Coordinating and Managing the Environmental Impact Analysis Processes - Environmental Impact Analysis: Process and Methods - page 346

such agency representatives on the technical advisory committee to ensure
methods satisfactory to subsequent permitting activities are employed and
get an early read on the permitability of various aspects of alternatives. Of
course, having full environmental analysis participation and cooperation of
those who will ultimately issue the permit will expedite and simplify the
permitting process for the proposed action.

9.2.3 Environmental Analysis in Support of Environmental Permitting

Many of the requirements and procedures for permit approvals are based
on environmental evaluations in addition to meeting standards, and the
comprehensive environmental impact analysis conducted before selecting
a proposed action can fulfill these requirements. Thus, early identification
of the permits is necessary and any evaluations required for issuance of the
permits included in the comprehensive environmental impact analysis pro-
cess is essential. Similarly as pointed out earlier, involvement of the permit-
ting personnel in scoping and other aspects of the analysis process is critical.
Again the Clean Water Act provides perhaps the best example of the
overlap in analysis and permit activities. Section 404 of the Act identifies
wetlands protection, and Section 404(b)(1) identifies some of the specific con-
ditions that must be met to obtain a permit for activities potentially affecting
wetlands. Under Section 404(b)(1) no discharge of fill material into wetlands
shall be permitted if:

r There is a practicable alternative to the proposed discharge which
will have less adverse impact on the aquatic ecosystem.
r It violates state water quality or toxic effluent standards.
r The fill jeopardizes the continued existence of an endangered or
threatened species.
r It violates the protection of any marine sanctuary.
r It will cause or contribute to significant degradation of the waters of
the United States.
r Appropriate and practicable steps have not been taken which will
minimize potential adverse impacts on the aquatic ecosystem.
r The proposed action, as determined by the U.S. Army Corps of
Engineers, is water dependent and requires siting in waters of the
United States.
r An upland alternative does not exist which will involve less wet-
lands impacts.

Most, if not all, of these provisions are embodied in the methods and pro-
cedures which must be conducted for a technically sound and defensible
environmental impact analysis. The primary goal of environmental analysis