Breath of Clarity

Impacts of Recreational Use- NEPA Surprises (Comment)

Original Post by Niesa McMillan:

What surprises me the most about NEPA is the absence of commitment to designated monitoring of environmental impacts following a NEPA decision. There is also a lack of consistency among agencies to implement standards for disciplinary training and public involvement, which may lead to long delays in decision making and high associated costs (Stern and Mortimer 2009, 13-14). Although, the lack of consistency among agencies to exhibit homogeneity in the overall NEPA process is not unexpected given the nature of variance among agencies.

The means in which the U.S. Army Corps of Engineers (USACE) applies the NEPA process is also interesting in that the agency avoids making independent management action proposals. Instead, USACE decides on third-party sponsors who are often government affiliated and responsible for a portion of associated NEPA costs (Stern and Mortimer 2009, 16-17). While this may be of benefit to USACE NEPA proceedings, it demonstrates deviation from other federal agency NEPA framework.

Stern, Marc J., Mortimer, Michael J. 2009 “Exploring National Environmental Policy Act Processes Across Federal Land Management Agencies.” Gen. Tech. Rep. PNW-GTR-799. Portland, OR: U.S. Department of Agriculture, Forest Service, Pacific Northwest Research Station. 106 p.

My Comment:

Great point about USACE deviating from the standard NEPA framework. The Environmental Protection Agency (EPA) was critical of USACE’s NEPA environmental impact statement for the Delta Wetlands Project in San Joaquin and Contra Costa counties. Specifically, EPA said the review discussed greenhouse gas emissions during construction and operation, but did not include a discussion of climate change on the project (Reeves 2015). Further, sea level rise is mentioned as a risk in several places throughout the document, but no in-depth discussion is provided (Reeves 2015). EPA recommended including regionally-specific studies of future sea level rise, drought, storm surges and flooding due to climate change, and also to update monitoring of historical water levels to account for the recent four years of drought and the potential impact of long-term drought conditions and climate change on water supply and operation (Reeves 2015).


Reeves, Dawn. 2015. “EPA Comments Underscore Uneven Climate Treatment In NEPA Reviews”. Inside EPA’s Clean Air Report. 26(22): 33-34.