A NEPA review includes documentation
of the analysis, which then becomes available to the public. The degree
of public input and the detail included in the documentation varies depending
on the severity, in context, of the environmental impacts of the proposal
B. Five options
Five options to document a
NEPA analysis are available:
to file Prepare a memo to file when the proposal has already
been analyzed in site-specific detail in a previous NEPA document, no
different impacts or changes to the project are expected, and environmental
conditions have not changed. A notation to this effect should be prepared
and placed in the project files.
for which no formal documentation is necessary This option is
applicable when the action is described using one of the categories
in section 3.3 and no
exceptions (section 3.5)
exist. If appropriate, and if a project file exists, a memo to file
may be placed in the project file.
for which a record is needed Prepare
these records when the action is described using one of the categories
in section 3.4 and no exceptions
(section 3.5) exist. Complete
the ESF (appendix 1) and the CEF
(appendix 2) and include them
with the project file.
Prepare an EIS when the potential for significant impact to the
human environment exists (see section
4.2), as indicated by an EA, an ESF, or other scoping, or because
the proposed action or alternative is described in section
(a) the significance of impacts is unknown (e.g., to determine whether
an EIS is required).
(b) the proposed action is not described on either of the CE lists (sections
3.3 and 3.4) or the
list of actions that normally require an EIS (section
(c) the proposed action would take several CE categories to describe
fully, would involve one or more of the exceptions described in section
3.5, or would involve unresolved conflicts concerning the use of resources.
Each of these options has specific
content and public involvement requirements. For options 3, 4, and 5,
you should complete the clear definition of objectives, an initial
range of alternatives and actions including connected and cumulative actions,
internal interdisciplinary scoping (see section
2.6), and an ESF (see section
2.6 (B) (1)) before you determine the appropriate NEPA pathway. For
options 1 or 2, no ESF is required, although you should consult the list
of exceptions to categorical exclusions (see
section 3.5) to see whether any apply.
C. The choice of pathways
you believe option 1 above applies, the IDT should re-read the NEPA
document that it believes already describes and analyzes the impacts
of the action. If it does so in site-specific detail, and the analysis
is up-to-date (see section 2.6 (C)),
no further documentation is required, although for the administrative
record, you must write a memo to file as described above. (Also note
that this memo should be approved by the Superintendent or his/her designee
after consultation with the regional environmental coordinator.)
option 1 does not apply, but you believe option 2 does, check the list
of actions in section 3.3.
If it is described on this list (and no exceptions in section
3.5 apply), you may take action without further paperwork.
the action is not on the list in section
3.3, or if it is described and analyzed in a previous NEPA document,
you should complete internal scoping, complete the ESF form, and check
the list of actions in section
the action is described in section
3.4, and no exceptional circumstances (section
3.5) exist, the CE is likely the appropriate pathway. Section
3.2 of this handbook describes the categorical exclusion process
in more detail.
the action is not described on the CE list, check the list of actions
that normally require the preparation of an EIS (section
4.4). If it is on the list, or the potential for significant impacts
exists as indicated by the ESF, you must write an EIS. Chapter
4.0 of this handbook details the process to follow in preparing
should prepare an EA if the action is not described on any list, or
if one of the following applies:
or more of the categories on the ESF apply or are checked data
needed or yes, but you do not know if any will result
in significant impacts;
categories in section 3.4
are required to completely describe the project;
action is described in section
3.3 or 3.4, but one
or more of the exceptions in section
conflicts concerning the use of resources exist; or the significance
of impacts is unknown.
If the EA indicates there may be significant impacts,
you must prepare an EIS, unless the unique and limited circumstances described
in section 5.4 (F)(3) apply and
a proposal can be modified with mitigation measures to lessen the severity
of impact, sometimes referred to as a mitigated EA. The use
of the terms significant and significance over
the years has become quite contentious in NEPA documents. It is highly
recommended that these terms be avoided in EAs and EISs, since these terms
apply primarily to the determination of the most appropriate NEPA pathway.
to previous section
to next section>>
Return to top of page.