Summary of the National Environmental Policy Act and Implementing Regulations - Environmental Impact Analysis: Process and Methods - page 21

analysis, comparisons such as air quality benefits versus adverse effects on
community noise levels, or highway traffic versus brook trout habitats are
inevitable. Using a degree of common methodology, such as significance cri-
teria (see Chapter 5), is an important analysis approach that facilitates an
integration of disciplines to compare alternatives and make decisions that
balance effects on critical environmental resources.
Using a similar level of detail, accuracy, and precision to investigate
resources with similar levels of impact is another aspect of an interdisciplin-
ary approach that facilitates comparison of alternatives and decision mak-
ing, and adds to the objectivity of an environmental analysis. If two parallel
environmental attributes (e.g., endangered species and historic properties)
have the potential to be similarly impacted by a proposed action, the level
of investigation of each should be similar. If one attribute is analyzed using
extensive data collected from existing conditions, laboratory tests, and math-
ematical modeling of predicted impacts while the other is evaluated only
qualitatively, the formulation of alternatives, impact comparisons, trade-offs,
and mitigation affecting these resources will be biased.
The next NEPA requirement (Sec. 102 B) is unique in that it is not proj-
ect-, policy-, or program-specific but addresses agency-wide obligations.
NEPA includes a requirement for all agencies of the federal government
to develop methods and procedures to ensure that “presently unquanti-
fied environmental amenities and values” (42 U.S.C. 4332 Sec. 102 B) are
considered appropriately when the agencies make decisions that could
affect the environment. Since environmental analysis was in its infancy
when NEPA was enacted, there was no accepted overall approach for a
comprehensive, integrated, and interdisciplinary environmental impact
analysis and for incorporating environmental concerns into agency deci-
sions. The requirement to develop methods and procedures was intended
to address the deficiency. This has been interpreted as requiring some
level of research into the environmental effects of actions within an
agency's jurisdiction: for example, the health effects of radiation by the
Nuclear Regulatory Commission, wildlife effects of prescribed burns by
the Forest Service, or noise effects on communities by Air Force flight
training missions.
The research requirement specified consultation with CEQ in developing
these methods, but in practice each agency has proceeded independently
with responsible agencies taking the lead in certain areas. Environmental
resource agencies, such as the Fish and Wildlife Service, National Marine
Fisheries Service, and state historic preservation officers have developed
methods for quantifying and evaluating resources under their protection
and jurisdiction. The U.S. EPA has also taken the lead in developing inves-
tigation and evaluation methods in the aquatic environment, primarily due
to their responsibility in issuing National Pollution Discharge Elimination
System (NPDES) permits and other responsibilities under the Clean Water
Act. The U.S. EPA did extensive toxicity testing and developed protocols to