Environmental Engineering Reference
In-Depth Information
comparison is an extension of the screening process and thus is presented as
the final discussion in this section.
4.5.1
Proposed Action and Alternatives Treatment
There are two primary schools of thought on the treatment of alternatives
as part of environmental analysis. One is to identify a proposed action that
is the preferred alternative the proponent intends on implementing to meet
the purpose and need. After this alternative is developed and designated as
preferred, development of alternatives to the proposed action proceeds, but
generally only to comply with the consideration of alternatives mandated
by regulations. However, specific alternatives are sometimes developed in
response to issues raised or impacts identified late in the environmental anal-
ysis. The other approach is to begin with a blank slate and characterize the
full-range of practical options that meet the purpose and need as equal alter-
natives. Both approaches are consistent with the letter and intent of NEPA
and most other environmental analysis regulatory programs. Each approach
has advantages and constraints, as discussed below and the choice is depen-
dent on the specific project, proponent, and stakeholders.
If the NEPA or other environmental analysis process is initiated late in proj-
ect planning and there is not an anticipated active, informed, committed, and
cooperative stakeholder population, the approach of identifying the proposed
action during the scoping process and in the draft document is a common
approach. This acknowledges to the stakeholders, and potentially to the courts
if there is a challenge, that the project proponent does in fact have a preference
and encourages reaction to the preference. It also allows and perhaps encour-
ages the proponent to develop and refine the proposed action so that sufficient
detail is available to fully describe environmental impacts and even develop
environmental impact mitigation measures. The downside of the approach is
that there can be the perception that the proponent has already made a selec-
tion and is simply using the environmental analysis to justify their decision,
thus an “after the fact” environmental analysis.
Another advantage to the initial designation of a proposed action that is
only rarely used maximizes public input to identify alternatives. In such
cases, the proponent develops the preferred alternative in detail, including
at least a qualitative determination of associated impacts. It is then presented
to the public, and if unforeseen issues and impacts are identified, additional
alternatives are developed to avoid the impacts and address the issues. These
alternatives developed based on public input are then compared in detail
with the original proposed action in the environmental impact analysis, and
a final selection is made based on the results of the analysis.
The other approach to alternatives analysis (equal treatment without a desig-
nated proposal) is supportive of environmental analysis as an integral part of
the project planning process. Under this approach, transparency is essential and
the project proponent should not have internally identified a preferred course of
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