Environmental Engineering Reference
In-Depth Information
action. If this approach is followed to select a single preferred alternative, it is
critical that environmental considerations be a component of the comparison
of alternatives.
The alternative development and comparison appendix could also be
constructed based on nonenvironmental factors and identify the alterna-
tives that are practical and fully meet the purpose and need. The envi-
ronmental implications of each alternative and the identification of the
proposed action could then be the focus of the environmental analysis.
If this approach is followed and all the alternatives considered preferably
from a nonenvironmental perspective (technical, economic, implemen-
tation, etc.) result in a significant environmental impact to one or more
environmental resources, it may be necessary to revisit the initial alter-
native screening and carry at least one alternative forward that mitigates
environmental impacts.
There is another approach to identifying the proposed action that incor-
porates active public involvement in the alternative selection process.
The alternatives can be developed and a full technical, economic, imple-
mentability, and environmental analysis included in the draft document.
The alternatives can be compared on each of these bases and the public
encouraged to weigh in with comments on the draft, or even workshops
with active stakeholder participation conducted on the draft environmen-
tal analysis. The public input during the workshops and comments on the
draft environmental analysis can then be integrated into the alternative
comparison and the proposed action identified in the final environmental
analysis.
Any alternative development, analysis, comparison, and selection pro-
cess as part of an environmental impact analysis must at a minimum have
two alternatives: proposed action and no action. In cases where history has
shown there is a successful approach with little or no environmental impact
to satisfy a similar proposed action, incorporating the minimal number of
alternatives can be adequate and the environmental analysis can focus on
site-specific conditions and mitigation of minor impacts. Similarly, if the pur-
pose and need are of relatively small magnitude and preliminary environ-
mental analysis and project planning have clearly demonstrated that there
are no significant adverse impacts associated with the proposed action, the
analysis can be limited to just the proposed action and no action as alterna-
tives. This condition could apply to a simple EA as opposed to a full EIS for a
NEPA environmental analysis. In such cases, the courts have ruled in NEPA
compliance cases (Smith 2007) that if a clear explanation incorporating envi-
ronmental concerns is provided as to why other alternatives were not consid-
ered in the environmental impact analysis, evaluation of just the proposed
and no actions is adequate treatment of alternatives. Such explanations can
be part of the analysis document, an appendix to the document, or earlier
investigations such as a feasibility study referenced in the environmental
impact analysis.
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