Coordinating and Managing the Environmental Impact Analysis Processes - Environmental Impact Analysis: Process and Methods - page 342

9.2 Integrating Environmental Approvals and Analysis

Environmental protection under the National Environmental Policy Act
(NEPA), as well as other programs as discussed in Chapter 8 has evolved into
a two-pronged approach. The first is the analysis phase, as described in the
preceding chapters, and is aimed at understanding the environmental impli-
cations of a proposed action before they occur. This phase, when conducted
properly and comprehensively, can do much to understand the impacts and
lay the groundwork for environmental protection. But just analyzing and
understanding the impacts alone does not guarantee full environmental
protection. The second phase, environmental approvals and permits, is a
companion to environmental analysis, and when fully coordinated, the two
can maximize environmental protection.
The primary goal of environmental analysis is to understand the conse-
quences of an action prior to implementation, but the intent of environmen-
tal permits is to protect the resource. The European Union (EU) has almost
by default developed a system of both analysis and resource protection (see
Section 8.4) with a tiered approach to analysis and a series of resource-specific
policies, goals, and protection. However under the EU program, the resource
policies and regulations are only weakly enforced and there is no strong incen-
tive or mechanism to closely link the analysis and environmental approval
process. Thus the potential environmental protection and impact avoidance
have not been maximized under the EU system, but there is a strong move-
ment in that direction. Under NEPA and individual state programs in the
United States, there has been more success in integrating the two approaches
to maximize protection and ensure adherence to environmental policy. The
integration starts with the analysis phase, but prior to a discussion of inte-
gration approaches, a summary of concepts and examples of environmental
permits and approvals is presented here to put the integration in perspective.

9.2.1 Environmental Permits and Approvals

Environmental legislation defining the need for permits or other approvals
not only establishes the policy for resource protection, but it also mandates
the development of regulations. These regulations lay out specific proce-
dures to follow before an activity potentially affecting an environmental
resource can be approved and moved to implementation. In contrast to envi-
ronmental analysis, which is broad, comparative, 100% completed prior to
implementation, and generally does not mandate specific actions to achieve
environmental protection, the environmental permitting process:

r Establishes specific conditions that must be met to protect an environ-
mental resource
r Sets rules that must be followed