Considering Cumulative Effects Under the National Environmental Policy Act Page: 1
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INTRODUCTION TO CUMULATIVE EFFECTS
ANALYSISEvidence is increasing that the most deva-
stating environmental effects may result not
from the direct effects of a particular action, but
from the combination of individually minor
effects of multiple actions over time.
Some authorities contend that most envir-
onmental effects can be seen as cumulative
because almost all systems have already been
modified, even degraded, by humans. According
to the report of the National Performance
Review (1994), the heavily modified condition of
the San Francisco Bay estuary is a result of
activities regulated by a wide variety of govern-
ment agencies. The report notes that one mile
of the delta of the San Francisco Bay may be
affected by the decisions of more than 400
agencies (federal, state, and local). William
Odum (1982) succinctly described environ-
mental degradation from cumulative effects as
"the tyranny of small decisions."
The Council on Environmental Quality's
(CEQ) regulations for implementing the
National Environmental Policy Act (NEPA)
define cumulative effects as
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
other actions (40 CFR 1508.7).The fact that the human environment continues
to change in unintended and unwanted ways in
spite of improved federal decisionmaking
resulting from the implementation of NEPA is
largely attributable to this incremental
(cumulative) impact. Although past environ-
mental impact analyses have focused primarily
on project-specific impacts, NEPA provides the
context and carries the mandate to analyze the
cumulative effects of federal actions.
NEPA and CEQ's regulations define the
cumulative problem in the context of the action,
alternatives, and effects. By definition, cumu-
lative effects must be evaluated along with the
direct effects and indirect effects (those that
occur later in time or farther removed in
distance) of each alternative. The range of
alternatives considered must include the no-
action alternative as a baseline against which
to evaluate cumulative effects. The range of
actions that must be considered includes not
only the project proposal but all connected and
similar actions that could contribute to cumu-
lative effects. Specifically, NEPA requires that
all related actions be addressed in the same
analysis. For example, the expansion of an air-
port runway that will increase the number of
passengers traveling must address not only the
effects of the runway itself, but also the expan-
sion of the terminal and the extension of
roadways to provide access to the expanded
terminal. If there are similar actions planned
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Council on Environmental Quality (U.S.). Considering Cumulative Effects Under the National Environmental Policy Act, text, January 1997; Washington D.C.. (https://digital.library.unt.edu/ark:/67531/metadc31126/m1/10/: accessed April 23, 2024), University of North Texas Libraries, UNT Digital Library, https://digital.library.unt.edu; .