An evaluation paradigm for cumulative impact analysis

Cumulative impact analysis is examined from a conceptual decision-making perspective, focusing on its implicit and explicit purposes as suggested within the policy and procedures for environmental impact analysis of the National Environmental Policy Act of 1969 (NEPA) and its implementing regulations. In this article it is also linked to different evaluation and decision-making conventions, contrasting a regulatory context with a comprehensive planning framework. The specific problems that make the application of cumulative impact analysis a virtually intractable evaluation requirement are discussed in connection with the federal regulation of wetlands uses. The relatively familiar US Army Corps of Engineers' (the Corps) permit program, in conjunction with the Environmental Protection Agency's (EPA) responsibilities in managing its share of the Section 404 regulatory program requirements, is used throughout as the realistic context for highlighting certain pragmatic evaluation aspects of cumulative impact assessment.To understand the purposes of cumulative impact analysis (CIA), a key distinction must be made between the implied comprehensive and multiobjective evaluation purposes of CIA, promoted through the principles and policies contained in NEPA, and the more commonly conducted and limited assessment of cumulative effects (ACE), which focuses largely on the ecological effects of human actions. Based on current evaluation practices within the Corps' and EPA's permit programs, it is shown that the commonly used screening approach to regulating wetlands uses is not compatible with the purposes of CIA, nor is the environmental impact statement (EIS) an appropriate vehicle for evaluating the variety of objectives and trade-offs needed as part of CIA. A heuristic model that incorporates the basic elements of CIA is developed, including the idea of trade-offs among social, economic, and environmental protection goals carried out within the context of environmental carrying capacity.