Summary of the National Environmental Policy Act and Implementing Regulations - Environmental Impact Analysis: Process and Methods - page 45

on the draft EIS and subsequent negotiations with the agency proposing the
action do not address the concerns through the Clean Air Act Section 309
EPA Review procedures, EPA has the option of elevating the issue to the
CEQ, as described above, at the final EIS stage.
EPA's rating system, as described in detail in U.S. EPA (1984) procedures
for the review of federal actions and summarized below, addresses both the
technical adequacy of the environmental analysis and the level of impact of
the federal agency action. The rating categorizes are: 1 - adequate; 2 - insuffi-
cient information; or 3 - inadequate. A rating of 1 indicates no further data or
analysis is necessary. A rating of 2 is applied if the draft EIS does not contain
enough information to fully assess environmental impacts or a new reason-
able alternative has been identified by EPA that could reduce the adverse
environmental impacts of the proposal action. The EPA expects the federal
agency preparing the EIS to address the 2 rating on the draft in the FINAL
EIS. The lowest rating (3 - inadequate) indicates that the purposes of NEPA
are not met in the draft EIS and a supplemental or revised draft EIS should
be produced and made available for public comment.
The impact level of a proposed federal agency action is assigned one of the
four ratings:
r LO (Lack of Objections): The predicted impacts of the proposed
action are consistent with the goals of NEPA and other environmen-
tal regulations.
r EC (Environmental Concerns): The proposed action will result in
adverse environmental impacts that should be avoided and there
are changes available to the preferred alternative or mitigation mea-
sures that can reduce the environmental impact to levels consistent
with the goals of NEPA and other environmental regulations.
r EO (Environmental Objections): The proposed agency action will
result in significant environmental impacts and avoidance of the
impacts may require substantial changes to the proposed action,
selection of a different alternative, or implantation of substantial
mitigation measures. Impacts forcing an Environmental Objection
rating can include:
- Violation of or inconsistency with an environmental standard.
- Violation of the proposing federal agency-specific environmen-
tal requirements in the areas of EPA's jurisdiction or expertise.
- Violation of an EPA policy declaration.
- A precedent would be set by the proposed action that if left
unchecked could cumulatively result in significant environmen-
tal impacts.
r EU (Environmentally Unsatisfactory): EPA believes the proposed
action will result in adverse impacts to the degree that the action