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
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.
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.
- 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.
- 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.
- 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.
- 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.
- 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
- Environmentally preferable
alternative See section
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
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)).
- 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
- 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
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.
- Methodology section
EAs should briefly summarize the methods used to predict impacts.
- Regulations and policies
section EAs should briefly detail relevant laws, regulations,
and park or other policies for each impact topic.
- Cumulative impact section
A discussion of cumulative impacts is important in EAs and must
be included (see sections
- 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.
- 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.
- 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.
A bibliography, a glossary of terms and acronyms, and
appendixes should be part of an EA.
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