Focused EA Review and Thoughts

Focused EA Review and Thoughts

Ken Post

EAs should not be using the terms significant and non-significant issues anymore. Current FSH direction discourages it (FSH 1909.15, Chapter 10, Section 12.41). Note: the WO template still uses these incorrect terms.

I like when an EA has Existing Conditions (EC)/Desired Future Condition (DFC) sections—particularly in an easy-to-read table; it really helps lay out the why we are doing the project. This provides a nice lead in to the proposed action.

I noticed that some EAs identified the issues (Southern Pine Beetle, Duke Power) and others differentiated between issues identified by the public and the IDT (Skyline North). Is there a need to provide a bit more clarity on how issues are presented in an EA?

The FSH (Section 43.1) states that “a FONSI should be supported by references to the relevant sections of the EA.” Does that info have to be in the EA or can it be in the record?

It may not be fair, but an EA will always be partially judged on its length. I think there are several things we can do to make the EA shorter and more user-friendly to the public. These include:

• Minimize the amount of information cited from the Forest Plan direction to just the core parts that help lay out the EC/DFC. Anything else can be put in the record, if necessary.
• Not including or minimizing the Affected Environment section. There is no requirement for this section in an EA.
• Strive to remove unnecessary wording such as overly long introductions to sections explaining what the intent of that section is or citations of CEQ regulations. In most cases, it’s pretty self-explanatory. For example, we don’t need a preamble explaining that the effects section includes direct, indirect and cumulative effects, whether the effects are qualitative or quantitative, etc.; that’s pretty evident just by reading the effects section.
• I don’t think there is a requirement to include the irreversible or irretrievable wording in an EA. It is usually a reiteration of the effects and I don’t think anyone pays attention to this compared to the direct/indirect/cumulative effects section.
• Discourage appendices unless it is essential to understanding the document. For example, I wouldn’t include a BE as an appendix but would briefly summarize the info in the analysis and then place the BE in the record.

Questions for IDTs

• What do you see being the biggest internal barriers to “streamlining” an EA? Resource specialists? Line officers?
• How do you think the public will respond to a Focused EA since it could look very different from what they’re used to seeing?
• What kind of time-savings would occur by only including truly required/relevant info in EA (vs project record)? Would the resource specialists still need the same amount of time? If so, we may be improving the readability of the EA, but not necessarily saving the time it takes to complete the EA.