUdllfe. Department of Commerce— Office of Economic Opportunity. Department of Housing and Urban Develop- Department of Transportation— National Bureau of Standards. Coast Guard. ment (urban areas). Atomic Energy Commission. Department of Commerce (economic develop- Water Resources CouncU. Environmental Protection Agency— River Basins Commissions (as geographically ment areas). Office of Radiation. appropriate). Economic Development Administration. Department of the Interior— WILDLIFE Department of Transportation— Bureau of Mines (uranium mines). Urban Mass Transportation Administration. Environmental Protection Agency. Sanitation and Waste Systems Water Resources Council. Department of Agriculture— Atomic Energy Commission Forest Service. River Basins Commissions (as geographically (radioactive waste). SoU Conservation Service. appropriate). Department of Health, Education, and WelDepartment of the Interior*— Rodent Control fare—(Health aspects). Bureau of Sport Fisheries and Wildlife. Department of Defense— Department of Health, Education, and WelBureau of Land Management. fare (health aspects). Army Corps of Engineers. Bureau of Outdoor Recreation. Department of Housing and Urban Develop- . Water Resources CouncU. Environmental Protection Agency— ment (urban areas). Solid Waste Office. River Basins Commissions (as geographically Water Quality Office. appropriate). Urban Planning! Department of Transportation— FEDERAL AGENCY AND FEDERAL-STATE AGENCY Department of Transportation— U.S. Coast Guard (ship sanitation). Orncts FOR RECEIVING AND COORDINATING Federal Highway Administration. Department of the Interior— COMMENTS UPON ENVIRONMENTAL IMPACT Bureau of Mines (mineral waste and re- Department of Housing and Urban DevelopSTATEMENTS ment. cycling, mine acid wastes, urban solid wastes). Environmental Protection Agency. ADVISORY COUNCIL O N HISTORIC PRESERVATION Bureau of Land Management (solid wastes Department of the Interior— Office of the Executive Director, suite 618, Geological Survey. on public lands). 801 19th Street NW., Washington, D.C. Bureau of Outdoor Recreation. Office of Saline Water (demlnerallzatlon 20006, 343-8607. Department of Commerce— of liquid wastes). Economic Development Administration. Water Resources Council. DEPARTMENT OF AGRICULTURE River Basins Commissions (as geograph- Water Resources Council. Office of the Secretary, Washington, D.C. River Basins Commissions (as geographically ically appropriate). 20250. 447-7803. appropriate). Shellfish Sanitation Microbiological Contamination  WATER  Department of Commerce— Water Quality and Water Pollution Control National Marine Fisheries Service. National Oceanic and Atmospheric Admin- Department of Agricultureistration. Soil Conservation Service. Forest Service. Department of Health. Education, and WelAtomic Energy Commission (Radioactive fare (Health aspects). substances). Environmental Protection Agency— Department of the Interior— Office of Water Quality. Bureau of Reclamation. TRANSPORTATION Bureau of Land Management. Bureau of Sports Fisheries and Wildlife. Air Quality Bureau of Outdoor Recreation. Environmental Protection Agency— Geological Survey. Air Pollution Control Office. Office of Saline Water.  Ko. 84—Ft. II  2  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.  FEDERAL REGISTER, VOL. 38, NO. 84—WEDNESDAY, MAY 3, 1973  - 206 PROPOSED RULES  10864  OFFICE OF ECONOMIC O P P O l l O N l T l  GENERAL SERVICES ADMINISTRATION For regulatory matters: Office of the Assistant Director for Regulation, Washington, Office of Environmental Affairs, Office of the Office of the Director, 1200 19th Street NW, Washington. D.C. 20506, 254-6000. ' : D.O. 20546, 973-7531. Commissioner, Public Buildings Service, OHIO RIVER BASIN COMMISSION ' Washington. D.C. 20405, 343-4193. DEPARTMENT OF COMMERCE GREAT L A K E S BASIN COMMISSION Office of the Chairman, 36 East 4th Street, Office of the Deputy Assistant Secretary for suite 208-20, Cincinnati, Ohio 45303, 813Environmental Affairs, Washington, D.C. Office of the Chairman, 3475 Summit Road, 684-3831. 30330, 967-4335. Ann Arbor, Mich. 48106, 313-769-7431. DEPARTMENT OP DEFENSE  DEPARTMENT  OF H E A L T H , EDUCATION, AND WELFARE  PACIFIC NORTHWEST RIVER BASINS COMMISSION  Office of the Assistant Secretary for Defense (Health and Environment), Room 3E172, Office of Environmental Affairs, Office of the Office of the Chairman, l Columbia River, Vancouver, Wash. 98660. 206-695-3606. the Pentagon, Washington, D.C. 20301, Assistant Secretary for Community and 697-3111; Field Services, Washington, D.C. 20202, B0UBI3-RED-RAINY RIVER BASINS C O M M I S S I O N 963-5896. DELAWARE SZVEB BASIN COMMISSION Office of the Chairman, suite 6. Professional DEPARTMENT OP HOTTSINO AND OBBAN Building, Holiday Mall, Moprhead, Minn. Office of the Secretary, P.O. Box 360, Trenton, DEVELOPMENT 66560, 701-237-6227. NJ. 08603, 609-883-9600. DEPARTMENT O F R A T S Director, Office of Community and EnvironENVIRONMENTAL PROTECTION AGENCY * mental Standards, room 7206, Washington, Office of the Special Assistant to the SecDirector, Office of Federal Activities, Environ- D.C. 20410, 755-5977. retary for Environmental Affairs, Washingmental Protection Agency, 401 M Street DEPARTMENT OF T H E INTERIOR ton, D.C. 20520, 632-7964. NW., Washington, D.C. 20460, 755-0777. SUSQUEHANA RIVER BASIN C O M M I S S I O N Office of the Deputy Assistant Secretary for FEDERAL POWER COMMISSION Programs, .Washington, D.C. 20240, 343- Office of the Water Resources Coordinator, Commission's Advisor on Environmental 6181. Department of Environmental Resources, Quality, 441 O Street NW., Washington, 106 South Office, Building, Harrisburg, Pa. MISSOURI RIVER BASINS C O M M I S S I O N D.C. 20426, 386-6084. 17120. 717-787-2315. Office of the Chairman, 10050 Regency Cir-\ TENNESSEE VALLEY AUTHORITY » Contact the Office of Federal Activities for cle, Omaha, Nebr. 68114, 402-397-6714. I environmental statements concerning legislaOffice of the Director of Environmental ReNATIONAL CAPITAL P L A N N I N G C O M M I S S I O N tion, regulations, national program proposals search and Development, 720 Edney Buildor other major policy Issues. Office of the Executive Director, Washington, ing, Chattanooga, Tenn. 37401, 616-766For all other EPA consultation, contact the D.C. 20576, 3B2-1163. 3003. Regional Administrator ln whose area the N E W ENGLAND RIVER BASINS COMMISSION DEPARTMENT OF TRANSPORTATION proposed action (e.g., highway or water resource construction projects) will take place. Office of the Chairman, 55 Court Street, Bos- Office of the Assistant Secretary for EnvironThe Regional Administrators will coordinate ton, Mass. 02108. 617-223-6244. ment, Safety, and Consumer Affairs, Washthe EPA review. Addresses of the Regional ington, D.C. 30690, 426-4474. Administrators, and the areas covered by . contact the Director with regard to entheir regions are as follows: DEPARTMENT O F TREASURY Regional Administrator I, Room 2303, John vironmental impacts of legislation, policy F. Kennedy Federal Building, Boston, Mass. statements, program regulations and proce- Office of Assistant Secretary for Administration, Washington, D.C. 20220, 964-6391. 02203, 617-223-7210; Connecticut, Maine, dures, and precedent-making project deciMassachusetts, New Hampshire, Rhode Is- sions. For all other HUD consultation, conUPPER MISSISSIPPI RIVES BASIN COMMISSION tact the HUD Regional Administrator ln land, Vermont. Regional Administrator n, Room 908,26 Fed- whose Jurisdiction the project lies, aa fol- Office of the Chairman, Federal Office Building. Fort Snelllng. Twin Cities, Minn. 55111, eral Plaza, New York, N.Y. 10007, 212-264- lows: 613-735-4690. 3625; New Jersey, New York, Puerto Rico, Regional Administrator I, Environmental Virgin Islands. Clearance Officer, room 405, John F. KenWATER RESOURCES COUNCIL Regional Administrator IH, Curtis Building, nedy Federal Building, Boston, Mass. Office of the Associate Director, 3120 L Street Sixth Floor, Sixth and Walnut Streets, 02203, 617-223-4066. Philadelphia, Pa. 19106, 215-697-9801; Regional Administrator II, Environmental NW., suite 800. Washington, D.C. 30037, Delaware, Maryland, Pennsylvania, Vir254-6443. Clearance Officer, 26 Federal Plaza, New ginia, West Virginia, District of Columbia. York, N.Y. 10007, 212-264-8068. APPENDIX HI—STATE AND LOCAL AGENCY Regional Administrator IV, Suite 300, 1421 Regional Administrator III, Environmental REVIEW or IMPACT STATEMENTS Peachtree Street NE., Atlanta, Ga. 30309, Clearance Officer, Curtis Building, Sixth 404-526-5727; Alabama, Florida, Georgia, 1 . OBM Circular No. A-95 through Its sysand Walnut Streets, Philadelphia, Pa. Kentucky, Mississippi. North Carolina, tem of clearinghouses provides a means for 19106, 216-597-2560. South Carolina. Tennessee. Regional Administrator IV, Environmental securing the views of State and local enRegional Administrator V. 1 North Wacker Clearance Officer, Peachtree-Seventh Build- vironmental agencies, which can assist ln the Drive, Chicago, 111. 60606, 312-353-6250; preparation of Impact statements. Under ing, Atlanta, Ga. 30323, 404-626-5585. Illinois, Indiana, Michigan, Minnesota, Regional Administrator V, Environmental A-95, review of the proposed project ln the Ohio, Wisconsin. of federally assisted projects (part I of Clearance Officer, 360 North Michigan Ave- case Regional Administrator VI, 1600 Patterson A-S5) generally takes place prior to the prepnue, Chicago, III. 60601, 312-353-6680. Street, Suite 1100. Dallas. Tex. 75201, 214- Regional Administrator VI, Environmental aration of the Impact statement. Therefore, 749-1962; Arkansas. Louisiana, New Mexon the environmental - effects of Clearance Officer. Federal Office Building, comments ico, Texas, Oklahoma. the proposed project that are secured during 819 Taylor Street, Fort Worth. Tex. 76102. Regional Administrator VII, 1735 Baltimore this stage of the A-95 process represent In817-334-2867. Avenue, Kansas City. Mo. 64108. 816-374- Regional puts to thj environmental impact statement. Administrator VII, Environmental 6493; Iowa, Kansas, Missouri, Nebraska. 2. In the case of direct Federal developClearance Officer, 911 Walnut Street, Kan- ment Regional Administrator VLTI, Suite 900, Lin(part n of A-95), Federal agencies are sas City. Mo. 64108, 816-374-2661. coln Tower, 1860 Lincoln Street, Denver, required to consult with clearinghouses at Colo. 80203, 303-837-3895; Colorado, Mon- Regional Administrator VIH, Environmental the earliest practicable time ln the planning Clearance Officer, Samsonlte Building, 1051 of the project or activity. Where such contana, North Dakota, South Dakota, Utah, South Broadway, Denver, Colo. 80209, 303-sultation occurs prior to completion of the Wyoming. 837-4061. draft impact statement, comments relating Regional Administrator IX, 100 California Regional Administrator IX, Environmental to the environmental effects of the proposed Clearance Officer, 450 Golden Gate Avenue, action would also represent Inputs to the enStreet, San Francisco, Calif. 94111, 415P.O. Box 36003, San Francisco, Calif., 94102, vironmental Impact statement. 656-2320: Arizona, California. Hawaii, Nevada, American Samoa, Guam. Trust Ter- 416-656-4752. 3. In either case, whatever comments are Regional Administrator X, Environmental made on environmental effects of proposed ritories of Pacific Islands, Wake Island. Clearance Officer, room 226, Arcade Plaza Federal or federally assisted projects by clearRegional Administrator X, 1200 Sixth AveBuilding, Seattle. Wash. 98101, 206-583- inghouses, or by State and local environnue. Seattle, Wash. 98101, 206-442-1220; Alaska, Idaho. Oregon, Washington. 6415. 4  FEDERAl. IEOISTR. VOL 38, NO. 84—WEDNESDAY, MAY X 1W1  PROP  RULES  mental agencies through clearinghouses, In (c) [Use of existing mechanisms].—This the course of the A-95 review shoald be at.(b) This subsection provides a general tached to the draft impact statement when It Is former section 3(d), essentially unchanged. overview of the 102 process from draft 4. Federal agencies included; effect of Actthrough final, emphasizing again the Imporis circulated for review. Copies of the statement should be sent to the agencies making on existing agency mandates.—This section tance of early preparation pursuant to the such comments. Whether those agencies then adds additional language to former section policy of section 2. elect to comment again on the basis of the 4 to emphasize that NEPA expands the tra(c) The "lead agency" concept Is clarified draft Impact statement Is a matter to be left ditional mandates of agencies covered by here, and the desirability of Joint statements to the discretion of the commenting agency the Act—a view that is fully supported both is emphasized in accordance with Recomdepending on its resources, the significance by the legislative history of the Act, see, e.g.. mendation No. 8 of the May 16 memo, 3 ER of the project, and the extent to which its Hearings on S. 1075, S. 237, and S. 1752 Before86-87 (attached, app. A), and with similar earlier comments were considered in pre- Senate Committee on Interior and Insular recommendations made both by agencies and Affairs. 91st Cong., 1st Sess. 206 (1969); 115 paring the draft statement. Cong. Rec. (part 30) 40416 (1969) (remarks environmental organizations.' The section 4. The clearinghouses may also be used, by of Senator Jackson), and by early and con- also makes clear that where a "lead agency" mutual agreement, for securing reviews of sistent Judicial opinion. See, e.g., Calvert prepares the statement, input from other the draft environmental Impact statement. Cliffs v. AEC, 2 ERC 1779. 1780-81 (D.C. Cir. participating agencies should still be secured. However, the Federal agency may wisb to deal 1971); Zabel v. Tabb, 1 ERC 1449, 1457-59 Finally, additional factors relevant to selecdirectly with appropriate State or local agen- (5th Cir. 1970). tion oi a lead agency are specified. cies in the review of impact statements be(d) This subsection responds to the deci5. Actions included.—The nonapplicabllity sion cause the clearinghouses may be unwilling or in Greene County Planning Board V. unable to handle this phase of the process. of the Impact statement process to general FPC. 3 ERC 1595 (2d Cir.. 1972). prohibiting In some cases, the Governor may have des- revenue sharing is confirmed. the use of applicant EIS's. Someflexibilityis The former section 5(d) of the CEQ guide- preserved, ignated a specific agency, other than the however, to permit the use (after clearinghouse, for securing reviews of Im- lines, exempting all of EPA's environmental review) of Initial information furnished by pact statements. In any case, the clearing- protective regulatory activities from the re- an applicant In the form of an EIS. houses should be sent copies of the impact quirements of section 102(2) (C), has been (e) This Is a revision and codification of deleted In recognition of the fact that new statement. section 511(c) of the Federal Water Pollu- what appears in sections 6(d) and 10(e) of 6. To aid clearinghouses In coordinating tion Control Act Amendments of 1972 now the existing guidelines, with some additional State and local comments, draft statements specifically addresses this Issue, requiring general guidance about when to hold hearshould include copies of State and local EPA to prepare impact statements In some ings. Agencies are also asked to identify In agency comments made earlier under the A- cases, and exempting EPA from the require- their procedures contexts in which hearings 95 process and should Indicate on the sum- ment in other cases. This general matter will are normally held as part of the review procmary sheet those other agencies from which be addressed In EPA's NEPA procedures is- ess. The final clause of the former section comments have been requested, as specified sued pursuant to section 3(a) of these guide- 10(|e) has, been deleted In response to the in appendix I of the CEQ guidelines. decision in Greene County, supra. lines. 8. Content of EIS's. (a) The points to be SXCTIOM-BT-SECTION C O M M E N T AND EXPLANA6. Identifying "major," environmentally covered have been reorganized and new lan"significant" actions.—This new section com- guage has TION or MAJOR PROPOSED REVISIONS been added: (1) Emphasizing the bines parts of the existing guidelines with 1. Purpose and authority.—This section need for a comprehensive but comprehensible remains basically unchanged, except for new directives for interpreting and applying description of the proposed action and the minor stylistic revisions and expanded refer- these key words of the Act. existing environment and for accurate pop(a) General guidance from previous sec- ulation data. Identified by source, in making ence In subsection (a) (purpose) to national goals described In section 2 of NEPA. In addi- tion 5(b) is Included here about the statu- assessments of population Impact; (2) Illustion a new subsection (b) has been added tory criteria for determining when an EIS trating the range of environmental values making explicit the basis of the Council's is required. (The discussion of the "lead which agencies should keep in mind in evalagency" concept has been moved to the folrole tn the NEPA process. uating proposals, and indicating that the efThe former reference to EPA's Implementa- lowing section (sec. 7(c)).) on the international environment Is (b) More specific guidance is included here fect tion of section 309 of the Clean Air Act Is also to be assessed where relevant; and (3) concerning factors to consider in assessing replaced with a more general reference to all discussing the kinds of secondary effects to commenting entitles in order to reflect more "significance." Specific cross-reference iswhich agencies should be alert In making accurately the matters covered by the new made to appendix II which contains a list environmental assessments. of typical kinds of environmental impact directive. Additional language in the discussion of 2. Policy.—This section reenforces the to consider in making this assessment In- alternatives (sec. 8(a) (ill),) reflects the deformer emphasis on early consideration of cluding a new reference to "energy conser- cision in XRDC v. Morton, 3 ERC 1558 (D.C. environmental Issues in agency planning, and vation." Cir. 1972) and Recommendation No. 4 In the (c) This subsection Indicates that each CEQ explains In general terms the function of May 16 memo. 3 ER 83-84. the environmental Impact statement process agency should supplement the general CEQ (b) This subsection emphasizes the imm meeting this objective. The emphasis on criteria with specific criteria, and review its portance of substance over form in the conearly preparation of statements accords with typical actions to determine those that will the directive In section 102(2) (C) of the Act require statements and those that will not. tent of EIS's. and stresses the primary EIS function of serving as a full disclosure docuthat such statements "accompany the pro- With respect to remaining actions and acposal through the existing agency review tions likely to require statements, agencies ment. The reference to incorporation of unprocess." It also accords with results of re- are to develop guidance, indicating for par- derlying documents is from Recommendation view sessions held last July by the Council ticular kinds of projects how environmental No. 6 of the May 16 memo, 3 ER 86. (c) This is former section 6(c), with adwith major Federal agencies following issu- Impact is to be determined. The emphasis ance of the GAO Report on Improvements on agency responsibility to develop such cri- ditional language clarifying the act's referNeeded in Federal Efforts to Implement teria for making environmental assessments ence to use of an "interdisciplinary" NEPA. , accords with longstanding CEQ policy and approach. 9. Review of draft EIS's.—(a) Review by with provisions contained in recommenda3. Agency and OMB Procedures.—(a) (Re- tion No. 1 of the CEQ's memorandum of Federal agencies is discussed here, incorpoquirement for Agency Procedures],—This May 16. 1972. See 3 Environmental Reporter rating parts of former section 7 with minor subsection reaffirms the previous direction 83 ("Current Developments," May 19. 1972). revisions, and adding a discussion of the reto agencies to develop their own NEPA procelationship of section 102(2) (C) to other (d) This subsection emphasizes the use- Federal dures and requires further revision as necesstatutes requiring consultation and sary to reflect new changes in the CEQ guide- fulness and desirability of program or over- coordination. The deletion of the clause In lines. New provisions also require agencies to view statements. In accord with recommenda- the first sentence of former section 7 Is reconsult with CEQ In developing or revising tion No. 9 of the CEQ May 16 memo, 3 ER sponsive to the decision in Greene County, procedures and to notice significant proposed 87. supra. The list of relevant commenting agen7. Procedures for preparing draft EIS's.— revisions for public comment. This is a new section, discussing procedural cies has been moved to the appendix. (b) This subsection relates EPA review of (b) {Consultation with other agencies].— aspects of preparing draft statements. This subsection retains the previous recomunder section 309 of the Clean Air (a) Because the decision whether or not EIS's mendation for consultation with other agenAct to the EIS process generally and requires cies in developing or revising NEPA pro- to prepare an impact statement is a crucial prompt notification of the Council where cedures and incorporates and clarifies the point In the 102 process, this subsection adds statements are rated Inadequate or projects previous reference (former sec. 3(c)) to new provisions for making public the decision are determined to be environmentally OMB Circular A-85 as the means tea ob- when it Is made. The "notice of Intent" de- unsatisfactory. taining State and local review of such pro(c) Procedures for securing State and local vice was previously recommended In the cedures. review are referenced here to the recent Joint May 16 memo (see Rec. No. S, 3 ER 85-86). CEQ-OMB memorandum. This joint memo-  mUAL  REGISTER, VOL 38, NO. 84—WEDNESDAY, MAY », 1973  - 208 r K U r - U S E D RULES (b) Former section 10(c). provisions concerning number of copies to 13. Application to existing projects and file with CEQ and waiting periods prior to action. Additional language at the end of programs.—This section has been slightly subsection (b) draws attention to the pos- revised to make clear that the act applies to sibility of amending and recirculating state- major actions yet to be taken on environments, as further discussed ln the Council's mentally significant projects, even though "Third Annual Report," chapter 7, pages such projects were begun prior to passage of the act. This view ls now supported by over238-239. (c) This subsection indicates how time pe- whelming Judicial precedent, see, e.g., Jicariods are to be calculated. The periods for rilla Apache Tribe v. Morton, 4 ERC 1933 (9th review and advance availability of statements Cir., Jan. 2, 1973); EDF v. TV A, 4 ERC 1850 run from the date of receipt of the EIS by (6th Clr., Dec. 13, 1972) (Tellico Dam case), CEQ, as per Recommendation No. 7 of the and is consistent with the Intent of the former section 11 of the CEQ guidelines. May 16 memo, 3 ER 86. 14. Supplementary guidelines and evalua(d) , (e) Substantially unchanged. (f) This subsection describes ln general tions.—This section ls former section 12, terms the Council's role ln the EIS process, with a new sentence ln subsection (b) reIncluding the Council's authority to require quiring agencies to report on their progress agencies to prepare either an EIS or. If the ln developing substantive guidance for mak10. Preparation and circulation of final responsible agency has determined an EIS ing environmental assessments. statements.—(a), (b) These subsections In- ls not required, a publicly available record 15. Effective date.—The amended guidecorporate Recommendation No. 3 of the of the reasons for that determination. lines will apply to all draft and final Im12. Legislative actions.—(a) This general May 16 memo, 3 ER 84-85. language concerning application of section pact statements filed with the CouncU more 11. Distribution of statements; minimum 102 ln the legislative process corresponds to than 90 days after the publication of the periods for review and advance availability.— agreements reached between CEQ and OMB revised guidelines ln final form. (a), (b) These subsections Include relevant last fall after the July agency review sessions [FR Doc.73-8576 Filed 5-1-73;8:45 am] portions of former section 10(b). retaining to followup the QAO report.  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 replaces former section 9 of the guidelines. (d) A new subsection ls added discussing arrangements for securing public review of statements. The discussion reflects Recommendation No. 7 of the May 16 memo, 3 ER 86. (e) This subsection ls new, providing general guidance for commenting entitles. (f) The time limits for review have been expanded to 45 days for all commenting entities. 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.  1  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 Hills  (from Belknap and Furtado, 1967)  - 211 -  O U T L I N E OF ANALYSIS PROCEDURE:  A.  Given a Total Site  G. Angus H i l l s  .7 ,  The total site for analysis is subdivided into smaller units of physiographic 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 landform, geologic composition and water content within the site region. (Watertypes are not classified here. )  3. Physiographic site classes, by isolating areas within the landtypes on the basis of local climate consideration. 4. Physiographic site types, by differentiation of micro-landform variation within the site classes.  B.  C.  A Possible Range of General Land Uses is Determined and P h y s i c a l Requirements for Each are Identified 1.  Specific land-use activities appropriate to each of the general use categories (Agriculture, Wildlife, F o r e s t r y and Recreation) 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.  Use Potential is Ranked at Two A r e a Levels, Under Various Management Conditions, and Using Separate "Value Scales 1.  A t the L o c a l 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  DIAGRAMMATIC OUTLINE OF ANALYSIS  TOTAL  USE.CAPABILITIES USE SUITABILITY  SITE  CUD UM3  LXn LXO  UED  HUMEl jjll  LTD LTT] rrm  jiji  PROCEDURE  - 213 -  2.  D.  a.  Use Capability, ranked on an A-to-G scale of seven values based on the inherent potential at the highest observed l e v e l of physiographic production under optimum management conditions.  b.  Use Suitability, o r the degree to which a unit, i n i t s p r e s ent condition, can respond to specific management practices.  c.  Use F e a s i b i l i t y , the present l i k e l i h o o d o r potential of a unit for development under specified socio-economic conditions.  A t the Community Level: P a t t e r n s of site types and phases with s i m i l a r l a n d f o r m c h a r a c t e r i s t i c s a r e regrouped into landscape units (16-square-mile minimum) and land units (a portion of a landscape unit with s p e c i a l significance for some s p e c i f i c use) to provide a basis f o r comparative evaluation of feasible uses. The following are again ranked before making a r e c o m mendation: a.  Use Capability, s i m i l a r to C. 1. a. , but on a l-to-7 scale.  b.  U s e Suitability: see C. l . b .  c.  Use F e a s i b i l i t y : see C. 1. c.  Recommended Use The land-use activity with the highest f e a s i b i l i t y ranking i n a landscape unit i s recommended as a m a j o r or co-major use.  E.  M u l t i p l e - U s e Regions Maps are prepared showing recommended multiple m a j o r and com a j o r uses f o r each landscape unit.  -214  -  TABLE 2  C r i t e r i a Developed By McHarg (1969) To Evaluate The S u i t a b i l i t y Of Land For Different Uses  - 215 -  ECOLOGICAL FACTOR  RANKING CRITERIA  PHENOMENA RANK I II  VALUE FOR LAND USE C | P| A| R I I  III  CLIMATE AIR POLLUTION  INCIDENCE mm  MAX m  TIDAL INUNDATION  INCIDENCE MAX •» u m  FtoaMJna  GEOLOGY FEATURES OF UNIQUE. SCIENTIFIC AND EDUCATIONAL VALUE  SCARCITY MAX  •» MIN  2 Buriad VaHaya 3 O n Pin  2 Unit of GUaation  4 Graaeinti  3 lnu>t» Tnal FOUNDATION CONDITIONS  MAX m  COMPRESSIVE STRENGTH mn  1 Sarpanuna J Oi  FEATURES OF UNIQUE. SCIENTIFIC AND EDUCATIONAL VALUE  SCARCITY MAX • HI*  fclnWaj— within Outliar  LAND FEATURES OF SCENIC VALUE  DISTINCTIVE MOST » LEAST  WATER FEATURES OF SCENIC VALUE  DISTINCTIVE MOST » LEAST  RIPARIAN LANDS OF WATER FEATURES  MOST  SMa  UMiMSaa*  PHYSIOGRAPHY • Shore Sarpantina Ridaa Beadl  1 ThaR 2 Kin Van KuO 3 Arthur KU  VULNERABILITY a»  1 ThtNaman 2 Kill Van Hull 2 Arflw Kin  LEAST  BEACHES ALONG THE BAY  VULNERABILITY MOST e» LEAST  SURFACE DRAINAGE  PROPORTION OF SURFACE WATER TO LAND A R E A MOST e» UAST  SLOPE  Rioie  Martian* •rsearn/ewaar  GRADIENT HIGH a» LOW  S-2**  r*-c%  HYDROLOGY  MARINE Commercial Craft Ptossurv Craft  NAVIGABLE CHANNELS DEEPEST e» SHALLOWEST FREE EXPANSE OF WATER LARGEST » SMALLEST  FRESH WATER Active recreation (swimming. EXPANSE OF WATER paddling, model-boat sailing. LARGEST *> SMALLEST ate.)  The RanunBa,  Freeh K a  Tl.  1 OhrbacfiLaka 4 I 5 1  Stream-sice recreation (fishing, trails, etcl  SCENIC MOST •> UAST  WATERSHEDS FOR STREAM SCENIC STREAMS QUALITY PROTECTION MOST e» LEAST AQUIFERS  YIELD HIGHEST V LOWEST  AQUIFER RECHARGE ZONES  IMPORTANT AQUIFERS MOST a> LEAST  rtanurbarund intermittent  SamMrbantzsd  LMaximl  Nonurbanued tntenninant  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  PEDOLOGY  SOIL DRAINAGE  RANKING CRITERIA  EROSION  III  IV  VALUE FOR LAND USE Cl P I A I R I I  PERMEABILITY AS INDICATED BY THE HEIGHT OF WATER TABLE MOST  FOUNDATION CONDITIONS  PHENOMENA RANK I II  a. LEAST  COMPRESSV IE STRENGTH ANO STABILITY  MOST  a.  Grandly tt  LEAST  SUSCEPTIBILITY  GnMadyanJ or silt loams  Grtyatty andy to fint  t Sandy lam 1 AHuvajfll 2 Gram 2 Swamp Muck 3 Saachaanck 1 Tidal n  an StocanI0-2H%) Othara 12%-lOVon on a/anrily land I Grevauyssnd orsrtt kaaii or sill kuma 1 OtMh/B  MOST. •» LEAST  VEGETATION  EXISTING FOREST FOREST TYPE EXISTING MARSHES  WILDLIFE  EXISTING HABITATS INTERTIDAL SPECIES WATERA - SSOCIATED SPECIES FIELD AND FOREST SPECIES  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 URBANZ IED URBANZ IED FOREST QUALITY BEST » POOR EST  URBANR - ELATED SPECIES PRESENCE OF TREES ABUNDANT  a» A B S E N T  LAND USE  I PORTANCE FEATURES OF UNIQUE. M MOST t» L EAST EDUCATIONAL. AND HISTORICAL VALUE FEATURES OF SCENIC DISTINCTIVE VALUE MOST a> LEAST  Tha Voi Bnkja  EXISTING AND POTENTIAL AVAILABILITY RECREATION RESOURCES MOST a. LEAST  1 axrjdraj pubiieopi  1 AmboyRoad Araawrth 2 TottanvHIa atxindanca ConfSfinof ' of landmarks  2 E»aa*aj  C:CONSERVATION; P:PASSIVE RECREATION; A:ACTIVE RECREATION; R:RESIDENTIAL DEVELOPMENT; ^COMMERCIAL & 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 oftfteproject) Pos*«tie*tte^*«ca»W « stage of.  Poesntial SlfnlBcanct' rt Stage ofi Category b. Tax Beat 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 H I attaratlon  12)  Interaction with turfact drainage  b. Surface Watar (1)  Shoreline and bottom attaratlon  (21  Effects of fMing and dredging  13)  Oralnaga and flood CTwatTteristlca  e. Quality aspects 11) 12)  Effect of affluent loadings Implication of other actions auch a* • disturbance of benthic layers • alteration of currents • changes in flow regime • saline intrusion In ground water  4.  |3)  Land use  Ml  Public health  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 which couWoerjrjeWv«aawet}aanag  (3)  In region  1. "x" denotes an Impoce  (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) (2) (3) (4)  Cultural resources Scientific resouron Historic resources Recreation areas  b. Life style and activities (1) (2)  Increased mobility 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  - 220 -  FIGURE 1  An Example Of One Of The Networks Or Stepped Matrices Developed By Sorensen (1971)  A] M A T R I X  RESIDENTIAL, C O M M E R C I A L , AGRICULTURAL.  USES :<ESIDEN'TIAL COMMERCIAL CROP  DEVELOPMENT SERVICES  FARMS  RA.NCKINC AND DAIRY INC FORESTRY.  POSSIBLE  ADVERSE  IMPACT  i  CONSEQUENT  CORRECTIVE CONDITION  EFFECT  6 ) CONTROL  a  or MECHANISMS  REFERENCES  101.1  I d r N M l 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  101.2.1  Mdwca M i l a n * 1* aat«nntna taatan.  •i«U».  101.J.)  l a c r M i t . rr«qo*m<7 . t l u af Ha«-aa.  101.1.4  laicraaMa I S N ( 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 M i t a a a a t 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..  101.1.1.1 — 101.1.1.1  l*tf*fll d t f f  i t f M l . r u a aiUMlaa.  A 130.1 Itparll caatta (la*! alala a * ^ l o a - « . 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 r n l . t l a * lata <tr l«a*U. a J'0.1  102.2.4.1  rtova i W L m i i t l a a aaa) a boal lata afatraa*.  7  101.2.4.1 102.1.1.1  Mit latraatatm af rraaawatar atjatfata. Piaaatle* af aMl If las. a**,,  101.1.«.l  to..** atatlt ara-aWtltlt*. lavMi af •»*< Ira.  tataWaall  ACTION  INDEX  - 222 -  FIGURE 2  A Stepped Matrix Used As A Summary Of An Environmental Impact Statement  (from Daniel, Mann, Johnson and Mendenhall, 1972)  CAUSAL  FACTORS  F i g u r e 7 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  *• *  I "DIM Of IRHNKTIQa  I M P A C T •OSIt|« IWttT  M A T R I X  o  u  u  (MDC ft RHINtD 1->ACI  FRUIT/CHURCH INDUSTRIAL PARK  iwusm lourm ON >iiis..-.?yB*L 4.  m-1 rcraiUoa 'J^^.  ALTERED  fKMAKIV PF CHARM  ELEMENTS  •ttTIICRl t av I B0!T'[ MT  sot i  f •nruultwril  -i'uqr«dini| of indtrttnil -Wind rroilon 'ubiurfaca Nat*r  adj*c**t Land lit*  •Reduced InMltritloA dut to Impcmtiblc lurfact,  l i t t l e chirnir  •InduMriil dt>• Ioniant  -L«detrrT.irw/«) o t l l « b l 11ty of-unit io. I itroHatarvd ooinola uporttjing of •djtcfit urban cnanctar • Incrxtad truck traffic  - h i r c ^ H w i l t l*<rrl  *JBtaltr OralMH aiwj Irriiattao  - Incrtiad runoff -Bettor runoff control •Full ttr.it* (.ptdn It*  Hllllty Facltttlw Trantporutioa Sritatn  -Conitrwctiot) traffic -I»«r»ii»d traffic f lo* -attraction of aava I ocaailt  | SOtlO-EroajHK IWlMWffHT C*vU-a»nt Oopertiwltlat  « - > I U i *ad lafati  -IntrMttd milovnrnt by n U t l n a Iftdaltry-, attraction of n n aafiloiart  -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 M a t r i x Proposed F o r I d e n t i f y i n g And E v a l u a t i n g The E n v i r o n m e n t a l Impact Of A P r o s p e c t i v e Action  (from L e o p o l d , e t . a l . , 1971)  - 227 -  {FIGURE 2  An Energy Network Diagram Of A g r i c u l t u r e In Florida  Cfrom Lugo, Odum, e t . a l , 1971)  - 229 -  FIGURE 3  An E x p l a n a t i o n Of Some Symbols Used I n Energy Network Diagrams  (from Lugo, Odum, e t . . a l . , 1971)  - 230 -  The Energy Language In