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Chapter 2 of this handbook is
focused on the analysis process. Chapters 3 through 5 deal with documentation
of the analysis.
CEQ does not mandate a particular
analysis process. However, because NEPA is meant to be part of planning
and thus should be applied early, you should carefully consider beginning
NEPA when your park is framing its purpose or goals for a particular proposal.
Over the years, there has been much confusion in the park service concerning
the use of the terms "proposed action" and "preferred alternative." The
majority of actions in the park service involving NEPA do not have a specific
or even conceptual "proposed action" from the onset of the process. In
fact, it can be dangerous to start into a NEPA process with a solidified
proposal that precludes consideration and equal treatment of other reasonable
alternatives.
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 Typically
in the park service, purpose and need as well as objectives can be defined,
and from there, a range of alternatives developed, one of which becomes
“preferred” at the conclusion of the analysis process. This “preferred
alternative” is then identified in the EA or EIS before it is released
to the public for review and comment. In these situations, it is not necessary
to use the term “proposed action” since what the park is proposing
to do is essentially synonymous with the term “preferred alternative.”
An exception to this might be when a park is analyzing a “proposal”
or “proposed action” from an external applicant or “project
proponent.” For example, a park receives a “proposed action”
from an applicant desiring to develop a mining claim. The park responds
to the applicant’s proposed action by developing a range of alternatives
to mitigate impacts of the applicant’s proposal. In this case, the
applicant’s “proposed action” may be very different from
the park’s preferred alternative. In either case, a simplified version
of a typical analysis process is as follows:
- The best way to
begin is by clearly stating your park’s need for action. Need is
the proper framing of the question “why take action?” It is
a “because” statement and should include a statement of problems
the park is trying to solve, opportunities it is about to take advantage
of, and so forth.
- The next step is
to establish the purpose and objectives, or goals the park must accomplish
by taking action for the action to be considered a success. The objectives
and goals, or purpose, of the action are different from the purpose
of the park. They are the reasons for proposing action.
- When you have identified
what your park hopes to accomplish, the next step is to develop a proposal.
CEQ defines “a proposal” as the stage where a park has defined
goals and is actively pursuing different means of accomplishing its
goals (1508.23). If there is no one “proposal” in mind to
meeting goals and objectives, the park may keep the proposal general,
such as “NPS proposes to provide visitors an extended experience
at the north rim.” The next step would be to create a range of
alternatives (see step 5 below) that are consistent with the proposal,
for instance, building a lodge, renovating cabins in the park, subsidizing
overnight accommodations in the local town, etc. As a note, the decision-maker
or designee is required to identify a “preferred alternative”
(see sections 4.5 E (8) and
5.4 (D)) before an EA or EIS
is released for public review. This is the alternative the park service
believes would best accomplish its goals after the in-house NEPA analysis
has been completed, when the choice of an alternative as “preferred”
is appropriate.
- The next step is
to use the interdisciplinary team (IDT) approach to identify issues
or environmental problems that need to be addressed to reach park goals
and objectives and resolve need for action. This step is often the beginning
of internal scoping (section 2.6),
and it should involve a site visit (or familiarity of team members with
the site) and discussions with appropriate agencies. The Environmental
Screening Form (ESF; appendix 1)
may serve as a guide in determining affected resources. These may later
be supplemented with input from public scoping (sections
4.8 and 5.5). The IDT should
pay particular attention to focusing the issues; in other words, what
specifically may affect a resource, and what about the resource might
be affected. These specifics will form the basis for your impact topics.
If your proposal is general, such as “providing an extended experience
on the north rim,” the issues may also be more generalized. An
example would be “providing an extended experience for visitors
may require infrastructure that could eliminate habitat and disturb
archeological sites.”
- If the issues
show that the proposal would likely result in environmental impacts,
the team should create a set of reasonable alternatives that mitigate
or eliminate these problems, but that still fulfill the stated purpose
and resolve need — for example, “create a campground, renovate
existing cabins, subsidize hotels in town.” The alternatives themselves
may create environmental problems, which the team will need to correct
by adding mitigation or refining the alternatives, or to identify as
unresolved issues in the NEPA document.
- The team should
then identify data that it has and will need to describe the affected
environment and predict impacts of all alternatives. If you start collecting
data before you know your purpose and need, issues, and potential alternatives,
you might be spending time needlessly collecting irrelevant information.
- Using these data,
the team predicts impacts of each action in each alternative on those
specific environmental resources identified as impact topics. For those
resources that may experience a discernible impact, the team uses the
best available methods to predict the extent of the effect. This prediction
includes a discussion of context, intensity (e.g., degree), duration,
and timing (e.g., short-term vs. long-term), and a conclusion by the
park staff and other experts of the relative severity of the impact
(minor, moderate, or major).
This process may be modified to fit your park’s particular need,
and it should include agency and public involvement in identifying and
reviewing the documentation of issues, alternatives, and the extent of
impact. Also, some steps will be unnecessary if no potential for environmental
impact exists and the process outlined in section
3.2 applies.
Further Links:
See
10 Steps, NPS NEPA Analysis Process
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2.1
Overview of the NEPA Process — The Analysis Process