NPS Director's Order 12: Conservation Planning, Environmental Impact Analysis and Decision Making
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Bent's Old Fort National Historic Site7.4 Programmatic Documents and Planning — Tiering

Hotel, Hawaii Volcanoes National ParkCEQ encourages agencies to use a tiering process, working from broad, general NEPA environmental impact analysis documents to more site-specific ones in decision-making (1502.20). When preparing a large-scale plan that determines broad direction, such as the GMP, information can be less detailed and site-specific, because decisions are made on a gross scale. When land identified as potentially suitable for development is planned for a set of visitor-related facilities, the decision to develop the area is not revisited. Instead, the NEPA document prepared in conjunction with the development plan proposal is “tiered,” or procedurally connected to the large-scale plan NEPA document. This narrows the range of alternatives in the development plan analysis to those that explore how and where to site facilities within the designated development area. The decision to designate this as an area for development has already been made. Tiering allows NPS “to focus on the issues which are ripe for decision and exclude from consideration issues already decided or not yet ripe” (1508.28).

Tiering is not the appropriate tool to use when you are dealing with a previous, broad-scale NEPA document that is outdated or for which there is new information requiring the original decisions to be revisited. For example, a programmatic decision made to develop an area for visitor facilities and evaluated in a previous NEPA analysis would require reanalysis and reevaluation if it is subsequently learned that the site is subject to “flash floods,” is the critical habitat of endangered species, or is the location of extensive archeological remains.

  The original, or programmatic, NEPA document from which subsequent documents are tiered is almost always an EIS. This is because larger-scale decisions often have larger-scale impacts, and courts are more likely to deem them “major federal actions.” Also, if the programmatic document is an EA and not an EIS, subsequent NEPA documents tiered to it cannot be EISs without invalidating the original EA.  

The original, or programmatic, NEPA document from which subsequent documents are tiered is almost always an EIS. This is because larger-scale decisions often have larger-scale impacts, and courts are more likely to deem them “major federal actions.” Also, if the programmatic document is an EA and not an EIS, subsequent NEPA documents tiered to it cannot be EISs without invalidating the original EA (see section 7.1).

Tiering may also help in examining cumulative impacts in proper context. For instance, the cumulative impacts of developing all areas designated as suitable should be part of a large-scale planning NEPA analysis, but it does not need to be repeated as part of a development plan NEPA document. Instead, the development plan EA or EIS should make reference to the appropriate pages of the broader plan NEPA document and note that they are tiered.

Further Links:

Director's Order 2: Park Planning

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