Indirect and cumulative impacts analyses are tough issues for NEPA document writers. We spoke with Susan Geist, Environmental and Transportation Planning Coordinator from Federal Highway Administration (FHWA) to get 5 tips from an expert.
“The ICI discussion must clearly identify the rationale for including/excluding resources in the analysis. Customize the section to include relevant resources based on the particular project and the findings of the direct impacts analysis.”
“Resource study areas (RSAs) must be clearly defined (both the physical and temporal boundaries), and will likely vary for each resource. The rationale for the selection of these areas should also be included in the discussion.”
“The relationship between transportation and land use must be acknowledged if appropriate to the project. The ICI analysis must adequately discuss baseline conditions and the scope for potential changes in access and economic development/land use conversion. All other planned actions, including other reasonably foreseeable transportation projects, must be accounted for during the analysis.”
“Added capacity projects in non-attainment areas should analyze air quality in the ICI section. This analysis needs to address ozone, carbon monoxide (CO), and MSATs, using the non-attainment area as the RSA, and should include a brief summary of the direct impacts rather than repeating the entire direct impacts analysis verbatim.”
“Keep in mind that although the transportation agency may not be responsible for the mitigation of an indirect or cumulative impact, it is still necessary to do a thorough analysis of all the ICI impacts that may occur in relation to the project as part of the NEPA process.”