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Draft EIS/EIR for the San Luis Reservoir SRA Resource ...

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5. Environmental Analysis<br />

5.2.3 Assumptions and Methods <strong>for</strong> Evaluating Impacts<br />

Impact analyses and conclusions are based on interdisciplinary team knowledge<br />

of resources and <strong>the</strong> Plan Area, reviews of existing literature, and in<strong>for</strong>mation<br />

provided by experts in Reclamation, CSP, and o<strong>the</strong>r agencies. Impacts described<br />

in this section are based on <strong>the</strong> conceptual Plan as implemented by <strong>the</strong> proposed<br />

alternatives described in Chapter 4. The in<strong>for</strong>mation used to establish a baseline<br />

of existing conditions (including applicable laws and regulations <strong>for</strong> each<br />

resource) is described in Chapter 2. The management alternatives have been<br />

configured to optimize benefits and minimize adverse effects on both ecosystem<br />

function and <strong>the</strong> human environment. In <strong>the</strong> absence of quantitative data, best<br />

professional judgment prevails. Protocol surveys <strong>for</strong> special-status species were<br />

not conducted as part of this programmatic planning ef<strong>for</strong>t.<br />

One of <strong>the</strong> primary differences between NEPA and CEQA is <strong>the</strong> way significance<br />

is determined and discussed in environmental documents. Under NEPA,<br />

significance is used to determine whe<strong>the</strong>r an <strong>EIS</strong> or some lower level of<br />

documentation will be required. NEPA requires preparation of an <strong>EIS</strong> when <strong>the</strong><br />

proposed federal action (project) as a whole has <strong>the</strong> potential to “significantly<br />

affect <strong>the</strong> quality of <strong>the</strong> human environment.” The determination of significance is<br />

based on context and intensity (40 CFR §1508.27). Some impacts determined to<br />

be significant under CEQA may not be of sufficient magnitude to be determined<br />

significant under NEPA. Under NEPA, once a decision to prepare an <strong>EIS</strong> is made,<br />

it is <strong>the</strong> magnitude of <strong>the</strong> impact that is evaluated, and no judgment of its<br />

significance is deemed important <strong>for</strong> <strong>the</strong> text. NEPA does not require that a<br />

determination of significance <strong>for</strong> individual resources be stated in an<br />

environmental document. Once <strong>the</strong> proposal itself is considered as a whole to<br />

have significant effects, all of its specific effects on <strong>the</strong> environment (whe<strong>the</strong>r or<br />

not “significant”) must be considered, and mitigation measures must be developed<br />

where it is feasible to do so (40 CFR §1502.14(f), 1502.16(h), 1508.14, and <strong>the</strong><br />

Council on Environmental Quality’s [CEQ’s] 40 Most Asked Questions #19a 7 ).<br />

CEQA, on <strong>the</strong> o<strong>the</strong>r hand, does require an identification of each “significant effect<br />

on <strong>the</strong> environment” resulting from <strong>the</strong> project and ways to mitigate each<br />

significant effect. A significant effect on any environmental resource triggers <strong>the</strong><br />

preparation of an <strong>EIR</strong>. Each significant effect on <strong>the</strong> environment must be<br />

disclosed in <strong>the</strong> <strong>EIR</strong> and mitigated, if feasible. In addition, <strong>the</strong> CEQA Guidelines<br />

list a number of mandatory findings of significance that also require <strong>the</strong><br />

preparation of an <strong>EIR</strong>. There are no types of actions under NEPA that parallel <strong>the</strong><br />

findings of mandatory significance in CEQA.<br />

According to <strong>the</strong> CEQA Guidelines Section 15382, a significant impact on <strong>the</strong><br />

environment refers to a “substantial, or potentially substantial, adverse change in<br />

any of <strong>the</strong> physical conditions within <strong>the</strong> area affected by <strong>the</strong> project, including<br />

land, air, water, minerals, flora, fauna, ambient noise, and objects of historical or<br />

aes<strong>the</strong>tic significance.” Environmental impacts may be associated with visitor<br />

7 http://ceq.hss.doe.gov/NEPA/regs/40/40p3.htm.<br />

<strong>San</strong> <strong>Luis</strong> <strong>Reservoir</strong> <strong>SRA</strong> 5-5<br />

<strong>Draft</strong> RMP/GP and <strong>Draft</strong> <strong>EIS</strong>/<strong>EIR</strong>

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