Multilevel Environmental Impact Analysis - Environmental Impact Analysis: Process and Methods - page 241

r How will the CSO plan be funded? The benefit of CSO abatement
would be realized in Boston Harbor, but the majority of work and
cost would be inland, associated with a very large wastewater col-
lection system. So there was much negotiation to be done to develop
an equitable funding plan.
r If the combined sewers are replaced with a separate storm water sys-
tem, what will happen to the storm water from even the smallest
storm? As antiquated, overburdened, and dilapidated as the collec-
tion system was, it still captured the precipitation from small storms
(which are the majority of storms) and conveyed the storm water
(which flushed the urban streets) to the wastewater plant for treat-
ment before discharge away from the shore. If a separate storm water
system was created, all storm water would be discharged close to
shore, and planning a system to manage all that storm water would
take many years and thus unnecessarily delay selection and imple-
mentation of a comprehensive wastewater management solution.
Thus, delaying the complete evaluation and decision on CSOs cleared the
way to focus on overarching wastewater management issues and the provision
to allow accommodations for CSO in the overall plan removed constraints on
future CSO planning. With the CSO obstacle removed, there were still several
critical wastewater management components to be addressed, but with the
set-aside of the CSO issues, the other elements could be more easily defined
and a phased process formulated to address the other issues. The remaining
critical decisions for the comprehensive wastewater management plan were:
r Where should the wastewater be treated?
r How should the raw sewage be conveyed to the selected treatment
location?
r What was the appropriate level of treatment?
r Where should the treated effluent be discharged?
r Where and how should the residuals be stabilized?
r What should be the ultimate treatment and fate (e.g., disposal, reuse,
incineration) of the residuals?
After conceptual engineering and environmental evaluation, a consensus
was reached that an initial EIS should be initiated with a focus on where
the treatment facilities should be located. The other issues, as listed above,
would be addressed to the extent possible. But there was the realization and
acknowledgment that subsequent NEPA phases or tiers would be necessary
to address all the issues.
At the time of preparation, the initial EIS was not termed a programmatic
EIS, but in reality it was. It established the purpose and need for action,
clearly defined the issues, and evaluated the interrelationship of the issues