Summary of the National Environmental Policy Act and Implementing Regulations - Environmental Impact Analysis: Process and Methods - page 30

USAID employs a phased approach to addressing NEPA requirements by
first preparing an “Initial Environmental Examination.” This examination
results in a “Threshold Decision” concluding: (1) no significant environmen-
tal effect and no further NEPA action or (2) there is significant effect and
either an EA or EIS must be prepared. Generally for other federal agencies
and for actions within the United States, the potential for a “significant envi-
ronmental effect” is the trigger for a full EIS, and an EA will suffice if there is
no indication of signiicant impact (see Section 3.1 of the topic). However, the
unique circumstances governing NEPA compliance in international situa-
tions and USAID's mission prompted the agency to identify a different crite-
rion defining when to prepare an EA and when to prepare an EIS. For USAID
actions, a formal NEPA document (an EA or EIS) is prepared only if cat-
egorically included or if there is a “significant environmental impact” on the
physical or natural environment (i.e., not the built environmental or social
resources). An EIS is required only in one of the three specific situations:
r If there is an impact on the global environment (e.g., international
ocean areas, Mediterranean Sea) or areas outside the jurisdiction of
any nation (e.g., Antarctica).
r If the agency action would have a significant impact on the environ-
ment of the United States.
r At the discretion of the USAID administrator.
In all other cases of significant impact, an EA is the designated environmen-
tal impact analysis procedure and document under the USAID NEPA program.
The intent of this system is to force consideration of the natural environ-
ment within a host country when USAID takes action in that country but
is not to be subject to the full public participation and disclosure require-
ments of a standard EIS prepared for a project in the U.S. This is because in
many countries where USAID provides support, the democratic principles
and practices have not matured to the point of making public participation
and disclosure a common practice. Implementing such procedures for envi-
ronmental concerns when they are not part of the host country's treatment
of other issues could cause difficulty for the government of the host country
as well as the U.S. State Department.
Does NEPA apply in international situations? Yes, but there are several
limitations, restrictions, exemptions, and constraints. There is a legitimate
effort to protect the global commons and also a strong commitment to pre-
vent NEPA from interfering in critical and sensitive relationships with for-
eign countries. Experience has shown that if NEPA procedures would apply
if the federal action was implemented within the boundaries of the United
States and if the country where the action would occur sees the benefits of
applying NEPA, then the federal agency proposing the action will conduct a
thorough environmental analysis. If there are implications to foreign affairs
or relations with the host country, particularly as determined by the U.S.