Coastal Services Center

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An Assessment of the NEPA Cumulative Impact Assessment Methodologies as Related to Beach Nourishment Projects

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Assessment of the cumulative impacts of U.S. Army Corps of Engineers (USACE) beach nourishment projects is a complex endeavor that has received increased levels of attention from the public, regulatory, and scientific communities during the last several years. However, an effective and defensible assessment of cumulative impacts is a complex challenge and is not easily achieved because of the natural variability of ecosystems, and the associated scientific problems of making accurate predictions of impacts. The issue is further complicated by the interaction of the impacts of a proposed project with those of past, existing or reasonably future projects in the vicinity and region. This is the essence of the issue surrounding the difficulties associated with the assessment of cumulative impacts.

The National Environmental Policy Act Council on Environmental Quality (CEQ) provides guidelines and methodologies for assessing cumulative impacts (CEQ 1997) that have been incorporated by the USACE on several recent major projects such as the Broward County beach nourishment project in Florida (USACE 2002). The USACE has also been very active at a broader level in an effort to incorporate and develop cumulative impact assessment techniques into the planning process. However, a significant amount of controversy still exists regarding the degree and nature of cumulative impacts of beach nourishment projects. Consequently, the USACE and other agencies are interested in improving their assessment methodologies to enable better prediction of potential cumulative impacts. As a result, this paper has been prepared by NOAA as part of this web page forum in order to summarize information on the latest approaches used by the USACE and other agencies to assess cumulative impacts.

The specific objectives of this paper are: (1) to describe the context in which cumulative impacts are assessed under NEPA and the CEQ guidelines; (2) to describe the methodologies currently employed by the U.S. Army Corps of Engineers (USACE) to assess the cumulative environmental impacts of beach nourishment projects; and (3) to provide an overview of how other federal agencies address cumulative impacts of these and other types of projects. The intent of the paper is to illustrate the complex nature of assessing cumulative impacts in an effort to communicate this information to decision makers and the public on this web page forum. As such, the paper has been prepared as a means of augmenting the information on the National Environmental Policy Act (NEPA) and Section 404 Clean Water Act (CWA) permitting presented in two other documents in this series (please refer to the other papers on NEPA and Section 404 topics in this series). These papers dealt with the broader processes of assessing the effects of beach nourishment process in the context of NEPA and the Section 404 permitting process. Since cumulative impacts are an important emerging issue surrounding the assessment of potential environmental effects of beach nourishment projects, this additional paper has been included on the web page as part of the overall project.

The importance of adequately addressing cumulative impacts was summarized in the 1997 CEQ report entitled ""Considering Cumulative Effects Under the National Environmental Policy Act, Council on Environmental Quality, Office of the President" (January 1997)(CEQ 1997)(web site) as follows:

"Federal agencies have struggled with preparing cumulative effects analyses since CEQ issued its regulations in 1978. They continue to find themselves in costly and time-consuming administrative proceedings and litigation over the proper scope of the analysis."

"Court cases throughout the years have affirmed CEQS requirement to assess cumulative effects of projects but have added little in the way of guidance and direction."

"To date [1997], there has not been a single, universally accepted conceptual approach, nor even general principles accepted by all scientists and managers."

"One study analyzed 89 EAs announced in the Federal Register between January 1, 1992, and June 30, 1992, to determine the extent to which treatment of cumulative effects met CEQS requirements (Figure 1). Only 35 EAs (39%) mentioned cumulative effects. Nearly half of those failed to present evidence to support their conclusions concerning cumulative effects" (McCold and Holman 1995 in CEQ 1997).

The present paper has therefore been developed as a means of providing additional, more detailed information on the issue of how cumulative impacts of beach nourishment projects are assessed, within the context of this web page forum.

This paper provides the following specific information:

Description of the Context in Which Cumulative Impacts Are Assessed: This section provides definitions of the terms "cumulative impact," "direct impact," and "indirect impact" as used in NEPA Environmental Impact Statements (EISs) and Environmental Assessments (EAs), and the regulatory and legal framework within which these impacts are required to be addressed.

How are Agencies Currently Addressing Cumulative Impacts?: This section describes the approaches used by the USACE and other agencies in addressing cumulative impacts, including a detailed summary of the specific 11-step approach currently being used by the USACE to assess cumulative impacts of beach nourishment projects, as well as a summary of broader scale programs and approaches used by the USACE to address cumulative impacts of beach nourishment projects. Methods used by the U.S. Environmental Protection Agency (EPA), CEQ, National Marine Fisheries Service (NMFS), U.S. Fish and Wildlife Service (USFWS), and the National Park Service (NPS) to address cumulative impacts are also summarized.

References: A set of references (including web page addresses) on cumulative impact assessment methodologies under NEPA is provided.

Description of the Context in which Cumulative Impacts are Assessed

NEPA provides the broader context for assessing cumulative impacts. NEPA and CEQ’S regulations require defining cumulative impacts within the context of the proposed action, alternatives, and effects. The CEQ guidelines require the following approach:

"By definition, cumulative effects must be evaluated along with the direct effects and indirect effects (those that occur later in time or farther removed in distance) of each alternative. The range of alternatives considered must include the no action alternative as a baseline against which to evaluate cumulative effects. The range of actions that must be considered includes not only the project proposal but all connected and similar actions that could contribute to cumulative effects. Specifically, NEPA requires that all related actions be addressed in the same analysis" (CEQ 1997).

In practice, The Council of Environmental Quality (CEQ) regulations for implementing NEPA (40 CFR 1508.7) require that three basic types of impacts be addressed as part of an Environmental Impact Statement or Environmental Assessment:

Direct impacts: Direct impacts are those impacts that result from short-term and long-term changes in the environment brought on by the primary action. A direct effect of a beach nourishment project, for example, would include an immediate elimination of benthic habitat by placement of beach sand. This would constitute a short-term impact, but could also be a long-term impact depending on local conditions.

Indirect impacts: Indirect impacts are those that are caused by secondary economic growth that is induced by a proposed action. An indirect effect of a beach nourishment project might be, for example, the effects of increased stormwater runoff in a coastal area on water quality caused by growth associated with the improvement and extent of beaches. This would be a long-term impact since the runoff would be essentially a permanent change.

Cumulative impacts: The CEQ regulations define a cumulative impact as the "impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (federal or non-federal) or person undertakes such other actions." They can also be defined as the sum ("z") of the proposed action ("x") plus all other past, present, and reasonably foreseeable future actions ("y"). In this approach, x + y = z. Example cumulative impacts are shown in Table 1-1, taken from the CEQ publication on cumulative impact assessment (CEQ 1997).

These definitions have been provided to present the basic context within which cumulative impacts are addressed under NEPA. NEPA regulations require that all three types of impacts be addressed in the EIS or EA. As pointed out previously, in the early days of NEPA, the majority of the focus in many EISs and EAs was on the direct impacts of a proposed project, with less attention and detail (or none) provided on cumulative impacts. For example, many Environmental Assessments in the past have never even included a summary of cumulative impacts (CEQ 1997)(please refer to Figure 1-2 from CEQ 1997, which provides the results of a study of how many EAs included an assessment of cumulative impacts). As the potential importance of cumulative impacts has become more recognized, however, increased attention has been given to indirect and cumulative impacts according to the intent of the CEQ guidelines. In the case of beach nourishment projects, a significant amount of attention has recently been focused on cumulative effects. This phenomenon has not been limited to USACE beach nourishment projects, however, and many agencies are currently developing new and improved approaches to address cumulative impacts more effectively. The approaches used by various agencies in addressing these types of impacts are addressed in the next section of this paper.

How are Agencies Currently Addressing Cumulative Impacts?

This section provides a summary of how the USACE, USEPA, CEQ, USFWS, NMFS and the NPS address cumulative impacts. Since the major focus of this paper is on beach nourishment projects, the major emphasis is placed on the approach that has been developed by the USACE. Information on approaches being used by other agencies is also provided to illustrate how this is an important issue to those agencies, and in general what their approach is. All approaches have the objective of meeting the intent of the CEQ regulations for implementing NEPA (40 CFR 1508.7), however.

USACE Methods of Assessing Cumulative Impacts

The USACE has made a major effort in the last several years to improve the methodology for assessing cumulative impacts of large beach nourishment projects during the preparation of their NEPA EIS and EA documents. This effort has been developed partially in response to comments made on recent USACE NEPA EIS and EA documents by the US Environmental Protection Agency and other agencies concerned about potential cumulative impacts, as well as in response to comments made by private citizens and academia. The papers in this series entitled on NEPA compliance discuss the types of comments made on this issue.

The USACE has developed a methodology that adheres to the 11-step approach defined in the CEQ publication entitled "Considering Cumulative Effects Under the National Environmental Policy Act, Council on Environmental Quality, Office of the President" (January 1997). The following is a summary of this process (please refer to this pdf document for a detailed example of the actual implementation of this methodology to a USACE beach nourishment project in Broward County, Florida)(USACE 2002).

1. Identify Significant Cumulative Effects Issues and the Assessment Goals.

Identify the "direct and indirect effects of the proposed action"; "which resources, ecosystems and human communities are affected," and "which effects on these resources are important from a cumulative effects perspective." Focus analysis on "important issues of national, regional, or local significance"… through the scoping process (CEQ 1997). Summarize the rationale for identifying the cumulative effects and the results of the process of identification of cumulative impact issues and the assessment goals. Table 1-1 from CEQ (1997) summarizes typical cumulative impact issues faced by federal agencies on various types of projects. Table 1-2 from CEQ (1997) summarizes the main characteristics of cumulative impacts. Tables 1-3 and 1-4 from CEQ (1997) summarize examples of cumulative effects and types of cumulative effects, respectively. Table 1-5 from CEQ (1997) provides a summary overview of the CEQ approach to assess cumulative impacts. Table 2-1 from CEQ (1997) summarizes an approach for identifying potential cumulative effect issues for a project.

2. Establish the Geographic Scope.

Describe the geographic scope of the proposed action and why it is appropriate (methods, rationale, and results). Note that different affected resources may have different geographic scopes of impact. Expand the geographic scope of the proposed action sufficiently to include potential other actions in the area that might lead to cumulative impacts worthy of note. The scale should focus on level of landscapes, watersheds, air sheds, or human communities, as opposed to, for example, counties, installation boundaries, or resource management units. Table 2-2 from CEQ (1997) provides examples that can be used.

3. Time Frame.

Describe the time frame and explain why the time frame was selected (methods, rationale, and results). The time frame as projected into the future should not go to the point of shear speculation or to the point at which prediction would be too unreliable. As in the case of the geographic scope, the time frame could be different for different resources, and expanded to take cumulative effects on a broader scale into consideration. Figure 2-2 from CEQ (1997) can be used as a basis for organizing information on assessing time frame for a cumulative impact assessment.

4. Other Actions Affecting the Resources, Ecosystems, and Human Communities.

Define other actions in the vicinity of the proposed project that could also have potential effects on natural and cultural resources. These should include any type of action that when taken together with the proposed beach nourishment project, could lead to cumulative effects. A schematic diagram can be developed for this purpose using GIS or simple mapping techniques. The diagram or map shows the location of the proposed action in relation to other facilities or projects, disturbed areas, or human communities in the area. The diagram is useful as a means of showing potential overlap between these areas and the proposed project.

This requires application of a cause and effect analysis. Actions can be excluded from the cumulative impact analysis if they are outside the establish sphere of influence as shown on the diagram or they are outside the established time frame (Step 3), the action would not affect resources that are the subject of the cumulative impact assessment, or if including the action would be arbitrary (CEQ 1997).

5. Characterize the Resources, Ecosystems, and Human Communities Identified During Scoping in Terms of Their Response to Change and Capacity to Withstand Stresses.

In this step, the existing condition of the potentially affected system and the ability to withstand change are characterized and used as the basis for estimating the potential cumulative impacts of the proposed project in conjunction with other actions (methods, rationale, and results). This involves the following steps:

• Application of scientific analyses to obtain an objective description of the current ecological status of the potentially impacted area,
• Identification of "common cumulative effects issues within the region";
• Characterization of "the current status of the resources, ecosystems, and human communities identified during scoping";
• Identification of "socioeconomic driving variables and indicators of stress on these resources";
• Characterization of "the regional landscape in terms of historical and planned development and the constraints of govern- human communities"; and
• " Definition of a "baseline condition for the resources using historical trends" (CEQ 1997).

6. Stresses Affecting the Resources and Thresholds.

This step involves compiling information on stress factors relating to resources, ecosystems, and human communities. Table 3-1 from CEQ (1997) provides an example of this approach for a coal mining project. The approach is based on identification of utilities/services, commercial activities and residential developments, and recreation, mining and grazing actions that actually occur or are proposed to occur in the vicinity of the proposed action. The types of environmental issues that are associated with these actions, and the location of the anticipated impacts are also assessed. Please refer to this pdf document for an example of a recent USACE beach nourishment project where a similar approach has been applied.

7. Baseline Condition.

The objective of this step is to establish the past conditions at the beginning of the time frame selected. This is not necessarily the "pristine" condition. The baseline condition is established using historical trends for the area in the vicinity of the proposed action. A major issue here is the problem associated with natural variability of ecosystems. It is an established fact that the abundance and distribution of organisms vary in space and time, making accurate measurements difficult. For example, density of benthic organisms in nearshore coastal environments is "patchy," resulting in large standard deviations of density estimates made with quadrats or similar techniques. In addition, populations vary seasonally and between years, and there are also longer term cycles in populations that result in additional levels of variation. This variation has the potential to mask the effects of a beach nourishment project ob benthic organisms, for example, and must be dealt with in the scientific assessment of impacts.

8. Cause and Effect Relationships.

Information on cause and effect relationships between stressors and resources is collected and analyzed. This is the basis for estimating the additive effects of other actions on the same resources. A simplified model is developed that predicts the effects of all known primary stressors on the resources. This model is based on important relationships that can be supported by available information. This is a best estimate using professional judgment, in effect. Figure 4-2 from CEQ (1997) is an example of such a model. The important part of this analysis is to define a "baseline condition of the resource, ecosystem or community beyond which an adverse or beneficial change would cause significant degradation or enhancement of the resource, respectively’ (CEQ 1997). This is consistent with the intent of NEPA, which requires comparison of alternative actions to the baseline, to include an assessment of how the quality of the resource has changed over time.

9. Magnitude and Significance relative to regulatory or other threshold(s)] of Cumulative Effects.

Magnitude of effects is determined by preparing a comparison of the effects of past, present, proposed and future actions in a table (Table 4-1 is an example from a biological impact assessment from CEQ 1997). This methodology involves estimate the % increase or decrease in extent or abundance of resources for past, present, proposed and future actions, and adding the percentages to obtain the total cumulative effects. This methodology is consistent with the definition of cumulative impacts given previously. This can also be done qualitatively.

Cumulative impacts can be both beneficial and adverse, depending on the circumstances. However, this approach allows the decision maker to estimate and identify incremental effects of all past, present, proposed and future actions using this approach. This allows for modification of selected actions or the agency’s preferred action, in view of the projected cumulative effects. The entire analysis is thus geared towards avoiding exceeding the ability of the resources to withstand stress.

Determining significance is based on the context of the impact and its intensity. The context of an impact refers to scale and is either site-specific, regional, national, or international. Intensity refers to "severity of effect" (CEQ 1997) and is usually defined as negligible, minor, moderate or major. The duration of impacts is either short-term or long-term. Impact frequency refers to how often is occurs.

Thresholds are typically established for defining the context, intensity, duration and frequency of impacts, including cumulative impacts. These are all ultimately based on some sort of cause and effect relationships. Because of all the various unknowns in this process, professional judgment is often employed by agencies faced with making a decision, using the best information available. Decisions are also made in the context of the NEPA review process, in which the collective judgment of scientists, engineers, planners, officials, and citizens are all employed to reach consensus on issues, impacts and solutions. Risk assessment methods and adaptive management techniques may also be employed (CEQ 1997).

10. Mitigation of Significant Cumulative Effects.

Mitigation refers to avoiding, minimizing or reducing potentially adverse impacts. Adaptive management approaches can be used to mitigate the potentially adverse impacts of cumulative actions. This requires monitoring of effects (see Step 10) and then developing appropriate mitigation measures to offset potentially adverse impacts. Adaptive management is a system that allows for recognition of potentially adverse cumulative impacts, and making appropriate policy or planning changes that will allow avoidance, reduction or minimization of impacts.

Monitoring and Management.

The ultimate goal of NEPA is to avoid, reduce or minimize potentially adverse impacts. This is achieved through monitoring and implementing of adaptive management strategies. However, monitoring is the key to achieving this overall goal because it assesses the conditions of the resources in question. Important elements of a monitoring program are as follows:

• Measurable indicators of the magnitude and direction of ecological and social change;
• Appropriate time frame;
• Appropriate spatial scale;
• Means of assessing causality;
• Means of measuring mitigation efficacy; and
• Provisions for adaptive management.

Means of Presenting Cumulative Impact Methodology in USACE NEPA Documents

Since this is a lengthy process, the results of the 11-Step process the USACE presents the following information in the main body of the EIS or EA:

"Table [22 – from USACE 2002] summarizes the impact of such cumulative actions by identifying the past, present, and reasonably foreseeable future condition of the various resources which are directly or indirectly impacted by the proposed action and its alternatives. The table also illustrates the with-project and without-project condition (the difference being the incremental impact of the project). Also illustrated is the future condition with any reasonable alternatives (or range of alternatives). Appendix D to this EA [EIS] contains more detailed information of how the cumulative impacts were examined using the 11 steps identified by the Council on Environmental Quality, 1997. ["Considering Cumulative Effects Under the National Environmental Policy Act," January, 1997, Executive Office of the President, Washington, D.C.]"

An example of this table is provided (Table 22 from USACE 2002) in this paper in order to illustrate the concept and approach used by the USACE on a recent project (the Broward County beach nourishment project). The table summarizes information on the resource, the resource boundaries, past conditions, future conditions with and without the project, future conditions with proposed action, and future conditions with alternative actions. Only the first page of this table are included here. The full table and EIS can be viewed at this address (pdf) .

An Appendix (called Appendix D – see example posted at this address (pdf)) is also included with the NEPA document. This appendix documents the technical data, definitions, and methods for assessing the cumulative impacts. The definitions and methods are taken largely from the Council on Environmental Quality (CEQ) publication "Considering Cumulative Effects Under the National Environmental Policy Act" 1997. (CEQ 1997).

The above CEQ reference also identifies 11 methods or tools for analyzing cumulative effects:

1. Questionnaires, Interview, and Panels
2. Checklists
3. Matrices
4. Networks and System Diagrams
5. Modeling
6. Trends Analysis
7. Overlay Mapping and GIS
8. Carrying Capacity Analysis
9. Ecosystem Analysis
10. Economic Impact Analysis
11. Social Impact Analysis

Appendix A of CEQ (1997) provides detailed information on each of these tools. Table 5-3 from CEQ (1997) provides a summary of the advantages and disadvantages of each method. The USACE uses these tools in varying degrees on beach nourishment projects.

The USACE also addresses the issue of cumulative impacts on a broader scale through various means. These have included the following:

The USACE has made every effort to address the cumulative effects of their activities in all environmental documentation prepared in accordance with the National Environmental Policy Act (NEPA). For example, the Wilmington District recently completed the Dare County Beaches Feasibility Study and EIS in advance of the project’s authorization in the Water Resource Development Act of 2000. The documentation reflects a close look at direct project impacts as well as the project’s relationship to the impacts of other Wilmington District shoreline project activities throughout North Carolina. The USACE has prepared many other NEPA documents on similar projects along the South Atlantic and Gulf coastal waters. All these documents address cumulative impacts as required by the NEPA and involve extensive engineering and technical analysis of alternatives.

The USACE has undertaken efforts in recent years to look at our coastal projects and their effects in a broader regional context. They recognize that such efforts will help achieve greater efficiencies and better overall results (including environmental quality) as they address complex coastal issues. Some key initiatives are summarized below.

Coast of Florida Erosion and Storm Effects Study, Region III. This study and associated EIS comprehensively addressed a geographic area that included coastal waters of Dade, Broward, and Palm Beach Counties. This study was authorized by Congress and was a cooperative effort with the non-Federal sponsor (Florida Department of Environmental Protection) and many other stakeholders and interested parties.

The State of Florida supported long range plans to work in partnership with the Corps to perform similar studies along the entire East Coast of Florida that would lead to more efficient and environmentally friendly ways of accomplishing federally authorized coastal navigation and shoreline projects.

The Florida Department of Environmental Protection (DEP) has developed a regionally based Strategic Beach Management Plan for Florida's entire shoreline. DEP has identified over 300 miles of critically eroded shoreline in Florida.

Also, the State legislature has passed a law providing a dedicated funding source in the amount of $30,000,000 each year to address critically eroding areas. The USACE is working closely with the state regarding the cost effective and environmentally acceptable implementation of their strategic plan.

The USACE has embraced the concept "regional sediment management," recognizing that coastal resource issues cannot be most effectively addressed for the long term on a project by project basis. In 1999, the Corps initiated the first of a series of Regional Sediment Management Demonstration Projects under a National Regional Sediment Management (RSM) Program. Jacksonville, Wilmington, and Mobile Districts are planning and pursuing these demonstration projects along portions of the Florida, North Carolina, and Alabama shorelines. The goals of RSM include retaining all appropriate sand resources in the littoral zone and promoting balanced natural coastal systems.

On a national scale, the Corps of Engineers has initiated planning for a National Shoreline Management Study that presents an opportunity to comprehensively examine the status of the Nation’s shoreline for the first time in 30 years. The study will provide a technical basis and analytical information useful in developing recommendations on levels of Federal and non-Federal participation in shore protection, and system approaches to sediment management. .

EPA Methods of Assessing Cumulative Impacts

EPA reviews EISs and EAs prepared by other federal agencies, and comments on the effectiveness of the cumulative impact assessment sections in these documents. EPA also prepares its own EIS and EA documents, and utilizes a specific approach for addressing cumulative impacts. The EPA approach for preparing cumulative impact analyses for its own documents is based on the previously described CEQ system (CEQ 1997). EPA has also published a summary of how it reviews the cumulative impact sections in other agency documents (EPA 2003). This document is posted at this address (pdf) and can be downloaded in its entirety. Since the basic approach used by EPA in preparing its own documents follows the same 11-step CEQ process as the USACE, this process will not be described further. However, the following excerpts provide is summary of the key elements of guidance provided by EPA for staff who review the cumulative impact sections of other agency NEPA documents:

General Comments

EPA makes the comment that "Cumulative impacts, however, are not often fully addressed in NEPA documents due to the difficulty in understanding the complexities of these impacts, a lack of available information on their consequences, and the desire to limit the scope of environmental analysis." They also refer to the CEQ (1997) handbook for assessing cumulative impacts, which is cited as the most comprehensive and up to date approach.

EPA notes that "One possible difference is that cumulative impact assessment entails a more extensive and broader review of possible effects. Reviewers should recognize that while no "cookbook" approach to cumulative impacts analysis exists, a general approach is described in the CEQ handbook.

The EPA reviewer should determine if the information presented is commensurate with the impacts of the project, i.e., a greater degree of detail is needed for more potentially serious impacts. In addition, in making its rating determinations,

"Cumulative impacts that result in significant impacts can be the basis for adverse ratings. EPA will consider cumulative impacts when determining the rating for the environmental impacts of the proposed project. Ratings should be based on the overall environmental impact of the proposed project or action, which includes cumulative impacts."

Resources and Ecosystem Components

"EPA reviewers should determine whether the NEPA analysis has identified the resources and ecosystem components cumulatively impacted by the proposed action and other actions. The reviewer can determine which resources are cumulatively affected by considering":

1. whether the resource is especially vulnerable to incremental effects;
2. whether the proposed action is one of several similar actions in the same geographic area;
3. whether other activities in the area have similar effects on the resource;
4. whether these effects have been historically significant for this resource; and
5. whether other analyses in the area have identified a cumulative effects concern."

"Three documents that can provide useful information when considering important resource components include the 1993 EPA report, "Habitat Evaluation: Issues in Environmental Analysis Review," the 1993 CEQ report, "Incorporating Biodiversity Considerations Into Environmental Impact Analysis Under the National Environmental Policy Act," and the 1994 EPA report "Evaluation of Ecological Impacts from Highway Development."

"Cumulative impacts can affect a broad array of resources and ecosystem components. In addition to considering the biological resources that are the staple of NEPA analysis, examples of other resources that should be considered include historic and archaeological sites, socioeconomic services and issues, and community structure and character. While a broad consideration of resources is necessary for the adequate assessment of cumulative impacts, the analysis should be expanded for only those resources that are significantly affected. In similar fashion, ecosystem components should be considered when they are significantly affected by cumulative impacts. The measure of cumulative effects is any change to the function of these ecosystems."

Ecosystem Components

"The NEPA document should identify which resources or ecosystem components of concern might be affected by the proposed action or its alternatives within the project area. Once these resources have been identified, consideration should be given to the ecological requirements needed to sustain the resources. It is important that the NEPA document consider these broader ecological requirements when assessing how the project and other actions may cumulatively affect the resources of concern. Often these ecological requirements may extend beyond the boundaries of the project area, but reasonable limits should be made to the scope of the analysis."

Geographic Boundaries And Time Period

"EPA reviewers should determine whether the NEPA analysis has used geographic and time boundaries large enough to include all potentially significant effects on the resources of concern. The NEPA document should delineate appropriate geographic areas including natural ecological boundaries, whenever possible, and should evaluate the time period of the project's effects."

"The EPA reviewer can determine an appropriate spatial scope of the cumulative impact analysis by considering how the resources are being affected. This determination involves two basic steps":

1. "identifying a geographic area that includes resources potentially affected by the proposed project and
2. extending that area, when necessary, to include the same and other resources affected by the combined impacts of the project and other actions."

Past, Present and Reasonably Foreseeable Future Actions

"Reviewers should determine whether the NEPA document considered all past, present, and future actions that contribute to significant cumulative effects on the resources of concern. The analysis should include the use of trends information and interagency analyses on a regional basis to determine the combined effects of past, present, and future actions."

Describing the Condition of the Environment

"EPA reviewers should determine whether the NEPA analysis accurately depicts the condition of the environment used to assess cumulative impacts. In addition, reviewers should determine whether NEPA documents incorporate the cumulative effects of all relevant past activities into the affected environment section. For the evaluation of the environmental consequences to be useful, it is important that the analysis also incorporate the degree that the existing ecosystem will change over time under each alternative."

"For the purposes of section 309 reviews, different methods of depicting the environmental condition are acceptable. The condition of the environment should, however, address one or more of the following":

1. "how the affected environment functions naturally and whether it has been significantly degraded;
2. the specific characteristics of the affected environment and the extent of change, if any, that has occurred in that environment; and
3. a description of the natural condition of the environment or, if that is not available, some modified, but ecologically sustainable, condition to serve as a benchmark."

Using Thresholds to Assess Resource Degradation

"EPA reviewers should determine whether the analysis included specific thresholds required under law or by agency regulations or otherwise used by the agency. In the absence of specific thresholds, the analysis should include a description of whether or not the resource is significantly affected and how that determination was made."

Examples of thresholds include:

"The total change in land cover is a simple indicator of biotic integrity; thresholds for areas with high alterations would generally be lower than areas that are not as degraded; if open space or pristine areas are a management goal then the threshold would be a small percentage change in land cover."

"Patch size distribution and distances between patches are important indicators of species change and level of disturbance. Thresholds would be set to determine the characteristics of an area needed to support a given plant or animal species."

"Estimates of fragmentation and connectivity can reveal the magnitude of disturbance, ability of species to survive in an area, and ecological integrity. Thresholds would indicate a decrease in cover pattern, loss of connectivity, or amount of fragmentation that would significantly degrade an area."

"Indicators of water quality and watershed integrity can be used to set thresholds. Specific concentrations and levels of nitrogen, phosphorous, turbidity, dissolved oxygen, and temperature can be used."

"Thresholds for a decline in water quality can take the form of size and amount of riparian buffer zones. Condition of riparian zones and changes in percent of buffer areas can indicate a decline in water quality due to soil erosion, sediment loading, and contaminant runoff."

USFWS Methods of Assessing Cumulative Impacts

The USFWS policies for involvement with other agencies on NEPA review are provided in their NEPA Reference Handbook (pdf document). The Department of Interior NEPA guidance policies are provided in Department of the Interior National Environmental Policy Act Procedures (516 DM 1-7)(pdf document). Service procedures for implementing NEPA are published in the federal Register at (pdf document)(Federal Register: January 16, 1997 (Volume 62, Number 11, Page 2375-2382, Department of the Interior National Environmental Policy Act Revised Implementing Procedures. Notice of Final Revised Procedures for the Fish and Wildlife Service. The USFWS Division of Habitat Conservation also issued Fish and Wildlife Manual (FWM)# 153 on June 28, 1994 as part of the series on interagency activities, Part 505: Environmental Review (web site). Part C(d) of this FWM specifies that… "An analysis of potential direct, indirect, and cumulative impacts that could occur for each alternative considered" (USFWS 1994). Part D of FWM 153 on tiering of NEPA documents, specifies that

"the CEQ's NEPA regulations (40 CFR 1502.20) encourage tiering EISs. Tiering, however, is not a substitute for the adequate assessment of site specific environmental effects. For example, a programmatic EIS must consider cumulative, direct, and indirect impacts; however, this may result in less detailed assessments of impacts than would be addressed on a site-specific EIS" (USFWS 1994).

Part F(1) of FWM 153 specifies:

"EIS reviews should include consideration of total, long-term ecological impacts, including any direct and secondary (or indirect) impacts. Also, Service reviewers should consider any cumulative effects, or possible project segmentation which could mask cumulative effects." (USFWS 1994)

"EIS reviews should include consideration of total, long-term ecological impacts, including any direct and secondary (or indirect) impacts. Also, Service reviewers should consider any cumulative effects, or possible project segmentation which could mask cumulative effects." (USFWS 1994)

The USFWS service is a primary reviewer of EISs on beach nourishment projects. The agency has specific guidelines for the process of reviewing other agency EISs. This guidance and policy is contained in Chapter 7 of the Department of the Interior Departmental Manual Part 516 National Environmental Quality Policy Act of 1969 Review of Environmental Statements Prepared by Other Federal Agencies 516 DM 7.1 (pdf document)(USWFS 2003). The following is a summary of this information:

"7.5 Content of Review Comments on Draft Environmental Statements

A. Departmental Comments:

(1) Departmental comments on draft environmental statements prepared by other Federal agencies shall be based upon the Department's jurisdiction by law or special expertise with respect to the environmental impact of the proposed action or alternatives to the action. The adequacy of the statement in regard to the Act and the Council on Environmental Quality's Guidelines is the responsibility of the Federal agency that prepared the statement and any comments on its adequacy shall be limited to the Department's jurisdiction or environmental expertise."(USDOI 2003).

"(2) Reviews shall be conducted in sufficient detail to insure that both potentially beneficial and adverse environmental effects of the proposed action, including cumulative and secondary effects, are adequately identified. Wherever possible, and within the Department's competence and resources, other agencies will be advised on ways to avoid or minimize adverse impacts of the proposed action and on alternatives to the proposed action that may-have been overlooked or inadequately treated."(USDOI 2003).

In their review of beach nourishment EISs and EAs, the USFWS is concerned primarily with potentially adverse direct, indirect and cumulative impacts on federally listed species of endangered species, as well as other fish and wildlife species. This agency is one of the major reviewers of beach nourishment EISs and EA documents, and also is a major stakeholder in the NEPA process. In the case of federally listed species, the USFWS has the authority to request formal consultation if the agency believes that significant adverse impacts might occur from project implementation. This is conducted under Section 7(1)(a) of the Endangered Species Act (16 U.S.C. 1531 et seq.}. The agency has published a Section 7 Consultation Manual that provides guidance for staff in conducting the reviews. The manual is available at this web site (USFWS 1998).

NOAA/NMFS Methods of Assessing Cumulative Impacts

NOAA/NMFS addresses NEPA requirements in Administrative Order 216-6 (Environmental Review Procedures for Implementing the National Environmental Policy Act Issued 06/03/99; effective 05/20/99)(web site). This is the most recent version of the A.O. 216-6 (the first A.O. being issued on March 10, 1983)( please refer to this web site for original A.O. 216-6). The 1999 version is "… a complete revision and update to the Order. Major changes include: "incorporation of the requirements of E.O. 12898 and E.O. 13112; addition and expansion of specific guidance regarding categorical exclusions, especially as they relate to endangered species, marine mammals, fisheries, habitat restoration, and construction activities; expansion of guidance on considering cumulative impacts and tiering in the environmental review of NOAA actions"…; and inclusion of a NOAA policies statement regarding the fulfillment of NEPA requirements. Revisions also have been made to format and content to promote clarity and ease of use. The following is a summary of key elements of this order as they relate to assessment of cumulative impacts:

"Significant Impact. A measure of the intensity and the context of effects of a major Federal action on, or the importance of that action to, the human environment (40 CFR 1508.27). "Significant" is a function of the short-term, long-term, and cumulative impacts, both positive and negative, of the action on that environment. Significance is determined according to the general guidance in Section 6.01 of this Order. Specific criteria (Section 6.02 (a) - (i) of this Order) are established to expand the general conditions for determining the significance and the appropriate course of action. Determinations of non-significance will be made by the RPM but reviewed by the NEPA Coordinator prior to clearance. All additional criteria for "significant" must be approved by the NEPA Coordinator and published in the Federal Register as amendments to this Order (40 CFR 1508.27).

NOAA/MFS defines cumulative impacts are the combined effects on quality of the human environment that result from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions, regardless of what Federal or non-Federal agency or person undertakes such other actions (40 CFR 1508.7, 1508.25(a), and 1508.25(c)). Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time.’(NOAA 2001). NOAA defines direct and indirect effects as follows:

"... Direct effects, ... are caused by the action and occur at the same time and place. (b) Indirect effects ... are caused by the action and are later in time or farther removed in distance, but are still reasonably foreseeable. Indirect effects may include growth inducing effects and other effects related to induced changes in the pattern of land use, population other natural systems, including ecosystems. density or growth rate, and related effects on air and water and other natural systems, including ecosystems."(NOAA 2001).

In Exhibit 5b of AO 216-6, NOAA/NMFS makes a reference to cumulative impacts in their assessment of whether a project qualifies for a categorical exclusion from further NEPA analysis in an EA or an EIS, as follows:

"After reviewing the proposed rule (copy attached) in relation to NOAA 216-6, including the criteria used to determine significance, we have concluded that the proposed action would not have a significant effect, individually or cumulatively, on the human environment. Further, we have determined that the proposed action is categorically excluded from the requirement to prepare an environmental assessment or environmental impact statement in accordance with Section 6.03a.3b. of NOAA Administrative Order 216-6. Specifically, this is an "action of limited size or magnitude" that does not result in a significant change in the original environmental action and involves only minor changes to the regulations." (NOAA 2001)

In the completion of NOAA programmatic EISs, the agency offers the following guidance for consideration of cumulative impacts during the scoping process. While this information has been developed to guide the agency in the preparation of programmatic EISs, this information is presented here because it sheds light on the legal, regulatory and technical complexities associated with addressing cumulative impacts. The following excerpts are provided:

"The EIS provides the scientific and analytic basis for comparing and assessing alternatives to the proposed action. It must disclose both the direct and indirect environmental effects, as well as any cumulative impacts that alternatives to the proposed action will have on the environment (See 40 CFR 1508.7and 1508.8). In this way, the EIS insures the integrity of the agency process by forcing it to face difficult issues and objections raised in the preliminary public scoping process. As such, it serves as an environmental full disclosure law allowing the public to weigh a project’s benefits against its environmental costs. As an analytical document, the EIS also serves to identify gaps in the knowledge base of the action."(NOAA 2001)

The memorandum goes on to specify:

"A programmatic EIS (hereinafter also referred to as a PEIS) is the comprehensive document in which the Agency considers a number of related actions or projects being decided within one program. As such, a PEIS looks to the environmental consequences of a program as a whole. One of its purposes is to assess the impact of connected and cumulative actions under one programmatic umbrella in order to determine significant impacts to the environment. In it, the analysis of environmental impacts is tied to a specific program and the individual and cumulative effects of each project individually, and all projects together, are analyzed in a way which allows senior level decision makers to examine the implications of their programs. As stated in Northcoast Environmental Center v. Clickman, 136 F.3d 660 (1998), .".. a programmatic EIS is superior to a limited, contract-specific EIS because it examines an entire policy initiative rather than performing a piecemeal analysis within the structure of a single agency action." (NOAA 2001)."

In Section 1A of the memorandum, NOAA discusses the legal and regulatory difficulties associated with assessing cumulative impacts, as follows:

"Regardless of the regulations outlining this basic framework, scoping a tight, concise and sufficiently detailed PEIS can be daunting. In their effort to afford a wide range of Federal agency activity with sufficient leeway for tailored assessments, the regulations remain fairly broad and often raise more questions than they address. A look at the case law alone lends further confusion. Beginning in 1976, a handful of landmark cases attempted to describe the scope and necessity for a comprehensive or programmatic EIS. (See Kleppe v. Sierra Club, 427 U.S. 390 (1976)( "When several proposals are pending before an agency at the same time, and when those proposals have cumulative or synergistic environmental impacts, their environmental consequences must be considered together.") and Fritiofson v. Alexander, 772 F.2d 1225 (5* Cir. 1985)(the agency must review the cumulative impact of incremental actions)). Unfortunately, these early cases led to significant confusion regarding timing, scope and the early enunciation of the principles of cumulative actions versus cumulative effects." (NOAA 2001).

Additional references to cumulative impacts in the memorandum are as follows:

Statement of Purpose and Need:: "In addition, and as appropriate, the PEIS statement of Purpose and Need should describe the role of a cumulative effects analysis in establishing a baseline environmental picture which will allow the Agency to assess whether the current management regime is working and how it might be changed, if necessary."(NOAA 2001).

Types of actions that should be considered in a programmatic EIS: (1) Connected actions, which means that they are closely related and therefore should be discussed in the same impact statement. (See Custer County Action Association v. Garvey, 256 F.3d 1024 (2001) (Actions are connected if one automatically triggers another, or they are sufficiently interdependent to not proceed on their own), (2) Cumulative actions, which when viewed with other proposed actions have cumulatively significant impacts and should therefore be discussed in the same impact statement, (See Kleppe), and (3) Similar actions, which when viewed with other reasonably foreseeable or proposed agency actions, have similarities that provide a basis for evaluating their environmental consequences together, such as common timing or geography. An agency may wish to analyze these actions in the same impact statement. It should do so when the best way to assess adequately the combined impacts of similar actions or reasonable alternatives to (Emphasis added). such actions is to treat them in a single impact statement."(NOAA 2001)

"Under 40 C.F.R. § 1508.25(a), two types of actions require a PEIS (cumulative and connected actions), and one is discretionary (similar actions). The two categories of mandatory PEIS, however, have been sufficiently broadened by case law to the extent that there are actually two additional instances where an agency must consider producing a comprehensive, single programmatic EIS. The other two instances are: 1) when an agency undertakes a broad program or regional planning, and 2) where there are cumulative or synergistic environmental impacts upon the environment from past, present or reasonably foreseeable future actions."(NOAA 2001).

The memorandum continues to assess the need for a programmatic EIS based on whether cumulative impacts are projected: "While the CEQ regulations make separate reference to regional and geographic planning in 40 C.F.R. 9 1502.4(b) and 40 C.F.R. 5 1508.18(b)(4), these sections do not make the PEIS process mandatory. It is in post-regulation case law that the courts have held that when regional plans and multiple federal programs will have a cumulative or synergistic environmental effect upon a region, the relevant agency must prepare a programmatic environmental impact statement. Churchill County v. Babbitt, 150 F.3d 1072 (1998); City of Tenakee Springs v. Block, 778 F.2d 1402 (9th Cir. 1985)."(NOAA 2001)

"The cumulative impacts requirement (2 above) ostensibly relates more to synergy and the interplay of cumulative effects as opposed to specific actions. The CEQ regulations define cumulative impacts in 40 CFR 1508.7. That section provides that: "Cumulative impact" is the impact on the environment which results from the incremental impact of the action when added to other past, present, and reasonably foreseeable future actions regardless of what agency (Federal or non-Federal) or person undertakes such other actions. Cumulative impacts can result from individually minor but collectively significant actions taking place over a period of time." (NOAA 2001)

"This section has its roots in earlier case law (Fritiofson) which attempted to capture past, present and future actions in the analysis of cumulative impacts (as opposed to cumulative actions). Like the regional planning requirement, this standard was swept in to the regulations in a section unrelated to the section 1508.25 scoping provision and therefore without a mandatory statement for a programmatic EIS. Nevertheless, it is now widely recognized and generally held that any project that will have cumulative effects as a result of its interplay with other projects, whether government action or not, must assess those other impacts as well. In other words, it is not sufficient to discuss a single action that has significant synergistic effects based another projects without addressing the impacts from those other projects in a broader, more comprehensive EIS."(NOAA 2001).

In the environmental consequences section of the memorandum, the following information is provided on cumulative impact methodologies:

"A five part process for conducting the threshold cumulative effects analysis was set forth in Fritiofson. There, the court held that a meaningful cumulative- effects analysis must identify:

1. the area in which effects of the proposed project will be felt;
2. the impacts that are expected in that area from the proposed project;
3. other actions- past, proposed and reasonably foreseeable- that have had or are expected to have impacts in the same area;
4. the impacts or expected impacts from these other actions, and
5. the overall impact that can be expected if the individual impacts are allowed to accumulate." (NOAA 2001).

The memorandum further states:

"Only significant effects need to be assessed in the PEIS. The CEQ regulations define "significant effects" in terms of context and intensity. The context requirement generally means that the significance of the effect "must be analyzed in several contexts such as society as a whole (human, national), the affected region, the affected interests, and the locality ...." The regulations also specify that "[Bloth short-term and long-term effects are relevant." (See 40 C.F.R. 1508.27(a)). Intensity refers to the severity of impact and requires that the agency consider both beneficial and adverse effects, the unique characteristics of the affected environment, public health and safety, highly controversial effects, uncertain and unknown effects, the extent precedence will be established, the impact on unique cultural and historical resources, the impact on endangered or threatened species, the effect of Cumulative impacts on the project, and potential violations of existing law designed for protection of the environment. 40 C.F.R. 5 1508.27(b)."(NOAA 2001)

"Case law also provides that the PEIS should consider whether the program causes an unacceptable degradation of a resource for which there is often no regulation or mechanism for regulating incremental impacts. Challenges to the adequacy of a PEIS can be successfully challenged by a plaintiff focusing on the potential effects of several actions on unregulated target resources. In Natural Resources Defense Council v. Hodel, 865 F.2d 288 (1988), the Federal Energy Regulatory Commission’s EIS supporting several offshore oil drilling proposals was found legally insufficient because it failed to consider the cumulative impacts of oil exploration and oil drilling ranging from Alaska to southern California on two target resources (salmon and whales) that migrated past all the widely separated locations of activity. While acknowledging that such an assessment was potentially an extreme undertaking, the court nevertheless left no doubt that the NEPA analysis was incomplete without it."(NOAA 2001).

The Memorandum includes a "Final Word" on cumulative impacts, as follows:

"B. A Final Word on Cumulative Impacts, Environmental Consequences and the Affected Environment "There are two potential pitfalls associated with the delineation of impacts on the affected environment which are worth noting. First, the cumulative impacts assessment must always be considered as separate and distinct from the cumulative action assessment. The cumulative action assessment consists of determining whether there are multiple projects represented by actual proposals which must collectively be reviewed in one EIS. To do this, the agency must determine whether multiple projects are presented by actual proposals and whether they may have cumulative impacts. Thus, the cumulative actions are considered for the purpose of cumulative environmental impact assessment and for the purpose of decision making on each proposed action."(NOAA 2001).

"The cumulative impacts assessment provides that for every action, whether a single-action EIS or a cumulative action EIS, an analysis must be made of the synergistic effects of all of the actions, both individually and collectively. In other words, both the cumulative action programmatic EIS and the single-project EIS call for the assessment of the cumulative effects of each action. In a programmatic EIS, this analysis can become quite wieldy. Nevertheless, failure to note this distinction and address its tenets can lead to significant legal shortcomings in the PEIS and leaves the agency vulnerable to time-consuming and costly litigation." (NOAA 2001).

"The Cumulative impact analysis is of tremendous significance in the PEIS. Because the PEIS is a broad, overview document, it is critical that it look at the cumulative impacts the program is expected to have (and has had) over time. Without a full-blown look at cumulative and synergistic effects, the PEIS will be held legally insufficient. In Greenpeace v. NMFS, 55 F. Supp. 2d 1248 (W.D. Wash. 1999), Judge Zilly held the National Marine Fisheries Service could not continue "to make individually minor but collectively significant changes to the Fishery Management Plans (FMPs) without preparing an SEIS analyzing these changes" and that "NEPA’s cumulative effects provisions requires a programmatic analysis of the FMPs in their current f01-m." (See also, Sierra Club v. Penfold, 857 F.2d 1307 (1988) (an EIS must include a cumulative impacts assessment)."(NOAA 2001).

"Second, the agency must remain mindful that both the CEQ regulations and the courts require the agency to consider past and present actions as well as future actions when assessing the affected environment and environmental consequences. In essence, the word "consequences" connotes future effects. When assessing environmental impacts, it is easy to be blind to the requirement to consider past and present impacts caused by other activities that have affected the environment." (NOAA 2001).

40 C.F.R. $ 1502.15 defines the "Affected Environment" as ."..the areas to be affected or created by the alternatives under consideration ..." For purposes of the environmental consequences comparison, the area is defined as it exists prior to the effect of any proposed or alternative action. Thus, it establishes a baseline environmental picture by which to gauge the effects of each of the alternatives. In order to adequately present the baseline, it has been held that .".. impact statements ... will take into account the effect of their approval upon the existing environment; and the condition of that environment presumably will reflect earlier proposed actions and their effects." Kleppe (emphasis added). Allowing the cumulative impacts of contemplated actions to be evaluated later simply acknowledges that the effects of past and present actions have created the existing environment." (NOAA 2001).

"This "backward look" requirement appears to make the PEIS process appear piecemeal. Many have tried to argue that it is contrary to NEPA’s overall prohibition against using the EIS process to justify past actions. But the purpose of the look back is not to document or discuss the merits of the past action, but to insure that the environmental baseline is presented as it actually exists. Congress passed NEPA out of concern that our limited natural resources are being lost in "small but steady increments." By requiring that the affected environment be described in terms that reflect the degree of existing environmental degradation caused by previous activity and by requiring that the cumulative impacts assessment account for previous effects on the environment, the goal of NEPA to help agencies avoid undue environmental harm through creeping and incremental loss is, in fact, advanced and assured."(NOAA 2001)

"In a programmatic EIS, an analysis must be made of the synergistic effects of all of the actions, both individually and collectively. In other words, both the cumulative action programmatic EIS and the single-project EIS call for the assessment of the cumulative effects of each action. In a programmatic EIS, this analysis can become quite wieldy. Nevertheless, failure to note this distinction and address its tenets can lead to significant legal shortcomings in the PEIS and leaves the agency vulnerable to time-consuming and costly litigation." (NOAA 2001).

"If these aspects have been overlooked and the sufficiency of the PEIS analysis is legally challenged, the decision making process will be delayed as the court remands the document to the agency for their inclusion. Accurately capturing the baseline environmental scope of the affected area, including the consequences of past actions, is time consuming and complex. During the pendency of the redrafting, fie court can, and generally does, forestall proceeding with the proposed action. Sierra Club v. Penfold, 857 F.2d 1307 (9th Cir. 1988). It is therefore imperative that the agency provide a complete environmental baseline of the affected environment up front and include the consideration of past actions in their cumulative effects analysis." (NOAA 2001).

Clearly. NOAA has been deeply involved in the issue of how to address cumulative impacts in their NEPA process The potential significance of cumulative impacts on resources within the purview of NOAA has been one of the major legal and regulatory driving forces for many years.

NOAA/NMFS’s involvement with NEPA with regard to beach nourishment projects is primarily as a reviewer of documents and projects, and as an agency stakeholder. The issue of cumulative impact assessment is clearly at the forefront of this agency’s thought process and administration of the laws and regulations governing the marine/coastal environment. This information provides valuable insights for he present web page forum.

NPS Methods of Assessing Cumulative Impacts

The NPS has developed guidelines for assessing cumulative impacts that are contained in their document entitled "Directors Order 2, Planners Sourcebook" (NPS 2003a). NPS NEPA policies and guidelines are provided in "Directors Order 12 – NEPA Handbook" (NPS 2003b). The NPS is trending towards using the CEQ approach of defining cumulative impacts as a mathematical equation: X + Y = Z, where is ‘X’ is the impact of alternative A on a resource [the incremental effect], ‘Y’ is the impacts of other actions on the resource, and ‘Z’ is the cumulative impact. "Other" actions are considered by the NPS to include all actions outside park boundaries that might affect the park resources. The NPS also considers how the additive effect of actions inside the park might affect resources outside the park. NEPA is implemented in conjunction with all NPS actions, but primarily in the case of development of or modification to General Management Plans (GMPs). In this case, an EIS is prepared simultaneously with the GMP. The purpose of the GMP is to define appropriate future conditions for the park based on public input and park policies, laws, regulations and mandates. The GMP/EIS is a document that describes the impacts of alternative future conditions on the natural and man-made environment. The NEPA and GMP process are thus intertwined, as defined in the Planners Sourcebook. There is much current interest regarding cumulative impacts within the NPS. Recent GMP/EIS documents can be obtained on the Internet from the NPS planning site at this web site.

To assess impacts in the NEPA document, the NPS first develops a list of issues based on public scoping. Issues are stated as questions, such as "what will be the effect of implementation of the preferred GMP alternative on wetlands?." A set of impact thresholds are then developed that define the context (site-specific, regional, or national), intensity (negligible, minor, moderate or major) and duration (short or long term) of the impact on a particular resource. Many of these thresholds are shared with and by other agencies in their NEPA documents (i.e., USFWS etc…). This process occurs when one agency reviews another’s NEPA documents and provides comments on the validity or utility of impact thresholds. Through this process, over time, the approach is improved.

Specific impact threshold are developed according to guidelines and generic thresholds provided in the Planners Sourcebook. The following generic impact thresholds were developed by the NPS and presented in the DO 2 Planners Sourcebook (NPS 2003):

Negligible: The impact is at the lower levels of detection.
Minor: The impact is slight, but detectable.
Moderate: The impact is readily apparent.
Major: The impact is severely adverse or exceptionally beneficial.

Detailed thresholds are developed for each resource/issue area and used to define direct impacts of each alternative. An example set of detailed thresholds from the Santa Monica Mountains GMP/EIS is as follows (this document has been used for the present paper because we have found it to contain the most up to date thresholds for various issue areas):

Negligible– Impact is barely perceptible and measurable; remains localized and confined to a single, non-sensitive biological element under discussion, such as a single location, population, process, species, community, or other biological entity. An example would be the removal of ten individuals of a common shrub from the edge of a chaparral - covered slope next to a building.

Minor – Impact is perceptible and measurable; remains localized and confined to a single or few elements of a non-sensitive biological element under discussion, such as a single location, population, process, species, community, or other entity that is recognized as relatively common, and that would recover from disturbances in a relatively short time period (years). An example would be the removal of a tenth of an acre of California Buckwheat on the edge of a hillside covered with coastal sage scrub vegetation during the re-grading a previously constructed campground .

Moderate– Impact is sufficient to cause a change in character-defining features of a biological element; generally involves a single or small group of elements in a biological community, process, species, or other entity that is moderately to highly sensitive to human development, encroachment, or disturbance, and that would recover from disturbances in a moderate time period (decades). An example might be the removal of a half a c re patch of grassland vegetation adjacent to a larger, thirty acre grassland covering a hillside and valley. The small patch, while used for raptor foraging, is not critical to the survival of any species utilizing it. the removal of a threatened, endangered, or rare species by grading, the disturbance of a critical wildlife corridor between two large habitat patches by a foot trail, or the elimination of the last remnants of a particular habitat, community, process, or other biological entity from the SMMNRA. resource and wetland analysis is defined as:

Major – Impact results in substantial and highly noticeable change in character defining features; involves a large group of contributing elements, or involves an individually significant element with a significantly important ecological role in a biological community, process, species, or other entity that is highly sensitive to human development, encroachment, or disturbance, and that may not recover fro m the impact within the SMMNRA or region . Examples would include the blockage of a wildlife movement corridor by a building, the removal of a threatened, endangered, or rare species by grading, the disturbance of a critical wildlife corridor between two large habitat patches by a foot trail, or the elimination of the last remnants of a particular habitat, community, process, or other biological entity from the SMMNRA.

The above thresholds are used to assess direct impacts, but are also developed by the NPS to address cumulative impacts as well. The NPS system also includes a definition of "impairment" of natural and cultural resources that derives from the Organic Act, the founding legislation for the NPS. This act requires the visitors be provided an opportunity to enjoy the park but not damage the resources to the point where they cannot be enjoyed further.

The general methodology used by the NPS to address cumulative impacts is as follows:

A list of all ongoing projects in the vicinity of the park is created using planning information from local agencies. The potential effects of the proposed NPS action in combination with these other actions on resources outside the park are then assessed as one component of "other" ("Y") actions.

The potential combined effect of the other projects outside the park on resources inside the park are also assessed. This is the second subcomponent of "y" (other actions).

All effects are compared with the impacts of the no action alternative as a basis for making NPS decisions.

Cumulative impacts are defined for each issue category in the GMP/EIS. The GMP/EIS also includes a separate section at the beginning of the impact assessment chapter that describes the methodology for assessing cumulative impacts. Cumulative impacts are also defined in terms of context, intensity, duration and type of effect. Intensity of cumulative impacts is also defined according to the same intensity levels used for direct impacts. Thresholds are developed for each level of intensity of the identified cumulative impacts.

References for the Further Information on Cumulative Impact Assessment Methodologies Under NEPA

The following is a summary of references on cumulative impacts used in this paper, as well as other useful references on the subject. Hyperlinks are provided where available.

Reference	Web Page
Council on Environmental Quality (CEQ). 1997. Considering Cumulative Effects Under the National Environmental Policy Act, Council on Environmental Quality, Office of the President" (January 1997)	http://ceq.eh.doe.gov/nepa/ ccenepa/ccenepa.htm
Department of Interior. 2003. Department of the Interior National Environmental Policy Act Procedures (516 DM 1-7)	http://www.fws.gov/r9esnepa/ DOINEPAProced/ 516dm1-7index.PDF
EPA. 2003. Consideration Of Cumulative Impacts In EPA Review of NEPA Documents. U.S. Environmental Protection Agency, Office of Federal Activities (2252A). EPA 315-R-99-002/May 1999	http://www.epa.gov/Compliance/ resources/ policies/nepa/ cumulative.pdf
National park Service. 2003a. Directors Order 2 Planners Sourcebook	http://planning.nps.gov/ document/do2%2Epdf
National park Service. 2003b. Directors Order 12 Handbook	http://planning.nps.gov/ document/ACFBF%2Epdf
National park Service 2003c. Santa Monica Mountains National Recreation Area GMP/EIS.	http://www.nps.gov/samo/ supplans/GMPress.htm
NOAA. 2001. Memorandum for: William Hogarth, Assistant Administrator for Fisheries, from Craig R. O’Connor, Acting General Counsel, for Fisheries Guidance on Programmatic Environmental Impacts Statements. December 2001.	http://www.fakr.noaa.gov/analyses/ GuidanceonPEIS.pdf
NOAA. 2003. Environmental Review Procedures for Implementing the National Environmental Policy Act Issued 06/03/99; effective 05/20/99)	http://www.rdc.noaa.gov/ ~nao/216-6.html
US Fish and Wildlife Service. 2003. NEPA Reference Handbook	http://www.fws.gov/r9esnepa/ NEPA%20Handbook%20TOC.pdf
USACE. 1996. Shoreline Protection and Beach Erosion Control Study Final Report: an Analysis of the U.S. Army Corps of Engineers Shore Protection Program. Prepared by Theodore M. Hillyer Project Manager Shoreline Protection and Beach Erosion Control Task Force U.S. Army Corps of Engineers For the Office of Management and Budget June 1996 IWR REPORT 96 - PS - 1	http://www.iwr.usace.army.mil/ iwr/pdf/96ps1.pdf http://www.iwr.usace.army.mil/
USACE. 2002. Draft Environmental Impact Statement, March 2002. Broward County Shore Protection Project. Segments 2 and 3. Broward County, Florida. Lead Agency: Jacksonville Corps of Engineers. Cooperating Agency: Broward County Department of Planning and Environmental Protection.	http://www.saj.usace.army.mil/pd/ envdocs/Broward /BC_Beach_Erosion_Control_Proj/ index.html
USACE. 2003a. List of recent Jacksonville USACE NEPA documents, with hyperlinks	http://www.saj.usace.army.mil/ pd/envdocs/envdocsb.htm
USACE. 2003b. Jacksonville District project web page: Regional Sediment Management Web Page, Florida	http://www.saj.usace.army.mil/ dp/spp.htm https://rsm.saj.usace.army.mil/ index2.html
USACE. 2003c. Regional Sediment Management: Background and Overview of Initial Implementation Prepared as part of the U.S. Army Corps of Engineers Institute for Water Resources Policy Studies Program IWR Report 02-PS-2 Lynn R. Martin July 2002	http://www.iwr.usace.army.mil/ iwr/pdf/02ps2sed_man.pdf
USFWS. 1994. USFWS Division of Habitat Conservation Fish and Wildlife Manual (FWM)# 153, June 28, 1994, Part 505: Environmental Review.	http://policy.fws.gov/505fw3.html
USFWS. 1997. Department of the Interior National Environmental Policy Act Revised Implementing Procedures. Notice of Final Revised Procedures for the Fish and Wildlife Service. Federal Register: January 16, 1997 Volume 62, Number 11, Page 2375-2382,	http://www.fws.gov/r9esnepa/ FWSNEPAGuidance/516dm6.pdf
USFWS. 1998. Endangered Species Consultation Handbook. Procedures for conducting consultation and conference activities under Section 7 of the Endangered Species Act	http://endangered.fws.gov/ consultations/ s7hndbk/ toc-glos.pdf
USFWS. 2003. USFWS NEPA Reference Handbook.	http://www.fws.gov/ r9esnepa/TOCnotebook.PDF