Coordinating and Managing the Environmental Impact Analysis Processes - Environmental Impact Analysis: Process and Methods - page 345

requirements to protect different aspects of the resource. Again using the Clean
Water Act as an example, there are approvals required for multiple activities
such as dredging and filling, waste water discharges, and storm water man-
agement. Similarly, under the Safe Drinking Water Act (42 U.S.C. §300f et seq.)
there are requirements for disinfection, storage of finished water, and accept-
able levels of chemicals and pathogens in potable water.
9.2.2 The Role of Environmental Permits in Environmental Analysis
A primary role of permits in environmental analysis is the establishment of
impact significance criteria (as discussed above in Section 5.3.2). Most envi-
ronmental permits and approval procedures include very specific standards
or requirements and these can form metrics against which to judge an alter-
native's degree of impact during the environmental analysis. Thus, identify-
ing what approvals may be required and the standards that must be met for
approval must be an early step in the analysis and built into the scope and
impact prediction steps in the analysis. For example, if achievement of the
purpose and need requires a wastewater discharge or air emission approval,
the requirements of the permit can form the basis for the impact significance
criteria for aquatic and air-quality environmental resources. If wetlands are
involved, the allowable square meters of fill allowed can define the threshold
of a significant impact.
Other areas of analysis and environmental approval integration are screen-
ing, development, and comparison of alternatives. If an alternative directly
affecting an environmental resource protected by legislation does not meet the
criteria established for an approved permit, it can be screened out early in the
process. Similarly, the permit requirements can be used to establish broader
screening criteria. For example, if the purpose and need requirement is for san-
itary wastewater treatment for a municipality, and the NPDES permit requires
secondary treatment, all wastewater treatment sites too small to construct the
required level of treatment can be eliminated at the screening stage. The permit
requirements can also be major factors in developing alternatives by defining
the level of performance, degree of treatment, and other requirements.
The comparison of alternatives can benefit from integration of permit
requirements into the environmental impact analysis in two ways. The mea-
surement of an alternative against the impact significance criteria based on
permit requirements puts the comparison on a common basis across differ-
ent alternatives and environmental resources (Figure 5.12). Also, the com-
plexity, duration, and likelihood of success of permit approval can be a major
selection factor in the alternative comparison.
Identification of key stakeholders is the other area where environmental
permitting comes into play during the impact analysis process. If a permit
is ultimately required, representatives of the issuing authority should be
contacted directly during scoping to get their early input on scope of the
analysis and identification of alternatives. It is also standard practice to have