Environmental Engineering Reference
In-Depth Information
noise monitoring, traffic counts). It would be very rare for a programmatic
analysis to include original data collection because the scope and geographic
area are typically too large for representative sampling or monitoring. The
tiered analysis also includes detailed development of the proposed action
and alternatives frequently to the point of preliminary engineering and flag-
ging locations in the field. It defeats the purpose of a program-level analysis
to go to this level of detail.
6.2.4
Piggyback Environmental Analysis
In the early 1970s, there was no such thing as piggyback environmental
analysis because NEPA was the only game in town and there was nothing
to ride on the back of a NEPA EIS. However, as other environmental analy-
sis programs, regulations, and legislation were put into place, the potential
for duplicative and sometimes contradictory analyses between NEPA and
other programs such as state environmental requirements developed. For
example, based on comments on the draft environmental analysis docu-
ment for the state program, the proposed action could be modified. The par-
allel federal EIS would then have to be reissued in draft form to reflect the
changes and there was nothing to prevent repeating this scenario between
the two separate documents, causing a do-loop and associated frustration
and delays.
The need for coordination was recognized in NEPA (Section 104,
42 U.S.C. §4334), the Council on Environmental Quality (CEQ) Regulations
implementing NEPA, and the several international environmental pro-
grams. Specifically, the CEQ Regulations specified in NEPA Section 1506.2
(Elimination of duplication with state and local procedures) require:
r Federal agencies to cooperate with state and local agencies to the
fullest extent possible to reduce duplication.
r Cooperation be included in the planning, research, public outreach,
and environmental documentation.
r Development of joint impact statements with state and federal agen-
cies identified as joint lead agencies.
r Identifying and discussing any inconsistencies with state or local
plans or laws in federal EISs and where appropriate the approach to
address the inconsistencies.
However, initially there were no or only poorly developed state or local
environmental programs and it was not possible for federal agencies to fully
meet the intention of the CEQ Regulation with regard to coordination or
“piggybacking” with other environmental regulations.
Currently, many state programs are well developed with a history of suc-
cessfully meeting the goals of NEPA, and in recognition of the state programs,
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