Environmental Engineering Reference
In-Depth Information
redirect efforts as early as possible if necessary due to changed conditions or
new information. It is essential to the successful completion of the analysis
and EIS, and should be a tool and skill every NEPA practitioner has mas-
tered. The analysis plan and schedule is so important and so often ignored,
it is afforded an entire section of this topic (Section 9.3.2).
3.1.3.2
Draft EIS Environmental Analyses
The draft EIS documents the analyses conducted to support the intent of
NEPA, and thus must meet a high level of scientific and objective scrutiny.
The critical technical analyses supporting impact prediction and appropri-
ate methodologies to conduct them are generally identified during scoping.
These technical evaluations are comprised of literature review, field data col-
lection, laboratory testing, and modeling of existing and future conditions.
These technical evaluations are typically the first activities initiated as part
of the EIS preparation because they have the longest lead time. The detailed
methods of any investigation should be reviewed and accepted by the appro-
priate stakeholders. This generally insures not only a superior investigation,
but when the results are obtained they should be acceptable to the key tech-
nical stakeholders. Also they should be satisfactory to stakeholders in gen-
eral because they have been blessed by independent, non-agency, non-EIS
team technical experts.
There is also significant preparation work with respect to securing equip-
ment, laboratory contracts, and logistical planning for detailed investiga-
tions; thus obtaining concurrence with the investigation methods from key
stakeholders early in the process is critical. These detailed investigations into
natural systems are required frequently to address conditions in multiple
seasons or at least key seasons, such as breeding times for sensitive biologi-
cal resources. It is a sad day (and experience shows it has happened more
than once) when scoping identifies a critical sampling period for a biological
resource or water quality and that period ended yesterday. Thus the sam-
pling cannot be completed until the same time next year! Thus anticipation
of such situations and initiation of critical time-sensitive investigation as
soon as possible can be an essential element in maintaining the EIS schedule
and maximizing efficiency.
The results of the investigations and the methods used are best documented
in detail in appendices to the EIS and the results summarized in the body of the
document. This approach satisfies the CEQ's brevity and readability require-
ments: the CEQ Regulations specify brevity and call for EISs to be 150 pages
or less for most agency actions and not more than 300 pages for unusual or
complex proposals. Use of appendices also satisfies a common sense approach
because the majority of stakeholders do not want to read extensive, highly
technical discussions of every environmental resource potential affected.
Their interest is in the results, and the individual appendices can be delegated
to experts in the specific discipline for review and comment.
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