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available information concerning the numbers of juvenile fish that would be
entrained in a cooling water facility, the responsible agency must disclose
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and consider the possibility of the loss of the commercial or sport fishery.
In addition to an analysis of a low probability/catastrophic impact event, the
worst case analysis should also include a spectrum of events of higher
probability but less drastic impact.
21. Q. Where an EIS or an EA is combined with another project planning
document (sometimes called "piggybacking"), to what degree may the EIS or EA
refer to and rely upon information in the project document to satisfy NEPA's
requirements?
A. Section 1502.25 of the regulations requires that draft EISs be prepared
concurrently and integrated with environmental analyses and related surveys
and studies required by other federal statutes. In addition, Section 1506.4
allows any environmental document prepared in compliance with NEPA to be
combined with any other agency document to reduce duplication and paperwork
However, these provisions were not intended to authorize the preparation of a
short summary or outline EIS, attached to a detailed project report or land
use plan containing the required environmental impact data. In such
circumstances, the reader would have to refer constantly to the detailed
report to understand the environmental impacts and alternatives which should
have been found in the EIS itself.
The EIS must stand on its own as an analytical document which fully informs
decision makers and the public of the environmental effects of the proposal
and those of the reasonable alternatives. Section 1502.1. But, as long as the
EIS is clearly identified and is self-supporting, it can be physically
included in or attached to the project report or land use plan, and may use
attached report material as technical backup.
Forest Service environmental impact statements for forest management plans are
handled in this manner. The EIS identifies the agency's preferred alternative,
which is developed in detail as the proposed management plan. The detailed
proposed plan accompanies the EIS through the review process, and the
documents are appropriately cross-referenced.
The proposed plan is useful for EIS readers as an example, to show how one
choice of management options translates into effects on natural resources.
This procedure permits initiation of the 90-day public review of proposed
forest plans, which is required by the National Forest Management Act.
All the alternatives are discussed in the EIS, which can be read as an
independent document. The details of the management plan are not repeated in
the EIS, and vice versa. This is a reasonable functional separation of the
documents: the EIS contains information relevant to the choice among
alternatives; the plan is a detailed description of proposed management
activities suitable for use by the land managers. This procedure provides for
concurrent compliance with the public review requirements of both NEPA and the
National Forest Management Act.
Under some circumstances, a project report or management plan may be totally
merged with the EIS, and the one document labeled as both "EIS" and
"management plan" or "project report. This may be reasonable where the
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