Overview and Initiating the Environmental Impact Analysis and Assessment - Environmental Impact Analysis: Process and Methods - page 109

implemented within their organizations requiring various levels of environ-
mental analysis and assessment. If the proposed action requires a permit related
to an environmental resource, there is a strong likelihood that at least some level
of environmental impact analysis is necessary. Thus, a first step in determining
the need for environmental analysis is to identify environmental resources (e.g.,
historic properties, regional transportation, and water supply) potentially at risk
and the regulatory mandates and procedures related to such resources. If a per-
mit based on environmental criteria could be necessary for the action, then some
level of environmental analysis is beneficial if not required.
If the organization or entity proposing the action does not have thresh-
old criteria and there are no apparent regulatory mandates, the practitioner
must make a case-by-case determination of the need for analysis based on the
magnitude and intensity of the proposed action. If the area affected is large,
the construction duration is long, the number of people/properties involved
is large, it is highly visible, or there is a high cost of the action, there is likely
a need for environmental analysis. The relative magnitude of “large, long,
great, highly, and high” can be determined by comparison to other similar
actions by the proposing or similar entities. If other historic actions of similar
or less magnitude have conducted environmental analysis, it will likely be
required and beneficial to the success of the action under consideration.
There are certain types of actions, regardless of size or intensity, where
environmental impact analysis is typically warranted. These types of actions
have historically generated substantial public interest, opposition, and con-
troversy and in some cases avoidable environmental impacts. Examples of
such actions are:
r Changes in land use
r New or substantially modified transportation resources (e.g., roads
or changes in mass transit systems)
r Power generation
r Water supply
r Air emissions and wastewater discharges
If the need or level of environmental analysis is uncertain based on the
type and size of the proposed action there are simple steps that can be taken
to make the determination. One is to study the list of recent EISs reviewed by
EPA under the Clean Air Act, Section 309, regarding level of environmental
analysis (see Section 2.4 of this topic) if the action is within the U.S. or similar
inventories in another jurisdiction. If there have been numerous similar proj-
ects, plans, or policies requiring environmental analysis, chances are that
the action under consideration would benefit from a full EIS or comparable
analysis. Another approach is to inquire within government resource or reg-
ulatory agencies and environmental advocacy groups to determine whether
actions similar to that proposed are generally subject to environmental anal-
ysis, but keep in mind there will be inherent biases in these groups.