Multilevel Environmental Impact Analysis - Environmental Impact Analysis: Process and Methods - page 235

sometimes narrowly limit the scope of subsequent documents implement-
ing specific aspects of the program as long as they adhere to the protocols
established in the programmatic evaluation. In some cases, a commitment to
following the protocols and implementing the mitigation measures can even
eliminate the need for individual environmental impact analysis for certain
specific actions.
A similar approach has been successfully applied integrating program-
matic analysis and CATEX (see Sections 3.6 and 5.4.5). After environmen-
tal analysis, stakeholder input, and development of environmental impact
mitigating measures, certain program components can be shown to have no
impact. These actions can then be added to a federal agency's or equivalent
organization's list of actions excluded from the need for individual environ-
mental impact analysis. Thus, when implementation of these program com-
ponents is initiated, a separate environmental impact analysis may not be
necessary.
The application of a programmatic analysis can have both advantages and
disadvantages that should be weighed and considered before it is chosen as
an approach. On the plus side, it can be very efficient by minimizing dupli-
cation, and perhaps more importantly, it facilitates evaluating impacts from
a broad perspective and a comprehensive treatment of cumulative impacts.
A programmatic analysis can also be an excellent base for subsequent tiered
documents, allowing them to work with specific stakeholder groups and
issues.
On the downside, a programmatic approach can have schedule implica-
tions. Besides the delay in preparing, reviewing, and revising the program-
matic document, subsequent site-specific evaluations can uncover details not
apparent at the programmatic level. In such cases, the process might have to
return to “go” for a comprehensive reevaluation of the program-level decisions
and impacts. Similarly, conditions, funding, goals, etc., can change between
development of the program and individual actions causing a similar return
to the start. Under NEPA the programmatic analysis is frequently a full EIS,
and EAs are adequate for the follow-up actions. Also, because environmen-
tal evaluations are often prepared by detail-oriented scientists and engineers
and followed by stakeholders with detail concerns, there is frequently a ten-
dency for the programmatic analysis to deconstruct to a detail rich process,
following multiple “rabbit trails” and deviating from the original intent of a
broad-scale analysis. This can severely delay the process and simultaneously
frustrate project proponents and stakeholder groups.
The tiered environmental impact analysis is the logical follow-up to a pro-
grammatic approach. As in the above hypothetical example of the National
Park or Forest land use plan, the programmatic evaluation establishes an
overarching proposed action, and the subsequent tiered analyses address
individual actions in detail. These individual actions are addressed by con-
sidering site-specific conditions to the point of frequently implementing
data collection programs (e.g., biological sampling, water quality surveys,