CHAPTER 4 ALTERNATIVES

--- “The driving impetus for conducting environmental impact studies is to comparatively present the effects of proposed alternatives which, in turn, leads to better decision making.” (p. 51) … and shall serve as the means of assessing the environmental impact of proposed agency actions, rather than justifying actions already taken (Jain et al.)

- Agencies will focus on significant environmental issues and alternatives and should reduce paperwork and the accumulation of extraneous background data (C.F.R Implementation) --- to achieve these purposes agencies shall prepare an EIS in the manner (C.F.R ).

(d) state how alternatives considered in it and decisions based on it will / will not achieve requirements of Section 101 [ Congressional Declaration of National Policy] and Section 102 [EIS] of NEPA and other relevant environmental law (e) range of alternatives discussed in EIS shall encompass those to be considered by the ultimate agency decision maker

(f) agencies shall not commit resources prejudicing selection of alternatives before making a final decision [reiterated in C.F.R Limitations on Actions During NEPA Process] … what text (p. 53) means by “… initial range of alternatives should not be limited by preconceived solutions.”.

- Because of the importance in impact analysis, study of alternatives should be thorough and systematic and include input from all interested / potentially impacted governmental / population elements

4.1 Purpose and Need - The foundation for developing alternatives is to establish in depth and conciseness: (1) deficiencies of the current situation (2) the need for specific action (3) establish explicit goals / objectives that will satisfy existing need - Written purpose-and-need will become the first section of the EA or the EIS --- it should lead clearly and methodologically to the adopted list of goals and objectives --- scope of its participation should mirror the project

4.1 Purpose and Need, cont - This sections should be treated as the “heart” of the EIS --- based on sections Affected Environment and Environmental Consequences it should present environmental impacts or proposal and alternatives in a comparative form [thus giving a clear basis for option choices by sponsoring agency and interested parties]

4.1 Purpose and Need, cont - In this section the agencies shall: 1. explore and objectively evaluate all reasonable alternatives [where alternatives have been eliminated, briefly discuss why] 2. devote substantial treatment to each alternative considered in detail [so evaluators can assess comparative merits of each] 3. include reasonable alternatives not in the jurisdiction of lead / sponsoring agency

4.1 Purpose and Need, cont (4) identity lead / sponsoring agency preferred alternative(s) (5) include alternative of no-action (6) include appropriate mitigation not already included in proposed action or alternatives 4.2 Developing a Preliminary Range of Alternatives - If Purpose and Need has been carried out, developing an initial range of alternatives follows logically

--- range should include the consideration of all possible ways to respond to identified need and established goals and objectives, including those that may be outside the jurisdiction of the sponsoring agency - These alternatives might be grouped / categorized: … No-Action… Technology … Location / Siting… Configuration … Policy

4.3 The Screening Process - The next step in the screening of initial alternatives towards a preliminary list of reasonable alternatives for scoping --- this is based on a set of preliminary evaluation criteria… including, but not limited to:

Efficiency in responding to state needs and objectives Maximum cost bases on funding Political acceptance. Engineering constraints Significant, obvious environmental effects

- The environmental study will be environmental overview of Chapter Sometimes called a constraint assessment or fatal-fault analysis, this overview investigates the proposed project / activity characteristics and location for possible severe environmental effects. For example:

Existence of an endangered species-critical habitat Wetlands destruction. Required destruction of, or alternation of, a significant visual amenity Location within a Native American religious site. Alteration of a designated floodway

- Results of initial screening will be the preliminary list of possible alternatives for the scoping process - Alternatives will continue to be screened and refined during environmental analysis to avoid or minimize potential impacts

4.4 The No-Action Alternative -In all studies, the option exists to “do nothing” … this alternative normally consists of maintaining the existing or proposed future condition, with no significant capital outlay - Although the No-Action Alternative, by definition, will not respond to stated needs or meet goals/objectives,

It cannot be dropped from the list of alternatives considered in environmental studies or from the environmental document … if for no other reason, this option becomes a baseline for comparison with future alternative actions/scenarios [i.e.: this is how things are/will be – how will each alternative affect this situation?] … the No-Action Alternative cannot just be a “now”, it must also project future characteristics without any action being taken and be aware that no-action by itself can foster adverse impacts

4.5 Contents of Draft Environmental Impact Statement and 4.6 Reassessment and Selection of Preferred Alternative [Really nothing new in these sections. Discussed extensively in NEPA Section 102 material in Introduction and Chapter 1 and additional introduction in Chapter 3]

4.7 Contents of Final Environmental Impact Statement - Alternatives section of FONSI of FEIS focuses in the preferred alternative --- procedures of, and reasons for, selection or elimination should be given detailed coverage --- alternatives introduced in the DEIS but not selected should be summarized and a clear statement for reason of dismissal provided - Afterwards, FEIS is circulated to all agencies and individuals commenting on DEIS - Public announcement of completion and 30 days review period for additional comment

4.8 Record of Decision - Prepared after the EIS review period - Usually ends the NEPA EIS procedure - Written to be a concise record of: (1) the decision made (2) identification of all considered alternatives, specifying the alternative that was environmentally advisable (3) discussion of preferences among alternatives and the basis for each preference (4) a statement on practical means to avoid/minimize environmental harm from the selected