7.3 Programmatic Documents and Planning Feasibility and Planning
|Is NEPA Triggered by Plans? | When to Begin NEPA on Plans | Feasibility and Planning | Tiering | Programs and Policies | Long-Term Resource Management|
NEPA begins at the proposal stage that is, when NPS has a goal and is actively preparing to make a decision on one or more alternative means of accomplishing that goal, and the effects can be meaningfully evaluated (1508.23). Feasibility analysis to define a realistic proposal or goal is sometimes required before NEPA can begin. In the GMP planning process, the definition of the corral bounded by the park purpose, significance, and special legislation is a form of feasibility analysis.
|Agencies often mistake this weeding-out process as one that allows them to choose only their favorite alternatives for analysis without having first completed NEPA.|
For projects or implementation plans, early in the process you can eliminate alternatives that are not feasible because they are unreasonably expensive, are not implementable for technical or logistic reasons, do not meet park mandates, or are not within legal or other mandatory constraints. This does not mean that alternatives must be cheap or easy, or that those actions within another agency's jurisdiction can be eliminated if they are reasonable in other respects. Rather, it is an initial step to ensure that alternatives that could not be implemented are not subjected to extensive environmental analysis. Likewise, if it appears that a technically or economically feasible alternative would have profound adverse environmental impacts or would not be allowed by another agency from which a permit is required, it should be eliminated as environmentally infeasible.
Agencies often mistake this winnowing process
as one that allows them to choose only their favorite alternatives for
analysis without having first completed NEPA. Rather, it is a procedure
for eliminating infeasible or duplicative alternatives while still leaving
a full spectrum of reasonable choices ready to undergo the
objective environmental analysis that NEPA dictates.