NPS Director's Order 12: Conservation Planning, Environmental Impact Analysis and Decision Making
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Arlington House, the Robert E. Lee Memorial, VA5.4 Environmental Assessments — Format and Content of an EA

Although CEQ does not require a particular format for EAs, the format of an NPS EA should be similar to that of an EIS. There are some differences between NPS EAs and EISs, however. For instance, EAs do not require a separate affected environment section, although the baseline information needed to compare impacts must appear somewhere in the EA. Also, unless the EA is more than 50 pages, a summary, an abstract, and a table of contents are not needed. Following is the suggested format for an EA. Many of the sections also detail required content, and they should be read carefully. More detail on the suggested contents and organization of each chapter is presented in the EIS format section 4.5 of this handbook.

A. Abstract or summary

If the EA is longer than 50 pages, a one- to two-page summary of important issues and major findings may be appropriate. The summary should stand alone; the reader should not need to read the entire EA to understand the conclusions outlined in it. See section 4.5 of this handbook for more information about summaries.

B. Table of contents

If an EA is longer than 50 or so pages, it must include a table of contents following the summary.

C. Purpose and need

Sections 2.2 and 4.5 (d) should be consulted in preparing the purpose and need sections of an EA. Usually the first chapter or section of an EA is titled either Purpose and Need or Introduction. This section may also be an appropriate place to discuss issues that were dismissed and issues that were kept for analysis and led to impact topics.

Campground at Hawaii Volcanoes National ParkD. Alternatives

EAs must fully describe the proposal (general or specific), no action, and a range of reasonable alternatives that meet objectives as laid out in the purpose section, and that reduce or eliminate impacts to important environmental resources. If your park has a preferred alternative at the time an EA is released for public review, it should be identified.

  1. Range of Alternatives — Normally, an EA should fully analyze a range of reasonable alternatives (see section 4.5 (e)). However, if the IDT finds that no reasonable alternatives exist and that the proposal does not have the potential for significant impacts, the EA may instead include a discussion of alternatives considered but rejected, and the reasons why these were rejected. In this case, the EA would analyze only the no action alternative and the park's proposal.

  2. Defining the range of alternatives — If the range of alternatives is quite narrow because objectives have been defined narrowly, the IDT may wish to take a second look at the objectives and whatever led the team to define the objectives (a park plan, for instance). For example, if the EA is examining different building materials, colors, and styles for a proposed visitor center because the GMP or another plan has stated that any buildings in the park must blend with the natural environment, but the location of the visitor center is a poor one, the team should re-examine the project purpose, the need for the project, and the plan itself. Often GMPs and other plans, or their accompanying NEPA documents, are outdated or are the result of reconnaissance data that, upon site-specific analysis, may turn out to be incorrect or too generalized to be useful. Although the GMP may dictate a visitor center location, if the team finds the location infeasible for technical, economic, or environmental reasons, the EA should examine other sites as alternatives, rather than a narrow range of building materials. Although a modification to the GMP would be required in this example, this kind of constant monitoring and updating of park plans leads to the excellent decision-making that NEPA requires and to the conservation of resources that the NPS Organic Act mandates.

  3. Comparative summaries — To facilitate review, EAs should include comparative summaries of impacts, features of alternatives, and a discussion of the degree to which each alternative accomplishes the purpose or fulfills the need identified in the purpose and need section.

  4. Costs and benefits — If a cost-benefit or other economic report has been completed, and relative costs and benefits of alternatives will be used in making decisions between alternatives in an EA, relevant information should be summarized in the EA or the cost-benefit analysis should be attached as an appendix.

  5. No action alternative — The impacts of the no action alternative are important for comparison purposes, and must be part of any NPS EA. For additional information on how to analyze the impacts of no action, see section 2.7 (c).

  6. Environmentally preferable alternative — See section 2.7.

E. Affected environment

Information about the existing environment relevant to understanding the impact of the proposal, no action, or other alternatives must appear in an EA (see section 2.8).

Wood stork, Everglades National Park, FLF. Impacts

Like an EIS, an EA is focused on “real” environmental issues, it is concise and clear, and it is meant to be a useful tool to decision-makers and the public. Also like an EIS, the analysis in an EA must discuss direct, indirect, and cumulative impacts (see section 2.9). Beneficial impacts should also be analyzed. Also, as in an EIS, the context, duration, and intensity of impacts should be defined and quantified as much as possible (see section 4.5 (g)).

  1. Objectivity (also see section 2.9) — An EA that results in the issuance of a FONSI must provide adequate support for the statement that no significant impacts are likely if the proposal or any alternative is implemented. Therefore the objective and accurate presentation of data is particularly important, as is the interpretation of those data in all appropriate contexts (see below). Court battles on EAs have been lost on the basis that the EA included undocumented information, that methods or data were controversial, or that the EA depended on mitigation to reduce impacts to below a “significance” threshold.

  2. Context (also see 4.2(a)) — CEQ says that one reason EAs are prepared is to determine whether the potential for significant impact exists. If the potential for significant impact exists, an EIS is the more appropriate NEPA document (see section 5.1). Significance is often a relative term, so the context, duration, and intensity of impacts must be measured and compared to impacts of ongoing activities (such as the impact of no action). Without these comparisons, it is difficult or impossible to determine the significance of impact.

  3. Mitigation — An environmental assessment is a valuable planning tool in designing a project or proposal with minimal adverse effects to resources. Mitigation should be included as part of the proposal and alternatives and be analyzed in terms of its effectiveness. See section 5.2 for more information.

  4. Methodology section — EAs should briefly summarize the methods used to predict impacts.

  5. Regulations and policies section — EAs should briefly detail relevant laws, regulations, and park or other policies for each impact topic.

  6. Cumulative impact section — A discussion of cumulative impacts is important in EAs and must be included (see sections 2.4(c), 2.9(c)).

  7. Sustainability and long-term management — NPS EAs are not required to include separate sections as described in 4.5 (g)(8), although the balancing of short-term needs with long-term ecosystem health, biodiversity, and sound resource planning should be themes that pervade any park EA or EIS.

  8. Conclusions — At the end of the discussion of impacts of each alternative on each environmental resource, a brief “conclusions” section should summarize all major findings, including whether or not a resource impairment is likely or would occur.

  9. Organization — For EAs shorter than about 30-40 pages, many readers find the impact section is more readable if it is organized by alternative, with impact topics as subheadings. For EAs longer than this, the impact section may be followed more easily if it is organized by impact topic, with alternatives as subheadings. Either is acceptable. Impacts may also be combined with affected environment information in an EA.

G. Consultation and coordination

This section should list persons, organizations, and agencies that were contacted for information and that assisted in identifying important issues, developing alternatives, or analyzing impacts. Memoranda of agreement or understanding, formal agreements, major cooperative agreements, or documentation indicating final compliance with applicable laws or regulations should be appendixes to the EA or readily available for public inspection. Any scoping or other public involvement efforts should also be detailed, and a brief summary of major issues should be included.

A list of preparers and their qualifications is recommended, as is a list of recipients of the EA.

H. References

A bibliography, a glossary of terms and acronyms, and appendixes should be part of an EA.

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