NEPA Process and Specific Requirements - Environmental Impact Analysis: Process and Methods - page 68

archaeological investigations that were done for the draft and final EIS and
resulted in a final project design that mitigated cultural and natural resource
impacts to the satisfaction of the commenting resource agencies.
The time between issuance of the final EIS and ROD gives the opportunity
for federal agencies proposing the action to express and resolve any final
concerns or conflicts among sister agencies. If the federal agency propos-
ing the action has not responded in the final EIS to draft EIS comments by
another federal agency with resource jurisdiction or expertise to their satis-
faction, the responses can be included in the ROD to address the concerns. If
an agreement cannot be worked out in the ROD, the issue can be elevated to
the CEQ (see discussion above) which is the least desirable alternative to all
involved. As in the above example, if the U.S. Air Force had not committed
to mitigation in the ROD, the U.S. Forest Service in all likelihood would have
elevated the issue to CEQ which could have required a supplemental EIS to
work through the issue which could have delayed this fast-track project by
a year or more.

3.1.4 Environmental Assessment and Finding of No Significant Impact

If the potential for “Significant Impact is Not Known” (Figure 3.1 and affir-
mative response to question number 3 “There probably will be some level
of impact resulting from the action, but we don't know enough to assess the
likelihood or severity of the impact”) by the federal agency proposing the
action, the CEQ Regulations include a procedure for determining the level of
significance of anticipated impact without a full EIS. As discussed above, if
the agency knows from implementing similar actions or by other means that
the proposed action has a high likelihood of creating significant environ-
mental impacts, they must prepare an EIS. Similarly if they know from past
experience the action will not have a significant impact, a CATEX will satisfy
NEPA requirements. If the proposed action falls between these two extremes
and the level of impact is unknown, CEQ Regulations call for the agency to
prepare an EA to make the decision.
Similar to an EIS, an EA is a decision document for the federal agency pro-
posing the action. But in contrast to an EIS, where the decision is whether and
how to proceed with the proposed action, the decision addressed in the EA
is, “will the proposed action result in a significant environmental impact?”
In order to address this question an environmental impact analysis must be
conducted and the EA is the procedure prescribed by the CEQ Regulations
for the analysis. The basic approach and structure for the analysis should
be similar to that of an EIS and methods discussed in Chapters 4 and 5. An
EA is similar to an EIS in that the primary goal of both documents is to fur-
ther the intent and goals of NEPA; however, an EA has an additional goal
of determining whether there would be significant impacts, and if so a full
EIS is required. If not, the EA is the appropriate NEPA environmental impact