Documentation of cumulative impacts in environmental impact statements

The National Environmental Policy Act (NEPA) of 1969 and the Council on Environmental Quality (CEQ) regulations in the United States require federal agencies to apply an environmental impact assessment (EIA) in decision-making related to their actions. One aspect requires an examination of direct, indirect and cumulative impacts (CIs). Historically, cumulative impact assessment (CIA) has been given limited attention in EIA and resultant environmental impact statements (EISs), not because of its lack of importance, but owing to limitations in methodologies and procedures, including documentation consistency. The objectives of this study were to identify deficiencies in the documentation of CIs and CIA in EISs and to formulate appropriate recommendations (potential solutions) related to such deficiencies. The study involved the systematic review of 33 EISs (11 each from the U.S. Department of Agriculture: Forest Service, the U.S. Army Corps of Engineers, and the U.S. Department of Transportation: Federal Highway Administration). The results indicate that improvements have been made in documentation practices since 1990; however, inconsistencies and inadequacies still exist. Therefore, the following recommendations were developed: (1) CIs should be reported in a separate part of the “Environmental Consequences” section, and they should be addressed for each pertinent environmental resource; (2) a summary of CIs should be included; (3) any CIs considered not significant should be mentioned plus the reason(s) for their non-significance; (4) spatial and temporal boundaries addressed within the CIA process should be defined for pertinent environmental resources; and (5) utilized guidelines and methodologies should be described.