Unless there is a compelling
reason to do otherwise (CEQ 1502.10), CEQ requires that you follow
its format (laid out in this section) for all EISs. Variations from the
CEQ format described in this section must first be approved by the Environmental
Quality Division (EQD) and the Department's OEPC.
Also see Section
2 of this Handbook.
A. Cover sheet
You must make sure the cover
sheet does not exceed 1 page. It must include the following:
- a list of responsible agencies
including the lead agency and any cooperating agencies.
- the title and location of
the proposed action that is the subject of the statement.
- the name, address, and telephone
number of an NPS contact person.
- designation of the statement
as a draft, final, or supplement.
- a one-paragraph abstract
of the statement that identifies significant impacts and alternatives
to the proposed action/proposal.
- the date by which comments
must be received.
B. Summary (1502.12)
Each EIS must contain a summary that adequately and
accurately summarizes the statement. You must stress the major conclusions,
the areas of controversy (including issues raised by agencies and the
public), and the issues to be resolved (including the choice among alternatives)
in the summary. Normally, you should not allow the summary to exceed 15
C. Table of contents (1502.10)
You should make sure the table of contents is sufficiently
detailed to allow the reader to quickly locate major subject matter in
the EIS, particularly specific impact topics and alternatives analyzed
in the document.
D. Purpose and need for action (1502.13,
Purpose and need for action is usually
the title of chapter one of an EIS, although introduction
may be more appropriate. In this chapter, you must specify the underlying
purpose and need to which your park is responding in its proposal (see
section 2.2), and you should
describe the issues identified by the IDT (see section
2.5). This chapter may introduce a number of factors, including economic
or technical considerations, or service or departmental statutory, or
legislative mandates. Take care to ensure that this is an objective presentation
and not a justification of the proposal.
In the section of this chapter on issues (1500.4 (C),
1502.2 (b)), you should discuss important environmental issues and also
dismiss unimportant issues. Important issues may be raised by the public,
other agencies, or the IDT. You should include a corresponding impact
section for all issues that the IDT retained for full analysis.
If the team found that some issues were not relevant
to the scope of the document and decided to drop them from further analysis,
this should be stated in the document. You may wish to do this in a paragraph
or two at the end of the discussion of issues. You should also include
a short statement on the reason the issues were dropped. Supporting documentation
on why an issue was analyzed or not analyzed must be included in the administrative
E. Alternatives (1502.14)
Chapter 2 of an EIS describes the proposal (it can
be general or specific as defined in section
2.1 of this handbook) and alternatives. It also includes a discussion
of the range of reasonable alternatives and mitigation measures and a
summary of impacts of each alternative. You must describe and evaluate
the no action alternative, and all reasonable alternatives retained for
analysis in comparative detail.
Alternatives are different ways of meeting park goals or objectives.
They are considered the most important section of an EIS. Because alternatives
fulfill park objectives to a large degree, they are directly related
to the purpose and need. Because they also reduce impacts to important
resources, they also are tied to issues. In an EIS or an EA, the no
action alternative should be described first because all other alternatives
are then compared against changes in the environment from conditions
described under the no action alternative projected into the future.
- Range of Alternatives
(see section 2.7
(A) for more information) An EIS should include a discussion
at the beginning of the alternatives chapter that describes how the
IDT arrived at the final range of reasonable alternatives. This discussion
should include factors such as agency or environmental constraints;
references to policy in planning documents, legislation, or elsewhere;
site characteristics; and factors such as sensitive environmental resources
that narrowed the range of possibilities. Making reference to purpose
(i.e., goals and objectives) and need may be appropriate.
- Reasonable Alternatives
CEQ defines reasonable alternatives as those that are technically
and economically feasible and that show evidence of common sense (Q2).
They also meet project objectives, resolve need, and alleviate potentially
significant impacts to important resources. An alternative is not automatically
rendered unreasonable if it requires the amending of a park plan or
policy; causes a potential conflict with local, state, or federal law;
or lies outside the scope of what Congress has approved or funded or
outside the legal jurisdiction of the NPS.
Another point to consider when identifying reasonable alternatives is
how they meet the policies set forth in section 101 of NEPA (see section
2.7(D) of this handbook).
- Proposed Action
CEQ uses the term proposal synonymously with proposed action
(1508.23). As described in section
2-3 of this handbook, a proposal may be a specific method of accomplishing
objectives or fulfilling need, or it may be a general restatement of
NPS's purpose in taking action.
- No Action (see section
2.7(C) for more information on no action) The no action alternative
must be fully analyzed in all EAs and EISs, even if another law prohibits
the adoption of the no action alternative or the park is under legislative
or other command to act. The no action alternative is usually a viable
alternative, but even when it is not, it sets a baseline for comparing
the impacts of existing actions with those proposed.
- Alternatives Eliminated
from Further Study Following the description of alternatives
retained for analysis, you should describe alternatives considered but
eliminated from further study. This should be limited to those alternatives
initially thought to be viable or suggested by the public, but later
dismissed. Briefly state in this section the reasons they have been
eliminated, and fully document supporting reasons in the administrative
record. Reasons to eliminate alternatives include:
(a) technical or economic infeasibility.
(b) inability to meet project objectives or resolve need.
(c) duplication with other, less environmentally damaging or less expensive
(d) conflict with an up-to-date and valid park plan, statement of purpose
and significance, or other policy (see section
7.3 of this handbook), such that a major change in the plan or policy
would be needed to implement.
(e) too great an environmental impact.
- Cost If a
cost-benefit analysis has been developed and is important to the decision-maker
or the public in choosing between alternatives, either the entire analysis
should be appended to the draft EIS or it should be summarized and incorporated
by reference into the body of the EIS (1502.23). It is appropriate to
include costs of each alternative in the alternatives chapter.
- Preferred Alternative
The preferred alternative is the agency-preferred course of action
at the time a draft EIS or a public review EA is released. Unless your
decision-maker has no preference, the preferred alternative must be
identified in the draft EIS so that agencies and the public can
understand the lead agency's orientation (1502.14 (e), Q4a). You
may identify the preferred alternative in an explanatory cover letter
to the draft EIS or in the text of the EIS. All final EISs must identify
the preferred alternative. Therefore, if no preferred alternative exists
at the time the draft EIS is released, you must identify it in the final
EIS. For all externally initiated (i.e., non-NPS) proposals, you must
identify the NPS-preferred alternative in the draft (and final) EIS
(516 DM, 4.10 (2)). It is important to remember that all alternatives
in an EIS must be treated with the same level of detail in the analysis
of impacts (1502.14(b), Q5b).
- Environmentally Preferred
Alternative You must identify in a draft EIS and EA what
the environmentally preferred alternative is so that the public can
have the opportunity to comment on it. (See section
You should summarize the following in the alternatives chapter:
(a) the degree to which each alternative meets purpose, need, and objectives.
(b) the important features of each alternative.
(c) the impacts of each alternative, including a determination of potential
improvement to park resources. (See
(d) how each alternative achieves requirements of sections
101 and 102(1) of NEPA, including
the environmentally preferred alternative, and any potential conflicts
between each alternative and other environmental laws and policies.
Items (c) and (d) are mandatory (1502.14). The summary
usually includes a matrix for easy comparison of alternatives. Although
a chart is not required, the comparison must sharply define
differences between alternatives (1502.14).
It is helpful to readers if the discussion of issues
dismissed and issues kept for further analysis, and the corresponding
impact topics, precede the summary of impacts in the alternatives chapter.
F. Affected Environment
requires that NEPA documents succinctly describe the environment
of the area(s) to be affected or created by alternatives under consideration
(1502.15). This description forms chapter 3 of an EIS. Although
you should present enough information to give the reader a general understanding
of the environment affected, the length of this chapter should not normally
exceed 20 percent of the total EIS.
Describe only those resources that may experience or
cause impact or be affected if the proposal or alternatives are implemented.
If specific resources would not be affected (e.g., threatened and endangered
species) or impacts would be negligible (impact is at a low level of detection),
you should list them in the issues discussion as issues and impact
topics considered but dismissed. You should keep data and analyses
in this section commensurate with the intensity, context, and duration
of the impact.
- Incorporation by Reference
An EIS is to be analytic rather than encyclopedic. You should
either append, summarize, or incorporate by reference background material,
highly technical material, and less important descriptive information.
NPS can incorporate many different kinds of material by reference, and
this should be done when the effect will be to cut down on bulk
without impeding agency and public review of the action (1502.21).
Besides written material of all kinds, you can refer in an EIS (or an
EA) to conversations, conference proceedings, taped hearings or workshops,
and so forth. If you decide to incorporate by reference, you must provide
a summary of the relevant text in the NEPA document, and the resource
itself must be reasonably available for inspection by potentially
interested persons within the time allowed for comment on the
draft EIS (or EA).
Materials that should be incorporated by reference (and available as
part of the project file) include other NEPA documents, lists of common
plants and animals, historic resource studies, detailed air and water
quality data and standards, separate scientific studies, compilations
of demographic and socioeconomic data, and published works.
Topics You must consider all of the following in an EIS:
(a) possible conflicts between the proposed action and land use plans,
policies, or controls for the area concerned (including local, state,
or Indian tribe) (1502.16, 1506.2(d)), and the extent to which your
park will reconcile the conflict.
(b) energy requirements and conservation potential (1502.16).
(c) natural or depletable resource requirements and conservation potential
(d) urban quality, historic and cultural resources, and design of the
built environment (1502.16).
(e) socially or economically disadvantaged populations (see Environmental
Justice EO 12898 for more information).
(f) wetlands and floodplains (100-year, and 500-year when critical actions
as defined in the NPS floodplain management guides are involved) (1508.27).
(g) prime and unique agricultural lands (1508.27).
(h) endangered or threatened plants and animals and their habitats (including
those proposed for listing, or on state lists) (1508.27).
(i) important scientific, archaeological, and other cultural resources,
including historic properties listed or eligible for the National Register
of Historic Places (1508.27).
(j) ecologically critical areas, Wild and Scenic Rivers, or other unique
natural resources (1508.27).
(k) public health and safety (1508.27).
(l) sacred sites (EO 13007).
(m) Indian Trust resources (ECM 95-2).
If these are irrelevant issues in your EIS, include them in the discussion
of issues and impact topics dropped from the analysis.
Impact Topics, and Data
National Park Service Resources:
Although alternatives are important, they are useless
unless you clearly and correctly assess their impacts in an EIS or an
EA. The prediction of impacts of each alternative is the basis of chapter
4 of an EIS.
This discussion must be accurate and focused. If it
rambles on about non-issues, or if the data are wrong or mislead the reader,
it wastes the reader's time and the park's money. The impacts discussion
is not just a reiteration of the proposal or actions, but rather a discussion
of the impact should the proposal and alternatives be implemented. For
instance, instead of there will be a bridge from A to B, the
discussion will focus on the impact of building a bridge from A
to B on each resource identified as an issue and impact topic.
Whereas issues describe the impact relationship between
actions and resources, impact analysis predicts the magnitude of that
relationship. For instance, building a bridge will disrupt riverbank
soils and make the water muddy is an issue. Suspended solids
in the river will increase from its present 10-15 ppm to 1000 ppm for
2-3 weeks during construction is the kind of information that belongs
in the impact chapter.
CEQ requires that the impact analysis:
- be concise, clear, and to
the point (1500.2 (b)).
- emphasize real environmental
issues (1500.2 (b)).
- provide reasonable alternatives
to the proposed action (or proposal, whether generally or specifically
described) that minimize adverse impacts (1500.2 (d)).
- be of high quality, using
accurate scientific analyses (1500.1 (b)).
- be scrutinized by other
agencies and the public (1500.1 (b)).
- include direct, indirect,
and cumulative impacts (1502.16).
You must analyze both beneficial and adverse impacts
for the resource in question.
Impact Information The role
of NPS NEPA documents is to fairly, objectively, and candidly display
the projected impacts of each alternative. If you can meaningfully and
accurately quantify the magnitude of this impact, this is the best way
to present the information. If you have little confidence in an absolute
number, you may want to use a range of reasonable impacts; rather than
conveying false confidence, documents should give the decision-maker
and the public a true picture of how well you can predict an impact.
You must support qualitative and quantitative impact analyses with the
scientific literature and/or other experts' testimony. Such references
should be cited liberally in the impact section. CEQ requires that impacts
be quantified as much as possible and described in terms of their context,
duration, and intensity (see below).
You should analyze impacts in several contexts, if the severity
varies geographically, over time, or in some other way (CEQ (1508.27
(a))). See section 4-2(a) for more information on context.
or Unavailable Information CEQ (1502.22) requires agencies
to obtain information if it is relevant to reasonably foreseeable
significant adverse impacts, if it is essential to a reasoned
choice among alternatives, and if the overall costs of obtaining
it are not exorbitant. The costs are measured not only in money,
but also in time (to complete a research study or survey, for instance).
If such information is unavailable or if the costs of obtaining it are
exorbitant, an EIS must include statements to let the public know this
and its effect on NPS's ability to predict impacts to the particular
resource. Existing credible scientific evidence should then be summarized
and the impact predicted based on this evidence. CEQ says that reasonably
foreseeable impacts include those that have catastrophic consequences,
even if their probability of occurrence is low (1502.22, modified in
Although the CEQ case applies only when the information is essential
and the impacts significant, EISs and EAs should routinely inform the
public when data are lacking, models are error-prone, or insufficient
research or experience is available for predicting impacts accurately.
Indicators The measurement of impact must be accurate, scientifically
credible, and understandable to a lay readership. This is why it is
helpful to include a methodology section preceding the impact analysis
for each topic. That section can lay out the criteria or thresholds
used to draw a conclusion on the context, intensity, and duration of
impact. Defining thresholds and impact indicators requires consultation
with resource experts, literature searches in some cases, and best professional
judgment. In the case of the suspended solids in the river, an impact
topic might be the effect of the muddy water on visitor experience.
This impact is more difficult to measure than turbidity itself, but
not impossible. One indicator might be the number of visitors passing
through the area in the context of the rest of the park for instance,
Fewer than 2% of the total visitors to the park would be able
to see the construction on the river.
Thresholds Impacts must be quantified as much as possible
and interpreted in terms of their context, duration, and intensity.
For instance, in the example in section 4.5 (g), the
impact is quantified as suspended solids in the river would increase
from its present 10-15 ppm to 1000 ppm for 2-3 weeks during construction.
This is adequate for intensity and duration. However, the reader needs
a context to understand the full extent and relative importance of the
impact. This can be provided by comparing the impact to a relevant standard,
such as the state's water quality standards for suspended solids. The
methodology section would define the threshold as any increases
in suspended solids that violate the state's water quality standard
for this parameter would be considered a major impact.
The analysis would follow with the increase in suspended solids
from 10-15 ppm to 1000 ppm is well below the state's water quality standard
for this river (3000 ppm). The analyst should also interpret the
quantitative information for a lay audience. In this example, the specialist
might conclude, Because the impact would last only 2-3 weeks and
be well below the standard, it would be a minor, short-term adverse
impact to water quality.
Notice that criteria were cited (state standards) in the determination
of the intensity (in this case, minor) of the impact. Criteria, or thresholds,
help to establish the sideboards for understanding the severity and
magnitude of the impact. If the analysis simply stated that the suspended
solids would increase from 10-15 ppm to 1000 ppm for 2-3 weeks, the
public and the decision-maker would be unable to fully understand the
extent of the impact.
Impact Analysis Data Links
of Regulations and Policies Impact Indicators and Criteria
Management Policies (Search under Impairment.)
Analysis for a GMP
In an EIS, you must develop and analyze mitigation even
for impacts that by themselves would not be considered significant
(Q19a). All relevant, reasonable mitigation measures that could
improve the project are to be identified, even if they are outside
the jurisdiction of the agency (Q19b). You must also analyze the effectiveness
of mitigation measures proposed, and the impacts if the project were
to proceed without mitigation. For instance, it should be clear whether
mitigation is integral to the project and therefore included as part
of the alternative, or dependent on factors such as funding or permission
from another agency.
CEQ (1508.20) defines mitigation measures as:
(a) avoiding the impact altogether by not taking a certain action or
parts of an action.
(b) minimizing impacts by limiting the degree or magnitude of the action
and its implementation.
(c) rectifying the impact by repairing, rehabilitating, or restoring
the affected environment.
(d) reducing or eliminating the impact over time by preservation and
maintenance operations during the life of the action.
(e) compensating for the impact by replacing or providing substitute
resources or environments.
Learned: Determining Impact Significance and Mitigation Success
the Impact Chapter The impact section can be organized by
alternative, with impact topics as subheadings, or by impact topic,
with alternatives as subheadings. As a general rule, if impacts to a
particular resource for one alternative are the same as another alternative,
making reference to that section in the EIS is preferable to repeating
the information. You may briefly summarize information in the referenced
section to help readers track impacts.
(a) Methodology section You should begin the discussion
of impacts by describing methods used to predict impact. As indicated
above, if the methods used are the best available, but they require
many assumptions that may not be correct or that have been criticized
by other professionals, these assumptions should be explained in the
This section is also a good place to define or explain how data were
interpreted. In other words, you should define terms such as minor
or major for a particular impact topic. If relevant, explain
the reasoning behind this interpretation why, say, 100 ppm is
a major impact but 50 ppm is a minor impact.
This is a discussion of thresholds of impact.
(b) Regulations and policies section Following the methodology
section, you may include a separate section that details relevant laws,
regulations, and/or park or other policies for each impact topic. This
section may help clarify why a particular impact topic is important
to discuss, or help support the reasoning for the impact threshold discussion
in the methodology section. This section may be placed in the alternatives
or purpose and need chapter if more appropriate.
(c) Cumulative impact section CEQ requires the analysis
of cumulative impacts to each resource and for each alternative. This
discussion should be identified separately from, but follow the same
order as the discussion of, direct or indirect impacts. It should precede
the conclusions section (see 6 (d) below).
Cumulative impact information may be less exact than information on
direct and indirect impacts of the alternatives, but a good faith effort
to accurately and completely assess major sources of impact and their
contribution to resources affected by the proposal and alternatives
should be part of any EIS or EA. For plans or other larger-scope federal
actions, the analysis of cumulative effect may be a major focus of the
NEPA document requiring regional resource data by which to analyze impacts.
(d) Conclusions At the end of the discussion of impacts
of each alternative on each impact topic (e.g., resource), a brief conclusions
section should summarize all major findings, including whether or not
a resource impairment is likely or would occur. It should focus on those
impacts that would be major, but include a statement that resources
examined would experience less severe impacts as well (if this is true).
The conclusions section should not contain information that is not already
in the impact section.
of Impact Topic Analysis Organization (Get
the Adobe Acrobat PDF Reader 5.0 to read the document.)
and Long-term Management Considerations of long-term impact
and the effect of foreclosing future options should pervade any EIS
or EA, because these are ideas that Congress put forward as the purpose
of both NEPA (section 101 (b)), and the NPS Organic Act. However, for
each alternative you must also include a separate section that focuses
on the following required discussions:
H. Consultation and coordination
This section should include
a brief history of public involvement, a list of preparers and their expertise,
and a list of recipients of the EIS. If it is the final EIS, it must include
a response to comments section.
- History of Public Involvement
In this section you should briefly:
(a) summarize important consultations that occurred during the evolution
of the proposal, the alternatives, and the EIS.
(b) describe any public scoping sessions or other public involvement
(c) include names of any federal, state, or local agencies; major organizations;
or experts consulted.
(d) identify environmental issues or conflicts discussed during consultation
(e) include a brief summary of major issues raised during scoping.
(f) describe any relevant existing or proposed cooperative agency mechanisms,
or consultation undertaken in compliance with other laws or regulations.
(Memoranda of agreement, memoranda of understanding, formal agreements,
major cooperative agreements, or documentation indicating final compliance
with applicable laws or regulations, such as comments from the state
historic preservation office, should be appendixes to the EIS or readily
available for public inspection.)
(g) summarize steps taken to identify and involve low-income and minority
communities that would be affected by the proposal and alternatives.
- List of Preparers
The EIS must include a list of persons primarily responsible
for preparing the document or significant background papers
(1502.17). You should identify people responsible for preparing a particular
section and include the qualifications of the preparers their
expertise, experience, and professional disciplines. Normally the list
will be no longer than 2 pages.
- List of Recipients
You should include a list of all agencies, organizations, and
people to whom copies will be sent. The list should be organized alphabetically
under federal agencies, state and local agencies,
Indian tribes, organizations, and individuals.
If the list of individuals is longer than 3 pages, it may be placed
in the project file instead of the EIS, with a notation in the EIS that
the complete list is available from the issuing office. In the final
EIS, an updated list of recipients is provided as necessary to indicate
who will be receiving the final EIS.
- Response to Comments
See section 4.6, Final EIS.
Also see Section
4.8 of this Handbook.
The last section of the EIS
is dedicated to references, and it should include a bibliography, a glossary,
an index of key words, and appendixes.
You should include a list of all references cited in the EIS, including
written material and personal communications.
Define in a glossary any technical or other terms not understandable
to an average lay reader. Be sure to define them in plain language.
If agency or other acronyms are used in the EIS, define them either
in the glossary or in a separate list of acronyms.
- Index of Key Words
You should include an index that contains (in alphabetical order)
enough key words from the EIS to allow the reader to find the information.
The entries should relate to the subject matter of the text and should
not repeat the general topic headings of the table of contents.
- Appendixes (1502.18)
Appendixes are for amplification or support of critical analyses
in the EIS. They are not a data bank or library for total reference
support. They should contain only major substantiating data, essential
relevant descriptions of environmental components, important professional
reports, and copies of major legislative and executive documents, agency
agreements, or other information necessary for a complete use of the
EIS for analytical/decision-making purposes. If the audience reading
the EIS is not likely to be interested in the supporting material, consider
keeping a copy of it in the file and readily available if requested
rather than sending it out as an appendix.
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