NPS Director's Order 12: Conservation Planning, Environmental Impact Analysis and Decision Making
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White Sands National Monument, NM2.1 Overview of the NEPA Process — The Analysis Process

Chapter 2 of this handbook is focused on the analysis process. Chapters 3 through 5 deal with documentation of the analysis.

CEQ does not mandate a particular analysis process. However, because NEPA is meant to be part of planning and thus should be applied early, you should carefully consider beginning NEPA when your park is framing its purpose or goals for a particular proposal. Over the years, there has been much confusion in the park service concerning the use of the terms "proposed action" and "preferred alternative." The majority of actions in the park service involving NEPA do not have a specific or even conceptual "proposed action" from the onset of the process. In fact, it can be dangerous to start into a NEPA process with a solidified proposal that precludes consideration and equal treatment of other reasonable alternatives.

 

Steps in a typical analysis process include:

  1. Identify your park's need for action.
  2. Identify your park's goals and objectives in taking action.
  3. Identify your proposal.
  4. Identify issues or problems that need to be addressed to reach park goals and objectives.
  5. Resolve these issues by creating reasonable alternatives.
  6. Identify information gaps and needs and gather needed data.
  7. Identify the impacts of each alternative
 
Backcountry camp at Glacier National Park, MTTypically in the park service, purpose and need as well as objectives can be defined, and from there, a range of alternatives developed, one of which becomes “preferred” at the conclusion of the analysis process. This “preferred alternative” is then identified in the EA or EIS before it is released to the public for review and comment. In these situations, it is not necessary to use the term “proposed action” since what the park is proposing to do is essentially synonymous with the term “preferred alternative.” An exception to this might be when a park is analyzing a “proposal” or “proposed action” from an external applicant or “project proponent.” For example, a park receives a “proposed action” from an applicant desiring to develop a mining claim. The park responds to the applicant’s proposed action by developing a range of alternatives to mitigate impacts of the applicant’s proposal. In this case, the applicant’s “proposed action” may be very different from the park’s preferred alternative. In either case, a simplified version of a typical analysis process is as follows:
  1. The best way to begin is by clearly stating your park’s need for action. Need is the proper framing of the question “why take action?” It is a “because” statement and should include a statement of problems the park is trying to solve, opportunities it is about to take advantage of, and so forth.

  2. The next step is to establish the purpose and objectives, or goals the park must accomplish by taking action for the action to be considered a success. The objectives and goals, or purpose, of the action are different from the purpose of the park. They are the reasons for proposing action.

  3. When you have identified what your park hopes to accomplish, the next step is to develop a proposal. CEQ defines “a proposal” as the stage where a park has defined goals and is actively pursuing different means of accomplishing its goals (1508.23). If there is no one “proposal” in mind to meeting goals and objectives, the park may keep the proposal general, such as “NPS proposes to provide visitors an extended experience at the north rim.” The next step would be to create a range of alternatives (see step 5 below) that are consistent with the proposal, for instance, building a lodge, renovating cabins in the park, subsidizing overnight accommodations in the local town, etc. As a note, the decision-maker or designee is required to identify a “preferred alternative” (see sections 4.5 E (8) and 5.4 (D)) before an EA or EIS is released for public review. This is the alternative the park service believes would best accomplish its goals after the in-house NEPA analysis has been completed, when the choice of an alternative as “preferred” is appropriate.

  4. The next step is to use the interdisciplinary team (IDT) approach to identify issues or environmental problems that need to be addressed to reach park goals and objectives and resolve need for action. This step is often the beginning of internal scoping (section 2.6), and it should involve a site visit (or familiarity of team members with the site) and discussions with appropriate agencies. The Environmental Screening Form (ESF; appendix 1) may serve as a guide in determining affected resources. These may later be supplemented with input from public scoping (sections 4.8 and 5.5). The IDT should pay particular attention to focusing the issues; in other words, what specifically may affect a resource, and what about the resource might be affected. These specifics will form the basis for your impact topics. If your proposal is general, such as “providing an extended experience on the north rim,” the issues may also be more generalized. An example would be “providing an extended experience for visitors may require infrastructure that could eliminate habitat and disturb archeological sites.”

  5. If the issues show that the proposal would likely result in environmental impacts, the team should create a set of reasonable alternatives that mitigate or eliminate these problems, but that still fulfill the stated purpose and resolve need — for example, “create a campground, renovate existing cabins, subsidize hotels in town.” The alternatives themselves may create environmental problems, which the team will need to correct by adding mitigation or refining the alternatives, or to identify as unresolved issues in the NEPA document.

  6. The team should then identify data that it has and will need to describe the affected environment and predict impacts of all alternatives. If you start collecting data before you know your purpose and need, issues, and potential alternatives, you might be spending time needlessly collecting irrelevant information.

  7. Using these data, the team predicts impacts of each action in each alternative on those specific environmental resources identified as impact topics. For those resources that may experience a discernible impact, the team uses the best available methods to predict the extent of the effect. This prediction includes a discussion of context, intensity (e.g., degree), duration, and timing (e.g., short-term vs. long-term), and a conclusion by the park staff and other experts of the relative severity of the impact (minor, moderate, or major).

This process may be modified to fit your park’s particular need, and it should include agency and public involvement in identifying and reviewing the documentation of issues, alternatives, and the extent of impact. Also, some steps will be unnecessary if no potential for environmental impact exists and the process outlined in section 3.2 applies.

Further Links:

See 10 Steps, NPS NEPA Analysis Process

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