C-EA Supplemental Guidance

**Enclosure A: Administrative Record Guidance and Checklist**

**Enclosure B: Annotated Environmental Assessment Outline**

**Enclosure C: Cumulative Effects Analysis**

**Enclosure D: Impairment Guidance**

**Enclosure E: Sample FONSI**

**Enclosure A**

**Administrative Record Guidance and Checklist**

NEPA ADMINISTRATIVE RECORD - CHECKLIST FOR COMPILATION

The Administrative Record is the compilation of files/materials
documenting the decision-making process of the agency. "These are the
documents that a judge will review to determine whether that process and
the Service's final decision were proper." This memorandum includes
guidance provided by the Department of Justice on compiling an
Administrative Record.

The Administrative Record **should** include:

-   All documents and materials that were before or available to persons
    involved in the decision at the time the decision was made.

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-   All documents that were considered or relied upon by persons
    involved in the decision.

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-   Documents that relate to both the substance and procedure of making
    the decision.

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-   All pertinent documents regardless of whether they favor the
    decision that was finally made, favor alternatives other than the
    final decision, or express criticism of the final decision.
    Documents should never be withheld just because they reflect
    negatively on the decision that was finally made.

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-   Documents that may end up later being redacted or removed from the
    record on the basis of privilege.

The Administrative Record should **not** include:

-   Documents associated with, but not part of, the decision-making
    process, such as fax cover sheets.

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-   Various versions of a document where the differences among the
    drafts reflect minor editing changes. Include drafts, however, where
    hand-written notes or changes from one version to the next reflect
    the evolving process.

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-   E-mails and other correspondence that discuss the agency action
    generally but do not reflect decision-making considerations by staff
    (for example, communications between biologists whose work may be
    affected by the outcome of the decision-making process but who are
    not involved in the decision itself).

Types of materials to include:

-   Paper, email (printed out), computer tapes and discs, microfilm and
    microfiche, data files, graphs, charts and decision-specific
    handwritten notes.

Kinds of information to include:

-   All documents and materials prepared, reviewed or received by agency
    personnel and used by or available to the decision-maker.

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-   Policies, guidelines, directives and manuals.

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-   Articles and books (be sensitive to copyright laws governing
    duplication).

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-   Factual information or data.

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-   Communications the agency received from other agencies and the
    public, and any responses to those communications (electronic
    communications in hardcopy form; telephone/conference calls as memos
    to file).

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-   Documents and materials that contain information that support or
    oppose the agency decision.

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-   Exclude documents and materials not in existence at the time of the
    (agency) decision.

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-   Drafts circulated for comment outside the author and the agency, if
    changes in the drafts reflect significant input into the
    decision-making process.

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-   Technical information, sampling results, survey information, reports
    or studies.

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-   Decision documents.

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-   Minutes of meetings or transcripts thereof.

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-   Documentation of telephone conversations and meetings, including
    memos and handwritten notes.

**NEPA COMPLIANCE DOCUMENTATION CHECKLIST**

**FOR**

**ADMINISTRATIVE RECORD AND/OR PROJECT FILE\***

**(per DO-12 and Handbook, Conservation Planning, Environmental Impact
Analysis and Decision Making)**

## Project Title: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_

**Project Number: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

**PMIS Number: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_**

### ENVIRONMENTAL ASSESSMENTS OR ENVIRONMENTAL IMPACT STATEMENTS

-   Memo to the File

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-   Relevant permit information, copies of permits (404, ARPA, XXX,
    etc.)

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-   Environmental Screening Form or Disturbance Form

 Finding of No Effect from SHPO

-   Biological Assessment (under Endangered Species Act, Section 7)

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-   FWS / NMFS Biological Opinion

-   Concurrence of no effect from FWS, NMFS, and state agency (if
    applicable)

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-   106 Review

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-   Public meeting notices

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-   All public comments, comment letters, comment sheets, etc.,
    electronic and paper submittals

 IDT or other meeting notes regarding content, issues, alternatives,
etc., of EA/EIS

 Minutes of meetings of public involvement

 Letters of public involvement

 Telephone records (conversations with federal, state, local agencies,
Indian tribes, interest group or public)

-   FACA groups -- By-laws, charters, all Federal Register notices, all
    meeting minutes, all recommendations/decisions/reports

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-   All studies / surveys contracted for to gather data for NEPA
    decision making process

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-   All incoming and outgoing correspondence with Federal agencies (ie.
    USACOE, FWS, NMFS, EPA), all state and local agencies (SHPO), Indian
    tribes, interest groups, general public -- electronic and paper

-   Copy of NOA, NOI

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-   Draft EIS

-   Public review EA

-   Wetland / Floodplain Statement of Findings (if applicable)

-   Coastal Zone Consistency Statement (if applicable)

-   Prime and Unique Farmland statement (if applicable)

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-   Comments generated from review of EA or EIS (including internal
    comments)

-   Revised EA (if applicable)

-   Final EIS

-   Errata sheets (if applicable)

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-   Finding of No Significant Impact (signed original)

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-   Record of Decision (signed original)

-   Issues identified by the IDT or individual members of the IDT and
    follow-up documentation on how the issue was resolved

-   Mitigation Agreements

-   Cited documents in the text and complete references that have been
    summarized or incorporated by reference in the EA or EIS must be
    reasonably available for public inspection (including policy
    manuals, Director's Orders, and other policy used)

#### CATEGORICAL EXCLUSIONS

-   Environmental Screening Form or Disturbance Form

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-   Concurrence of no effect from FWS, NMFS, and state agency (if
    applicable)

-   106 Review / Finding of No Effect from SHPO

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-   IDT or other meeting notes

 Telephone records (conversations with federal, state, local agencies,
Indian tribes, interest group or public)

-   All incoming and outgoing correspondence with Federal agencies (ie.
    USACOE, FWS, NMFS, EPA), all state and local agencies (SHPO), Indian
    tribes, interest groups, general public -- electronic and paper

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-   Issues identified by the IDT or individual members of the IDT and
    follow-up documentation on how the issue was resolved

-   Agreements for minor mitigation

-   Categorical Exclusion Form

\* The compliance file should not be disposed of at any time

**ENCLOSURE B**

**Annotated Environmental Assessment Outline**

**SUMMARY**

If the EA is longer than 50 pages, a one or two-page stand-alone summary
of important issues and major findings may be appropriate.

**TABLE OF CONTENTS**

**PURPOSE AND NEED**

**Purpose of and Need for the Proposed Action**

Identify the proposed action and the objectives (the desired outcomes
and desired future conditions). For example: "The National Park Service
(NPS) is considering \[provide a brief description of the proposed
action\] at \[park, county, state\]." Describe the undesirable
conditions. For example: **"**This action is needed because..." Describe
what the EA is intended to accomplish (i.e., to analyze the preferred
alternative, the no action alternative, and other reasonable
alternatives, as appropriate, and their impacts on the environment).

State that the EA has been prepared in accordance with the National
Environmental Policy Act (NEPA) of 1969 and implementing regulations, 40
CFR Parts 1500-1508; National Park Service Director's Order #12 and
Handbook, *Conservation Planning, Environmental Impact Analysis, and
Decision-making;* and Section 106 of the National Historic Preservation
Act of 1966 as amended, and implementing regulations, 36 CFR Part 800.
Indicate if the NEPA process is being used to comply with Section 106.

**Purpose and Significance of the Park**

Refer to the Park's enabling legislation and/or management documents
(GMP, other planning documents, etc.).

**Project Background**

> **Project background.**
>
> **Previous planning (if any).** Refer to previous studies, management
> plans, and other planning documents. Indicate if project is addressed
> in the Park's GMP or other planning documents.
>
> **Scoping.** Describe the internal and external scoping for this
> project. Internal scoping refers to the interdisciplinary process used
> to define issues, alternatives, and data needs. Internal scoping
> generally results in the completion of an environmental screening form
> (ESF). Scoping with interested federal, state, and local agencies and
> Indian tribes is also part of the internal scoping process. External
> scoping is the process used to gather public input and may include
> scoping sessions, direct mailings, newsletters, ads, or open houses.

**Issues**

Include an introductory statement detailing how the issues were
identified (internal and external scoping, FHWA road condition or
scoping reports, other agency or organization input, etc.). Describe all
issues that were kept for analysis and led to impact topics. Issues may
describe problems or concerns associated with current impacts from
environmental conditions or current operations, as well as problems that
may arise from the implementation of an alternative. Issues can usually
be described in terms of cause and effect. Example: Lack of formalized
access trails to historic sites results in informal trail formation that
increases the impact from visitors to the historic sites.

**Impact Topics**

> **Derivation of impact topics.** Describe the methods by which impact
> topics were identified. For example: "Specific impact topics were
> developed for discussion focus, and to allow comparison of the
> environmental consequences of each alternative. These impact topics
> were identified based on federal laws, regulations, and Executive
> Orders; 2001 NPS *Management Policies*; and NPS knowledge of limited
> or easily impacted resources. A brief rationale for the selection of
> each impact topic is given below, as well as the rationale for
> dismissing specific topics from further consideration."
>
> **Impact topics included in this document.** Note that the impact
> topics described here should be the same as those identified and
> described in the Affected Environment section of this EA.

# Impact topics dismissed from further analysis. Note that the impact topics dismissed should NOT be included in the Affected Environment section of this EA. 

**ALTERNATIVES**

Identify the alternatives and explain how they meet objectives as laid
out in the Purpose and Need section, and how they reduce or eliminate
impacts to important environmental resources. If a Value Analysis (VA)
was conducted, explain the process and how the results were used to
define the range of alternatives.

**The No Action Alternative (Alternative A)**

Note that the no action alternative presents the park's ongoing routine
of continuing maintenance and repairs and implementing previously
approved plans; in other words, the no action alternative describes the
day-to-day operations of running the park as it relates to the preferred
alternative in this document. It does not imply or direct discontinuing
day-to-day maintenance and repairs or stopping previously approved
plans. The no action alternative provides a basis for comparing present
park operations with the action alternatives and their anticipated
environmental consequences. Should the no action alternative be
selected, the NPS would respond to future needs and conditions without
major actions or changes in the present course.

**The Preferred Alternative (Alternative B)**

Describe the NPS preferred alternative and define the rationale for the
action in terms of resource protection and management, visitor and
operational use, costs, and other applicable factors.

**Other Action Alternative (Alternative C)**

Include as appropriate.

**Other Action Alternative (Alternative D)**

Include as appropriate.

**Mitigation Measures of the Action Alternatives**

Describe measures that would be taken to lessen the adverse effects of
the action alternatives.

**Alternatives Considered but Dismissed**

Identify alternatives considered but dismissed and present supporting
justification for why each alternative is being dismissed. Justification
for eliminating such alternatives from further analysis should be based
on factors relating to:

-   the alternative's lack of technical feasibility;

-   inability to meet the project's purpose and need;

-   duplication with other less environmentally damaging or less
    expensive alternatives;

-   conflict with an up-to-date park plan, statement of purpose and
    significance, or other policy;

-   severe environmental impact; or,

-   as a secondary, supporting reason, economic infeasibility.

Simply identifying agency preference is not defensible rationale for
dismissing an alternative.

**The Environmentally Preferred Alternative**

In accordance with DO-12, the NPS is required to identify the
"environmentally preferred alternative" in all environmental documents,
including EAs. According to CEQ guidelines, the environmentally
preferable alternative is the alternative that will promote the national
environmental policy as expressed in Section 101 of NEPA, which
considers:

1.  fulfilling the responsibilities of each generation as trustee of the
    environment for succeeding generations;

2.  assuring for all generations safe, healthful, productive, and
    esthetically and culturally pleasing surroundings;

3.  attaining the widest range of beneficial uses of the environment
    without degradation, risk of health or safety, or other undesirable
    and unintended consequences;

4.  preserving important historic, cultural and natural aspects of our
    national heritage and maintaining, wherever possible, an environment
    that supports diversity and variety of individual choice;

5.  achieving a balance between population and resource use that will
    permit high standards of living and a wide sharing of life's
    amenities; and

6.  enhancing the quality of renewable resources and approaching the
    maximum attainable recycling of depletable resources (NEPA, section
    101).

Describe what the environmentally preferred alternative is and identify
why it is the environmentally preferred alternative based on the above
criteria. Similarly, based on the above criteria, identify why the other
alternatives are not the environmentally preferred alternative. The
analysis should specifically compare and contrast each of the
alternatives (including no action) relative to how well each achieves
(or does not achieve) each of the 6 NEPA goals:

**Alternatives Comparison Table**

Include a table that compares and contrasts the alternatives, including
the degree to which each alternative accomplishes the purpose or
fulfills the need identified in the purpose and need section (*see
sample format below*).

+-----------------------+----------------------+----------------------+
| **COMPARATIVE SUMMARY |                      |                      |
| OF ALTERNATIVES**     |                      |                      |
+-----------------------+----------------------+----------------------+
| Alternative A-No      | Alternative          | Alternative C        |
| Action                | B-Preferred          |                      |
|                       | Alternative          |                      |
+-----------------------+----------------------+----------------------+
| ACTION: Describe      | ACTION: Describe     | ACTION: Describe     |
| Action                | Action               | Action               |
|                       |                      |                      |
| Meet Project Needs?   | Meet Project Needs?  | Meet Project Needs?  |
| TEXT. One or two      | TEXT. One or two     | TEXT. One or two     |
| sentences             | sentences            | sentences            |
+-----------------------+----------------------+----------------------+

# Summary of Environmental Consequences/Impact Comparison Matrix

# 

# Include a matrix or table of impacts for comparison purposes among the project alternatives, including no action (*see sample format below*). The matrix should present a concise summary of each alternative's potential effects by impact topic. Note that the environmental consequences summarized here should be the same as those identified in the Environmental Consequences section; consider repeating the conclusion statements from that section in this table. . 

  ------------------- ------------------ ----------------- ---------------
  **SUMMARY OF                                             
  ENVIRONMENTAL                                            
  CONSEQUENCES**                                           

  **Impact Topics**   **Alternative      **Alternative     **Alternative
                      A\--No Action**    B\--Preferred     C**
                                         Alternative**     

  Soils                                                    

  Vegetation                                               

  Water Quality                                            

  Archeological                                            
  Resources                                                

  Historic Structures                                      

  Visitor Experience                                       

  Park Operations                                          
  ------------------- ------------------ ----------------- ---------------

# AFFECTED ENVIRONMENT

# 

# Present information about the existing environment relevant to understanding the impact of the proposal, no action, and other alternatives. Note the topics addressed in the Affected Environment section will be the same as the impact topics identified earlier, and will be retained and analyzed in the Environmental Consequences section of the EA.

Identify references and other sources where detailed information on park
resources may be found (e.g., the park's master plan or general
management plan and the park's *Resources Management Plan)*.

Provide a summary of the resources associated with this project
consistent with the impact topics analyzed.

# ENVIRONMENTAL CONSEQUENCES

Describe the environmental consequences associated with the alternatives
including direct, indirect, and cumulative impacts. This section should
be focused on "real" environmental issues and be concise and clear.
Potential impacts should be described in terms of:

-   type (beneficial or adverse);

-   context (site-specific, local, or regional);

-   intensity (negligible, minor, moderate, or major);

-   duration (short or long-term); and

-   impairment (would or would not impair park resources and values).

> The context, duration, and intensity of impacts should be defined and
> quantified as much as possible.

**Methodology**

Describe the basis for the analysis and conclusions. Typically, this
includes review of existing literature and park studies; information
provided by experts within the park and other agencies; professional
judgments of park staff; consultation with the state historic
preservation officer and interested local Tribes; and public input. This
section also includes the framework for the impact analysis, including
key assumptions, parameters or measures of impact, and analytical
techniques or approaches (including modeling).

# Context. Context is the affected environment within which an impact would occur, such as local, park-wide, regional, global, affected interests, society as a whole, or any combination of these. Context is variable and depends on the circumstances involved with each impact topic. As such, the impact analysis determines the context, not visa versa.

# Impact intensity. Because definitions of intensity (negligible, minor, moderate, or major) vary by impact topic, intensity definitions should be provided separately for each impact topic analyzed. In all cases the intensity thresholds should have the following attributes;

-   They should measure intensity or "magnitude" in terms of at least
    two parameters (example: ability to detect, extent of disturbance,
    etc.).

-   They should form a graduated scale of intensity with fairly distinct
    transitional gradations between impact levels.

-   They should not use duration (short term, long term) to help
    determine the intensity.

-   They should reflect the nature of effects specific to the impact
    topic (example: vegetation impact thresholds should relate to
    characteristics of vegetation communities i.e. relative abundance,
    level of existing disturbance, sensitivity of communities, etc.).

-   To the extent possible they should allow for the quantification of
    both adverse and beneficial impacts.

-   They should match the impact parameters used in the analysis in the
    text.

# For examples of impact topic specific intensity thresholds or additional guidance, please contact the DSC technical representative. 

> **Duration.** Because duration of impact (short or long term) will
> also vary by impact topic, a description of duration should be
> provided separately for each impact topic. Depending on the resource,
> impacts may last as long as construction takes place, or a single year
> or growing season, or longer.
>
> **Direct and indirect impacts.** A direct impact is an effect that is
> caused by an action and occurs at the same time and place. An indirect
> impacts is an effect that is caused by an action but is later in time
> or farther removed in distance, but still reasonably foreseeable.
> Note: NPS policy requires that direct and indirect impacts be
> "considered." However, directness is not to be specifically labeled or
> identified as "direct/indirect" in any of the impact topics in the
> environmental consequences chapter. Do the analysis but do not say
> whether the impact is direct/indirect.
>
> **Cumulative effects.** NEPA regulations require an assessment of
> cumulative impacts in the decision‑making process for federal
> projects. Cumulative impacts are defined in 40 CFR 1508.7, and this
> definition should begin the methods section. Cumulative impacts may be
> analyzed and expressed in terms of x + y = z; with x being the impacts
> described as a result of actions being proposed under each
> alternative; y being impacts of *other* past, present, and reasonably
> foreseeable future actions; and z being the cumulative impact. Present
> the impacts of the *other* actions first (the 'y'), followed by a
> statement linking the impacts of the alternative (the 'x'), such as --
> "The impacts of the above actions, in combination with the impacts of
> alternative A, would result in minor long-term adverse **cumulative**
> impacts to wildlife." Analyses should also highlight the incremental
> contribution of the NPS alternative relative to the overall cumulative
> impact (compare x to z), Cumulative impacts are considered for all
> alternatives and are presented at the end of each impact topic
> discussion analysis.
>
> *Projects that make up the cumulative impact scenario.* Identify
> *other* projects or actions in the area with the potential to have
> impacts to the resource in question. Projects may be identified by the
> park or determined by meetings and phone calls with county and town
> govern­ments and state land managers. Potential projects identified as
> cumulative actions should include any planning or development activity
> that is currently being implemented or that would be implemented in
> the reasonably foreseeable future.
>
> Evaluate the impacts of these cumulative actions in conjunction with
> the impacts of each alternative to determine if they would have any
> additive effects on a particular natural resource, cultural resource,
> visitor use, or the socioeconomic environment. Because some of these
> cumulative actions may be in the early planning stages, the evaluation
> of cumulative effects may be based on a general description of the
> project. Name and briefly describe under separate headings past,
> present, and reasonably foreseeable future actions that could
> contribute to cumulative effects.
>
> More information on the analysis of cumulative impacts can be found in
> Enclosure C: *Cumulative Effects Analysis.*
>
> **Impairment of park resources or values**. In addition to determining
> the environmental consequences of the preferred and other
> alternatives, the 2001 NPS *Management Policie*s and DO-12, require
> analysis of potential effects to determine if actions would impair
> park resources and values. *Typically, impacts with the potential for
> impairment would be determined to be major, or occasionally moderate
> in intensity in NEPA impact analyses; impacts of a negligible to minor
> intensity would not have the potential for impairment.* The following
> background information is mandatory text that shall be incorporated
> into this section of the EA.
>
> The fundamental purpose of the National Park System, established by
> the Organic Act and reaffirmed by the General Authorities Act, as
> amended, begins with a mandate to conserve park resources and values.
> National Park Service managers must always seek ways to avoid or
> minimize to the greatest degree practicable adverse impacts on park
> and monument resources and values. However, the laws do give NPS
> management discretion to allow impacts to park resources and values
> when necessary and appropriate to fulfill the purposes of a park, as
> long as the impact does not constitute impairment of the affected
> resources and values. Although Congress has given NPS management
> discretion to allow certain impacts within parks, that discretion is
> limited by statutory requirement that the NPS must leave park
> resources and values unimpaired, unless a particular law directly and
> specifically provides otherwise.
>
> The prohibited impairment is an impact that, in the professional
> judgment of the responsible NPS manager, would harm the integrity of
> park resources or values, including opportunities that otherwise would
> be present for the enjoyment of those resources or values. An impact
> to any park resource or value may constitute impairment. However, an
> impact would more likely constitute impairment to the extent it
> affects a resource or value whose conservation is:

-   necessary to fulfill specific purposes identified in the
    establishing legislation or proclamation of the park;

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-   key to the natural or cultural integrity of the park or to
    opportunities for enjoyment of the park; or

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-   identified as a goal in the park's Master Plan or General Management
    Plan or other relevant NPS planning documents.

State that a determination on impairment is made in the conclusion
statement of the impact analysis of each alternative. The following is
recommended impairment statement language for impacts of a moderate to
major intensity:

Because there would be no major adverse impacts to a resource or value
whose conservation is 1) necessary to fulfill specific purposes
identified in the park's establishing legislation, 2) key to the natural
or cultural integrity of the park or to opportunities for enjoyment of
the park, or 3) identified as a goal in the park's general management
plan or other relevant NPS planning documents, there would be no
impairment of park resources or values related to \[IMPACT
TOPIC/RESOURCE\].

If the impact intensity is found to be negligible to minor, a simple
statement should be presented in the conclusion indicating that impacts
to this impact topic under this alternative would not result in
impairment. Note that the National Park Service does not analyze
Recreational Values/Visitor Experience (unless impacts are resource
based), Socioeconomic Values, or Park Operations for impairment.

For further guidance on impairment determinations, see Attachment B,
Enclosure D, *Impairment Guidance*.

**Impacts to Cultural Resources and Section 106 of the NHPA**

Provide an explanation of the Section 106 process and indicate how
compliance with Section 106 is being coordinated with the NEPA process
(per 36 CFR 800.8). If the NEPA process is being used to comply with
Section 106 requirements, contact the DSC technical representative for
guidance and recommended language to include in this EA.

**Impact Analysis**

Impact topics will be the same as those identified in the Impact Topics
section of the EA. For EAs shorter than 30-40 pages, many readers find
the impact section is more readable if it is organized by alternative,
with impact topics as subheadings. For EAs longer than this, the impact
section may be followed more easily if it is organized by impact topic,
with alternatives as subheadings. Either is acceptable. Impacts may also
be combined with affected environment information in an EA.

> The following sample format shows organization by alternative, with
> impact topics as subheadings:
>
> Alternative A
>
> Impact Topic
>
> Impact Topic Analysis
>
> Beneficial or adverse
>
> Intensity (negligible, minor, etc.)
>
> Duration (short term vs long term)
>
> Cumulative Impacts
>
> Projects/actions inside and outside the park that make up the
> cumulative impact scenario
>
> What the impacts of these other projects/actions are
>
> What the cumulative impacts of this alternative are, including
> duration (short/long term), beneficial or adverse, and intensity.
>
> Conclusion: Briefly summarize Impact Topic Analysis and Cumulative
> Impacts. Note the conclusion should not introduce any new information
> (i.e., information not previously included in the analysis). Include
> an impairment statement as described in methodology section, above.

**CONSULTATION AND COORDINATION**

This section should list persons, organizations and agencies that were
contacted for information and that assisted in identifying important
issues, developing alternatives, or analyzing impacts. This section
should also identify any future compliance needs, such as permits,
additional NEPA analysis, etc. Memoranda of agreement or understanding,
formal agreements, major cooperative agreements, or documentation for
final compliance with applicable laws or regulations should be
appendixes to the EA. Any scoping (internal and external) or public
involvement efforts should also be detailed, and a brief summary of
major issues should be included.

**LIST OF PREPARERS**

**REFERENCES**

Include a bibliography and a glossary of terms and acronyms.

**APPENDICES** (include as appropriate)

Memoranda of Agreement or Understanding, Cooperative Agreements, etc.

Statement of Findings (Wetlands and/or Floodplains)

Biological Assessment (USFWS Section 7 Consultation)

Scoping Letter(s)

Section 106 correspondence

Summary of comments or copies of written comment letters

Public Service Statement(s) and/or Press Release(s)

**Enclosure C**

**Cumulative Effects Analysis**

**[CEQ Regulations §1508.7 Cumulative Impact]{.underline}**

> Cumulative impact is the impact on the environment which results from
> the incremental impact of the action when added to other past,
> present, and reasonably foreseeable future actions regardless of what
> agency (Federal or non-Federal) or person undertakes such actions.
> Cumulative impacts can result from individually minor but collectively
> significant actions taking place over a period of time.

**[DO-12, Conservation Planning, Environmental Impact Analysis and
Decision Making]{.underline}**

> §4-5, G.6: Cumulative impact information may be less exact than
> information on direct and indirect impacts of the alternatives, but a
> good faith effort to accurately and completely assess major sources of
> impact and their contribution to resources affected by the proposed
> action or alternatives should be part of any EIS or EA. For plans or
> other larger-scope federal actions, the analysis of cumulative effect
> may be a major focus of the NEPA document.

**[Example]{.underline}**

If the park proposes to expand a campground in grizzly bear habitat,
other activities that have a combined impact on the grizzly bears must
be included in the analysis. This would include other NPS road projects
that would occur in grizzly bear habitat, as well as plans for future
garbage disposal in the park's gateway communities and last year's
Forest Service timber harvest. It doesn't matter who takes the actions,
or whether they took place in the past, are taking place in the present,
or will take place in the foreseeable future.

**[Cumulative Impacts = Additive and Interactive]{.underline}**

**Additive**. These impacts accumulate in the same way as a "straw on a
camel's back." Straws keep adding weight until, finally, the camel's
back is broken. One impact-causing occurrence, such as a single gas
well, may be of little significance. A hundred wells in the same area,
however, may profoundly impact a given valued resource.

**Interactive**. These impacts accrue as a result of assorted similar or
dissimilar actions being taken that tend to have similar impacts,
relevant to the valued resource in question. Vegetation quality,
diversity, density, and general health, for instance, could be affected
by several actions. These actions could include unmitigated over-grazing
by wildlife/wild horses/burros, cattle, plus motorcycle/off-road vehicle
use, industrial development, and roads.

**[How do I start?]{.underline}**

1.  Consider what the geographic area of influence should be for your
    affected resource. This area will differ from resource to resource.
    You might use regional watersheds, for example, or counties for
    economic effects.

2.  Assemble a list of other past, present, and reasonably foreseeable
    future actions called the "cumulative scenario." Be sure to include
    actions that might be taken by NPS or other agencies or individuals
    that could also affect resources in the area of influence.

3.  Work through the cumulative scenario and determine which actions are
    relevant to your impact topic. Focus on actions with impacts that
    are clear contributors.

4.  Develop the cumulative impact analysis. You may want to think of
    cumulative impacts as x + y = z (with x being the impacts you have
    described as a result of actions being proposed under each
    alternative; y being other past, present, and reasonably foreseeable
    future actions; and z being the cumulative impact).

5.  Determine the context and intensity or magnitude of the actions.
    Intensity refers to the severity of the effect. Use the same terms
    that you used for your impact analysis -- negligible, minor,
    moderate, and major.

6.  Describe the total impact for your topic. You should also highlight
    the relevant contributions of the NPS action proposed for the
    project or plan (compare x to z). For example, the NPS alternative's
    contribution x may be a relatively small part of the overall
    cumulative impact z.

7.  Where possible, use quantifiable data. Realize that your analysis
    may be mainly qualitative.

8.  When either x or y is zero, then there are no cumulative impacts
    (z=0).

**Enclosure D**

**Impairment Guidance**

**From Director's Order 12**

**4.7 Prohibition on Impairment**. In managing units of the national
park system, the Service may undertake actions that have both beneficial
and adverse impacts on park resources and values. However, by the
provisions of the laws governing the NPS, the Service is prohibited from
taking or authorizing any action that would, or is likely to, impair
park resources or values. In addition, under other environmental laws,
adverse impacts may be prohibited as well. Impacts that may constitute
an impairment of park resources or values will be evaluated and
described in impact analysis contained within environmental documents
produced by the Service.

**From NPS *Management Policies***

**1.4.3 The NPS Obligation to Conserve and Provide for Enjoyment of Park
Resources and Values**. The "fundamental purpose" of the national park
system, established by the Organic Act and reaffirmed by the General
Authorities Act, as amended, begins with a mandate to conserve park
resources and values. This mandate is independent of the separate
prohibition on impairment, and so applies all the time, even when there
is not risk that any park resources or values may be impaired. NPS
managers must always seek ways to avoid, or to minimize to the greatest
degree practicable, adverse impacts on park resources and values.
However, the laws do give the National Park Service the management
discretion to allow impacts to park resources and values when necessary
and appropriate to fulfill the purposes of a park, as long as the impact
does not constitute impairment of the affected resources and values....

**1.4.4 The Prohibition on Impairment of Park Resources and Values**.
While Congress has given the Service the management discretion to allow
certain impacts within parks, that discretion is limited by the
statutory requirement (enforceable by the federal courts) that the Park
Service must leave park resources and values unimpaired, unless a
particular law directly and specifically provides otherwise...

**1.4.5 What Constitutes Impairment of Park Resources and Values.** The
impairment

that is prohibited by the Organic Act and the General Authorities Act is
an impact that, in the professional judgment of the responsible NPS
manager, would harm the integrity of park resources or values, including
the opportunities that otherwise would be present for the enjoyment of
those resources or values. Whether an impact meets this definition
depends on the particular resources and values that would be affected;
the severity, duration, and timing of the impact; the direct and
indirect effects of the impact; and the cumulative effects of the impact
in question and other impacts.

An impact to any park resource or value may constitute an impairment. An
impact would be more likely to constitute an impairment to the extent it
affects a resource or value whose conservation is:

-   Necessary to fulfill specific purposes identified in the
    establishing legislation or proclamation of the park;

-   Key to the natural or cultural integrity of the park or to
    opportunities for enjoyment of the park; or

-   Identified as a goal in the park's general management plan or other
    relevant NPS planning documents.

An impact would be less likely to constitute an impairment to the extent
that it is an unavoidable result, which cannot reasonably be further
mitigated, of an action necessary to preserve or restore the integrity
of park resources or values.

Impairment may result from National Park Service activities in managing
the park, visitor activities, or activities undertaken by concessioners,
contractors, and others operating in the park. A determination on
impairment is made in the Environmental Consequences section for

each impact topic.

**1.4.6 What Constitutes Park Resources and Values.** The "park
resources and values"

that are subject to the no-impairment standard include:

-   The park's scenery, natural and historic objects, and wildlife, and
    the processes and conditions that sustain them, including, to the
    extent present in the park: the ecological, biological, and physical
    processes that created the park and continue to act upon it; scenic
    features; natural visibility, both in daytime and at night; natural
    landscapes; natural soundscapes and smells; water and air resources;
    soils; geo-logical resources; paleontological resources;
    archeological resources; cultural landscapes; ethnographic
    resources; historic and prehistoric sites, structures, and objects;
    museum collections; and native plants and animals;

-   Opportunities to experience enjoyment of the above resources, to the
    extent that can be done without impairing any of them;

-   The park's role in contributing to the national dignity, the high
    public value and integrity, and the superlative environmental
    quality of the national park system, and the benefit and inspiration
    provided to the American people by the national park system; and •
    Any additional attributes encompassed by the specific values and
    purposes for which it was established.

**1.4.7 Decision-making Requirements to Avoid Impairments.** Before
approving a proposed action that could lead to an impairment of park
resources and values, an NPS decision-maker must consider the impacts of
the proposed action and determine, in writing, that the activity will
not lead to an impairment of park resources and values. If there would
be an impairment, the action may not be approved.

In making a determination of whether there would be an impairment, a
National Park Service decision- maker must use his or her professional
judgment. The decision-maker must consider any environmental assessments
or environmental impact statements required by the National
Environmental Policy Act of 1969 (NEPA); relevant scientific studies,
and other sources of information; and public comments.

When an NPS decision-maker becomes aware that an ongoing activity might
have led or might be leading to an impairment of park resources or
values, he or she must investigate and determine if there is, or will
be, an impairment. Whenever practicable, such an investigation and
determination will be made as part of an appropriate park planning
process under-taken for other purposes. If it determined that there is,
or will be, such an impairment, the Director must take appropriate
action, to the extent possible within the Service's authorities and
available resources, to eliminate the impairment. The action must
eliminate the impairment as soon as reasonably possible, taking into
consideration the nature, duration, magnitude, and other characteristics
of the impacts to park resources and values, as well as the requirements
of NEPA, the Administrative Procedure Act, and other applicable law.

**8.1 (Use of the Parks) General.** Impacts may affect park resources or
values and still be within the limits of the discretionary authority
conferred by the Organic Act. However, adverse impacts are never welcome
in national parks, even when they fall far short of causing impairment.
For this reason, the Service will not knowingly authorize a park use
that would cause adverse impacts unless it has been fully evaluated,
appropriate public involvement has been obtained, and a compelling
management need is present. In those situations, the Service will ensure
that any adverse impacts are the minimum necessary, unavoidable, cannot
be further mitigated, and do not constitute impairment of park resources
and values.

**From the Director's Order 12 handbook, *Conservation Planning,
Environmental Impact Analysis and Decision Making***

**6.0 Decision Documents.** In both Findings of No Significant Impact
and Records of Decision, the National Park Service has a requirement of
affirmatively stating whether or not an impairment to park
resources--actions prohibited under the NPS Organic Act--will result
from any direct, indirect, or cumulative impact of the action to be
selected for implementation. If such an impairment does exist or is
likely, a Finding of No Significant Impact cannot be approved. If a
preferred alternative has impairment impacts at the EIS/ROD level, that
alternative may not be selected for implementation. Both FONSIs and RODs
need to provide information on general levels of impact and conclusions
as to degrees of impact and any potential for impairment. Both documents
must affirmatively state, and contain supporting information in the
analysis, that the preferred alternative for selection will not impair
park resources or values and, as a result, will not constitute a
violation of the NPS Organic Act. Actions that are likely to, or would,
cause an impairment may not use a memoto file or Categorical Exclusion
as an appropriate vehicle for decision making.

**What Does This Mean for the National Park Service?**

Impair is not a synonym for impact or effect. For us in NPS, impair has
a specific meaning, and is one of our levels of effect. Although most
NPS employees are beginning to have an understanding of impairment,
documents prepared by contractors should be carefully reviewed to ensure
the term is used properly.

**The first step** is to determine the context and intensity level of
the effect. Until you know whether or not you have a major adverse
effect, you cannot decide on impairment. However, not all major adverse
effects constitute impairment, although you should carefully determine
whether the major adverse effect is or is not impairment.

**Once you have identified context and intensity level of the effect**,
then you carefully apply the criteria from Management Policies to
determine if the adverse effect actually constitutes impairment. This
decision should not be made in a vacuum by only one resource expert, it
will take a team effort with resources experts and the park
decision-maker to make the impairment determination. You may need to
demonstrate how decisions were made on prioritization of resources.
(Gettysburg NP cyclorama building torn down, even though signficant,
because it was contributing to a more important cultural landscape
resource goal.)

**You should discuss whether or not an impact constitutes impairment**
topic by topic

in your NEPA document, according to DO-12. In the document, you should
show the logic/rationale the decision-maker used to make the impairment
determination. We make an impairment decision on each impact topic in
the conclusion statement. You must also say whether or not
implementation of each alternative would result in impairment of park

resources.

**You do not need to make impairment determinations** in the
socioeconomic and visitor use sections of the document. We don't need to
deal with impairment on socioeconomics because impairment relates back
to park values and purpose and socioeconomic effects would rarely fit
that test. According to the Organic Act language, you cannot impair
enjoyment the same way you could impair park resources/values. If we
allow enjoyment to deteriorate, we have a secondary consideration. We
have to keep them unimpaired to enjoy them.

Make an objective of your project/plan that alternatives will not lead
to an impairment (could be a reason to reject an alternative). This
means action alternatives should not result in impairment, although the
no-action alternative could indeed result in impairment.

Impairment is a very important term with significant ramifications. Some
have suggested it's so important that if we cannot correct an
impairment, we should reconsider a park's eligibility in the National
Park System. Although that is debatable, it does mean that we shouldn't
use the term lightly, for example, by claiming that we really need a
project to prevent impairment of park resources. We should only use the
term impairment after a thorough, documented review of impacts. If you
think you have impairment, you must call and talk to your regional
environmental coordinator. He/she is then required to consult with the
Washington Office about all impairment determinations.

**For more guidance, go to the Impairment web site at
www.nps.gov/protect.**

**Enclosure E**

**Sample FONSI**

**FINDING OF NO SIGNIFICANT IMPACT**

**Remodeling Interior of Visitor Center**

#### Aztec Ruins National Monument

At Aztec Ruins National Monument the National Park Service will remodel
a portion of the visitor center's interior, to more efficiently serve
the needs of visitors and staff by improving visitor flow, maximizing
the use of space to better provide more in-depth orientation and
information about the monument's primary interpretive themes, and
providing adequate office and work space for the monument's interpretive
staff. In addition, a new, larger capacity, electrical transformer will
be installed and a new underground electrical service will be extended
to the building to accommodate the remodel and correct electrical safety
problems.

Aztec Ruins National Monument's visitor center occupies part of the
historic home/office of Earl Morris, which was listed in the National
Register of Historic Places in 1996. Morris built the house in the far
southwest corner of the monument's present-day boundary during
1919-1920. Morris's former residence and subsequent additions currently
encompass the monument's visitor center, interpretive and resource
management staff offices, library, and museum.

Aztec Ruins National Monument averages about 58,000 visitors per year.
Because of the monument's small size, one of the principal visitor
activities is touring the visitor center/museum. Presently visitors
enter the south double doors of the visitor center and walk directly to
the visitor center information desk, to pay the entrance fee and receive
orientation. The L-shaped information desk supports two cash registers -
one for entrance fee receipts and the other for Southwest Parks and
Monuments Association (SPMA) sales.

On the west wall south of the fireplace is an exhibit case housing a
temporary exhibit on the yucca plant and its uses in artifacts. Along
the east wall are two seven-foot tall shelves housing books managed by
SPMA. The bookshelves and information desk with the two cash registers
are within six feet of each other. Visitors must pay entrance fees,
browse the book offerings, receive orientation, obtain information about
travel routes and area attractions, and purchase SPMA items within an
approximate 30 square foot space.

During high visitation, this area becomes very crowded and noisy,
impacting the service that the staff can offer the visitors. At times so
many visitors are crowded in the small area, the ranger operating the
information desk cannot see who has entered the front door so that
he/she can greet them properly and collect fees. Also, the space
available to offer a variety of SPMA educational materials is limited.
The book outlet and its offerings greatly assist monument staff in
providing interpretive materials relevant to the monument.

Two workstations are located within 10-feet of the information desk, in
a room west of the information desk, with no intervening wall to
separate working staff members from visitors at the information desk.
Monument staff find it difficult to conduct their work at their
workstations in such an intrusive and noisy atmosphere, much less hold
work-related conversations that should remain private from visitors.

In addition, conduits, and electrical outlets and fixtures are visible
throughout the lobby and adjacent offices, which cumulatively detract
from the historic appearance of the building's interior. Also, the
visitor center/museum is currently in violation of three electrical
safety codes, and a larger capacity electrical transformer and service
is needed both to bring the building's electrical system up to code and
to accommodate the proposed remodel.

The 1989 General Management Plan (GMP) for Aztec Ruins National Monument
indicated that the design of the visitor center's interior was
inadequate to efficiently serve the needs of visitors and the staff. The
GMP proposed remodeling the interior of the building to

-   improve visitor flow;

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-   provide more in-depth orientation and information;

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-   maximize the use of space to better present the monument's primary
    interpretive themes; and

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-   provide adequate office and work space for the monument's
    interpretive staff.

The visitor center remodel as described in the GMP, however, was
contingent upon an additional office building being built elsewhere to
both house the monument's museum collection and provide office space for
staff, thus freeing space in the visitor center. The office building has
not yet been funded, and it is unlikely to be funded in the near future.
To address the immediate problems that exist due to overcrowding and
inadequate office and work space, the monument proposes to proceed with
remodeling part of the visitor center's interior to better accommodate
visitors, interpretive and resource management staff, and educational
materials and sales items.

**PREFERRED ALTERNATIVE**

Under the preferred alternative, select interior spaces of the visitor
center/museum will be modified to improve visitor flow, maximize the use
of space to better present the monument's primary interpretive themes,
and provide adequate office and work space for the monument's
interpretive staff. The lobby will be remodeled and the information desk
enlarged and made fully accessible to all visitors and staff, in
conformance with the Architectural Barriers Act of 1968 (P.L. 90-480),
the Rehabilitation Act of 1973 (P.L. 93-112), and the 1984 Uniform
Federal Accessibility Standards (UFAS). Two cash registers will be
located at the desk, but workers using them will be separated by more
space. There will be more room for visitors to be served between the two
registers, such that they will not block the operation of them. A
workstation will be located at the information desk, so staff can take
advantage of slow times to work in that area.

A floor to ceiling, wood framed wall with a French door will be built
between the information desk and the nearby workstations, creating new
office space and reducing the amount of intrusive noise. The door will
match the existing door between offices 1 and 2. A similar French door
will also be added between the new sales area (now office #3) and the
office immediately north. In addition, a small casement window built
into the wall will enable a ranger working in the area west of the
information desk to quickly and unobtrusively assist and answer
questions by volunteers working at the information desk.

The non-historic wall, including the built in cabinets, bookcases and
exhibit case, that separates the entrance lobby and the office space to
the west will be removed to expand the lobby, as well as to provide
additional space for freestanding shelving to hold SPMA sales items. The
staff member currently using this space will be relocated to another
area of the building. In addition, the upper portion of the non-historic
wingwall on the north side of the fireplace will be removed to allow for
greater visibility into the sales area and lobby. A second French door
will be installed in the doorway of the wall between the reconfigured
SPMA sales area and the northwest office adjacent to the information
desk area.

An air conditioner located in the non-historic wood framed window of the
westernmost office will be removed. The non-historic, window will also
be removed and replaced with a six-light casement sash window, to
restore the window to its historic appearance.

Inconspicuous track lighting will be added in the sales and office areas
to improve poor lighting. The non-historic fluorescent light fixtures
hanging from the ceiling, a more recent addition to the building, will
be removed. The historic light fixtures now hanging in the front lobby
and office to the west will remain.

A new underground electrical service will be extended to the visitor
center/museum. A trench for the underground lines (about 18-inches wide,
42-inches deep, and 125 feet in length) will be hand dug from an
existing pole west of the visitor center/museum to the western wall of
the building. The trench will accommodate two, 2-inch PVC (polyvinyl
chloride) pipes, through which will run the electrical cables. The new
trench will be excavated in previously disturbed ground. The new trench
will parallel an existing utility trench and, for a short distance, a
stucco wall, whose foundation extends more than 3-feet below the ground
surface.

The two underground electrical lines will be buried to a depth of about
42-inches. All pipeline installation procedures, which primarily include
clearing, trenching, pipe preparation and assembly, and backfilling,
will be confined to the narrow, linear construction corridor, to
minimize soil compaction. Backfilling and compaction will begin
immediately after the pipe is placed into the trench. The narrow, linear
construction corridor will be restored to its pre-construction contour
and condition.

Excavation of the trench will follow guidelines approved by the staff of
Aztec Ruins National Monument, and an archeologist will monitor all
digging. These guidelines will be intended to minimize any potential
disturbance of unknown archeological resources. If during construction
previously undiscovered archeological resources are discovered, all work
in the immediate vicinity of the discovery will be halted until the
resources could be identified and documented and an appropriate
mitigation strategy developed, if necessary, in consultation with the
New Mexico State Historic Preservation Office. In the event that human
remains, funerary objects, sacred objects, or objects of cultural
patrimony are discovered during construction, provisions outlined in the
Native American Graves Protection and Repatriation Act (25 USC 3001) of
1990 will be followed. All significant archeological resources, as well
as human remains, funerary objects, sacred objects, or objects of
cultural patrimony, will be left *in situ* and the trench will be
rerouted to avoid further disturbance.

A small (2-feet high and 4-feet square) electrical transformer will be
installed on a cement pad adjacent to the west wall of the visitor
center/museum, which is out of sight of the public and inaccessible to
visitors. An electric service line from the transformer to the visitor
center/museum will enter the building through the basement.

The exterior of the transformer will be painted a flat, non-reflective
color that will blend in with the building and its natural surroundings,
to further minimize any visual obtrusiveness. The undersized transformer
that is presently located atop the power pole west of the visitor
center/museum, and which is visible from the monument's interpretive
trail, will be removed. An electric meter that is visible from the
interpretive trail will be relocated to the exterior of the building's
western wall, which is out of sight of visitors. Due to the installation
of a larger capacity transformer, an upright electrical panel about
50-feet south of the building, which is also visible from the
interpretive trail, will be greatly reduced in size and will resultantly
be less visually obtrusive.

Portions of the visitor center/museum's electrical system will be
rewired to meet current safety codes. Strip outlets now attached to the
wooden baseboards will be removed and replaced with recessed wall
outlets. Conduits containing electrical lines now on the wall surfaces
will be removed or embedded in the plastered walls and patched.
Extraneous phone jacks will be removed, along with associated wires. An
adequate number of phone jacks will be installed to serve all work
stations and the information desk. A fire hose on the south wall of the
office west of the information desk will be removed. Wires to the alarm
systems will be embedded in the plastered walls and concealed. In some
cases, the thermostats may be moved to less conspicuous locations.

All walls and finished surfaces exposed or damaged by demolition and
remodeling will be patched, repaired, and repainted to an off-white
color, which is the historical interior color of the building. The
entire visitor center will be recarpeted.

Staging and stockpiling for construction will only occur on the overflow
parking area or other previously disturbed lands.

**ALTERNATIVES CONSIDERED**

The environmental assessment analyzed the preferred alternative
described above and a no-action alternative. Under the no action
alternative the interior of the visitor center will not be remodeled. In
addition, electrical service to the visitor center will continue to be
inadequate and in violation of safety codes. The no action alternative
does not meet the project objectives of improving visitor flow,
maximizing the use of space to better present the monument's primary
interpretive themes, and providing adequate office and work space for
the monument's interpretive staff.

# ENVIRONMENTALLY PREFERRED ALTERNATIVE

The environmentally preferred alternative is determined by applying the
criteria suggested in the National Environmental Policy Act of 1969
(NEPA), which is guided by the Council on Environmental Quality (CEQ).
The CEQ provides direction that "\[t\]he environmentally preferable
alternative is the alternative that will promote the national
environmental policy as expressed in NEPA's Section 101:

-   fulfill the responsibilities of each generation as trustee of the
    environment for succeeding generations;

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-   assure for all generations safe, healthful, productive, and
    esthetically and culturally pleasing surroundings;

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-   attain the widest range of beneficial uses of the environment
    without degradation, risk of health or safety, or other undesirable
    and unintended consequences;

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-   preserve important historic, cultural and natural aspects of our
    national heritage and maintain, wherever possible, an environment
    that supports diversity and variety of individual choice;

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-   achieve a balance between population and resource use that will
    permit high standards of living and a wide sharing of life's
    amenities; and

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-   enhance the quality of renewable resources and approach the maximum
    attainable recycling of depletable resources.

The no action alternative will have no impact upon the National Register
of Historic Places listed Aztec Ruins Administration Building-Museum,
which fulfills the fourth goal of NEPA's Section 101 (*preserve
important historic, cultural and natural aspects of our national
heritage...*) to a greater degree than the preferred alternative.
However, because reconfiguration of the historic structure's interior
spaces will be done without harming those qualities for which the
structure is eligible to be listed in the national register, and
excavation of the trench for underground electrical service will neither
affect known archeological resources nor alter the topography,
vegetation, circulation features, spatial organization, or land use
patterns of the monument's cultural landscape, both the preferred and no
action alternatives fulfill the first goal (*fulfill the
responsibilities of each generation as trustee of the environment for
succeeding generations*).

By improving visitor flow in the administration building-museum and
providing adequate office and work space for the monument's staff, as
well as maximizing the use of space in the visitor center to better
present the monument's primary interpretive themes, the preferred
alternative furthers to a greater degree than the no action alternative
the conditions prescribed in goals two, three and five (*assure for all
generations safe, healthful, productive, and esthetically and culturally
pleasing surroundings;* *attain the widest range of beneficial uses of
the environment without degradation, risk of health or safety, or other
undesirable and unintended consequences;* and *achieve a balance between
population and resource use that will permit high standards of living
and a wide sharing of life's amenities*).

The National Park Service determined that the preferred alternative is
the environmentally preferred alternative. The no action alternative
fulfills the fourth goal of NEPA's Section 101 to a greater degree than
does the preferred alternative and both the no action and preferred
alternatives fulfill the first goal. The preferred alternative, however,
best achieves the conditions prescribed under goals two, three, and five
(the sixth goal is not applicable to this project). Therefore, because
the preferred alternative both protects the national register listed
administration building-museum while providing the widest range of
beneficial uses of the structure, i.e. integrates resource protection
with opportunities for an appropriate range of visitor and monument
staff uses, the preferred alternative is the environmentally preferred
alternative.

**WHY THE PREFERRED ALTERNATIVE WILL NOT HAVE A SIGNIFICANT EFFECT ON
THE HUMAN ENVIRONMENT**

As defined in 40 CFR §1508.27, significance is determined by examining
the following criteria:

***Impacts that may have both beneficial and adverse aspects and which
on balance may be beneficial, but that may still have significant
adverse impacts which require analysis in an EIS***: No major adverse or
beneficial impacts were identified that would require analysis in an
environmental impact statement. No impacts to geology and topography;
prime and unique farmland; air quality; water resources; biotic
communities; threatened, endangered and candidate species and species of
special concern; ethnographic resources, or cultural landscapes;
soundscape or lightscape management; environmental justice; or the
monument's socioeconomic environment were identified for the preferred
alternative. Construction related impacts to soils will be adverse, but
minor and short-term. Impacts to archeological resources and the
historic structure will not be adverse. Adverse, construction related
impacts to visitor use and experience and monument operations will be
short-term and minor in intensity. Beneficial impacts to visitor use and
experience and monument operations will be long-term and moderate in
intensity.

***Degree of effect on public health or safety***: During construction,
traffic flow and vehicle access to the visitor center parking area,
where staging and stockpiling will occur, may be temporarily restricted.
Construction vehicles, equipment, or material will not be stored outside
the boundaries of the identified staging and stockpiling area without
prior approval of monument staff. Impacts will be adverse, but minor and
short-term, lasting only as long as construction.

The visitor center will remain open during construction, but visitors
touring the visitor center during construction could be inconvenienced
and experience delays in service. For example, during demolition
sections of the visitor center could be temporarily cordoned off with
ceiling to wall plastic to control dust. All efforts will be made to
reduce any inconveniences for visitors as much as possible, but some
visitors inconvenienced by construction activities could be frustrated
and may consider any inconveniences or delays interminable. However,
construction will occur during Aztec Ruins National Monument's
off-season when visitation is lower. Overall such impacts will be
adverse, but minor and short-term, and will not be expected to
appreciably affect either the number of visitors to the monument or
their average length of stay.

Construction activities would also introduce temporary visual, audible,
and atmospheric intrusions into the setting of Aztec Ruins National
Monument. Such intrusions could reduce the quality of the visitor
experience during the construction period. Impacts will be adverse but
construction related only, short-term, and minor.

***Unique characteristics of the geographic area such as proximity to
historic or cultural resources, park lands, prime farmlands, wetlands,
wild and scenic rivers, or ecologically critical areas***: As described
in the environmental assessment, prime farmlands, wetlands, wild and
scenic rivers, and ecologically critical areas will not be affected.

American Indian tribes traditionally associated with the lands of Aztec
Ruins National Monument, and others with whom monument staff regularly
consult, are concerned about ground disturbance at the monument and the
potential discovery of human remains, funerary objects, sacred objects,
or objects of cultural patrimony. Excavating a trench for installation
of the underground electrical service line will occur on land previously
disturbed by past construction activities associated with Earl Morris's
residency and later National Park Service administration of the site,
including the previous installation of underground utilities. Although
inadvertent discoveries are unlikely, in the event that human remains,
funerary objects, sacred objects, or objects of cultural patrimony are
discovered during construction, provisions outlined in the Native
American Graves Protection and Repatriation Act (25 USC 3001) of 1990
would be followed. All items would be left *in situ* and the trench
would be rerouted to avoid further disturbance. Because it is very
unlikely that ethnographic resources would be affected, and because
appropriate steps would be taken to protect any human remains, funerary
objects, sacred objects, or objects of cultural patrimony inadvertently
discovered, ethnographic resources will not be affected by
implementation of the preferred alternative.

Implementation of the preferred alternative will not alter the
topography, vegetation, circulation features, spatial organization, or
land use patterns of the monument's cultural landscape, and any adverse
impacts associated with installation of the transformer will be
long-term but negligible. In addition, any visual, audible, and
atmospheric intrusions associated with construction will be temporary
and negligible, lasting only as long as construction.

Because trenching would occur in previously disturbed ground, no known
archeological resources will be impacted. In the event significant
archeological resources are discovered during construction, the
resources would be left in situ and avoided by rerouting the trench.
Overall, impacts to the historic structure (the National Register of
Historic Places listed Aztec Ruins Administration Building-Museum),
including cumulative impacts, would be beneficial, long-term, and range
in intensity from minor to moderate. After applying the Advisory Council
on Historic Preservation's criteria of adverse effects (36 CFR Part
800.5, *Assessment of Adverse Effects*), the National Park Service
concluded that implementation of the preferred alternative will have *no
adverse effect* on either the archeological resources of Aztec Ruins
National Monument or the Aztec Ruins Administration Building-Museum.

***Degree to which effects on the quality of the human environment are
likely to be highly controversial***: There were no highly controversial
effects identified during either preparation of the environmental
assessment or the public review period.

***Degree to which the possible effects on the quality of the human
environment are highly uncertain or involve unique or unknown risks***:
There were no highly uncertain, unique or unknown risks identified
during either preparation of the environmental assessment or the public
review period.

***Degree to which the action may establish a precedent for future
actions with significant effects or represents a decision in principle
about a future consideration*:** The preferred alternative neither
establishes a National Park Service precedent for future actions with
significant effects nor represents a decision in principle about a
future consideration.

***Whether the action is related to other actions with individually
insignificant but cumulatively significant impacts***: Impacts of the
preferred alternative identified in the environmental assessment were to
soils, archeological resources, the historic structure, visitor use and
experience, and monument operations. As described in the environmental
assessment, cumulative impacts were determined by combining the impacts
of the preferred alternative - remodeling the interior of the visitor
center - with other past, present, and reasonably foreseeable future
actions. No reasonably foreseeable future development is anticipated for
the visitor center, but the monument does anticipate relocating Ruins
Road, the access road to Aztec Ruins National Monument, as well as
erecting boundary fencing and improving the monument's irrigation
system.

Because significant archeological resources, if discovered, would be
avoided during implementation of the preferred alternative, the
preferred alternative would not be anticipated to contribute to the
cumulative impacts of other past and reasonably foreseeable future
actions on archeological resources. The minor to moderate
construction-related adverse impacts of the preferred alternative, in
conjunction with the adverse impacts of other reasonably foreseeable
future actions, would result in adverse cumulative impacts to soils, the
historic structure, visitor use and experience, and monument operations
ranging in intensity from negligible to minor, depending upon both the
scope of the potential actions and the location. However, the adverse
impacts of the preferred alternative would be a relatively minor
component of the overall cumulative impact, due to the limited scope of
the preferred alternative.

The minor to moderate beneficial impacts that implementation of the
preferred alternative would have on visitor use and experience and park
operations, in conjunction with the beneficial impacts of other
reasonably foreseeable future actions, could result in net beneficial
cumulative impacts ranging in intensity from minor to moderate.

***Degree to which the action may adversely affect districts, sites,
highways, structures, or objects listed on National Register of Historic
Places or may cause loss or destruction of significant scientific,
cultural, or historical resources***: As described in the environmental
assessment, a number of long-term, minor, adverse and beneficial impacts
to the National Register of Historic Places listed Aztec Ruins
Administration Building-Museum will occur as result of implementing the
preferred alternative. Compliance with Section 106 of the National
Historic Preservation Act was completed through the consultations with
the staff of the New Mexico State Historic Preservation Officer (SHPO)
and their review of the environmental assessment. The SHPO concurred
that the preferred alternative will have *no adverse effect* on the
Aztec Ruins Administration Building-Museum (Elmo Baca, New Mexico State
Historic Preservation Officer. Letter to Stephanie Dubois,
Superintendent, Aztec Ruins National Monument. 18 February 2002).

***Degree to which the action may adversely affect an endangered or
threatened species or its critical habitat***: As described in the
environmental assessment, no threatened, endangered and candidate
species and species of special concern potentially found San Juan County
are known to inhabit Aztec Ruins National Monument or the general
vicinity. Listed bird species (Southwestern willow flycatcher, Mexican
spotted owl, bald and golden eagles, ferruginous hawk, and mountain
plover) range over large areas of the region and are potential
transients in the monument, but there are no known nesting sites in the
monument and monument lands are not vital for foraging and roosting.
Construction related noise could potentially disturb transient bird
species but such adverse impacts would be temporary, lasting only as
long as construction, and negligible, because suitable habitat for
transient birds is found throughout the region. There is no critical
habitat in Aztec Ruins National Monument or the general vicinity.

***Whether the action threatens a violation of federal, state, or local
environmental protection law***: The preferred alternative violates no
federal, state, or local environmental protection laws.

**IMPAIRMENT OF PARK RESOURCES OR VALUES**

In addition to reviewing the list of significance criteria, Aztec Ruins
National Monument determined that implementation of the preferred
alternative will not constitute an impairment of the monument's
resources and values. This conclusion is based on a thorough analysis of
the impacts described in the environmental assessment, the agency and
public comments received, and the professional judgement of the
decision-maker in accordance with the National Park Service's
*Management Policies, 2001* (December 27, 2000). As described in the
environmental assessment, implementation of the preferred alternative
will not result in major, adverse impacts to a resource or value whose
conservation is (1) necessary to fulfill specific purposes identified in
the establishing legislation or proclamation of Aztec Ruins National
Monument; (2) key to the natural or cultural integrity of the monument;
or (3) identified as a goal in the monument's general management plan or
other relevant National Park Service planning documents.

**PUBLIC INVOLVEMENT**

The environmental assessment was made available for public review and
comment during a 30-day period ending February 15, 2002. Two responses
were received. The office of the New Mexico State Historic Preservation
Officer (SHPO) concurred that the preferred alternative will have *no
adverse effect* on the Aztec Ruins Administration Building-Museum (Elmo
Baca, New Mexico State Historic Preservation Officer. Letter to
Stephanie Dubois, Superintendent, Aztec Ruins National Monument. 18
February 2002). The Mescalero Apache Tribe stated that the preferred
alternative "...will not affect any objects, sites, or locations
important to our traditional culture or religion" (Donna Stern-McFadden,
Tribal Historic Preservation Officer, Mescalero Apache Tribe. Letter to
Stephanie Dubois, Superintendent, Aztec Ruins National Monument. 20
February 2002).

**CONCLUSION**

The preferred alternative does not constitute an action that normally
requires preparation of an environmental impact statement (EIS). The
preferred alternative will not have a significant effect on the human
environment. Negative environmental impacts that could occur are minor
or moderate in intensity. There are no significant impacts on public
health, public safety, threatened or endangered species, historic
properties either listed in or eligible for listing in the National
Register of Historic Places, or other unique characteristics of the
region. No highly uncertain or controversial impacts, unique or unknown
risks, significant cumulative effects, or elements of precedence were
identified. Implementation of the action will not violate any federal,
state, or local environmental protection law.

Based on the foregoing, it has been determined that an EIS is not
required for this project and thus will not be prepared.

**Recommended:**
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Stephanie Dubois Date

Superintendent, Aztec Ruins National Monument

**Approved:**
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Karen P. Wade Date

Director, Intermountain Region