Environmental Impact Report/Environmental Impact Statement Annotated Outline

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Environmental Impact Report/Environmental Impact Statement Annotated Outline

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Chapter 2 – Project Alternatives

Project Description

Writing the Document

1. Consider providing a brief paragraph telling the reader the purpose of this section. For example:

This section describes the proposed action and the design alternatives that were developed by a multi-disciplinary team to achieve the project purpose and need while avoiding or minimizing environmental impacts. The alternatives are Alternative “X,” Alternative “Y,” and the “No-Build Alternative.”

2. Provide a very brief restatement of the description of the existing facility and the purpose and need for project. For example:

The project is located in ABC County on Route ## from west of Route ## South (PM 5.00) to east of the River Causeway near Highway ## (PM 7.3). The project covers a distance of 2.1 miles. Within the limits of the proposed project, Route ## is a conventional two lane undivided highway with two 12 foot lanes, and 2 to 4 foot non-standard shoulders. The purpose of the project is to upgrade the highway to current design standards to improve safety and correct operational problems incurred as a result of the traffic queues formed by slow moving vehicles.



Outline of Alternatives Section

1. Project Alternatives

a. Build Alternatives. This would include a range of reasonable alternatives (see heading below) that could meet the purpose and need of the project. Once a preferred alternative has been identified it should be listed prior to the other alternatives under consideration.

i. Common Design Features of the Build Alternatives

ii. Unique Features of Build Alternatives. Use separate subheadings for each build alternative

iii. Include TSM and Mass Transit alternatives:

  • TSM Alternative (usually only relevant in urban areas over 200,000 population)

  • Mass Transit Alternative (To be considered on all proposed major highway projects in urban areas over 200,000 population)

b. No Build (No Action) Alternative. The "no build" analysis must discuss the existing conditions as well as what would be reasonably expected to occur in the foreseeable future if the project was not approved.

2. Comparison of Alternatives

3. Identification of a Preferred Alternative (include in the final document)

4. Alternatives Considered but Eliminated from Further Discussion (for final document, change section title to Alternatives Considered but Eliminated from Further Discussion Prior to Draft EIR/EIS)

Range of Alternatives

An EIR/EIS will include a range of reasonable alternatives. Alternatives may be developed to avoid resources such as wetlands, floodplains, Section 4(f) properties, endangered species, cultural sites or to be consistent with federal, state and departmental directives such as DD-64 for Non-motorized travel. If no alternatives are developed to avoid impacts on floodplains or wetlands, then an only practicable alternative finding must be made for these resources. The document should include a reference to the appropriate section where further discussion can be found on wetlands, floodplains, Section 4(f) properties, endangered species, etc., as applicable.


1. An EIR requires a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project, and an evaluation of the comparative merits of the alternatives (CEQA Guidelines Section 15126).

2. The range of alternatives is governed by the “rule of reason” that requires that the EIR set forth only those alternatives that lead to a more informed decision. The range of alternatives shall be selected and discussed in a manner that fosters meaningful public participation and informed decision-making.

3. An alternative location should be considered when developing alternatives. If no feasible alternative locations exist, then the EIR must disclose reasoning why.


1. CEQ’s regulations for implementing NEPA specify requirements for treatment of alternatives in Environmental Impact Statements. All reasonable alternatives must be rigorously explored and objectively evaluated. For alternatives that were eliminated from detailed study, briefly discuss reasons for their elimination. Devote substantial treatment to each alternative considered in detail. Include reasonable alternatives not within the jurisdiction of the lead agency, and include the alternative of no action. Identify the agency's preferred alternative (PA) or alternatives, if one or more exists, in the draft statement and identify such alternative in the final statement unless another law prohibits the expression of such a preference. Include appropriate mitigation measures not already included in the proposed action or alternatives.

    2. FHWA Technical Advisory T6640.8A requires a discussion of a reasonable range of alternatives. Under NEPA, alternatives must be discussed in equal detail. However, SAFETEA-LU Section 6002 allows the PA to be developed to a greater level of detail to assist in the development of mitigation measures and compliance with other federal environmental laws provided that all the requirements in the 6002 final guidance are met. Also under NEPA, consideration should be given to transportation system management (TSM), transportation demand management (TDM) and multi-modal alternatives. For additional information, see Standard Environmental Reference, Chapter 32, “Environmental Impact Statements (EIS)” and CEQ 40 Facts, 1a, Range of Alternatives.

3. Additional alternatives may be required on projects where a law, Executive Order, or regulation (e.g., Section 4(f), Executive Order 11990, or Executive Order 11988) mandates an evaluation of avoidance alternatives.

Writing the Document

Project Alternatives

1. Include an introductory paragraph that briefly discusses the criteria used for alternative evaluation. Major features used for comparison may include project cost, level of service and other traffic data, and specific environmental impacts.

Common Design Features of the Build Alternatives

1. This heading should be used when the build alternatives share many common features. Shared design features (i.e., park-and-ride facilities, ramp metering, interchanges, etc.) discussed here do not have to be repeated under each alternative description.

2. Include design exceptions, new or revised access, and status of their approval in this discussion.

Unique Features of Build Alternatives

For each alternative:

1. Discuss utility relocations, designated optional borrow/fill sites, staging areas, proposed access, etc.

2. Describe the rationale for inclusion of the alternative in the document.

3. Make sure the names of the various alternatives are distinct and will not be easily confused with each other by the public or decision makers. Keep the names of the alternatives consistent throughout the document.

4. Make sure the project description and description of alternatives in the environmental document, (Draft) Project Report and technical studies match.

5. Include a map or maps showing the details of the build alternative(s). Other graphics such as typical cross sections and typical profiles should also be included, especially when needed to illustrate variations in the alternatives.

Transportation System Management (TSM) and Transportation Demand Management (TDM) Alternatives

Include a discussion of viable Transportation System Management (TSM) and Transportation Demand Management (TDM) alternatives.

1. TSM strategies consist of actions that increase the efficiency of existing facilities; they are actions that increase the number of vehicle trips a facility can carry without increasing the number of through lanes. Examples of TSM strategies include: ramp metering, auxiliary lanes, turning lanes, reversible lanes and traffic signal coordination. TSM also encourages automobile, public and private transit, ridesharing programs, and bicycle and pedestrian improvements as elements of a unified urban transportation system. Modal alternatives integrate multiple forms of transportation modes, such as pedestrian, bicycle, automobile, rail, and transit.

2. If applicable, add a boilerplate paragraph for one common conclusion: Although Transportation System Management measures alone could not satisfy the purpose and need of the project, the following Transportation System Management measures have been incorporated into the Build Alternatives for this project: [list items here].

3. TDM focuses on regional strategies for reducing the number of vehicle trips and vehicle miles traveled as well as increasing vehicle occupancy. It facilitates higher vehicle occupancy or reduces traffic congestion by expanding the traveler's transportation choice in terms of travel method, travel time, travel route, travel costs, and the quality and convenience of the travel experience. Typical activity within this component is providing contract funds to regional agencies that are actively promoting ridesharing, maintaining rideshare databases and providing limited rideshare services to employers and individuals.

No Build (No Action) Alternative

1. Environmental review must consider the effects of not implementing the proposed project. The no-build alternative provides a baseline for comparing the impacts with the other alternatives. Explain the effects of the no-build alternative. Effects could be tied to the purpose and need for the project, and might include deteriorating level of service, impacts to air quality, and ongoing maintenance costs. Indirect impacts might include economic impacts to an adjacent community. The no-build alternative may result in cumulative impacts if several smaller fixes are implemented in a piecemeal fashion.

Comparison of Alternatives

1. As a supplement to the discussion, a summary table comparing the alternatives is advisable but not mandatory. The discussion and table should focus on the criteria used for evaluation. The text should explain how the criteria were developed and how the criteria will be or has been used to reach a decision. Include the no-build alternative in the comparison discussion.

2. When a proposed Preferred Alternative (PA) has been identified at the Draft EIR/EIS stage, it must be disclosed (see suggested wording below). Explain in some detail why the Department identified that alternative as the PA. Suggested introductory language for the PA discussion in a draft EIR/EIS:

After comparing and weighing the benefits and impacts of all of the feasible alternatives, [Include as appropriate: some of which are summarized in the summary table], the project development team has identified Alternative [X] as the preferred alternative, subject to public review. Final identification of a preferred alternative will occur subsequent to the public review and comment period.

Note: For larger or more complex projects, the PA is not typically identified until after the circulation of the draft environmental document.

3. If local governments or organizations have voiced a preference for a particular alternative, state that preference and label that alternative the “Locally Preferred Alternative.” The identification of a “Locally Preferred Alternative” is required if the project is a Federal Transit Agency (FTA) project. If there is any opposition to the project or any of its alternatives, include that information here.

4. Briefly explain the final decision-making process. See sample text below.

After the public circulation period, all comments will be considered, and the Department will select a preferred alternative and make the final determination of the project’s effect on the environment. In accordance with CEQA, the Department will certify that the project complies with CEQA, prepare findings for all significant impacts identified, prepare a Statement of Overriding Considerations for impacts that will not be mitigated below a level of significance, and certify that the findings and Statement of Overriding Considerations have been considered prior to project approval. The Department will then file a Notice of Determination with the State Clearinghouse that will identify whether the project will have significant impacts, mitigation measures were included as conditions of project approval, findings were made, and a Statement of Overriding Considerations was adopted. With respect to the NEPA, the Department, as assigned by FHWA, will document and explain its decision regarding the selected alternative, project impacts, and mitigation measures in a Record of Decision in accordance with NEPA.

The above text should be eliminated or revised to past tense for the final document.

Identification of a Preferred Alternative

1. Explain the rationale for identifying the preferred alternative. The identification decision must be structured, analytical, and clearly address the specific evaluation criteria developed for the project. It must ensure that the preferred alternative meets the need and purpose for the project (See Project Development Procedures Manual, Chapter 12, Section 2).

2. Where more than one alternative is equally suitable, the Final environmental document can be structured to present such options.

Alternatives Considered but Eliminated from Further Discussion

1. This section should include all alternatives that were considered during the project development process but were eliminated before the draft environmental document. Alternatives that were considered in the draft environmental document should not be placed in this section; they remain viable alternatives. The Department may have identified some of these alternatives, while other alternatives may have been identified by other public agencies or members of the public. Information on alternatives considered but eliminated from further discussion can be found in the environmental and design project files, as well as the project initiation document and other planning documents. This section provides an opportunity to explain to those outside of the project development team why alternatives were not considered further. In addition, the section provides documented reasoning why alternatives identified in early planning documents are not to be carried for future consideration. Keep in mind the following when writing this section.

a. Briefly describe the other alternatives that were considered and explain why each was eliminated from further discussion. Note: Consider using the criteria for alternative selection as the basis of this discussion.

b. CEQA provides three factors that may be used to eliminate an alternative from detailed consideration in an EIR. They are (i) failure to meet most of the basic project objectives, (ii) infeasibility (see CEQA Guidelines section 15126.6(f)(1)), or (iii) inability to avoid significant environmental impacts. For further information on factors used to eliminate alternatives see Chapter 36 of the SER under the subheading “Narrowing the Range of Alternatives: Feasibility and Other Concerns.”

c. For projects where Transportation System Management (TSM), Transportation Demand Management (TDM) and modal alternatives might be considered reasonable alternatives at first glance but are not being considered as viable alternatives in the environmental document, include a brief discussion that they were considered but eliminated and explain why.

Permits and Approvals Needed

1. List all permits and approvals that will be needed, including waters and wetland permits, threatened and endangered species approvals (biological opinions, determinations), freeway agreements, etc. Also, give the status of each approval as in the following example.

The following permits, reviews, and approvals would be required for project construction:




United States Fish and Wildlife Service

Section 7 Consultation for Threatened and Endangered Species

Review and Comment on 404 Permit

Non-jeopardy Biological Opinion issued on November 18, 2007. USFWS has actively participated in NEPA/404 process.

United States Army Corps of Engineers

Section 404 Permit for filling or dredging waters of the United States.

Concurrence on the LEDPA as part of NEPA/404 received on August 28, 2007. Application for Section 404 permit anticipated after final ED distribution.

California Department of Fish and Game

1602 Agreement for Streambed Alteration

Section 2080.1 Agreement for Threatened and Endangered Species

Application for 1602 permit submitted on July 28, 2006. Section 2080.1 agreement received on August 28, 2007.

California Water Resources Board

Water Discharge Permit

Section 401 permit applied for on May 31, 2006.

County of San Diego, City of Chula Vista, City of San Diego

Freeway Agreement

Freeway agreement will be finalized after the route adoption by the CTC.

EIR/EIS Annotated Outline April 2008

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