Conducting the Environmental Impact Analysis and Assessment - Environmental Impact Analysis: Process and Methods - page 227

The requirement to consider cumulative impact was important in the early
days of environmental analysis because there was a natural tendency to
focus on the action at hand and spend less time integrating the projected
effects on a broader canvas. The specific cumulative requirement forced the
practitioner to take the broader perspective, and much has been written on
approaches to cumulative impact analysis (e.g., Eccleston 2008). However,
there is another view that cumulative impact analysis should not be dis-
tinct but an integral component of a comprehensive environmental impact
analysis.
Any thorough environmental analysis should fully document and consider
the environmental setting (or Affected Environment, see Section 5.2) as part
of impact prediction. Certainly a complete description of existing conditions
would incorporate “ other past, present…actions ….” Similarly, the description
of the no-action alternative would incorporate “ reasonably foreseeable future
actions, ” and these actions should be included in the prediction of impacts
for all alternatives. Thus, the full impact prediction approach, procedure, and
methods as described in Section 5.3 will address cumulative impacts com-
pletely, and a separate and typically less comprehensive analysis of just cumu-
lative impacts will be redundant and nonproductive. This is not to diminish
the importance of considering the impacts of the proposed action and alterna-
tives in combination with other actions; cumulative considerations are essen-
tial to a successful prediction of impacts. They just should not be performed
or considered as an add-on after-the-fact analysis of impacts.
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