Overview and Initiating the Environmental Impact Analysis and Assessment - Environmental Impact Analysis: Process and Methods - page 151

action. A full range of alternatives is identified through technical evaluation and
stakeholder input, and each is treated equally with respect to description and
analysis. The one that emerges from an objective comparison and decision pro-
cess then becomes the proposed action and the preferred alternative.
If the project and stakeholder conditions are ripe for the equal identification
and treatment approach, but the regulations or project proponent's organiza-
tional constraints (e.g., agency guidance or precedence) dictate designation
of a “Proposed Action,” the object of transparency and equal treatment can
be achieved in other ways. One possibility is to characterize the “Proposed
Action” as the purpose and need or the intended goal of the action and then
develop alternative approaches to achieve the goal. For example, if the issue
is congestion in a small Maine town, because the regional highway goes
through the center of the town, the proposed action could be reduction of
in-town congestion. Equal alternatives could be developed including:
r Widening the street through the town
r Varying traffic patterns so there are more lanes going toward the ski
resort outside of town on Friday evening and more lanes going the
other direction on Sunday evenings
r Restricting logging truck traffic during peak recreational traffic
periods
r Construction of a bypass around the town center via a number of
alignment options
Another widely accepted example of defining the proposed action gen-
erally is given in CEQ's “Memorandum: Forty Most Asked Questions
Concerning CEQ's NEPA Regulations (46 Fed. Reg. 18026 March 23, 1981, as
amended 51 Fed. Reg. 15618 April 25, 1986, and summarized in Table 2.3 of
this topic) as Question 5. In this example the proposed action is to grant a
National Pollutant Discharge Elimination System (NPDES) permit to a non-
federal entity, and the equally treated alternatives could include:
r Various wastewater treatment technologies (e.g., conventional aera-
tion treatment, biological nutrient removal, or activated carbon filter)
r Effluent reuse
r Method of discharge (e.g., land application or aqueous discharge)
r Various discharge locations
Another possibility of applying the transparent and equal treatment
approach is to develop alternatives in an appendix to the EIS or other environ-
mental analysis document. This appendix could include: identification of a full
range of alternatives; alternatives screening, including environmental criteria,
initial comparison of alternatives, identification of alternatives for detailed
evaluation, and then designation of one of the alternatives as the proposed