NEPA Process and Specific Requirements - Environmental Impact Analysis: Process and Methods - page 81

ultimately acceptable to the stakeholders may not have been developed and
implemented. Thus the strong purpose and need statement served the intent
of focusing the program on the real issues and allowed the U.S. Army Corps
to achieve its goal of developing a residual management system that fully met
reissued NPDES permit requirements while achieving cost-effectiveness and
not compromising the quantity or quality of water supplied to the Washington,
D.C. Metropolitan area. By focusing the U.S. Army Corps' efforts on the true
issues, the purpose and need statement also facilitated development of a pro-
posed action which minimized impacts on the neighbors and in the final anal-
ysis generally satisfied their concerns.

3.4 Purpose and Need Case Study: U.S. Coast

Guard Rulemaking for Dry Cargo Residue
Discharge in the Great Lakes

3.4.1 Background

The economic life blood of the Great Lakes region and in many ways the
industrial revolution in the United States is the combined presence of plentiful
and easily extractable natural resources (e.g., coal, iron ore, and limestone) in
the region and easy transportation from the sources of these primary compo-
nents required to steel manufacturing operations. There are significant coal
deposits both at the western (e.g., Montana) and eastern (e.g., Pennsylvania
and West Virginia) ends of the region, and iron ore is plentiful, particularly in
Minnesota at the western end of Lake Superior. The other component required
for steel manufacturing, limestone, is abundant in the center of the region.
This distribution of resources is not unusual in North America but the ability
to cheaply and quickly transport them to central locations for manufacture is
unique. Since the 1800s, these materials have been loaded on Great Lake ships
at or near their point of origin and transported to Ohio, Indiana, and other
ports where they are converted to steel. The steel was then easily transported
to Detroit and other industrial centers around the Great Lakes for the produc-
tion of cars, appliances, and other goods that made U.S. manufacturing a dom-
inant factor in the country's development and ultimately their place in history.
Transport by ship was easy, convenient, and quick. There was no need for
roads or railroads, and many of the steel mills, such as those in Cleveland
were on the lake's edge, and the raw materials for steel production could be
unloaded directly to the mills. The cost of moving a ton by ship is a small
fraction of that by any other means of transport, and although the ships
might not travel at the speed of a train, they could navigate a direct line
course from source to factory. Also, the ships never stop, so transport effi-
ciency was also superior to other means of transportation.