NEPA Process and Specific Requirements - Environmental Impact Analysis: Process and Methods - page 84

TABLE 3.2
USCG Rulemaking Dry Cargo Residue Discharge Alternative Screening Criteria to
Meet Purpose and Need Statement

Alternative Screening Criteria Link to Purpose and Need Statement

Prevent impacts that significantly degrade
the Great Lakes aquatic resources

USCG's strategic goal of protecting natural
resources

Regulate with only minimal additions to
existing Coast Guard organizational
structure and resources

Prevent compromising USCG's
organizational strategic goals by diverting
resources needed to meet the goals

Avoid regulating dry bulk carriers and
related shoreside facilities in a way that
threatens their continued economic viability

Congressional mandate to maintain the
economic viability of the shipping industry

Avoid regulating dry bulk carriers in a way
that threatens their safe operation

USCG's strategic goal of maritime safety and
maritime mobility

Minimize additional energy use USCG's strategic goal of protecting natural

resources

Provide for an adequate and appropriate
recordkeeping and compliance monitoring
system

Provide a monitoring system so the USCG
could demonstrate compliance with the
regulations, Congressional mandate, and
organizational strategic goals

Use proven dry cargo residue control
measures

USCG's strategic goal of maritime safety and
maritime mobility

Source: Adapted from USCG, Final Environmental Impact Statement: U.S. Coast Guard Rulemaking

for Dry Cargo Residue Discharges in the Great Lakes , Washington, DC: Commandant
USCG Headquarters, 2008.

of inconsistency with one or more of the criteria established to evaluate
achieving the purpose and need as follows:

r The alternative to adopt the existing interim rule without modifi-
cation was eliminated because it did not include a record keeping
requirement, and the USCG would not be able to determine whether
they met their Congressional mandate over the long term.
r A newly developed USCG permitting system was eliminated as an
alternative for detailed evaluation because it would have required a
significant modification with substantial expenditure of resources to
the existing organizational structure, potentially compromising the
USCG's ability to fully meet its organizational goals. There was no
additional environmental or economic benefit to this alternative com-
pared with others, and it risked other aspects of the USCG mission.
r Structural modification of the deck and ship's hold to retain DCR
wash-water and prevent overboard discharge was also eliminated
as an alternative. Based on the extensive knowledge of ship safety
within the USCG (ship safety has been their primary mission for
over 200 years) it was determined that the wash-water could weigh