Cumulative Impacts

1. Cumulative Impacts

2. What is a cumulative impact ? CEQ Regulations at 40 CFR 1508.7 define cumulative 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 . . .”

3. Why look beyond your project? To determine if your proposed action will result in a significant impact when coupled with other past, current or future projects.

4. Requirements CEQ regulations require: • Consideration of cumulative, connected, similar and independent actions • Focus on past, present, future actions • Federal and non-Federal actions • Focus on each affected resource individually • Address additive, countervailing and synergistic effects • Look beyond the life of the action

5. Key concepts • Connected actions – “ . . .closely related actions that : (a) automatically trigger other actions which may require environmental impact statements; (b) cannot or will not proceed unless other actions are taken previously or simultaneously; or (c) are interdependent parts of a larger action and depend on the larger action for their justification.” (1050.1E, paragraph 500c) • Past actions – Often limited by availability of usable data, best mined through successful agency scoping • Present actions – Include FAA, other Federal, and non-Federal (including non-government) actions within the geographic area and timeframe. Non-Federal actions sometimes hampered by confidentiality. • Reasonably foreseeable actions – “. . .developed with enough specificity to provide meaningful information . . .” and that would affect the resources affected by the FAA action and occur in the same timeframe (5050.4B, paragraph 9q)

6. PHL Regional Study Area

7. Airport development actions Geographic area established by resource category on a project-by-project basis Geographic Boundaries to Consider Air Quality Metropolitan area, air-shed, global atmosphere Water Quality Stream, watershed, river basin, estuary, aquifer Fish Stream, river basin, estuary, spawning area, migration route Wildlife Breeding grounds, migration route, wintering areas, range Plants Watershed, forest, range, ecosystem Land Use Community, metropolitan area, county, state, region Historic Neighborhood, community, city, state, tribal territory, district _____________________________________________________________________ (Considering Cumulative Effects under the National Environmental Policy Act – CEQ)

8. Studies Beyond Regional Area

9. Airport development actions Time frames established by resource category on a project-by project basis • How far back? • In theory, duration of impacts should guide this decision • In practice, lack of data often limits this analysis, often resulting in a qualitative analysis • Data sources include previous NEPA documents, permit applications, and comprehensive scoping with agencies, other stakeholders and public • What is reasonably foreseeable? • On-going construction (duh) • Subject of current (or recent) NEPA process or other regulatory action by a federal, state, local or Tribal agency • Federal or non-Federal action that has been designed and/or funded • Would occur within the time frame of the proposed action • Would affect at least on environmental resource that the proposed action would affect

10. Airport development actions What types of Federal and non-Federal actions need to be considered in cumulative analysis? • Public infrastructure – transportation and other govt. facilities, runway strengthening to accommodate A380, DOD facilities • Private infrastructure – commercial/office/retail/residential development, suburban expansion, private recreational facilities • Changes in Federal operations or operations requiring Federal approval – introduction of new jet service, transit expansion (rail spur to airport), military operations • Other agency actions- forest management, etc.

11. Consultation Scoping can be the most valuable source of information about past, current and reasonably foreseeable actions. Consult with: • Federal, state and local cooperating and other agencies • Tribal resources • MPO • Academic and institutional sources • NGOs • Individuals

12. Determining effects • FAA Orders and guidance does not establish significance thresholds for cumulative impacts • Thresholds for cumulative significance are based on thresholds for individual environmental resource category significance thresholds, but refined to reflect project-specific context • Some principles & approaches for determining cumulative significance thresholds: • Document baseline- what would happen to the resource without the action? • Will the action degrade the ability of the resource to sustain itself? • Develop a ‘big picture’ perspective to identify cause/effect relationships between the proposed action, other past/current/reasonably foreseeable actions and resources (matrix)

13. Determining effects • Baseline set in geographic and temporal context for resources commonly affected by the proposed action (and/or its alternatives) and other past, current and reasonably foreseeable projects • Quantitative or qualitative analysis? Depends on availability and accuracy of data • Cumulative effect on sustainability or resources, ecosystems, or human communities • Mitigation for cumulative effects – Focus on measures to reduce cumulative impacts to affected resources • Consult with resource agencies and others early and often

14. Affects of Airspace Redesign on CEP

15. CEQ, EPA and FAA Guidance • CEQ – Considering Cumulative Effects under the National Environmental Policy Act (January 1997), 40 CFR 1508.7 • EPA – Consideration of Cumulative Impacts in EPA Review of NEPA Documents (May 1999), EPA 315-R-99-002 • FAA – 1050.1E & 5050.4B, Desktop Reference