7 Tips on How to Review an Environmental Impact Statement
We understand the struggle of reading through Environmental Impact Statements (EIS), which are usually hundreds if not thousands of pages long. Here are 7 helpful tips on disecting these important documents:
- Learn how the project is broken up into different parts.
Whether its a wind farm or a cement plant and limestone mine, projects that trigger an EIS review typically have several components. Laying out each moving part will help you navigate the permitting structure.
2. Learn the hierarchy of the EIS.
In our wind farm example, there is a huge wind project currently making its way through the EIS process. The Draft EIS has an 84 page summary. Start there. The full EIS is broken up into five “volumes.” Each volume contains many chapters, or appendices. Generally, each chapter covers one broad topic. There are different chapters on agriculture, air and climate change, electrical environment, environmental justice, geology, soils & minerals, groundwater, health & safety, historic and cultural resources, land use, noise, recreation, socioeconomics, special status species, surface water, transportation, vegetation, visual resources, wetlands, floodplains, & riparian, wildlife, fish, & aquatics and cumulative impacts. Recognize that if the Department of Energy wrote on a topic, that does not necessarily mean that the Plains and Eastern Clean Line Project will cause irreversible harm regarding that particular topic; instead, recognize that the DOE evaluated the topic, and that you’ll need to read a particular section to see the analysis.
3. Focus on the impacts.
Portions of the beginning of each chapter contain substantial amounts of background information. As the information is presented, minimalistic analysis is provided with a lot of qualifiers (“may”, “could” and “potential” are good qualifying terms). But the actual “impact statement” tends to be towards the end of each chapter under a subheading, “Impacts to…”. The impacts are then further analyzed between “Unavoidable and Adverse Impacts” and “Irreversible and Irretrievable” resources lost.
4. Get help.
If you read at a rate of 1 page per 2 minutes, it’d take about 33.3 hours of nonstop reading to complete a 1,000 page document. That’s almost your entire work-week! The document itself can be extremely technical and includes discussions on seismic hazards, stream water quality, race and poverty, sound levels, socioeconomics and a whole host of other issues and topics in fine detail. Even if a person were to read the full document, chances are that one person is not an expert on all the topics covered, and the amount of time necessary to become an expert would likely surpass the comment period deadline. Recognize that you’re unlikely to read the full document without some help.
5. Focus on issues that you either have an expertise in, or are most interested in.
Not everyone is interested in the number of jobs the project could create, or the types of soil in the project right of way, or even what electromagnetic fields are. To quickly find what you are looking for, first use the tables of content, then open up a chapter and use the “search” or “find” function in your PDF viewer. This is a simple trick that evidently some 90 percent of internet users haven’t ever heard of.
6. Keep a list of terms and acronyms handy.
Back to our wind farm example, here are a few acronyms: EPMs, BMPs, HDVC…The Glossary is Chapter 7, and it alone is 20 pages long.
7. When writing your comments, make the regulator’s job easy.
There are two ways to help out regulators, like the Department of Energy (DOE). The first way is to completely ignore the EIS and write whatever you want. Asking a lot of questions and making unsubstantiated claims will make it a lot easier for the DOE to dismiss your comments. The second and preferred way to help the DOE is by thoroughly reading (a portion of) the EIS, cite specific portions of it, and providing credible research. Do your and their homework.