NPS Director's Order 12: Conservation Planning, Environmental Impact Analysis and Decision Making Back to EQD
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White Sands National Monument, NM2.4 Overview of the NEPA Process — Connected, Cumulative, and Similar Actions

When analyzing the proposal and alternatives, you must consider actions that result as a direct or indirect consequence — that is, connected, similar, and cumulative actions. These actions should be incorporated into the description of the proposal and alternatives if relevant.

A. Connected actions (1508.25)

Connected actions are those that are “closely related” to the proposal and alternatives. Connected actions automatically trigger other actions, they cannot or will not proceed unless other actions have been taken previously or simultaneously, or they are interdependent parts of a larger action and depend on the larger action for their justification. For instance, if your park proposes building housing for rangers on an existing trailhead parking lot, and the trailhead lot must be relocated as a result, this is an action connected to the proposal of building the housing. The impacts of removing the existing parking lot, relocating the lot, and reducing visitor access to the trailhead must be analyzed in the same NEPA document as the housing.

B. Similar actions (1508.25 (a)(3))

Similar actions are those that have similar geography, timing, purpose, or any other feature that provides a basis for evaluating their combined impacts in a single NEPA document. They can be the same as connected or cumulative actions. As an example, if in the future you intend to build a restaurant in association with the lodge on the north rim of the Grand Canyon, the restaurant and any parking, fencing, utilities, and so forth that are connected with it would be a similar action, which should be analyzed in the same NEPA document as the lodge itself.

C. Cumulative actions (1508.7, 1508.25 (a)(2))

Wild horses at Assateague Island National Seashore, VA and MDCumulative actions are those that have additive impacts on a particular environmental resource. It is irrelevant who takes these actions (i.e., they are not confined to NPS or even federal activities), or whether they took place in the past, are taking place in the present, or will take place in the reasonably foreseeable future. As an example, if your park is proposing building a small sewage treatment plant and discharging treated wastewater into a river, other activities (i.e., cumulative actions) that also have an additive impact on the river must be included in the analysis on water quality. These activities might include disposal of wastes from recreational vehicles in the park, cattle ranching upstream of the park on public land, or release of water from a reservoir on private property downstream of the park. If you are preparing a GMP or other broad-scale plan, actions on land adjacent to, or even in the region of, the park unit may have combined impacts on resources inside the park boundaries and need to be included in the cumulative impact analysis. One source of information about methods to analyze cumulative impacts is the CEQ’s January 1997 report, “Considering Cumulative Effects under the National Environmental Policy Act.”

Further Links:

Guidance and Cumulative Effects

Sierra Club vs. Babbitt, Stanton, Reynolds, and Albright — Lessons Learned: General Descriptions, Cumulative Impacts, and Changed Conditions

Cumulative Effects Analysis

Considering Cumulative Effects Under the National Environmental Policy Act

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